In Frazee v. Hall Seely (2002) 95 Cal.App.4th 627, the court held that a simple notice of joinder in a motion for summary judgment was not sufficient for purposes of the summary judgment statute. Frazee was a legal malpractice case against two separate law firms who represented the plaintiff in her marital dissolution action at different stages of the action. (Id. at p. 630.) The first law firm the plaintiff had hired (S&R) filed a motion for summary judgment or adjudication on the grounds the plaintiff could not prove damages, could not show a breach of fiduciary duty, and because there was no material misrepresentation. (Id. at p. 631.) The later-hired law firm (HH&E) filed a notice of joinder, contending that the issues of causation of damages were identical. (Ibid.) Because HH&E had filed a simple notice of joinder, but had not filed a separate statement, the court opined the joinder was not sufficient for purposes of the summary judgment statute, which requires each moving party to support its motion for summary judgment with a separate statement. (Frazee, supra, 95 Cal.App.4th at p. 636.) The court further held that even if the mere failure to file a separate statement was insufficient to deny the motion, "the separate statement and documentation on which HH&E relied did not provide a basis for granting summary judgment in their favor. The separate statement mentions HH&E only in terms of their initial involvement in the dissolution action. It does not set forth facts relating to their alleged malpractice that they contend are not in dispute. Without such factual assertions, the court's grant of summary judgment was improper." (Ibid.)