In Pham v. Nguyen (1997) 54 Cal.App.4th 11, shortly before trial an expert witness refused to testify, and the specific factual basis for the purported unavailability was not presented to the trial court. The Court of Appeal affirmed the trial court's denial of a continuance, observing that no "real facts" had been presented to the trial court concerning unavailability and that "there is no indication that Nguyen's witness was under subpena." ( Id. at p. 18.) Pham emphasizes that the party seeking a continuance must establish good cause as described in section 9 of the Standards of Judicial Administration.