Case 2:08-cr-20105-CM-JPO Document 107 Filed 06/23/10 Page 1 of 3

Carrie Neighbors
Defendant [1J I Pro Se Litigant :. ~1. t n ::
~. .~'

1104 Andover
Lawrence. Kansas 66049
(785) 842-2785

IN THE UNITED STATES COURT

FOR THE DISTRICT OF KANSAS

UNTIED STATES OF AMERICA

Plaintiff,

v. Case No: 07·20073-CM

07-20124-CM
OS-2010S-CM
CARRIE NEIGHBORS,

Defendant 1,

GUY M. NEIGHBORS

Defendant 2,

DEFENDANT (1)'S MOTION TO QUASH THE PLAINTIFF'S

MOTION FOR UNDER SEAL. AS TO DEFENDANT (1)

[Pursuant to 18 USC § 3771]

COMES NOW on this 23 th day of June 2010, the Defendant [1], Carrie Neighbors, acting

as a pro se litigant is filing a Motion to Quash the Plaintiffs Motion for Under Seal as to

Defendant [1], filed on 06/22/2010, pursuant to 18 USC§ 3771. The Motion is as follows:

1). This motion is a kitchen sink motion, in which fails to specifically identify why this

Motion for under seal is needed, at this point and time. Whereby, it should be quashed.

2). The Defendant [1] has a right pursuant to18 USC § 3771 not to be excluded from any

court proceeding, as well as, the right from unreasonable delay, in which is not so in this matter.

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3). Pursuant to President Obama's Memorandum on Transparency, this case should not be

allowed to be placed under seal, due to the public has a right to know after the government had

spent all the taxpayers monies on attempting to prosecute a case way beyond the statute of time

limitations. Now, that the Defendant [1] had raised the proper motions and the government has

failed within due diligence, to prosecute in a timely manner. the government now wants to

conceal from the public the errors they have committed within this case.

4). This case was not concealed against the Defendant when the government had publicized

this case on 12117/2009, even after the court ordered it not to be publicized, whereby stating it in

layman's terms when it only benefits the Plaintiff, or government in this matter. Whereby, this

now violates the rights of the accused to either defend or challenge the evidence or witnesses

against her in a criminal prosecution, now that she is her own attorney. This is holding her to a

heightened standard, as well as, confirms that she is denied equal access to justice. This is

absurd at this point and time.

THEREFORE the Defendant [1], Carrie Neighbors, acting as a pro se litigant is filing a

Motion to Quash the Plaintiffs Motion for Under Seal as to Defendant [1], filed on 06/22/2010,

pursuant to 18 USC§ 3771, and PRAYS the Court Quash the Plaintiffs Motion to place this

matter under seal as to Defendant [1] for the above referenced merits.

Respectfully submitted.
/J

Carrie Neigh 0
Defendant [1 I Pro Se Litigant
1104 Andover
Lawrence, Kansas 66049
(785) 842-2785

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CERTIFICATE OF SERVICE

[Pursuant to KSA 60-205]

The undersigned also hereby certifies that a true and correct copy of the foregoing
docwnent in the above captioned matter was deposited in the United States mail, fIrSt class
postage prepaid, addressed to:

Cheryl A Pilate
Melanie Morgan LLC
Defendant [2J counsel ofrecord
142 Cherry
Olathe, Kansas 66061

Marietta Parker
Terra Morehead
U.S. Attorneys
500 State Ave.
Suite 360
Kansas City, KS 66101

On this 23 rd day of June 2010.

Respectfully submitted,

cQ[;;;J
Defendant [IJ I Pro Se Litigant
1104 Andover
Lawrence, Kansas 66049
(785) 842-2785

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