Local Rule 7056-1: Summary Judgment
Bankr. M.D. Tenn. — General rule
7056-1 Summary Judgment
(a) Statement of Undisputed Facts. To assist the court in ascertaining whether there are material facts in dispute, any motion for summary judgment made pursuant to FED. R. BANKR. P. 7056 shall be accompanied by a separate, concise statement of the material facts which the moving party contends are not disputed. Each fact shall be stated in a separate, numbered paragraph. Each fact shall be supported by specific citation to the record. After each paragraph, the word "response" shall be inserted, and a blank space shall be provided reasonably calculated to enable the nonmoving party to respond to the assertion that the fact is undisputed.
(b) Response to Statement of Facts. 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. 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. Such response shall be filed with the papers in opposition to the motion for summary judgment. In addition, the non-movant's response may contain a concise statement of any additional facts that the non-movant contends are material and disputed. 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.
(c) Reply Statement. If the non-moving party has asserted additional facts, the moving party shall respond to these additional facts by filing a reply statement in the same manner and form as specified in sections (a) and (b) above. The reply of the moving party shall be filed within 14 days of the filing of the response of the non-moving party.