1. Appellees, UNITED STATES, Intervenor

2. The addition of an intervenor with full rights should be reserved for exceptional situations.

3. The administrative appellant, intervenor appellant, or administrative appeal representative states the issue of fact and the issue of law.

4. The OIC Staff and Intervenors' failure to agree to or offer Counterproposals for discovery is yet another example of their obstructionist tactics in this litigation

5. The administrative appellant, intervenor appellant, or administrative appeal representative may file an application for view, cite or copy for such evidence materials stipulated in last Paragraph.