.13 Appeals From Proposed Orders of Hearing Examiners.

A. A party noting an appeal to the Commission from a Proposed Order of Hearing Examiner shall, within 10 days after filing a Notice of Appeal, file with the Commission, and serve on all other parties, a Memorandum on Appeal. A Reply Memorandum may be filed in response to a Memorandum on Appeal within 20 days after the date of the filing of the Memorandum on Appeal. Further response will not be entertained unless the Commission orders otherwise.

B. Memorandum on Appeal.

(1) A Memorandum on Appeal shall contain:

(a) A short statement of the case;

(b) A summary of the basic position of the party filing;

(c) The grounds upon —which the appeal rests; and

(d) The argument in support of the appeal with appropriate references to the record and legal authorities.

(2) In addition, a party may, in a Memorandum on Appeal, set forth proposed specific findings which it considers to be supported by the record in the proceedings. A Reply Memorandum shall generally follow the same style prescribed for a Memorandum on Appeal, but may omit a statement of the case if it was correctly stated in the Memorandum on Appeal.

C. A Memorandum on Appeal and a Reply Memorandum shall be self-contained and limited to 15 pages in length, provided that for good cause the limitation on length may be altered or waived for either class of memorandum upon application to and order of the Commission within the time limit for filing of the respective memorandums. Nine copies of the memorandum shall be filed with the Commission.

D. There shall accompany and be attached to each Notice of Appeal, Memorandum on Appeal, and Reply Memorandum a Certificate of Service stating that the document has been served on every other party to the proceeding.