Sections of a closing:

1) What this case is about

2) Theory of the case
3) What did you prove under the law
4) Major facts that support you side
5) Ask the judge to side with you
Note to self, if the document
Theme First:
Reputation over what is best for people.
Your honor, throughout these past 2 hours, the claimant has been
able to demonstrate a very specific fact pattern in this case. The defense
consisting of Mr Ward and supporters of his investigation, repeatedly
ignored evidence and testimonies proving Harley’s residence for the past 2
years in his aunt’s apartment. Letting the bias and personal prejudice of Mr
Ward, control the forefront of the investigation instead of making a rational
decision based on the facts presented. This is the story of government
employees, failing at their duties and using the bias against Harley to cover
it up.

In 2016, after living in multiple flop houses and with friends, Harley
was able to reestablish contact with his great aunt Barbara Stone. Moving
in to assist with her care, Harvey ran into legal trouble earlier after
commiting a crime of poverty. This led to Page fibbing to the court about
Harleys current living details in an attempt to lessen his sentence and be let
off with a slap on the wrist.

Returning to society after his sentence, Harley would routinely talk to

his neighbor Finley adams who had no issue with Mr. Davisons criminal
background and allowed them to foster a friendly relationship. Only living
outside his apartment for brief periods of time with his Fiance, mainly
during arguments with his aunt. Did not change his primary residence to
that of one outside his aunt's apartment. This continued for 2 years until
filing for inheritance of the apartment on april 2nd 2018 and denied.
 Under the law, the claimant has proved beyond a preponderance of
the evidence that: The DHPD’s arbitrary and capricious actions, used an
abuse of discretion when deciding to approve Harleys application for
inheriting his aunt's apartment.

In Ward v City of Long Beach, the case outlines that an action is

arbitrary and capricious when: it is taken without sound basis in reason or
regard to the facts. We have outlined this by showing that when ignoring
multiple supporting facts supporting Harleys case, the DHPD, went out of
their way to find their own selective witnesses, and ignored specific
documentation submitted when opening their investigation.
Their mind was made up before the investigation had begun.

As heard throughout Blake wards cross, there was a heavy slant

when it came to interviewing anyone who could testify on Harleys behalf.
Not only pressuring and then ignoring the statements made by one of
Harleys corroborators. Mr Ward's refused. to interview Mr. Davison or his
fiance page based on their backgrounds.

In Sages case, he did not interview him because of the fact that he
was her fiance, his title instantly disqualified him in Mr. Wards eyes. And in
Harley’s case, he was a criminal. We heard from Wards that he thought
Harley was a leech on society, the type of person the DHPD does not want
in their municipal housing program. Is this the man who is in charge of
determining who gets housing and who doesn’t? Someone who would let a
personal vendetta be judge jury and executioner of another person's life. It
is not the role of the DHPD to determine whether someone is morally fit to
be a part of their housing program. It is their job to review evidence and
facts that lie on both sides of the issue, a job the DHPD did not do.
 However among those Wards did interview is where we see the true
scope of his investigation. In Finley's direct we heard that he did see Harley
live in the apartment leaving and entering with his own key. Wards admitted
to while interviewing Finley adams, a senior citizen who when took his time
to answer, was pressured to respond. Attempting to rush the one person he
interviewed who actually corroborated Harleys story, something he did not
do to anyone else.

The second person he interviewed was Rivers Ebb. Barbara Stone’s

nurse who called Harley a lowlife and a thief speaking only negatively
towards her. Someone who was reaffirmed that Harley did not live in her
apartment but only spent 2 hours a day in her apartment at a time where
almost no person would still be at home.

And now the third person, Tatum Neal. A probation officer who while
failing to do his job, never considered it worth his time to confirm Harleys
address. Hearing on cross that he considered his job nothing more than
paper pushing and coffee klatches. Someone anxious for retirement and
because of it, did not fulfill his job as Harleys probation officer. However
even though this is true, Wards who is admittedly good friends with Neil,
valued his statements far above the rest while these facts was present.

Wards investigation was undoubtedly so skewed, that obvious and

blatant flaws in each of his supporters stories were seen as pure fact, with
Finley's being the only outlandish claims in Wards eyes.

And the story of government employee failure doesn't end here.

When filing for inheritance, Harley testified accurately that each step:
on time, properly, and orderly in the application. Harley also submitted
other documentation, including a DHPD document that his aunt Barbara
Stone, signed and submitted, indicating Harleys rights to succession to his
aunt's apartment corroborating with everything his story has told us. During
Mr. Ward’s investigation, he valued the authenticity of a lease signed
before Harley was born, over this document. Your honor can you not see
the ludicrousy in that statement? A lease signed before a man was born
was valued more than a DHPD document signed by his Aunt, saying he
lived in and was entitled to that apartment.

Thrash Defense:

Knowing these facts your honor, we ask that you side with the
claimant showing that the actions taken by the DHPD were indeed arbitrary
and capricious during their investigation, thankyou.

On the other side you heard from 3 extremely biased witnesses.

Take every important thing and make it humanizing.
LOTS of Pathos
Take everything from cross and put it together.

Pre Trial Motions

Constructively Sequestered.
Hand out Rosters.
Move about the well
We would like to request a 5 minute break between opposing counsel