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. - • i <br />ducted their case. Two <br />first. with almost every <br />to add new issues to the <br />no support in the record <br />that record and. in many <br />before the board. <br />factors are especially relevant: <br />successive filing. plaintiffs sought <br />case. and second. these issues had <br />and were conclusively rebutted by <br />cases. by plaintiffs' own testimony <br />The first of these points is addressed in detail in <br />the affidavit of Paula C. Phillips. attached hereto as exhibit <br />A. This affidavit traces the issues addressed in plaintiffs' <br />major filings. Particularly noteworthy in this context are <br />"Plaintiffs. Memorandum Brief in Support of Their Notion <br />for Summary Judgment and Reply Grief." filed on cr about <br />November 22, 1982• which raised for the first time at least <br />eleven new issues or arguments, all of which were groundless. <br />and plaintffs• "Memorandum Brief in Support of Motion to <br />Alter on Amend Judgments" filed on or about March 1. 1983, <br />which. even after final judgment. raised at least nine new <br />and equally frivolous issues. 2/ See Affidavit of Paula G. <br />Phillips (exhibit A~. para. 8 at 2-3. para. 11 at 4-5. <br />Plaintiffs' summary judgment brief necessitated a 41 page <br />response by defendants. the unusual length and detail of <br />which were a direct result of the fact that plaintiffs' argu- <br />ments had consistently ignored or misstated the records <br />facts. See "Defendants' Memorandum Brief in Opposition tc <br />-6- <br />