Spreadbury v. Bitterroot Public Library et al

Filing 111

AFFIDAVIT in Support re 108 MOTION for Summary Judgment DEFENDANT LEE ENTERPRISES INC'S MOTION FOR SUMMARY JUDGMENT ON REMAINING COUNTS FOUNDATIONAL AFFIDAVIT OF JEFFREY B SMITH IN SUPPORT OF DEFENDANT LEE ENTERPRISES INC'S MOTION FOR SUMMARY JUDGMENT ON REMAINING COUNTS filed by Lee Enterprises Incorporated. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J) (Smith, Jeffrey)

EXHIBIT A

Jeffrey B. Smith

GARLINGTON, LOHN & ROBINSON, PLLP
350 Ryman Street. P. O. Box 7909
Missoula, MT 59807-7909
Telephone [phone]
Telefax (406') 523 -2595
j [e-mail]
Attomeys for Defendant, Lee Enterprises, Inc.

IN THE UNITED STATES DISTRICT COURT
FORTHE DISTRICT OF MONTANA
MISSOULA DIVISION

MICHAEL E. SPREADBURY,
Plaintiff,

Cause No.

CV-l l-064-M-DWM

DEFENDANT, LEE ENTERPRISES,
INC.'S FIRST SET OF WRITTEN
DISCOVERY REQTJESTS TO
PLAINTIFF

BITTERROOT PIJBLIC LIBRARY,
CITY OF HAMILTON. LEE
ENTERPRISES, INC., and BOONE
KARLBERG P.C..
Defendants.

COMES NOW Defendant, Lee Enterprises, Inc., and pursuant to Federal
Rules of Civil Procedure 26,33,and 36, hereby requests the Plaintiffto answer the

following Interrogatory and Request for Admission in writing and under oath,
within thirty (30) days after receipt thereof. Amended or supplemental answers to
said lnterrogatory and Request for Admission should be served and filed at any
later date as required by Federal Rule of Civil Procedure 26(e).

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03991l

1.

REOLIESTFORADMISSIONNO.

l:

Pleaseadmitthecornments

published with the September 10, 2009, article on the Ravalli Republic website, as
alleged in your Second Amended Complaint (Dkt. No. 90) were made by third-

party, on-line readers,
RESPONSE:

2.

INTEIRROGATORY NO. 1: Ifyouranswertothepreceding

Request for Admission is anything other than an unqualified admission, please list

all of the facts and circumstances upon which you relied in denying the above
Request for Admission.

RESPONSE:

DATED this 12th day of August, 201

l.

Attorneys for Defendant, Lee Enterprises, Inc.:
GARLINGTON, LOHN & ROBINSON, PLLP
350 Ryman Street . P. O, Box 7909
Missoula,MT 59807-7909
Tel ophone (406) 523 -25 00
Telefax [phone]

CERTIFICATE OF SERVICE
I hereby certiS that on the

rzt

day of August, 2011 , a copy of the foregoing

document was served on the following persons by the following means:

1.2-

CM/ECF
Hand Delivery
Mail
Overnight Delivery Service
Fax

E-Mail

L

Michael E. Spreadbury
P.O. Box 416
Hamilton. MT 59840
Pro Se Plaintiff

2.

William L. Crowley
Natasha Prinzing Jones
Thomas J. Leonard

BOONE KARLBERG P.C.
P.O. Box 9199
Missoula, MT 59807-9199
Aftomeys for Defendants Bitterroot Public Library, City of Hamilton, and
Boone Karlberg P.C.

lsl

Jeffrev B. Smith
Attomeys for Defendant, Lee Enterprises, Inc.

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