In order to comply with M.R. Civ. P. 7(d), a party opposing summary judgment must properly controvert the movant's statement of material facts ("SMF"). To do so, the opposing party must controvert the specific paragraphs of the movant's SMF. See Prescott v. State Tax Assessor, 1998 ME 250, 6, 721 A.2d 169, 172. Failure to properly controvert the movant's SMF results in those statements being deemed admitted. Id. Additional facts in the non-moving party's SMF may be considered if they are supported by appropriate record references. See id. the trial court is to consider only the portions of the record referred to in the Rule 7(d) statements. Id. at P8. "To survive a defendant's motion for summary judgment, a plaintiff must produce evidence that, if produced at trial would be sufficient to resist a motion for a judgment as a matter of law." Corey v. Norman, Hanson & DeTroy, 1999 ME 196, P7, 742 A.2d 933, 937-38. The non-movant has the burden of proof to "establish a prima facie case for each element of his cause of action." Id., 1999 ME 196, P9, 742 A.2d at 938.