Sunday, December 28, 2008

MOTION FOR DISMISSAL

This was a motion to dismiss.

Motion for Dismissal against guy and carrie neighbors Case No. 07-20124-01-02-KHV/DJW With Terra D. Moreh... Motion for Dismissal against guy and carrie neighbors Case No. 07-20124-01-02-KHV/DJW With Terra D. Morehead and Marietta Parker US kansas Jones, Walker Yellow House case. In response to the complaints On April 20, 2006 LKPD Chief Ronald Olin wrote to Ms. Swain that quote “I believe Sergeant Mike Pattrick from this department as well as Special Agent Bob Shaefer with the FBI has spoken with you in person about these very issues” end quote. Kansas City Special Agent Bob Shaefer testified under oath in Federal Court during a hearing August 11th, 2008 before Judge O‘Hara. That his actual name is Walter Robert Schaefer, and his jurisdiction is the Western District of Missouri. He did not have a file for the investigation, nor did he interview anyone in connection to the complaints. Mr. Schaefer also testified he did not view any of the affidavits in connection with Guy and Carrie Neighbors complaints.


IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF KANSAS
UNITED STATES OF AMERICA,
Plaintiff,
vs. No. 06-20171-01/02-CM
GUY NEIGHBORS,
and
CARRIE NEIGHBORS,
Defendants.
MOTION FOR DISMISSAL
The United States of America, by and through Eric F. Melgren, United States
Attorney for the District of Kansas, and Terra D. Morehead, Assistant United States
Attorney for said District, respectfully requests this Court for an order dismissing the
Indictment without prejudice in the above captioned matter. In support thereof the
Government states that it has recently developed significant additional evidence which will
require further investigation and anticipates the filing of additional charges. Therefore, the
Government requests dismissal without prejudice of the Indictment which was filed on
December 7, 2006.
2
WHEREFORE, the plaintiff prays that the requested relief be granted.
Respectfully submitted,
ERIC F. MELGREN
United States Attorney
s/ Terra D. Morehead
TERRA D. MOREHEAD, Ks.S.Ct. # 12759
Assistant United States Attorney
500 State Avenue, Suite 360
Kansas City, KS 66101
(913) 551-6730
FAX: (913) 551-6541
Terra.Morehead@usdoj.gov
CERTIFICATE OF SERVICE
I hereby certify that on the 5th day of May, 2007, the foregoing was electronically
filed with the clerk of the court by using the CM/ECF system which will send a notice of
electronic filing to the following:
James George
Attorney for Guy Neighbors
R. Bruce Kips
Attorney for Carrie Neighbors
s/ Terra D. Morehead
TERRA D. MOREHEAD
Assistant United States Attorney
at 4:47 PM
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