May 2nd 2022
Reckless Endangerment of Child
Out-of-State Warrant Removal
Client was super person, super mom, and super everything. She did everything right and inspiring in every way. She was living afar in another state in a productive job, productive relationship, and productive and supportive mother to her children. However, there was one thing that had been plaguing her which she knew she had to address which was an open warrant for child neglect from years ago. Client was very understanding, patient and organized. She kept outstanding notes from this event from nearly ten years ago. However, removing a warrant can be difficult when the person resides out of state and there is no provision for removing a warrant—unless the person is present. Attorney Barabino explained to client that he would try to remove the warrant without her presence, even though there was no provision for doing so. In preparation of this, he drafted a background memorandum on client on her entire life and the unique facts of her prior default and the circumstance of the underlying matter. He also produced several affidavits in support of this request and finally, he developed a full-blown exhibit to bring into the removal. He went to hearing and was initially denied the request, but after explaining the unique circumstances, it was permitted, and the warrant was removed without client having to fly across the country. Once completed, they arranged for another court date via zoom and resolved the matter with a pre-trial probation for 180 day which means she never returns to court, pays no money, and most importantly the matter is completely dismissed and she admitting to NO wrongdoing or criminality.
RESULT: Warrant removed Without Going to Court. Zero Admission of any Wrongdoing.
