MEMORANDUM OF POINTS AND AUTHORITIES
STATEMENT OF FACTS
We represent Joe David, a 25-year-old single father of three children (ages 1, 3 and 11). Joe is a low-income, high-school educated public school bus driver whose case we have taken pro bono, in an action against Sovereign Auto Store (Defendant), a used car dealership in Columbia. Joe visited Defendant to purchase an SUV in July 2009. Disregarding Joe's $200 per m...
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