Defendants’ (County of Orange and Keith Hernandez) unopposed Motion for an Order Compelling Attendance and Testimony, Demand for Production (filed on 3-15-18) is DENIED, without prejudice.
California Rules of Court, rule 3.1113(b), states, “The memorandum must contain a statement of facts, a concise statement of the law, evidence and arguments relied on, and a discussion of the statutes, cases, and textbooks in support of the position advanced.” “Rule 3.1113 rests on a policy-based allocation of resources, preventing the trial court from being cast as a tacit advocate for the moving party’s theories by freeing it from any obligation to comb the record and the law for factual and legal support that a party has failed to identify or provide.” (Quantum Cooking Concepts, Inc. v. LV Associates, Inc. (2011) 197 Cal.App.4th 927, 934.)
Plaintiff’s Memorandum of Points and Authorities refers to Code of Civil Procedure sections 2020.010, subdivision (a)(1) and 2020.020. Code of Civil Procedure s