FOR THE DISTRIC OF KANSAS

UNITED STATES OF AMERICA

V. Plaintiff,
~.(.lA

GUY M. NEIGHBORS Case No. 07-20124-01-0#DJW

Defendant,

Notice of Motion Requesting a

Change of Venue and to Have

Both Prosecutors Recues

Themselves from Said Cases as

To Avoid the Appearance of

A Conflict of Interest.

Comes now Defendant Guy Neighbors pro-se, and asks the honorable court
to change the venue of all the cases UNITED STATES V. GUY NEIGHBORS
& CARRIE NEIGHBORS 20124-01-01, 07-20073-01j02jwljdjw, 08-20105
jwljjpo, from the State of Kansas to the State of Nebraska, and that the
Prosecutors Marietta Parker and Terra Morehead Recuse themselves from
the cases on the grounds that the Defendants cannot receive a fair trial or
be tried by an impartial prosecutor in the State of Kansas.

I,
 Wherefore the defendants pray that the courts will grant this
request in the interest of Justice, and the defendants would respectfully ask
the honorable court to court to consider the special circumstances
surrounding this case in that the prosecutor is now acting District Attorney
for the District of Kansas and the defendants have filed motions claiming
prosecutorial misconduct, have exhibits from other defendants that will
show a pattern of abuse and said defendants have filed a complaint against
the prosecutors under 42 U.S.C. 1983 for Civil Rights Violations.

The prosecutor now has a vested interest in getting a conviction above and beyond
the interest of Justice. The defendants pray the court will entertain this pro- se
motion as to avoid any appearance of a conflict of interest that could prejudice the
defendants.

The 14th Amendment guarantees the fundamental rights of citizens to due

process and such rights require the scrutiny of the Court. If the Court
decides that it has the right to deny the defendants due process by refusing
to consider their pre- trial pro-se motions, then the Court is failingto insure
justice in this case. Alternatively if no change of venue is granted, then the
defendants ask for a dismissal of all charges.

Because a defendant has no constitutional right to hybrid representation,

the decision to allow such representation lies within the sound discretion of
the trial court. This case merits such a need for pro-se motions because the
Prosecutors control over the defendant's attorneys have caused prejudice
upon the defendants in this case.

Although many jurisdictions have refused to recognize a right of counseled

defendants to exercise their 6th Amendment right to lend assistance of their

).
counsel in their own defense, it is ultimately left to the discretion of the
trial court to determine whether such participation is permitted (see, e.g.,
United States v Einfeldt, 138 F3d 373,378 [8th Cir], cert denied 525 US
851; United States v Tutino, 883 F2d 1125, 1141 [ad Cir], cert denied 493 US
1081; United States v LaChance, 817 F2d 1491, 1498 [t ith Cir], cert denied
484 US 928; United States v Mosely, 810 F2d 93,97-98 [6th Cir], cert
denied 484 US 841; United States v Halbert, 640 F2d 1000, 1009 [oth Cir];
State v Frye, 224 Conn 253, 256, 617 A2d 1382, 1384-1385; State v Long,
216 N.J Super 269 275-276, 523 A2d 672,675-676).

While there may be circumstances where the unjustified refusal to

entertain meritorious pro se motions would constitute an abuse of

discretion, that circumstance does not apply when a defendants

Constitutional rights are jeopardized.

DEFENDANTS HAVE A CONSTITUTIONAL RIGHT TO BE HEARD

The decision to allow hybrid representation implicates the trial court's

function in ensuring the orderly administration of the proceedings and the
special circumstances in this case. (see, People v Mirenda, supra, 57 NY2d,
at 266). As such, it is a matter committed to the sound discretion and of the
Trial Judge,

The defendants respectfully ask this court to change venue or dismiss

through this pro se complaint under oath alleging violations of civil and
Constitutional rights, conspiracy, direct conflict of interest, and
prosecutorial misconduct, and therefore the courts must read the
complaint's allegations expansively, Haines v. Kerner, 404 U.S. 519, 520-21,
92 S. Ct. 594, 596, 30 L. Ed. zd 652 (1972), and take them as true for
purposes of deciding whether they state a claim. Cruz v. Beto, 405 U.S. 319,
322,92 S. Ct. 1079, 1081, 31 L. Ed. zd 263 (1972). Moreover, "the court is
under a duty to examine the complaint to determine if the allegations
provide for relief on any possible theory." onner v. Circuit Court of St.
Louis, 526 F.2d 1331, 1334 (8th Cir. 1975) (quoting Bramlet v. Wilson, 495
F.2d 714, 716 (8th Cir, 1974)).

There are fundamental rights of citizens to due process and such rights
require strict scrutiny of the Court.

The courts have assumed that the sixth amendment rights to representation
by counsel and to defense pro se are mutually exclusive. Under the hybrid
defense the defendant has the active assistance of counsel but may also
participate in his own defense as co-counsel. A necessary tool to ensure
justice when the defendant has been prejudiced by the restrictions placed
upon the defense by the Prosecutors in the case.

The defendants are currently represented by competent counsel but are

forced to me motions pro-se because the Prosecutor has created prejudicial
limitations upon the defense attorneys, by violating the defendants right to
assist their attorneys in their own defense, and controlling through
limitations how the defense attorneys handle the defense of their clients
through the "contract to withhold discovery from the defendants" This is a
standard contract that the prosecutor has forced the defense attorneys
representing clients in cases she is prosecuting to sign. All defense
attorneys in USA v. Neighbors have confirmed they were forced to sign this
contract before accepting the case. (see exhibits 1 page 1 &2, a copy of Terra
Moorhead's illegal contract to withhold discovery from defendant) in
violation of Federal Rules of Criminal procedure, rule 16, which clearly
states the defendant has rights to the discovery. At no time does Rule 16
say the prosecutor has a right to force the defendant's attorney to sign a
contract to withhold discovery from defendant, nor does this Federal rule
give the Prosecutor the right to only disclose the discovery to the
defendants attorney)

The Prosecutor has made it nearly impossible for the defendants to assist
in their own defense, by forcing the defense attorneys to sign a contract that
does not allow the defendants to view, copy, or obtain the evidence that is
being used against them. A clear violation of the defendant's rights.

Paid attorneys hired by the Neighbors have been threatened with "Money
Laundering" charges by the Federal prosecutors in an attempt to control
the defense. (see exhibits labeled money laundering #2)

(Defense attorney Sarah Swain told the defendants the prosecutor had
threatened her with "Money Laundering" and therefore would need all
future payments to be made with credit cards. Defense Attorney Aaron
McKee was threatened with "Money Laundering" and requested that the
defendants set up a paypal account using someone else's name in order to
pay him, then as shown in the exhibit even placed the request for paypal on
the bill. After the defendants accused the Attorney of coercion with the
prosecutor the payment option was removed. See Exhibit #2 pg.z )

s.
This hybrid pro-se motion accommodates the fundamental values
underlying the sixth amendment and should be recognized as the
constitutionally compelled approach, for defendants implementing "the
right to assistance of counsel."

BACKGROUND:
It is a matter of fact that the Prosecutor Marietta Parker has a direct conflict
of interest in Prosecuting this case and do to the fact she is currently the
Acting United States Attorney for the District of Kansas, overseeing the
DISTRICT OF KANSAS Department of Justices in Topeka, Wichita, and Kansas
City, and is currently in direct control of overseeing over 100 attorneys.

The defendants cannot possibly be assured a fair, un-bias and impartial

prosecution and trial in the State of Kansas. The disqualification of
Government counsel is indeed a drastic measure" Bullock v. Carver, 910 F. Supp.
551, 559 (D. Utah 1995) "where it is shown that an Assistant United States
Attorney is subject to a conflict of interest, the proper remedy generally is to
remove that individual from the case. Crocker v. Durkin, 159 F. Supp. 2d 1258,
1284-85 (D. Kan. 2001).

During the course ofthe investigation starting in 2005 into the Yellow
House Business, the Defendants and their defense attorney along with
numerous witnesses turned in formal complaints alleging Police
misconduct, color of law violations, racial profiling, rules of evidence
handling violations, evidence storage violations, due process of law
violations, search violations, false arrest, forgery of legal documentation,
harassment and coercion of witnesses, along with the allegation of an
altered video being presented to the courts as evidence, and several months
of covert surveillance from the Fire station across the street, absent of a
court order. These complaints inadvertently were sent to the Prosecutor,
yet the Prosecution has excluded all of this exculpatory evidence from the
defendants discovery files handed over to the defense attorneys in the case.

(In a direct conflict of interest) All these complaints were forwarded by

Internal Affairs Sgt. Dan Ward under the direction of Chief Ronald Olin, to
the Kansas City Department of Justice, and ended up in the prosecutor of
the case; AUSA Marietta Parkers office for review and action.

In support of this allegation: (see exhibit #3 letter from KU Police Director

Ralph V. Oliver informing the Neighbors that the complaint was forwarded
to the AUSA Marietta Parker and all further complaints should be
forwarded to her.) Also see Chief Olins letter to attorney Sarah Swain
advising that Marietta Parker was the one to address complaints to. (In
exhibit #4 pg. 5)

Instead of insuring justice on behalf of the defendants rights violations,

the US Attorney's office has conspired with law enforcement, staged an FBI
investigation (see FBI exhibits #4 pages I through IS)

(Exhibit #4 page 1 &2, Signed affidavit by Laura Helm stating she was
picked up by two officers posing as FBI agents.)

(Exhibit #4 page 3 & 4, Interview-statement by Brad Perico to Private

Investigator Cecilia Woods stating he was contacted by two officers

l,
claiming the FBI was investigating the Yellow House and had him on tape
going into the business with a drill.)

(Exhibit #4 page 5, Letter to defense attorney Sarah Swain from Police

Chief Ron Olin stating that he could not release the identity of the Federal
Investigators, that Police posing as FBI would be a crime, and that Special
Agent Bob Shaefer had spoken to her about the issue. He also states that
further correspondence concerning the case should be directed to u.S.
Attorney Marietta Parker.)

(Exhibit #4 page 6 & 7, Letter to Sarah Swain from the FBI explaining that
u.S. Attorney Marietta Parker sent FBI Special Agent Walter Schaefer to
investigate the allegations of police posing as FBI agents, verifying 60 days
had passed and made reference to repeated unanswered phone calls made
by Swains office to the FBI in an attempt to set up further meetings with SA
Schaefer. According to Special Agent Scott Gentine from the Topeka FBI,
the letter was Signed by a retired special agent Kevin Stafford, sent by
Timothy A Gallagher)

(Exhibit #4 page 8, letter to Bob Schaefer FBI, from Defense attorney Sarah
Swain)

(Exhibit #4 page 9 & 10, article in LJworid newpaper that the FBI was
investigating the conduct of police in the Yellow House investigation. Jeff
Lanza also confirmed the FBI was not involved in the Yellow House
investigation.)

(Exhibit #4 page 11, article in LJworid Newspaper stating that the FBI
investigation was stalled and that the FBI had not received a formal
complaint. Even though the defense attorney had attempted multiple times
to set up meetings, some days attempted to call SA Schaefer 6 times
'without a return call, left messages and faxes for SA Schaefer.)

(Exhibit #4 page 12, Article in LJworld Newspaper confirming the FBI had
completed the investigation and cleared the police of misconduct.)

(Exhibit #4 page 13, letter to Agent Schaefer from Defense attorney Sarah
Swain letting him know she had forwarded a sworn affidavit of illegal
conduct by the Lawrence Police, and had made numerous attempts to
contact him about the matter but had gotten no response from him.)

The Government in a controlled reaction, used the information contained

in the complaints forwarded to her, to use her team of investigators to
retaliate and conspire against the defendants and then in an abuse of her
power, also controlled the defense attorneys handling the case.

In order for a defendant to prove conspiracy the defendant need not allege
personal involvement by all the parties. When a person is part of a
conspiracy, one does not require a hub and spoke form. One need only be
part of a chain of conspirators.

Law enforcement officers Jay Bialek, Mickey Rantz, Michael Riner, Police
Chief Ron Olin, Postal Inspector David Nitz, IRS Agent Robert Jackson
and the Kansas City FBI Agent "BOB SHAEFER" Walter Robert Schaefer,
were employed by the Prosecutor as her agents to do the dirty work on her
behalf, outside of their agencies jurisdictions with her full knowledge and
approval. In conspiracy to cover-up, conceal, obstruct justice, and limit
liability in order to avoid accountability for the Governments unjust actions
against the defendants.

Conspiracy to violate civil ri9.!1.1§.

In order for this court to establish a cause of action to change of

venue or dismissal for conspiracy, there must be sufficient facts to
support the following elements:

1) two or more persons;

2) an object to be accomplished;

3) a meeting of minds on the object or course of action;

4) one or more unlawful acts; and,

5) "damages" directly linked to the violation of the defendants rights ..

1. Obviously there are two or more persons involved.

2. The object to be accomplished is to obstruct justice, cover up for
color of law violations and prosecutorial misconduct, obtain a
conviction through fraud, to cover up criminal conduct against citizens
by officials, and to avoid liability.
3. The Government clearly had a unity of purpose or a common design
and understanding in their joint efforts to avoid liability and conceal
Constitutional rights violations. The Prosecutors Terra Morehead and
Marietta Parkers actions were clearly improper and directly
connected to the conduct of the acting Government officials under her
command. There is no other explanation as to why these Prosecutors
would break the rules to cover up reports of criminal activity by Law

!D.
 enforcement against a wrongly accused citizen other than that they
had joined into a common purpose with the team.
4. The unlawful acts against the defendants have greatly prejudiced the
defense and have been documented through photographs, video's
and voice recordings, court documents, affidavits, and testimony
under oath during various hearings before Federal Judges
overseeing this case.

These are very serious allegations and this court has a duty
to the Constitution to protect the integrity of the courts.
Therefore, this District of Kansas court, which has a prima
facia conflict of interest, has a duty to construe this pro- se
motion very liberally and grant the defendants request for
change of venue or dismissal of charges, in order to protect
the public perception of the integrity of this court.

A FAIR TRIAL FOR THE DEFENDANTS IS NOT POSSIBLE IN

THE STATE OF KANSAS or MISOURI
-_._-- _----_ _ -
.. ..

AUSA prosecutor Terra Morehead has interfered with the Defendants

Guy and Carrie Neighbors fair chance to defend themselves.

Terra Morehead originally charged the defendants with being unlawful

users with firearms. A statute that the case did not qualify under.
Because the defendants had no criminal history, there was no evidence
of habitual drug use, and the firearms were expensive collector "non-
 qualifying" firearms unloaded and unlawfully seized without a warrant by
law enforcement from a locked safe.

During several hearings before Federal Judges, law enforcement

officers have read fabricated stories by witnesses and lied under
oath, to the court .

The prosecutor has taken things out of the defendants discovery. Certain
things that were seen in the discovery while in the possession of past
attorneys Bruce Kipps, Philip Gibson, Alex McCauley and James George
have been changed or switched out. ie. Police evidence reports,
statements, search warrants, receipt for same list.

The Courts have been made aware of the fact that the false testimony by
convicted felon Patrick Nieder was presented before the Grand Jury in
exchange for an 8 year reduction of his prison sentence.

On July 1, 1998, a 3-judge panel of the 10th Circuit, U.S. Court of Appeals
delivered a decision, in the case U.S. v. Singleton, The 10th Circuit ruled that
bartered-for, testimony in federal criminal court is not only illegal and
inadmissible, but technically punishable by a substantial fine, and/or up to 2 years
in prison.

Prosecutors have offered both cash payment and leniency to some witnesses, and
offered plea deals to louis Parsons and James P. ludwig in exchange for
anticipated false testimony at trial claiming that the Defendant Carrie Neighbors
conspired with them to conceal the conspiracy, absent of any existing evidence to
substantiate these claims. It is the responsibility and duty of the prosecutor to
always try to substantiate (what) any witness for the government is going to be
saying.

In a separate case in a 31-page ruling U.S. District Judge William J. Zloch threw out
the testimony of three accused drug defendants on grounds that it was solicited
with a prosecutor's promise of a reduced sentence a violation of federal bribery
laws, he ruled. In this case.

"U.S. Code, Title 18, Section 201©(2) (the 'bribery statute'

could not be more clear. It says: Whoever ... directly or indirectly, gives, offers or
promises anything of value to any person, for or because of the testimony under
oath or affirmation given or to be given by such person as a witness upon a trial,
hearing, or other proceeding, before any court authorized by the laws of the
United States to hear evidence or take testimony shall be fined under this title
or imprisoned for not more than two years, or both."

A sting video was altered, and there is documented missing evidence,

from the police evidence locker, but the Federal Prosecutors have
continued the prosecution of this case anyway.

The Prosecutors have used their influence and power of authority

to control the Federal Agencies, witnesses and Defense attorneys
involved with this case.

And have exercised in a similar pattern of abuse of power in other

cases as well.

(See exhibit #5 pages 1-5, JOHNNIE WILLIAMS III, case 06-20047-

01-cm. letter to Chief Judge Lungstrum alleging misconduct by
Prosecutor Terra Morehead)

(Exhibit #6 pages 1-5, JASON McKINNEY dated June 30,2008

complaint sent to The Office of Disciplinary Administrator, alleging
malicious prosecution by AUSA Terra Morehead.)

(Exhibit #7 pages 1-4, James McKeighan letter to The Honorable

Judge Lungstrum dated Jan. 22, 2007, alleging Prosecutorial
Misconduct against Terra D Morehead)

/3
 The Prosecutors have interfered with the defense attorneys
filing motions on behalf of their clients.
1. IE. The Neighbors requested that Attorney Phil Gibson file a motion
to release an illegal lis pendens placed against their property by the
Prosecutor. The motion was filed and Judge Murguia scheduled a
hearing the following week. Mr. Gibson then canceled the court date.
After 3 week delay, the motion was refilled and four days later the
Prosecutor filed a Superseding indictment to moot the motion. With
the sale of the house still in limbo and the buyers getting anxious the
defendants asked Mr. Gibson to refile the motion, he agreed to refile
that weekend but then, even after repeated requests from the
defendants never did refile the motion. After several more weeks the
sale of the house had to be terminated.
2. The Prosecutors in this case have violated the Neighbors Bill of
RIGHTS!
3. Amendment V.- Deprived the Neighbors of life, liberty, and property.
A- Life- The Prosecutor has had the Neighbors arrested by agents
operating outside their Jurisdictions several times, searched, and
held in custody, using statutes and laws that do not apply. Ruined
their business, reputations within the community, the false allegations
have cost the Neighbors their Foster care license and their affiliation
with the Big Brothers program, In 2005,Prior to any charges being
filed the Government contacted ebay and made false unsubstantiated
allegations resulting in the immediate suspension of the defendants
seller account and also resulted in the defendants money in the
Paypal account being frozen., greatly affecting the defendants
livelihood and ability to run their business and pay bills.
 Public False allegations released to the press include stolen
property fencing, money laundering and drug trafficking. And on the
DOJ press release web site falsely claimed the Yellow House crimes
had been investigated by the FBI.
B-Property- The Government has been holding Property since
December 2005, property unlawfully seized during the execution of a
violated search warrant, and gained through an illegal warrantless
search, denying the defendants constitutional right to due process of
law.
4. Amendment VI. Right to Speedy Trial and effective council.
5. A- violation of right to speedy trial. The original charges of being an
unlawful user with firearms was originally dropped with just 7 days left
before the time limit of a speedy trial ran out. The same charges were
re-filed as a brand new case, and the prosecutor had the Neighbors
strong armed arrested from their home and illegally searched.
B- The original search and seizure was executed in December of
2005. This is now November of 200B.The Neighbors have been
denied the due process of Law, have not been allowed to view the
discovery or see the evidence being held against them. Because of
the Prosecutors threats against the defense attorneys, during the
three years the case has been in the courts, the defendants have not
had any motions filed by the defense attorneys directly related to
defending the case ie. standard Motion Requests for evidentiary
hearing, request to see the evidence, request for dismissal, request
for suppression of evidence. The Neighbors have not been afforded
an investigator to conduct interviews of witnesses nor has the
 prosecution allowed the defendants to see the list of witnesses
scheduled to testify at trial on behalf of the prosecution.
C- The Prosecutor has forced the Neighbors to loose paid attorneys,
and then forced them to use court appointed attorneys that are willing
to sign her contract and allow her to maintain a strong influence over
the handling of the defense.

CONCLUSION;

This court has a responsibility to assure that its regulations are conceived
in the public interest and not in furtherance of self-interests. Every lawyer
and prosecutor is responsible for observance of the Rules of Professional
Conduct. Neglect of these responsibilities compromises the independence
of the profession and the public interest which it serves.

The United States is a government of the people, by the people, and for the
people. The judicial system's function is to serve the public by providing a
means to serve justice and to resolve disputes. This can only be done in an
environment where honesty, integrity, and high moral standards are strictly
enforced.

There is an obvious mix of Conflict of Interest and Special Circumstances

in this case that together will prevent the Neighbors from entertaining their
Constitutional right to a fair and impartial prosecutor. Since the judicial
system is self-governing and is therefore responsible for policing itself, it
has become obvious that the Neighbors cannot possibly expect a fair trial
under these circumstances. Therefore the Neighbors respectfully ask the
courts to grant this Pro-se Motion to Change of Venue or Dismiss all
charges.

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 PROOF OF SERVICE FORM

A copy of this form shall be appropriately filled out and attached when Proof of Service or statement of delivery or
mailing is required.

Personal Deliverv: I (! / r
I declare that on jI- D3-oVI personally delivered the attached/%tiol! ,-f// (h41/ dJ(t~
(Dat~k.L J ~ ( o'--/''t-- (Description of Document)

(Name of Recipient)
~;? v sl-c;~ Cofl
(Location)

:;1'7
Part 3 I declare under penalty of perjury that the forJ'1!'0ing is true and c~rrect and that this declaration was

Executedon6-tJ( at J"s,f.-c< IkfL/i j}/S/r,2 ! cf- .Kansas.

(Date) (City)
 U.S. Department of Justice

Eric F. Melgren
United States Attorney £"'>"'/1.11,;- ..
District of Kansas
£XJ//rIILFf,
Kansas City Office Wichita OjJicl
S",ilL! 160 llOOEpic Center
500 Stak Awn"" \. 301 N. Mai.
Kansas City, Kw",66101·U33 V Wichita, Kanras 67101-4811

TEL{YJ3) 55!~7]0 Topeka Office

FAX (913) 551-65n' U4 Qwinq
TOD (913) 551-M66 S.lte ]!IIJ
Tape*". Kanuu 66~]-]591

. United States vs. James McKeighan

Case No. 06-20066.QI-IWL

as
1 hereby acknowledge counsel for theabove captioneddefendant, that I am in receipt, on
loday's date, of discovery consisting of oneClxwhh pages which are bates-stamped from 0001 •
Pll'3 . By signing below, 1further agree lhat I will not show the pages of discovery to myclienl or to
provide copies to' anyone including illY client Finally, in the event that I withdraw from this case, I will
return all discovery to the U.S. Attorney's Office So that it can be properly disseminated to substitute
COWLSel. This agreement wiJI also applyto any further or future discovery provided by the Government
in this case.

£?if CJ'c-r~~
S.A. Scimeca
Attorney for James McKeighan

Date

\ I
,I
 ,
U.S. Department of Justice

•
rr-. Eric F. Melgren
United States Attorney
District of Kansas
Kansas City Office Wichita OffICe
SuireJ60 1200£.pic Center
500 Stare Al'enue 301 N. Main
Kansas City, Kansas 66101-1433 Wichita. Kansas67l01-181 2

TEL(9J3) 551·6730 Tope1:a ODie<

FAX{9lJ} JJl·6H1 SuiJe290
TDD(f)I3) 551·6666 4# SEQuin')'
Topeka,Kansas 66683-3592

June 5, 2006

Tim Scimeca
313 North Seneca
Wichita, KS 67203

•
,~..
Re: United States v. James McKeighan

Dear Tim:

.'. Enclosedare pages which are. bates-stampedfrom0120 - 0138 which are provided
to you as discovery in this case: TFtEi~(! are provided to you y,.ith the understanding that
you are riot tashCiw them toY()UrclleritortiJ'provide~plesto anyone including yourdient.
If you have a prbblerrrWithihis,. plea's8 retuiri.theni to me;' Iii the event that you withdraw
from this case, please return all disGOi'etytd thisofflce So that it can be properly
. disseminated
.
to substitute
.. .
counsel. Ple~'se'&illn1'eif
; . ' .' . .
you. have any Questions.

Sincerely,

j
J~-D.J/VL~
YERRAO. MOREHEAD·
Ass istanHfuited-Sfutes-AttOIII ey

TMijrns

Enclosures

• ),
 Law Office of Aaron C. McKee, Esq.
21604 West 98th Terrace

-
Lenexa, KS 66220
Phone (913) 219-0652
Fax (913) 764-0652
aaronmckee@mckee~law.com
www.mckee-Iaw.com

l" internet at www.mckee-Iaw.com.

To:
Yellowhouse
Date
Carrie Neighbors
1904 Massachusetts Street 8/3112006
Lawrence, KS 66046

Amount Due Amount Enclosed

$6,057.85

Dale Transaction Rate Hours Amount Balance

08/28/2006 Teleprtone conference with Rob Jackson 175.00 02 3500 4,692.85

regardin9 proffer meeting on August 29, 2006.

08/29/2006 Attended proffer meeting W'ith Lawrence PO, 175.00 4.5 787.50 5,480.35
I IRS and USPS.

L 08/29/2006 Traveled to/from Lawrence to attend proffer

meeting,
175.00 1.4 245.00 5,725.35

, 08/30/2006 Telephone conference with Carrie Neighbors 17500 0.4 70.00 5,795.35
i regarding Guy Neighbors firing Sarah Swain.
I
08/30/2006 Telephone Conference with Rob Jackson 175.00 0.3 52.50 5,847.85
regarding Guy Neighbors finng Sarah Swain.

08/31/2006 Telephone conference with Jim George 175.00 0.5 87.50 5,935.35
regarding status of case.

08/3112006 Telephone conference with Carrie Neighbors 175.00 0.2 35.00 5,970.35
regarding Jim George replacing Sarah Swain
on case.
i 6,057.85
I 08/31/2006 Telephone conference with Carrie Neighbors 175.00 0.5 87.50
regi:Jrdil1g case strategy and settlement
negotiations.

I
l
,,
I
i
:
,, 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS
j CURRENT Amount Due

-
DUE DUE DUE PAST DUE

3,380.35 2,677.50 0.00 0.00 0.00 $6,057.85

:
- Page 3
 13970 Santa Fe Trail Drive
-., lenexa, KS 66215
Phone (913) 492-3970
Fax (913) 492-3971
aaronmckee@mckee-Iaw.com Aaron C. McKee, Esq.
kimberlyireland@mckee-Iaw.com Kimberly.l. Ireland, Esq.
www.mckee-Iaw.com

Statement
To:
Yellowhouse
Carne Neighbors Date
1904 Massacl1usetts Sireet
11130/2006
Lawrence, KS 66046

Amount Due Amount Enclosed

$4,490.35

Date Transaction Item Rate Hours Amount Balance

09/06/2006 Traveled to/from Lawrence to meet with ACM - Travel 175.00 1.6 280.00 3,195.35
lawrence PD.

09/0612006 Met with Lawrence PO and USPS. ACM - Meeti. 175.00 2 350.00 3.545.35

09/0812006 Telephone conference with Rob Jackson ACM· Telep ... 175.00 0.3 52,50 3,597.85
regarding case.

19/08/2006 Telephone conference with Rob Jackson ACM - Telep ... 17500 03 52.50 3,650.35
I"'" regarding case.

09/11/2006 Telephone conference with Mickey ACM - Telep ... 175.00 0.2 35,00 3,685.35
Rantz regarding potential undercover
operation.

0912112006 Telephone conference with Carrie ACM· Telep ... 175.00 0.2 3500 3,720.35
Neighbors regarding status of case.

0912112006 Telephone conference with Rob Jackson ACM· Telep ... 175.00 0.2 35.00 3,155.35
regarding status of case.

10/1212006 Telephone conference with Mickey ACM - Telep .. 175.00 0.2 35.00 3,790.35
Rantz regarding raid on LP.

10/1212006 Telephone conference with Carne ACM - Telep... 175.00 0.2 35.00 3,825.35
Neighbors regarding raid on lP.

10/20/2006 Telephone conference with Rob Jackson ACM - Telep ... 175.00 0.2 35.00 3,860.35
for status report.

11/1512006 Telephone conference with Carrie ACM - Telep ... 175.00 0.3 52.50 3,912.85
Neighbors regarding Lawrence PO's
request to meet with her.
I

.-
1-30 DAYS PAST 31·60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS
CURRENT Amount Due
DUE DUE DUE PAST DUE

2,432.50 0.00 0.00 2,051.85 0.00 $4,490.35

I

Page 3
KUKANSAS Office of Public Safety

October 8, 2008

Carrie and Guy Neighbors

1904 Massachusetts Street
Lawrence, Kansas 66044

Dear Mr. & Mrs. Neighbors,

On September 16, 2008, you delivered a written complaint to the University of Kansas Public
Safety Office. Captain Schuyler Bailey was the department representative who received your
complaint. Your complaint alleges that on August 13, 2008, a member of the University of
Kansas Public Safety Office, Detective Michael Riner, committed perjury during testimony in
Federal court.

By way of this letter, I am notifying you that your complaint has been provided to the U.S.
Attorney's Office. That office is the appropriate investigative agency to receive a complaint of
alleged perjury in Federal court. The following individual may be contacted should you wish to
provide any further information regarding your complaint against Detective Michael Riner:

AUSA Marietta Parker

500 State Ave.
Suite 360
Kansas City, Kansas 6610 I
913-551-6730
marietla.parker@usdoj.gov

RVO!sp
cc: Marietta Parker

{L0013126 /lOmce of Public safety

Public safety Building: 1501 Crestline Drive, Suite 120 I Lawrence, KS 66049
(785) 864-5900 I Fax (785) 864-5211 I www.ku.edu/ckucops
r>. THE SWAIN LAW OFFICE
Sarah G. Swain
Attorney at Law

601 Missouri. Suite 3 110 N. Cherry, Suite 240

Lawrence, KS 66044 Olathe, KS 66051
(785) 842-2787 866-550-2787
www.lawrencecriminalattomey.com swainlawoffice@gmail.com

FAX COVER SHE~~r

DATE: 6-30-06

FAX TO: Bob Schaefer / FBI

FAX l\1JMBER: (816) 512-8545

SENDER'S NAME & FAX NUMBER: Sarah G. Swain @ (785) 842-2787

RE:

PAGES: 1

COMMENTS:
Untitled rage I 'J or zu

/
WOOD INVESTIGATIVE SERVICES, INC.

I. Laura Helm. oflawful itge. btin~ full)" :JW'Om upon oath, states:

Ibat. in carl ..· March ~OOi;. ! \">1~ contacted tty two men while 1 was !it&ying al my
bmlher"s tRay Mayberry) residence located ar 2200 Harper. e44 lawrence, K5. I am
,t
unsureof the date. but J dll rc:l.:w! ~;15 several weeks ago llr'Id it 'MIS duri~ !he week. (
belie..'e. but ( urn not certain, that the dale Yle3C' two men I;nntac[ed and uuervie)\\!'d me
wat .\1arch 6. 2006 between Q:OO a.m.• J0:00 a.m.

Tbat. these two men, appmacll.~d m~' re.sidence and asked to 51'tak with me, I can
best describe the IirsL man as a "\.\11m. 5'05". a little ~I!y and short s.piky blonde- hair.
Thi~ man did rnosr of the tatking during our contact. He ~id his naDl~. which I do nOI
re-call. and ·i~.ud !he~ worked with the "Federal Bureau of invesligBi:ion." He cUd not ':!lUy
'!11 flit: ~t -nivl 'IJ<-~ entire Surecu nc.ne. Ihe second man was a wzm, !hort d.a.rk. hair.
6·rj" and 3. biii!!~T build. than the firsr man. The second man did DOl say much. The-
';"~·l'~t; ""!'ut1 .!.oJ 1t.:'!1 m~' i ·,ra:'" om il'l trouble, but GUY andCarrie NclJlhbors were. Both
men were -i-;m))an) dressed ill ~}u. and shirts, Th~y both wore a ~.dBe nn Ltu:ir belb
and h;K1 guns in holsters made of light color leather that Wi1.'J abo worn on their waist.

ru.«. !hliO :\r-;( man told nit! : ··naJ [0 tall to them." 1 asked 11 m ifit "had to be
rcdev," He ii11,J j( Lilli nm aave [0 be 1000,.. aUG mll:!:~ agreed aJ come tJIKk Uk t"oll'll\\lllltr
Ja... These ,,\111\:l.;'~ retuned 11"1..:· 'll!'XI ,-1a~ .mc rkl-:o;:.i rue ';.J~ in ":!. ·h:~ blue ':;::'V !'I.r.;o
Yt:i'uc.le. : J1J not want to W(I with the-n. blJtfeit lrum the way [hey WC.l:'e ming mat I did
1101 have ;] cboiee. TIl~ drove me.' 'v the- Lawrence Police Department at 11'· and
\lassachl,;k"tT:t ~l~t:r. Lawrence. K'S. we went mstde the i:'Iuilding tnrough an lJutside
door. I n~t.:.:J.l! fh~ min .murinM In <l P I:JS Lode !D th~ :mc:riM tiot)r lllal allowed US inside
!ho: police Jt'rarunenL ..,.~ weru inn- un imerv re...... room where hor.h men r4lked to me.
Th~y qtf<~t:.l~ mt: -tcms I traW .sold 1(1 (h< 1 <lJr,.,v HOlJfFe in lhe pest. They loltJ
.tnVlJI
me:- ~hey oM:lI~ my name through ch :!Ck" tbat were written by the Yellow House.

Trw.t. i!ft~:, t~~ quesucned me ror JD hour to an hour and a halJ. they dwn drove
me truck co rn~· h.¢u....c. During tile drive: home: mit) gO\li: me a busiUt:53 card widl Bold
lettering on il. I heve mispieced that -tard. Tht':' told me to c::aJ ( if [ d~ded to work for
th.em on ~t-...~ Y.:lI~J\\, HOLL~~ case. TIley offcrtd me $50.00 for ea~b time 1 would be
willing to atttm1JJl to !5eil stolenitems to the YeUow House.

bttp:lldocs.google.comIView?docIb=dgpr72qd_497g2ppzmfp&revision=_latest 10/112008
Untitled Page 20 of20

Tha~ j did oor leellike I bad • choice in talking with tbest RlCII amll bad to go to
UIo JWiOll with lhem or I would have been in lrOUble,

That. because I un on prcbericn, l comecred my E'rubation OffiCt-T. Harley Eddis.

af\(:r lhi~ ";lmW:~ to advise him whlu had occurred. He- told me that I c:ould not be
Involved in this type of work for ~ soliee if f wanted to ~ to my probarion on:ler. (
never had ally lnt-eruinns ofwooong 'WIth the police and lold them r wouJd net.

That. t :am certain 1 have seen these men before and I belity~ they BI'e Lawrence
Pettee Qffkm and 00'
federal 3.~nt i. Ibc first mati dearr~' identH'ied· himself ~ :hl,,!
·l·.=~ . .'r,lol iJur..:.I.U.d In\~$U¥UllrJn.''

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Subscribed lllH! ".om 10 mebefore lhi~,- day of ~'._,,;, " •• 2006.

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 (,

Dnd Perko ;.. ") 2-""(,

1008 Alma
Lawreoee, KS. 66847
An attempt was made to contact Brad at this address. The man residing at this duplex
reported therewas no Perieo at this locationand he did not know the name. Another
possible address was located for Brad Perico:
Possible address:
4500 OverlandDrive # 105
Lawrence, Ks.

Brad calledthe office from 785-841-0227. Arrangements were made for an interviewon
03mJ2006 at Culver's ~urant at 4:00 p.m, Brad reported he wanted to get this
situation stmightened out He said he had been in to see Carrie Neighbors and she told
him not to come back around. She told him to call me and talk about this situationbefore
heretumed.

Brad reported he was recentlycontactedby Lawrence Police Detectives. He recalled one

Detective as Jay Bialek. He did not know the other Detective but he describedhim as a
w/m, 6'0", with short brown hair combed on the side, Brad said he wssat a friend's
apartmenton Redbud Street approximately three weeks ago. He said he was leaving the
apartment and walking to the front locked entry way when he saw the Detectives at the
front lockeddoor attempting to 'jimmy the lock." Brad said he is certain the cops had to
have followed him over to this Redbud address, becausehe knows of no other way they
knew he was there.

Brad said Bialektold him the YellowHouse had been under federal investigation f0l'7-8
months. He told Brad, Carrie has been under federal investigation and "She is going
down" and "She will take her husband with her." He further said the FBI hadhim (Brad)
on surveillance tape at the Yellow House taking in a drill. He said they questioned him
about the drill. He explainedto them that he has done auto body work for years and had
a lot of tools. He said the detectives told him, "We knowyou are in trouble." Brad said
Bialek also told him, "We know you know what's going down." Bialektold him he
would get him help with the (6) municipal citations he had ifhe would help them with the
Yellow House investigation. Brad said he told them he would think about it, but he knew
he would not help them. Brad said he wouldn't do this becausehe was friends with Guy
and Carrie. He said Detectives at the LKPD had also lied to him in the past and have not
come through with their promises, so he did not wish to help them any longer.

Brad said while the Detectiveswere talking to him outside ofthe apartment building on
Redbud Streetthey started to hand him a business card. He said lllId he told them not be
banding him their cards in public. He said he told Bialek to drop his business card on the
ground and he would pick the card up later. He said did pick the card up. He said this
was the card he accidentally handed Came one day at the Yellow House. Brad said he
figures the Detectives were targeting him to work with them because he bad these prior
tickets. He also said he was stopped about 1 liz months ago and ticketed fur a DWS.

4
 Brad said Terik Katib is apparently the Detective's superviser, H~ seid Tcrik does not
like him. Brad further explained that he did a lot ofinformant work for the Lawrence
Police department in the past. He said, more specifically, he did a lot of work for Officer
Scott Peck. Brad said he was the ConfidentialInformant who assisted Peck in his drug
related investigationswhen be was with the police department. He said Peck came under
fire by Judge Malone and he was accused offalsifying his affidavits. Brad saidhe was
eventually exposed at the CI and the Judge said that he (Brad) was not a trustworthy
witness or informant and that is why Peck was ultimately fired.

Brad said it was approximatelythere weeks ago he went to see his friend Jesse
DelCampo at his restaurant "The Slow Ride" in north Lawrence. He said he saw he saw
a lot ofcops in there eating and drinking. Jesse told Brad later that after he left, the cops
told him to stay away from him. Brad said the Slow Ride is a new hang out for the cops.
Brad noted it was shortly after be went into the Slow Ride that the detectives contacted
him on Redbud Street about the Neighbors.

Brad said he was at Kohl's last week and he saw Bialek coming out of the back room of
the store. He said they engaged in small talk and Bialek asked if he had given anymore
thought to what they talked about earlier. He said Bialek admitted Katib "had it out for
him." He said some cops apparentlydid not like the personal relationship he (Brad) had
with Peck.

Brad said his old girlfriend is Kim Filcher. Kim is a sister to Carrie Urbanek. Carrie
/---- Urbanek works for the Douglas County Sheriff's Department Drug Unit. She is married
to LieutententRay Urbanek.

Brad said he believes the two pawn shops in town are raising hell about the yellow
House. He thinks this might have been one of the reasons they are being targeted again.

END OF INTERVIEW

5
 ~~/~~
v7 ~~ A N SA S

W. Ronald Olin, Ph.D. Mike Wildgen

Chief of Police City Manager

April 20, 2006

Sarah Swain, Attorney at Law

601 Missouri, Suite 3
Lawrence, KS 66044

Dear Ms. Swain:

I am in receipt of email correspondence between you and Officer Bialek

regarding the ongoing investigation involving your clients, Guy and Carrie
Neighbors. It is my understanding that you wish to speak with the Federal
investigators involved with the investigation of your clients. Officer Bialek
assures me that he has contacted the agents involved and has informed them of
your wish to be contacted. Additionally, I am aware you have been in contact
with U.S. Attorney Marietta Parker who is handling this case at the federal level
for prosecution. The Lawrence Police Department will not release the identity of
any Federal investigator who is involved in the case.

Your most recent email isofsomeconcern.asit could be read as an

attempt to report potential criminal activity. If this is your intention and the
actlvmes in question took place in the City of Lawrence, please feel free to file a
police report with our department. If these activities took place elsewhere,
please contact the appropriate law enforcement agency from that jurisdiction. I
believe Sergeant Mike Pattrick from this department as well as Special Agent
Bob Shaefer with the FBI has spoken with you in person about these very issues.

Any further correspondence concerning this case should be directed to

U.S. Artomey Marietta Parker. if you need 10 correspond with anyone in the
Lawrence Police Department, please do so in writing, instead of emailing a
specific officer so that it may be routed and handled appropriately. You are
welcome to address your correspondence to me.

Very truly yours,

W. Ronaid Olin, Ph.D.

Chief of Police
WRO:mrp

Investigation & Training Center- 4820 Bob Billings Pkwy. Lawrence, KS 66049· (785) 830-7400
Law Enforcement Center, Parrot & Records Division> III EaSI l lth Street> Lawrence, KS 66044· (785) 832-750 I
City Hall· 6 East 6th Street> Lawrence, KS 66044· (785) 832-3000
www.lawrencepolice.org
 ............
,..- ~, '

U.S. O~partltl~nl of Justice

I) Federal Bureau of Investigation

In Reply, Pfense Refer to

FileNo. 194-KC-C81080 1300 Summit

July 7, 2006

Sarah ,G. Swain

601 Missouri
Suite 3
Lawrence, Kansas 66044

Dear Ms. Swain:

The Kansas City Office of the Federal Bureau of

Investigation (FBI) is in receipt of your letter to Special Agent
Walter R. Schaefer, which was facsimiled to the Kansas City
Division of the FBI on June 30, 2006. The Kansas City Division
of the ;'SI is also in receipt of a facsimiled Affidavit which was
allegedly prepared by Laura Helm on April 22, 2006. This
Affidavit was received by the Kansas City Division of the FBI on
~,~ June 15, 2006.

As you are aware, Special Agent Schaefer visited your

office on April 19, 2006, as a result of your public allegations
and correspondence to Assistant United States Attorney, Marietta
Parker, that members of the Lawrence Police Department were
conducting an investigation and identifying themselves as FBI
agents.
On April 19, 2006, when SA Schaefer visited you in your
office at 601 Missouri, Suite 3, Lawrence, Kansas 66044, you
advised him,that you had ten to twelve witnesses Who claimed that
members of the Lawrence Police Department identified themselves
as FBI ,agents during an investigation.
On April 19, 2006, SA Schaefer requested those names
and you advised him that you,did not have the names and that your
investigator, Cecilia Wood, had those lists of names.
 From April 19, 2006, until June 16, 2006, (sixty days
later)the Kansas City Division of the FBI and SA Schaefer had not
received any correspondence or information concerning your
initial allegations.
The two meetings you referenced as scheduled with SA
Schaefer in your letter dated June 30, 2006, were set by you
without verifying the availability of SA Schaefer.
Any future meetings/interviews should be verbally
verified with SA Schaefer. Simply leaving a voice mail message
advising SA Schaefer that you have a meeting set up on a specific
date at a specific time will not guarantee SA Schaefer's
availability. SA Schaefer can be reached at 816/512-8640.

Sincerely

Kevin L. Stafford
Special Agent in Charge

2
 THE SWAIN LAW OFFICE
Sarah G. Swain, Attorney at Law

Theno Office Complex Park Cherry Building

601 Missouri, Suite :> lION. Cherry, Sui te 24<0
Lawrence, KS 6604<1< Olathe, KS 66051
(785) 842-2787 866-550·2787

June 14, 2006

Bob Schaefer, Special Agent

Federal Bureau oflnvestigation
1300 Summit
Kansas City, MO 64< I 06

Dear Mr. Schaefer:

Enclosed please find the affidavit that we executed with Ms. Helm. We are still
working on getting other affidavit's executed, but as I'm sure you are aware, many
people are too scared to come forward and go public with their accusations against the
Lawrence Police Department.

We appreciate your efforts in investigating what we believe to be police misconduct. If

there is anything that I can do to assist you with your investigation, please don't
hesitate to contact me at the numbers or addresses listed above

JIJ1.L
Sarah G. Swain
Attorney at Law

Ir
 I inquiry underway in conduct orponce I Lr wortd.com "Hj-'", •• T· ..J •• _ • • _
• • -.- • •

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FBI inquiry under way in conduct of police

Some allege that officers posed as federal agents

By Ron KnoK

Thursday, June 15, 2006

The Federal Bureau of Investigation is questioning whether Lawrence Police officers have
improperly posed as federal agents when interrogating suspects, the Journal-World has
learned.

The FBI inquiry stems from allegations that Lawrence Police claimed to be agents from the
FBI when questioning people during the police Investigation of an alleged fencing operation
atthe Yellow House secondhand shop, 1904 Mass .

.~ "We are attempting to resolve whether or not a person or persons falsely represented
themselves as FBI agents," FBI spokesman Jeff Lanza confirmed Wednesday.

Lanza would not comment further.

But sources with knowledge of the investigation told the Journal-World the FBI inqUiry was
prompted by complaints from Sarah Swain. attorney for the secondhand store, and others
close to the fencing probe.

The sources also said the FBI was never involved in the actual fencing investigation, but
was only involved because of allegations against the police.

The Lawrence Police Department would not comment for this article because it involved
another agency's investigation, spokeswoman Kim Murphree said Wednesday.

Agents from the FBI have already met with Swain and the police department, in part to
establish that the FBI was not actually involved in investigating the Yellow House.

The meeting between Lawrence Police Sgt. Mike Pattrick and

FBI Special Agent Bob Shaefer was at the request of Swain,
who had heard from Yellow House owners Guy and Carrie
Neighbors and others that FBI agents were using the Douglas
County Law Enforcement Center to interview people who sold
merchandise to the store.

i' That allegation culminated in a sworn affidavit from Lawrence

I "r II
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resident Laura Helm, who said two men identifying themselves

Photo by Thad Allender
as FBI agents had taken her from her brother's home to the
.~,. pollee station to interview her.
Carrie Neighbors waits
According to the affidavit, the men questioned Helm for 90
for customers inside her
minutes before driving her back to her brother's home.
secondhand store. The
Yellow House, 1904 "They questioned me about items I had sold to the Yellow
Mass. The Federal House in the past: she said in the affidavit. 'They told me they
Bureau of Investigation obtained my name through checks that were written by the
is looking into the Yellow House."
Lawrence Police
Department because of Helm said in the affidavit that the men had guns and badges
allegations that officers on their belts, and that at least one of the men knew the door
were posing as federal code needed to enter the Law EnforcementCenter.
agents in a fencing
probe involving Yellow Helm is on probation for attempted forgery and reported the
House. incident to Harley Eddis, her probation officer, the affidavit
said.

During the meeting of Swain, Pattrick and Shaefer, Swain said both men told her the FBI
had no involvement in the Yellow House investigation.

·Shaefer told me that the FBI would not be involved," Swain said. "There is no interagency
task force or anything like that."

When Swain contacted the police department to confirm the FBI's involvement in the
investigation of her clients, Lawrence Police Chief Ron Olin would only conlirm that the
appropriate federal agents had been contacted, according to a letter from Olin to Swain, a
copy of which was obtained by the Journal-World.

"(LPD) Officer (Jay) Bialek assures me that he has contacted the agents involved and has
informed them of your wish to be contacted," he wrote Swain.

Bialek is involved in the investigation of the Yellow House.

Olin said in the letter that he would not name any federal investigaton; involved, but did
mention the meeting between Swain, Pattrick and Shaefer. and said that all further
questions should be addressed to U.S. Atty. Marietta Par1<er, who is handling prosecution on
the federal leveI.
Jim Cross, spokesman for the U.S. Attorney's Office, would not comment on whether his
office was involved in the fencing investigation.
Police acknOWledged assistancefrom the Internal Revenue Service and the U.S. Postal
Service in a news release from DecemberWhen police served an initial search warrant
against Yellow House.
The release called the alleged fencing operation, which entails the ~urchase and resa~ of
stolen goods. "one of the largest, most sophisticated fencing operations we have seen In
Lawrence,"

6/1 S!2OO6 10:08AM

 FBI inquiry stalled by lack of formal complaint

By B&n.. K!l~
June 21, 2006
Advertisement

A federal probe into possible misconduct within the Lawrence Police Department has stalled as the FBI
waits for a fonnal complaint to be filed.
FBI spokesman Jeff Lanza said no one had come forward with a formal complaint alleging anyone
posed as FBI agents when questioning people in relation to a police investigation of an alleged fencing
ring at the Yellow House secondhand shop, 1904 Mass.
"We cannot move forward without a formal complaint," Lanza said.
Lanza previously said the FBI was looking into the matter.
Sarah Swain, attorney for Yellow House, said she and a private investigator were working to set up a
meeting between the FBI and people who allegedly have been interrogated by police officers claiming
to be federal agents.
.r-- "'.
Swain also said a private investigator sent the FBI at least one sworn affidavit that should serve as a
formal complaint.
The Lawrence Police fencing investigation, which began last year, has focused on the alleged purchase
and resale of stolen goods through the secondhand store and online sales, according to a police news
release from December 2005.
Police have served search warrants at the Yellow House and at the home of Guy and Carrie Neighbors,
the store owners, in relation to the case.
No charges have been filed as a result of the monthslong fencing investigation.
The police department has declined comment about the FBI inquiry, saying it was against department
policy to discuss another agency's probe.

More about the inquiry

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 FBI clears Lawrence Police of impersonation allegation

YelJow House Store, owners' residence served with two more search warrants in
ongoing fencing investigation

July 8,2006
Advertisement

The FBI oil) s if;; cleared Lawrence Police of an allegation ilial an officer impersonated WI FBI agt:lIl
during the investigation of an alleged fencing operation at the Yellow House used appliance store.
"We looked into the situation and found no evidence to indicate that anyone impersonated an FBI
agent," FBI spokesman Jeff Lanza said Friday.
The news came the same day the U.S. Postal Inspector's office, assisted by Lawrence Police and the
r>, Internal Revenue Service, served two more search warrants at the store at 1904 Mass., and at the home
of owners Guy and Carrie Neighbors in the 1100 block of Andover Street.
Authorities said they were looking for e-mail records, surveillance tapes, receipts, computers, sealed
merchandise and sales records from the online auction service eBay.
I---··-,·----·~

,~ s:

Photo by lU'id ,;item!.u

Guy and Carrie Neighbors say that they don't buy or sell stolen property at the Yellow House Store,
1904 Mass. The U.S. Postallnspector's office served two search warrants on Friday and searched the
Neighbors' home and business in an ongoing fencing investigation.
It's the latest twist in an investigation that's been going on since December, when Lawrence Police said
they'd uncovered what they describe as a large-scale, sophisticated fencing operation. So far, there
have been at least five search warrants served, but no one has been arrested and no charges have been
filed.
"I think this whole thing is around our eBay sales," Guy Neighbors said on Friday as he stood outside
his store, which was surrounded by yellow police tape. "It's been, what, eight months now? I don't
know. Maybe they have more than I know."
The Neighborses maintain their innocence and have been critical of police at every turn.
 THE SWAIN LAW OFFICE
Sarah G. Swain, Attorney at Law
Theno Office Complex Park Cherry Building
601 Missouri, Suite 3 110 N. Cherry, Suite 240
Lawrence, KS 66044 Olathe, KS 66051
(785) 842-2787 866-550-2787

June 30. 2006

Bob Schaefer, Special Agent

Federal Bureau of Investigations
1300 Summit
Kansas City. MO 64106

Dear Agent Schaefer:

On June 14, 2006, I forwarded you a copy of a sworn affidavit that alleged illegal
police conduct on the part of the Lawrence Police Department. Since that date, I
have tried contacting you on at least six occasions to set up a meeting with you,
Ms. Helm, and myself. At this point, , have been unable to speak with you on the
phone, and' have not received replies to the numerous voice messages that I
..,r--. have left for you.

I contacted you twice regarding setting up a meeting with Ms. Helm. I told you
that I would be available to meet with you and Ms Heim regarding your
investigation on Thursday June 29, 2006. Obviousiy, that meeting didn't take
place.

At this point, I am unsure about your intentions regarding this investigation.

While you seemed concerned about these issues during our first meeting that
involved Sgt. Patrick from the LPD, I am certainly not convinced from your
actions or lack of investigation during the last two weeks that this is something
that you Intend to pursue in any sort of meaningful manner.

I am currently pursuing possible other avenues for an investigation of the LPD,

and I would appreciate some clarification from the FBI about the manner and/or
extent of any investigation that your agency intends to pursue. Certainly, I will
keep YOIJ apprised of any further developments on my end, and I Will be awaiting
a call from you regarding a meeting with lV.s. Helm.

n~.L
Sarah G Swain
AttOiT,E;Y at Law
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j

PROSECUTORAL MISCONDUCT

TO THE HONORABLE JUDGE LUNGSTRUM:

The prosecutor (Tera D. Morehead) is not giving me a fair

chance to defend myself.
I have been saying since April 20, 2006, I want a copy of my
discovery. I ne~d to see the evidence that the Government thinks
it has against me so I can adequally prepare myself for trial.
Instead of following the laws of the United States this over-
zealous prosecutor has taken the law into her own hands. She has
been trying to take away every tool I have at my disposal to help
me vindicate myself. This prosecutor has attacked and harassed
everyone (including my paid attorneys) who have been trying to
help me just so she can wrongfully convict me.

In my opinion the prosecutor has broken the laws and not

given me a fair chance to defend myself as follows:

1.) December 18, 2006, the prosecutor lied to the court and
jUdge. .
A. The judge asked the prosecutor if there was any Governmental
restrictions concerning my discovery and the prosecutor
replied, uNo".
B. Leigh Bledsoe, Tim Schemica, Baltizar Salazar, Robin Fowler,
and Bruce Kips have shown me a letter from the prosecutor
and signed by Tera D. Morehead stating that in accepting the
discovery from her they are agreeing not to: 1. I show me the
discovery, 2.) discuss with me the discovery, and 3.) they
are not to make any copies of the discovery.

2.) The prosecutor has taken things out of my discovery.

A. Certain things that I have asked my current attorney to see
that I have seen from other attorneys are no longer in the
discovery. ie. Arrest warrents, application to search
warrants, and parts of search warrants somehow have
disappeared.
3.) On April 28, 2006, (my detention hearing) the lead detective
Greg Lawson, was caught lying on the witness stand under
oath, to the court.
A. Instead of charging Greg Lawson with perjury, the prosecutor
threatened and harassed my then attorney Tim Schemica.
B. The prosecutor knows that law enforcement has falseified
police documents and she has looked the other way. 1.)
April 20, 2006, police said I had used my vehicle and hit
them, 2.) police officers said I said things that I never
said, and 3.) gun reports no longer have Michael Orr's
name on them ..

4.) The prosecutor and police officers have used coercion on

Leigh Bledsoe.
A. They told Leigh there was a chopped up dead body with bullet
holes in it in my storage shed.
B. Police officers made Leigh get in their police car and drove
 her ana fifty to sixty minute drive drilling her about
charging her with murder if she did not let them search her
house.
C. They told Leigh that if she did not say what they wanted her
to say they would throw her into jail for murder, perjury
and money laundering.

5.) The prosecutor and police officers have harassed Leigh at

work.
A. The prosecutor and police called and harassed Leigh at work
although they had her cell phone and her house number.
B. May 9, 2006, Leigh called detective Lawson's supervisor
about Lawson harassing her and that he was not to call her
anymore. approximately three hours later Lawson called
Leigh's cell phone again.
C. The prosecutor sent Government agents to talk to Leigh and
her boss at work.
D. The prosecutor and Government agents called Leigh's boss and
his boss in an attempt to put pressure on Leigh by making
her life miserable at work so Leigh would cave into a
vicious and over- zealous prosecutor who abuses the powers of
the Federal Gpvernment. The prosecutor intentionally tried
to ruin Leigh's life. After five months of the prosecutor
and federal agents harassing Leigh, her boss and her bosses
boss at work she was fired. Leigh had been employed at
siemens for over five years before Tera D. Morehead
interfered.

6. ) The prosecutors strong influence over my attorneys.

A. Tim Schemica
1. Made Tim sign a contract with the prosecutor in order to get
the discovery. 1.) Tim was not to show me the discovery,
2.)discuss with me, and 3.) he was not to give me any part
or make copies of the discovery and give them to me.
B. Baltazar Salazar
1. The prosecutor told Baltazar to fly from Houston to Kansas
City and she would then give him the discovery. When he got
to Kansas City she refused to give him the discovery. The
prosecutor then called Baltazar a drug dealer and accused
him of being in a drug syndica because he is from Houston.
Morehead told Baltizer I will never see the discovery and
supoenied Baltizar twice that I know of.
2. The prosecutor accused this attorney of being a hired bully
from someone down south.
3. The prosecutor took Baltizar's retainer fee and his local
council Melanie Morgans retainer fee. I was then told that
if my family or anyone associated with me hired another
attorney the prosecutor will take their payment as well.

2.
C. Melanie S. Morgan
1. Told me the government does not give out the discovery any-
mOre and that I will never see it or get a copy of it.
2. The prosecutor supoenied Melanies bank records.
3. On August 23, 2006, Melanie came to CCA and asked me some
questions about Tim and his form of payment.
4. On August 25, 2006 the prosecutor called Leigh at work and
asked her the exact same questions.
D. Robin D. Fqwler
1. Told me that certain things that I tell him he was going to
report to the prosecutor.
2. Told me the Government does not give out the discovery.
3. I told him certain motions to file and he said he could not
file them.
4. I told him to fight an ex parta and an in camera deal the
prosecutor was trying to do against me. Fowler told me not
to worry about this because it will never happen. My next
attorney told me in the discovery was an in camera that had
been done on me with Fowler and the prosecutor.
E. R. Bruce Kips
1. Told me the prosecutor said I am not allowed to have any
part of the d~scovery and showed me the letter containing
the contract about giving the dicovery to him.
2. I told Kips the same motions I told Fowler to file and fully
expect him to file them along with giving me a copy of the
transcripts from all of my court dates.

7. ) Prosecutor has violated my Bill of Rights.

A. Amendment V. - Deprived me of my life, liberty and property.
1. Life - The prosecutor so far has robbed me of nine months of
my life.
2. Property - The Government is holding personal property of
mine that I want back. ie. DeYry student Id cards, credit
cards, expired drivers license cards and electronic
equipment.
B. Amendment VI. Right to a speedy trial and effective
assistance of council.
1. 210 days after I was incarcerated I was given my indictment
after I told the judge I didn't have it.
2. 278 days after I was incarcerated I still have not been
able to adequately view the evidence against me.
3. The prosecutor has taken three paid attorneys from me and
forced me to use two court-appointed attorneys that she has
a strong influence over.

3.
 .B.!!.l- O()./o7 JJOt·"/ ~ -J" P l,
~~'1
hI . fo.ot-~ 5~J..bi>' ....
her-on-a fifty to sixty minute drive drilling her about
charging her with murder if she did not let them search her
house.
C. They told Leigh that if she did not say what they wanted her
to say they would throw her into jail for murder, perjury
and money laundering.

5.) The prosecutor and police officers have harassed Leigh at

work.
A. The prosecutor and police called and harassed Leigh at work
although they had her cell phone and her house number.
B. May 9, 2006, Leigh ·called detective Lawson's supervisor
about Lawson harassing her and that he was not to call her
anymore. approximately three hours later Lawson called
Leigh's cell phone again.
C. The prosecutor sent Government agents to talk to Leigh and
her boss at work.
D. The prosecutor and Government agents called Leigh's boss and
his boss in an attempt to put pressure on. Leigh by making
her life miserable at work so Leigh would cave into a
vicious and over-zealous prosecutor who abuses the powers of
the Federal Gpvernment. The prosecutor intentionally tried
to ruin Leigh~s life. After five months of the prosecutor
and federal agents harassing Leigh, her boss and her bosses
boss at work she was fired. Leigh had been employed at
Siemens for over five years before Tera D. Morehead
interfered.
6.) The prosecutors strong influence over my attorneys.
A. Tim Schemica
1. Made Tim sign a contract with the prosecutor in order to get
the discovery. 1.) Tim was not to show me the discovery,
2.)discuss with me, and 3.) he was not to give me any part
or make copies of the discovery and give them to me.
B. Baltazar Salazar
1. The prosecutor told Baltazar to fly from Houston to Kansas
City and she would then give him the discovery. When he got
to Kansas City she refused to give him the discovery. The
prosecutor then called Baltazar a drug dealer and accused
him of being in a drug syndica because he is from Houston.
Morehead told Baltizer I will never see the discovery and
supoenied Baltizar twice that I know of.
2. The prosecutor accused this attorney of being a hired bully
from someone down south.
3. The prosecutor took Baltizar's retainer fee and his local
council Melanie Morgans retainer fee. I was then told that
if my family or anyone associated with me hired another
attorney the prosecutor will take their payment as well.

2.

•
 I am not aware of any situation in the world in which there
is a system of Jurisprudence that is recognized by civilized
people, where an individual can be tried without and convicted
without seeing or knowing the evidence against him.

Some of the motions that I have told my attorneys to file

and expect them to file are:
•
1.) Motion for Discovery
A. citing Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10
L.Ed.2d 215 (1963),
2.) Motion for Exculpatory and Impeaching Evidence
B. citing Giglio v. united Stated, 405 u.s. 150, 92 S.Ct. 763,
31 L.Ed.2d 104, and
3.) Motion for Early Disclosure of Jencks Act Material
C. citing the Jencks Act: 18 U.S.C 3500, 18 U.S.C. 3500 (e) (1),
18 U.S.C. 3500 (e) (2), 18 U.S.C. 3500 (e) (3).

Sir, I am an American citizen. Born and raised in America and

having thus done so the constitution of the united Stated
Government guarant~es me certain unalienable rights that this
prosecutor cannot ,take away from me.

Judge Lungstrum, could you please protect and make sure this
prosecutor does not make any more evidence in my favor disappear.

Thank you for your time and consideration.

James McKeighan