What constitutes a valid separate statement?
The separate statement must separately identify each cause of action, claim, issue of duty, or affirmative defense, and each supporting material fact claimed to be without dispute with respect to the cause of action, claim, issue of duty, or affirmative defense. (CRC 3.1350.) The statement must be in a two-column format, with the undisputed material facts in numerical sequence in the first column and the evidence that establishes those undisputed facts in the second column. (Ibid.) Citation to the evidence in support of each material fact must include reference to the exhibit, title, page, and line numbers. (Ibid.
