GA-ND — Summary Judgment

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.