Case 2:07-cr-20124-CM -JPO Document 393

Filed 09/27/10 Page 1 of 3

IN UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS UNITED STATES OF AMERICA V. CARRIE NEIGHBORS CASE NUMBER: 07-20124

CARRIE NEIGHBORS MOTION FOR A JUDGMENT OF ACQUITTAL OR IN THE ALTERNATIVE A MOTOIN FOR A NEW TRIAL COMES NOW, Carrie Neighbors pursuant to Federal Rule of Criminal Procedure 29 and does hereby move for a judgment of acquittal or in the alternative a motion for a new trial. In support of said motion the defendant would state as follows: 1. There was insufficient evidence submitted by the government to support the verdicts submitted herein by the jury and the court should dismiss all counts against the defendant. 2. The court should not have instructed the jury with the “deliberate ignorance” instruction in this matter. In doing so the court committed error that requires that this matter be retried. Wherefore, the defendant would request that the case against her be dismissed or in the alternative that the court grant a new trial in this matter. /s John M. Duma JOHN M. DUMA #10760 303 E. Poplar Olathe, Kansas 66061 (913) 782-7072 Fax 782-1383 John@Dumalaw.com ATTORNEY FOR CARRIE NEIGHBORS CERTIFICATE OF SERVICE I hereby certify that on September 27, 2010, I electronically filed the foregoing with the clerk of the court by using the CM/ECF system, which will send a notice of electronic filing to Marietta Parker and Terra Morehead, Assistant U.S. Attorney, 360 U.S. Courthouse, 500 State Avenue, Kansas City, Kansas 66101 and all other counsel of record. I further certify that I mailed the foregoing document and notice of electronic filing by first-class mail to the following non-CM/ECF participants: N/A _/s/ John M. Duma_____ JOHN M. DUMA #10760

Case 2:07-cr-20124-CM -JPO Document 393

Filed 09/27/10 Page 2 of 3

Case 2:07-cr-20124-CM -JPO Document 393

Filed 09/27/10 Page 3 of 3

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