How to Prepare the Separate Statement for a Summary Judgment Motion

fingers on keyboard tying out a separate statement in support of a motion for summary judgmentEvery motion for summary judgment or summary adjudication must include “a separate statement setting forth plainly and concisely all material facts which the moving party contends are undisputed.” CCP §437c(b)(1). Here’s what to include in a separate statement and how to format it. Continue reading

Which Summary Judgment Document Do You Draft First?

452028697When it comes to preparing a summary judgment motion, many attorneys prepare the supporting documents in the same order each time (and instruct new attorneys to do so, too). But one order may not fit all cases.

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The Mighty Separate Statement

The separate statement that accompanies your summary judgment motion in California courts is not merely a technical requirement you can breeze through; rather, it’s an exceedingly important document, and should not be viewed as an afterthought. In fact, when the law is straightforward and well known to the court, the judge may turn first to the separate statement and form an impression on whether the motion is well taken. Continue reading