What is the legal basis for a motion for augmentation in a personal injury case?

Appellate counsel alleged that he was unable to provide a more specific factual basis for augmentation, because appellant's trial counsel "(did) not have an adequate memory of the trial." Appellate counsel argued that even without a more specific showing, he had complied with the requirements of rule 12(a) and the standard enunciated in People v. Hill (1967) 67 Cal.2d 105, 122-125, 60 Cal.Rptr. 234, 429 P.2d 586. Alternatively, he contended that a denial of his motion for augmentation would violate

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