(1) Plaintiff’s Proposed Findings of Fact. Plaintiff must organize proposed findings of fact as follows: In consecutively numbered paragraphs and simple declarative sentences, plaintiff must set forth all of the facts relied on in support of plaintiff’s claim for relief. Each finding must reference in parenthesis the supporting trial exhibit and/or pages in the trial transcript.
(2) Plaintiff’s Proposed Statement of Conclusions. Plaintiff’s statement of conclusions must set forth all conclusions necessary to demonstrate liability. Plaintiff must consecutively number and clearly and concisely state each conclusion. Plaintiff must include only one conclusion per paragraph, and must include a supporting citation to legal authority for each conclusion.
(3) Defendant’s Proposed Findings, Conclusions, and Response. Defendant must prepare its proposed findings and conclusions in the manner described above. In addition to its own proposed findings and conclusions, defendant must respond to plaintiff’s proposed findings and conclusions. Each response must bear the same number as the proposed finding or conclusion to which it is addressed.
(b) Definitions. As used in Rule 52.1(a), the term plaintiff includes plaintiffs as well as counterclaimants, crossclaimants, intervenors, and any other parties who assert affirmative claims for relief. The term defendant includes defendants as well as counterclaim defendants, crossclaim defendants, and any other parties who are defending against affirmative claims for relief.
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