Olivero

facts in plaintiff’s opening brief contains numerous inaccurate record citations to the Department’s separate statement of undisputed facts filed in support of its motion and to asserted additional undisputed facts in plaintiff’s response to defendant’s separate statement, without citing where in the record we can find the evidence supporting the facts she asserts. Plaintiff’s response to the defendant’s separate statement is not itself evidence of disputed facts but, rather, a “mere assertion” of disputed facts. (Stockinger v. Feather River Community College (2003) 111 Cal.App.4th 1014, 1024–1025, disapproved on other grounds in Regents of University of California v. Superior Court (2018) 4 Cal.5th 607, 634, fn. 7.) Plaintiff was required to provide the record citations to the actual evidence (e.g., deposition testimony, documents, declarations). (Stockinger, at pp. 1024–1025; Cal. Rules of Court, rule 8.204(a)(1)(C).) Plaintiff’s error is compounded because many of her citations to the separate statements are to pages that do not even discuss the facts asserted in the statement of facts section of her opening brief. (See Alki Partners, LP v. DB Fund Services, LLC (2016) 4…