surrounding the presentation of evidence to the grand jury and the disclosure of grand jury testimony to a key prosecution witness.” Order (Aug. 5, 2003). 4 .The plaintiff submitted this statement of material facts pursuant to Local Rule 7.1(h), now Rule 7(h). “Rule 7.1(h) requires a party moving for summary judgment to provide a statement identifying the undisputed facts that entitle it to judgment as a matter of law, and directs the nonmoving party to respond with a statement listing the facts 'as to which it is contended there exists a genuine issue necessary to be litigated.’ ” Waterhouse v. District of Columbia, 298 F.3d 989, 991 n. 2 (D.C.Cir. 2002) (quoting LCvR 7.1(h)). 5 . See, e.g., King v. Tecumseh Public Schools, 229 F.3d 1152, 2000 WL 1256899, *3 (6th Cir.2000) (Table) (<HOLDING>); Moody v. Town of Weymouth, 805 F.2d 30, 31
holding that general allegations of a need for additional discovery will not suffice the person presenting such a claim must show what discovery has been obtained why it is inadequate and the what additional information he expects to obtain from additional discovery holding that plaintiffs right to argue a need for discovery prior to the entry of summary judgment was preserved since plaintiff moved to vacate summary judgment ten days later and included precisely the discovery needed and not generalized statements of necessary discovery holding that it was within the trial courts discretion to refuse any additional discovery and that the courts refusal to allow additional discovery was not an abuse of discretion recognizing that while summary judgment is improper if the nonmovant is not afforded a sufficient opportunity for discovery it is the nonmovants responsibility to inform the district court of the need for discovery by filing an affidavit pursuant to rule 56f of the federal rules of civil procedure or filing a motion requesting additional discovery holding that entry of summary judgment while a motion for additional discovery was pending should be construed as an implicit denial of the motion for additional discovery