This is not the way to write a motion. The way to do it is to state the facts in a way that the facts speak for himself.
The fury and emotion of the lawyer should NOT be showing through.
Clark should have just stated his case for removal and left the ranting out of it. His case for removal isn't actually that bad, but you wouldn't know it from this motion.
I give this motion a D-. It's a confusing incoherent mess.