How have the courts treated evidence in a personal injury case?

(Du Jardin v. City of Oxnard (1995) 38 Cal.App.4th 174, 179-180 [attorney's argument is not evidence].) In fact, Father's own evidence, a mediator's report, stated that Mother "has complied with her court ordered counseling sessions." Mother also stated in her declaration that she had completed the court-ordered counseling. In other words, Father's only argument on appeal is unsupported by the record.