Case 2:08-cr-20105-CM-JPO Document 100 Filed 06/22/10 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF KANSAS
(Kansas City Docket)

UNITED STATES OF AMERICA )

)
Plaintiff, )
) 07-20073-02-CM
v. ) Case No. 07-20124-01-CM
) 08-20105-02-CM
CARRIE MARIE NEIGHBORS, )
)
Defendant. )

MOTION FOR ADDITIONAL TIME TO FILE RESPONSE

The United States of America, by and through Lanny D. Welch, United States

Attorney for the District of Kansas, Marietta Parker, First Assistant United States Attorney,

and Terra D. Morehead, Assistant United States Attorney, and respectfully requests that

this Court issue an order allowing additional time for the Government to file its response

to the defendant's Motion for Reconsideration of Oral Order Given on 5/24/2010, as well

as Exceptions and Objections filed June 1, 2010, (Case No. 07-20073-02, Doc. #140; Case

No. 07-20124-01, Doc. # 239; Case No. 08-20105-02, Doc. #97); and, Defendant's

Amended Motion to Dismiss Case Nos. 07-20073-CM, 07-20124-CM, and 08-20105-CM

with Prejudice, filed on June 14, 2010, (Case No. 07-20073-02, Doc. #141; Case No. 07-

20124-01, Doc. # 240; Case No. 08-20105-02, Doc. #98), and for said time to be excluded

for purposes of speedy trial calculations. In support of said motion, the Government states:

1. The Government's responses to defendant's motions are currently due on

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June 28, 2010.

2. That counsel for the Government has requested transcripts of the hearings

held on March 25, 2008 (Doc. # 58), November 4, 2008 (Doc. # 155) and February 18,

2009, (Doc. # 158). Government counsel was informed by the Court reporter that due to

other pending matters, including regular court appearances, the transcripts may not be

prepared until sometime on or after July 1, 2010.

3. Counsel for the Government will be unable to adequately respond to the

defendant's motions until said transcripts have been received and reviewed.

4. That counsel for the Government would request that the response time for

these motions be scheduled for one week after the transcripts have been received.

5. That the additional time requested will not prejudice the parties herein.

Further, such additional time outweighs the best interests of the public and the

defendant in a speedy trial, as set out in 18 U.S.C. § 3161(h)(7) and that this time is

otherwise being excluded pursuant to 18 U.S.C. § 3161(h)(1)(D).

WHEREFORE, the United States respectfully requests that this Court issue an

order allowing the Government a period of one week after said transcripts have been

received, to file its response to defendant's motions.

Respectfully submitted,

LANNY D. WELCH
Acting United States Attorney

s/ Terra D. Morehead
Terra D. Morehead, #12759
Assistant U.S. Attorney
500 State Avenue, Suite 360
Kansas City, Kansas 66101
(913) 551-6730
Terra.Morehead@usdoj.gov

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 Case 2:08-cr-20105-CM-JPO Document 100 Filed 06/22/10 Page 3 of 3

s/ Marietta Parker
Marietta Parker, #77807
Assistant U.S. Attorney
500 State Avenue, Suite 360
Kansas City, Kansas 66101
(913) 551-6730
Marietta.Parker@usdoj.gov

ELECTRONICALLY FILED
Attorneys for Plaintiff

Certificate of Service

I hereby certify that on the 22nd day June, 2010, the foregoing was electronically

filed with the clerk of the court by using the CM/ECF system which will send a notice of

electronic filing to the following:

John Duma
303 E. Poplar
Olathe, KS 66061
Stand-by Attorney for Defendant Carrie Marie Neighbors

Cheryl A. Pilate
Morgan Pilate LLC
142 N. Cherry
Olathe, KS 66061
Attorney for Defendant Guy Madison Neighbors

I further certify that on this date the foregoing document and the notice of electronic

filing were mailed by first-class mail to the following non-CM/ECF participants:

Carrie Marie Neighbors

104 Andover
Lawrence, Kansas
Defendant, pro se

s/ Terra D. Morehead
TERRA D. MOREHEAD
Assistant United States Attorney