E.D. Va. Local Civil Rule 56

(A) Summary Judgment – Time of Filing: The time provisions of Fed. R. Civ. P. 56(b) shall not apply

in this District. No motion for summary judgment shall be considered unless it is filed and set for hearing

or submitted on briefs within a reasonable time before the date of trial, thus permitting a reasonable time

for the Court to hear arguments and consider the merits after completion of the briefing schedule specified

in Local Civil Rule 7(F)(1).

(B) Summary Judgment – Listing Of Undisputed Facts: Each brief in support of a motion for

summary judgment shall include a specifically captioned section listing all material facts as to which the

moving party contends there is no genuine issue and citing the parts of the record relied on to support the

listed facts as alleged to be undisputed. A brief in response to such a motion shall include a specifically

captioned section listing all material facts as to which it is contended that there exists a genuine issue

necessary to be litigated and citing the parts of the record relied on to support the facts alleged to be in

dispute. In determining a motion for summary judgment, the Court may assume that facts identified by

the moving party in its listing of material facts are admitted, unless such a fact is controverted in the

statement of genuine issues filed in opposition to the motion.

(C) Summary Judgment – Separate Motions: Unless permitted by leave of Court, a party shall not file

separate motions for summary judgment addressing separate grounds for summary judgment.