What is the test for denying a motion to suppress without an evidentiary hearing?

¹ Southern District of California Local Rule 47.1(g)(1) requires a declaration. Criminal motions requiring a predicate factual finding must be supported by declaration(s)....The court need not grant an evidentiary hearing where either party fails to properly support its motion of opposition.

A trial court has discretion to deny a motion to suppress without an evidentiary hearing if a defendant fails to support the motion with specific facts. United States v. Wardlow, 951 F.2d 1115, 1116 (9th Cir.1991) (affirming district court's denial of evidentiary hearing because requirements of Central District Local Rule 9.2 not met by declaration of counsel containing broad assertion that the statement of facts in a memorandum of points and authorities was based on discovery received by counsel); United States v. Batiste, 868 F.2d 1089, 1092 & n. 5 (9th Cir.1989).