USA v. Carrie Neighbors

Case No. 07-20124-01-CM-JPO

Response by Defendant to Governments motion for mental examintation

UNITED STATES’ THIRD
MOTION FOR MENTAL EXAMINATION PURSUANT TO
TITLE 18, UNITED STATES CODE, SECTION 4241
AND FOR A HEARING


To the Honorable Judge Carlos Murguia,

I come before this honorable court today on behalf of myself, in opposition of the Governments motion to have me placed in a mental health facility. Because I believe in Justice, this courts fairness, in myself and my Constitutional right as a defendant in this case to maintain my innocence against the Governments allegations against me.

I would like to assure this court that I am of sound mind, quite capable of understanding the charges against me, and assisting in my own defense.

My attorney John Duma has informed me, that because of my refusal to plead guilty he will not defend me against this motion, therefore I am forced to come before the court in my own defense.

This case has entailed the Governments pursuit against me since 2005, and this has been extremely stressful, however I believe that confinement to a mental facility will only add to the already tremendous amount of stress and pressure the Government has already forced upon me by creating yet another huge disruption in my life, finances, and mental health program I am already on.

I would like to reiterate to the court that I was extensively evaluated by a licensed professional therapist Marilyn Hutchinson, and she has found me to be competent to stand trial.

I have been under the constant supervision on a monthly basis of this courts US Probation officer Melissa Goldsmith since 2007. I have maintained my updated reports to Melissa on a monthly basis, and have complied with meeting with her in person once a month.

I have submitted to monthly random drug testing as ordered by this court since 2007. I have never failed a single test while under the court order, nor have I missed any appointments.

I have complied with all the court orders and restrictions that this court has placed upon my life and business over the past two years.

I have maintained steady housing and continued to run my business full time during the time I have been out on bond.

I have never lost focus of the fact I have very serious charges against me and I understand fully the possible consequences of my choices when I choose to continue to fight for justice, rather than except a plea of guilty.

I am currently voluntarily maintaining my mental health through regularly scheduled appointments at The Bert Nash Mental Health Center in Lawrence Kansas. I am under the care of a licensed mental health professional Dr. Harold Hogan.

I am including with this response to the court, a signed letter from my current mental health physician Dr. Harold Hogan.

I would like to reiterate for the courts, that in order to be put on the current mental health program I am on, I was first put through the extensive Bert Nash intake process. This intake process required several months of mental health evaluations, tests, interviews and appointments.

For the reasons as stated above, and under solemn oath I am requesting that the Governments motion to have me committed to a mental health facility be denied.