California, United States of America
The following excerpt is from Hiramanek v. Hiramanek (In re Hiramanek), H036471, H036723 (Cal. App. 2014):
Adil also asserts that the court erred by failing to appoint a referee under section 2032, subdivision (d). That provision grants the court discretion to "order that a referee be appointed pursuant to Section 639 of the Code of Civil Procedure to oversee the allocation of fees and costs." ( 2032, subd. (d).) Adil's bald assertion that the court should have granted his unopposed request for a referee does not establish abuse of discretion. (Reed v. Reed (1953) 118 Cal.App.2d 399, 400.)
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