Most courts’ rules require that any brief of ten or more pages have a table of contents and a table of authorities. Based on this image I got from an anonymous source, this brief was less than ten pages long, but its author (I’m guessing) had some issues with formatting the sections and/or page numbers:

Of course, there’s no rule saying you can’t have a table of contents for shorter briefs, so he or she could have just put in the table. But then if you don’t know how to fix page numbers, doing a TOC is probably out of the question.

The author at least deserves credit for being candid.