Moving party reply factum
The moving party may serve a reply factum to address any new issues raised in the responding party's factum. The factum shall contain consecutively numbered paragraphs setting out the moving party's position on the issue, followed by a concise statement of the law and authorities relating to it.
The moving party shall file three (3) copies of the reply factum with proof of service within ten (10) days after the service of the responding party's factum.
The moving party may serve a reply factum to address any new issues raised in the responding party's factum. The factum shall contain consecutively numbered paragraphs setting out the moving party's position on the issue, followed by a concise statement of the law and authorities relating to it.
The moving party shall file three (3) copies of the reply factum with proof of service within ten (10) days after the service of the responding party's factum.
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so, i can only respond to new issues raised in the factum.
and there are quite a few, actually - they essentially filed a report. if there was ever a time for a reply factum, this is it.