Spreadbury v. Bitterroot Public Library et al

Filing 115

RESPONSE to Motion re 108 MOTION for Summary Judgment DEFENDANT LEE ENTERPRISES INC'S MOTION FOR SUMMARY JUDGMENT ON REMAINING COUNTS filed by Michael E. Spreadbury. (Attachments: # 1 Brief in Support, # 2 Affidavit, # 3 Exhibit to Affidavit) (APP, )

F
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To: Jeffrey B. Smith esq.
Garlington, LoIIn, Robinson PUP
P.O. Box 7909
Missoula, MT 59807

From: Michael E. Spreadbury

Fax: (406) 523·2595

PO Box 416
Hamilton, MT 59840

pg cover, and

Phone: [phone]

Pages:1

Subject:Discovery Info.

8pg supporting pages

Date: August 15,2011
For Review [x I

Urgent( ]

Reply []

COmments:

Dear Jeff,
Enclosed are comments. articles related to Ihe BPl case as requested in your August 12,
2011 pleading served upon Ihe court.

I am enclosing commenm. article of August 9, 2009 article due to Judge Lynch indicating
liability to your client Note a "non-<:OmlClion' to that article also included.
Within comments found for September 10, 2009. invalidation of career job at FEMA
included as page 8 which I attempted to correct with John Cramer and Perry Backus as
indicated on the form. Comments regarding my health included.
80th articles identified my name on Ihe front page of the Ravalli Republic Newspaper.
On June 27,2011 it appears I sent the commenm to Ihe August 9,2011 article.
This should satisfy your discovery request.

Please contact me if you

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any questions.

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ravailirepublic.com

[C
I care

at St. Patrick Hospital

funding!'

loans If they serve rural

Baucus promised to
look Into the status of
that money, tbenbanded
OIithis private e-mail
address to the crowd and
urged them to get In touch
with Wm directly. He also
urged Sebelius to check
on Partnersbip'sfunding
predicament.

areas.

"He doesn'tforget

much!, Sebelius sai!:l
with a laugh. "l imagine
we'll be checking Into the
Creil.mery buiJdlngvery
soon!'
Baucus and SebeIius
also touched onanother
centralissue affecI:Ing
MontaD.a\lS and health
-the state's rural popula­
tionand the growing I.ac.k
ofprimary caI\l doctors.
The health carei:efonn
act provides Incent1ves
fQrmedical students to
becQrne primlllY caI\l
docs InsteiId ohpecial­
iSts,lncludingforgiving

Baucus said that's a
posiliw step In ~efocusing
health caI\lon patients

fulreimbUrsement SYS­
tem are steps that health
care providers support,
said St.Patrlck Hospital
Presldent ref! Fee.
"There is serious inter­
est in changing the way
health care is provided in
western Montana," Fee

insteadofhealth care pro­
viders.
"We have to spend our
healthcare dollm on the
said.
.
patient:' Baucus said. " ...
The struggleto make
We've not thought alot
about the patient!'
the needed changes
Instead, American
was summedup by
health care has focused on Fmnk Reed, a doctor at
Community Medical
quantity, because more
Center who quoted
patientsmeans more
reimbursement money,
Winston Churchill: "We
he said.
can always COWlt on the
Americans to do the right
That, of COIIISe, is
how America became the thing. after they have
country that spends more exhausted all the other
of its Income on health
possibilities!'
care than nearly every
other developed nation.
Rep<)Tw Michael
M()(J'ro C<IIl be reached
"We need to have
at 523-5252 or by at
reimbursements on the.
11I11lOOl"e@mj8souifan.
basis of quality:' Baucus.
com.
said.
More primary care
and a better, less waste­

1910
. of the first flour are orna­
mental plaster anddOOrs

.~~=<:,~Mrs.

/

Discussion: Spreadbury lawsuits begin pretrial hearings

Page I of2

Horne I Ravalli Republic II News I Local I Crime and Courts I

Spreadbury lawsuits begin pretrial hearings
• Story
• Discussion

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(2) Comments

10 "1'1) AM r~<t" ...",.

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I.
momrun said on: August 9, 2010, 12:42 pm

I sincerely hope the judge nails Spreadbury with every dime ofthe cost his frivolous
suits cost the city and county, and perhaps a countersuit for malicious prosecution is in
order, as well. It is time to shut this guy down once and for all.
Quote This Report Abuse

2.
notphilLesh said on: August 9,2010, 8:57 am

I spit out some coffee at Spreadbury's "he is lost in space" quote. I think it is quite
obvious who is living in a different universe here. Hopefully this will be dismissed,
the city and county attorneys can get back to their jobs, and Mr. Spreadbury can get
--)-". the psychiatric help he clearly and desperately needs. ~

Quote This Report Abuse

Add Comment

httn·l!www TRv,dlirennhlicmm/newsllocal/crime-and-courts/article

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r~~~'¢;:t~~~~Q.._jBr~;.~~-:-=-.~~~~~s;!!t:..,,:t:~~j;{;.tWi~~~I;,~~~~c~~~ or tS'~

Donn Mcsle.. of Hamilton checks the temperature of ,orne ribs on Saturday at lhe Creamery Picnic,
Mcafee was working with Benny's barbecue catering co"'p-.my to compete in the barbecue competition,

A-L

Dr. Kent Kultgen,
Stevensville
Public Schools
Superintendent, was
at the mercy of l'Js
students 011 Saturday.
He bravely spent a
good half-hour on
the dunk tank at the
Creamery Picnic at
Lewis and Clark Park
in Stevensvill.e on
Saturdav afternoon.
Of course, Dr. Kultgen
wanted to look hls best
if he was going to be
repeatedly splashed
into a bucket in front
of hundreds of gleef..,l
children, so he wore a
suit and tie. The sight
of a top administrator
apparently got the doz­
ens of kids who paid
good mouey to get their
shot, more fired up,
however,

Sec PICNIC, Page 6

Spreodhury lawsuits begin pretrim heorinUS

JEFF SCHMERKER
SlA'i Rt?(Y':;~

Attorneys representlngthe
city of Hamilton and Ravalli
County on Friday argued
for sununary judgement
in Michael Spreadbury's
sprawling $3.6 million cases
against many of the county's
civic and municipal officials.
Arguments were made to
District Judge John Larson
in Hamilton. The Missoula­

based judge said he ",111
deli,'Br a written ruling later,
Spreadbury, an 11DS\lC­
cessfui mayoral candidate, is
seeking a totalof $3.6 million
from the county, city and
Hamilton librarian in three
separate lawsuits.
In complaints against the
city and county attorney's
office, Spreadbury said ear­
lier prosecutions against
hhn were made on improper .

a

grounds and with intentional
malice. Earlier on Fridav
Larson held a pre trial hearing
all an appeal by Spreadbury
over his disturb, the peace
.sen§jdjon tbis SIl iog.
On Friday, attorneys rep­
resenting the two offices
asked for the cases to be dis­
missed, saying Spreadbury's
claims were not backed by
evidence, were based on
bnproper readings of law or
were simply nonsensical.

Arguing for the county,
attorney Michael King told
Larson that most of the
county attorney's actions
Spreadbury clahn were Inju­
rious to hhn were actually
protected,
"In Montana you can not
claim emotional distress
when you are legally entitled
to do what you have done,"
King said.
See SPREADBURY, Page 7

County's junk car removal program funded

JE!'!' SCHMERKER

Ravalli COWlty has $58,734
in statemoney available this
year to implement Montana's
junk vehicle removal pro­
gram.
County commissioners
onFriday accepted a low bid
offer from Kyle Marvin to

remove jw1ked vehicles under
the program.
The program will pay
Marvin $45 per vehicle plus
$4.33 per loaded mile.
The statewide junked cars
recycling program makes
money av.ruable to counties
to haui away junked vehicles
which are sold as scrap metal:

money from the sale of the
metal is used for environ­
mental health programs.
Ih. prognllll in Ravalli
County is administered
through the environmental
health department. It's run
partly for health reasons and
partly for aesthetic reasons.
Junb:ii cars can detract from

property values, and car flu­
ids like oil and antifreeze can
leak into and contaminate
the groundwater. tinder law
junked vehicles and vehicle
parts must be screened from
public view - and that does
not mean covering them with

a turp.
See CARS,

7

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01. (.'11lJll-'-.

drugs in

Jeffrey
arjjuana
tsinApriJ

records

nonsthey
tijuana

mitoredby

JolmJJ. told
atherdi­

Glke1lSed

15said
iSinfur­

Doc, a setter beJOIlgiug to the Swam!OIl&mily of Corvallis. .11S iu (be shade of an apple tree while Luke Swanson, the fourth
generation ofSwansons to grow'~ilU:ireBitterroot Valley, pulls hail-aamaged apples from one of the family's orchards ' - - ­
Wednesday afternoon. With pickingff:lllll0il drnwmg near, the family - whIch has been growing tbe fruit in the valley for 100 years
now - is geanng up fOT another harvesL
,h"'i' "\-e;:( ~

~Y'<'-

infor­

';land..tl!riZes himselfasaCba:raC­
. './ . spreadbury, 313,.. public
...•
"'<,-watchdogandchampion
Miclla.tIP , dl-setan
. of free speechan\l civil .
rrnmi!ms' "''!tfor .;1,
rights who is dedicated to
-a~~l!iI!Ction Day
e!ipOsing A vSt criminal
- andQ 1
iSpreadbury
coruopiracyin the Bitterroot
Ol:lltel iI! I s
•vaIley.
SJ;q.......';who

:Acoordingto pub­
..lie Il!CI)I'ds, police have
S\lrcha1gl!s,'..
an.d$l11.. '.inCOllrt.
..

i!:satln

!"J9bm;

,dis­

;)ewery
~
-.l'gge4

~f',\..!#"-J

fees.
.....

~~

""I,. ... !ed 13 times since

c6mtlS. ·1\pIi!.200B to complaints

abOut Spreadbury's behav­

ior attire libnny, the county
;jdmjnistration building,
tlreoounty clerk ofcomt'~

·$«-IPIIlADBUIY, Page 8

services this weekend
oollarsandshelters. "We
·w.mt to show our support for
anything that has to do with
the pet community in Ravalli

Coonty. I think that'. a very
-worthwhile deal?'
Low cost rabies vac­
. dnations will be avallable
dogs from

will provide micro-chippin~
services.
Dogs who have grown
a little longinthe paw can
get their nails trimmed for
a reduced fee by Monica'S .
Doggy Barber and the
Montana Companion
Animal Network and Mobile
Adoption Unit will be on
handto hclp people search
for. find and save the "dog of
their dreams!'

A­
HanillDnll'li¥J1ll anlidate Mldl3eI Sprea:II::uyplea:lerlrd:guilty W~tooim'rally beifElSSillg at the
BItIaroct F\i)1!c Library in HamlIIDn City Court.
~ry wcs issue:! a SUT'I1"I:I'6 forthemi9:la1e

a offmseco Aug. 20 when heeta"a::l <n:I1'EITilre:J
UlIawftJIIy at the library, wtee his privilege; haI.e I:a:n revoI<a:I, aa:o!l:ling to a crrrplaint filed by City
At!:llrrle'f Ken Bell.
SpalcbJry faa:sa maxinrn j:Jm1ty ofa $500 fine, six fT'Q1I:ts in jail <n:I $92 In ax.rt fte; <n:Istld ",ges.

rerae

City CourtJ~ Mk:hael Rmrdcn E ill CITllibus h!ar1ng for Nov. 2 • a day
Eled:ial Day. <n:I release:!

$p'l!2d:uy co ra::og1izarm

$p'l!2d:uy, v.ro ra:J eta1 a pbllc defe'ld!r, GlIlt kBIie Ravalli Courty wl1tloutthe OJUIt's

p3TT1issial.

The J~ aoo warre:I hiTI rd:to Ena"the library's pq:aty, wtee he wcsl:aTa:t in Jtre aftJ!r Insisting he IE

allOW3d to IJ,tco re9l!M!a cq:JVofa leUEracrusing local JUllic offidals of ra..tirely denying~to dtiza1s.

$p'l!2d:uy, 38, cha~ him;elf as apblic watd1cbg <n:I cl"aTplco of free ~ <n:I civil rIgtei v.ro is

da:licatEd to exposing a va!t criminal anspIiacy in the BItIaroct Valley.

~ L.l4~

Aa:nrtling to pbllc rw:xtIs, mice haI.e ~ 13 tiTEs since Ap11 2008 to crrrplaints ctn.tSpmiuy's
tB1avloratthe library, theauty actnlnlslritia1 wilding, theautyclerl<of OJUIt's office, the Ravalli
Rep.b11C, the HanillDn roml district, Marcus Daly Merraial Hospital, KMSO 102.5 Mountain FM <n:Ithe
auty fairgro.rds.
All of the crrrpIalnls allega th:t he adB:I ~ q:A iaIeIy. He hasonly b;eo ~ In o:nmIco with the
library IncidErt
Aam:llng to 1WlIlil, crrrplalnls by the library, auty, ~ <n:I fair v,a\;! relcm:l to Spmctuy's
polltlcall5sJes. CarflIaints fromtheOO;pi!aI <n:IsdmI OJI1CB11ejhis forrre"~atttaeplaas. The
crrrpIalnt Iitm the radio &!tico 0JI1CB11ej his allegatloo th:t Its btoa::l< 55 i tIa fee with his tele\IIsial
~

The 1ab:st<XJTl)lalntto police ClCO.IITS:I Friday night at the falrgro.rds.

Del:x:lr.i1 RDgaIa, thefair~,sakl ~wcshokling a polItICal placard crd distrib.tlng "Mldl3eI
Maya-" p:ndls rm-the rcx:IEoE!'tnn:E, which violalB:l fair rules ra:J.liring ~tostay In

~for

theirl:Jodhs.

~ l..l6.,xr'

Shesald~~I!9!:m!crd~when!t'eexplare:Jtherules<n:la:l<l!dhiTI
I~lyto reI!.rn to his bodh

He initially refu;a:I, ll.d:then said, "You p:qlIe &:are me, Im leaving," <n:I he rcI1 off, RDgaIa said.

Spteach.ry ilCXl.I!ES g::tve II rrElT, law e fu ce let, prc:I5eCIiors, jU:lges, the~, the 11bIary, ~
eIede:loffidals<n:l Cliesof Ino:lllpetlil 0=, ~,defa ra:lori, ~crddharmlscord.rd: in a
anspIiacy cmIrolled by Courty At!:llrrle'f ~Com th:t r&ld1es litmthe BItIaroct Vallely <n:I Helem to
WashirVon, D.C.
Sprea:b.Jry'S an::errB<UElrerttv starla:l in Odrte<2lXE when he wcs citB:l for allegadly a!El.Ilting a nelghOOr

v.ro hoc! a tun pile on or rm- theira:fj:lining pq:aty line.
I~~ w- - c.sQ

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Aam:llng to oourt 1WlIlil, a j.JtY cawidW Sp6d!.irY of m~!!i!' ifa!El.I~ in Au;ju!t 3JJ7 <n:I he wcs
~ to six fT'Q1I:ts in jail with flvefT'Q1l:ts ~ <n:I $514 In ax.rt m;lSand fees, tLt a j.I:IJe threN
at the cawid:ia11n l:n.ay 2008 aftE!r ruling he hoc! rd: receive:l a tITeIy bial.

I (,.(~' 3

Since ttm, 5pIe:b.Jry ras mainlalre:l re was "falsely" arres1a:l, p!"CI5l:)O iIB:I ad anrn::te::I ad re ras wkB:! his
CO'l'lliaints aIxllt "the S)I5Isn" at p,bllc rner;tings, CI'1 his Web site ad in oIhfnm.JE!S.
_

'1=j\!.S6" U6l-t\

In Febnay, treCOl.J"tya:mn1ss1on grt5ple:b.Jry a lettrnBl1ing hmto stI:4:lt'ara9si1g C!ll!1tyamloya:;s
ad acting disnJt:tlvely.
The IEm!rwn rut aftEr COI.J"ty eTPioyees Silk:! re!i:lxd ClItside tre COI.J"ty minlstrctioo wilding, p.t a P3P3'
tag CM!l"his 00ld wiltltre~OJt out:, reid an Am31can flag ~00wn - whid1 is a sign of distJ:I:ss - ad
txxiq:h:mg~ of hirrfli!tf.
..J,.

F'~ t..I6w«' - 1>\~ ~ irkr¥'Ol

5pIe:b.Jry ~ was J:I'oIi!Stlng tre clerk ad re::tIIT.ilr's hadling of his faile:l ra:all patitlc:ns glnst local
ad st:ie officials.

In July, tre Pavalli RJerx.iblic grtSj:re:lcb.Jry a I~!en:.rooibltlng hm frana:rning CI'1to itspelil!es~of
Dis ta"a\1Qr. ,...." "'\\-~s: u,"1-ir

m9lO

5pIe:b.Jry, ...no ras d,t£ta lEd to file iawruitsgirlJttredty, COI.J"ty and ~, dalles ad:ing
inapprqllialEly In all tre ti'rEstiW pol~ haw re;pco::\!d to CXlIT'pialnts aIxllt his b!t'oavior.
5pIe:b.Jry is Sl'Sdngto I.ffl3!II:lnOJTte't Mayor Je-ry Staale Intre Nov. 3eled:ia1. His~1 OJ'l'lBigl
slog<flls "S~ The Word."

Aa::oo:ling to his Wf'b site, 5pIe:b.Jry is a gs:>1og1st:, o:rwltrt and tEacher and a 1i:lm'a" U.S. Dep3tb I a t of
HCI1'li!I1.nl Security officer.
Log CI'1 to PavallIRepublic.crmto roli I a tCl'1 this ad oIherSDries.

Reporter.John O'aTI:rcan be rmcta:f at 3Q3-3:DJorjcrara@ravalilrep..;blic.can.

Google Search for Michael Spreadbury 10-23-0913:40hours
1.

Ravalli Republic - Bitterroot Valley News: Hamilton, Stevensville ...
Sep 10, 2009 ... Hamilton mayoral candidate Michael Spreadbury pleaded not guilty
Wednesday in ..... Spreadbury does NOT and has NEVER worked for FEMA. ...
Call to John Cramer before 17:30hours 10-22-09, reporter said he would look at It In the
morning.

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