Case 2:07-cr-20124-CM-JPO Document 229 Filed 04/26/10 Page 1 of 4

Carrie Neighbon
Defendant [1J / 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-20t05-CM
CARRIE NEIGHBORS,

Defendant 1,

GUY M. NEIGHBORS

Defendant 2,

DEFENDANT ill'S MOTION TO TURN OVER ANY AND ALL GOVERNMENT

EVIDENCE, OR PERSONAL PROPERTY SEIZED, PURSUANT TO THE BATES

SYSTEM, IN WHICH IS NOT RELATED TO TillS CAUSE OF ACTION

[pursuant to Fed. R. Crim. P. 41 (g), FRE § 402 and FRE § 403]

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 Turn Over any and all Government Evidence, or

Personal Property seized, pursuant to the Bates Numerical System, in which is not related to this

cause of action, pursuant to Fed. R. Crim. P. 41 (g), FRE § 402 and FRE § 403.

1). Any and all evidence seized, in which the government does not intend to use during

this cause of action, pursuant to Fed. R. Crim. P. 41 (g).

Motion to Turn over any and all evidence, or Personal Property seized. Page 1
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2). Any and all personal property seized, in which the government does not intend to use

during this cause of action.

3). Any and all Merchandise seized, in which the government does not intend to use

during this cause of action.

4). Any and all Jewelry seized, in which the government does not intend to use during

this cause of action.

5). Any and all computers or electronics seized, in which the government does not intend

to use during this cause of action.

6). Any and all Bicycles seized, in which the government does not intend to use during

this cause of action.

7). Any and all weapons or ammunition seized, in which the government does not intend

to use during this cause of action. (Or place a hold on this property until this cause of action is

over), so not to be in violation of a Court order and bond.)

8). Any and all shoes or clothing seized, in which the government does not intend to use

during this cause of action.

9) The Defendant [1] request that proper record of any and all evidence was documented

to preserve any and all evidence seized from either the personal home of the Defendant or the

Business of the Defendant. The Defendant will only accept evidence that is properly recorded

through the bates numerical system.

10). The government has failed to properly handle (through the chain of command), or

properly document any and all evidence seized, in which is governed by equitable principles.

[see ref Floyd v. United States, 860 F 2d 999, 1003 (1 o" ct-. 1988))

Motion to Turn over any and all evidence, or Personal Property seized. Page Z
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11). The Defendant [1] is attempting to make a good faith attempt to avoid any potential

element of surprise to the court, as well as, any and all parties involved in this cause of action,

whereby, the only recourse is to have an evidentiary hearing and attempt to resolve issues of the

evidence, prior to any trial to avoid any unnecessary delay or confusion, as well as, make the

court aware of the evidence being returned back to the Defendant [1], alleviating the courts waste

of time through unnecessary evidence being presented in which may prejudice the case.

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

Motion to Turn Over any and all Government Evidence, or Personal Property seized, pursuant to

the Bates Numerical System, in which is not related to this cause of action, pursuant to Fed. R.

Crim. P. 41 (g), FRE § 402 and FRE § 403.

Motion to Turn over any and all evidence, or Personal Property seized. Page 3
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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 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.

fully

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

Motion to Turn over any and all evidence, or Personal Property seized. Page 4