FRANKUM, Justice.
Rule 16 of this court provides that the brief of the appellant shall be divided into two parts; that "part 1 shall contain a concise statement of the case, including a statement of the reasons why the Supreme Court and not the Court of Appeals has jurisdiction, with citation of the part or parts of the record, and if possible the particular paragraphs thereof, showing such jurisdiction," and that "part 1 shall also contain succinct and accurate statements...
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