Thursday, June 24, 2010

DEFENDANT (1)'S MOTION TO QUASH THE PLAINTIFF'S MOTION FOR UNDER SEAL. AS TO DEFENDANT (1) [Pursuant to 18 USC § 3771]

6-23-2010_07912287374


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

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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.

Motion to Quash the Motion for Under Seal as to Carrie Neighbors

Page 1

Case 2:08-cr-20105-CM-JPO Document 107

Filed 06/23/10 Page 2 of 3

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

Motion to Quash the Motion for Under Seal as to Carrie Neighbors

Page 2

Case 2:08-cr-20105-CM-JPO Document 107

Filed 06/23/10 Page 3 of 3

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,

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

Motion to Quash the Motion for Under Seal as to Carrie Neighbors

Page 3

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