__________ [Name], defendant, submits the following
separate of undisputed material facts with reference to
supporting evidence in support of __________ [his or her or its]
motion for summary judgment pursuant to Code of Civil Procedure
section 437c(b).
[If the motion addresses more than one cause of action or
affirmative defense, identify each cause of action or
affirmative defense and categorize the undisputed material facts
under appropriate headings, for example]:
1. __________ [Name], defendant, is an independent
contractor.
UNDISPUTED MATERIAL FACT SUPPORTING EVIDENCE
__________ [Set forth __________ [Set forth references
plainly and concisely all to evidence supporting the moving
material facts which the party's contention that the facts
moving party contends are are undisputed, for example]:
undisputed, for example]:
1. By the terms of their Independent Contractor Agreement,
agreement, __________ [name] Paragraph 7.01, Page 12, Exhibit
defendant, and __________ A.
[name] explicityly contracted
for __________ [name], defend-
ant to be an independent con-
tractor.
2. [Identify additional causes of action or affirmative
defenses and categorize relevant undisputed material facts under
appropriate headings.]
Dated __________.
______________________________
[Signature]
Attorney for __________.
