“Those officers could have and should have exercised greater diligence in verifying and determining the true whereabouts of a known convicted felon serving a probated sentence in another state. At the very least, alleging that Dale Barlow was located on the YFZ Ranch — without checking with the Arizona Probation Office these officers knew to be supervising him — constituted a reckless disregard for either standard law enforcement protocol or common sense,” reads Goldstein’s request for a hearing to investigate the issuance of the search-and-arrest warrants.

“Moreover, prior to executing the initial warrant, (Schleicher County Sheriff David Doran) was advised that Dale Barlow was in Arizona and not on the premises sought to be searched. In fact, prior to entering the premises Sheriff Doran actually spoke to Dale Barlow in Arizona by cell phone, confirming his driver license number and the fact that he was in Arizona.”

And about that cell phone call from a woman in Colorado Springs:

“The veracity of the factual underpinnings for any probable cause in support of (one of the search warrants) is further undermined by the revelation that the telephones utilized by the alleged sexually abused, pregnant, 16-year-old mother claiming to be Sarah Jessop to contact the New Bridge Family Shelter ‘Crisis Hotline’ in San Angelo, Texas, have been traced back to a 33-year-old, childless African American woman in Colorado Springs, Colorado,” Goldstein states.