Separate Statement in Summary Judgment

Posted by Yisrael Gelb | Nov 19, 2023 | 0 Comments

A separate statement of material facts is a crucial component in a motion for summary judgment, providing a clear and concise presentation of undisputed facts that support a party's position in a case. This document, typically required in conjunction with motions for summary judgment, outlines key details that are essential to the legal arguments presented. It serves as a roadmap for the court, aiding in the identification of genuine disputes between the parties. The statement is crafted with precision, highlighting facts relevant to the case's legal issues while avoiding unnecessary details. Its purpose is to streamline the court's review process, ensuring a focused consideration of the essential facts that bear significance in the determination of the case's outcome.

A deficient separate statement or failure to file one altogether, is grounds for dismissal of the motion. (C.C.P. section 437c, sub. (b)(1).)

A statement must state material (as opposed to immaterial or evidentiary) facts and be followed by supporting evidence. (Cal. Rules of Court (3.1530(d)(2).) 

Cal. Rules of Court (3.1530(d)(3) also requires a specific two-column format for the separate statement.

Reach out to Gelb Law for help with your motion or opposition to summary judgment. 

About the Author

Yisrael Gelb

Yisrael is the founding attorney of Gelb Law.  He graduated from Southwestern Law School in December 2021, where he was editor of the Journal of International Media and Entertainment Law, an official ABA publication. He was also a Moot Court competitor and an active student leader on campus. Yis...


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