Does defendant have the burden of proving that the same day service is proper?

Because defendant's costs memorandum was insufficient on its face to determine whether the service of process items were proper, defendant had the burden of proof to establish the "reasonableness of the service costs." (Nelson v. Anderson (1999) 72 Cal.App.4th 111, 132.) Although in her opposition to the motion, defendant submitted invoices in support of her request for service of process costs, she did not state why she or her counsel chose same day service for the challenged subpoenas, leaving plaintiff and the trial court to speculate why such a service method was chosen. Indeed, rather than determining whether the "same day" service of process costs were necessary and reasonable, the trial court appeared to have engaged in a "tit-for-tat" analysis, stating it was going to allow the service of process costs because "I knocked out the other [costs]." The trial court abused its discretion by allowing recovery of the service of process costs for four deposition subpoenas and one trial subpoena served on the "same day."⁷ We remand the matter to the trial court to determine the amount of costs that should be awarded for unexpedited service of process.