Guy Neighbors anisiia Bs] cdoornbos Hello, Mr. Six My name is Guy Neighbors, co-owner of the yellowhouse store (business) here in Lawrence. Our case began in Dee. of 2005 and I have had 5 indictments, and 2 supereed, all of which have been dismissed, and the Federal Judge in his order stated that My "speedy trial” and my "Due Process" were violated. Mr. Six, ‘My question to you is did you sign these warrants that are attached to this, fyou did not please email me back and say as such and I'will fill out an affidavit my self and file your response with my affidavit and addendum supporting an evidence hearing. Your response will allow me to avoid a request of you to attend the evidence hearing. Also attached are a few other documents that may be of interest. Thank you for you consideration in this matter. _ one Preview attachment 1 Scanned Pages.pdf 4 Scanned Pages.pdt Preview attachment 2 Scanned Pages.pdfPreview attachment 3 Scanned Pages.pdf Preview attachment 4 Scanned Pages.pdf & 4 Scanned Pagos.paf Preview attachment MOTION FOR EVIDENTIARY HEARING PURSUANT TO FEDERAL RULE CRIM.docx W MOTION FOR EVIDENTIARY HEARING PURSUANT TO FEDERAL RULE CRIM.docx Preview attachment ADDENDUM TO MOTION FOR EVIDENTIARY HEARING AND FRAUD UPON THE COURT.docx W ADDENOUM TO MOTION FOR EVIDENTIARY HEARING AND FRAUD UPON THE COURT.docx Six, Steve me ‘Mr. Neighbors, that is my signature on the four documents you attached. Steve Steve Six Stueve Siegel Hanson LLP 460 Nichols Road, Suite 200 Kansas City, MO 64112 816-714-7190 tel 816-714-7101 fax Visit us on the web at www.stuevesiegel.com_ “The information contained in this message from Stueve Siegel Hanson LLP, any attachments thereto, and any information contained in messages replying to this message is privileged and confidential. This message is intended only for the use of the named recipient(s) and the attorney-client and attorney work- product privileges are not waived by virtue ofthis having been sent by e-mail. if you receive this message inerror, you are strictly prohibited from, and it may be illegal to, copy, distribute or use the information. if ‘you have received the foregoing email in error, please contact the sender immediately by return email and delete the original message. 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If you change your mind and want future communications sent in a different fashion, please let us know AT ONCE From: Guy Neighbors [mailto:quysmileys52@amail.com] Sent: Friday, August 15, 2014 7:53 AM To: Six, Steve; Guy Neighbors; J wray; cdoornbos@ljworld.com ‘Subject: Search warrants in the "yellowhouse Case”SEARCH WARRANT STATE OF KANSAS, DOUGLAS COUNTY, ss: TO ALL LAW ENFORCEMENT OFFICERS OF THE STATE OF KANSAS: use Having evidence underoath before me from which I find there is probable to believe that a crime has been or is being committed and that certain items; to-wi Any books, record sheets, receipts, checks/check ledgers, eBay documents, and other documentation recording the sale, delivery, and possession of items being sold or purchased by or through the business located at 1904 Massachusetts, including any: CPU's, floppy disks, hard disks, or any other means of storing electronic data. The data stored on any computer, or removable media, located at thie above listed business. Personal property tending to establish identities of person(s) if control or ‘employed at the business to be searched including, but not limited to, employment applications, tax information, and personnel files. Physical property to include: {Items from sale on 11/07/2005) Apple iPod (SN# YM543KJVSZ8), Apple iPod (SN# YM5431PSZB), Apple iPod (SN# 5U543VCETJT), Apple iPod (SN# 5US43WCVTJT), inmotion iPod Station (SN# 5100ALWW0074614), iLogic iPod Station (SN# IP 1060509030402), Sonicare toothbrush (SN# 516001SCB), (Items from sale on 11/48/2005) Fuji F'10 digital camera (SN# 53053592), Fuji F10 digital camera (SN# 53453848), Samsurig Digimax digital camera (SN# 55405117), KitchenAid 4-1/2 QT Mixer (SNi# WP0855889), Texas Instruments Graphing Calculator (SR# unknown package marked by AFFIANT), (Items from sale on 11/29/2005) Apple iPod Shuffle (SN# 4HS46XEXRS9), Apple IPod Shuile (SN# 4HS46X8TRSO), Apple iPod Special Edition U2 (SN# JQ449E7PS2X), Panasonic Cordless Phone Set (SN# 5JAXC175873), JBL ‘on tour” Portable Music Box (SN# ‘SZONT-0274411), Phillips Portable DVD player (SN# LI000538008661), and Polaroid 7” Under-the-Cabinet DVD player (K0502010570016877) which items are contraband or are fruits, instrumentalities, or evidence of such crime; or were used in the commission of such crime, are located in or upon ‘The premise and outbuilding located at 1904 Massachusetts Street, a business commonly known as Yellow House Quality Appliances or the Yellow House Store, Lawrence, Douglas County, Kansas 66044. YOU ARE THEREFORE COMMANDED forthwith, within ninety-six (86) hours of the issuance hereof, to search the person, place, thing or means of conveyance COPY Kelp OS, iaif hereinbefore specified for such items, holding them to be dealt with according to lew, and to make due return of this warrant, whether executed or not. - Geis) Issued this 2O day of Kauenber _, 2005", t BeEcK _Zm. JUDGE OF THE DISTRICFCOURT oe COPY Seldbel & 2Bo BOUNTY T COURT oust DISTAT AFFIDAVIT FOR SEARCH WARRANT’ 20 P 2: 28 STATE OF KANSAS, DOUGLAS COUNTY, ss: BY { J e COMES NOW Officer Micky Rantz, AFFIANT, with the Lawrence Police Department, and makes this Affidavit in support of the issuance of a Search Warrant to search the following described place; to-wit: ‘The residence located at 1104 Andover Street, Lawrence, Douglas County, Kansas 66049. The residence is described as a two story light brown with white trim wood frame structure located on the east side of the street. and there to seize anything which has been used in the commission of a crime or which a sontraband or which is property which constitutes or may be considered part of the eet fuits or instrumentalities of a crime, particularly the following described items; to wit: 4, Marijuana, marijuana plants, and marijuana seeds. 2. Plastic baggies, scales, and other drug paraphernalia used in the bultivation, processing, use, and possession of the above mentioned drug(s). 3. Any books, record sheets, ledgers, and other documentation recording the sale, delivery, and possession of the above mentioned drug(s). 4. Physical property to include, but not limited fo, items that appest Ce tens thet are in their original packaging, and items with their original sale tag(s) attached. 5. New and discarded packaging material used to ship and receive items. FURTHER, for the purpose of showing probable cause that 8 crime has been or is being committed and that the above described items exist and are located at the cbove described place, AFFIANT states the following facts which he has reasonable (grounds to believe and does believe to be true, to wit: Aifiant has been a Kansas law enforcement officer for over seven yor During that time period Affiant has worked as Drug Interciction offices for the City of Ft Satil Kensas, a Narcotics Detective and Underoover Officer for the Cherokee County Kansas Sherif’s Department, and for the last four years Affiant has worked coe lice Officer for the City of Lawrence. During the four year time period Affiant eAdsd"B* a2has worked for the Lawrence Police Department, nineteen months of that time was spent with the Affiant being assigned to the Lawrence/Dougias County Drug Enforcement Unit as an investigator. Affiant has received extensive training in detecting and identifying the presence of illegal narcotics. Affiant has participated in Fumerous investigations of violations of the Uniformed Controlled Substances Act ‘Over the years Affiant has requested and been granted numerous search warrants that were for violations of the Uniformed Controlled Substances Act. On the afternoon of November 30”, 2005, AFFIANT requested and was subsequently granted a search for the residence located at 1104 Andover, Lawrence, Douglas County, Kansas. The search warrant was for an attempted possession of stolen property investigation that AFFIANT was working on involving coe pusiness located 1904 Massachusetts, Yellow House Quality Appliance, fencing Stolen property, The residence located at 1104 Andover is owned and occupied by Carrie and Guy Neighbors, who are also the owners of Yellow House Quality Appliance. On December 2, 2005, at approximately 1035 hours, Officers of the Lawrence Police Departments, IRS Agents, Postal Inspector Agents, and AFFIANT arrived at the residence to serve the search warrant. Guy Neighbors, who had been contacted by his wife Carrie Neighbors in reference to the search warrant at the business, aaaved at the residence at approximately 1045 hours. AFFIANT explained to Mr. Neighbors that AFFIANT had a search warrant for the residence and then provided him with a copy of the search warrant. AFFIANT asked Mr. Neighbors for a key to the residence, so that officers would not have to force entry. Mr. Neighbors advised that he did not have a key, but kept one hidden on the back porch. Officers escorted Mr. Neighbors to the back porch area, where he retrieved a key from a plastic trashean containing charcoal. Before officers entered the residence Mr. Neighbors advised that he keeps his office door lacked on the second floor of the residence, however, the key for the office is located on a bookshelf next to the door. Officers entered and oleared the residence announcing, “Police Department, ‘Search Warrant’. As AFFIANT was clearing the office area, that Mr. Neighbors had Savised AFFIANT about, AFFIANT located a hidden door located behind a bookshelf, AFFIANT entered the concealed room and located what AFFIANT believes to be @ concealed marijuana grow operation. Inside the room AFFIANT ecated several green plants approximately 6 feet tall, which based on AFFIANT'S training knowledge and experience AFFIANT believes to be marijuana, Also located inside the concealed room was grow lights, fertilizer, several bags containing green vegetation, and a tray containing green vegetation. AFFIANT field-tested a smal portion of the green vegetation, which showed a positive indication as marijuana {See digital photos below for additional deseriptors of the marijuana grow operation). iy © anit §vous DIST - ___SEARCHWARRANT. — ......‘UHLOEC By. STATE OF KANSAS, DOUGLAS COUNTY, ss: f— — TO ALL LAW ENFORCEMENT OFFICERS OF THE STATE OF KANSAS: Having evidence under oath before me from which | find there is probable cause to believe that a crime has been or is being committed and that certain items; to-wit: 4. Marijuana, marijuana plants, and marijuana seeds. 2. Plastic baggies, scales, and other drug paraphernalia used in the Cuitivation” processing, use, and possession of the above mentioned drug(s).. 3, Any books, record sheets, ledgers, and other documentation recording te sale, dalivery, and possession of the above mentioned drus(s), 4. Physical property to include, but not limited to, items that appear new, torre that are in their original packaging, and items with their original sale tag(s) attached, 5, New and discarded packaging material used to ship and receive items. Which items are contraband or are fruits, insirumentalities, or ‘evidence of such crime, or Ware used in the commission of such crime, are located in or upon The residence located at 1104 Andover Street, Lawrence, Douglas County, Kansas 66049. The residence is described as a two story light brown with white trim wood frame structure lacated on the east side of the street YOU ARE THEREFORE COMMANDED forthwith, within ninety-six (86) hows of the issuance hereof, to search the person, place, thing or means of conveyance ne cinbefore specified for such items, holding them to be dealt with according to law, tnd to make due return of this warrant, whether executed or not Issued this_ day of Decenbern 200, at!#o'clock 2m. JUDGE OF THE DISTRICT COURT ‘GOVERNMENT EXHIBIT edhe atSTATE OF KANSAS, DOUGLAS COUNTY, saith HAY ~9 pol! TO ALL LAW ENFORCEMENT OFFICERS OF THENSTATE-OF KANSAS: Having evidence under oath before me from which | find there is probable cause to believe that a crime has been or is being committed and that certain items; to-wit; 4. Any books, record sheets, receipts, checks/check ledgers, eBay documents, surveillance video, and other documentation recording the sale, delivery, and possession of items being sold or purchased by or through the business located at 1904 Massachusetts Street, Lawrence, Dougias County, Kansas from and/or involving Dustin Had! (W/M, DOB: 10/11/4979). 2. Blue Companion air compressor with serial number 226.15350 and model number 921.153500. Which items are contraband or are fruits, instrumentalities, or evidence of such crime, of were used in the commission of such crime, are located in or upon 4, The premise and outbuilding located at 1904 Massachusetts Street, a business commonly known as Yellow House Quality Appliances or the Yellow House Store, Lawrence, Douglas County, Kansas 66044 YOU ARE THEREFORE COMMANDED forthwith, within ninety-six (96) hours of the issuance hereof, to search the person, place, thing or means of conveyance hereinbefore specified for such items, holding them to be dealt with according to law, and to make due retum of this warrant, whether executed or not Issued this g dayot MAY nae at___$", 40 o'clock Jf m. District JudgeState of KANSAS County of DOUGLAS, ss Comes now Officer Jay Rozelt,Affiant, with the Lawrence Police Department and Teikes this affidavit in support of the issuance of a search warrant to search the following described place; to wit; 4, ‘The premise and outbuilding located at 1904 Massachusetts Stent a business commonly known as Yellow House Quality Appliances or the Yellow House Store, Lawrence, Douglas County, Kansas 66044. and there to seize anything which has been used in the commission of a crime or ainich is contraband or which is property which constitutes or MY be considered part of the evidence, fruits or instrumentaiities of a crime, particularly the following described items; to-wit; 4. Any books, record sheets, receipts, checks/check ledgers, eBay documents, surveillance video, and other documentation focording the sale, delivery, and possession of items being sold or purchased by or through the business located at 1904 Massachusetts Street, Lawrence, Douglas County, Kansas from andior involving Dustin Had! (W/M, DOB: 40/11/1979). 2, Blue Companion air compressor with serial number 226.15360 and model number 921.153500. FURTHER, for the purpose of showing probable cause that a crime has been or is being committed and that the above described items, exist and are located at the above described place, Affiant states the following facts which he has reasonable grounds to believe and does believe to be true; to-wit; 4. Affiant has been a swom police officer with the Lawrence Kansas Police Department since July 14, 2003. Affiant has conducted several burgiary and theft investigations. Affiant Knows suspects in burglaries and thefts attempt to sell stolen items at local Pawn Shops and Used Goods stores. 2, On Sunday, March 26, 2006 at approximately 7:54 PM, Affiant was dispatched to 1908 E. 19” Street Lot E-185 In reference toa residential burglary. Lot owner, Raymond Edwards (W/M, OB: 6/25/1942), reported several items were stolen from his residence between 3/18/2006 and 3/26/2008. 3, Mr. Edwards reported the following items were stolen during the burglary: 44 MG Brazil Rifle, model #016042, Motorola cellphone LG2000, Garmin handheld GPS, Kodak 5 MP digital camera, and Panasonic 35 MM camera. 4, On Saturday, April 1, 2006 at approximately 5:17 PM, Affiant was contacted by Mr. Williams and advised several additional tems were stolen from the residence. Mr. Williams reported the following items missing: JVC compact camcorder, Blue Companion air compressor, Remington 12 gauge shotgun. 5. On Wednesday, April 12, 2006 at approximately 2:26 PM, Rant was contacted by Mr. Williams and advised he received ‘Mormation that implicated Dustin Hadl (WIM, DOB: 10/11/4979) inthe burglary. Mr. Williams advised Affiant he personally a rected Carrie Neighbors at Yellow House and asked if Dustin“ Hadi had sold any items at her store recently. Carrie Neighbors provided Mr. Williams with a sellers form with Dustin Hadl's<— exe on it and indicated Yellow House purchased a Companion tir compressor from him on 3/30/2006 for $40.00. 6. Mr.Williams presented Affiant with a copy of the “Sellers Form" obiained from Yellow House, 1904 Massachusetts Street, Lawrence, Douglas County, Kansas, which indicated Dustin Hadl sold 2 Companion air compressor to Yellow House for $40.00 on 3/30/2006. ‘The sellers form indicated Dustin Hadi was paid by check by Yellow House in the amount of $40.00. 7. The sellers form had Dustin HadI's name and date of birth on It The date of birth matched Dustin Had!'s date of birth 8. Me. Williams believed the model number on the compressor was 921,153500 and the serial number was 226.1830. Mr. Willams advised Affiant that Carrie Neighbors at Yellow House told him the blue Companion air compressor sold within a few days of being brought to the store. a. There was a Kansas driver's license listed, K1 10938519, which was very similar t Dustin Hadl's, KO1-93-8519. The only (4. mumbers switched were the "1" and "0". — “the castor! jes 2” Ale Galler Seren 40. The Affiant contacted Carrie Neighbors at Yellow House and asked her about the sellers form and Dustin Hadl. Ms. Neighbors confirmed the sellers form provided by Mr. Willams vbto the Affiant was from Yellow House and verified Dustin Had! had sold the compressor to her on 3/30/2006. Affiant later requested Ms. Neighbors provide documentation of the sale (possibly listing who purchased it) of the blue Companion air compressor in an effort by the Affiant to locate and recover the stolen air compressor. Ms. Neighbors was unwilling to cooperate any further. 41. Affiant contacted Officer Jay Bialek, Lawrence Police Officer, ‘who is conducting an on-going investigation of Yellow House regarding the fencing of stolen property through the Yellow House store and is familiar with the Yellow House store and how Carrie Neighbors conducts her business transactions. Officer J. Bialek advised Affiant through his investigation he leamed that Carrie Neighbors maintains business check stubs containing the Tames of whom she has bought merchandise fer a8 wel a receipe shoving sales hat that are conducted in (Gre. Officer J. Bialek also advised Affiant that Carrie jeighbors often resells merchandise online using eBay whereby __sshe maintains sales receipt ledgers to document online sales. 12. Furthermore, to complete a thorough investigation of the purchase and resale of the blue Companion air compressor, the Affiant requests thal a search warrant be issued for the premise and outbuilding located at 1904 Massachusetts Street, a business commonly known as Yellow House Quality Appliances or the Yellow House store, Lawrence, Douglas County, Kansas 66044. Further Affiant sayeth vf Affian| ‘ozell State of Kansas County of Douglas Signed and sworn to before me on May 8, 2006, by Jay Roget. a _— District JudgeINVENTORY OF PROPERTY. SEIZED ‘AND RECEIPT FOR SAME AND RECEIPT FOR SANE In accordance with the command of this warrant, the following items were seized and are now in my custody, subject to the order of the court: Le cept Haigo ow 3|22}rexe che Dustin Heb > Stree * 4° OFFICER IN CHARGE OF SEARCH OURie ax, Zoww qme: Locsvenes_Pib | acknowledge that | received @ copy of this warrant and receipt for the above described property seized. Signature of parson upol warrant was served. PERSONS PRESENT DURING SEARCH: oy )- Pool _ Cape Nes tuber? Res. pon Dirac). Bretioe— eh fe — t Sh Mewes: : wx? ue‘As officers were executing the search warrant at the residence, additional officers ‘were executing a search warrant at the Yellow House business. During the execution of the search warrant at the business, officers briefly interviewed Carrie Neighbors. During the interview Carrie Neighbors told officers that no stolen items were located at her residence, which is inconsistent with what officers located at the residence. Based AFFIANT’S training, knowledge, and experience, AFFIANT believes that pased on the totality of the circumstances so far, that Carrie and Guy Neighbors are knowingly involved in the receiving and distribution of stolen property (i.e. fencing stolen property). AFFIANT believes that based on the items located inside the residence probable cause exist that the new item located inside the residence ere Stolen from an unidentified victim. Furthermore, to complete @ more thorough investigation that a second search warrant be issued for the residence for the above listed items. Further AFFIANT saith not. Subscribed and sworn to before me this ra day of LDecenben So 20(D°S; by Officer Micky Rantz. — JUDGE OF THE DISTRICT COURT 1 pensay CARTY TAT THE rons INSTRUMENT IS A TRUE AND CORMECT. " ae 5 SPEAR AL SS pod peaRETURN | received this warrant on the _<2__day of Lee HOR. , 00S at approximately 7/20. o'clock 21, and executed the same on the —22— day of P-30'2S by seizing the property descfibed on the Tenia tha receipl allached hereto or shown on the reverse side hereot, and by eiing 2 tue Gopy of this warrant and its attached inventory and receipt upon or, there being no person available upon whom to serve same, by leaving same at Leg At SBM, OFFICER IN CHARGE OF SEARCH Like Kioste TILE: _ Ocoee | engey ceRniPe TAT THE FOREGOING cr COPY