Craft an argument --- using legal precedent --- that the charges leveled against, our client, Mr. Robert James do not rise to 1) "life threatening deficiencies"; or 2) "pose a serious threat to the public's health and safety," as detailed in the annexed charging document. Essentially, the Government is maintaining that --- the presence of bed bugs and mice (likely the two most difficult charges to overcome) along with a dirty lamp shade, a light bulb that went out, a missing closet door knob, a broken handle on a dresser drawer, etc., etc. --- meet the definition as stated in 22-B Section 3104.4 and 22-B Section 3107.1 of DCMR.
The Memorandum should argue that those items, assuming that they have been proven --- but especially if now remedied --- do not constitute "life threatening deficiencies," nor do they "pose a serious threat to the public's health and safety." I would need the Memorandum within seven days and would need to know the price points. The Charging Document is annexed