Marietta Parker Case No 07-20124-02-JPO Guy and Carrie Neighbors Motion To Revoke Bond Mental Evaluation Cause Hearing

Case 2:07-cr-20124-CM-JPO Document 165 Filed 04/27/2009 Page 1 of 9
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF KANSAS
(Kansas City Docket)
UNITED STATES OF AMERICA )

)
Plaintiff, )
)
v. ) Case No. 07-20124-02-JPO/CM
)
)
GUY MADISON NEIGHBORS, )
)
Defendant. )
UNITED STATES' RENEWED MOTION TO

REVOKE DEFENDANT'S BOND
or, IN THE ALTERNATIVE,
MOTION FOR MENTAL EXAMINATION AND
FOR SHOW CAUSE HEARING
Comes now the United States of America, by and through the undersigned
Acting United States Attorney and herein moves this honorable court to revoke the
defendant's bond for failure to comply with the terms of his pretrial release order in the
above-referenced cases or, in the alternative, moves for an order for a mental
examination of the defendant. In support of this motion, the government offers the
following:
Relevant Procedural Background

1. The United States incorporates by this references all claims and allegations
set forth in it's Motion to Revoke Bond (Document (Doc.) 65) and the exhibits filed
1
thereto (Docs. 66, 67), filed on May 1, 2008.
2. On July 18 and July 21, 2008, this Court conducted a hearing on that motion'
but before a decision was rendered on the issues, the parties submitted an agreed-upon
temporary restraining order "which specifically prohibits all parties in this matter from
making any statements, other than to members of the defendants' immediate family...
in writing, orally or by electronic dissemination, either personally or indirectly through
any party, including but not limited to any internet sites or through any form of
communication whatsoever which mentions the names of any witnesses, attorneys,
potential witnesses or of any persons associated with the investigation or prosecution"
of case No. 07-20123 and case No. 07-20073. (Doc. 118, p. 1-2).
3. On August 18, 2008, the provisions of the temporary restraining order were
made part of the conditions of the defendants' bond in the cases styled United States v.
Guy and Carrie Neighbors, Case No. 07-20124 (Doc. 132) and Case No. 08-20105-
01/02-CM/JPO. (Doc. 27) Each of those orders provided in pertinent part: "Conditions
of release in the Obstruction Case wil track those (which) have been previously set in
Case No. 07-20124 (the "EBayCase") (Docs. 5 and 9). In addition to those conditions,
defendants shall comply with the agreed restraining order in the EBay Case (Doc. 118)."
(Docs. 132 and 27, p. 2). The defendant, Guy Neighbors, has again2 failed to comply
with these conditions of his bond
J The United States requests the Court take judicial notice of all of the evidence
received at the hearing on that Motion.
-
2 See Doc. 128 and Doc. 142, Motions to Revoke Bond in Case No. 07-20124.
2
Violations of Conditions of Bond

4. On Wednesday, April 22, 2009, the defendant, Guy M. Neighbors, sent by
electronic mail, a message to various individuals under the heading "Lawrence Police
offcer Mike McAtee corruptly operates as a Federal agent crossing state lines to
interrogate and harass people for federal Prosecutor Terra Morehead." (Exhibit 1,
attached). Attached to that e-mail were various documents, one of which was entitled
"Notice of Motion Requesting a Change of Venue and to Have Both Prosecutors
Recuses (sic) Themselves from Said Cases as To Avoid the Appearance of A Conflict of
Interest."
In his e-mail message, the defendant reiterated statements that he knew to be
false, to wit:
1. Federal Prosecutor Terra Morehead sent Lawrence Police

officer Mike McAtee across state lines to the State of Florida, to
investigate with the Jurisdictions (sic) of a Federal agent.
2. Lawrence Kansas Police offcers Jay Bailek and Mickey Rantz

pose as FBI agents while conducting Federal investigations for Marietta
Parker and Terra Morehead in the Yellow House case, to cover-up for
missing evidence, search warrant & chain of custody violations and the
lack of FBI involvement in the case.
3. Kansas city FBI agent Walter Schaefer, poses as FBI agent Bob
Shaefer, to conduct fake FBI investigations outside of his agencies (sic)
juristictions (sic) to cover-up for Federal Prosecutor Marietta Parker, who
is conspiring to cover-up police misconduct.
The defendant is fully aware that all of the individuals mentioned in these paragraphs
are witnesses in the case or are attorneys representing the government. In light of the
un-controverted evidence received at the hearing on the government's first motion to
revoke bond and by his own admission that the allegations of sexual misconduct are
3
mere rumors, it is clear that the defendant intentionally and purposefully violated the
conditions of his bond. Therefore, the United States respectfully submits that Guy M.
Neighbors continues to engage in conduct that constitutes a violation of § 21-4004,
K.S.A., criminal defamation; of 18 U.S.C. § 1503, influencing an officer3; and of 18
U.S.C. § 1512, witness tampering. Without question, the e-mail sent by the defendant
on April 22, 2009, constituted a violation of the conditions of the defendant's bond and
establishes that he is unwilling to conform his behavior to the order of the court.
Therefore, the government requests that the defendant's bond be revoked and that he
be detained until the completion of the trial of this case.
Motion for Mental Examination
Should the Court determine that there is insufficient evidence of the intentional
violation of the terms of Guy Neighbors' supervised release, the United States
respectfully submits that the false statements the defendant published in his e-mail of
April 22, 2009, gives rise to the inescapable conclusion that he is currently suffering
from a mental disease or defect that prevents him from conforming his conduct to the
requirements of the terms of his pretrial release or that he suffers from a mental disease
or defect that causes him to be subject to delusions. Clearly, the defendant should
know that several of the above-referenced statements are not true because at the
3 The false allegations of professional and sexual misconduct by the prosecutors

taken together with the demand in the attachment to the e-mail, entitled "Notice of
Motion Requesting a Change of Venue and to Have Both Prosecutors Recuses (sic)
Themselves from Said Cases as To Avoid the Appearance of A Conflct of Interest"
indicates that the defendant continues in his attempts to prevent the attorneys for the
government from prosecuting the cases now pending against him, a clear attempt to
corruptly influence these officers of the Court in the lawfûl performance of their duties.
4
hearing on the government's first Motion to Revoke Bond, it was established that: all
physical evidence recovered during the investigation of this case is either in the custody
of the Lawrence, Kansas, Police Department or has been returned to the rightful owners
(Doc. 150, Transcript of Motions held on July 18 and 21, 2008, testimony of S.A. D.
Nitz, at pp. 217-18); that neither Offcer Bailek nor Officer Rantz posed as FBI agents
during the investigation of this case (Doc 150 at p 37-38, testimony of P.O.M. Rantz);
and that F.B.I. S.A. Walter Robert "Bob" Schaefer conducted an investigation of those
allegations and was unable to corroborate the allegation. See (Doc. 150 at p 186-192,
testimony of S.A. W. Schaefer).
In addition to the reassertion of these allegations, the defendant made false and
defamatory allegations of misconduct by the prosecutors in this case without any basis
in fact to support those allegations. In his e-mail of April 22, he states:
Where is the oversight of Government spending and constitutional

law that
WOLlld allow Federal Prosecutors in an abuse of power spend millions of
tax dollars investigating and prosecuting meritless cases, using defense
attorneys and law enforcement as their own personal pawns, operating
outside of their agencies jurisdictions and the law, crossing state lines,
City officers acting as Federal Investigators, repeatedly violating citizens
. (sic) Constitutional rights without consequence.
Now we are hearing rumor of a sex scandal involving high ranking
officials, the same officials who are the alleged violator (sic) of human
rights. Please we need a complete investigation into these two
prosecutors and the cases they have prosecuted.4
Ex. 1. These statements establish reasonable cause to believe that the defendant may
presently be suffering from a mental disease or defect such that he rendering him
currently unable to assist in his defense.
4 Counsel for the United States categorically and unequivocally deny each and
everyone of the allegations made against them in the defendant's e-mail of April 22nd.
5
Title 18, United States Code, Section 4241 (a) provides in pertinent part:
(a) Motion to determine competency of defendant - At

any time after the commencement of a prosecution for an
offense and prior to the sentencing of the defendant,... the
attorney for the Government may file a motion for a hearing
to determine the mental competency of the defendant. The
court shall grant the motion, or shall order such a hearing on
its own motion if there is reasonable cause to believe that
the defendant may presently be suffering from a mental
disease or defect rendering him mentally incompetent to the
extent that he is unable to understand the nature and
consequences of the proceedings against him or to assist
properly in his defense.
(b) Psychiatric or psychological examination and report.--

Prior to the date of the hearing, the court may order that a
psychiatric or psychological examination of the defendant be
conducted, and that a psychiatric or psychological report be filed
with the court, pursuant to the provisions of 4247(b) and (c.)
Title 18, United States Code, Section 4247 provides in pertinent part:
(b) Psychiatric or psychological examination. - A

psychiatric or psychological examination ordered pursuant to
this chapter shall be conducted by a licensed or certified
psychiatrist or psychologist, or if the court finds it
appropriate, by more than one such examiner.... For
purposes of an examination pursuant to an order under
section 4241, '" the court may commit the person to be
examined for a reasonable period, but not to exceed thirty
days, ... to the custody of the Attorney General for placement
in a suitable facility. Unless impracticable, the psychiatric or
psychological examination shall be conducted in the suitable
facility closest to the court.. The director of the facility may
apply for a reasonable extension, but not to exceed fifteen
days under section 4241, ... upon a showing of good cause
that the additional time is necessary to observe and evaluate
the defendant.
(c) Psychiatric or psychological reports. - A psychiatric or

psychological report ordered pursuant to this chapter shall be
prepared by the examiner designated to conduct the psychiatric or
psychological examination, shall be filed with the court with copies
6
provided to the counsel for the person examined and to the

attorney for the Government, and shall include--
(1) the person's history and present symptoms;
(2) a description of the psychiatric, psychological, and
medical tests that were employed and their results;
(3) the examiner's findings; and
(4) the examiner's opinions as to diagnosis,
prognosis, and--
* * *
(A) if the examination is ordered under

section 4241, whether the person is suffering
from a mental disease or defect rendering him
mentally incompetent to the extent that he is
unable to understand the nature and
consequences of the proceedings against him
or to assist properly in his defense....
Because of the defendant's most recent publication of information he knows to
be false, in violation of the clear and unambiguous language of the temporary
restraining order and the orders of the court relating to the terms of his pretrial release,
the United States submits that this conduct gives rise to a reasonable belief that the
defendant is currently unable to understand the proceedings and to assist in his own
defense. Therefore, the United States moves this Court for an order directing the
defendant to the custody of the Attorney General pursuant to 18 U.S.C. §§ 4241 4247
for a mental examination to determine if the defendant is suffering from a mental
disease or defect rendering him mentally incompetent to the extent that he is unable to
understand the nature and consequences of the proceedings against him or to assist
properly in his defense.
WHEREFORE, for the foregoing reasons, the United States respectfully requests
that this defendant be found in violation of the terms of the temporary restraining order
and his pretrial release conditions and, for the reasons stated in this motion and in the
7
government's prior Motions to Revoke Bond in Case No. 07-20124 (Docs. 64 - 66 and
129) and that he be detained. In the alternative, the United States respectfully requests
an order directing the defendant to the custody of the Attorney General pursuant to 18
U.S.C. §§ 4241 and 4247 for a mental examination to determine if the defendant is
suffering from a mental disease or defect rendering him mentally incompetent to the
extent that he is unable to understand the nature and consequences of the proceedings
against him or to assist properly in his defense.
Respectfully submitted,
s/ Marietta Parker. KS Dist. Ct. #77807

Acting United States Attorney
500 State Avenue; Suite 360
Kansas City, Kansas 66101
Telephone: 913-551-6730
Facsimile: 913-551-6541
E-mail: marietta.parker(gusdoj.gov
ELECTRONICALLY FILED
Attorneys for Plaintiff
Certificate of Service
I hereby certify that on the 27th day of April, 2009, the foregoing was
electronically filed with the clerk of the court by using the CM/ECF system which will
send a notice of electronic fiing to the following:
John Duma
303 E. Poplar
Olathe, KS 66061
Attorney for Defendant Carrie Marie Neighbors
8
. Case 2:07-cr-20124-CM-JPO Document 165 Filed 04/27/2009 Page 9 of 9
Cheryl A. Pilate
Morgan Pilate LLC
142 N. Cherry
Olathe, KS 66061
Attorney for Defendant Guy Madison Neighbors
I further certify that on this date the foregoing document and the notice of
electronic filing were mailed by first-class mail to the following non-CM/ECF participants:
None
s/Marietta Parker
Acting United States Attorney
9
Case 2:07 -cr-20124-CM-JPO Document 165-2 Filed 04/27/2009 Page 1 of 61
EXHIBIT 1
Case 2:07-cr-20124-CM-JPO Document 165-2 Filed 04/27/2009 Page 2 of 61
Lawrence Police officer Mike McAtee corruptly operates as a
Federal agent crossing state lines to interrogate and harass
people for federal Prosecutor Terra Morehead
Following a mistrial in Federal court, Lawrence Kansas Police offcer Mike McAtee traveled across
state lines into Florida acting in the capacity of a Federal agent to investigate, and harass family
members of Johnnie Wiliams, Zachary Wiliams and Terry McIntyre, for Federal Prosecutor Terra D.
Morehead. This took place after these three defendants already were forced by Prosecutor
Morehead to spend 2 years in segregation (because they refused to accept a plea deal) while
incarcerated in Leavenworth. Before finally going to the first trial which ended in a mistrial, second
trial was postponed, and a circuit Judge called in, and the original and second sentencing dates
have been postponed.
Attached are hand written notarized letters from five family members living In the State of Florida,
Lucinda Stallworth Zachary & Johnnie Willams mother, Elizabeth K. Richardson Grandmother of
Terry McIntyre, Johnnie Wiliams and Zachary W., Reina Mejia Zachary Willams girl friend, and
Devon Edwards Lucinda's sister and Terry McIntyre's mother.
These family members were interrogated by Lawrence Kansas Police Detective Mike McAtee
(operating outside of his local jurisdiction), acting in the capacity of a Federal Agent crossing state
lines, in a Federal Investigation under the direction of Federal Prosecutor Terra Morehead
prosecuting the Federal case involving Johnnie Wiliams, Terry McIntyre and Zachary Willams.
Questioning the appropriation of funds for travel expenses for a Lawrence Kansas Police offcer,
conducting a Federal investigation outside of his agencies Jurisdiction and across state lines?
Typically Federal Investigations brought before Federal Prosecutors for prosecution are handled by
a Federal Agency.
That is not the case for the Federal Prosecutors Marietta Parker & Terra Morehead in the Kansas
Department of Justice.
Protocol would be police Detective that works for one State, that needs to investigate matters in
another State would typically contact the police in that States to handle the investigation and then
compare notes. Or when the case crosses state lines the FBI would typically become involved in the
case.
In a pattern of conspiracy and cover-up between Federal prosecutors and Lawrence Kansas City
police:
1. Federal Prosecutor Terra Morehead sent Lawrence Police officer Mike McAtee across state lines to
the State of Florida, to investigate with the Jurisdictions of a Federal agent.
2. Lawrence Kansas Police offcers Jay Bialek and Micky Rantz pose as FBI agents while conducting
Federal investigations for Marietta Parker and Terra Morehead in the Yellow House case, to cover-
up for missing evidence, search warrant & chain of custody violations and the lack of FBI
involvement in the case.
3. Kansas City FBI agent Walter Schaefer, poses as FBI agent Bob Shaefer, to conduct fake FBI
investigations outside of his agencies jurisdictions to cover-up for Federal Prosecutor Marietta
Parker, who is conspiring to cover-up police misconduct.
4. In a case lacking merit or probable cause. Federal Prosecutor Terra Morehead has the Yellow
House owners Guy and Carrie Neighbors falsely arrested 3 times, repeatedly searched, and
incarcerated in Leavenworth Federal prison for 12 days on charges involving a state investigation
without merit.
2
S. Federal Prosecutors Terra Morehead & Marietta Parker in an abuse of power control defense
attorneys by forcing public defenders to sign her contract to not allow their clients access to their
own discovery, and cause "conflicts of interest" that lead to withdraw or mistrial by showing the
defendants attorneys secret Grand Jury information. They also threaten to pull paid defense
attorneys banking records, and they threaten them with money laundering charges if they do not
comply.
Where is the oversight of Government spending and Constitutional law that would allow Federal
Prosecutors in an abuse of power spend milions of tax dollars investigating and prosecuting
meritless cases, using defense attorneys and law enforcement as their own personal pawns,
operating outside of their agencies jurisdictions and the law, crossing state lines, City offcers
acting as Federal Investigators, repeatedly violating citizens Constitutional rights without
conseq uence.
Now we are hearing rumor of a sex scandal Involving high ranking offcials, the same offcials who
are the allege violator of human rights. Please we need a complete investigation into these two
prosecutors and the cases they have prosecuted.
P.S. The last two pdf files wil show a pattern of abuse by the Lawrence police offcers. The PDF file
of Jessica is her statement that offcer Jay Bialek and Offcer Mickey Rantz impersonated FBI
agents during their investigation of the yellow house store.
The last PDF file is a change of venue motion filed in the yellow house case and if you will take a
look at the last S-pages you wil see the formal complaints the inmates named in this letter filed in
their cases. These complaint wil show a pattern of abuse.
The only bad mistake is the one from which we learn- nothing.
Rediscover Hotmail(8: Get e-mail storage that grows with you. Check it out.
3
ocument 165-2 Filed 04/27/2009 Page 5 of 61
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Case 2:07-cr-20124-CM-JPO Document 165-2 .. Filed Cf4/27/20~Page 12 of 61
Case 2:07-cr-20124-CM-JPO Document 153 Filed 11/03/200r-'\"'Page 1 of 50
(J ~ t'Jr/Lt!)
D¡šrRl~': t tfICr C."i,.!i
IN THE UNITED STATES DISTRICT COURT !f Nay i.raF"J:,i;~š;:l
p.'l I: r;3
FOR THE DISTRIC OF KASAS "-
UNITED STATES OF AMERICA
v. Plaintiff,
Carre M. NEIGHBORS Case No. 07-20124-01-02-

~JW
()v Defendant,
Notice of Motion Requesting a
Change of Venue and to Have
Both Prosecutors Recues
Themselves from Said Cases as
To Avoid the Appearance of
A Conflict of Interest.
Comes now Defendant Guy Neighbors pro-se, and asks the honorable cour
to change the venue of all the cases UNITED STATES V. GUY NEIGHBORS
& CARE NEIGHBORS 20124-01-01, 07-20073-01/02 jwlldjw, 08-20105
jwl/jpo, from the State of Kansas to the State of Nebraska, and that the
Prosecutors Mariett Parker and Terra Morehead Recuse themselves from
the cases on the grounds that the Defendants cannot receive a fair trial or
be tred by an impartal prosecutor in the State of Kansas.
I(
Wherefore the defendants pray that the cour will grant this
request in the interest of Justce, and the defendants would respectfy
ask
the honorable cour to cour to consider the special circumtaces
surrounding this case in that the proseutor is now actng Distrct Attorney
for the Distrct of Kansas and the defendants have filed motions claiming
prosecutorial misconduct, have exibits from other defendants that will
show a pattern of abus and said defendants have fied a complaint against
the prosecutors under 42 U.S.C. 1983 for Civil Rights Violatons.
The prosecutor now has a vested interest in getting a conviction above and beyond
the interest of Justce. The defendats pray the cour wil entertn ths pro- se
motion as to avoid any appearce of a conflict of interest tht could prjudice the
defendants.
The 141h Amendment guarantees the fundamental rights of citins to due
proces.i; and such rights require the scmtiny of the Court. If the Cour
decides that it has the right to deny the defendants due process by refuing
to consider their pre- tral pro-se motions, then the Cour is failingto insure
justice in this case. Alternatively if no change of venue is grnted, then the
defendats ask for a dismissal of al charges.
Because a defendat has no constitutional right to hybrid representation,

the decision to allow such representation lies within the sound discretion of
the tral cour. Th case merits such a nee for pro-se motions beuse the
Prosecutors control over the defendant's attorneys have caused prejudice
upon the defendants in this case.
Although many jurisdictions have refused to recognize a right of counseled

defendats to exercise their 6th Amendment right to lend assistace ,of their
).
Case 2.07-cr-20124-CM-JPO Document 153 Filed 11/03/2008 Page 3 of 50
counsl in their own defense, it is ultimately left to the discretion of the

tral court -to determine whether such parcipation is permitted (see, e.g.,
United States v Einfeldt, 138 F3d 373, 378 (8th Cir), cert denied 525 US
851; United States v Tutino, 883 F2d 1125, 1141 (2d Cir), cert denied 493 US
1081; United States v LaChance, 817 F2d 1491, 1498 (11th Cir), cert denied
484 US 928; United States v Mosely, 810 F2d 93, 97-98 (6th Cir), cert
denied 484 US 841; United States v Halert, 640 F2d 1000, 1009 (9th Cir);
State v Frye, 224 Conn 253, 256, 617 A2d 1382, 1384-1385; State v Long,
216 NJ Super 269 275-276, 523 A2d 672, 675-676).
While there may be circumstances where the unjustified refusal to

entertain meritorious pro se motions would constitute an abuse of
discretion, that circumstance does not apply when a defendants
Constitutional rights are jeopardized.
DEFENDANTS HAVE.... CONSTITUTIONAL RIGHT TO BE HEARD
The decision to allow hybrid representation implicates the tral cour's
function in ensurng the orderly administration of the proceedings and the

special circumstances in this cae. (see, People v Mirenda, supra, 57 NY2d,
at 266). As such, it is a matter committed to the sound dicretion and of the
Trial Judge.
The defendants respectfly ask this cour to change venue or dimiss

through this pro se complaint under oath allegig violations of civi and
3,
Constitutiona rights, conspiracy, direct conflict of interest, and

prosecutonal misconduct, and therefore the cours must read the
complaint's allegations expansively, Haines v. Kerner, 404 U.S. 519, 520-21,
92 S. Ct. 594, 596, 30 1. Ed. 2d 652 (i972), and take them as tre for
puroses of decidig whether they state a claim. Cru v. Beto, 405 U.S. 319,
322, 92 S. Ct. 1079, 1081, 31 L. Ed. 2d 263 (1972). Moreover, "the cour is
under a duty to examine the complaint to determine if the allegations
provide for relief on any possible theory." onner v. Circuit Cour of St.
Louis, 526 F.2d 1331, 1334 (8th Cir. 1975) (quoting Bramlet v. Wilsn, 495
F.2d 714,716 (8th Cir. 1974)).
There are fudamenta rights of citi to due pross and such rits
reuir strct scti of the Court
The cour have assumed that the six amendment rights to representation
by counel and to defense pro se are mutually exclusive. Under the hybrid
defense the defendant has the actve assistace of counsel but may also
partcipate in his own defense as co-counsel. A necesa tool to ensure

justice when the defendant has been prejudiced by the restrctions placed
upon the defense by the Prosecutors in the case.
The defendants are currently represented by competent counel but are

forced to file motions pro-se because the Prosecutor has created prejudicial
limitations upon the defens~ attorneys, by violating the defendants right to
assis their attorneys in their own defense, and contrlling through
liitations how the defense attorneys handle the defense of their clients
through the "contract to withhold discovery from the defendants" This is a

standard contract that the prosecutor has forced the defense attorney
4,
representing clients in cases she is prosecutig to sign. Al defense

attorneys in USA v. Neighbors have confirmed they were forced to sign this
contract before accepting the case. (see exhibit# i page i &2, a copy of Terra
Moorhead's ilegal contract to withhold discover from defendant) in
violation of Federal Rules of Criminal procedure, rule 16, which clearly
states the defendant has rights to the discovery. At no time does Rule 16
say the prosecutor has a right to force the defendant's attorney to sign a
contract to withold dicover from defendant, nor does this Federal rue
give the Prosecutor the right to only disclose the discovery to the
defendants attorney)
The Pr.)secutor has made it nearly impossible for th~ defendants to assist
in their own defense, by forcing the defense attorneys to sign a contract that
v",., ....4-
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being used against them. A clear violation of the defendant's rights.
Paid attorneys hire by the Neighbors have ben threatened with "Money
Laundering" charges by the Federal prosecutors in an attempt to control
the defense. (see exhibits labeled money launderng #2)
(Defense attorney Sarah Swain told the defendants the prosecutor had
theatened her with "Money Laundering" and therefore would need all
future payments to be made with credt cards. Defense Attorney Aan
McKee was theatened with "Money Laundering" and requested that the
defendants set up a payp account usg someone else's name in order to
pay him, then as shown in the exhibit even placed the request for paypal on
the bill. Afer the defendats accused the Attorney of coercion with the
prosecutor the payment option was removed. See Exibit #2 pg.2 )
S'~
Case 2.07 -cr-20124-CM-JPO Document 153 Filed 11/03/2008 Page 6 of 50
.yi me.
an no.
e ree .
Th pJ U~ pr" ~e m"...o...... om...V'-t..s th" fud..LU.."'....t..1 va. "5
n as e
unde 1 .ng the sl' xt a ndment d Sw uid b og izd th
..
consttutionally compelled approach, for defendants implementing "the
right to asŠ1stanee of counseL. ~ ..
BACKGROUN:
It is a matter of fact that the Prosecutor Marett Parker has a direct confict
of interest in Prosecuting this cae and do to the fact she is currently the
Acng United States Atorney for the Distct of Kasas, overseing the
DISTRICT OF KASAS Departent of Justices in Topeka, Wichita, and Kansas
City, and is curently in direct control of overseing over 100 attorneys.
The defendats caot possibly be asured a fai, un-bias and impartal

prosecution and tral in the State of Kasas. The disquaification of
Governent counel is indeed a drstc measur" Bullock\'. Carer, 910 F. Supp.
55 i, 559 (D. Uta 1995) "where it is shown that an Assistant United States
Attorney is subject to a confct of interest, the proper remedy generay is to
remove that individua frm the case. Crocker v. Dukin, 159 F. Supp. 2d 1258,
1284-85 (D. Ka. 2001).
Durig the coure of the investgation stng in 2005 into the Yello""
House Business, the Defendants and their defens attorney along with
numerous witneses tued in formal complaints allegi Police
misconduct color of law violations, racial profiing, rules of evidence
handling violations, evidence storage violations, due process of law
~,
violations, search violations, false arest, forgery of legal documentation,

harssment and coercion of witnesses, along with the allegation of an
altered video being presented to the cour as evdence, and several months
of covert sureillance from the Fire station across the street, absent of a
court order. Thes complaints inadvertently were sent to the Prosecutor,
yet the Prosecution has excluded al of this exculpatory evdence frm the
defendats discovery files handed over to the defense attorneys in the case.
(In a direct conflict of interes) Al thes complaints were forwarded by

Internal Afairs Sgt. Dan Ward under the direcon of Chief Ronald Olin, to
the Kansas City Deparbent of Justice, and ended up in the prosecutor of
thë ca; AUSA Maretta Parkers offce for review and action.
In support of ths alegation: (see exhibit #3 letter from KU Police Director

Raph V. Oliver informing the Neighbors that the compJait was forwrded
to the AUSA Mariett Parker and al fuer complaints should be
forwared to her.) Also see Chief OUns letter to attorney Sarah Swain
adviing that Mariett Parker wa the one to address complaints to. (In
exhibit #4 pg. 5)
Instead of inuring justce on behalf of the defendants rights violations,
the US AtorneYs offce has conspired with law enforc~ment, staged an FBI
investigation (see FBI exhbits #4 pages 1 through 15)
(Ehibit #4 page 1 &2, Signed affdavit by Laura Helm sttig she was
picked up by two offcers posing as FBI agents.)
(Eibit #4 page 3 &: 4, Intervew-statement by Brad Perico to Private
Investiator Cecilia Woods statig he was contacted by two offcers
l,
claiming the FBI was investigating the Yellow House and had him on tape
going into the business with a drll.)
(Exbit #4 page 5, Letter to defense attorney Sarah Swain from Police
Chief Ron Olin stating that he could not releas the identity of the Federal
Invesators, that Police posing as FBI would be a cnme, and that Special
Agent Bob Shaefer had spoken to her about the issue. He also states, that
fuher correspondence concerning the case should be directed to u.s.
Atorney Mariett Parker.)
(Ebit #4 page 6 & 7, Leer to Sarah Swan from the FBI explaining tht
U.S. Atorney Mariett Parker sent FBI Special Agent Walter Schaefer to
investigate the alegations of police posing as FBI agents, verig 60 days

had passed and made reference to repeated unanswered phone cas made
by Swains offce to the FBI in an attempt to set up furter meetigs with SA
Schaefer. According to Special Agent Sctt Gentie from the Topeka FBI,
the leter was Signed by a retired special agent Kevn Staord, sent by
Tiothy A Gallagher)
(Exbit #4 page 8, letter to Bob Schaefer FBI, from Defense attorney Sarah
Swai)
(Exbit #4 page 9 &: 10, artcle in LJworld newpaper that the FBI was
investgating the conduct of police in the Yellow Hous investgation. Jef

Lan7.a alo confed the FBI was not involved in the Yellow Hous
investgation.)
(Exibit #4 page 11, artcle in IJworld Newspaper stating that the FBI
investgation was stled and that the FBI had not received a formal
~.
Case 2i07-cr-20124-CM-JPO Document 153 Filed 11/03/2008 Page 9 of 50
complaint. Even though the defense attorney had attempted multiple times
to set up meetings, some days attempted to call SA Schaefer 6 times
without a retu cal, left messages and faxes for SA Schaefer.)
(Ebit #4 page 12, Arcle in LJworld Newspaper confirmng the FBI had
completed the investigation and clea the police of misconduct.)
(Eibit #4 page 13, letter to Agent Schaefer frm Defense attorney Sarah
Swai lettng him know she had forwarded a sworn affdavit of ilegal
conduct by the Lawrence Police, and had made numerous attempts to
contact him about the matter but had gotten no response from him.)
The Governent in a controlled reacton, used the infonntion contaied

in the complaints forwarded to her, to use her team of investgators to
retaliate and conspire agaist the defendats and then in an abuse of her
power, also controlled the defense attorneys handling the case.
In order for a defendat to prove conspiracy the defendat need not alege
personal involvement by all the partes. When a person is part of a
conspiracy, one does not require a hub and spoke form. One nee only be
par of a chai of conspirators.
Law enforcement offcers Jay Bialek, Mickey Rantz, Michael Rier, Police
Chief Ron Olin, Posta Inspector David Nitz, IRS Agent Robert Jackon
and the Kasa City FBI Agent "BOB SHAFER" Walter Robert Schaefer,
were employed by the Prosecutor as her agents to do the dirt work on her
behalf, outside of their agencies jurisdictions with her fu knowledge and
approval. In conspiracy to cover-up, conceal, obstrl1ctjustce, and limit
liability in order to avoid accountability for the Governments unjus actons
r
against the defendants.
ConsDiracv to violate civil rifl
In order for this court to establish a cause of adion 10 change of

venue or dismissal for conspiracy, there must be sufcient fact to
support the following elements:
1) two or more persons;
2) an objec to be accomplished;
3) a meeting of minds on the object or cours of aelion;
4) one or more unlawful acts; and,
5) Udamages" direcy linked to the violation of the defndants rihts..
1 Obviously there are tw or more persns involved.

2. The objec to be accmplished is to obstruct justice. cover up for
color of law violations and prosecutorial misconduc, obtain a

conviction through fraud, to cover up criminal conduct against citizens
by offcials, and to avoid liabilit.
3. The Government dearly had a unity of purpose or a common design
and undersanding in their joint effort to avoid liabilit and conceal
Constitutonal rights violations. The Prosecutòrs Terr Morehead and
Manett Parkers actions were clearly improper and directly
conneced to the conduct of the acting Government offcials under her
command. There is no other explanation as to why these Prosecors
would break the rules to cover up report of criminal activit by Law
10.
enforcement against a wrongly accsed citien other than that they

had joined into a common purpose wih the team.
4. The unlawfl acts against the defendants have greatly prejudice the
defense and have been documented through photographs, video's
and voice recordings, court docments, affdavits, and tesimony
under oath during various heanngs before Federal Judges
overseing this case.
These are very serious allegations and this court has a duty
to the Constitution to protect the integrity of the court.
Therefore, this District of Kansas court, which has a prima
facia conflict of interest, has a duty to construe this pro.. S8
motion very liberally and grant the defendants request for
change of venue or dismissal of charges, in order to protec
the public perception of the Integrity of this court
A FAIR TRIAL FOR THE DEFENDANTS is NOT POSSIBLE IN

THE STATE OF KANSAS or MISOURI'
AUSA prosecutor Terra Morehead has intenered wit the Defendants

Guy and Carrie Neighbors fair chance to defend them.e~v88.
Tera Morehead originally charged the defendants wih being unlawfl
users wih firearms. A statute that the case did not qualif under.
Because the defendants had no criminal history, there was no evidence
of habitual dru us, and the fireanns were expensive collecr Unon-
If '
qualifinglt firearms unloaded and unlawflly seized without a warrnt by

law enforcement from a loced safe.
During several hearings before Federal Judges, law enforcement

offcers have read fabricated stories by witnesses and lied under
oah, to th court .
The prosecutor has taken things out of the defendants discovery. Certain
things that were sen in the discovery while in the poseion of past
attorneys Bruce Kipps, Ph;ip Gibson, Alex McCauley and James George
have ben changed or switched out. ie. Police evidence report,
statements, search warrnts, recipt for same list.
The Court have ben made aware of the fact that the false tesimony by
convicted felon Patck Nieder was presented before the Grand Jury in
exchange for an 8 year reducton of his prison sentence.
On July 1,1998, a 3-judge pane' of the 10th Circuit, U.S. Court of Appeals
delivered a decision, in the case US. v. Singleton, The 10th Circuit ruled that
bartered-for, testimony in federal criminal court is not only Ilegal and
inadmissible, but technicaUy punishab'e by a substantial fine, and/or up to 2 years
in prison.
Prosecutors have offered both cash payment and leniency to some witnesses, and
offered plea deals to Louis Parsons and James P. Ludwig in exchange for
anticipated false testimony at trial claiming that the Defendant Carrie Neighbors
conspired with them to conceal the conspiracy, absent of any existing evidence to
substantiate these claims. It is the responsibility and duty of the prosecutor to
always try to substantiate (what) any witness for the government is going to be
saying.
In a separate case in a 31-page ruling U.S. District Judge Willam J. Zloch threw out
the testimony of three accused drug defendants on grounds that it was solicited
J~.
with a prosecutor's promise of a reduced sentence a violation of federal bribery

laws, he ruled. In this case.
"u.s. Code, Title 18, Section 201cc(2) (the -bribery statute-

could not be more clear. It says: Whoever. . . directly or indirectly, gives, offers or
promises anything of value to any person, for or because of the testimony under
oath or affirmation given or to be given by such person as a witness upon a trial,
hearing, or other proceeding, before any court. . . authorized by the Jaws of the
United States to hear evidence or take testimony. . . shall be fined under this title
or imprisoned for not more than two years, or both.1I
A Stii .g video was aftered. ~=id there is (Jocumentt:d missing evide:ice.

from the police evidence locker, but the Federal Prosecutors have
continued the proscutiuii vï ¡his caSi; gÎlÎ'i"ay.
The Prosecutors havit üõed their influence an.j power of authority

to ~"ntrol the Federai Ageiicies, witnesses and Defense attorneys
involved wi this case.
And have exercised in a similar pattrn of abuse of power In other
cases 89 well.
(See exhibit
#5 pages 1-5, JOHNNIE WILLIAMS III, case 06-2007-
01-cm.. lettr to Chief Judge Lungstrm alleging misconduct by
Prosecutor Terra Morehead)
(EXhibit #6 pages 100, JASON McKINNEY dated June 30,208 .

complaint sent to The Ofce of Disciplinary Administror, alleging
malicious prosecuton by AUSA Terra Morehead.)
(Exhibit #7 pages 1-4, James McKelghan lettr to The Honorable

Judge Lungstrum dated Jan. 22,2007, alleging Prosecutorlal
Misconduct against Terr 0 Morehead)
/3
Case 2:07 -cr-20124-CM-JPO Document 153 Filed 11/03/2008 Page 14 of 50
The Prosecutors have Interfered with the defense attrneys

filing motions on behalf of their cliets.
1. IE. The Neighbors requested that Attorney Phil Gibson file a motion
to release an illegal lis ~ndens place against their propert by the

Proseutor. The motion was file and Judge Murguia scheduled a
hearing the following week. Mr. Gibsn then canceled the court date.
After 3 week delay, the motion was refilled and four days later the
Proseutor filed a Superseding indictent to moot the motion. Wit
the sale of the house stil in limbo and the buyers geting anxious the
defendants asked Mr. Gibson to refile the motion. he agreed to retile
that weekend but then. even afer repeated requests from the
defendants never did refle the motion. Aftr several more weks the
sale of the house had to be terminated.
2' The Prostors in this case have violated the Neighbors Bil of
RIGHTSI
3. Amendment V.- Deprived the Neighbors of life. ii be
rti and propert.
A.- Life- The Proseutor has had the Neighbors arrsted by agents
opering outide their Jurisdictions several times. searced, and
held in custody. using statutes and Jaws that do not apply. Ruine
their businessi reputations within the community. the false allegatons
have co the Neighbors their Foster care license and their affliation
wi the Big Brothers program, In 2005,Prior to any charges beng
filed th Government contacted ebav and made false unsubstantated
allegations resultng in the immediat suspension of the defendants
seller accunt and also resulted in the defendant money in the
Paypal account being frozen., greatly affecng the defendants
livelihood and abilit to run their business and pay bills.
l~,
Public False allegations released to the press include stolen

propert fencing, money laundering and drug traffcking . And on the
DOJ press release web site falsely claimed the Yellow House crimes
had been investigated by the FBI.
B-Propert~ The Government has been holding Propert since
Deber 2005. propert unlawully seized during the executon of a
violated search warrant. and gaine through an ilegal warrantles
search, denying the defendants constitutional right to due procss of
law.
4. Amendment VI. Right to Speedy Trial and efecve counciL.
5. A- violation of ñght to speedy triaL. The original charges of being an

unlawfl use with firearms was originally droppe wit just 7 days left
before th time limit of a spey trial ran out. The same charges were
(e-led as a brand new ease. and the proseor had the Neighbors
strong armed arrested from their home and ilegally searched.
B- The original search and seizure was executed in Decmber of
2005. This is now November of 2008.The Neighbors have ben
denie the due procss of Law. have not ben allowed to view the
discovery or se the evidence being held against them. Beuse of
the Proseutors threats against the defense attorneys. during the
three years the case has been in the courts, the defendants have not
. had any motions file by the defense atorneys direcy related to
defending the case ie. stndard Motion Reques for evidentiary

heanng, reque to se the evidence, reuest for dismissal. reuet
for suppression of evidence. The Neighbors have not been aforded
an investigator to conduct interviews of winess nor has the
Iii ,
prosecution allowed the defendants to see the list of witnesses

scheduled to testif at trial on behalf of the proscuton.
C- The Prosecor has forced the Neighbors to loose paid atorneys,
and then force them to use court appointed attorneys that are willing
to sign her oontract and allow her to maintain a strong infuence over
the handling of the defense.
CONCLUSION;
This court has a responsibility to assure that its regulations are conceived
in the public interest and not in furtherance of self-interests. Ever¡ lawyer
and proecutor is responsible for bbservance of the Rules of Professional
Conduct. Neglect of these responsibilities compromises the independence
of the profession snd the public interest which it seNes.
The United States is a government of the people# by the peple, and for thl
people. The judicial system's function is to serv the public by providing a

means to serve justice and to resolve disputes. This can only be done in an
environment where hones, integrity, and high moral standards are stn'otly
enforcd.
Thera ;s an obvious mix of Conflct of Interest and Special Circumstances

in this case that together will pf9vent the Neighbors from entertaining their
J ¡~ .
Constitutional right to 8 fair and impartial prosecutor. Since the judicial

system is self-governing and is therefore responsible for policing itself it
has become obvious that the Neighbors cannot possibly expect a fair trial
under these circumstances. Therefore the Neighbors respetflly ask the
courts to grant this Pro-se Motion to Change of Venue or Dismiss all

charges.
/7t
PROOF OF SERVICE FORM
A copy of this form shall be appropriately filled out and attched when Proof of Service or statement of delivery or
mailng is required.
Personal Deli\'erv: . /
i declare that on / /~ 3- ¡)g I personally delivered the attched ¡J j n . ~.¿ V~ Ve IÚJ~ '-.
, (D) C¿ ~ ofDo..cn)
t4/c ~ 'f-t t'~
~ø ~
~o .tJ~ (Nam ecipient) A
(Locaton)
.~0/R (i~) ks
Part 3 I declar under penalty of perjur that the foregoing is tre and correct and that this declaraton was
Executed
(Date) (City)
on 11-3--0~ a!./).Æf è)-lú0-l1t. J /)shdJ-()f ,Kansas.
ClLiS 43Jk/J
. (Type or (! (Sig)~
Prnt Name)' Cf --
Case 2:07 -cr-20124-CM-JPO Document 153 Filed 11/03/2008 Page 19 of 50 .
,
U.s. Department of Justice
-- Eric P. Melgren
Unite Silltes Attomcy
Distct of Ka
KtJ ca" OJIC W-,ui/a Oicc

SlifM 16 lID Epic Cr.m
sOt Si AW'/J \. JO/ N. Møi"
Kø.v City Xanøi65/0J..UJJ 'v IYlch¡lø, XII 67201--'11
TEJl9/J) 55/-61JO Tøp Oje.

FA.(9J3) SS)-GSll' lU flii
roD (9/J) JSJ-l Srltr 19
TopCl. Xmiu 66J.1JJ1
. UnIted Statu vs. James McKeighan

.
Cu No. Q620-OI.JWL
. ... 6
acWledge as cosel for the abve çaptioile defeødat, th I am in rept, on
.1 hey
today's dae, ofdiscvei consistofonc'CO with paes which ar bate-sd froniOO1-

.I~. By sigo beow, i fù ag th I will not slÏwthe pa of discvery to my dicil or to
pr.vìde coies tcliYos includi iiy cUeit. FiDy. in th event tb I withw tim tl ca. I wil .
nmUD' all discver to thc U.S. Atii's Offce šo tht it ca be prpe dismi 10 subsûtutc .
(\. 'Ol~eJ. Ths agt will also apply to any fU ()r fúl1~ discver prvided by th Oov~eit
in.t1U$ cu.
~J'~r~.
~.:iU8yfi r McK~fl
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Date
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We, /C., tl: u.s. Department of Justice
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e, ., ...~,.... cß!j Erie F. MelgreD
United Stales Attomey
Distrct ufKiusas
Cøll aI), Offce 1lcJftø Offa
Suit, J~O . J2dEiic c.,,,
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Ju 19 5, 2005
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Tim 'Scireca
313 Nort Seneca
.
~.
WiGhita, KS 67203
r-,: , ' Re: United Státes v. Jam's McKeighan
,,
" Dear Tim;
"
,'", .',' EndOs~aiep~9,~Vt~I~~~,~~i~-sta~pedf~lno12Q -013å~jchareproVided'
., to you as dlscöveiy in fliš' case~ Tljše' årft provided lei yoü Wí the understanin that
,. you äte riot td sfióW tH~m (q'jóurolléril 'dr'iQ ptóvide'Çopîe"tÒ' ~nyone fndudln your cliet.
If ycM have' a prilèni:WitJlfhis; plä,~'Sij' retû'tiHh.eÏn tò liiè';¿ jr.-Ihe eveiit thåt you wilhdraw
fr~rri .t~s" ca~e, ple~s~ :r~~ù'r.ti aii. dìs~~~~~~ .'!lif" 'Dflf~i.'o that It ~n be property
. d;ssem~~tèd to 'Sul;~.fllut~ eónsel,_ PJ~~~" ,~'if ~lJ l~ave" any questins. ,
: ....1.,. O' ::", ..... 0'
Sinceràiy~':..' . :, ','
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TERRÄ'D. MuREHËAD. -=
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Case 2:07-cr-20124-CM-JPO Document 165-2 Filed 04/27/2009
Document 153 Filed 11/
Case 2:07-cr-20124-CM-JPO
~r7
Law Offce of Aaron C. McKee, Esq.
.~ \ /' &. ~ .~fY
~G~J,,'b(l c Y J)"
iJ~'\
I'~ll 1\ /tt). )l
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21604 West 98th Terroe
,_- .-.. Lenexa. KS 66220
Phone (913) 219-062
" * ~ \~iig.._.
Fax (913) 764-0652
aaromceemceeaw.co
ww.mckee-Iaw.com
To:
Yelloouse
1).~Statement
'Y .~ .'
For via
a 3%creit
convenience fee client
can: U81n~ oyer may
intemet at \W.mckeë.co.
the pay
Carrie Neighb Dale

190 Ma8lustts Stret 81112
Lawrence, KS 660
Amunt Due Amunt Enclsed

$6,057.85
Date Transaction Rate Hours Amunt Balace

08128100 Telephon conf wi Rob Jackson 175.00 0.2 35,00 4,692.86
rearding prffer meeting on August 29, 200.
089100 Attende proffr meeting wit lawrece Po, 175,00 4.5 787.50 5,480.35
IRS and USPS.
0891200 Tl1veled tolm Lawrence to attend proff 175.00 1,4 245.00 5,725.35
~ , metl. I
0810100 Telephone conf1 wi Carr Nehbo 175.00 0.4 70,00 6.796,35

reardng Guy Neighbors filing Sarh Swain.
0800 Telepon cOnc wit Rob Jackson

rearding Guy Neighbors llg SBlah Swain.
175.00 0.3 52.50 5,847.85
08/31/200 Telephone coferce wi Jim Geoge 175.00 0.5 87.50 5,935.35

regardng sttu of cas.
08/311200 Teleph coce with Carre Neighb 175.00 0,2 35.00 5,970.35
reardng Jim Gerg replacing Sara Swain
on c;.
175.00 0.5 87.50 8.057.85
08/311200 Telephone confnce wit Care Neighbor
rl'garding case stregy and settlment
n.:guliations.
1-30 DAYS PAST 31-6 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS Amunt Due
CURRENT DU DUE DUE PAST DUE
&~- ""
3,380.35 2,677.50 0,00 0.00 0.00 $8,057.85
L
Page 3
Case 2:07-cr-20124-CM-JPO Document 165-2 Filed 04/27/2009 Page 33 of.61
Case 2:07-cr-20124-CM-JPO Document 153 Filed 11/03/2~ Page 22 of 50
~..
Law Offce of Aaron C. McKee, Esq., L.L.C. ~
13970 Santa Fe Trail Drie t.() 1/
.. ._..
Phon Lenexa. KS 66215 ~ X.l . ~
(913)
Fax (913) 492-370
492.3971 -t lw\
Q()~ /~\,." 11 -
asronckecke&løw.(,m 1./ .., \ V
__.co ~Qi) ~~l) ~
Jumbeyinind~mçkee-Ia.com \ w1( \Ï n.
. . AII~on'.C. Mllell.1:aq.
l(lmI.l'lY.... lrèl.Rd. E...
To:
Yellowouse
? Statement
Date
Caræ Neighbo
190 Massmusels Stet
Lawrce. KS 6604 I: ,,-
Amnt Due Amoul En
$4.490.35
Dae Traon Item Rate Ho Amnt Balance
091200 TraVeled toom Lawrnce to mee1 wi ACM - Travel 175.QO 1.8 280.00 3.195.35
lance PO.
09101200 Me wi Lawrenc PO an USPS. ACM - Met/. 176.00 2 360.00 3.645.35
091012006 Telephone confeenc with Rob Jackson ACM - Telep.. 175.00 D.3 52,50 3.597.85
rearding ca.
".
" 19l00 Tel coer wi Rob JøclOn ACM - Tølep... 175.00 0.3 52.50 3.65:.35
I8gardlng t:&e.
0911flOO Tel coerce wi Mfey ACM - Telep... 175.00 0,2 35.00 3.685.35
Rantz reardin potental undercve
opeat.
09f211200 Telepone (,nfenmce with Cane ACM - Telep... 175.00 D.2 35.00 3.720.3
NeIl1 re 81aa of ca.
091112 Tel ool1 wl Rob Ja ACM - Telep... 175.00 0.2 3600 3.755.35
rearding status of ca8e.
Telephon coference with Mickey ACM . Telep... 176.00 0.2 36.00 3.790.35
10112100
Re re ra on LP.
175,00 0.2 36.00 3.825.35
10112/ Telep conmce wt Car ACM - Telep..
Nelghbo rerding raid on LP.
17~.OO 0.2 35.00 3,86.35
1010120 Telephone conf~ wi Rob Jackson ACM - Telep..,
fer sta re.
175.00 0.3 62.50 3.912.85
11/15/2006 Telephone coera wih Came ACM - TeI...
NeI røg l. lC PO8
rest to me wi her.
1.3 DAYS PA5T 31.e DAYS PAST 61-9 DAYS PAST OVER 90 DAYS .
PAST Due
Am Due
CURRENT DUe DUE DUE
,~ --
0.00 2.057.85 0,00 $4.490.35
2,432.50 0.00
,
Pa 3
..
Case 2¡07-cr-20124-CM-JPO Document 153 Filed 11/03/2008 Page 23 of 50
IV~AS Ofe of Public Safety . Js 'o-r

~ jÑ'v~
V..'\ ~
Octobe 8, 2008
g
Care and Guy Neigh ,.
i 90 Massahustt. Str
'Lawrnce; l(8l 66
De Mr. & Mis. Neighbors
On Septmber 16,2008, you delivere a wrtt complait to 1h Univerity orKaas Public

Safet Office. Cata Schuyler Bailey wa th depent rerentave wh reived your
complaint. Your complait alegs th on Aug 13,2008, a member of1b Univerity of
Ka Public Safety Offce, Detective Michael Riner, commited perjur dur tesny in
Feder cou.
By way oftbs letter, I am notifyg you tht your complat ba been provided 10 the U.S.
Attorny's Ofce. That offce is the appropriate investigatve agency to reive a complat of
alleged pejur. in Fed co. The following inividua may be contate should you wh to
prvide any fuer inormon regang your complai ag Detective Michal Ri:
AUSA Marett Parer
SOO Sta Ave.
Suite 36()
Kan City, Ka 66101
913-551-6730
mAtieta.parerCoi .e:ov
~~
. h V. Oliver
Diror
RVO/sp
cc: Maret Parer
(LOOl 3126 IlOcl of public Safaty

Public Safety 8uUding I 1501 Crestline DrIve, Suite 120 I LiiwrenCt!. KS 66049
(785) 864-5900 ( Fax (785) 864-5211 I WW,ku.lill..s
,. , THE SWAI LAW OFFCE

Sa G. Swa
Atrney at Law
601 M_ssour. Suite 3 110 N. CherT, Sui 240

l .,i..p. .,.,. I( \: l\llnA,f f)~.i:h~.. KS f:M.si
(ió:ï, ti:izidi 8öô-55û-2787
~~~Vt.: .L .'!¡ c:if.cc¡¡¡ci¡i;.~¡.n¡;i ..."'..:. ¡nf.. &lianOlliLL;Ggw.LvIl
:.:.~.~ 8:;'it~:i~ :-;1 ¡~ :t:':~
!)¡L.;~. f. i~'.!:(~
FAX TO: Bob Schaefer I FBl
FAXNUMBER: (816) 512-8545
SENDER'S NAM & FAX NUMBER: Sar G. Swa (g (785) 842-2187
RE:
,. PAGES: J
COMMS:
,(l S
~
..,
~se 2:07 -cr-20124-CM-JPO Document 153 Filed 11/03/2008 Page ~f §:i ¿u
./'.
/
WOQD ai, "EStIGA nVE SERVICES, INC.
\FFIDA VI"!
l. Ui lllm oflawfa ap. bcll fùlly swom up oe sis:

Thill. in caly March 200, I y,es cunuc: by rwo me wbl- J was -l'iDS- m"
btui. tRAy M.ybelJ~ iu lø at 2200 ~. C-l ~. Xa i il
un of di di. li i i,u im it W..lI seve wcs. ll Ii .. l1 Il we I
1i-c. bu L ¡l1t CM \i ib date di tw Jh ~nØlI an la me
wa Mih 6. :! ~n 9:00 Lm. .10:0h.m. ".
1'h-.it.lh iw men. aph:d m~' ru~ 1inlhskedlO sp..wi1b'l. r ca
bo -nti Utl h ma ~ a 'kIlIL ~'QS", . Jitlle liUy _ibo 1p li ba.
Tb åia Jill mò or ilI iia.iø¡ dall OW~. He -l 1t i-ic, wJic: l do G'
i-1.1I -l:iMl tJ~ lI'Ork.. widl it "Fed 8ui "fln\'i-" HI cl1l'.,
/. 91 l~ ii~ "..M 'ho r:riiir. biw ØI. (' _an it ..u a vi!t4 *,.di hi,
~~ ft 1)" ii a bllP buld ibi l- IbIl Tb ØI II ... 00 ., nw ni
~'i'r.c! !J1ari did lell i~ i 'XJl~ i' in rl'uble but Guy ell t=1I1! Nclbb we. "Ø
me llCl ..l-)' dreu in 11K" aD ids. T-1 bø wo . i. De di Hh
ii Ji ..lI in hø in or lighi colo IiiCl tI ., al -i ell dl WI
ThaI. ihl ,'INC IJI told m. I '1i 10 lalk In ilwm:' L ukd Jim If ii "' tv be
to," He icid ii did Ml ha~ 10 li .od,. ;uid the)' IIràlo o;om Ii Ii rolluill
i: . TI"' ."r~~ Mimed th ii~, .l -;ii "ii.k~i nie ur in 1 ¡jr. ~ ti ,. "'l"
\'-llc. ~ ,jlill WI to ¥(I wih :h. bu teli iiu ih ..y.., "'lCna ,1ht" Gl~
ilC ..we :a cbide Tb' 4ive Ml co 1M l. Pol" Di Ii 11* -i
"".IlU8'f1 ~tr.,. LiwMKc. KS. We Wen 1Di2 lM lillJdtn i.'ilb 11 óødt
door. I ~'I\l thi IÙft lftcrins in;¡ p-i .: to ~ .l\lo iblt ili aIweliln.i
i"" pnl4-c ~I. ~\'-= "Cl intl' ii i~llW ~'" wli bo lI fDki Ie nw
i1 IlllUi,nc me .rui .icn I Ji .ild It ih 'i cJlow Hull in aie i-. Thy lOl
1J *l' .i:ûnG m~ i\t! ihtuili i.h !C"ir i: ~ "linen by li Valiow HOI.
Thai. lift",: uw~ 'lue;ion~ in :Ì'r m hø 10 _ l\UlID . haf; di ih. dI
me ~ C! ns~' howi DI il c&'c Ii 1b "YII me a ii_ cu wi.. pld
lcltlI ùh It. I hie nrsplQ-4 di .:a. ~ wid ni 10 caU it 11I IÓ Wr Iø
tbm "" :N \,,,l~ HøU: ca" ~ of& .. SSO.*, lb... dil wøiid be
wiiI to IIlo -iblOl"" ¡l.lO th y.u l-. .
t)t7 II
.
~4ì ~f &ol
.,-__.....ýj ~ f \
101112
bUp:l/dD.gooe.coiewdoibgpd_ 497g2vion Jates
Case 2.07-cr-20124-CM-JPO Document 153 Filed 11/03/2008 Pag~c~ól2o
UDlcd
!
1.-
.r".
1' J.l ooi i- lIç i Iu . ch ÌI ai wI u- ma ...i hi to lJ to

ti.. wt ll or J wod ~¥C li ÍD II .
11 boll J 1m on prl-~1L r l-IICC my ~ Oft. ll.£di.
,ft ibi ~ii~. 10 -t lIili Mo_ -l ocut. H. iod .. -l l -i Il bl
liiyol"idïrt this ly i) work fot Øw ~Iice if i wll to .. to lI pri- Dl. i
nevi- iiy i/l-iii øtwort -id 1h pOlIC4 lId told di i'Md IiL
'i J .. Cl J have ii ~ me tilb .. I ti .y 1f La_

Mii Ofca Al ~i linl ¥f' i. .1l fifl rnlÍ cllly Idficd hii-f. :b
-r .:J..,.. 1J~.i I"~csøation:.
MFI- 'NTSAY. 'N - T i.

. , Ir
l l. l. ~&.. i ii 'i ..\
. .. r~ 'lr\. .
i-lian"\V to mi befoi ~daY of -~, ,. ~ ._.
.:.....:~"' ~.. .. ~ ~~
~1~-"""..... .,. ..... ~~....
-N"al Public
.,-,
~~~~~
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btt:l/do.googe.cie7docgp72d_497&2w-i-- ,-.0 -
10//200
Case 2:07-cr-20124-GM-JPU uocumerit 165-2 Filed 04/27/2009 Page 38 of 61
(,
-, Br Pc.. 3'~ ~ &. -.i,-

i.. ÂI
l. KS ~'7
An at wu ma to ao Bill tb 8d88 Th II ~ at ti ctlo
re th wa DO Pe at 1hs loon 8D be did:n kDw th -. ADth
poble ad wa locat for Bra Per:
Poòæ ad:
4500 Ovei Drve ##105
Lawi Ks
Br ca th off 1Ìm18S-841..27. Aren we ma for an ùi 01
0312006 at Cuve's R- at 4:00 p.m. Bra ie he WI to _ ch, .
øi~ out He sad he ha be in to se Cae Nel1v-d øh to
i- ie
hi I1t to (O ba arund. She told hi to ea mo aD li ib tb iD bd
BNd re hè WI rcy coac by Lawr Poll Dewi. He na oi

Deve IS Jay Bi He di no lmw th o1h Dave but he da hi.. a
w/m, 6'0", with sh br ba oombe on 1b Bide. Br sa be W8 at . fr'i
apai on hd Str ap tb wo.. He sali 'W l- ib
bptm 8D W8 to th lit loc en wa whi he II th DdWI at th
li lo do ~ to iimy 1b lo H Br sai ho is co1b CO i- to
DO ot wa th
r'., bø be wu th. .
have follwe hi ove to th Red 8d be he boWl of
Bm sad Bia to hi tJ Yell Ho ha be UD te ia~pt fo'''

Dl He tod Br C8 ha bo UD w. Dl~iOD 8D .. iI &o
do" an"S wm ta he huba wi ..') He fu ai th FBI ha hi (B)
on IU ta at the Yellow Hous ta in a dr He sa tb quOJ hi
abut th dr. He ex to tb tb he ha da au bo wo fo,. -i hi
tols He 88 th deves told hi "We bow)'u ai in 1i." Bi lld
a lo of
Biek 1110 told bi "We bow youbiw ~'i ßO down" Bia to hi he

wod se hi help wi tb (6) impa ~ he ba ifll wo hep tb wi th
Yelow Hø ~OD. Bra ØI be to1bhe wo tb ab it bu. ba,
he"M DO be tb Br sa h8 wo't 40 tb be be .. fr wi Gu
aø Ca. He sa Dees attb LlD ha al li to Jå in 1b i- -l ha DO
ca tb wi di pr 10 he did no wi to bo th al 1o.
B1 ta wl th Devea we lAln to Iu ou ofdie .. W1", OD

Rø Sii Ua -l to ba hi a i,1.i oe He ui _be to1411 DO be
l. iw da ca ii pue, He sa he tod Biek to ch hi but'''. ce OI'"
po aD he wo pidi ca up la. He I8 cld pi th.. up He sa ti
wa th ca he -icly ha qi 01 da at th y.now Il Bt II ~
ii1h ~ wellet hi to 'W with tb __ be bi liJI
ti He 8110 aa lI WI is abut 1 % JD li an ~ fb aDWI.
.~.
ací ~?' ,L
4
~~'(\ ~ 'b
. Case 2.07-cr-20124-CM-JPO Docum,~ 153 Filed 11/03/2008 Page 28 of 50
~..~. Br Rid Tar Kab is aptly th Deve"g su. Uò -l Tci CI iø

lie hi Bia lU exJa th he did a Jot of ÏD woi fo 1b LaWl
. Poli det in th pu He sa~ JI spifca. he did a 1o ofwo fo Of
Sc Pec Bra &a he WI th Codc In wI as Peot in hi dr
rela invcgpom wh be wa with th poli de He II Pec aa1J
fi by Jud Maon an he wa ac of1ing hi Ifda Br sa be WI
eveaua ex at th Cl8Id th Jud sa tb he (B) wa no a 'I;y
wi1D or iD aD lb is why PDC W8 ully fi
Bra sa it WI aply th ~ . he Mi to se bi fi i-
DelCa at hi re wr Slw Ride" D1 no La He sa he sa be la
a lot of oos in l: ea -l dll\_ Jes told Bia la th af la le"th cop
told him to sly aw frm hi. Br sad ti Slow Ride is a ne ha ou fo th oo
Br DO it wa shy af he we in th Slow IUth th deve co
hi on R. Sli ab th Neirø
Bm sad be W8 at Ko'. la we aD he saw Biaek Mmi. out ofCh be I' of
th st He ii th.. in nal tB ad Bla ub itho hi IÌve ~
tht to wh th I8 about ee. He 8ld Bial AdÌl Ka"b ., it out fo
hi." Ho _d Il colIy di DO li di pe reOD be (B) hi
wi Pc
Br sa m. old pUiku ia Ki Fllch. Ki is a si to Cae tJ. Ca
l-'. UJb'V fo th Do Cw Shs De~ Dr Ua. Sb jø ID
to Liut Ray Uil
B1 sad he beev th tw pawn sh in to ar ra beU abut th yell
Hou. He tJ ti mi have be OD oftb i- tb ar be tal8
EN OF INVIB
~L .~
.~... ~~~
fJ ~"
s
t~ l¡l~ ~ 1 \A
:07 -cr-20124-CM-JPO Document 153 Filed 11/03/2008 Page 29 of 50
--
w. R. Oli Ph.
~l~~
aref of Poce Mi Wildiu
City Ma
April 20, 200
Sarah Swain, Attorney at Law
601 Missouri, Suite 3
Lawrance, KS 660
Dear Ms. Swain:
l am in recipt of emai correspondence between you and Officer Bialek

regarding the ongoing investigation involving your clients, Guy and Came
Neighbors. It is my understanding tht you wish to speak with the Federal
investigators involved with the investigatin of your clients. OfCGr Biaek
assures me that he has cotacted the agent involved and has Informed them of
your wish to be contacted.'Addltionally, l am aware you have been In contact
with U.S. Attomey Marietta Parker who ;s handUng this case at th fedral level
for prosecution. The Lawrence Police Departnt will not release th Ident of
any Federal investigator who is involved Ln the case.
,,-.
Your most recent email is of some çoncem, as it could be read as an
attempt to report potentia) criminal acity. If ths is your intention and the
activities in questn too place in the Cit of Lawrance. pleae feel free to file a
polic report with our department. If 1hse acflvltles too place elsewhere, .
please contact the appropriate law enforcment agency from that jurisiction. I
believe Sergeant MIke Pattnck from this department as wen as Special Agent
Bob Shaefer with the FBI has spoken with you In persn about these very Isues.
Any furtr correspondence concrnng this case should be directed to

U.S. Attorny Mariett Parker. if you neeå to coriesponå with anyone In the
Lawrence Police Department, plase do so in wring, instead of emaling a
specific offr so tht It may be routed and handl~ appropriately. You are
welcome to address your corrspondenc to me.
~~ s Very truly yours,
~JJ (4
li~
cJ 'l ~(oS W. Ronald Olin, Ph.D.
Chie of Polio
WRO:mrp
.- mvepi & Tmg Ceter · 4820 Bo Billhias Pk · Lawre. KS 669. (715 830740
Law &for Ca. Pauo &. Recrds DiYi · i i i Eat 1 lih Sir · Làwæn KS (j. (7) 832-7501
City Hall- 6 East 6th Sir · LawRA. KS 66. ~ 832-30
ww.lawrpolicc.or
Case 2:07-cr-20124-CM-JPO Document 153 Filed 11/03/2008 Page 3a of 50
..- '-' ..
.... ....
-- ,.'.
r-
.
U.S. o.,uCmelil or JUltl .
Fed..1 Bureau of Jnvntptoii
II Rll)', Pl- Refoao

n~~. 194-KC-C81080 1300 SWlit
July 1, 2006
Sarah .G.Swain
601 Missouri
Suite 3
Lawrence, Kansas 66044
Dear Ms. Swain:
The Kansas Ci ty Office of the Federal Bureau of

Investigation (FBI) is in receipt of your letter to Special Agent
Walter H.' Schaefer, which was faesimiled to th,~ Kansas City
Divisio:. of t.he FBr on uuue 30, 2006. 1'he lCansas city Division
of the ~BI is also in receipt of a faesimiled Affidavit which was
allegedly prepared by Laura Helm on April 22, 2006. This
Affidavit was received by the Kansas City Division of the FBI on
~~ June 15, 2006.
As you are aware, Special Agent Schaefer visited your
office on April 19, 2006, as a result of your public allegations
and correspondence to Assistant United States Attorney, Marietta
. Parker, that members of the Lawrence Police Departmnt were
conducting an investigation and identifyinq t~emelvea a8 FBI
agents.
, On April 19, 2006, when SA Schaefer visited you in your
office 2t SOl t1issou'ti. .'"..)1:.:: 3, TJ.::o/!'I:mee, Kar.~as 66044, yOIJ
arjvis~'~i .iÜr. th.it you h..... . -.;1 ;".' i II"'!.'!~ ..1 i ¡",r\e9-:'~e ~'mo r:laime': that
memberE: ')f the Lawrence Pollee Depè'rtment identified themselves
as FFE a 1ents during an I..'test.gation.
On April 19, 2tl\În, SA Sc:.ae:fer i;equested those names
and YOlo :idvisec1 him thcll .;'h._..:~.:! not have the names and that. your
investigator, Cecilia Wood, had those lists of names.
.
.~~~~
~V~ OJ'
-, ~ Õ- G¡
\R
-
. -~
,. Case 2:07-cr-20124~CM-JPO Document 153 Filed 11/03/2008 Page 31 of 50
--.
From April 19, 2006, until June 16, 2006, (sixty days
later)the Kansas City Division of the FBI and SA Schaefer bad not
received any correspondence or information concerning your
initial allegations.
The two meetings you referenced as scheduled with SA

Sehaefer in your letter dated June 30, 2006, were set' by you
without verifyinq the availability of SA Schaefer.
Any future meetings/interviews should be verbally

verified with SA Schaefer. Simply leaving a voice mail me8sAge
advising SA Schaefer that you have a meeting set up on a specific
date at a specifio time will not guarantee SA Schaefer's
avai~ab11ity. SA Sohaefer can be reached at 816/512-8640.
Sincerely
Kevin L. Stafford
Special Aqent in Charge
'~~.
"t Ý.J
. ~ ~.
.~I/ .,¡ "\
,.~~ .1
~(t~
~ 2
;',
i;
THE SWAIN lAW OFFCE
I
_..' Sarah G. Swdi, Attorney at law
Theria Offçe Complex Park Cherry Buiding
601 Missouri Suite S 110 N. Cherry, Suite i40
Lawrt'nce. KS 66040+ Olathe, KS 66 i
(785) 842-2787 868.2787
June 14,2006
Bob &~haeter, Special Agent
FedeniJ Bureau ot'nvesti~tion
ISOO Siimmit
Kansas City, MO 640106
Der Mr. Scefer:

Enclosed pleas find the afdavit that we execute with Ms. Helm. We are sti
worlùng on getting othr afdavit's executed, but as I'm sure you are aware, many
r-/
peple are too acared to come forward and go public with their accusations agast the
Lawrence Police Department.
.. Wt aplll'eciate your efforts in investigating what we believe to be police miiconduct If

there is anything that I c;n do to assist YOll with your investigation, please don't
hesitate to contact me at the numbers or addresses listed above.
n¿.L
saah G. Swam
Attrney at Law
n~
. ~~'N a. 4
tp ~ \)~
I,
~ Case 2:07-cr-20124-CM-JPO Document 1'~"""'Fil.4.UD3/2008 Page 33 of 50
.. iJl'.
" · E-mail stQ£
. Printer-friendly
· E-mail editor
. Comments (44)
. 'Pod frndlY
FBI inquiry under way in conduct of police

So all that offcers pose as federal agnts
By Ron Knox
Thursay, June 15.2008

Th Federal Bureau of Investigation is questioning whether Lawrence Police ofrs have
improperly posed as federal agents when interrogating suspct, th Jouma'..Wori has
learned. .
Th FBI Inquiry stems from allegations that Lawrnce Polic Claimed to be agents fr the
-
FBI when questionìng people during the polic investigaton of an all fencng opn
at th Yellow Hou8e secondhand shop. 1904 Mass. .
"We are attemting to resolv whether or not a person or persns falsely reprete
themlv as FBI agentsi- FBI spoltesman Jeff Lanza confrme Wedney.
Lanza would not coment further.
But sourcs wi kne of the investiation tokf the Journl-World th FBI Inquiry was
prompt by colaint fr Sarah Swain, atty for the secohand 8tore. and othtn
close to the fencing probe.
Th sours also said the FBI was never involved in th actual fencing investiation. but
was only involed ~ecuse of allegations against th police.
\
The Lawrence Polic Oeartt would not coment for this art becut It Inolved
anothr agencys invesatlo. spokeswoman Kim Murphree said \Nneay.
Agent from th FBI have already met wIth SWain and th poic der1t, in part to
eslish that th FBI was not acually involved in Investiati the Yel Ho.
Th meeg betwee Larece Pol Sgt. Mie Patt an
FBI Special Agent Bob Shefr was at th reue of Swain.
who had heard from Yello HOU88 owners Gu and Carr
Neighbors and others that FBI ager were usin the Do
."" County law Enforcment Centr to tntMe pe who so
merchandis to the store.
\...~._../ That allegation culminted in a sworn aiavitfro Lanc
ø \0 1.\ \,4 fli,m0 l~ AI

. ,!t.
()f!rJ a
~ as Phot
. ~
rDI niqull iin~ ;Mlk~&~P~f~PO Document 153 Filed 11/03/20~8 Page 34 of 50
FSrbyagents
Or.C(m hU:l"'ww2.Uworld.Cllnln~OOuaJ'/fb i-.... .-- '
hadreident
Th Aflnde..r takeLaur
he Helm.
fr her broatw ho
Wh 811d
,\ \.A,..
,~ . '. !'"
to ththrv
me fdent
' .
J --'''-'--_Wl..
-. .. polic staon to Intrvie her.

Car Nehbors walt
for cuser. Inalde he
According to the afavit, th men queatl He for eo
mInutes before driin her back to her brotir'. ho.
sendha store, The
Yell Ho. 190 lPey queson me abou itms , had so to th Yello
Mas. Th Federal House In the past. ehe said in the afvit. '7ey to me tfey
Bur of Investigation obtaJne my name through chs that we wr by th
Is looklng lnto the Vetrow House."
Larece Police
Dedmen beus of Helm said In the 8favit tht the men ha gun an b8
afle that ot on their bett, and th at Ie-l on of th men kne th do
we po as feera code needed to ente the La Enfrcme Ce.
. ag In a feg Helm Is on proati for attd fo an ie .,
pr Involvng Yel
House. Incfnt to Har1ey Eddf, her prtin of, th ai
said.
During the meng of SW, Pattck and Shaefer, SWn .ald bo men tol he th FBI
had no Involvement In the YeU~ House investigation.
-stoJd me Itat the FBI wold not be lnv'ed." SWain iaid. -i11 no Inra
a-
t" \
ta fo or anyting like that."
Wh SWlin cont th police departent to confinn th FBI's involvemet in 1h
. .
InvestIgation of her clts. l. PoUce Chie Ron onn wokf only co"'..ii th8t th
apprrie faderaJ egenl8 had ben contaced, aocrcfrng to 8 .. frm Oli to SW, .
copy of whh was obtain by the JoumaJ.WorJd.
-(LPD) Of (Ja) Bialek assures me that he ha coct th agen Invol and h.

Inform them d yo wi to be oontact.. he wro SWn. .
Blele Is InvoNe in th inV88tJetion of th YeUo Hous. .
0I 8f in th le that he would not name any feerallnvetl InvoJv, but di
meon the meng be.rn Swn, PBtfck and Sha. and iaid th al fu
queni should be addre to U.S. Att. Mariet Parker, wh 18 handli piOI.cu on
the fel reveL.
of was invo In 1h fecing investigatIon.

. . .
Jim Cl, spoesm fo the U..S. Attey'. Of. wold not comm on whr hi
Po aó -lnce frm the Intel Revenue SeIvIçe and th U.S. POI

Selc In 8 ne rese frm Decmb when po 8eed an lni".ch wa
ag Vello Hou.
r'\ Th r8188 call th ai fe operation, whch enta th ~uro an .. ci
st goode, -on of th 'aig, mot øohiette feci ~cd. we .. -l In
t.. ·
ý'~\;:i\~
-Ð ~ ~ ~ \D 61lSI 10:. AM
...-- '.
FBI inqui ItaBed by'lack of formal eomplat

By Ron Knox
Ju 21, 200
Ad-i
A fed prbe into possible mindut WI ifc La Polce De ba sted as th FBI
WB for a for complat to be filed.
FBI sp lefLe sad no one ha co fo with a for col8Í aUgi an
po as FBI ag whCl quoning peple in reon to a police ineson of an alegd fenin
ri at th Yellow Ho~ sc sho, 190 Ma.
"We ca moe fo witht a form cola ø La sad.
La priousy sad th FBI wa lookig int th ma.
Sa Swu at fo Yelow Hous, sad sh aø a ,pvat inves we 'W to Nt up'a
mee be the FBI an,
pele who allegedy have be Jiga by poli offce çJAilq
to be fe ag.
r...... Sw al sa a prvat invesor se th FB at lea one swrn afdavit tb shul.so 88 a
foi êolat.
Th La Poli feo inestgaon whch bega las yea, ha foe on 1b aled pu
stlen go 1hugh th se st an oi saes II to a police DØ
im ree of
re frm Debe 200. .

Poli have seed se wiáma at the Yell Hou 8D at the ho of
Gu ID Cae Nei.
tb stre owi in:ioa to ti cae.
No chi have be fied as a ret of th mont fe mveptoi
Th poli de ha deoli commen abut th FBI iD, sa it wa ..ii ~
po1i to di moth agy's prbe.
More .bot tie ..
· lPU.~IDie"ï.l¡~ .
· §.e.WlLú4ç;.J::l\l.ltv~l.gar¡(ii,l ~f.Y ellQyI H1U~. s.!J. C01\tiD~
· FBlli:u under way in conuucl of police (06- i 5-06)
· wtter fim Police Chief Ron Olin to Sar-oih Swain ubut the investiption (.Wt)
· AJlidavIt on alleged î.pr~ t~ctic,s 'lsed bY polic~ officers l ,J)
· l..llç_~ LWJb_ V ~lIow.llouse in mmen gQO~.!IDyeJ!lìgaû!tn ('05-09-06)
· l1ill. P.ld~tñiJ&i.Qt~igoJJJ!Ii'yl'yeUQ.~llm~ p~jl1.4.::1,4:
. Yetlûw Hous store ownei's to hiive party to tl sl1l)orers l-03 ~02-06
r....\
~~¡y~
d ~~,,\
'
..
FBI clears Lawrence Police of impenonatioD a8egation
YeUow Hoaøe Store OWDen' resideDee ien'ed wi two more Nard wa.. iD
onging feiida investitia
By l:ri¡; W.i~an.icr
Jul 8, 2006
Aclent
The FBI ~lS it's cleed Lawren Fullee of an alegaoii th il offcer imB()Qflted IW FBI agtU
du th investgation of an aleged fenci opetion at the YeUow Hous us ap &t
"We looed into th sitution 8D foun DO evidee to inca tb anyo im BD FB
ag" FBI spkes JeffLiu sad Frida.
1b ne ca 1he sae da th U.S. Pos In's offce, as by La Polico an th
r-.. Inte Re Sece se tw mor iea wam at th stre at 190 Ma., aa at ti hom
of owner Gu an Cae Ners in th i i 00 block of Anver S1
Autes sai th wer lo for Coma rerd suei tas, ie co &e
iniBe an saes ierd &o 1h mi aucton sece eB.
-..,~,
J., '.,...~J'
,¿ 'è.':~ .~-:Li:.;".::r.
.......".i;". (j 't ",.
~'\;'::~~0C~;~~~~
:~.~ .
Ph by Thad ,\Jlcndt.r
Gu an Cae NeilS sa th th don't bu Ol se stlen prpe at th Yenow Ho St
190 Ma Th U.S. PostlDs oBk se tw se watl on Fri -l -i 1b
Neighrs' hom an ~,siftes in an ongoi fe invesoa
It's th IB tw in aD iDvesgaÓD th's be IDÌD on si De, wi Lawn Po1 sad
thd UDer wh th debe as a lae-sce, sophi fanin oralloa So fa, 1b
have be at lea fiw se wats seed bu no cm ba bc 8I im no ch have be
fied
"I th th whle th js arun our eBay aaes" Gu Nci sai OI Fri .. bo st OUcl
..,.0'..,.. hi st whch wa su by yellow police ta. "It'. be wh, eigb JD DD I do't
bo. Maybe th have mo tb I know."
The Ncigbbos ma th imocence an have be crca of poli at fJ tu
hl.,_L\",v( st\J'~~~~ Q~ \2.

THE SWAIN LAW QElfICE

-. Sarah G. Swain, Attorney a La
r C
Theno Ofce Complex ~y h"ry Buiid'ng
601 Missouri, Suite 3
Lawrence, KS 6604 I ~c ~tSuite240
o a J KS 051
(786) 842-2787 866-550-2787
June 30, 2006
Bo Schaefer, SpecIal Agent

Federal Bureau of Investigations
1300 Summit
Kansas Clty. MO 64106
Der Agent Schaefér~
. On June 14, 2006. I forwarded you a copy of a sworn affavlt that alleg illeal
polic conduc on the part of the Lawrènce Police Oepártmenl Since that dale, I
have tried contacting you on at least six occsIons to set up a meeting wi you,
Ms. Helm. and myself, At this point, I have ben unable to speak wit you on th
phone. ,nd , have not received replies to the numerous voice messages that i
,. have left ,for you. . _. . . ", ..
I contacted you twice regarding setting up a meeting with Ms. Helm. I told you
1hat I would be available to meet with you and Ms. Helm regarding your
investigation on Thursday June 29; 2006, Obviously, that meeting didn't take
place.
At this point, 'am unsure about your Intentions regarding this investigat.
While 'you seeme concerne about these issues during our first meeng that
involved Sgt. Patrick from the LPO, I am cGrtainly not convince from your
actns or lack of investiaton during the last two weeks tht this la sothing
that you intend to pursue in any sort of meaningfl manner.
I am curently pursuing possIble other avenue for an investigatn of

the LPO,
. and I wourd appreat Sfme clarIfication from the FBI about the manner and0r
extent of any Investation that your agency intends to pursue. Certinly', I will
keep YOIl apprsed of any further developments on my end. and t wi be awaitng
a call from you regarding a meeting with Ms. Helm, ~
- ,.
n¿.~
Sarah G, Swain
Attorn&y at Law
~~
~(O
'.6~ l
\ ~-t L\ .0
r \.
"
.
.
.
Case 2:07-cr-20124-CM-JPO Document 153. Filed 11/03/2008 Page 38 of 50
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Case 2:07 -cr-20124-CM-JPO Document 153 Filed 11/03/2008 Page 39 of 50
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Document 153 Filed 11/03/2008 Page 50 of 50
-~~
Case 2:07-cr-20124-CM-JPO
C"Sfw-)~Ci.cr-:ioo(,- :lWL O~i"4.l'. lø~ ii- oijc 7/ a.Dt (o't ~ - i¡ ø
('~i
El\v\.Zl- 7 · (
I am not aware of any situation in the world in which there

E)th;~j-l ..1
is a system of Jurisprudence that is recognized by civilized

people, where an indi vidual can be tried wi thout and conv1cted
without seeing or knowing the evidence against him.
SOMe of the motions that I have told my attorneys to file

and expect them to fi le are:
,
1. ) Motion for Discovery
A. citing Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10
L.Ed.2d 215 (1963),
2.) Motion for Exculpatory and Impeaching Evidence
B. citing Giglio v. United Stated, 405 u.s. 150, 92 'S.Ct. 763,
31 L.Bd.2d 104, and
3.) Motion for Early Disclosure of Jencks Act Material
C. citing the Jencks Act: 18 U.S.C 3500, 16 u.s.e. 3500 (e)(1),
18 U.s.C~ 3500 (e) (2), 18 U.S.C. 3500 (e)(3).
Sir, I am an American citizen. Born and raised in AMerica and

having thus done so the Constitution of the United stated
Government guarant~e8 me certain unalienable rights that this
prosecu7~T cannot ~ake away from me. "
Judge Lungstrum, could you please protect and" make sure this
prosecutor does not make any m~re evidence in my favor aisappear.
---- -- · -- --r "our time and consideration.

~ j1~
JBmlls I1cI(eighan

Marietta Parker Case No 07-20124-02-JPO Guy and Carrie Neighbors Motion To Revoke Bond Mental Evaluation Cause Hearing

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Marietta Parker Case No 07-20124-02-JPO Guy and Carrie Neighbors Motion To Revoke Bond Mental Evaluation Cause Hearing

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Case 2:07-cr-20124-CM-JPO Document 165 Filed 04/27/2009 Page 1 of 9

IN THE UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA )

UNITED STATES' RENEWED MOTION TO

Relevant Procedural Background

thereto (Docs. 66, 67), filed on May 1, 2008.

in writing, orally or by electronic dissemination, either personally or indirectly through

communication whatsoever which mentions the names of any witnesses, attorneys,

potential witnesses or of any persons associated with the investigation or prosecution"

with these conditions of his bond

Violations of Conditions of Bond

"Notice of Motion Requesting a Change of Venue and to Have Both Prosecutors

In his e-mail message, the defendant reiterated statements that he knew to be

1. Federal Prosecutor Terra Morehead sent Lawrence Police

2. Lawrence Kansas Police offcers Jay Bailek and Mickey Rantz

un-controverted evidence received at the hearing on the government's first motion to

Neighbors continues to engage in conduct that constitutes a violation of § 21-4004,

K.S.A., criminal defamation; of 18 U.S.C. § 1503, influencing an officer3; and of 18

be detained until the completion of the trial of this case.

Motion for Mental Examination

3 The false allegations of professional and sexual misconduct by the prosecutors

testimony of S.A. W. Schaefer).

in fact to support those allegations. In his e-mail of April 22, he states:

Where is the oversight of Government spending and constitutional

currently unable to assist in his defense.

(a) Motion to determine competency of defendant - At

(b) Psychiatric or psychological examination and report.--

(b) Psychiatric or psychological examination. - A

(c) Psychiatric or psychological reports. - A psychiatric or

provided to the counsel for the person examined and to the

(A) if the examination is ordered under

Because of the defendant's most recent publication of information he knows to

be false, in violation of the clear and unambiguous language of the temporary

for a mental examination to determine if the defendant is suffering from a mental

properly in his defense.

against him or to assist properly in his defense.

s/ Marietta Parker. KS Dist. Ct. #77807

#t). -;;.;; S G ,."

'1\ J. stll ¡.Ò K\ L¡- /3- cJ 9

i- 'l mo..'I, ~ o.c!c!..ess \ So

on HCt'i ()+ dOQ~~, fl

H..i (',hqpJ .Je.e_./ c.o.r~ .+0

_ .,' ._:-r _ L+. ~ C001a' .~ue.,~---

". .. . '. ;'.

jl-e J e l.l mL-t'YiC .,-; .

;ß. AGj~_ rI'i;")

- -_. ------ ----- . -..- ------_. ..-

FOR THE DISTRIC OF KASAS "-

UNITED STATES OF AMERICA

Carre M. NEIGHBORS Case No. 07-20124-01-02-

Notice of Motion Requesting a

Change of Venue and to Have

Both Prosecutors Recues

Themselves from Said Cases as

To Avoid the Appearance of

The 141h Amendment guarantees the fundamental rights of citins to due

Because a defendat has no constitutional right to hybrid representation,

Although many jurisdictions have refused to recognize a right of counseled

counsl in their own defense, it is ultimately left to the discretion of the

While there may be circumstances where the unjustified refusal to

DEFENDANTS HAVE.... CONSTITUTIONAL RIGHT TO BE HEARD

The decision to allow hybrid representation implicates the tral cour's

function in ensurng the orderly administration of the proceedings and the