What is a plaintiff's responsibility to formulate the legal basis for her claim prior to litigation?

It is a plaintiff's responsibility to formulate the legal basis for her claim prior to litigation, and to refine it, if necessary, during litigation. If a statutory or regulatory basis is needed, it is plaintiff's responsibility to conduct the legal research necessary to discover the applicable statutes or regulations. Plaintiff cites no authority for her assumption that, if her claim, as alleged, is legally insufficient, defendant is required to make plaintiff's case for her. " 'The pleadings delimit the issues to be considered on a motion for summary judgment.' " (Laabs v. City of Victorville (2008) 163 Cal.App.4th 1242, 1253.) In its motion for summary judgment, a defendant is only required to address the claims alleged in the complaint, not new, unpleaded issues raised by the plaintiff in opposition. (Ibid.)