In Frazee v. Seely (2002) 95 Cal.App.4th 627, plaintiff's counsel, in a declaration filed in opposition to a defense summary judgment motion, explained he needed more time to complete ongoing discovery. Certain deposition transcripts had not come from the reporter, and other discovery (including answers to interrogatories and expert depositions) was still in progress. Counsel declared he had been diligent, but "due to logistical and scheduling problems, he had not been able to complete discovery." (Id. at p. 633.)