What is the test for establishing that a Defendant's assignment of error is not sufficient to warrant an independent investigation into its merits?

Defendants' "'mere naked assignment of error is . . . insufficient to warrant an inquiry into its merits. [Citation.]'" (Martter v. Byers (1946) 75 Cal.App.2d 375, 379.) "'[T]he burden rests on appellant to point out clearly and concisely not only the matters claimed to be erroneous, but the reasons why they are so; and upon his failure so to do, it will be deemed that such matters are not of sufficient importance to demand independent investigation.'" (Ibid.) Here, defendants did not refer to the record at all to support their legal argument. Defendants merely recite the law without attempting to apply the law to the facts of their case. "Appellate courts will not act as counsel for either party to an appeal and will not assume the task of initiating and prosecuting a search of the record for the purpose of discovering errors not pointed out in the briefs." (Fox v. Erickson (1950) 99 Cal.App.2d 740, 742.) Because defendants have failed to appropriately "support the

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arguments in its briefs by appropriate reference to the record, which includes providing exact page citations," we are "unable to adequately evaluate which facts the parties believe support their position . . . ." (Bernard v. Hartford Fire Ins. Co. (1991) 226 Cal.App.3d 1203, 1205.)