W.D. Tenn. LR 56.1

(a) Moving Party. In order to assist the Court in ascertaining whether there are any

material facts in dispute, any motion for summary judgment made pursuant to Fed. R.

Civ. P. 56 shall be accompanied by a separate, concise statement of the material facts

as to which the moving party contends there is no genuine issue for trial. Each fact

shall be set forth in a separate, numbered paragraph. Each fact shall be supported by

specific citation to the record. If the movant contends that the opponent of the motion

cannot produce evidence to create a genuine issue of material fact, the proponent shall

affix to the memorandum copies of the precise portions of the record relied upon as

evidence of this assertion.

Memoranda in support of a motion for summary judgment shall not exceed 20

pages without prior Court approval. The separate statement of material facts shall

not exceed 10 pages without prior Court approval.

(b) Non-moving Party. Any party opposing the motion for summary judgment must

respond to each fact set forth by the movant by either:

(1) agreeing that the fact is undisputed;

(2) agreeing that the fact is undisputed for the purpose of ruling on the motion for

summary judgment only; or

(3) demonstrating that the fact is disputed.

Each disputed fact must be supported by specific citation to the record. Such response

shall be filed with any memorandum in response to the motion. The response must be

made on the document provided by the movant or on another document in which the

non-movant has reproduced the facts and citations verbatim as set forth by the

movant. In either case, the non-movant must make a response to each fact set forth

by the movant immediately below each fact set forth by the movant. In addition, the

non-movant’s response may contain a concise statement of any additional facts that

the non-movant contends are material and as to which the non-movant contends there

exists a genuine issue to be tried. Each such disputed fact shall be set forth in a

separate, numbered paragraph with specific citations to the record supporting the

contention that such fact is in dispute.

Memoranda in opposition to motions for summary judgment shall not exceed 20 pages

without prior Court approval. A non-movant’s statement of additional facts shall not

exceed 5 pages without prior Court approval.

A party opposing a motion for summary judgment must file a response within 28 days

after the motion is served or a responsive pleading is due, whichever is later.

(c) Reply by Moving Party. Leave of Court is not required to file a reply to a response to

a motion for summary judgment. Replies must be filed within 14 days after the

response is served. Without prior Court approval, a reply by a moving party shall not

exceed 7 pages. If the non-moving party has asserted additional facts, the moving

party shall respond to these additional facts by filing a separate reply statement in the

same manner and form as specified in section (b) above.

(d) Failure to respond to a moving party’s statement of material facts, or a non-moving

party’s statement of additional facts, within the time periods provided by these rules

shall indicate that the asserted facts are not disputed for purposes of summary

judgment.

(e) Objections to Rule 56 Evidence. Objections to evidentiary materials offered in support

of or in opposition to motions for summary judgment shall be included within a timely

response or reply memorandum, shall be separately designated as a specific evidentiary

objection, and shall identify the Rule of Evidence or other authority that establishes

inadmissibility of the proffered evidence. If any objection to evidentiary materials is

raised for the first time in the reply memorandum, the party opposing such objection(s),

within 7 days of service of such reply memorandum, may file a sur-reply of not more

than 4 pages that only responds to the evidentiary objection(s) raised in the reply

memorandum.