present all the material that is pertinent to the motion.
See also Island Tile & Marble, LLC v. Bertrand, 57 V.I. 596, 612 (V.I. 2012) (citing ... unswom representations of counsel as to
factual matters—which are not themselves evidence . ." Island Tile & Marble, LLC, 57 V.I. at
613. "[U]nswom representations of counsel as to factual matters