Sato

Sato v. Bank of America CA1/1

Good Law
Court of Appeal of CaliforniaMarch 2, 2015A138944California6,182 words

Opinion

Opinion

Banke, J.

BACKGROUND

Violations of Rules of Court The Rules of Court require litigants to “[s]upport any reference to a matter in the record by a citation to the volume and page number of the record where the matter

1 appears.” (Cal. Rules of Court, rule 8.204(a)(1)(C).) Thus, stating facts without providing any record cite, or citing to only a document rather than to a page, violates this rule. (See, e.g., Evans v. Centerstone Development Co. (2005) 134 Cal.App.4th 151, 166 [“plaintiffs repeatedly cite to 170 pages of their motion to vacate without directing us to specific pages”] (Evans); Doppes v. Bentley Motors, Inc. (2009) 174 Cal.App.4th 967, 990 [“Sections of the statement of facts in the appellant’s opening brief include no record citations at all.”].) When a litigant repeatedly provides no page citations to the record, the rule violation is “egregious[],” significantly burdening the opposing party and the court. (Evans, supra, 134 Cal.App.4th at pp. 166–167.) In this appeal, the Satos submitted opening and reply briefs totaling 105 pages that fail to provide a single page-specific citation. Instead, the briefs provide “citations” such as “see FAC” (referring to the first amended…

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