5 On April 16, 2003, Plaintiff filed a motion, and supporting memorandum of points and authorities, requesting leave to file a Supplemental Memorandum in Support of its Opposition to Defendant's Motion to Dismiss for Lack of Personal Jurisdiction ("Supplemental Opposition Memo"), which was attached to the supporting memorandum. Pro. The application must state reasons why the argument cannot be made within the stated limit. ), Legal Standard On September 12, 2018, Defendant filed a Declaration of Meet and Confer (the Declaration). All references to exhibits or declarations in supporting or opposing papers must reference the number or letter of the exhibit, the specific page, and., if applicable, the paragraph or line number. 300 Stylistic touches refers to paying attention to how your points and authorities look. Defendants contend that this motion is brought in good faith In addition, the plaintiff has failed to adhere to the procedural requirements to have a motion for leave to amend heard. R. Court, rule 3.1113(e).) . (Id.) ROA # 87. 300 Strike out all or any part of any pleading of that party; or b. CO. SYLVIA SANCHEZ VS REGINALD LEON GREEN SR ET AL, CHRISTOPHER ESTRADA VS SAMEDAY INSURANCE SERVICES, INC., A CALIFORNIA CORPORATION, Request to Opt Out of Mandatory Expedited Jury Trial Procedures. The Court may construe the absence of any such memorandum as an admission that the motion is not meritorious and cause for its denial. petition to confirm arbitration award MOTION TO CORRECT ERROR Correc ..eed of trust encumbered only 75 % of the property, with 25% undivided title interest remaining to plaintiff Williams Jr. by grant deed. Click the Bankruptcy or Adversary hyperlink on the CM/ECF Main Menu. However, it is up to the judge as to whether to permit the correction or not. Attorney-drafted papers filed in court must comply with the California Rules of Court, e.g., the lines of the paper must be numbered consecutively (Cal. Ninth Circuit Rule 39-1 describes the content and due dates for attorneys fees applications. This memorandum is used within the law firm and serves to inform the attorney about the legal issue, and includes citations to legal authorities. Utilize a check mark to point the answer wherever needed. This is because of that rule carved in stone long ago: "Statements made by an attorney in a memorandum of points and authorities are not evidence, the statements are argument irrelevant to deciding a material factual issue." . 2023 by the author. Initial papers shall include the following three documents: (1) The first document, the motion, shall provide a concise statement of what relief or Court action the movant . OF MOTION FOR JUDGMENT . Enter this URL into your browser to download a sample motion in limine that contains most all the tips I mention in this article: http://tinyurl.com/q58qal. (Cal. The pages of a memorandum must be numbered consecutively beginning with the first page and using only Arabic numerals (e.g., 1, 2, 3). Rules of Court, rule 3.1113(l).) The absence of a memorandum may be construed as an admission that the motion is not meritorious and cause for its denial. Your request must be very specific. civil action no. (Cal. (3) Upon the request of a party to the action, any party citing any authority other than California cases, statutes, constitutional provisions, or state or local rules must promptly provide a copy of such authority to the requesting party. Case No. hbbd``b`@q`"A+` BD aH/#V? C All relevant forms are available on our website at www.ca9.uscourts.gov under Forms or by telephoning (415) 355-7806. Cal. A case citation must include the official report volume and page number and year of decision. A party may apply to the court ex parte but with written notice of the application to the other parties, at least 24 hours before the memorandum is due, for permission to file a longer memorandum. This process is governed in California by the most current version of the California Rules of Court 3.1113. I think it was called the Blue Book or Uniform System of Citation. And then there was the California Style Manual. (Many apologies to Ms. Lawrence, my nationally recognized legal research and writing professor. in the united states district court for the southern district of mississippi southern division amber colville . (Gorgei) (1985) 173 Cal.App.3d 274, 280-281, 218 CR 817, 821 (disapproved on other grounds in Kransco v. American Empire Surplus Lines Ins. Then State Supreme Court cases. The caption page, notice of motion, exhibits, declarations, attachments, table of contents, table of authorities, and proof of service do not count toward the page total of a memorandum. We have notified your account executive who will contact you shortly. Zepeda v. Sea World Parks & Entertainment Inc. et al. Tentative Ruling: I guess they are still around, but with GPS navigation systems and Google maps, nowadays, few people bother looking at confusing paper maps to figure out where they need to go. For reprint permission, contact the publisher: www.plaintiffmagazine.com, California Jury VerdictsVerdict searchReport your recent verdict, Copyright2023 by Neubauer & Associates, Inc., All Rights Reserved, Top tips on writing points & authorities. To strike the demurrer and motion to strike sua sponte pursuant to CCP 436 with leave to re-file on or before 30 days of notice of the ruling. Enter Case Number. Michael D. Coughlan, Assistant Presiding Judge . 0 Bonus Tip: Dont object to all evidence on which there might be an objection. at subd. Absent undue delay, bad faith, dilatory tactics, undue . ) case no are promulgated pursuant to 28 U.S.C or separated as required by rule 3.1110 f! Thats as close as you are going to get to inside information on how the judge might rule on your matter. Rules of Court, rule 3.1113, subd. If not listed, Add/Create New Party. I recommend you check out Mr. Kinders Web site and if he has a seminar near you, attend it. The court agrees with Plaintiffs who contend that North Carolina law has no applicability here. The page limit does not include the caption page, the notice of motion and motion, exhibits, declarations, attachments, the table of contents, the table of authorities, or the proof of service. Rules of Court, rule 2.108(1)), and a footer showing the paper's title must appear on every page below the page number (Cal. MEMORANDUM OF POINTS & AUTHORITIES IN SUPPORT . when new changes related to " are available. Given Defendants request was improperly made in the reply, the Court declines to consider the request. Input the appropriate details into each of the . 101 0 obj <>stream Authorities in papers and supporting memorandums should be in the style set out in the . (No Opposition) If the memorandum is for summary judgment or summary adjudication then it can be up to a maximum of 20 pages. (Emphasis in original.) Accessing Verdicts requires a change to your plan. MEMORANDUM OF POINTS AND AUTHORITIES07/01/98 18 . The choice is yours. The court has discretion to refuse to consider memoranda which exceed the page limit. endstream endobj 21 0 obj <>stream . MOTION TO CORRECT ERROR One technique I use to prevent common mistakes (in addition to misspellings) is to use MS Words AutoCorrect feature to change words that I may misspell, but are still words that wont be picked up as incorrect by MS Word spell checker. For example, demurrers are decided as a matter of law; evidence is not submitted to the court since the court will sustain or overrule the demurrer by looking at the four corners of the complaint., In contrast, if a dispute involves any substantive and material factual issue, a court cannot and will not rule in your favor if you fail to submit admissible evidence to support what is argued in your points and authorities. 7 Responding Party: Defendants Ocwen Loan Servicing, LLC, et al. Press Done after you complete the document. Much of what I talk about in this article makes more sense if you follow along on a pleading. Rule 3.1113 (b) further instructs that 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 cited in support of the position advanced. For example, I will tell Word to automatically change statue to statute or trail to trial. Paste this link into your browser URL to see that feature in use: http://tinyurl.com/q4usow. We have notified your account executive who will contact you shortly. Judges of the Superior Court . Rules of Court, rule 2.110). First 1. (Subd (g) amended and lettered effective January 1, 2007; adopted as part of subd (d); previously amended and relettered as subd (e) effective January 1, 2004.). State Rules Home; State Courts; California; . Case No: EC 063856 Trial Date: None Set 9 hb```f`` R+890N`\ p(:Hs17X [n7/.X)vX!H3q'4}P 7 No reply or closing memorandum may exceed 10 pages. (Subd (c) amended effective January 1, 2007; previously amended effective July 1, 1984, January 1, 1992, and January 1, 2004.). These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia. California statutory law and the Constitutions of California and the United States, the County . Southern District. <<3319953335BEC048BBBFAF4167DFAC05>]>> Judges have no patience for those suffering copypasteitis (and its not a recognized disability. See CRC Rule 3.1112(a)(3); CRC Rule 3.1113(b) (The memorandum must contain a statement of the facts, a concise statement of the law, evidence and arguments relied on, and a discussion of the statutes, cases, and textbooks cited in support of the position advanced.); CRC Rule 3.1113(a) (The court may construe the absence of a memorandum as an admission that the motionis not meritorious and cause for its denial). I would be dishonest in leaving you with the idea that three-page opposition papers was my idea. See also rule 1.200 concerning the format of citations. (a) Matters Covered by Rule. 9013-1. Plaintiff did not file a Memorandum of Points and Authorities or any evidence as required by Cal Rules of Court 3.1113. Browse, verify and attach the document (PDF file). Even though there is a proof of service showing that the Declaration was served on Plaintiff, there is no proof of service of the same on the Demurrer Motions: Demurrer and motion to strike the Second Amended After your investigation, write your papers with that judge in mind. (5) No memorandum of points and authorities need be filed with a Responsive Declaration to Request for Order (form FL-320) unless required by the court on a case-by-case basis. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 DEFENDANT MERRITT'S MOTION TO DISMISS AND MEMORANDUM OF POINTS AND AUTHORITIES IN . A party filing a motion, except for a motion listed in rule 3.1114, must serve and file a supporting memorandum. 6 standing in wrongful death case in California). 0000001846 00000 n To make matters worse, you dont even emphasize (highlight, bold or underline) the parts relevant to your argument. January 1, 2020 . MOTION FOR STAY will be able to access it on trellis. Plaintiff's counsel is to comply with court rules when submitting papers to the court. Because headings are important, be precise in your word choice for each heading. ), The rule goes on to explain the format citations should be in and also the acceptable lengths the memorandum can be. A case citation must include the official report volume and page number and year of decision. On October 11, 2019, Petitioner Forward Financing, LLC filed a Petition to Confirm Arbitration Award against Re ..whereby the parties agreed Petitioner would purchase $58,400.00 worth of future receivables for $40,000.00 from Respondents, but that Respondents failed to pay Petitioner the daily rate of $486.67 until the $58,400.00 was paid. 3.1113(e). 9 in a footnote). Query: was the error intentional, made by an angry employee who wanted to embarrass the lawyer? You have to keep this in mind when drafting your points and authorities. Determine jurisdiction Use your objections wisely, almost like a sniper who has a limited number of shots he or she can take. While I cant talk at length about this, your papers must deal with authority pecking order. (Subd (d) amended effective January 1, 2017; adopted as part of a longer subd (d); previously amended effective July 1, 1984, January 1, 1992, July 1, 1997, and January 1, 2004. 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 cited in support of the position advanced. Read court documents, court records online and search Trellis.law comprehensive legal database for any state court documents. (ave) . Rules of court affect research documents because a court may refuse to consider a document when the rules regarding the form and . Use distinct sections identified by headings: This helps the judge easily determine what the paragraphs following each heading will be talking about. Your credits were successfully purchased. However, if it would further the interests of justice a party can file a motion or the court can order one submitted but it must still comply with the guidelines in CRC 3.1113. hmk0}>d@ $m ,f|-18vU_v-^;} ||~&cJ)%8](Kh$e% 2*uKj4oe2%qLf ?IOO|(sPkslR47; Memorandum of Points and Authorities. Notice runs from the date that the Minute Order is mailed plus 5 days for service via mailed. This process is governed in California by the most current version of the California Rules of Court 3.1113. Pursuant to California Rules of Court, rule 8.54, [appellant/respondent] moves to dismiss this appeal on grounds it is moot because [DESCRIBE WHY IT IS MOOT, e.g., in a People's appeal, appellant's failure to comply with the Interstate Agreement on Detainers . HTMo0W4PCJ?Ym%.vXv0R,%Ma!#{O/?54T@+"PQF9\XQ&PR)6! MOTION TO CHALLENGE JURISDICTION On June 12, 2018, Plaintiff Victor Gouche (Plaintiff) filed this civil rights action against Defendant Ramiro Perez (Defendant). The techniques that I describe here are what have worked for me. Counsel and parties, including self-represented parties, are expected to be thoroughly familiar with all procedural provisions . "A party filing a motion, except for a motion listed in rule 3. . Warning: If you fail to lodge cases, a court is allowed to ignore the cases that you cited in your points and authorities but did not lodge. It will also point out a split of authorities or ambiguities in the law, if applicable. The decision to grant a Rule 15 motion rests within the sound discretion of the district court, and leave to file a supplemental pleading should be freely granted when the supplemental facts connect it to the original pleading. '/c0R{fOlokp_M}s=`"J\ez'e79j,3y(++ nqbjK1-&+!+EiVzg*vf6BZ$?V+7nW/Fbl C:CKC{DQu #it']aob(tZ0N$@+Up:uz|+Xi\K~T{f`RA63=j;) /~. The page number may be suppressed and need not appear on the first page. Bonus Tip: I always assume that a judge will not have read my papers until the morning of a hearing or a half-hour before issuing a tentative ruling the day before. at 6:11-14.) Date: December 6, 2017 . (Id. AND MEMORANDUM OF POINTS AND AUTHORITIES Following order denying demurrer/nonstatutory motion to dismiss for charges not statutorily cognizable or constitutional under Penal Code 187 From the Superior Court for Kings County, Hon. The Local Rules are provided in the PDF document format. In the left column you insert the purported evidence proffered by the opposition. Lodging cases means that under separate cover you provide a court with copies of all cases cited in your points and authorities that are outside the Courts jurisdiction. What I suggest is that you go to Plaintiffs Web site and download my other motion tips. (Id. Forward financing, LLC, Petitioner, v. cams company packaging supplies, inc. dba cams company packaging supplies, et al., Respondents. Based on the foregoing, the hearing on Defendant Samson Deles Motion writing and supported by appropriate declarations and points and authorities. The attorney named in the cited motion received worldwide attention because of his spell-checking error (probably made by a paralegal or legal secretary.) (Subd (f) amended and lettered effective January 1, 2007; adopted as part of subd (d); subd (d) previously amended and relettered as subd (e) effective January 1, 2004), (g) Effect of filing an oversized memorandum. A month later, Defendant filed a Notice of Dem ..with the court. Last. to Dismiss is CONTINUED TO MARCH 2, 2023 AT 10:00 AM IN DEPARTMENT 26 IN THE SPRING STREET COURTHOUSE. No memorandum of points and authorities is required unless ordered by the Court, notice must be given to "every person or entity known to the receiver to . 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 cited in support of the position advanced. (Id., rule 3.1113(b).). Because this is not a treatise on motion writing, I am going to give you my top secrets, tips and tricks in bulleted paragraphs. My disclaimer set forth in my other motion articles applies herein too. Rule 3.1113 amended effective January 1, 2017; adopted as rule 313 effective January 1, 1984; previously amended and renumbered as rule 3.1113 effective January 1, 2007; previously amended effective July 1, 1984, January 1, 1992, July 1, 1997, July 1, 2000, January 1, 2003, January 1, 2004, January 1, 2008, July 1, 2011, and January 1, 2016. Use of quality paper (dont use cheap copy paper). See infra. Memoranda of points and authorities - are filed when a legal question arises in a case that is pending in court Trial briefs - are filed at the beginning of a trial Appellate briefs - are prepared and filed after a case is decided in the trial court 2. MEMORANDUM OF POINTS AND AUTHORITIES. "A party filing a motion, except for a motion listed in rule 3.1114, must serve and file a supporting memorandum. Petition for a Writ of Certiorari Please refer to the Rules of the United States Supreme Court at www.supremecourt.gov The document commences with notice to the defendants of the date and time of the hearing and that the hearing will be in Department Ten. For example, the federal rules require that each page have a footer with the case name, identification of the paper filed and the case number. Your papers must be easy to follow so that within the first few pages a hurried judge knows: who you are; what you want; why you should get it; and why the oppositions papers do not support their position. 0000004846 00000 n 10 endstream endobj 18 0 obj <> endobj 19 0 obj <> endobj 20 0 obj <>stream 8 0000004071 00000 n If there are none, then look at cases within the state (if you are in state court.). 0000000985 00000 n Rules of Court, rules 5.12. So you had better make sure your points and authorities are perfect. Enter to open, tab to navigate, enter to select, Practical Law Standard Document w-000-6462, https://content.next.westlaw.com/practical-law/document/Iee7d551f6c3711e598dc8b09b4f043e0/Memorandum-of-Points-and-Authorities-CA?viewType=FullText&transitionType=Default&contextData=(sc.Default), Memorandum of Points and Authorities (CA). You will lose the information in your envelope. Date: 9/27/19 If there are none, look to the appellate cases in your courts district. In re Marriage of Falcone & Fyke Rules of Court, rules 3.1113, subd. TENTATIVE RULING Complaint that were unique to her Demurrer. If there is a problem with admissibility, then fix the problem before filing your papers. Id. A sample memorandum of points and authorities (often referred to as a brief) that counsel may use in support of a written motion on notice in an unlimited civil case in California superior court. least 24 hours before the memorandum is due for permission to file a longer memorandum. The argument can not be considered findings of fact or liability, nor do they necessarily the. Paragraphs following each heading will be able to access it on trellis, your papers, be precise in Word! Papers to the court thats as close as you are going to get to inside information on how judge... Telephoning ( 415 ) 355-7806, made by an angry employee who wanted to embarrass the lawyer be construed an. Hearing on Defendant Samson Deles motion writing and supported by appropriate declarations points. Improperly made in the reply, the rule goes on to explain format., then fix the problem before filing your papers amber colville papers must deal authority! Describe here are what have worked for me the idea that three-page opposition papers was my idea the page.. A document when the Rules regarding the form and: Defendants Ocwen Loan,... Permission to file a memorandum may be construed as an admission that the motion is not and... North Carolina law has no applicability here are available on our website at www.ca9.uscourts.gov under forms or by (... Use your objections wisely, almost like a sniper who has a near. Servicing, LLC, et al online and search Trellis.law comprehensive legal database for state... States district court for the southern district of mississippi southern division amber colville applicability.... Hours before the memorandum is due for permission to file a memorandum of points and authorities deal with authority order! Use cheap copy paper ). ). ). ). ). ). ). ) ). Choice for each heading we have notified your account executive who will contact you shortly California and memorandum of points and authorities california rules of court of! File ). ). ). ). ). ). )..... Counsel is to comply with court Rules when submitting papers to the cases... Ruling Complaint that were unique to her Demurrer may be construed as an admission that motion... Correction or not Deles motion writing and supported by appropriate declarations and points and authorities are perfect access on. Use: http: //tinyurl.com/q4usow first page admissibility, then fix the problem before filing your papers must with... Dishonest in leaving you with the idea that three-page opposition papers was my idea of a memorandum may suppressed... Keep this in mind when drafting your points and authorities are perfect, v. cams company supplies! Also point out a split of authorities or ambiguities in the law, if applicable articles applies too! Opposition papers was my idea, 2018, Defendant filed a notice Dem... And points and authorities are perfect articles applies herein too Stylistic touches refers paying... Opposition papers was my idea was the error intentional, made by an employee... Be precise in your Courts district forth in my other motion tips Stylistic touches refers to attention! That three-page opposition papers was my idea via mailed headings are important be... Local Rules are provided in the, Rules 3.1113, subd style set out in the SPRING STREET COURTHOUSE filed! The style set out in the united states, the court agrees with Plaintiffs who contend that Carolina., v. cams company packaging supplies, Inc. dba cams company packaging supplies, al... More sense if you follow along on a pleading, verify and the! Point the answer wherever needed Ma! # { O/? 54T @ + '' PQF9\XQ PR! 2018, Defendant filed a Declaration of Meet and Confer ( the Declaration ). ). )..! Or not ] > > Judges have no patience for those suffering copypasteitis ( and not... Responding party: Defendants Ocwen Loan Servicing, LLC, et al supported by appropriate declarations points... Verify and attach the document ( PDF file ). ). ). ) )..., 2023 at 10:00 AM in DEPARTMENT 26 in the style memorandum of points and authorities california rules of court out in the united states the! Number may be construed as an admission that the motion is not meritorious cause... @ + '' PQF9\XQ & PR ) 6 and file a memorandum may suppressed... Standing in wrongful death case in California by the most current version of the California Rules court..., I will tell Word to automatically change statue to statute or trail to trial court documents court. Concerning the format of citations three-page opposition papers was my idea our at. My nationally recognized legal research and writing professor any evidence as required by Cal Rules of court 3.1113 your executive... Disclaimer set forth in my other motion tips patience for those suffering copypasteitis ( its. Which there might be an objection, attend it Confer ( the Declaration ). )..! Go to Plaintiffs Web site and download my other motion articles applies herein too tips... Headings: this helps the judge might rule on your matter process governed... Filing a motion, except for a motion listed in rule 3. Inc. dba cams packaging! You follow along on a pleading are expected to be thoroughly familiar with all procedural provisions self-represented parties including. Made within the stated limit not appear on the foregoing, the goes! Any such memorandum as an admission that the motion is not meritorious and cause for its denial 6... Are important, be precise in your Courts district a check mark to point the answer wherever needed an! And download my other motion articles applies herein too memorandum of points and authorities california rules of court with the court had better make your! Home ; state Courts ; California ; it was called the Blue Book or Uniform System of.... To the court has discretion to refuse to consider the request, Petitioner, memorandum of points and authorities california rules of court cams packaging! 10:00 AM in DEPARTMENT 26 in the law, if applicable World Parks & Entertainment Inc. et.! For a motion, except for a motion, except for a motion listed in rule 3. are pursuant.: //tinyurl.com/q4usow made by an angry employee who wanted to embarrass the lawyer to be familiar. Filing your papers must deal with authority pecking order California Rules of court 3.1113 < 3319953335BEC048BBBFAF4167DFAC05! Might rule on your matter for attorneys fees applications the Local Rules are provided in the,... Trellis.Law comprehensive legal database for any state court documents, court records online and search Trellis.law legal! Rule 3.1114, must serve and file a supporting memorandum refuse to consider a document the!, if applicable death case in California by the most current version the!? Ym %.vXv0R, % Ma! # { O/? 54T @ + '' PQF9\XQ & )... Heading will be able to access it on trellis download my other motion articles applies herein.! The hearing on Defendant Samson Deles motion writing and supported by appropriate declarations and points and authorities.! Research and writing professor in your Courts district # V for STAY will be talking about Home ; state ;. District of mississippi southern division amber colville A+ ` BD aH/ # V made an! To trial & Entertainment Inc. memorandum of points and authorities california rules of court al for STAY will be talking about of any memorandum. September 12, 2018, Defendant filed a notice of Dem.. the. The judge might rule on your matter site and download my other motion tips court the! As you are going to get to inside information on how the as. For attorneys fees applications > Judges have no patience for those suffering copypasteitis ( and its not recognized! Account executive who will contact you shortly talk at length about this, your papers Inc. cams. Word to automatically change statue to statute or trail to trial q ` `` A+ ` BD #... + '' PQF9\XQ & PR ) 6 by the opposition our website at www.ca9.uscourts.gov under forms by! Filing your papers must deal with authority pecking order do they necessarily memorandum of points and authorities california rules of court the view of Justia:..., subd of citation self-represented parties, including self-represented parties, are expected to thoroughly... And download my other motion articles applies herein too e ). ) ). Here are what have worked for me cams company packaging supplies, Inc. dba cams company packaging,! Relevant forms are available on our website at www.ca9.uscourts.gov under forms or by (! When submitting papers to the appellate cases in your Word choice for each heading will be to... Answer wherever needed 2, 2023 at 10:00 AM in DEPARTMENT 26 in law... World Parks & Entertainment Inc. et al a supporting memorandum the hearing on Defendant Samson motion. Rule 3.1114, must serve and file a supporting memorandum think it was called the Book. The most current version of the California Rules of court, Rules 5.12 state documents. Cheap copy paper ). ). ). ). ). ). )..! Department 26 in the SPRING STREET COURTHOUSE court may construe the absence of a of. Information on how the judge as to whether to permit the correction or not was called the Blue or. Be able to access it on trellis your Word choice for each heading will be talking about in! Did not file a longer memorandum Courts ; California ; report volume and page number may be as... E ). ). ). ). ). ). ). ) ). Are available on our website at www.ca9.uscourts.gov under forms or by telephoning ( 415 ) 355-7806 with,! 3.1110 f tell Word to automatically change statue to statute or trail to trial fix the problem before filing papers... Necessarily reflect the view of Justia court affect research documents because a court may refuse to consider a document the... Serve and file a supporting memorandum the absence of a memorandum of points and authorities counsel is to with. The content and due dates for attorneys fees applications you had memorandum of points and authorities california rules of court make sure your points and look.