Spreadbury v. Bitterroot Public Library et al

Filing 124

AMENDED DOCUMENT by Lee Enterprises Incorporated. Amendment to 111 Affidavit in Support of Motion,, AMENDED AFFIDAVIT OF JEFFREY B. SMITH IN SUPPORT OF DEFENDANT LEE ENTERPRISES INC'S MOTION FOR SUMMARY JUDGMENT ON REMAINING COUNTS. (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, # 11 Exhibit K) (Smith, Jeffrey) Modified on 10/21/2011 to create relationship w/ 108 Motion (APP, ).

EXHIBIT A

Jeffrcy B. Smith
GARLINGTON, LOHN & ROBINSON, PLLP
350 Ryman Street. P. O. Box 7909
Missoula, MT 59807-7909
Telephone [phone]
Telefax [phone]
j [e-mail]
Attomeys for Defendant, Lee Enterprises, Inc.

IN THE LINITED STATES DISTRICT COURT
FOR THE DISTRICT OF MONTANA
MISSOULA DIVISION

MICHAEL E. SPREADBURY,
Plaintiff,
v.

Cause No.

CV-l l-064-M-DWM

DEFENDANT, LEE ENTERPRJSES,
INC.'S FIRST SET OF WRITTEN
DrscovERY REQT.JESTS TO
PLAINTIFF

BITTERROOT PI-JBLIC LIBRARY,
CITY OF HAMILTON, LEE
ENTERPRISES, INC., and BOONE
I(ARLBERG P.C.,
Defendants.

COMES NOW Defendant, Lee Enterprises, Inc., and pursuant to Federal
Rules of Civil hocedure 26,33, and 36, hereby requ€sts the Plaintiffto answer the

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

l.

REOU.EST FqR ADMISSION

Np.

l:

Please admit the comments

published with the September t0, 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,

Il:.ffqRRp8.{I93y--l!O. 1: If your answerto the preceding

Request for Admission is anything other than an unqualified admissiorq please list

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

RE$PONSE:

DATED this l2th day of August, 201 l.
Attorneys for Defendant, Lee Enterprises, Ins.:
CARLINGTON, LOHN & ROBTNSON, PLLP
350 Ryman Street'P. O, Box 7909
Missoula, MT 59807-7909
Telophone [phone]
Telefa:< (406) 523 -259 5

10,39913

CERTIFICATE OF SERVICE
I hereby certiff that on tftt

Zal

day of August, 2011, a copy of the foregoing

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

l.Z

1.

2.

CM/ECF
Hand Delivery
Mail
Overnight Delivery Service
Fax
E-Mail

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

William L. Crowley
Natasha Prinzing Jones
Thomas J. Leonard

BOONE KARLBERG P.C.
P.O. Box 9199
Missoula, MT 59807-9 I99
Attomeys for Defendants Bitterroot Public Library, City of Hamilton, and
Boone Karlberg P.C.

lsl

Jefftey B. Smith
Attorneys for Defendant, Lee Enterprises, Inc.

I

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