![]() (c) Each defendant’s answering proposals shall correspond to plaintiff’s proposals: Each paragraph shall be followed by citations of authorities in support thereof. Such contentions shall be separately, clearly and concisely stated in separately numbered paragraphs. (2) Plaintiff’s statement of legal contentions shall set forth all such plaintiff’s contentions necessary to demonstrate the liability of each defendant to such plaintiff. It shall be so constructed, in consecutively numbered paragraphs (though where appropriate a paragraph may contain more than one sentence), that each of the opposing parties will be able to admit or deny each separate sentence of the statement. It shall, so far as possible, contain no pejoratives, labels or legal conclusions. It may contain references in parentheses to the names of witnesses, depositions, pleadings, exhibits or other documents, but no party shall be required to admit or deny the accuracy of such references. It shall be complete in itself and shall contain no recitation of any witness’ testimony or what any defendant stated or admitted in these or other proceedings, and no references to the pleadings or other documents or schedules as such. (1) Plaintiff’s narrative statement of facts shall set forth in simple declarative sentences all the facts relied upon in support of plaintiff’s claim for relief. (b) Plaintiff’s proposals shall include (a) a narrative statement ofĪll facts proposed to be proved and (b) a concise statement of plaintiff’s legal contentions and the authorities supporting them: Each defendant shall then provide the court with answering proposals, which shall have been served on each plaintiff. (a) Plaintiff shall first provide the court with proposed findings and conclusions, which shall have been served on each defendant. ![]() GUIDELINES FOR PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW ![]()
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