FILEO

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OOUGLAS COUNTY
DISTRICT COURT

AFFIDAVIT FOR SEARCH WARRANT 20 P 2: 28

STATE OF KANSAS, DOUGLAS COUNTY, ss: By Hln__
COMES NOW Officer Micky Rantz, AFFIANT, with the Lawrence Polce
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
is contraband or which is property which constitutes or may be considered part of the
evidence, fruits or instrumentalities of a crime, particularly the following described items;
to wit:

1. Marijuana, marijuana plants, and marijuana seeds.

2. Plastic baggies, scales, and other drug paraphernalia used in the

cultivation, 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 to, items that appear new,
items 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.

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:

Affiant has been a Kansas law enforcement officer for over seven years. During
that time period Affiant has worked as Drug Interdiction Officer for the City of Ft.
Scott, Kansas, a Narcotics Detective and Undercover Officer for the Cherokee
County Kansas Sheriffs Department, and for the last four years Affiant has worked:
as a Police Officer for the City of Lawrence. During the four year time period Affiant

:EXihibit 2
has worked for the Lawrence Police Department, nineteen months of that time was I
I..
spent with the Affiant being assigned to the Lawrence/Douglas County Drug .'
Enforcement Unit as an investigator. Affiant has received extensive training in :
detecting and identifying the presence of illegal narcotics. Affiant has participated inl

I
numerous 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 30th, 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 I
the business located 1904 Massachusetts, Yellow House Quality Appliance, fencingl.";
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. I
On December 2, 2005, at approximately 1035 hours, Officers of the Lawrence
Police Departments, IRS Agents, Postal Inspector Agents, and AFFIANT arrived at
I
the residence to serve the search warrant. Guy Neighbors, who had been contacte .
by his wife Carrie Neighbors in reference to the search warrant at the business,
arrived 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 escorte -
Mr. Neighbors to the back porch area, where he retrieved a key from a plastic
trashcan containing charcoal. Before officers entered the residence Mr. Neighbors --
advised that he keeps his office door locked 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 cleared the residence announcing, "Police Department,

Search Warrant". As AFFIANT was clearing the office area, that Mr. Neighbors had
advised AFFIANT about, AFFIANT located a hidden door located behind a
bookshelf. AFFIANT entered the concealed room and located what AFFIANT
believes to be a concealed marijuana grow operation. Inside the room AFFIANT
located several green plants approximately 6 feet tall, which based on AFFIANT'S
training knowledge and experience AFFIANT believes to be marijuana. Also locate
inside the concealed room was grow lights, fertilizer, several bags containing green
vegetation, and a tray containing green vegetation. AFFIANT field-tested a small
portion of the green vegetation, which showed a positive indication as marijuana
(See digital photos below for additional descriptors of the marijuana grow operation
 !
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:Marijuana: Plants I Grow Operation
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Tray of green vegetation (Field-tested pos. for Marijuana)

Also located inside the residence were dozens of boxes containing what
AFFIANT describes as new merchandise. The merchandise includes dozens of
boxes of new Nike tennis shoes in various sizes, Spot Bilt shoes in various sizes,
and children's jeans with the tags still attached etc ... The shoes were contained in
original shipping boxes that had labels still attached to them. The labels indicated
.that the items were originally supposed to be delivered to a business in Topeka,
! Kansas. The items located inside the residence are consistent with Carrie
:Neighbors telling AFFIANT dUring an undercover operation that she has
!acquaintance that is a truck driver, who sells her property that he/she takes of
 I
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'''~<;8 1'011«~~~_t ]t1~all

iCases of New Merchandise

Stacks
, .
_
•.•.. •..
of New Jeans with, Tags
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 AFFIANTS training, knowledge, and experience, AFFIANT believes that

based 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 are
stolen from an unidentified victim. Furthermore, to complete a more thorough
Investigation that a second search warrant be issued for the residence for the above
listed items. .

.'
 FILED
DOUGLAS COUNTY
DIS TRieT COURT

_SEARCH WARRANT _

STATE OF KANSAS, DOUGLAS COUNTY, ss:

BY_~_

TO ALL LAW ENFORCEMENT OFFICERS OF THE STATE OF KANSAS:

Having evidence under oath before me from which I find there is probable cause
to believe that a crime has been or is being committed and that certain items; to-wit:
1. Marijuana, marijuana plants, and marijuana seeds.

2. Plastic baggies, scales, and other drug paraphernalia used in the

cultivation, 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 to, items that appear new,
items 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, instrumentalities, or evidence of such crime, or
were 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 located on the east side of the street.

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 return of this warrant, whether executed or not.

Issued this 2 day of Oec.l1A1btA , 200S-, at l:iOo'clock f2.-.m.

 INVENTORY OF PROPERTY SEIZED
AND RECEIPT FOR SAME

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:

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I acknowledge that I received a copy of this warrant and receipt for the above described'
property seized. ~ ~/
Signature of person upon whom warrant
was served.

PERSONS PRESENT DURING SEARCH:

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RETURN

J received this warrant on the;< O~

day of bae. , 20 C? ~ at
approximately /: >0 o'clock -f2-;.,.m., and executed the same on the;< day of
O~6rcg , 20 0 S by seizing the property described on the
inventory and receipt attached hereto or shown on the reverse side hereof, and by
serving a true copy of this warrant and its attached inventory and receipt upon
/l/ /A , or, there being no person available upon whom to
'serve same, by leaving same at LcsFI A.J RB>iI~ .