Rule 56.1. Review of Decision on the Basis of Administrative Record.

     (a) Standards. Rule 56(a)–(b) apply.

     (b) Procedures.

     (1) The moving or cross-moving party shall file, together with its motion, a separate document entitled Statement of Facts setting forth the facts necessary to resolve the issues presented on review. This document shall contain concise, separately numbered paragraphs setting forth all of the facts upon which the party bases its motion and which are supported by the record. Each paragraph shall contain citations to the opposing party’s pleadings or to documentary evidence in the record.

     (2) The opposing party shall file, together with its cross-motion, a separate document entitled Counter-Statement of Facts. This document shall respond, by reference to specific paragraph numbers, to those statements of facts with which the party disagrees. The party shall state the precise nature of its disagreement and give its version of the events supported by record citations. The opposing party may also file Proposed Additional Facts as to any relevant matters not covered by the moving party’s statement to which the movant shall respond.