In Hawkins v. Wilton (2006) 144 Cal.App.4th 936, the defendant and moving party failed to set forth sufficient facts in its moving papers to negate every theory of liability alleged in the plaintiff's complaint. (Id. at p. 943.) The plaintiff, however, in addition to pointing out that defendant's proffered facts were insufficient to support summary judgment, tendered additional facts in his opposition papers. (Id. at p. 942.) The trial court apparently relied upon facts not set forth in the defendants' separate statement. (Id. at p. 945.) (Although it is not clear from the opinion, the additional facts were apparently those tendered by the plaintiff in opposition.) In doing so, the trial court "disregarded the statutory framework of summary judgment and improperly shifted the burden to the plaintiff." (Id. at p. 943.) The Hawkins court turned to the question of whether the error was prejudicial under the constitutional standard for harmless error. (Hawkins, supra, 144 Cal.App.4th at pp. 947-949.) It began by stating: "It has been said that the erroneous granting of a summary judgment motion 'lies outside the curative provisions' of the harmless error provision of the California Constitution because such an error denies a party of its right to a jury trial." (Id. at p. 947) Nevertheless, Hawkins continued, "purely technical errors in granting summary judgment can be found harmless." (Hawkins, supra, at p. 647.) As an example of such a harmless, technical error, the Hawkins court cites to Byars v. SCME Mortgage Bankers, Inc. (2003) 109 Cal.App.4th 1134, 1146, which held that the failure of the trial court to comply with the requirement that it state its reasons for granting summary judgment was harmless. (Hawkins, supra, at pp. 947-948.) The court then considered whether to review the plaintiff's evidence and the defendant's reply "in an effort to salvage the judgment" (Hawkins, supra, 144 Cal.App.4th at p. 948); that is, whether it should examine the entire record to determine whether there was a triable issue of material fact and that the moving party was entitled to judgment as a matter of law. The Hawkins court concluded that such a task "would be inappropriate." (Ibid.) The court explained: "First, it would encourage sloppy motion practices. Second, it casts an unfair burden on this court. Third, most importantly, in these circumstances the plaintiff was unfairly placed on the defensive and we simply cannot say that he was able to muster his best case in reply." (Ibid.)