You consider tracking the rule in your responding letter, figuring that (a) by tracking the rule, you will invoke its power, and (b) in tracking it, you cannot be accused of misquoting or mischaracterizing it. So you draft the argument as follows:
The submission of this unreported opinion was untimely because it was sent to the Court pursuant to Rule 2:6-11(d), which permits parties without leave of court to serve and file a letter calling to the Court’s attention and briefly describing any relevant case decided after the filing of the briefs. [Emphasis in original].
The rule says all that, but you don’t have to. You could say less to better effect:
The submission of this opinion was untimely because Rule 2:6-11(d) permits reference without leave of court only to cases decided after the briefs are filed.
