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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 have
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