Vartan Kojababian (plaintiff) sued Genuine Home Loans, Inc., Nectar Kalajian, and Aida Markarian (defendants), alleging fraudulent transfer and negligence. The defendants moved for summary judgment. The defendants supported their summary-judgment motion with a separate statement of undisputed facts, declarations, and documentary evidence. Kojababian responded to the motion, asking that either: (1) the motion be denied or (2) the motion be continued to allow for additional discovery. However, Kojababian did not include a separate statement of facts and did not specify what information he expected to get through further discovery that would help him respond to the motion. The trial court granted the motion for summary judgment. Kojababian appealed.