Zhang

DISCUSSION

I. Venue

We first consider whether the trial court erred in failing to consider Zhang’s purported motion to change venue. Zhang all but concedes that this issue was never brought to the trial court’s attention.1 And, she offers no legal authority in support of her suggestion that a failure to rule on a request that the trial court was not even aware of could be reversible error. (Benach v. County of Los Angeles (2007) 149 Cal.App.4th 836, 852.) Setting aside this obstacle, Zhang faces another. While she did object to venue in her original complaint and filed a

1 Zhang did not mention her concerns at either hearing on LASC’s demurrers. And, we are unconvinced by Zhang’s counsel’s oral argument that the burden to raise this issue somehow shifted to either the trial court or defense counsel.

3 memorandum of points and authorities, she never filed an actual motion requesting any relief. “If no notice of motion is given and no motion is made by the defendant seeking a change of venue, there is nothing before the trial court, and no action of the trial court is called for by the filing of a demand and affidavit.” (Hanovia Chemical & Manufacturing Co. v. Keller (1927) 82…