I cannot read a draft and comment on it in detail but glancing over it it looks fine. Remember to be very careful to always provide a reference where indicated – whenever you give a statement of fact or of law. I also just happened to see for example on your first page a sentence that said ‘Someone said that…’ You cannot do that, you have to give a name and a reference for whatever this person said. If it is not something that someone said but your own opinion/understanding, rather say: “It is submitted that…”