In what circumstances will the court allow a motion to allow discovery to be made after a motion has been denied?

The Beverly Hospital case states that requiring a motion to allow discovery in these situations "would plunge the trial and appellate courts back into a sea of discovery disputes when their dockets are already at flood stage." (Beverly Hospital v. Superior Court, supra, 19 Cal.App.4th at p. 1296, 24 Cal.Rptr.2d 238.) Beverly Hospital has exaggerated the burden on the courts in requiring a motion to allow further discovery. The moving party would simply have to show specific reasons that necessitate further discovery. In our view automatic reopening of discovery is far more likely to lead to a discovery free-for-all without any showing that further discovery is even necessary.