The purpose of a separate statement of undisputed facts is to Provide the court with a document that plainly and concisely specifies all material facts that are claimed to be undisputed (CCP §437c(b)(1)); Provide the court with clear reference to evidence supporting each material fact (Cal Rules of Ct 3.1350); and Afford due process to opposing parties (State ex rel Harris v PricewaterhouseCoopers LLP (2005) 125 CA4th 1219, 1262… [read post]