Case 2:08-cr-201 05-CM-JPO Document 87 Filed 04/26/10 Page 1 of 4

Carrie Neighbors
Defendant [1]/ Pro Se Litigant
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

07-20t24-CM
OS-20tOS-CM
CARRIE NEIGHBORS,

Defendant 1,

GUY M. NEIGHBORS

Defendant 2,

DEFENDANT [l)'S MOTION TO EXCLUDE WITNESSES

[Pursuant to FRE § 609 (a)(l)&(2)]

COMES NOW on this 26th day of April 2010, the Defendant [1], Carrie Neighbors,

acting as a pro se litigant is filing a Motion to Exclude Witnesses, pursuant to FRE § 609

(a)(1)&(2). The Motion is as follows:

1). The government had made deals with the witnesses to manufacture a case, to include

offering reduction of sentence, reduction of time, not charging witnesses for crimes committed,

offered money to manufacture a case, or change testimony.

Motion to Exclude Witnesses / w Memorandum in Support of Page 1

 Case 2:08-cr-201 05-CM-JPO Document 87 Filed 04/26/10 Page 2 of 4

MEMORANDUM AND LAW IN SUPPORT OF

DEFENDANT [lJ'S MOTION TO EXCLUDE WITNESSES

2). Pursuant to FRE 408 prevents these witnesses from testifying, due to this coercive

testimony, constitutes bias, or prejudicing this cause of action.

3). Pursuant to United States v. Old bear, 568 F. 3d 814 (l rfh Cir. June 1 rfh 2009)(No. 08-

6095) in which evidence was irrelevant and inadmissible, due to not one witness can testify that

the Defendant [1] had knowledge that the items were stolen, nor can they testify that the person

who sold the items, had notified the Defendant [1] that the property was stolen, in which would

only prejudice and show bias in this cause of action.

4). Pursuantto Camjieldv. City of Oklahoma City, 248 F.3d 1214,1232-33 (lrfh Cir. 2001)

5 acts was insufficient to establish a habitual pattern, in which was never shown in this case, in

which would only prejudice and show bias in this cause of action.

5). During the interviews the government / or police officers had made deals with the

witnesses to manufacture a case, to include offering reduction of sentence, reduction of time, not

charging witnesses for crimes committed, offered money to manufacture a case, or change

testimony. Whereby the creditability of the witnesses is at question, to tell the truth to reduce

their sentence, or time, or offered money to manufacture a case, or change testimony.

6). Now this brings into question the appearance of prosecutorial misconduct to

manufacture a case.

"The government must act with great care when engaging in the practice of paying witnesses for
more than expenses. A defendant's right to be apprised of the government's compensation
arrangement with the witness and to inquire about it on cross-examination, must be vigorously
protected United States v. Lipford, 203 8.3d 259 (4th Cir. 2000). "

Motion to Exclude Witnesses / w Memorandum in Support of Page 2

 Case 2:08-cr-201 05-CM-JPO Document 87 Filed 04/26/10 Page 3 of 4

"The bribery statute 18 US. CA. A§201 (c)(2 proscribing giving a thing of value for a witness's
testimony does not prohibit the United States from acting in accordance with long-standing
practice and statutory authority to pay fees, expenses, and rewards to informants even when the
payment is solely for testimony, so long as the payment is not for or because of any corruption of
truth of testimony. "

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

Motion to Exclude Witnesses, pursuant to FRE § 609 (a)(l)&(2).

Carrie Neighbors
Defendant [1J / Pro Se Litigant
1104 Andover
Lawrence, Kansas 66049
(785) 842-2785

Motion to Exclude Witnesses / w Memorandum in Support of Page 3

 Case 2:08-cr-201 05-CM-JPO Document 87 Filed 04/26/10 Page 4 of 4

CERTIFICATE OF SERVICE

[Pursuant to KSA 60-205]

The undersigned also hereby certifies that a true and correct copy of the foregoing
document 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 of record
142 Cherry
Olathe, Kansas 66061

Guy Neighbors 11520031

Federal Medical Center
P.O. Box 1600
Butner, NC. 27509

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

On this 26th day of April 2010.

Carrie Neighbors
Defendant [1J / Pro Se Liti
1104 Andover
Lawrence, Kansas 66049
(785) 842-2785

Motion to Exclude Witnesses / w Memorandum in Support of Page 4