Echoing Insalaco v. Hope Lutheran Church of West Contra Costa County (2020) 49 Cal.App.5th 506, this decision states that a separate statement should contain only the facts material to the challenged element(s) of a claim or defense.  Other background facts need not and should not be set out in the separate statement.  The decision also states that the nonmoving party must simply admit the facts that it does not truly dispute rather than supply obfuscating statements or objections.  The trial court can deny a motion if the separate statement is not rule-compliant.