E.D. Wash. LCivR 56

(a) through (b) [Reserved]

(c) Procedures.

(1) Supporting Factual Positions.

(A) Motion. A party filing a motion for summary judgment must separately file a

“Statement of Material Facts Not in Dispute” which shall specify the undisputed

material facts relied upon to support the motion. The material facts shall be set

forth in serial, numbered fashion, not in narrative form. As to each fact, the

statement shall cite to the specific page or paragraph of the record where the fact

is found (e.g., affidavit p. 3, deposition p. 3, line 6, etc.).

The specific portions of the record relied upon shall accompany the statement of

material facts, unless already part of the record, in which case a citation in the

format “ECF No. __ at __” shall be provided.

(B) Response. A party filing an opposition to a motion for summary judgment

must separately file a “Statement of Disputed Material Facts” which shall specify

the disputed material facts precluding summary judgment. The statement of

disputed material facts shall be set forth in serial fashion, not in narrative form,

and shall reference the moving party’s asserted, numbered fact. As to each

disputed fact, the statement shall cite to the specific page or paragraph of the

record where the disputed fact is found (e.g., affidavit p. 3, deposition ¶ 4, etc.).

The specific portions of the record relied upon shall accompany the statement of

disputed material facts, unless already part of the record, in which case a citation

in the format “ECF No. __ at __” shall be provided. The opposing party shall

also briefly describe any evidentiary objection to the moving party’s asserted fact.

(C) Reply. The moving party filing a reply memorandum must separately file a

“Reply Statement of Material Facts Not in Dispute” which shall specify the

opposing party’s disputed facts that the moving party contends are not in genuine

dispute. The reply statement of material facts not in dispute shall be set forth in

serial fashion, not in narrative form, and shall reference the opposing party’s

disputed, numbered fact. As to each disputed fact, the statement shall cite to the

specific page or paragraph of the record where the disputed fact is found (e.g.,

affidavit p. 3, deposition ¶ 4, etc.). The specific portions of the record relied upon

shall accompany the statement of disputed material facts, unless already part of

the record, in which case a citation in the format “ECF No. __ at __” shall be

provided. The moving party shall also briefly describe any evidentiary objection

to the opposing party’s asserted fact. The moving party may also briefly describe

any evidentiary basis countering the opposing party’s evidentiary objections.

(2) through (4) [Reserved]

(d) [Reserved]

(e) Failing to Properly Support or Address a Fact.

The Court may consider a fact undisputed and admitted unless controverted by the procedures set

forth in LCivR 56(c).

(f) through (h) [Reserved]

(i) Inapplicability to Administrative Record Review Cases.

The procedures described in LCivR 56(c)(1) do not apply to administrative record review cases,

including Social Security benefits cases.