In Diego Watercrafts, Inc. v. Wells Fargo Bank (2002) 102 Cal.App.4th 308, the issue involved consideration of a supplemental declaration containing new facts offered in the moving party's reply to the nonmoving party's opposition to the summary judgment motion. (San Diego Watercrafts, Inc., supra, 102 Cal.App.4th at pp. 312-313.) Ultimately, the court held that whether a court considers "evidence not referenced in the moving party's separate statement rests within the sound discretion of the trial court," a decision reviewed for an abuse of discretion. (Id. at p. 316.)