It sounds from your description like this is not just an expired plates citation but also a no operator's license. It is best to speak with an attorney. Under the revised laws the no operator's license can carry 2 points and depending on the municipality is likely a first degree misdemeanor which can be punished bu up to six (6) months in jail. The expired plates charge under the new law may be a two (2) point violation on its own as it is fairly unclear based upon the statutes whether this is now considered a moving violation or not. I would tell your friend to speak with an attorney to discuss their options.