California, United States of America
The following excerpt is from Barron v. Nat'l Mentor Healthcare, LLC, D063482 (Cal. App. 2014):
Niko v. Foreman (2006) 144 Cal.App.4th 344, 368 ["One cannot simply say the court erred, and leave it up to the appellate court to figure out why"]; In re Marriage of Schroeder (1987) 192 Cal.App.3d 1154, 1164 ["court is not inclined to act as counsel for . . . any appellant and furnish a legal argument as to how the trial court's rulings in this regard constituted an abuse of discretion."].)
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