Within 20 days after receipt of the transcript of the testimony,
each party and amicus may file a brief. Such briefs shall be served
simultaneously on all parties and amici, and a certificate of service
shall be furnished to the Administrative Law Judge. Requests for
additional time in which to file a brief shall be made in writing, and
copies shall be served simultaneously on the other parties. Requests for
extensions shall be received not later than 3 days before the date such
briefs are due. No reply brief may be filed except by special permission
of the Administrative Law Judge.