(a) Form of Motion.
(1) The movant for summary judgment shall attach to the motion a separate and concise statement of the material facts, numbered separately, as to which the movant contends no genuine issue exists to be tried. Statements in the form of issues or legal conclusions (rather than material facts) will not be considered by the Bankruptcy Court. Affidavits and the introductory portions of briefs do not constitute a statement of material facts.
(2) The respondent to a motion for summary judgment shall attach to the response a separate and concise statement of material facts, numbered separately, as to which the respondent contends a genuine issue exists to be tried. Response should be made to each of the movant's numbered material facts. All material facts contained in the moving party's statement that are not specifically controverted in respondent's statement shall be deemed admitted. The response that a party has insufficient knowledge to admit or deny is not an acceptable response unless the party has complied with the provisions of Rule 56(f) of the Federal Rules of Civil Procedure.
(3) All documents and other record materials relied upon by a party moving for or opposing a motion for summary judgment shall be clearly identified for the Bankruptcy Court. Where appropriate, dates and specific page numbers shall be given.
(b) Time. Motions for summary judgment shall be filed as soon as possible, but, unless otherwise ordered by the Bankruptcy Court, not later than 21 days after the close of discovery, as established by the expiration of the original or extended discovery period or by written notice of all counsel, filed with the Bankruptcy Court, indicating that discovery was completed earlier.
(c) A motion for summary judgment will be decided without a hearing unless the Bankruptcy Court directs otherwise.