Summary Judgment

(a) Every motion for summary judgment shall be accompanied by a separate, short and concise statement of the material facts as to which the moving party contends there is no genuine issue to be tried. (b) A party opposing a motion for summary judgment shall file with its opposition a separate, short and concise statement of the material facts as to which it contends a genuine issue exists for trial. The party opposing the motion is deemed to have admitted all material facts set forth in the moving party's statement, unless it controverts them as required by this Local Rule. 51 7065-1 Injunctions (a) An application for a temporary restraining order or a preliminary injunction shall be made in a motion separate from the complaint.

(b) An application for a temporary restraining order shall be accompanied by a certificate of the applicant's attorney, or by an affidavit, stating that: (1) (2) the applicant has given the adverse party's attorney, if known, or the adverse party, actual notice of the time of making the application, and copies of all pleadings and other papers filed in the proceeding and to be presented to the court at the hearing; or the applicant has been unable to give actual notice as described in Local Rule 7065-1(b)(1), and describing in detail the applicant's efforts to give notice of the application and furnish to the adverse party copies of all pleadings and other papers filed in the proceeding or to be presented to the court at the hearing; (c) Upon filing the motion for temporary restraining order, the applicant shall submit a proposed form of restraining order pursuant to Local Rule 9013-5. 52 Part IX