PLAINTIFF’S MOTION FOR SUMMARY ADJUDICATION CA CCP § 437c (p) For purposes of motions for summary judgment and summar adjudication: (1) A plaintiff has met his or her burden of showing that there is n defense to a cause of action if that party has proved each element of the cause o action entitling the party to judgment on the cause of action. Once the plaintiff ha met that burden, the burden shifts to the defendant to show that a triable issue of on or more material facts exists as to the cause of action or a defense thereto. Th defendant shall not rely upon the allegations or denials of its pleadings to show that triable issue of material fact exists but, instead, shall set forth the specific fact showing that a triable issue of material fact exists as to the cause of action or defense thereto. CRC 3.1350 provides that the Separate Statement of Material Facts should include “onl material facts and not any facts that are not pertinent to the disposition of the motion”. Th Sepa