In United Community Church v. Garcin (1991) 231 Cal. App. 3d 327, alter ego issue was not addressed by the moving party until its reply papers were filed. At that time the plaintiff responded to the alter ego issue by way of a supplementary declarations. The Court of Appeal stated, "By this time, however, it was too late.On a motion for summary judgment or SAI, the burden is always on the moving party to show there is no triable issue of material fact. ( Vesely v. Sager (1971) 5 Cal.3d 153.) When the moving party is the plaintiff, the burden is to prove every element necessary to establish its right to the relief it seeks and to disprove every affirmative defense asserted against it. Until this is done, the defendant has no burden to produce opposing evidence or to disprove anything at all." ( United Community Church v. Garcin, supra, at p. 338.)