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07912297136

07912297136

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Published by Jones, Walker

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Published by: Jones, Walker on Jul 08, 2010
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10/25/2012

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Carrie Neighbors
1104 Andover Lawrence, Kansas 66049(785) 842-2785
IN THE UNITED STATES COURTFOR THE DISTRICT OF KANSASUNTIED STATES OF AMERICA
v .
Case No:
07-20073-CM07-20l24-CM08-20l05-CMCARRIE NEIGHBORS,GUY M. NEIGHBORSDEFENDANT UPS REPLY TO PLAINTIFF'S RESPONSE TO THEDEFENDANT ill'S MOTION TO QUASH OR STRIKE DEFENDANT UPS PROFFER COMES NOW
on this day of July 2010, the Defendant [1], acting as a pro selitigant, is filing a Reply to the Plaintiff's Response to the Defendant [1]'s Motion to Quash or Strike Defendant [1]'s Proffer. The Reply is as follows:1). The Defendant [1] can clearly show before the court, that the proffer was altered, or changed. Whereby, the Defendant re-iterates and incorporates the contents of [Doc 130] into thisReply.2). Because the Proffer was not attended by the U.S. Attorney or properly recordedimpartially for the courts review, the Proffer itself is nothing more than non-credible hearsayReply to Plaintiffs Response to Quash or Strike Defendants ProffePage
1
 
written by officers with an agenda to convict. 259 2. ~ 3, "...These same agents have already demonstrated to this court an absolute lack of credibility. The Defendant [l] can also clearly show that the Plaintiff (government) hadoriginally breached the proffer contract, whereby the contract is null and void. When the (2)Lawrence Kansas Police officers (who were involved in the proffer) came into the Defendant's business, Yellow House Quality Appliance's Inc. (after the stipulation was made) and attemptedto question her in reference to some witnesses relevant to the proffer, outside the presence of theDefendant's counsel, in which violated the stipulated agreement with the proffer that theDefendant [1] could not discuss any information in reference to the proffer without the presenceof her counsel, Whereby, this breached the agreement. [see ref [Doc 133] in which Defendant [1]now requests to; re-iterates and incorporates the contents of [Doc 133] into this Reply. Due to thetestimony of the Officers in [Doc 133]. Reaffirmed by this recent Supreme Court decision byBreyer v.(99-244) 177 1331, 26,3). Once again the Plaintiff is intentionally misleading the court in ~ 2 of [Doc 259], whenin actuality the Defendant had cited case law in [Doc 130].4). Also note for the record that the gatekeeper had a fiduciary duty to make sure that the proffered expert evidence rested on a credible reliable foundation and was relevant, in which isnot so, in which the Defendant [1] can clearly show in this cause of action, whereby due to theReply to Plaintiffs Response to Quash or Strike Defendants [1] Proffer Page 2
 
tainted and mishandled evidence, failure to follow proper procedure, and chain of custody,testified by two Lawrence police officers, (as in [Doc 133])
215
v .
1126,1129
any proffer by the Defendant [1] null and void.[See ref v.
582 1192215
THEREFORE the Defendant [1], acting as a pro se litigant, is filing a Reply to thePlaintiffs Response to the Defendant [I]'s Motion to Quash or Strike Defendant [I]'s Proffer inits entirety from this cause of action, due to the Officers testimony in [Doc 133], and PRAYSthe court Quash or Strike the Proffer, for the Plaintiffs breach of contract, as testified by theofficers in reference to the breach, and clearly altered statements of Defendant [1] as in [Doc133], whereby the Defendant [1] has clearly shown and met her 51
%
burden of proof that theAltered testimony, failure to document the proffer properly, and breach of contract by thePlaintiff, should result heavy in favor of the Defendant [1].
Carrie Neighbo s
1104 Andover Lawrence, Kansas 66049(785) 842-2785Reply to Plaintiffs Response to Quash or Strike Defendants [1] Proffer Page 3

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