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<br />Plaintiffs' Motion for Summary Judgment and in Further Sup- <br />port of Defendants' Motion for Summary Judgment." For the <br />same reasons -- plaintiffs' assertion of new issues and per- <br />sistent disregard for the record -- defendants took the <br />unusual step of responding to plaintiffs' motion tc alter <br />or amend Judgment and supportin5 memorandum. fee "Defen- <br />dants' Response to Plaintiffs' Motion to Alter or Amend Judc- <br />ment." <br />The frivolousness of plaintiffs' myriad issues and <br />hence of their conduct of this litigation has been amply <br />addressed in defendants. prior filings in this case and <br />neeA not be discussed further here. It is sufficient for <br />present purposes to note that the time devoted to this <br />litigation by defendants' attorneys was in major part a <br />direct and unavoidable consequence of the manner in «hich <br />plaintiffs proceeded. Plaintiffs should not be heard now <br />to assert that defendants took their case too seriously. <br />Indeed. plaintiffs' position that defending against Frivolous <br />arguments or claims should not require much effort i5r.cres <br />an important distinction between an assertion that is ground- <br />less on its face and one that. by either misstating, or fail- <br />ing to acknowledge the facts. seems facially plausible or <br />even persuasive but is conclusively refuted by the reccrd. <br />The arguments to which defendants have objected are in the <br />-T- <br />