In San Diego Watercrafts, Inc. v. Wells Fargo Bank (2002) 102 Cal.App.4th 308, the movant for summary judgment, in connection with its reply, submitted evidence that was omitted from its separate statement. (San Diego Watercrafts, supra, 102 Cal.App.4th at p. 316.) The court held: "In considering this evidence, the trial court violated the plaintiff's due process rights. The plaintiff was not informed what issues it was to meet in order to oppose the motion. Where a remedy as drastic as summary judgment is involved, due process requires a party be fully advised of the issues to be addressed and be given adequate notice of what facts it must rebut in order to prevail." (Ibid.) In short, the court reversed the summary judgment because the trial court had considered evidence submitted for the first time with the reply brief. Relying on evidence that is not filed until after the opposing party had responded to the separate statement violates that party's due process rights; "due process requires a party be fully advised of the issues to be addressed and be given adequate notice of what facts it must rebut in order to prevail." (Id. at p. 316.)