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)

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EXHIBIT A Jeffrey B. Smith GARLINGTON, LOHN & ROBINSON, PLLP 350 Ryman Street. P. O. Box 7909 Missoula, MT 59807-7909 Telephone (406) 523-2500 Telefax (406') 523 -2595 j bsmith@arlington.com 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). | 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 (406) 523-2595 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. 10J99 r3

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