Most appellate counsel would not wish to be on the receiving end of a footnote like this one in Treasure Lake Property Owners v. Meyer, 832 A.2d 477 (2003):
“We also note with disapproval that [appellee] cited and attached to its brief an unpublished memorandum of this court. Superior Court Internal Operating Procedure Section 65.37 provides that, except in circumstances related to law of the case, res judicata, and collateral estoppel, ‘an unpublished memorandum decision shall not be relied upon or cited by a court or a party in any other action or proceeding.’”
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