Another quirk of his at the time was that in general he refused to look at any memo submitted to him in writing if it exceeded one page. He required memos from his employees and advisors to be reduced to one page and he preferred that each memo deal only with one subject matter.

Oberly v. Howard Hughes Medical Institute, 472 A.2d 366, 374 (Del. Ch. 1984) (Brown, C.) (describing one habit of late billionaire, magnate, and crazy person Howard Hughes).