202.5—Replies and requests that review not be exercised—content.
Replies and requests that review not be exercised shall contain in the order here indicated—
(c)
Where deemed necessary by the submitting party, a concise summary statement of the case explicitly pointing out any inaccuracy or omission in the statement of the other side, with references to the record where appropriate;
(d)
A listing of the reasons why review should not be exercised, each reason set forth in a separate, numbered paragraph;
(e)
The argument generally amplifying the material in paragraph (d) of this section and, in addition, specifically replying to the points of law, policy and fact presented by the other side (each stated separately) citing the authorities, statutes, and other material relied upon by the submitting party;
(f)
A conclusion, specifying with particularity the action which the submitting party believes the Secretary should take.