(d) Joint Statement of Material Facts

Within thirty (30) days after the answer or a certificate of completion is filed, whichever is later, the plaintiff shall serve on the defendant a proposed joint statement of material facts.  This statement shall be in narrative form, contain record citations, summarize all procedural developments, and describe all facts pertinent to the resolution of the case.  Within fourteen (14) days after the proposed joint statement of material facts is filed, the defendant shall inform the plaintiff of any proposed additions or deletions to the joint statement.  Within fourteen (14) days of receipt of the defendant’s proposed additions and deletions, the plaintiff shall file a joint statement of material facts containing all agreed-upon facts and record citations.  If any material facts remain in dispute, the parties shall each file a list of disputed facts including record citations within fourteen (14) days after the joint statement of material facts is filed by the plaintiff.