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3. By incorporating briefs not in the record in this case, the Appellee has circumvented <br />C.A.R. 57, limiting incorporation by reference of other briefs; C.A.R. 28(g), limiting the <br />Answer Brief's length; C.A.R. 28(a)(4), requiring the brief to contain the argument; and <br />C.A.R. 28(c) by, in effect, filing two (or more) Answer Briefs by "incorporation" in one <br />case. <br />4. C.A.R. 57, referring to appellate briefs in general, prohibits the incorporation by <br />reference of briefs previously filed in the lower court. If the incorporation by reference of briefs <br />previously filed in the lower court is prohibited, then clearly incorporation by reference of briefs <br />filed in separate cases by amici must be prohibited. See e.g. Fulton Inv. Co. v. Farmers' <br />Reservoir & Irrigation Co. 231 P. 61, 76 Colo. 472 (1925) (abuse of [different, but analogous] <br />rule adopting wholesale, all allegations of previous cause of action, relevant and irrelevant, so as <br />to make uncertain what pleader intends to use, will not be considered on appeal). <br />5. . C.A.R. 28(g) states that the Answer Brief should be no more than thirty pages. <br />Incorporating legal issues from separate briefs in other cases is an abuse of C.A.R. 28(g). This <br />unlawful incorporation would extend the Answer Brief far in excess of the limits of C.A.R. <br />28(g). The page limitations of C.A.R. 28(g) serve a useful purpose in preventing abuse of <br />process. People v. Rodriguez 914 P.2d 230, 248, fn. 8 (Colo. 1996); People v. Galimanis 728 <br />P.2d 761, 763 (Colo. App. 1986). When the "incorporated" pages are included, the Answer Brief <br />is both impossible to read and impossible to count. <br />6. Finally, by incorporating briefs filed in other cases, the Appellee has, in effect, filed <br />multiple answer briefs. C.A.R. 28(c) provides that "[n]o further briefs may be filed except with <br />leave of court." <br />W <br />