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Charges of Utter Death Threats x 3 withdrawn in the Ontario Court of Justice prior to trial. P.A. was in the midst of separation from his wife. During three separate arguments, the complainant recorded P.A. making threats. The complainant went to police and P.A. was charged. At the same time, the complainant retained family law counsel and filed an application for sole custody of their one child. Joseph Neuberger was retained as defence counsel. Joseph Neuberger obtained the recordings and transcribed them. Defence lawyer Joseph Neuberger also obtained medical records of P.A. that demonstrated around the timing of the impugned arguments, P.A. had been sleep deprived, and suffering extreme anxiety. P.A. was sent to a forensic social worker for assessment and therapy. After extensive therapy, a report was furnished to the Crown. Joseph Neuberger negotiated a withdrawal of all charges in exchange for the client signing a common law peace bond. As such, all charges were withdrawn.