Defendant San Diego Unified School District brings this motion for summary judgment. "The party moving for summary judgment bears an initial burden of production to make a prima facie showing of the nonexistence of any triable issue of material fact; if he carries his burden of production, he causes a shift, and the opposing party is then subjected to a burden of production of his own to make a prima facie showing of the existence of a triable issue of material fact." Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 851.

According to the Notice of Motion, the District seeks to summarily adjudicate four issues.

The Rules of Court require the Statement of Undisputed Material Facts to separately identify each cause of action, claim, issue of duty or affirmative defense and each supporting material fact claimed to be without dispute with respect to that cause of action, claim, issue of duty or affirmative defense. CRC 3.1350(d).

The District did not separately identify each issu