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Charges of Domestic Assault x 3, and Threaten Death, withdrawn in the Ontario Court of Justice, Scarborough, at trial. The complainant had charged the client on four (4) previous occasions and each time sought that the accused ought to receive a peace bond. On this occasion, an argument erupted regarding my client wanting to end the marriage. The complainant had discovered a letter noting that A.F.S. had retained a family lawyer. The complainant called police and alleged new Assault and Threatening charges. Joseph Neuberger was retained as the criminal lawyer Toronto on the file. Joseph Neuberger sought disclosure on all of the prior charges and subpoenaed the pictures of the client’s injuries from one occurrence and obtained the Affidavits of the complainant provided on two of the prior charges were the complainant averred that she fabricated the allegations to avoid being charged by A.F.S. It appears that A.F.S. had indeed been assaulted more than once by the complainant. Once all of this material was gathered, defence lawyer Joseph Neuberger disclosed the material to the Crown. Oddly the Crown at first took the position that the evidence was collateral and not relevant. Joseph Neuberger responded that a pattern of fabrication cannot be “collateral” and is a direct impugnment of the complainant’s credibility. At trial, further discussions took place and eventually all charges were withdrawn.