California, United States of America
The following excerpt is from De-Ortez v. Acuna, B237484 (Cal. App. 2012):
4. The trial court correctly ruled these new grounds, raised for the first time in the reply to the opposition, could not serve as the basis for granting the motion to vacate the judgment, as they were not referenced or discussed in the motion to vacate. (Cal. Rules of Court, rule 3.1110(a) [a notice of motion must state in the opening paragraph the grounds for issuance of the order sought]; Luri v. Greenwald (2003) 107 Cal.App.4th 1119, 1126-1127.) Having failed to raise the issues in a proper manner in the trial court, the issues are forfeited for purposes of this appeal.
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