Case 2:07-cr-20124-CM-JPO Document 231 Filed 05/03/10 Page 1 of 3

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

07-20124-CM
08-201 OS-CM
CARRIE NEIGHBORS,

Defendant 1,

GUY M. NEIGHBORS

Defendant 2,

DEFENDANT UPS MOTION FOR THE PRIOR COUNSEL OF RECORD

[JOHN DUMA] TO TURN OVER ANY AND ALL COPIES OF RECORDS

DOCUMENTS, EVIDENCE, MATERIALS, OR ANY MEMOS, IN WHICH

IS IN HIS POSSESSION PERTAINING TO THIS CAUSE OF ACTION

COMES NOW on this __

~
3-aiy of May 2010, the Defendant [1], Carrie Neighbors,

acting as a pro se litigant is filing a Motion for the Prior Counsel of Record [John Duma] to turn

over any and all copies of Records, Documents, Evidence, Materials, or any memos, in which is

in his possession, pertaining to this cause of action. The Motion is as follows:

1). The Defendant [1] has filed a Marsden Motion to Dismiss her counsel of record [John

Duma] due to violations of Attorney / Client privileges, misrepresentation, and malpractice acts

Motion for Prior Counsel to turn over copies of records, evidence, documents materials
or memos pertaining to this action in his possession Page 1
 Case 2:07-cr-20124-CM-JPO Document 231 Filed 05/03/10 Page 2 of 3

by former counsel, due to conflicts of interests, and failing to represent and protect the interests

of his client with zealousness.

2). The Defendant [1] request the Court order the former counsel [John Duma] needs to

tum over any and all copies of Records, Docwnents, Evidence, Materials, or any memos, in

which is in his possession, pertaining to this cause of action to the Defendant, so she can prepare

a defense to her cause of action.

THEREFORE the Defendant [1], Carrie Neighbors, acting as a pro se litigant PRA YS the

Court order the Prior Counsel of Record [John Duma] to tum over any and all copies of Records,

Documents, Evidence, Materials, or any memos, in which is in his possession, pertaining to this

cause of action.

Ca· 1 hbor
Defendant [1]/ Pr
1104 Andover
Lawrence, Kansas 66049
(785) 842·2785

Motion for Prior Counsel to turn over copies of records, evidence, documents materials
or memos pertaining to this action in his possession Page 2
 Case 2:07-cr-20124-CM-JPO Document 231 Filed 05/03/10 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
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 Ci ty, ~66101
t

On this ~ day of May 2010.

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

Motion for Prior Counsel to turn over copies of records, evidence, documents materials
or memos pertaining to this action in his possession Page 3