IN THE DISTRICT COURT OF THE UNITED STATES

9/13/2015

Guy Madison Neighbors

Plaintiff,

]
v.

Case # 15-4921-DDC

LAWRENCE POLICE

DEPARTMENT, et, al.,

Defendants

MOTION FOR SUMMARY JUDGMENT

Comes Now Guy Neighbors Propria Persona Im representing myself in Propria Persona (in your own
person) or pro-per Qualified me as an attorney in fact, according to Blacks Law Dictionary.By
asserting my Sovereign Right to represent myself in legal matters establishes my status as my own
attorney. To proceed in Pro Per, means that the court cannot impose the same standard up on me as are
imposed on a licensed attorney. This court will treat me as my own attorney, differently that it
would treat me as the defendant, and Moves this court for Summary Judgment for all claims asserted
by plaintiff Guy Madison Neighbors,

Based on the following fact:

I.Background
1. The City of Lawrence failed to place on the record any evidence showing Neighbors was in violation of
any Laws or Ordinances or otherwise.
2. Municipal Court has NO Jurisdiction to hear this case, as Kansas Municipal Court Clerks Manual
states it should be remembered that its the city Ordinance that gives the municipal court its
authority. Plaintiff is only compelled to follow the Constitution, or Congress. This court Lacks Subject
Matter Jurisdiction, as this court wholly derived its judicial authority from the statute of the UNITED
STATES, and NOT the Constitution, Congress or the Legislature. see; Manchester v. Massachusettys, 139
U.S. 240, 262, (1890) ; United States v. Flores, 289 U.S. 137, 151 (1932). The Constitution provides
judicial authority in Article 3, to an Article III court, and this court is NOT an Article III court and
therefore only had administrative Authority, and Lacks any Judicial Authority what so ever.
3. Missing Enacting Clauses, this court gets jurisdiction from the statutes of the UNITED STATES OF
AMERICA the corporation. These statutes and revised codes are not real laws, but prima facia law due
to the fact they do not have enacting clauses nor do they have titles. To be a law it must have an
enacting clause a title, and a body. The enacting clause, and title are missing which means is not a real
law.
4. Neighbors party invoked his Common Law Rights, and since all have received sealed orders from the
U.S. Attorney General, to change over to Article III Common Law Jurisdiction which has Not
occurred to date. This will show the courts "Jurisdiction" is 'Colorable,' bogus, not genuine. Aggrieved
Party believes this court is fraudulently operating as a "STATUTORY COURT OF COMMERCE WITH
INTERNATIONAL JURISDICTION".

5. Municipal Court in in violation of Deliberate Usurpation; Deliberate Usurpation; "Usurpation is

defined as unauthorized arbitrary assumption and exercise of power." State ex rel. Danielson v. Village of
Mound, 234 Minn. 531, 543, 48 N.W.2d 855, 863 (1951). While error is only voidable, such usurpation is
void. The boundary between an error in judgment and the usurpation of judicial power is this: The former
is reversible by fill appellate court and is, therefore, only voidable, which the latter is a nullity. State v.
Mandehr, 209 N.W. 750, 752 (Minn. 1926). The court lost jurisdiction from the beginning of this case
due to the fraud perpetrated by this court, officers of the court, and is in Violation of Aggrieved Parties
due process. See: Johnson v. Zerbst, 304 U.S. 458, 58 S.Ct. 1019; Pure Oil Co. v. City of Northlake, 10
Ill.2d 241, 245, 140 N.E. 2d 289 (1956); Hallberg v Goldblatt Bros., 363 Ill 25 (1936); (8) If the court
exceeded its statutory authority. Rosenstiel v. Rosenstiel, 278 F. Supp. 7 S.D.N.Y. 1967).
6. Traffic court Judge Scott Miller, has a conflict or interest, in that he is a former police officer from
someplace in Kansas, and therefore his impartiality is being called into question.
7. Fictitious victims were manufactured to dispose of evidence that is missing, or cover up for seized
property that were never officially logged into the property room.
8. The evidence from Plaintiffs Federal cases was NOT logged in using the Bates System for
authentication of chain of custody.
9. There is no way to verify the authenticity of the evidence that was presented to the court room at trial
for Carrie Neighbors.
10. Neighbors filed several formal complaints alleging mis-conduct and they have to date never been
investigated.

11. Neighbors investigator from Woods investigative services interviewed several witnesses who claimed
Lawrence Police officer Rantzs and Bialek were impersonating FBI, no real investigation was ever done,
and no one was interviewed by the FBI, agent Bob Schaefer, yet he cleared the Lawrence Police.
12. The only evidence that would show Neighbors did or did not have on a seat belt would be the police
dash cam. The still shot from the police dash cam marked Exhibit A and B will show the police
officer could not see who was driving the vehicle, and no way could he ever see if the driver had a
seatbelt or not.
13. Officer Wech Knew Neighbors vehicle due to the signage displayed on the door of the vehicle, and
also was aware that Neighbors had beat a seat belt ticket already.
14. In as much as every government is an artificial person, an abstraction, and a creature of the mind only,
a government can interface only with other artificial persons. The imaginary, having neither actuality nor
substance, is foreclosed from creating and attaining parity with the tangible. The legal manifestation of
this is that no government, as well as any law, agency, aspect, court, etc. can concern itself with anything
other than corporate, artificial persons and the contracts between them." (Doan's Administrators vs.
Pen.hallow, 3 U.S. 54; 1 L.Ed. 57; 3 Dall. 54, Supreme Court of the United States 1795).
15. Fraud on The Court: Officers of this court are involved in fraud in that this Municipal Court Only
has Administrative authority and is acting as an "Article III" court when it is Not. Whenever any
officer of the court commits fraud during a proceeding in the court, he/she is engaged in "fraud upon
the court". In Bulloch v. United States, 763 F.2d 1115, 1121 (10th Cir. 1985), the court stated "Fraud
upon the court is fraud which is directed to the judicial machinery itself and is not fraud between the
parties or fraudulent documents, false statements or perjury. ... It is where the court or a member is
corrupted or influenced or influence is attempted or where the judge has not performed his judicial
function --- thus where the impartial functions of the court have been directly corrupted."

16. Treason: Whenever a judge acts where he/she does not have jurisdiction to act, the judge is engaged
in an act or acts of treason. U.S. v. Will, 449 U.S. 200, 216, 101 S.Ct. 471, 66 L.Ed.2d 392, 406 (1980);
Cohens v. Virginia, 19 U.S. (6 Wheat) 264, 404, 5 L.Ed 257 (1821) Any judge or attorney who does not
report the above judges for treason as required by law assumes liability.

II. Standard
When filing a motion for summary judgment, the moving party claims that all necessary factual issues are
resolved or need not be tried because they are so one-sided. In this case the plaintiff has on record many
serious issues that prove the defendant came to court with unclean hands the exhibits will show a very
long and serious pattern of abuse and mis-conduct that span almost 10 yrs. Plaintiff has shown he was
forced into a trial without a jury against his will. The documents filed in federal court will show
misconduct that is already on the record in federal court criminal cases but have been ignored.
This court clearly lacked jurisdiction, and when Neighbors addressed the issue in a letter written to the
traffic court became arrogant, and commented that he did not think he would have any trouble defending
himself against Neighbors civil action. So here we are and Neighbors is moving for summary judgment
and if the defendants cannot respond sufficiently and produce evidence to rebut what is contained in this
motion for summary judgment, the motion should be granted in full and the requested damages should be
awarded and or what the court deems just and fair.

CERTIFICATE OF SERVICE
I hereby certify that on the 14th day of Sep, 2015, the foregoing document was filed
in person with the clerk of the court In Topeka KS. by the Plaintiff, to be emailed out to all
parties.
_______________________
Respectfully Submitted

VERIFICATION:

I Guy Madison Neighbors, declare under penalty of perjury in accordance with the Laws of the
United States of America that the foregoing is true and correct and complete to the best of my
knowledge and belief.

____________________________

on this __________th Day, of _______________ 2015

Guy Madison Neighbors

On this ______day of____________, 2015 before me, the undersigned, a Notary Public in
and for State of Kansas, personally appeared the above-signed, known to me
to be the one whose name is signed on this instrument, and has acknowledged to me that s/he has
executed the same.

Signed:_________________________________________
Printed Name:____________________________________
Date:___________________________________________

My Commission Expires:____________________________