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Tlre Univeniry of Kansas

PSYCHIATilCEVATUATIO{
Name: Birth Datc: Age: Examination:

GuyM.Neighbcirs January 1959 12, 51 years May 25, ZO11 'The UriitedStates GuyM. Neighbors vs.

Case Revercnce:

District Kansas of -J No.2:07-CR-20O7 No.2:07-20124{M PO;No.2:08-CR-20105{M-J 3{M; PO


Attorney Date of Report Background: GuyM. Neighbors charged with a numberofviolations is including obstruction justkr, of conspiracy manufacture to manufactured marijuana, intentionally marfuana,and beingan [possessing] unlawful in userof conttolled substances possesslon a fireann. Mr. Nelghbors' of bondwasrevoked in May,20@,and he is currentlyheldat the Ccjnections Corporation America facilityin Leavenurcrth, of Kansas^ hason repeated He occasions requested dismlssal hisdefense the of attorneys, beenassigned new Counsel, produced volumeof petitions and andfilingsin hisown hand. He persists the view a in that his prosecutlon improper, madepublicaccusations professionaland ls has personal of impropriety on the partof law enforcement government and and attorneys, continues arguethat the Courtlach to jurlsdiction, mentalhehlthprofessionals the evaluating lackappropriate him licensure, so forth. and Because the natureof his objections hisseemlng of and inability(or unwillingness) takethe to advlce attorneyt Mr. Neighbors beenpreviouslv of has evaluated rnentalhealthexperts several by on occaslons. Examinatlons havebeendirected, this present as one,to determine whetherGuyM. Neighbors a suffunsfrom mentaldisease defectwhichreduces capacity appreciate nature or his to the of the charges agalnst him,understand impactof a guiltyfinding and assist his own defense. the in MaterialsReJiewed: (and for In preparation my examination Mr. Neighbors separate of concurrent interviewof his quantityof materialduringthe course this evaluation; a spouse),reviewed large I of newlygenerated materials werealsoreceived revlewed, and and lastly, requested reviewand diagnostic I a interpretation a previously of completed batteryof psychological testingu/hichhad originally been generated Dr. MarilynA Hutchinson, Ph-D. 2008.Thisreviewand anterpretation performed by in was

Mr.Gary Hart luty 22,2O17

-TomFleFrefr ing6Ft-FtrC-a-eivbdft.m-otheiEne-uitaers.

(cf. as Less Ph.D. below).His to reportlsattached anappendix myevaluation. by Dr.elbertPole,

Thefollowingis a list of materialsI havereceivedand reviewed: Defendant's Bondor, In the U.SRenewed Motionto Revoke and Alternative, Cause Motlonfor Mental Examination ForShow 155 HearingDocument OrderDocurnent 175 Detentfon 65,84 U.5-Motionto Revoke Bond Document Order Document 118 128 U.5.Second Motionto Revoke Bond Docurment BondDocumentI42 U5. Renewed Motionto Revoke U.S. Second Motionto Revoke Bond ClerKsCourtroomMinute Sheet- Gerrral Document tiiZ 1to Document Exhibit 165 Defendant's Motion for hls ExpertWitnessto lntervienr Defendants artdCarrieNelgibors Guy GW andGnie Order AtrthorizlrgInterviewsof Defendants Neighbors DeftnseExpert by Lettef and initial emailfrorn GaryHaft,Attomey requesting with the case assistance Background Information detailon Mr. & Mrs.Neighbors, i.e.. residence, family,education, etc^ finances, Re$ster vs. No. Letterfrom GaryHartre: U.S. GuyM. NeEhbors, 11520-031 letterdated 5l L3lLtto the BoP'sFederal Medical Center, Butner, NC U.S. Department tustice-Federal of Medical Center Records gist Hutchinson & Associates AFFIDAVIT, nsedpsycholo lice Report Cornpetency of Evaluation GuyM. Neighbors Forensic Evaluation, M. Neighbors DavidE.Morrow,Ph.D., Guy by Forensic Psychologist Police phonecallsmadeby GuyM. Lawrence Dept.,Review CCA of Neighbors Hearing Exhibits from Carrie's Competency Destruction constitutionalrightsfor the YellowHouse of Store Corporation Owners- YellowPages letter from GaryHartto Mr. Madason Neighbors

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Authorization Release Protected Healthlnforrnation, M. Guy for of Nelghbors Medical Records GuyM. Neighbors for Sumrnary Search Residence of of locating "Marijuana4rou/' Operation and "Stolen"Property Affidavitfur Search Warrantof Business Residence & . 0<> J ServedAffidavitfor Residence Search Admbsions byGuyNe[hbors-t212/O5 LabResults itemsseized Gq/s home of at LabResults THC of L, e> .) Canie'sAllegedStatement Inforrnantre: Gqy'sMariluana to use Photos Guy,Carrie and their chlldren of KBILabReport Reporting Offtcerlnterview with CarrieNeighbors One note of information GuyNeighborc re: Guy'sstaternent Pollce to Re.porting Officer lnterviewof Guy Li O s Lies J Guyacknowhdged itemspurchased couldbe 'hot"

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hlskidsdownbringing horne stolenitemd' Guy "let Exarnple Why Guybelieves posing FBI P.D. of as Agents Officers Affidavitfor DNAsamples from Guyand Carrie KBILabReport Guy'semail "Yellowhouseownersfacedrug,gun allegations" apparent duplicates Exhibit throughDOC of l 165 Transcript MotionHearingDocument of 257 Transcript Hearing Dr. Lucking's of Report Document 384

Transcript Hearing Dr. Luc*ing's of TestimonyDocument 385

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of Document 268 Transcript Cornpetency Hearing


to Competency Docurnent 200 Orderfor Hospitalization Restore Previous Eualuations:

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GuyNeighbors examined a comprehensive of standardized was psychological and set instruments obtalnedby Dr. MarilynHutchinson, was in Ph.D., 2008. I havebeenprovided entirety the of the "raw data" from this evaluation to repeatinterpretatlon reanalysls sufftcient permita reliable of / 's testing thistestingdata (cf.Dr.AlbertPoje's reporf attached).Dr. Hutchinson which are results, psychological rcgarded time with regardto the asvalidup to the present feat.ures capabilities and of rneasured, not substantlate presence psychotic did syrnptoms the presence Deluslonal the or of Disorder. Hewasexamined the Federal at Colorado Dr. DavldMonow, Detention Centerin Englewood, by Ph.D. November 2009. Dr.Monow wasof the opinionthat the defundant in of rnightsufferfrorn tlelus'ronal Disorder, couldnot determine but that the defendant's ideas relativeto his legalsituation and potentiallegaldefense was "riseto the levelof a deluslon."Hisdetermlnatlon that Delusional Disorder shouldbe "ruledout." Hewas alsoevaluated the Federal N.C, treatmentandto determine facilityIn Butner, at for probability whether"there ls a substantial that he will attainthe capacity standtrial. Dr. RobertG. to luckingand Dr, Angela Weaverissued report in June,2010 a W. expressfng conclusion Mr. the that Nelghbors suffering is frorn Delusional Disorder and incapable standing of trial as a resultof this rnental disease: they als.o opinedthat this capacity couldbe restoredeffectively safelyby the and administration, voluntaryor forced,of antipsychotic medications. My reviewof Dr. Lucking's Dr.Weave/s reportreveals objective and no elements behavior of from the obseruations madeat Englewood with the one significant substantially different dlfference cameto adopta rejecting, that Mr. Neighbors evenhostileattitudetoward the examiner, Lucking Dr. whom he uftimately accused biasand lackof objectivity, of Personal Correspondgnce: Upon rg[$!ng to_Ea pate in.further exgrn]latiolp t rtic!.i for pumoses forrningrnyopinionrecorded of here),Mr. Neighbors mailedme a copyof his separately 'legalese" whichhe appended kind observation I shpuld to the handwritten that not take this stance of hispersonally, he wasappreciative my efforts,and hopedI would usemy tirne for thosewho that of needed me'9.' really

qnd MedicalHislorv.i Personal. Social. was Guy Neighbors the principal corroboration informantfor the history however was information from interviewof his spouse, well as extensively historical as duplicated obtained documented hiscasefiles. in lost at He is 51 yearsof age,hasfour siblings, his mother{deceased) ageeightor nine,and was andwasthe recipient a sports lunior College after secondary school of raised hisfather. Heattended by University hi5l6lgl ygqrsof education.Hedid not receive degree.His for scholarship Kansas at a is currentmarriage of 3Gryears'duration- the couplehasthreeadultchildren and hascaredfor almost church,Big in activities inctuding 30 fosterchildrenin their home.He hasbeeninvolved community and and repair(hisfather'sbusiness), Brothers Sisters, localschoolactivities.He hasdoneelectronlc plant,andwas mostrecently service.He selFemployed running delivery a workedin a manufacturing hiswife alsooperated usedmerchandise according storein Lawrence Topeka, and although and a to He in of Mr. Neighbors, wife wasmor involved the day-to{ay operation the business. hada hobby his forthe currentcharges problems to associated the used with of gardening. relates bases He the guns plantsamongthe merchandise hisbusinesses, he hadin hishomeand "a couple"cannabis in

ptants hobby gardening tf,TC,u, beddine inhis .$11 as admtts arrestedage and 20forpossession at 19 age Heisrecorded (and of t&fiJing been
man'juana. deniessr:gnificant currentcannabis on otherthan a fewgccasions deniesuse or and He use . rr\ l-- [lYS ]h"* /*^.#*'1Tr"ro of atcohotorotherintoxicants. years and wastreatedup He wasdiagnosed with AttentionDeficitDisorder durlnghisschool medication.He recalled periodof "clouded" a thinkingwhen to the time of hisarrestwith stirnulant of stimulant.Hecontinues first anestedas a likelyaftermathof abruptdiscontinuation the prescribed occasionally that he hasdifficultyfocusing attentionfor longperiods but doesnot feel that feel his to thisaffectshisoverallperformance understandlng. or He hashypertension which he takesLisinopril, for seasonal allergies whichhe takes for painfor whichhe takesacetamlnophen ibuprofen. loratadine, occasionaljoint and or Svmfiom Review:' joint He deniedphysicalsymptoms the exception long-standing painandoccasional of with perceptual fatigue.He deniedunusual sleepdisturbances, disturbances, of appetite.physical loss or of symptoms anxiety, lapses rnemory.Hedeniedanyform of halluclnation5, deniedbeing of s6d suspicious the motives behavior peoplein hisenvironment of or of l"exceptfor beingin jail...") He beingparticulady fearfulof or uncornfortable denied aroundotherinmatesor custodial staff. Hewas openaboutbeingsornewhat skeptical mentalhealthdoctors"beca theyseemto want to drug of use me." {

Examination: to that I setting, explained Mr. Neighbors our encounter at As always the outsetln a forensic -and that communications wouldnot be at all confidential the mannerof ordinaryphysician/patient in publicas of and of the entirecontentand conclusions my exarnination interview him would be rnade Attomey. Heindicated that he understood, States hls reported the C.ourt, attorney,andthe United to to notethat he was "takingpart in this fashion askedme and in a veryfriendly,almostapologetic me he him to explain, statedthat'the Courtis requiring to underdurcss-"When I asked examination on I talkto you-.- andwhen t pointedout that, in anycase, couldnot and wouldnot exertany Pressure that he understood all him,andthat he couldindeedaskme to stopandleaveat anytime, he indicated but this to be the case, "just wantedthat on the record.' (ahhough forcefulor whenappropriate was relaxed Mr. Neighbors entirelycooperative, no trernulousness, in intense).Heuraswell groomed, dressed inmategarb,and exhibited restlessness, or abnormalmovements rnotor weaknessgoaldirected, and coherent, was modulated, Hewasfully alert and oriented. Hisspeech in level. Hewascornplete his reflected overallnormatto highnormalverbalabilityandeducational an tell He when necessary. couldrOadily me the natureof the charges for and responses asked clarification and discuss intlre abstractthe conceptof plea agalnsthim, estirnatethe effectsof beir6 found Buihy, guiltyin hiscase. his aboutthe proprietyof pleading agreements he urasalsoableto express concerns - most slgnificantly not in any fashionpreoccupied with the.idiosyncraticjtnd decidedlyodd Hewas drawingaboutthe natureof he maklngand condusions acknowledged he contentions acknowledged (or and of the the the investigation, lackof jurisdiction, impropriety hisprosecution, the integrity lack he to thereof)of his attorneys. While thesematteis arosein response my specificquestions, was able little precision: internetmaterial thelrsources in to explain convictions, generalideqti{Y hls {albeltwtth and sources), recollected beingthe rnostsubstantial and counsel trom ftllow inrnates, spottyreadings presented he shouldbe the ff and mostlmportantly abstractly hypothetically, dfficulties cqulddiscuss, just plainwrong. Hewasableto acknowledge hisallegations made that deceirred, or rnisinformed, of and the aboutprosecutors couldbe ilt advised, accept possibility hisbeingin error. to with the truth of matters that he feh obligated proceed concluded However, inevitably he them. factual and legalas he perceives

ng)was
there of. As above was {ROS}. wasnoevidence jgrnpjgeO. Hisconcentration to5t$normal- noted p^ercgjlual . nor to of disturbances, bgggsdelusions, didheapperr lgve f_eelings.eferen ',\
I

rigidityof defenses he consistently statuswasa decided In abnormality rnental Thesingle to and as described himseJf besetfrornall sidesin hiscurrentlegalentanglement, appeared seereliance thet othersin contradiction his own convlctiDns a form of weakness wouldcolludein hisown as on to defeat.

Assessment: Psychological is as of Dr.Poje'sanalysis the raw datafronr psychologkaltesting appended partof this report. supporting of and patternof rigiddefenses, an absence indicators include personal a findings Significant disorderor prychosis. of the presence a cognitive lnformation: Ancillary of her wife. Overall description her 30 plusyearsas I wasalsoableto interviewMr. Neighbors' a moodor thinking, of to appeared confirmthe lackof anyprior historyof disturbances hisspouse on of and tendency stubbomself-reliance avoidance dependence others. to Diagnoses: t. It, lll.' gnin'ron; on of certainty the basis the medical opinion,whidr is heldwith reasonable In my professional and GuyM. Neighbors, my professional of my I materials havereviewed, examination the defendant Gut' does Psychfatry, M. Neighbors and in trainlngand experierrce the field of Adult Psychlatry Forensic the his ettectsor dirninishes ability to understand of NOTsufferfrom a mental dlsease defect uitrtctt to the charges hlm, to apprec'tate effect of a guiltyverdict,or to assisthis attorneys, the degree against in he chooses, hisown defense. Disctrssion: doessufferfrom a rnental has that the defendant Giventhat at leastone examlner deterrnined for on that it appears someexpansion the basis my verydiffurent Disorder, disorder, namelyDelus'onal conclusion ln order: ls PoranoioVera,Mono Symptomatk Delusional Disorder, DefusionalDisorder Paranold [aKA (studyof in describq4_entity the psychiatricnosology DisorderJ a poorly understoodand yEguely is to agreed conslst ofgl4gal gnstituent fealYles: years. lt is generally disorders) morethan 10O for or to out hat one bJ1altre?ted of a desire persecute harmout of derived whlchare not culturally and everfactual) Jelgus moqves(whichideasare treatedas always (without onsetspontaneotsly aboutthe natureof things); beliefs sharedideas or {thusunlikereligious accepted that in mentalillness) the adultor lateadult years-lt is general(y in obvious origins a previous and mood disordersrnustNDTbe oerceptions) othersymptorns(suchaslUlUgilgge.ggor.bizarre that th" jdgt iluolyg9 rece[ygitts theeltsenFus presentin order to even entertain this diagnosis.ln in Pelusional Disordermust npt be pgleqly "bizane' hasweakened bullemaiosileature which osticerrors. promotes somelesqrls with anxietyand depresedrnood Disorder Adiustment personality features or narcissistic obsessive Rigidity tlefensessuggesting of Hypertension,seasonalRhinitis,Arthritis

and are g$]q!g,td, this and above beyond coredescription coniectufal, used Currently "criteria" ro-ffi nEitYTf olft f Mup=otEma-tEn-rei rffi tffi enrf,-gT|tffi thanconjecture, other to too of timeareinsfficientandduration follow-up short permit
that conclusion it is the supports cautionary strongly Thevery distinctnatureof this disorder thoughts: unlikeSchizophrenia of by characterized the presence delusional from other itlnesses distinct by it'ts and and relatediltnesses, unlikeAffectivelmood)Disorders not accompanled otherconfirmatory 'antip-gychgtic' available mgdlcatigtrs to and and symptoms signs; it ceftainlvdoqsnot rcspond and ililgtinctive in its bi-oloqvand s, Iffi otlellgqrg$S. . never practice with the illness in sincepersons is Disorder raretyencountered clinical Delusional setf.reportorseekdiagnosisontheirown-nothingiswrongwiththeml@n arise from artioncthe sufftrqr maytake resultof legalentarulements when Starees {as ,?Slenfrely the in order to Jieh\a piggived.yrolg oI gen-!he$Ofe"), and c "tes who are accused ilfideli]y or of or paranoia), co'workers, employers [in the caseof conjugal matbasance. wrong, on from ideasbased beingsirnply be "Delusiont'mustalwaYs distinguished _misinformJd,orTeH@fs.Sov.retpsych|atrywas"ex@mmun|cated,,frorn persons'failureto adheib to enceof categorizing and hospitalization imposing andasa consequence as'delusional", ideas right-thinking ltalinis! drug regimens thoseso diagnosed. on enforced Dqluslons ideasheld with a degreeof fixity and infle{bilitV which interruptsthe normal flout are @:individualswithreliab|ydiagnosedde|usions(i.e.indborderswhere of the precence ottrer$/mptorns, !!$g!t-o{-i![gs, ggegcs, are spectrumdisorders, unableto adopt hypothetical as in Schizophrenlc J9!95!Iyj!Sgno5sl - "what if the world was not beingeaten up by demons?).Ihg1ygEd1g:Pgl:e (e.g. considerations 'normal" evennormal isll verifiabledelusioJ:il"but it_ glcontrast otherwise patienthotding from I

-mistaken-therrfri6ilfiEoi6iland and to are loeas suuject examination hypothesls

pfi'iio;ily.

rior.g!$ggized,He@nseouentlv ln myexamination, Neighbors@c 6uy asa matterof hYpothes was didnot "digin hrstrEe!{and. ableto. in t|:g.a potential having of possibility being wro,ng, the of pooriudgment of online utterances. usinE @lic
patterns perceivinB threatsandopportunities, preferred and of Hispersonality, characteristic opinionrenderhim adversity rnypmfussional in (evenobtigate) meansof copingwith his present perceive adversarialPgl99.4,s.Ast-9!9..eY9n the unlikelyto hisown conclusions, unlikelytoabandon e of othersmay knowbetter or OepossesseA sup that to handed, unlikely accept

His I hold mentalstatus, qth Eual of control hisfateto ang!!9_1,sgujgg!ge. relinqulsh unlikelyto he thilgs. At the end, remains to professional his does certainty, notreduce capacity doallthese

with and the knowing legaland life consequences, cooperating the of capable understanding charges,

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rations: "Sells" Conslde

to hewillchoose exercise rniy Oethat

for appropriate me to in natureof diagnosis this rnatter,it appears ln view of the contested the at of the and my opinionregarding appropriateness a.ttempts treatment: detailmy findings does that this defendant determined it of potentialforbenefitand likelihood riskshould beiudicially enforcing treatment.andthe court mustconsider refuses indeedsufferfrom a mentaldisease, treatmentin an effort to "lestore' competency' frn'n nelusional Disordel:9f sinceI am firmly of the opinionthat he dgesNOTsuffer Of course, takeno( voluntarilY rnedicatlon, Srat it ntal illness, is my opinircn antipsvchotic anyothel risk the associated beneficiafan! is administered, not likelYto-be drug reactions. of adrlerse "generationJ that tlgpiyqbllc-rnedlcal'on (of any phajmacologic It is alsopuzzllrgto-mQ of a hiEhlikelihood as b atyplcal, Presented typicator Disorder. fiom Delusional

of spectrurn mentali!!9,ordqrs.-q94not on based the broad to of Rates restoration competency

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the to I vS, States Ghani,undertook revlew thencurrent in with ln connection testimony United whentreated Disorder In outcomes Delusional treatment regarding (in beyond) literature 2960andJust for I have brieflysearched anynew rnedications. antipsychotic withthevarietyof thenavailable
relennt studieswhich might havebeen offeredsfnce' lt
overall, than a

con&sinnas

patfrobgical nkiqgt thi "?gg!ilsrhqten'

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risk treatrnentare not negl'rgible increased for.treq4dise.ase{cardiac The risksof antipsvchotic

and motormovements, ilsbeteslglE abnorrnal tlrnpglary or permanent distuibances, rhythm patient)^/ath a robust to treata voluntary n rnjgltbe.appropriate ttrem.fn r@@o among foremost

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toforc' it of hope a smat@ee-&Lso,nete1gf. notbelieveappropriate .ldo

at s is questionable best.

to DanEerousness Selfand Othgru: s, a+g!!$; on Based htslackof crirulabtgpgljrity, his historypt Fe"td f"t the.-"tt r:e of mood regulation,lt persistent disturbances or of absence any hlstoryof disordsg of impulseq11!ggl
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ptr!99tsgb!-gt that medical certalntv, that Mr. GuyNelghbors is myoplnion, wlth reesonable harminghimselfor@ ---=-.-Submitted, Respeaful$

-\Ut lWVl^KW06ta: ) M.D. Wtsner, JbAdn.


Sdences Behavloral Profesorof Pslrchiatryand Associate Clinical of School Medidne of Uni,rerslty Kansas KU Pslthlatry, Hospltal Inpatieht Directorof Attached: Ph.D. Reportof AlbertFoje,

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