A totality of facts assumes that facts can be totalised, but there are
at least two sorts of fact that cannot be so processed. Such facts as
these can be found as -

1) Emergent properties. For example, the totality of cows may or may not
result in the fact of a herd. Again, a collection of knives, forks and
spoons may not appear as a set of cutlery. Finally, the aesthetic
experience we may get from a painting is not a totality or summation of
the paintings aesthetic, sensory properties.

2) Manifesting conditions. That is, conditions that need to be in place
for objects to arise. Possibly the best example I can give comes from
Kant whose 'intuition' is the name for the conditions through which
objects are made manifest. These conditions, appearing as space, allow
'differences'. Without difference objects could not appear.

Of course, we can say that emergent properties and manifesting
conditions ARE facts, and that we can include these in a totality.

The
problem with that idea is that we have to reduce them to grammatically
empty marks so that we can cram them into a list of objects to which
they cannot belong. We might object that the elements in a list of facts
don't need to be related. But then we undermine the idea of a list. A
list requires conditions for its particulars. The fact that this
condition is that its particulars are 'facts' doesn't square with the
idea of totalisation.