What is the impact of a court's order to appoint a discovery referee on a party's ability to pay the referee's fees?

Section 639 of the Code of Civil Procedure requires all appointments of a discovery referee to be by written order and include specified findings, such as the parties' ability to pay the referee's fees. "Reference to a discovery referee imposes a substantial economic burden on . . . a party [of modest means]. It is therefore incumbent on trial courts . . . to look beyond the benefit realized by the judicial system and consider the economic impact the order of reference will have on the parties." (Solorzano v. Superior Court (1993) 18 Cal.App.4th 603, 615 (Solorzano); see also Code Civ. Proc., 645.1.)