Northern District of Georgia Local Rules — The Practitioner's Guide

GA-ND requires a Statement of Material Facts on summary judgment with paragraph-by-paragraph response. Facts cited only to pleadings will not be considered. GA-ND is a district 56.1 framework jurisdiction.

Movant's filing (LR 56.1(B)(1))

A separate, concise, numbered statement of the material facts to which the movant contends there is no genuine issue. Each material fact must be:

• Numbered separately.
• Supported by a citation to evidence proving the fact.

The Court will not consider any fact: (a) not supported by an evidence citation; (b) supported by a citation to a pleading rather than evidence; (c) stated as an issue or legal conclusion; or (d) set out only in the brief and not in the movant's statement.

Opposing party's filing (LR 56.1(B)(2))

• A response to the movant's statement of undisputed facts, with individually numbered, concise, nonargumentative responses corresponding to each of the movant's numbered facts.
• The Court deems each of the movant's facts admitted unless the respondent: (i) directly refutes with concise responses supported by specific evidence citations; (ii) states a valid objection to admissibility; or (iii) points out that the movant's citation does not support the fact, or that the fact is not material, or otherwise has failed to comply with LR 56.1(B)(1).
• A statement of additional facts which the respondent contends are material and present a genuine issue for trial.

For the trap on the SMF framework, see Watchpoints #5.

For the rule, see the N.D. Ga. Civil Local Rules.

GA-ND requires in-person conferral for early-case settlement and case-management discussions; meet-and-confer for discovery motions per LR 37.1. GA-ND is a discovery-only meet-and-confer scope district with live conferral.

Mechanics

• Settlement conferral (LR 16 region): *'All parties are required to confer in person in an effort to settle the case, discuss [other matters].'*
• Discovery motion conferral (LR 37.1): Required before motions to compel.
• In-person conference among lead counsel: Specifically required for case-management discussion under LR 16.

For the trap on in-person settlement conferral, see Watchpoints #4.

GA-ND has a structured discovery framework anchored in early-case planning via the Joint Preliminary Report.

Mechanics

• Joint Preliminary Report and Discovery Plan (LR 16.2): Required early in the case. Drives the case schedule.
• Discovery materials filing (LR 26.3): Not generally required; selective filing for motions, trial, appeal.
• Motions to compel (LR 37.1): Require conferral certification.
• No district-wide trigger-event deadline.

For the trap on the Joint Preliminary Report, see Watchpoints #8.

GA-ND uses district-uniform page limits set by LR 7.1(D). The court may decline to consider briefs that fail to conform.

Mechanics

• Brief in support or in response to a motion (LR 7.1(D)): 25 pages, absent prior permission of the Court.
• Reply brief (LR 7.1(D)): 15 pages.
• Effect of noncompliance (LR 7.1(F)): *'The Court, in its discretion, may decline to consider any motion or brief that fails to conform to the requirements of these rules.'*
• Type and font certification (LR 7.1(D)): At the end of the brief, counsel must certify that the brief uses an approved font/point selection per LR 5.1(B) (or, if typewritten, does not contain more than 10 characters per inch).

For the rule, see the N.D. Ga. Civil Local Rules.