- 6 - follow our Rules carefully as to the form and content of their briefs. Rule 151 concerns itself with briefs. Paragraph (e) of that Rule addresses the form and content of briefs, and directs that all briefs shall contain certain information. Subparagraph (3) of paragraph (e) directs that all briefs shall contain the following: Proposed findings of fact (in the opening brief or briefs), based on the evidence, in the form of numbered statements, each of which shall be complete and shall consist of a concise statement of essential fact and not a recital of testimony nor a discussion or argument relating to the evidence or the law. In each such numbered statement, there shall be inserted references to the pages of the transcript or the exhibits or other sources relied upon to support the statement. In an answering or reply brief, the party shall set forth any objections, together with the reasons therefor, to any proposed findings of any other party, showing the numbers of the statements to which the objections are directed; in addition, the party may set forth alternative proposed findings of fact. Petitioners have filed both an opening brief and an answering brief, as has respondent. Petitioners' opening brief fails to comply with Rule 151. In particular, it fails to comply with paragraph (e)(3) thereof. Following the heading "Petitioners' Proposed Findings of Fact" are 61 unnumbered pages, containing petitioners' proposed findings of fact. In support of their proposed findings of fact, petitioners fail to provide any references to either the trial transcript, exhibits, or stipulated facts. In her answering brief, respondent objects to many of petitioners' proposed findings of fact as not being supported by evidence in the record. Because petitioners havePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011