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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 incomplete
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