7056-1 MOTIONS FOR SUMMARY JUDGMENT

7056-1 Motions for Summary Judgment or Summary Adjudication

(a) Motions for Summary Judgment or Summary Adjudication. Each motion for
summary judgment or summary adjudication shall be accompanied by a “Statement of Undisputed Facts” which shall enumerate discretely each of the specific material facts relied upon in support of the motion and cite the particular portions of any pleading, affidavit, deposition, interrogatory answer, admission or other document relied upon to establish that fact. The moving party shall be responsible for the filing with the court of all evidentiary documents cited in the moving papers.
(b) Opposition. Any party opposing a motion for summary judgment or summary
adjudication shall reproduce the itemized facts in the Statement of Undisputed Facts and admit those facts which are undisputed and deny those which are disputed, including with each denial a citation to the particular portions of any pleading, affidavit, deposition, interrogatory answer, admission or other document relied upon in support of that denial. The opposing party may also file a concise “Statement of Disputed Facts,” and the source thereof in the record, of all additional material facts
as to which there is a genuine issue precluding summary judgment or adjudication. The opposing party shall be responsible for the filing with the Court of all evidentiary documents cited in the opposing papers. If a need for discovery is asserted as a basis for denial of the motion, the party opposing the motion shall provide a specification of the particular facts on which discovery is to be had or the issues on which discovery is necessary.
(c) Stipulated Facts. All parties-in-interest may jointly file a stipulation setting forth a
statement of stipulated facts to which all parties-in-interest agree. As to any stipulated facts, the parties so stipulating may state that their stipulations are entered into only for the purposes of the motion for summary judgment and are not intended to be otherwise binding.
(d) Summary Adjudication. This Rule shall apply to motions for orders specifying
material facts that appear without substantial controversy pursuant to FRCivP 56(d), except that the proposed “Statement of Undisputed Facts” and the “Statement of Disputed Facts” shall be limited to the facts which the moving party asserts are without substantial controversy and the facts the opposing party contends are in dispute.
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