Spreadbury v. Bitterroot Public Library et al
Filing
123
RESPONSE to Motion re 119 MOTION for Leave to File Under Seal filed by Michael E. Spreadbury. (Attachments: # 1 Appendix A) Appendix B is a DVD and will be retained in the Clerk's Office) (ASG, )
Michael E. Spreadbury
FILED
100 S. 4th Street
OCT
Hamilton, MT 59840
'8 :::1
PATFlICI( E. OUH 'i ' (L'-"!(
Br.
; .."'-l
Telephone: (406) 363-3817
OEI'UTY Ct..l!Ri<: MISI" ~,~-
-
mspread(d)hotmai l.com
Pro Se Plaintiff
IN 1HE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MONTANA
MISSOULA DIVISION
MICHAEL E. SPREADBURY
) Cause No: cv-11-64-DWM-JCL
)
Plaintiff
v.
) OBJECTION TO BOONE
BITTERROOT PUBLIC LIBRARY,
) SEALED STATEMENT OF
CITY OF HAMILTON,
) UNDISPUTED FACTS
LEE ENTERPRISES, INC.,
)
BOONE KARLBERG, PC,
)
)
Comes now Spreadbury with objection to Defendant Boone request for court to
allow statement ofundisputed facts under seaL
Brief in Support
Defendant City ofHamilton used unlawful use of City Police Force in the
aforementioned to deprive Spreadbury established right under color oflaw.
1
Plaintiff Objection to Sealed facts Cause 9:2011-CV-11-64-DWM-JCl
October 14, 2011
Defendant Boone imputed crime in Joint Function Test, Defendants interfered with
2009 mayor election as in Public Function Test with Defendant City ofH.amilton
by way of peaceful assembly August 20, 2009 at Defendant Public Library 306
State St. Hamilton Montana USA Johnson v. Knowles 113 F. 3d at 1118-1120 (9
th
cir., 1997). Defendant Lee published that Defendant city police "answered calls
about Spreadbury 13 times" although no arrests, citations, or warnings were made.
Spreadbury holds "public trust" National Security Clearance issued by FEMA Jan
2008 (Appendix A).
On October 4,2011 Defendant, and official policymaker Chief Ryan Oster
unlawfully entered Spreadbury's residence captured on video. Defendant Oster's
unlawful act demonstrates to the court continuous unlawful activity of Defendants
pled by Spreadbury as proof ofneed for injunctive relief from Defendant City of
Hamilton (2nd Amended Complaint ~237-232; TR. #10). Unlawful entry is an
equal protection violation by Defendant Oster, protected in the 14th Amendment
US Constitution. Defendant H.amHton Chief of Police made policy by entering
residence under color of law without permission as "everything OK" called over
his police radio Monell v. City o/New York Social Services 436 US 658 (1978).
To date this esteemed and Honomble Court has failed to protect Spreadbury from
civil rights deprivations under color oflaw as is prescribed in 42 USC § 1983.
2
Plaintiff Objection to Sealed facts Cause 9:2011-CV-11-64-0WM-JCL
October 14, 2011
Police reports are pretext to actual behavior of Spreadbury, deprivation of rights
under color oflaw. Spreadbury is not under investigation, nor has ever committed
a crime in Montana. Due to Montana's 48th ranking, Spreadbury is scrutinized
unlawfully by Defendant City Police, and this Honorable court. Defendant request
to court to allow sealed City of Hamilton Police reports are met with motion for
sanctions served upon Boone on this date for 21 day safe harbor per FRCP 11.
Bad faith litigation, abuse ofjudicial process, pleading not in well grounded fact
are well established reasons for Spreadbury request for sanctions, and notice.
This District court has not upheld Spreadbury's fundamental right to peaceful
assembly in the aforementioned August 20, 2009 at the public property adjacent to
the Bitterroot Public Library August 20, 2009.
Court is asked to reject request for police records under seal. Only fact remains is
Spreadbury's fundamental right not upheld. Court is directed to Appendix A
Spreadbury National Security Clearance. Spreadbury wishes to denounce court for
indicating use ofIFP as advantage. Defendants in this case have caused IFP status,
and Honorable Judges have to answer for depriving fundamental right to
Spreadbury in aforementioned.
Defendant Boone is a defendant in this case, and pleading in bad faith without
grounded facts outside the pretext of the City of Hamilton Police Department.
3
Plaintiff Objection to Sealed facts Cause 9:2011V~ vr"\\Et~\ ~~
Respectfully submitted this ~day of October, 2011
/
Michael E. Spreadbury, elfRepresented Plaintiff
5
lul¥/\1
Certificate of Service
Cause No. CV -11-0064-DWM-JCL
I certify as Plaintiff in this action, a copy of the below named motion was served
upon the US District Court Missoula Division and all opposing counsel for parties
in this above named cause of action by first class mail. The following addresses
were used for service:
Objection to Boone Sealed Statement ofUndisputed Facts
Leave File Rule 11 Sanctions Harassment (Boone)
Russell Smith Federal Courthouse
Clerk of Court
200 E. Broadway
Missoula, MT 59803
Defendant Counsel:
Plaintiff Counsel:
William L. Crowley
Michael E. Spreadbury
Boone Karlberg PC
PO Box 416
PO Box 9199
Hamilton, MT 59840
Missoula MT 59807
(self-represented)
Jeffrey B Smith
Garlington, Lohn, & Robbinson PLLP
POBox 7909
Missoula MT 59807
Dated _ _ _10114111_ __
Mi hael E. Sprea bury, Pro Se Plaintiff
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?