Statements of Material Facts on Motion for Summary

Judgment

(a) Unless the court orders otherwise, on motion or on its own, any motion for

summary judgment under Fed. R. Civ. P. 56 must be accompanied by a separate,

short, and concise statement, in numbered paragraphs, of the material facts as to

which the moving party contends there is no genuine issue to be tried. Failure to

submit such a statement may constitute grounds for denial of the motion. This rule

does not apply to claims brought under the Administrative Procedure Act or the

Freedom of Information Act.

(b) The papers opposing a motion for summary judgment must include a

correspondingly numbered paragraph admitting or denying, and otherwise

responding to, each numbered paragraph in the statement of the moving party,

and if necessary, additional paragraphs containing a separate, short and concise

statement of additional material facts as to which it is contended that there exists a

genuine issue to be tried.

(c) Each numbered paragraph in the statement of material facts set forth in the

statement required to be served by the moving party will be deemed to be

admitted for purposes of the motion unless specifically denied and controverted

by a correspondingly numbered paragraph in the statement required to be served

by the opposing party.

(d) Each statement by the movant or opponent under Rule 56.1(a) and (b), including

each statement denying and controverting any statement of material fact, must be

followed by citation to evidence that would be admissible and set forth as required

by Fed. R. Civ. P. 56(c).

(e)

In any case where all parties are represented by counsel, any party moving for

summary judgment must provide all other parties with an electronic copy, in a

standard word processing format, of the moving party’s Statement of Material

Facts. In any case where all parties are represented by counsel, the

counterstatement required by this rule must include each entry in the moving

party’s statement and set out the opposing party’s response directly beneath it.

For relevant historical context for this local rule, consult the Appendix of Committee Notes.

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Joint Local Rules, S.D.N.Y. and E.D.N.Y. Effective January 2, 2026