strictly speaking, i should probably file a motion to reject the factum.

it's twice as long as it should be. and, it's introducing a completely different argument.

but, let's remember what i filed - i filed a request for certiorari due to the incompetence of the oiprd. and, they're arguing that the court doesn't have jurisdiction for that, but that's what certiorari is - it's a rule that the higher court has jurisdiction to pull the file. they're essentially denying the basis of certiorari, on what i don't know, but it's particularly weird in context, because it's actually statutorily enshrined. i'd be perfectly happy to argue that certiorari is an unwritten constitutional convention, but i don't have to - it's stated explicitly in the judicial review act. so, this idea that there's no statutory power is wrong, too.

so, i'd rather address these arguments than reject them. this is what the case is about, so let's address the issues rather than ignore them.

to put it another way, had they done this right in the first place, my original factum would have looked a lot like the reply factum that i'm going to file.

so, i'll point that out.  but, i feel the need to take this on head first.