[brief] Plaintiff/Appellant, [...] ("[...]") makes three points in its appeal.  The first discusses the alleged negligence of the Defendant/Respondent [...] ("[...]").  The second relates to the Respondent's general obligations, and the third discusses the standard under Rule 4:50.  In all of these arguments, Appellant's claims are without merit or legal basis.  The negligence of Respondent, in addition to not being raised below, is without any actual proof or citation to the record.  With regard to the negligence claim, Appellant failed to satisfy the plain error standard of review.  For all of these reasons, this argument does not provide a basis for the requested relief.  Relative to the argument concerning the obligations of the [...], again, Appellant's arguments are without analysis.  They are discussions about a condominium association's obligations generally and not [...]’ responsibilities in this specific case.  There is no support or justification for the claims made by Appellant.  Appellant's Preliminary Statement is replete with lots of claimed facts without any actual proof of their accuracy or support for them.  Appellant discusses Hurricane Ida and the response along with statements about what Respondent "apparently recognized."  (App. Brief, p. 2).  There is a discussion of subsequent remedial measures in terms of repairs, and an argument that they should have taken place beforehand.  In reply, Respondent notes that Appellant has provided no substantiation for the claims in the Preliminary Statement.  There is no report attached and no depositions were taken in this case.  Despite some nineteen months of motion practice, and the fact that these arguments were made repeatedly, Appellant has failed to substantiate any of them.  Appellant has failed to meet the standards required pursuant to Rule 4:50(a) or (f), to warrant the relief being sought.  The Motion to Vacate was not supported by a Legal Brief, and the underlying Motion was not opposed, which creates a standing issue.  Substantively, there is no enunciation of how the excusable neglect standard relative to subsection (a) or the catch-all under subsection (f) has been met now and was met below, to warrant a reversal of the June 9, 2024 Order.  In terms of substance, the present appeal must fail.  The Motion to Vacate under Rule 4:50 was procedurally and substantively deficient.  Although prior counsel had more than three months to re-file and correct those deficiencies, they chose not to do so, and this appeal now follows.  Appellant's Brief is replete with arguments posited but devoid of any citation to the record, as well as any application of the specific legal support for the arguments being made.  Simply making a statement or advancing an argument without factual support in the record or a citation to any legal support deprives the Respondent of the ability to properly respond, instead forcing it to hypothetically argue in the negative.  It is submitted by doing so, Appellant affords itself the ability to articulate legal underpinnings in its Reply Brief while depriving Respondent the ability to combat these arguments in writing.  Same should not be countenanced.  As such, for the same reasons that Order of March 1, 2024, was granted, it is respectfully submitted that the present Appeal should be denied in its entirety and the Order of March 1, 2024, be allowed to stand.