- 7 - made it virtually impossible for the Court to verify any of their proposed findings that were objected to by respondent, and because they have violated Rule 151(e)(3), the Court, in making its findings, has disregarded all of petitioners' proposed findings to which respondent has objected. Respondent's briefs comply with Rule 151. In respondent's opening brief, respondent makes proposed findings of fact. In petitioners' answering brief, petitioners object to many of respondent's proposed findings of fact and provide alternatives thereto. The section of petitioners' answering brief entitled "Petitioners' Response to Respondent's Proposed Findings of Fact" is 64 pages long and contains both objections and alternatives. That section contains no citations to the record, either in support of objections or in support of alternatives. Following that section of petitioners' answering brief is a section entitled "Argument", the first subsection of which is entitled "The Proposed Findings of Fact". That subsection purports to deal with both respondent's proposed findings of fact and petitioners' "alternate" proposed findings of fact. That subsection is 751 pages long. It in no way complies with the instruction of Rule 151(e)(3) that proposed findings of fact "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." While the subsection does make reference to the record, in some cases those references are incompletePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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