Opposing Motions for Summary Judgment

From my ghostwriting experience, I share several pointers in how to address motions for summary judgment.Vallejo v. Montebello Sewer Co. (1962) 209 Cal.App.2d 721 at 730, 733:Because the procedure is summary and presented on affidavits without the benefit of cross-examination, a trial by jury and opportunity to observe the demeanor of witnesses in giving their testimony, the affidavits filed on behalf of the [plaintiff] should be liberally construed to the end that he will not be summarily deprived of the full hearing available at a trial of the action and the rights incident thereto.