to the arguments at the hearing on the motion to set aside the judgment. As a result, Fidel’s arguments on appeal were properly preserved. See DeFillippo v. Neil, 2002-NMCA-085, ¶ 12, 132 N.M. 529, 51 P.3d 1183 (stating that the primary purposes of the preservation rule are to alert the trial court to the potential error so the court has an opportunity to avoid mistakes and to give opposing parties a fair opportunity to meet the objection); Gracia v. Bittner, 120 N.M. 191, 195, 900 P.2d 351, 355 (Ct.App.1995) (stating that “the preservation requirement should be applied with its purposes in mind, and not in an unduly technical manner to avoid reaching issues that would otherwise result in reversal”); cf. In re Estate of Keeney, 121 N.M. 58, 60-61, 908 P.2d 751, 753-54 (Ct.App.1995) (<HOLDING>). Standard of Review {14} Ordinarily, when a
holding that information contained in affidavits and depositions submitted as attachments to a memorandum were properly before the trial court and appellate court for purposes of a motion for summary judgment holding that when the trial court proceeded to consider affidavits submitted with motion to reconsider summary judgment the affidavits were properly before the appellate court for purposes of reviewing the propriety of the trial courts grant of summary judgment holding that trial court may not grant summary judgment by default  when the movants summary judgment proof is legally insufficient holding that the trial court may not grant summary judgment on a ground not raised in the motion holding that an appellate court reviews a trial courts grant of a summary judgment motion de novo because it is a question of law