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. CASE NUMBER: 07-20124
CARRIE NEIGHBORS

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
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