What constitutes a valid opposing separate statement?
The opposing separate statement must set out verbatim on the left side of the page the facts claimed by the moving party to be undisputed. (CRC 3.1350(f).) Below the asserted undisputed facts, the statement must set forth the evidence said to establish that fact, complete with the moving partys references to exhibits. (Ibid.) On the right side of the page, directly opposite the recitation of the moving partys statement of material facts and supporting evidence, the response must unequivocally state whether that fact is “disputed” or “undisputed”. (Ibid.) If the opposing party contends there is a dispute, the party must state on the right side of the page, directly opposite the fact in dispute, the nature of the dispute and describe the evidence that supports the position that the fact is controverted. (Ibid.) That evidence must be supported by citation to exhibit, title, page, and line numbers in the evidence submitted. (Ibid.
