PRETRIAL ADJUDICATION
...Summary Judgment & Summary Adjudication
......Declarations & Affidavits
.........Pleadings: Relationship to
3 Cards On This Topic:

Affidavits in response to D’s SJ motion may not create issues outside complaint, and are not substitute to amendment to complaint.

The repetition of the substance of the complaint would be a useless act for the defendant, the doing of which the law does not require.

No need that D’s decl. repeat matters already asserted in complaint.