California, United States of America
The following excerpt is from Tarle v. Kaiser Found. Health Plan, Inc., 141 Cal.Rptr.3d 640 (Cal. App. 2012):
9 Our Supreme Court has not yet decided whether "a trial court's rulings on evidentiary objections based on papers alone in summary judgment proceedings are reviewed for abuse of discretion or reviewed de novo." (Reid v. Google, Inc., supra, 50 Cal.4th at p. 535, 113 Cal.Rptr.3d 327, 235 P.3d 988.)
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