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Charge of domestic assault withdrawn prior to trial date. H.D. was in the midst of a highly contentious separation and in order to remove him from the matrimonial home, the complainant made a allegation of domestic assault. Joseph Neuberger was retained as the defence lawyer. After reviewing the statement of the complainant, Joseph Neuberger drafted a memo on the massive inconsistencies and implausibility of the allegations and disclosed the memo to the Crown. After discussions with the Crown, the charge was withdrawn and the client entered into a common law peace bond.