M.D. Tenn. LR 56.01

(a) Generally. Motions for summary judgment must be filed in accordance with the

provisions of Fed. R. Civ. P. 56, with the following additional requirements.

(b) Memorandum of Law. The movant must file a memorandum of law as a separate docket

entry using the “Memorandum in Support” event in CM/ECF. The memorandum must not

be uploaded as an attachment or exhibit to the motion. The memorandum shall not exceed

twenty-five (25) pages without leave of Court.

(c) Statement of Undisputed Material Facts.

(1) The movant must file a concise, non-argumentative statement of the alleged undisputed

material facts (not legal conclusions, arguments, or characterizations) that the movant

contends supports summary judgment. The statement must be docketed separately

using the “Statement of Facts” event in CM/ECF.

(2) Each individual material fact must be numbered separately and must be supported by a

citation to materials permitted by Fed R. Civ. P. 56(c)(1).

(3) The purpose of the statement of undisputed material facts is to identify for the Court

those facts that the movant contends require judgment as a matter of law. Legal

arguments, including as to materiality, must be made in the supporting memorandum,

not in the statement of undisputed material facts.

(4) A copy of the statement of undisputed material facts must also be provided to opposing

counsel in an editable electronic format.

(d) Response to Motion. Unless otherwise ordered by the Court, the respondent must respond

to the motion for summary judgment within twenty-one (21) days of service of the motion

with a memorandum of law that shall not exceed twenty-five (25) pages without leave of

Court.

(e) Response to Statement of Facts. The respondent must also respond to the movant’s

statement of undisputed material facts in a separately filed response. The response must be

docketed separately using the “Response to Statement of Facts” event in CM/ECF.

(1) The response to the statement of undisputed material facts must contain individually

numbered, concise, non-argumentative responses corresponding to each of the

movant’s numbered undisputed material facts by (A) agreeing that the fact is

undisputed; (B) agreeing that the fact is undisputed for purposes of summary judgment

only; or, (C) disputing the fact on any basis permitted by Fed. R. Civ. P. 56(c).

(2) Each numbered response must start with “Undisputed,” “Undisputed for Summary

Judgment Purposes Only,” or “Disputed”.

(3) If the respondent disputes a fact, the evidentiary citations supporting the respondent’s

position must be limited to evidence specific to that particular fact.

(4) The respondent may state that a fact is not material, but stating that a fact is not material

shall not excuse the respondent from stating whether the fact is disputed or undisputed.

(5) Legal arguments, including as to materiality of any fact, must be made in the

responding memorandum, not in the response to the statement of undisputed material

facts.

(f) Reply. Unless otherwise ordered by the Court, the movant may file an optional reply

within fourteen (14) days of service of the response. The reply shall not exceed five (5)

pages without leave of Court.

(g) Failure to Respond. If a timely response to a moving party’s statement of material facts

is not filed within the time periods provided by these rules, the asserted facts shall be

deemed undisputed for purposes of summary judgment.

(h) Cases with Pro Se Parties. The provisions of this rule, including the requirement that a

statement of undisputed material facts must be filed with any motion for summary

judgment, apply in cases with a pro se party. However, pro se parties are excused from

providing a copy of the statement of undisputed material facts to opposing counsel in an

editable electronic format.