Q: Where exactly and how causes of action listed in complaint, are references in MSJ?

A: Under California law, when filing a motion for summary judgment (MSJ), the moving party must specifically address each cause of action listed in the complaint and explain why summary judgment should be granted on those causes of action. This is typically done in the following ways:

1. Separate statement of undisputed material facts: The moving party must provide a separate statement that clearly identifies each material fact relied upon to support the motion, with specific references to the evidence supporting each fact (e.g., exhibits, declarations, deposition transcripts). This separate statement should be organized by cause of action, making it clear which facts pertain to each claim.

2. Memorandum of points and authorities: In the legal memorandum supporting the MSJ, the moving party should devote a section to each cause of action, discussing the legal elements of the claim, the undisputed material facts that support or negate those elements, and the legal authorities that support the party's position. The memorandum should clearly reference the specific causes of action from the complaint and explain why the moving party is entitled to summary judgment on each claim.

3. Headings and subheadings: To make the MSJ clear and easily navigable, the moving party should use descriptive headings and subheadings that identify the causes of action being addressed. For example, a heading might read: "Plaintiff's First Cause of Action for Breach of Contract."

4. Specific citations to the complaint: When discussing each cause of action, the moving party should cite the specific paragraph numbers or page numbers from the complaint where the cause of action is alleged. This helps the court easily locate and reference the relevant claims.

By organizing the MSJ around the causes of action and clearly referencing them throughout the separate statement and memorandum, the moving party ensures that the court can easily understand which facts and legal arguments pertain to each claim, facilitating a proper analysis of whether summary judgment should be granted.