A respondent's references to statutes and transcripts in an outline of argument on appeal do not trigger the obligation to file a notice of contention under UCPR r 757 where those references are responsive to the appellant's own citations or merely support statements about the parties' conduct below, rather than constituting reliance on grounds other than those relied on by the primary judge. Overlapping lists of authorities between parties do not contravene paragraph 16(a) of Practice Direction 3 of 2013.
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