California, United States of America
The following excerpt is from A.H v. Fire Ins. Exch. Inc, F058022, No. MS302 (Cal. App. 2010):
This court has noted the use of the words "shall" and "all" in Code of Civil Procedure section 437c, subdivision (b)(1) and the resulting importance of complying with its terms. (Haney v. Aramark Uniform Services, Inc. (2004) 121 Cal.App.4th 623, 631-632.) In particular, when a moving party contends that a cause of action must fail, the facts material to the legal theory upon which the moving party bases its contention must be identified accurately in the separate statement. (Id. at p. 632.) "Both the court and the opposing party are entitled to have all the facts upon which the moving party
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