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Case 18-2868, Document 284, 08/09/2019, 2628244, Page35 of 38 Salahuddin v. Goord, 467 F.3d 263, 272-73 (2d Cir. 2006). If the movant makes this showing in either manner, the burden shifts to the nonmovant to identify record evidence creating a genuine issue of material fact. Jd. at 273. Local Civil Rule 56.1(a) carries out this summary-judgment procedure by requiring the summary-judgment movant to set forth “material facts as to which she contends there is no genuine issue to be tried.” Subsection (b) of the rule requires the party opposing summary judgment to set forth a “statement of additional material facts as to which it is contended that there exists a genuine issue to be tried” (emphasis supplied). Ms. Maxwell has moved for summary judgment; plaintiff has not. As movant, Ms. Maxwell is required under Local Civil Rule 56.1 to enumerate the facts she is asserting as undisputed; as the party opposing summary judgment, plaintiff is permitted—if she can—to introduce admissible evidence creating a genuine issue of material fact. See Fed. R. Civ. P. 56(c)(1). Plaintiff is confused. Plaintiff believes she—the party opposing summary judgment— must enumerate facts she is asserting as undisputed, and so she has submitted her own Rule 56.1 statement of “undisputed facts.” That gets the summary-judgment procedure exactly backwards. Plaintiff s “undisputed facts” are irrelevant. Plaintiff cannot avoid summary judgment by proposing “undisputed facts”; she may only do so by creating a genuine issue of material fact as to Ms. Maxwell’s statement of undisputed facts. Accordingly, this Court should strike plaintiffs statement of “undisputed facts.” Although Ms. Maxwell as the summary-judgment movant has no duty to respond to plaintiff's alleged “undisputed facts,” we hasten to add that Ms. Maxwell in fact opposes and disputes most of plaintiffs alleged “undisputed facts.” For example, Defendant’s Undisputed 34