Spreadbury v. Bitterroot Public Library et al
Filing
126
REPLY to Response to Motion re 108 MOTION for Summary Judgment DEFENDANT LEE ENTERPRISES INC'S MOTION FOR SUMMARY JUDGMENT ON REMAINING COUNTS DEFENDANT LEE ENTERPRISES, INC.'S REPLY BRIEF IN SUPPORT OF MOTION FOR SUMMARYJUDGMENT ON REMAINING COUNTS filed by Lee Enterprises Incorporated. (Attachments: # 1 Exhibit A) (Smith, Jeffrey)
EXHIBTT A
2
Case 9:10-cv-00049-DWM Document
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LODGEO
1
Michael E. Spreadbury
z
P.O. Box 416
3
llamilton. MT 59840
4
5
msp"rpad.9 hotmail. com
6
||
Telephone: (/+06) 363-3877
Pro Se Plaintiff
HAY
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PATRICK E, DUFFY,
CIERK
Bv
@
7
IN TT{E UNITED STATES DISTRICT COURT
I
FOR T}IE DISTRICT OF MONTANA
9
MISSOT.II.A. DTVISION
10
11
I\,rcT.IAEL
t2
13
SPREADBURY
PlaintirT
causeNo,MNn-{W
)
)
"v,
)
CO}IPLAINT AI{D DEMAND FOR
AISRTG}IT,
)
JT}RY
CULGAN
)
14
CHRIS HOFFMAN, DEPLITY
15
DEPUTY HOCHHALTER, DEPUTY
16
DEPUTY HUDSON, I.INKNOWN DEPUTY
B,
)
17
UNKNOWNDEPUTYC,GEORGECORN,
)
18
BN I-FULBRIG}TT, ANGEI"{ WETZSTEON, )
19
MATT STEVENSON, JIM BAILEY,
I
20
REOINA PLETTENBERG.
)
2t
RAVAI,LI REPLtsLrc NEWSPAPER,
)
22
S,A,F,E. OF T}IE BITTERROOT,
)
73
RAVALLI COTJNTY
)
24
Defendants
)
T"IAL
Case 9:10-cv-00049-DWM Document
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Filed 05111110 Page 2 of 49
25
Plaintiff Michael Spreadbury (hereafter "spreadbury") in his complaint against Chris Hoffman
26
et. al. Defendants allege as follows:
Parties:
27
ZB
t.
Michael Spreadbury, a resident and natural citizen of the State of Montana,
29
2.
Mary Miller, a resident and natural citizen of Montana.
30
3.
Chris Hoffman, Sheriff of Ravalli County, a natural citizcn of the State of Montana,
31
acting in his individual capacities, and those as policy making official as Sheriff of the
32
political subdivision of Ravalli County, Montana.
33
4.
94
35
capabilities as a natural person, also acting in the color of }aw-
5.
36
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Chris Albright, a Sheriff Deputy in Ravalli County, Montana acting in his individual
Chris Culgan, a Sheriff Deputy in Ravalli County, Montana acting in his individual
capabilities, and as a natural person in the color of law.
6.
38
Lawrence Hochhalter,
a Sheriff Deputy in Ravalli County, Montana acting in
his
individual capabilities as a natural person in color of law.
39
7.
Matthew Stevenson, a natural citizen of Montana acting in &e color of law.
40
8.
Angela Wetzsteon, a natural person of The State of Montana acting in color of law as a
4t
42
43
law student intern, without Montana Bar license in the Ravalli County Attorney Office.
9.
George Corn, Ravalli County Attorney, acting in his official capacity of policy maker for
the Ravalli County Attorney Office (RCAO), a natural person of The State of Montana.
case
M
45
10.
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Page 3 of 49
William Fulbright, Deputy Ravalli County Attorney, acting in color of law, in his
individual and official capacity, a natural person of The State of Montana'
46
ql
I L Ravalli County, a political subdivision of The State of Montana; considered a person with
48
12. The Ravalli Republic, a L.ee Enterprises Newspaper published in Hamilton, Montana. As
49
50
respect to 42 USCA $ 1983 in the State of Montana.
a
colporation it is considered a natural person of Montana'
13. James Bailey, a Justice of the Peace fbr Ravalli County Justice Court, a natural person of
51
The Statc of Montana.
52
14. S.A.F.E, (Supporters
53
54
55
56
57
59
59
O0
51
62
of Abuse Free Environments) a Montana Colporation, a natural
person domiciled in the State of Montana.
15. Unknown
Ravalli County Sheriff Deputy B a natural persons of Montana acting in his
individual capabilities, and under color of law.
16. Unknown
Ravalli County Sheriff Deputy C a natural persons of Montana acting in his
individuarl capabilities, and under color of law.
1?. Ravalli County Sheriff Deputy Hudson, a natural person of Montana, acting in color of
law and in individual capabilities.
18. Regina Plettenberg,
Ravalli County Clerk and Recorder, a natural person in the state of
Montana, acting in the color of law.
Case 9:10-cv-00049-DWM Document
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.Iurisdiction
64
The US District Court for Montana has jurisdiction in this matter since the constitutional
65
violations occurred within the State of Montana which is within the confines of this courts
66
domain. All parties in this case, describd,Id. at 27 paragraphs
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State of Montana. Jurisdiction is described within 28 USCA $1391 O).
68
The Montana Dstrict has jurisdiction over constitutional torts as prescribe d in 42 USCA
59
42 USCA $1985. The Federal question raised is brought under 28 USCA $1331,28 USCA $
7a
1343(3).
7!
The Plaintiff respectfully asks that the US District Court for the State of Montana hears this case
72
based upon the rypropriate
73
controversy and case contained within this complaint.
above reside within the
$
1983,
jurisdiction, timely nature of the case, the ripeness of issue, and the
Prima Facie Evidence
74
75
/-/8
l.
The Plaintiff believes, and is prepared to show with a preponderance of the evidence that
76
the Defendants listed, together, individually, and as pairs conspired to deprive the
77
Constitutional rights of Plaintiff. These rights are not limited to the Montana
78
Constitution Article tr Section WId. at80, the US Constitution Amendments One, Four,
79
Seven, Eight, and Fourteen in actions within Ravalli County, in the State of Montana,
80
the United States of America-
of
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Article II of the Montana Constitution:
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S€ctlon 3.Inallenable
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basic
They include the right to a clean and healthful environment and the rights of pursuing life's
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necessities, enjoying and defending their lives and liberties, acquiring, processin& and
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protecting property, and seeking their safety, health and happiness in all lawful ways. In
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enjoying these rightt all persons recognize corresponding responsibilities.
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2.
rights
All persons are born free and have certain inalienable rights'
Under the color of state law, two of more Defendants wished to achieve a criminal arrest
gg
record to reap ineparable damage to Plaintiffs employment, through the course of action
89
described in this complaint, the Defendants conspired to deprive the Plaintiff of his
90
constitutional rights, through one or more unlawful acts, and the Plaintiffhas incuned
91
substantial and actual damages as a result.
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3.
93
94
The Plaintiff had favorable disposition of all criminal actions in Ravalli County Justice
Court matters pertaining to this case.
4,
95
Defendants acted with malice, callous indifference, and without equal protection or due
process under the law which led to actual damages to the Plaintiff.
FactualBackground & Cause of Actlon
97
5.
98
99
Plaintiff Spreadbury resided at 29L Cooper Lane in Hamilton, MT on and prior to
October 10,2006
6.
This property is located within the county limits of Ravalli County, State of Montana.
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7.
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Filed 05/11/10 Page 6 of 49
On or around July 23, 2006 Spreadbury obtained Sheriff Case#06A7V243 due to threats'
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and criminal endangerment from neighbor Larry Robinson of 289 Cooper Lane
102
Hamilton, Montana. Defendant George Com rejected this case, in an effort to prosecute
103
SPreadburY.
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8.
10s
106
Spreadbury took pictures of criminal endangerment, and fire hazard to Deputy Chris
Culgan in July 2006.
g.
Deputy Culgan did not take action as a result of the fire hazard even though resPonse to
tO7
seeing 1000 wood pallets stacked at 285 Cooper Lane endangering Plaintiff residence
10g
stacked within an easement. Deputy Culgan's reaction to the pictures was "Oh, Wow".
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10. Ravalli County Sheriff Department did not take action when flatbed semi-tnrck was
110
blocking Plaintiff fuiveway at29l Cooper Lane and photo evidence of such was
111
presented to them in July 2006.
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I
l.
Spreadbury filed complaint about pallet burning, placement, and construction at 285
&
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2E9 Cooper Lane, Hamilton MT with the Ravalli County sanitarian in summer 2006'
!L4
Complaint also noted the inundation of smoke from the forklift working in the easement
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at 285 Cooper Lane which was entering Spreadbury's home at29L Cooper
116
at the residence were shut to prevent smoke from entering.
Lt7
Ln. Windows
It was July 2006.
12. County Attorney Com and Ravalli County Sheriff Hoffman obstructed work of Ravalli
l1s
County Sanitarian to investigate and intervene in environmental hcalth, and fire danger at
119
285 Cooper Lane Hamilton, MT which resulted in Sanitarian resigning from her position'
case
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Miller took information to Ravalli County Deputy Chris Culgan that Denise Linell,
13. Mary
L27
the domestic partner of Larry Robinson at289 Cooper Ln. was harassing her, slamming
L22
front door at29L Cooper Lane and that she was too afraid to sleep in the house at29I
123
Cooper [,n. alone due to the harassment from Linell and the ongoing pallet operations
t24
along the property
tzs
houble" by giving this information about Linell.
L26
127
128
L29
130
14. Mary
with
15. On
line, Deputy Culgan asked Miller if
Miller of 291Cooper Ln. on October
a
she "was trying to get someone in
10, 2006 had smoke allergies documented
Corvallis, MT doctor, Dr. Y Courchesne.
July l l, 2006 Montana Governor Brian Schweitzer signed executive order #34-06
determining the State of Montana to be in extremely dangerous ftre conditions.
16. On or about
July 18, 2ffi6l.arrry Robinson stacked 1000 pallets along the property line
lane and 291 Cooper l-ane Hamilton MT. The Stacks werc20
131
between 285 Cooper
132
high, 2 wide and 25 long. The pallets were up to the roof of Spreadbury's house, and
133
wcnt beyond the widrh of the house. The pallets were approximately 12" from29l
134
Cooper Ln.
135
136
17. The semi-truck blocked part of Cooper Lane and Spreadbury's driveway on or around
July 18,2006 and is photographed.
t37
18. Robinson had a burn pile upwind from Spreadbury's residence.
138
19. Robinson burned plastic dog houses, and whole and parts of wood pallets which were
139
determined to be treated wood
as
per the Ravalli County Sanitarian in20o7.
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20. On July 23,2006 Spreadbury gathered 10 signatures of proximity neighbors within 1/8
141
mi. of Larry Robinson's pallet production at289 and 285 Cooper Ln. (easement).
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Petition said Robinson's activities at 289 Cooper Ln. was a public nuisance' Spreadbury
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submitted petition based upon Montana Code Title 45 (crimes) to Sheriff Hoffman,
144
County Attomey Corn, and Ravalli County clerk and recorder Plettenberg.
I45
21. Ravalli County took no action.
t46
22. Deputy Hochhalter came to Robinson's home one hour prior to a burning ban when a
147
large pallet bonfire was roaring. Robinson yelled at the Deputy that he had a "right" to
148
have a bonfire an hour prior to the county ban at midnight July 26, 2006.
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150
151
152
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23. Robinsons bonfire was aflame until 3am
luly 26, 2006 and
was untended from 12:30am
to 3arn.
24. Robinson was on municipal court restrictions and was yelling at a Ravalli County Deputy
about his right to have bonfue at 1 lpm July25,2006.
25. Spreadbury left for a deployment to New York State (DR-1650-NY) for the Federal
ts4
EmergencyManagement Agency (FEMA). Spreadbury's salary at FEMA was $60,804
tS5
in 2007. The Social Security Administration has set Spreadbury's redrement year to
1s6
204]0.
157
26. On September 18, 2006 Spreadbury wrcte Attomey General McGrath, and copied
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Govemor Schweitzer about'bpholding his inalienable rights" with respect to healthy
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environmenr and defending property. Concerns seen in Ravalli County as to the Sheriff
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Department were also expressed,
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Pafries.
1G2
2006
28. Robinson had pallets stacked consistent to July upon Spreadbury's return to 291 Cooper
165
166
faxed from a Hotel in Albany, NY to both
27. Spreadbury was given a 10 day retum home from the New York disaster in October,
163
164
Irtter
Lane in October 2006.
29. Deputy Hochhalter showed indifference to situation at 285 Cooper Lane when he told
167
Spreadbury that he was
168
placed within a foot of his residence.
189
with 1000 pallets
Spreadbury not to go each respective property.
31. Prior to t0 pm, Linell, residents at285 Cooper Lane were becoming intoxicated, and
t7Z
173
about fire safety,
30. On October 10, 2006 at 5pm Deputy Lawrence Hochhalter warned Denise Linell, and
77O
t7t
'irational" to be concerned
were lighting fireworks at and around and within pallets stacked at property.
32. Linell was standing outside Plaintiff living room window and scared Mary
Miller.
She
t74
off two large smoke grenades the size of small mayonnaise jars while the window was
175
open.
tT6
777
33.
Miller w:rs taken back,
and inadvertently broke a glass which made the appearance that
the living room window broke
at29t Cooper Ln.
778
34. Sprcadbury exited the front door to drive off Linell.
179
35. Spreadbury warned Linell to leave the area.
9
lit
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x80
36. Spreadbury repeated warning to Linell to leave the area.
181
37. Unell asked why she should leave.
182
38. Spreadbury hurled water glass in direction of Unell, while staying on Property, with
183
Linell 20 to 30 feet away in the dark.
184
39. Glass was re-directed away from Linell and broke on foundation of 285 Cooper Lane,
185
and no breakage was evident from the sound of the re-direction and resultant breaking
186
away from
187
Linell. Water
glass was blunt, and therefore would not scratch
4O. Spreadbury feared for his and
Linell's face.
Miller's life due to proximity of combustibles, Iighting of
188
fireworks and smoke grenades and presence of Linell violating a verbal order of Sheriff
189
Deputy not to be at 291 Cooper l^ane property.
190
41. Conditions werc dark at 10pm on October 10,2006 and Spreadbury did not know
191
Linell had weapon
t9z
if
living room window at 291 Cooper
Ln.
193
194
195
as she stood under a Spreadbury's
42. Spreadbury did ascertain Linell's intoxication at catatonic at time of incident October 10,
2006. Intoxication brings unpredictable behavior such as looming under open windows.
43. Mary Millermade frantic
9ll phone call at approximately l0:l5pm
October 10, 2006 to
196
Ravalli County Dispatch. In conversation, she mentions how county was letting this go
L97
on all summer and was not doing anything about it.
198
199
44. Two Sheriff Deputy vehicles and rwo city vehicles arrive at 285 Cooper Lane within
about 15 minutes of the 911 call.
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285
45. Deputy Chris Albright and Spreadbury walked up the driveway and easement at
201
Cooper Ln. soon after law enforcement anived at 285 Cooper
zo2
were in easement, and previously
Ln'
1000 wood pallets
lit fireworks littered the easement around the pallets'
203
46. Denise Linell swore at the Deputy, Spreadbury asked if Albright caught the comment
204
from Linell. The Deputy affrrmed he heard the foul language. Linell wasn't cited for
203
intoxication.
206
47. As Deputy Albright and Spreadbury came to the living room window of 291 Cooper Ln.
207
two large smoke grenades that were spent were found. Deputy Albright picked one up to
208
examine
it.
No smoke glenade was photographed or taken as evidence.
209
48. The Sheriff Deputies separated the parties at this point to take statements.
210
49. Deputy Albright talked to Spreadbury with Mary Miller right next to him as he was
speaking to serve
2L1
272
50.
a,s
proxy witness to Spreadbury's testimony.
$/hile speaking, Deputy Albright purposely swiveled the microphonc of his
2r3
communication unit (walkie-talkie on belt) to manipulate what would be taken for a
2L4
recorded transcript. He asked Spreadbury to re-say things because he did not "get them".
215
Deputy Albright was altering the taped testimony of Spreadbury at the scene.
2L6
51. Spreadbury stated that he was protecting his property, that he warned Linell twice to
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leave the property, and that he stayed on his property. None of these topics rnade it to the
218
official transcript at trial. Mary Miller is a witness to this activity.
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Filed 05/11/10 Page 12 of 49
rights within
52. protccting property and guarantee of a healthy environment are inalienable
the Montana Constitution Article
tr Section
lII,
Id. at 8l-86,
or ProPerty
53. Montana HB 250 which protects individuals who are protecting themselves
Ln' It was passed
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was not passed ar time of the October 10, 2006 incident at285 Cooper
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in the Montana l,egislative session in 2009. This statute would have protected
224
SPreadburY.
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226
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54. Deputy Albright cited Spreadbury for misdemeanor assault on Octobcr 10, 2006 with
ricket
TK4G3068. Spreadbury wa.s defending his property with non-lethal force.
55. Linell was cited with one count of disorderly conduct, although Linell violated a verbal
2ZB
order of law enforcement, was drunk in public, and swore at law enforcement. Maximum
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jail for Linell was l0
230
Z3t
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days, compared to 180 days for Spreadbury.
56. Linell scratched her own face, and Deputy Hudson took pictures to be used in trial
of
Spreadbury. Plaintiff Spreadbury has never seen these photographs.
57. No Ravalli County deputy took pictures of smoke grenades, or cited Linell for
233
intoxication, or violating a verbal order given 5 hours earlier by Ravalli County Sheriff
234
Deputies.
235
58. SAFE of the Bitterroot (supporters of abuse free environments) wrote a letter to
236
Spreadbury on behalf of the Ravalli County Attorney asking Spreadbury to not contact
237
the victim in this case, Denise Linell of 289 Cooper Lane, Harrilton, MT.
L2
Case g:10-cv-00049-DWM Document
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Filed 05111/10 Page 13 of 49
for the
59. Spreadbury retained Sasba Brownlee of Hamilton, MT to rcprese nt Plaintiff
for scrvices t]rough
239
citation. Spreadbury paid the retainer [ee, and signcd
240
appcai.RCAO assigned l.,aw Student Wetzsteo$ misreprescnted identity to Sprcadbury'
a conBact
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60. Brownlee responded to the letlEr from SAFE on behalf of Spreadbury.
242
61. Wirbin 10 days of Oct. 10, 2006 incident, Spreadbury evacuated personal belongings and
243
furniture from 291 Cmper Ln due to dangerrrus fire conditions, threats from neighbors.
ZU
and no support from Ravalli
24s
Storage, Hamilton,
County, Two large storage units were rerted from A to Z
MT for a period of ttrec months.
246
62. Spreadbury returned to New York (DR-165GNY) as a FBMA employee'
247
63. Spreadbury returned to Hamilton, MT in late December, 2006 and appeared before
248
24g
Justice Bailey of Ravalli Justice Court on January '7,20A1.
64.
Bill Fulbright, Deputy County Attorney in the course of the charge told
250
Brownlee that
25t
Defense attorney
This occurred in the spring of 200?.
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"If
this were anyone but Spreadbury, the charge would be dismissed."
65. FEMA refused to promote Spreadbury due to the pending charge. A request for
2S3
Spreadbury to renrrn to New York to a ncw disaster DR-1670-NY was not accepted due
254
to remaining in trainee status due to the pending charge.
2s5
66. Spreadbury's supervisor from New
Yort
at DR-1650-NY requested him personaily,
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which is the only way he could get work. The new work was EM-3270-CO tbe snow
257
emergency in Denver.
Case 9:10-cv-00049-DWM Document
258
67. FEMA had Spreadbury
2
fill out a new security
Filed 05/1
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14 of 49
questionnaire and asked very specific
259
colleague
questions about the pending charge in March 2007' Spreadbury worked with a
260
held
that had similar experience and was granted a promotion. Spreadbury was being
26L
back at work due to the charge.
262
6E. The manager
of the regional employees based in Denver became very suspicious of
263
Spreadbury due to the charge. She specificatly asked why she should use Spreadbury in
2U
March 2007
265
aa
the regional office.
69. The suspicion within FEMA affected his employment, ability to get work, and the delay
266
brought by Ravatli County was not understood by regional FEMA officials. The Director
267
of Infrastructure repair in Denver asked when this charge would be resolved in June
268
2W7.
269
70. On
Spreadbury did not know how to arswer.
April I 1,2W7
Spreadbury wrote a recall petition for Sheriff Hoffman and County
270
Attorney Corn. County Clerk and Recorder Regina Plettenberg did not review recall
27L
petition for form. Petitions were sent to Flathead County Attorney Smith in Kalispell,
272
MT.
273
US Constitution was violated. Form of petition need only be substantially corect to pass
274
petition. Clerk Plettcnbcrg did not uphold Plaintiff right to petition government.
27s
276
7t.
Spreadbury's right to petition his government as prescribed in Amendment I of the
Spreadbury contacted Montana Attorney General office in
April, 2007 fot second time
about problem, hoping that intenention at higher level would resolve this issue.
74
case
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i2.
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Ravalli County Atorney
Kathy Seeleyo Assistant A$orney General attempted to contact
zrg
did r|ei lsswel Seeley's
Corn about issue. Corn gave criminal history of Spreadbury, and
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questions, or provide infcrrmation that was asked of him.
zgo
zst
pleascs in
73. Seeley stated that rhe County Attorney, Corn has'bide latitude" to do as he
a
May 16,2007 letter to Spreadbury.
ZsZ
74. Sceley dispAchcd the Deputy State Fire Marshall to 285 Cooper [-ane, Hamilton.
zs3
was
?5. Deputy State Fire Marshall visited the site on October 12,2006. Hs stated tbat there
284
285
z8E
definitely a fire violation to Sheriff Hoffman.
75. Deputy Fire Manhsll visited a second time to 285 Cooper I.n. and reportecl the continued
violation to Sheriff Hoffnran. Pallets remained in place tfuough April 2007.
zg7
7?. Sheriff Hoffman made policy decision to ignore stat€ fire codes, and took no action.
ZBg
78. Tdal was set for July 31, 2007. Spreadbury stayed home for (4) four months for trjal,
scr
zng
a retum
290
pending charge in Ravalli County, in violation of Spreadbury's state and federal rights'
trip mid-projects would not be necessary. A loss of income resulted in the
zgL
79. Motion to continue of July 3AZW7 by Corn and Futbright were utraware to Spreadbury.
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S0. Fulbright's motion was denied, Corn's motion was granted. Motions were to continue
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295
trial fium July
3
1,2W7 ad would violate Spreadbury'r right to speedy trial.
El. BrownleE contacted Spreadbury antt said a continuance was ordered, without a date set,
and no written date or continuance $hown to Sprcadbury.
15
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296
to South Dakota to
82. Spreadbury made himself available August 1,2007 and was deployed
297
approached
DR-1?02-SD. On August 8,2009 Federal Coordinating Officer Sanborne
298
had issued
Spreadbury and informed him he must go home immediately. Ravalli County
299
an arrsst wa11ant for contempt of court (found in title 3) which is not a crime,
300
Spreadbury retained Sasha Brownlec to represent hirn on the misdemeanor assault
301
charge.
302
303
83. Sasha Brownlee attempted u'rit of supervisory control, as well as a motion to dismiss'
Both were denied on August 8,2007 byJusticeBailey.
304
84. Judgc Bailcy denied a motion for speedy trial, siuce Spreadbury appeared lan7,2007 and
30s
trial was August 8, 2007. Brownlee determined that Spreadbury's right"s were not upheld'
306
Bailey also allowed evidence outside of discovery laws in Montana, spccifically the self
307
inflicted photograph of Linell, and all evidence submitted by law studcflt A. Wetzeon.
308
309
310
85. Angela Wetz.steon, a sscond year law student was a.rsigned to prosecute Spreadbury
without a Montana Bar License for trial date August 8, 2007.
86. Discgvery was allowed broken by Justice James Bailey, allowing a self-inflicted injury
311
photo of Linell of 289 Cooper Ln., and all other evidence for prosecution. Most cases
gLz
would be dismissed due to this fatal judicial error, but Defendants conspired against
3X3
Plaintiff.
314
315
8?. Spreadbury returned to Missoula Intemational Airport August
ll,?W . Mary Miller
informed him of three RCSO attempting a warant at 3am that morning'
15
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2
Filed 05/11/10 Page 17 of 49
316
assault' although
88. The Warrant mcntions that Sprcadhury must appcar for misdemeanor
3r7
Spreadbury was tricd in absentia on August 8,200?. Mcntion of Title 3 contempt
318
court was on the warant with TAG 0600104. Judge James Bailey issued and initialed
319
the area for day or night search, which is reserved for felony walTants.
320
89.
of
At 3am Augusr I1, 200? Deprrty Hochhalter, and Llnknown Ravalli county Deputies B,c
321
the
without escort by Hamilton Police Department (HPD); the law enforcement with
322
at
primary jurisdiction within the city of Hamilton, MT attempted to arrest Spreadbury
323
his new residence at 3
124
present.
325
326
g0. Mary
Miller informed
August
ll,2p7.
AM. A second attempt was made
a few days later
James Bailey that Spreadbury would not return
with HPD
until Saturday
The Ravalli County Shcriff displayed their intent to seize Spreadbury'
327
91. Spreadbury went shopping for attorneys due to Sasha Brownlee terminating the contract'
3?8
No attorney wanted to take the case. Finally, Spreadbury signed aretainer with Matt
329
St€venson, who interned with
330
to Defendants.
tip Ravalli County Attorney
as a
law student, well known
331
g2. Spreadbury had no idea that Steve.rrson would agree to the demand that Sprcadbur.v turn
332
himself in to something that was not a crirne, and effectively destroy his career with
333
FEMA.
334
335
93. Stevenson arranged with ttre bail bondsmau to "bosk and release" Spreadbury in the
Ravalli County Jail n'l am Augus 16, 2W7.
t7
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Page 1 B of 49
94. Stevenson also tipped off to the Ravalli County Sheriff Spreadbury's havel plan to
336
Hamilton, Montanaon August 16,2AO7 at6-7am.
337
95. Spreadbury traveled to Harnilton from Missoula starting at 6am August 16,2447. In less
338
(D sheriff
339
than 20 miles within Ravalli County, Spreadbury was confronted with five
340
deputy vehicles along the highway; agrtating traffic by passing large groups of south
341
bound vehicles. The RCSO was showing their matce to the plaintiff upon atfempt to
u2
comply with court.
343
96. Ravalli County Sheriff purposely attempted to aggravate and harass Spreadbury on August
u4
L6,2W. Aflsr five
345
County Sheriff vehicles within 20 miles along one srerch of highway, at any tinre .
346
97.
years of living in I'Iamilton, MT Spreadbury has ncvcr secn 5 Ravalli
Spreadbury and driver were fearful of their lives with this law enforceinent activity at 6am
347
to 7am on Auggst 16,zCffl, Actions of Sheriff were specifrc, hamssing, and intimidating
348
to Spreadbury. Spreadbury w:rs singled out and targeted by Ravalli Counry Sheriff Office.
34e
98.
co-signed the warrant with Deputy Cbris Albrigbt.
350
351
Sprcadbury was booked by Ravalli County on contempt charges on August L6,ZAU7 and
99.
Sprcadbury paid the $660 bond on $5000.00 bail. Spreadbury, with national security
352
clsarance, ownership of homc, no prior criminal history, for contempr of court for having a
3s3
licensed rctained aitorney appear in court on his behalf.
354
100. kt September,2007 Judge Reardon acquitted Spreadbury of the contempt charge, Prior to
355
the hearing, Reardon and Stevenson arrived together at the court building after conferring
3s6
with George Corn, in the Ravalli County Attorney Office (RCAO).
Case 9:10-cv-00049-DWM Document
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19 of 49
l0l' Matt $tevenson, after being paid a hefty retainer fee, wrote a motion for dismissal on
3s8
359
360
November 26,20[7, more than th.ree months after the trial in absentia on August 8, 2007.
102. Spreadbury hand wrote a letter
to Stevenson asking for quick resolution of charges on
August 23,2087.
361
l03.The Ravalli Rqubfc pubtiskd that Spreadbury was arrasted in the Sheriff blottcr on page 3
362
of the $eptember 12,2W7 edition. No charge designation was given in that publication.
363
Further, on September 10,2009 The Ravalli Republic published in a front page story that
364
Spreadbury was convictred of assault whea the rnatter had been dismissed by District Judge
365
Langton. In a February 19, 2010 front page article, The Ravalli Republic published for a
366
third time, and for a second time within a front page article that Spreadbury was convicted
367
of assault although the matter was dismissed due to
368
to July 13, 2009 the Ravalli Republic published Spreadbury'u conviction for the 2007
369
assault in two independent online commcnts at www.RavalliReopblig.gom. A July 13, 2009
370
lctter to Ms, Shcrri CulTan, L,ee Enterprise Corporatc Auorney, Spreadbury mentioned these
37r
publications. The Republic cortinued to defanre Spreadbury even when notification of
372
publication errors was brought to the attention of this defendant. The notification only
?73
intensified defarnation, and Newspaper defendant is aoting with malice, and collaborated
374
with othcr Defendants. On May 10, 2010 a front page article included the ?007 information.
375
376
7m
Amendment
dght. tn the week prior
10f. In September, 2007 Spreadbury was awarded Exernplary Sewice which few in FEMA
awarded
with. Ravalli County robbed Spreadbury of a decorated
19
career due to malice.
are
Case 9:10-cv-00049-DWM Document
377
105. Spreadbury was terminated
2
Filed 0511 1/1 0 Page 20 of 49
from FEMA in November ,2W7 due to time sheet irregularity.
378
Spreadbury's supervisor signed off on his timesheets. FEMA did not want to deal with
379
waiting for charge to be resolved in Ravalli County after more thzrn 12 months.
380
106. Judge Langton, ordered a dismissal of the misdemeanor assault charge due to speedy trial
381
provisions on January 3, 2008. From time of incident to dismissal took 16 months.
382
107.The delay in bringing Spreadbury to trial, the unequal treatment, and deprivation of due
383
process along the way led to actual damages, and deprivation of Spreadbury's rights.
Charees
384
Negligenc+Count
I
386
108. Spreadbury repeats and realleges paragraphs 1-107 of this complaint as if fully set herein.
387
109. County Attomey Corn, acting in his individual and official administrative duties assigned
388
Angela Wetzeon, a law student without a Bar License to prosecute Spreadbury's case.
389
110. Even if Corn did not direct Angela Wetzsteon to prosecute Spreadbury's case, as a head
390
391
manager of the office, Corn knew of should have known of Wetzeon's duties.
1l
392
393
Corn's actions constituted negligence as an administrator in the Ravalli County Attorney
Office (RCAO) in Hamilton, MT.
112. As a result of the Corn's negligence, Spreadbury suffered actual damages.
Negfigent Supervision and Training-Count 2
394
395
l.
1
13. Spreadbury repeats and realleges paragraphs l-1 12 of this complaint as if fully set herein.
20
Case 9:10-cv-00049-DWM Document
396
I 14. County Attorney Corn
2
Filed 05/11110 Page 21 of 49
in his administrative duties showed malice by assigning Wetzsteon
397
to prosecute Spreadbury when Defendant was not fully trained, licensed, or supervised to
398
do so. Wetzsteon could not carry out proper conduct in court, compiling case against
399
Spreadbury, adhering to court deadlines, or properly submitting evidence to the court.
400
401
402
115. As a result, the county did not prosecute in "good faith" against Spreadbury, and
Spreadbury suffered actual harm.
I 16. Due to negligent supervision of Angela Wetzsteon, Spreadbury suffered actual damages.
Abuse of hocess---Count 3
4O4
I 17. Spreadbury repeats and realleges paragraphs
l-l
16 of this complaint as
if fully
set herein.
405 ll8. Angela Wetzsteon commenced a criminal proceeding against Spreadbury with an ulterior
406
407
408
purpose of harming Spreadbury.
119. The proceeding was a willful acl on the part of the Wetzstfon, but not proper in the in the
regular conduct ofthe proceeding due to:
409
a.
A non-licensed attorney prosecuted the proceeding against Spreadbury
410
b.
Spreadbury's state constitutional right to protect property was not upheld
4:-l
c.
Physical evidence at the scene, and protected speech from Spreadbury which
4t2
413
4t4
would have exculpated Spreadbury were excluded from the trial.
120. Due to Wetzsteon's abuse of process, Spreadbury suffered actual damages.
Violation of Equal hotection/Amendment XIV--Count 4
z!
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2
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1/1
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Paqe 22 of 49
415 l2l. Spreadbuy repeats and realleges paragraphs l-1.2O of this complaint as if fully set herein.
416 122, As Counry Attorney Com assigns unlicensed attorney to pros€cute Spreadbury, rhis set$
municipal policy due to Com being the final policy maker in ths Ravalli County AttomCIy
417
418
Office ECAO).
419
I23, Corn
42O
124. Spreadhury suffered by this municipal policy due to not being offered equal protcction in
421
4zz
427
424
made this decision as an adminisuaror of the RCAO.
tte criminal process in Ravalli Counry.
125. Due to this municipal policy, whichviolated Sprcadbury's 14fr Amendment rights to equal
protection, Spreadbury suffered actual damages.
Negligence--Count 5
425
126. Sprcadbury repeats and realleges paragraphs 1-125 of this complaint as if fully set hercin.
426
127. Bill Fulbright, RCAO acting in his administrative duties, had knowledge of, or reassigned
427
Angela Weucon to prosecute Spreadbury.
428
128. On August 8,200? Angela'Wetzsteon was not licensed in Montana to practice law.
429
129. As a result of Fulbright's negligence with respect to assigning a student to prosecute a casc
430
after Fulbright was assigned, Spreadbury suffered actual damages.
Equal Protection violation/Amendment XIV--Count 6
432
130. Spreadbury repeats and realleges paragraphs
22
I - 129
of this complaint as if fitlly
se
t herein.
Gase 9:10-cv-00049-DWM Document
433
13l. Bill Fulbright, RCAO
2
Filed
05/11l10 Page 23 of 49
acting in his administrative capability making conversation with
434
Spreadbury's initial attorney indicated that
435
charges would be dropped."
436
"If
this were any person besides Spreadbury, the
132. Due to Bill Fulbright's comment to Spreadbury's initial attomey Sasha Brownlee, it
437
showed that the RCAO is acting with malice to prosecute Spreadbury outside of his right to
438
equal protection under the law as is prcscribed in the 146 Amendment to the US
439
Constitution.
MO
Mt
133. Due to equal protection violation by Fulbright while conducting administrative duties,
Spreadbury accrued actual damages.
Iqiunctive relief sought RCAO-Count 7
443
134. Spreadbury repeats and realleges paragraphs
4M
135. Bill Fulbright, and George Corn with full knowledge of his actions did write a motion to
I-
133 of this complaint as
if fully set herein.
445
continue trial beyond 6 months, and in bad faith prosecute Spreadbury lu:2007.
446
136. Bill Fulbright and Gcorge Corn did knowingly and intentionally violate the rights of
447
Spreadbury to his 7fr Amendment right to speedy trial, and equal protection l4thAmend.
48
137. hlbright acted with malice due to knowing that no evidence was prepared nor presented
49
for discovery by the RCAO; tampered evidence was knowingly used against Spreadbury.
450
451
138. In the July 3O,2OUI motion, one day prior to trial, Fulbright states that the "victim" Ms.
Linell was out of town.
23
Case 9:10-cv-00049-DWM Document
4s2
2
Filed 05/11/10 Page24 of 49
139. RCAO did ask Judge Bailey for discovery outside of tlre deadlines set by the court which
453
were granted. Due to the malice arrd cooperation required with ths Judge, County Sheriff
454
to deprive the Plaintiff s rights, injunctive relief is being sought from the District Court.
455
140. This issue is a ca.se, and controversy, and the RCAO has initiated more action against the
4s6
Plaintiff, and has more than reasonable belief it will continue in the firturc
457
Court intervention through permanent injunctive relief is grantcd.
458
I41. Injunctive rclief will benEfit the Plaintiff, and Plaintiff has standing for
unl.ess Federal
these r€asons:
459
Plaintiff
460
Plaintiff is in "efitraordinary circumstans&!"'exception which would enjoin into ongoing
46L
stale proceedings due to bad faith prosecution, harassment, and indepcndent violation
462
Plaintiffs protected speech, and peaceful assembly under the l*t Arnendment. Defendants
463
are retaliating against
4U
tribunal bias" exists for
465
Judge made false allegations and is being protected by SUte ludges. The extent of the state
466
tribunal bias is to the Chairman of the Montana Judicial Standands Comnission.
467
ha.s
current controveriy or case and grounded belief of fuaue harm by RCAO.
Plaintiff s exercise of constitutional rights. Further,
of
a "manifest state
Plaintiff Piaintiff sought public office; ex-wife of cufitnt State
Iduncdvc reltef--Justice Bailey, Ravalli County Justlce Corrt...Count
t
468
142. Spreadbury repeats and reallcges paragraphs 1-141 of this complaint as if fully set herein.
469
143. Justice Bailey allowed a non licensed attorney to practice law in his court. This fact was
470
brought up by Defense attorney Brownlee prior to Aug 8, 2007 trial.
24
Case 9:10-cv-00049-DWM Document
471
2
Filed 05111/10 Page 25 of 49
144. Justice Bailey insisted that Plaintiff was "arrested" prior to making an appearance in his
472
court. The insistence and cooperation by the Defendants was terminal to Plaintiffs career
473
with FEMA.
474
145. Justice Bailey wrote an arrest warrant for contempt of court, when an attorney was prEsent
475
on behalf of Spreadbury. It falsely stated thar "the Defendant (Spreadbury) must stand trial
476
for misdemeanor assault", when Spreadbwy was tried in absentia.
477
146. Further, Justice Bailey initialed the area where law enforcement could execute this warrant
day or night, something not allowed formisdemeanor warrants. This is an act of malice.
478
479
147
.
148. Bailey also denied a motion for
former police officer and knew what he
7th
Amendment speedy trail when time expired for this case
clearly violated Spreadbury' s rights.
482
483
a
was doing in initialing the order to have Spreadbury seized at night.
480
48t
It is an act of malice due to Justice Bailey being
149. To allow evidence at such a late date (day of trial) outside of discovery also shows malice
intent ofjudiciary.
484
150. To continue a trial to catch Spreadbury out of state was act of malice.
486
15l.
The cooperation of the RCAO, RCSO, and judiciaryin Ravalli Countyis something that
487
the Spreadbury is in jeopardy of having future constitutional violations create harm.
488
152. Due to the application of article III of the US Constitution, the likelihood of future issues
489
with the Defendants make this claim for permanent injunctive relief by the Plaintiff have
490
standing with this court.
25
Case 9:10-cv-00049-DWM Document
2
Filed 05/11l10 Page 26 of 49
49L
153. The Plaintiffbelieves the judiciary of Ravalli County will act will malice in the future.
492
Plaintiff has standing due to current case or contioveny and belief of future harm.
Negligence-Count 9
493
494
495
496
154. Spreadbury repeats and realleges paragraphs l- 153 of this complaint as if fully set forth
herein.
155. Angela Wetzsteon, a law student acting under the color of law, and in her individual
497
capacities did prosecute a criminal case against Spreadbury.
498
156. Wetzsteon was not employed by the RCAO as a prosecutor.
499
157. For prosecuting a case without proper licensure, oath of conduct, Wetzsteon was negligent
500
501
in her actions for the RCAO.
158. Due to negligence by the student assigned to be prosecutor, Spreadbury suffered darnages.
Fraud/Misrepresentation-Count
503
504
505
506
507
508
10
159. Spreadbury repeats and realleges pamgraphs 1-l5E of this complaint as if fully set fonh
herein.
160. Angela Wetzsteon, in representing herself as a prosecutor defrauded Spreadbury the rights,
ethics, and protections that a fully qualified prosecutor could provide.
161. Wetzsteon violated the Montana Bar Association code of ethics for representing a fully
licensed attomev.
26
Case 9:10-cv-00049-DWM Document
2
Filed 05/11/10 Page 27 of 49
509 162. Action of Defendants allowing Wetzeon to de&aud tlr court and misrepresent her legal
510
status dcprived Sprcadbury a fair trial and other common law pnotcctions.
511 163. Due to the &aud and misrcpresentation by Wetzsteon, Spreadbury suffered actual damagcs.
Sreacb of ContrncUMisreprmentatlon--Curnt
512
513
514
515
515
517
519
519
Ll
164. Spreadbury repeats and rcallcges paragraphs l-163 of this complaint as if fully set forth
herein.
165. Matt Stevenson was retaincd by Spreadbury to defcnd him with rEspect to a misdemeanor
assault in August 2007.
166. Sterenson did not prcvent the seizure of Spreadbury for a civil contempt charge which is
not a crime.
167. Stevenson did not object to Ravalli CountySheriff Deputies attempting to seize Spreadbury
5f0
at 3am August 11,2W7 on a fictitious misdemeanor warrant which cannot be executed in
521
the middle of the night" Spreadbury lives in the city of Haarilton who had primary
522
jurisdiction and Hamilton Police were not present at warrant execution.
523
168. Stevenson delayed requesting dismissal of TK-06-3068 (misdemeanor assault) against
524
Spreadbury for approximately 3 months. Motion for dismissal was tEceived by Ravalli
525
Counry District Court on November 26,2007.
526
527
169. Stevenson did not object to the delay by Justice l-angton who issued an order on January 3,
20S to dismiss TI(-06-3068 on grounds of epeedy trial.
27
Case 9:10-cv-00049-DWM Document
528
2
Filed 05/1 1/1
0
Paqe 28 of 49
170. Stevenson acted in color of state law duc to collusion with Ravalli County Attomey in
529
obtaining Spreadbury's arrest, which was objective of Defendants,
530 l7l.
Stevenson was in collusion with Iudge Reardon, who walked from Corn's office prior to
531
the hearing regarding contempt in Reardon's municipal courL
532
172. For misrepresenting services as defense attorney, Sprcadbury was harrred.
533
173. For allowing Spreadbury to be arrested for something that is not a crime, Steverrson
534
misrepresantd his senices to Spreadbury and caused actual damages.
Abuse of hocess---Count
535
537
538
539
540
541
542
543
544
545
546
1.2
174. Spreadbury repeats and realleges paragraphs l-173 of this complaint as if fully set forth
hcrein.
175. Sheritr Chris Hoffman acting under the color of law and in his individual capabilities did
overs€e the Ravalli County Sheriff Office (RCSO) in 20O6 through 2008.
176. The RCSO did act in callous indifference to Spreadbury in invcstigating case #06070243
against
lany
Robinson of 289 Cooper Lane Hamilton, MT.
177. The RCSO was willful in investigating Spreadburl, and flnding and fabricating evidence
against Spreadbury which was improper.
178. The investigation was willftrl in the use of process, not propcr in the regular conduct of the
investigation of Sp'readbury.
179. Due to Sheriff Chris Hoffman's abuse of process, Spreadbury has incurred damagcs.
Case 9:10-cv-00049-DWM Document
2
Filed 05/11/10 Page 29 at 49
l{egligence--Couot 13
547
54E
180. Sprcadbury repeats and realleges paragraphs 1-1?9 of this complaint as if fully set herein.
549
181. Sheriff Chris Hoffman, in colorof law and in his individual capacities did make policy by
550
rejecting suggestions of Montana Deputy State Fire Marshall Dick Larson with respect to
551
Spreadbury complaint. Hoffinan did
552
182. Hofftnan is policymaker as head of RCSO.
553
183" By making new policy, HotTman acted negligently towards Spreadbury.
554
184. As a result of this negligence by Hoffrnan, Spreadbury suffered actual dnrnages.
noC
uphold State Fire Laws.
1'r Amendment
556
Vlolation--Count
1.4
185. Spreadbury rcpcats and realleges Paragraphs I-184 of this complaint as if fully set fotth
557
herein.
558
186. Depury Albright, under the color of [aw, and in his individual capabilities did manipulate
559
his cornrnunication unit to alter the transcript of the conversation wjth Spreadbury on
560
October 10.2006.
561
187. Deputy Albright r*as following custom of law enforcement to swivel a knob on a hand held
562
communication dcvice which records a susDsct's communication in a law cnforcement
563
situation.
564
565
I88.
The practice of ranscript rranipulation by swivcling a knob on a law enforcement device
was
@artment wide, andprevalent in it's application wirhin
?9
the RCSO.
Case 9:10-cv-00049-DWM Document
566
2
Filed 05/1
1/1
0
Page 30 of 49
189. The transcript used in trial was altered from true speech by Spreadbury. Protecting
567
Property, and warning Linell twice prior to engaging neighbor by Spreadbury was missing.
568
This exculpatory evidence went missing, and was witnessed by Mary Miller of 291Cooper
569
Lane, Hamilton, MT on October 10, 2006.
570
571
190. Deputy Albright, and RCSO showed malice in practicing custom of altering speech of
Spreadbury to assist Defendants to convict Spreadbury of misdemeanor assault.
572
191. Practiceof custombyRCSOdeprivedSpreadburyof freedomof speechasprotectedin l*t
573
Amendment to the US Constitution. Spreadbury suffered actual damages as a result.
Equal hotection violation/Amendment XfV--Count 15
574
575
576
577
578
579
192. Spreadbury ropeats and realleges Paragraphs 1-191 of this complaint as if fully set forth
herein.
193. Under the Color of Law, Deputy Albright did not offer Spreadbury equal protection in
processing the crime scene at 285 Cooper Lane, Hamilton on October 10, 2006,
194. By allowing Linell freedom from violating a verbai order from RCSO five hours earlier,
580
the proximity of two smoke grenades, use of foul language with Deputies, and intoxication,
581
Deputy Albright did not offer equal protection to Spreadbury.
582
583
584
585
195. Deputy Albright demonstrated indifference towards Spreadbury in not affording equal
protection to Spreadbury on October 10, 2006. As a result, Spreadbury suffered damages.
Fraud/Misrepresentation- -Countl6
196. Spreadbury repeats and realleges paragraphs 1-195 of this complaint
30
as
if fully set herein.
Case 9:10-cv-00049-DWM Document
586
587
2
Filed
05/11l10 Page 31 of 49
197. Deputy Albright acting under color of law did misrepresent his duties as a sheriff deputy on
October 10,2006.
588
198. Deputy Albright did alter a taped convenation with Spreadbury
589
199. Deputy Albright did alter the collection of evidence to implicate Spreadbury.
590
200. Deputy Albright did alter the actual course of events to implicate Spreadbury.
591
201. Deputy did give indications that he was conducting
592
a proper investigation
of the incident at
285 CooperLane Hamilton, MT on October 10,2006.
593
202. Deputy Albright did not take into consideration of case ffi607}2$ in favor of Spreadbury.
594
203, Deputy Albright misrepresented his role
595
596
597
598
599
as a
Sheriff Deputy to impartially investigate
criminal incidents in Ravalli County Montana on October 10, 2006.
204. Deputy Albright conducted an intentional deprivation of Spreadbury's rights in his conduct
at2S5CooperLaneonOctober 10,2006.
205. As
a result
of the deliberate conduct to misrepresent facts, Deputy Albright harmed
Spreadbury, this misrepresentation caused Spreadbury actual damages.
Fraud/Misrepresentation--Charge 17
601
206, Spreadbury repeats and realleges paragraphs 1-205 of this cornplaint
as
if fully set forth
602
herein.
503
Deputy Hudson did misrepresent his duties as a Sheriff deputy on October 10, 2006.
31
Case 9:10-cv-00049-DWM Document
604
207. Deputy Hudson did misrepre$ent
605
606
a situation
2
Filed 05/1 1/1
0
Page 32 of 49
with a photograph to implicate Spreadbury for
misdemcanor assault.
208. Depury Hudson documentcd e vidence that wa.s a misrepresentation of actual facts' Linell,
W7
of 289 Cooper Lane did defraud Spreadbury by scratching her own face on October 10,
608
2006.
609
209. This evidence was used in a court of law to implicate Spreadbury.
610
210. The intentional misrepr*entation by Depury Hudson caused Sprcadbury actual danages'
Improper Selzure AfrempU 4e Anrendment-Curnt 18
611
612
211. Spreadbury repests and reallegss paragraphs 1-210 of this complaint
613
6L4
as
if fully
set
forth
herein.
212, Ravalli County Deputy Hoehhalter, under the color of lawn did attcmpt to seize Sprcadbury
615
at Q3ffihours at Plaintiff.s residence in Hamilton on August
616
warrant for Title 3 of the Montana Code Annotated (MCA).
l.l,
2007 with a contempt
6t7
213. Title 3 of the MCA does notcontain crimes.
618
214. A misdemeanor warrant cannot be executed in the middle of the night at 3 AI4.
619
215. The Harrilton Police Dcpartment ([PD) was not assisting the RCSO in this seizure attempt
620
621
although the HPD have original jurisdiction-
216. As a result of anempts by Deputy Hmhhalterto scize Spreadbury in violation of Montana
6?;2
Law, law enforcement practicg judicial standards, and written text on warrant with ?AG
32
Case 9:10-cv-00049-DWM Document
2
Filed 05/11l10 Page 33 of 49
623
06100104 dared U8f2007 and issued byJustice Bailey, it violated Spreadbury's fourth
624
amendmentright ro be secure against unreasonable seizures by government officials-
2l?.
526
2
Paragraph 216 shows an acnral malice shown towards Sprcadburyby Deputy Hochhalter'
18. As a result of an attempt to seize Spreadbury by Depury Hochhalter, the action violated
627
Spreadbury's right to renain &w of being seired by law enforcement officials as conlained
628
in the40 Amen&nent to the United States Constitution-
629
630
219. Spreadbury suffered acrual clamages
633
634
635
636
637
638
639
of tlre improper seizure ettemPt on August
Ll, 2W1 by Deputy Hoctrhalter.
Negfigence-.Count 19
631
632
as a result
220. Spreadbury repeats and realleges paragraphs l-220 of this complaint
as
if fully
set forth
herein.
221. Deputy Hocbbalter under the color of law, acted with malice in executing
when
it
a warrant at 3am
was for contempt of court, a civil code in Montana, or a misdemeanor at worst.
222. Hoctrbalter acted with negligence when he knew, or should have known that Title 3
warrants are not acrirne, snd misdemeanor warrants are not served day or night.
223. As a result of the negligence cxhitrited by Deputy Hochhalter, Spreadbury sufferd actual
damages.
640
641
33
Case 9:10-cv-00049-DWM Document
224. Spreadbury repeats and realleges paragraphs I to 223 of this complaint
544
645
against Spreadbury on August
226. Theexecution
652
653
lL,zffi7 with
an ulterior purpose.
as described in paragraph 225 was a
willful
act in the use of process not
prcper in the regular conduct of warant execution.
227.
D4te to the Defendant abuse
of process, Spreadbury has incurred danages.
Improlrcr Seizure AttempU 4fi Amendment-Count 21
650
651
if fully sst forth
225. Deputy Hochhalter under the color of law, commenced an execution of an arrest warrant
648
Ug
as
within.
640
647
Filed 05/11/10 Page 34 of 49
Abuse of Process"'Count 20
642
643
2
228. Spreadbuy repeats and realleges paragraphs l-227 of this complaint
as
if fully
set forth
herein.
229. Unknown Ravalli County Deputy B, under the color of law, did attempt to seize
654
Spreadbury at 0300hours at Plaintiff
655
contempt walrant for Title 3 of the Montana Code Annotated (MCA).
s residence
in Hamilton on August 71,2Co7 with a
656
230. Title 3 of the MCA does not contain crimes.
6s7
237. A misdemeanor warrant cannot be executed in the middle of the night at 3 AI\'1.
658
232. TheHamilton Police Department
659
(IfD)
was not assisting the RCSO in this seizure attempt
although the IIPD have original jurisdiction.
34
Case 9:10-cv-0004g-DWM Document
660
2
Filed 05/'11l10 Page 35 of 49
Montana
233. As a result of attempts by Unknown Deputy B to seiz,e Spreadbury in violation of
661
662
663
with TAG
Law, law enforcement practice' judicial standards' ard wtitten text on wrrant
06100104 dated 8/E/200? and issued by Justice Bailey, it violated Spreadbury's fourth
amendrnent right to be secure against unreasonable scizures by government officials.
6@
234. Paragraph 233 shows an actual rnalice shown towards Spreadbury by Unknown Deputy E'
E6s
235. As a result of an attempt to seize Spreadbury by Unknown Deputy B, the action violated
666
667
668
669
Spreadbury's right to remain free of being seized by law enfsrcement officials as contained
in ttre 4tr Arneadment to the United States Constitution-
236. Spredbury suffered actual dauages as a result of the improper seizure altempt on August
11, 200? by Unknown Deputy C.
Negfigence--Count 22
670
671 23?, Spreadbury repeats and realleges paragraphs l-236 of this complaint as if fully $et fonh
67?
herein.
67t
238. Unknown Deputy B uuder the color of law acted with malice in executing a warrant at 3am
674
when it was for contempt of court, a civil code in Montana, or a misdemeanor at worst,
67s
676
677
678
679
239. Ur*nown Deputy B acted with negligence when he knew, or should have known that Title
3 wanants are not a crime, snd misdemeanor warrants ar€ not served day or niglU.
240. As
a result
damages.
of the negligence exhibiled by Unknown Deputy B, Spreadbury srdfered actual
case 9:10-cv-00049-DWM Document
2
Filed 05/11/10 Page 36 of 49
Abuse of Procrss'-Count 23
681
682
6g3
684
6g5
686
GB7
241. Spreadbury repeats and reallcges paragraphs
690
691
of ttris complaint as if fully set forth
hercin,
242, Unknown Deputy B under the color of law did commence an execution of an affest warrant
against $preadhury on August
243. Theexecurion
as
I1,2W7 with an ulterior purpose.
described in paragraph ?AZwas a willful act in tho use of process
nd
prcper in rhe rcgular condrct of execution'
244. Due to ttre Defendant atruse of process, Spreadbury has incuned actual damages'
Improper $eizurt AtternpU 4s Amendment-Count 24
688
689
1 to 240
245. Spreadbury repeats and realleges paragraphs l-244 of this complaint
as
if fully set forth
herein.
246. Unknown Ravalli County Deputy C, under the color of law, did attempt to seize'
692
Spreadbury at O300hours at Plaintiffresidence in Hamilton on August
693
lI,zW'l
tvith a
conternpt warrant for Title 3 of the Montana Codc Annotat d (MCA).
694
2a7. Title 3 of thc MCA does not contain crimes.
695
248. A misdemeanor warrant cannot be cxecuted in the middle of the night at 3 AM.
696
249. TheHamilton Police Departmcnt
697
(IfD)
was not assisting the RCSO in this seizure attempt
although the HPD harrc original jurisdiction.
36
Case 9:10-cv-00049-DWM Document
698
250. As
a result of attempts
2
Filed 0511 1/1
0
Page 37 of 49
by Unknown Deputy C to seize Spreadbury in violation of Montana
699
Law, law enforccment practice, judicial standards, and written text on wafiant with TAG
7oo
06100104 deted 8/E/2007 and issued by Jusrice Bailcy, it violated Spreadbury's fourth
7oL
arnendment right to be secure against unreasonable seizures by government officials.
7OZ
251. Paragraph 250 shows an actual malice shown towards Spradbury by Unknown Deprty C-
7O3
?52. As
a result
af an attempt lo seize Spreadbury by Unknown Dcputy C, the action violated
7u
Spreadbury's right to remain free of being seized by law enforccnrcnt officials as contained
7os
in the 4tr Ampndapnt to the United States Constitution.
7OG 253. Spreadbury
7O7
ll,zW
suffered rc.hral damages as a rcsult of tte improper scizure attemg on August
by Unknown Deputy C.
Negligence-..Count 24
709
7tO
7LL
7t2
7L3
7I4
7t5
7t6
717
254. Spreadbury repeats and realleges paragraphs 1-253 of this complaint as if futly
set forth
herein.
255. Unknown Deputy C under the color of law acterl with malice in exccuting
a warrart at 3am
whcn it was for contcmpt of court, a civil code in Montana,
256. Unknown Deputy C acted with negligence when he knew, or $hould have known that Title
3 wartants arc not a crime, and misdemeanor warrant$ are not scrved day or night.
257, As a result of the negligence exhibited by Unknown Deputy C, Spreadbury suffered actual
damages.
Case 9:10-cv-00049-DWM Document
7t8
2
Filed 05/11/10 Page 38 of 49
Abuse of hrocess--Count 25
719
258. Spreadbury
72O
within.
721
repea0s and rcalleges paragraphs
against Spreadbury on August
723 260. The execution a.s described
725
728
729
730
ll,2W
with an ulterior pupose.
in paragraph 259 was a willful act in the use of process not
prcper in the regular conduct of cxecution.
261,. Due to Unknowtr Deputy C abuse of process, Spleadbury has incurred damages.
716
727
to 25? of this cornplaint as if fully set forth
259. Unknown Deputy C under the color of law commenced an executioa of an arrest warrant
727.
724
I
Dofamafion and Ilefamation Per Ss-Count 26
262. Spreadbury repeats and realleges paragraphs I-261 of this cornplaint as if fully sst forth
herein.
263. Defendants provided false and unprivilegsd information to thp Ravalli Republic Newspaper
in Hamilton,
MI
falsely ltathg that Spreadbury had been arrested with due causa.
731
264. The continued publication of this information constituted defamation pet se.
732
265. The continrred publication of the anrst caused defarnation of Spreadbury.
733
266. As a result of the multiple instances of defamation, and dcfamation per se by The Ravalli
734
Republic, Spreadbury suffcrcd actual damages.
735
736
38
Case 9:10-cv-00049-DWM Document
739
740
741
742
743
Filed
05/11l10 Paqe 39 of 4g
Negligencr..-Counl 27
717
738
2
267. Spreadbury repeats and realleges paragraphs 1-266 of this complaint as if fully sst forth
herein.
268. Thc Ravatli Republic Newspaper did publish that Spreadbury was arrested wheir Title 3 of
the Montana Code does not contain crimes.
269. The Ravalli Republic Newspaper knew or should have known that Spreadbury was tried on
August
8,2ffi7
and thus did nct need to *face trial for misdemeanor assault".
744 270. Witb respect to conduct, by the Ravalli Republic contained in paragraphs 268 and 269, this
745
746
747
748
can be constnred as mulriple instaoces of rre.gl.igence with malice intent
271. The Ravalli Republic Newspaper acted in color of state law by assisting the Defendants
obtain their goal of Spreadbury's arrest by publishing that information multiple timcs.
272. As a result of negJigence by the Ravalli Republic, Spreadbury has suffered damages.
749
750
751
752
753
Grcss Misconduct/Ir{egligence Count 2E
273. Spreadbury repeals and realleps paragraphs I-272 of this complaint as if fully set forth
herein.
274. The Ravalli Republic Newspaper did publish false information five (5) times
subscribcd
in[
as is
103.
754 275. Pubtication of information this is known or should have been known to be false is gross
755
misconduct and negligence, and evidence of malice intent.
.
Case 9:10-cv-00049-DWM Document
2
Filed 05/11110 Page 40 of 49
7sE 276' As a result of the gross misconduct by th Ravalli Republic, Spreadbury
757
damages.
758
759
760
761
762
763
764
suffered actual
Abuse of
hocs-{ount 29
277. Spreadbury repeats and realleges paragraphs 1-2?6 of this complaint as if fully ser fortb
herein.
278. SAFE of the Bitterroot commenced a prooeeding against Spreadbury with an ulterior
purpose.
279. The proceeding wac a willful act in the use of process not proper in the regular cnnduct of
the proceeding.
765 280. SAFE of the Bitterroot acted in color of state law by speaking on bchalf of the RCAO.
766 281, SAFEof the BittcrrootcontactedSpreadburyastheperpetratoragainstLincllin
767 282, Due to SAFE of the Bitterroot's
769 283. Spreadbury repeats and rcalleges
77L
772
of process, Spreadbury suffered actual damages.
Negligence Per
768
770
abuse
10/2006.
SpCount
30
paragraphs l -282 of this complaint as
if t'ully set forth
tprein.
2&{. The RCSO failed to prot€ct Spreadbury
as a uurpayer, and resident
of Ravalli County,
Montana.
773 285. Law eaforcement is there to protect people from halm, dangers, and crirne.
40
Case 9:10-cv-00049-DWM Docurnent
2
Filed 05/11110 page 41 of 4g
774 286. Spreadbury made good faith effort to infonn the RCSO of dangers from pallet operarion,
775
and activities that endangercd Sprcadbury by personncl who
rcsi& at 289 Cooper Lane.
n6
287. Rsvalli County tailed to prdect Spreadbury from harm.
777
288. As
a rpsult
of this failure, RCSO canstirurional deprivarions constitu0ed negligence per se.
778
289. As
a result
of RCSO negligcnce por se, spreadbury had acnral damages.
NcgHgeace Per Se--Count
780
781
782
783
7U
785
3I
290, Spreadbury repeats and rcallegcs paragraphs l-289 of this complainr
as
if fully
set
forth
herein.
291. The RCAO failed to protect Spreadbury as a trD(payer, and rcsident of Ravatli County,
Montana.
292. h county attorney office is there to prosecute persons who violate the law, not those who
follow it, and provide information for the betterment of tbe comrnunity.
786
293. The county attomcy office is paid for by fiupayers to protect them not victimize them.
787
294. The RCAO violations of common law, ethics, and properconduct damaged Spreadbury.
788
295. As a result of the RCAO intcntional deprivations, and negligence psr se, Sprcadbury
7Eg
suffered actual darnnges.
Malidous Procecutfun/Anrerdntent IV--Count 32
790
7gt
792
296. Spreadbury rep€ats and realleges paragraphs l-295 of this complaint as if fully set forth
herein.
4t
Case 9:10-cv-00049-DWM Document
2
Filed 05/11l10 Page 42 of 49
793
297. A judicial preeeding was commenced and prosecuted against Spreadbury.
794
298. Defendants were responsible for instigating, prosecuting, and/or conrinuing the proceeding.
795
299, The Defendants acred with malice towards Spreadbury.
796
3ffi.
797
301. The judicial proceedings terminated favorably for Spreadbury in 200? and 2008.
798
302. As a result of the Dcfendants actions, Spreadbury suffered rchral damages.
The Defendants acted without probable cause.
Nqligence--Count 33
8m
801
802
803
804
805
806
807
808
809
810
811
303. Spreadbuxy repeats and reallegrs paragraphs I -302 of this cornplaint as if fully set forth
herein.
3Ot. Deputy Culgan did not take information that Spreadbury or Miller presented to him to
protect eit[erparty.
305. Miller gave information about harassment from Linell, and the pallct danger to her
household at29l Cooper [.ane.
306. Spreadbury showed Culgan photographs of the tue dangcr which gained the responsc of
'bt1 wow" and yet did not take action on Spreadbury's behalf.
307. Spreadbury told Culgan that Miller was too at'raid to sleep in the residence at 291 Cooper
Ln and he would be gone for an extended perid of time. Culgan refused to take action.
308. Spreadbury asked for
a Sheriffcase to be opened concerning the threats, the smoke
intu.sion into the residence, and the fire hazard. Culgan rcfused.
42
case
9:1
0-cv-00049-DWM Document
2
Fited 05/1 1/1
0
page 43 of 49
812
309. With the infonnation that Spreadbury could ask the US Attomey for assisrance due to
813
being deployed as a federal officer, Culgan rhen relented and opened case+1060?0243.
814
310. Under the color of law, Deputy Culgan's actions constituted negligence.
815 3 t 1, fu a result of the ne$igence fiom Depury Culgan, Spreadbury
suffered actual damages.
Abuse of h,ocess--Count 33
817
312. Sprcadbury repeais and realleges paragraphs 1-311 of this complaint
818
as
if fully
set forth
herein.
819
313. County Clerk Regina Plettenberg, under the color of law commenced a recall p€tition
820
analysis for Spreadbury with an ulterior objective. Defendants subject to recall
821
wcrc prcsented to Plettenberg.
822
making analysis of Recall Petitions
3
prescribed by Montana Law.
Equal Protection/Amendment XIY
{ount
316. Spreadbury repeats and realleges paragraphs 1-3l5of this complaint
827
828
as
15. Due to Ms. Plettenbe rg's abuse of process, Spreadbury has incune d actual damagcs.
825
B?g
?0
314. Thc analysis was a willful act in the use of process of not proper in the regular conduct of
823
824
inl
35
as
if fully
set forth
hcrein.
3l?.
Rcgina Pletrenberg, under color of law, did treat Sp'readbury outside
tle guidelines of The
829
Montana Recall Act wlren making analysis of petitions trled against Defcndants George
830
Conr, and Cbris Hoffrnan on or around
April I l,
2.007.
Case 9:10-cv-00049-DWM Document
2
Filed 05/11l10 Page 44 of 49
831
318. Recall petitions must be substantially similar to form, but not exact.
832
319. Plettenberg did not check the form of Spreadbury's petitions.
833
320. Plettenberg sent petitions to Flathead County Deputy Attorney Smith for legal review.
834
321. Le,gal review is reserved for completed petitions, prior to placement on ballot for Recall of
835
s36
837
838
public officials. Clerk Plettenberg was directed by the RCAO Defendants about petitions.
322. Plettenberg treated petitions differently, which violates Spreadbury's right to l4d'
amendment protections under the US Constitution
323. Due to equal protection violations by Plettenberg, Spreadbury suffered actual damages.
Right to Petition GovernmenUAmendment l---Charye 36
839
840
84L
324. Spreadbury repeats
844
845
s l-323 of this complaint as if fully
set forth
herein.
842 325. Plettenberg
843
and realleges paragraph
in her capacity
as County
Clerk did not allow Spreadbury to petition his
government for a redress ofgrievances.
326. Due to not having the ability to petition the government Spreadbury's first amendment
right was violated.
846 327. Due to the violation of Spreadbury's right to petition a govemment by Plettenberg,
847
848
849
Spreadbury suffered achral damages.
Case 9:10-cv-00049-DWM Document
Spcedy TrlaU Amcndmeat
850
851
852
853
2
Filed
05/11l10 Page 45 of 49
YII-Count
37
328. Spreadbury repeats and realleges paragraphs I-32? of this complaint
as
if fully
set
forth
hercin.
329. Defendants did rot protec( Spreadbury's right to speedy rrial
as
prosecution progressed.
854 330. As a result of the proeecution, speedy trial right was exceeded by tlre Defendants.
855
331. A$ a result of the speedy uial violation in I 329,330 Spreadbury suffered etual damages.
Excessive BaiUAmendment
857
858
Ym-Count
38
332, Spreadbury repeats and realleges paragraphs 1-331 of this complaint
as
if fully
set forth
herein.
s59
333. Law Student Wetzeon acting under color of law, requested excessive bail at trial of
860
$5000.00 for contsmptof court which Spreadbury did not effect. nor is a crime.
861
334. Spreadbury owned home in community, no prior criminal convictions, and had national
862
public trust position with security clearance, and credible
863
Spreadbury was a deploye.d federal officer to a national disaster.
re ason to be
away from court,
864
335. Bail is set to assure app€araflce at tdel. Sprcadbury retained Brownlee to appear at tial for
865
him for misdemeanor rcpr€sentation. Ms Brownlee did attend trial on E|A0f for Plaintiff.
865 336. Spreadbury never missed n court dale, and warrant with excessive bail wa.s requested and
g67
issued with malie. This acrion violated the 86 Amend.nent of ttp US Constitution.
45
Case 9:1 0-cv-00049-DWM Document
868
809
870
87t
337. Due to excessive bail requirement, which was
874
875
876
877
Filed 05/1 1/1
a goal
0
Page 46 of 49
of Defendants, deprived Spreadbury
of his 86 Amendmenr Constitrutional rights.
338. Due to Wetzeon violating Spreadbury's eighth Amendmcnt rights, Spreadbuy had acrual
damages.
872
873
2
False ArresUAmendment
IY--Curnt
39
339. Spreadbury repeats and realleges paragraphs 1-338 of this complaint
as
if fully
set
forth
herein.
340. Arrest waffant of August 8, 2007 with TAG 061001M did not $tat€ a crime, misdemeanor
orfelony.
341. Sprcadbury retained $asha Brownlee
a.s
representative counsel to represent him for
878
misdemeanor assaultn which was charged with malice against Montana common law in
879
Article II Section TII. Id, ct 80; inalienable state right to protect and defend property.
880
342. Spreadbury did not fail to appear due to retaincd legal counsel appearing at August 8, 2007
881
trial, SashaBrownlee of Bnownlee Law Offices, Hamiltoo, MT
882
343. Defendants conspired in color of law to anest Spreadbury with malice.
883
344. Due to False firest on August 16,2(W Spreadbury suffere.d actual damages.
hrnldve Ilamages -Count 40
885
S86
345. Spreadbury repeats and realleges paragraphs t-344 of this complaint
herein.
as
if fully
set forth
Case 9:10-cv-00049-DWM Document
887
346. George H. Com in his administrative role
2
Filed 05/11/10 Page 47 of 49
as County
Attomey exhibited callous
888
indifference and malice towards Spreadbury by assigning a law student to prosecute him.
889
Corn also displayed malice by rejecting Plaintiff public nuisance petition and Sheriff case.
890
347. Sheriff Chris Hoffman exhibited callous indift'erence and malice towards Spreadbury in
891
rejecting State Fire Marshall's suggestion to site Larry Robinson for fire violations.
E92
348. Cbris Culgan exhibited a callous indifference to Spreadbury's constitutional, scatutory, and
893
corlmon law rights.
894
349. Lawrcnce Hochhalter exhibited a callous inditTerence and
895
to Spreadbury's
statutory, and common law rights.
896
350. Deputy Hudson exhibited
897
a callous indifference and a rccklessness no Spreadbury's
statutory, and common law rights.
898
351. Deputy Albright exhibited a callous indifference and
899
900
a recklessness
a recklessness to Spreadbury's
statutory, and common law rights.
352. Unknown Ravalli County Deputy B exhibited a callous indifference and a recklessness to
901
902
903
904
9OS
Spreadbury's statutory, and common law rights.
353. Unknown Ravalli County Deputy C exhibited a callous indifference and a recklessness to
Spreadbury's statutory, and common law rights,
354. Angela Wetzsteon,
a private party, exhibited a callous
Spreadbury's statutory, and common law rights.
47
indifference and recklessness to
Case 9:10-cv-00049-DWM Document
2
Filed 05/11110 Page 48 of 49
906 355. Geroge Com, Sheriff Ctris Hoffman, Deputy Hochhalter, Unknown Ravalli County
gO7
Deputy B& C, Deputy Hudson, Deputy Albright, AngelaWetzeon, and the Ravalli
908
909
Republic Newspaper's conduct were precipitated by evil motive or intent.
356. Defense actors in Paragraphs 346-355 committed unlawful acts and omissions that were
910
911
malicious, willful, wanton, and oppressive.
357. The conduct of individual Defendants in paragraphs l-356 allows for the imposition of
912
punitive damages as directed by a2 USCA$ 1933, and case law precedent in the Supreme
913
Court for the United States.
Relief Sousht bv Plaintiff
915
916
Plaintiff respectively requests that the court find against the Defendants:
i.
Plaintiff suffered special damages of lost earnings in the amount of $2.6IM
gL7 ii.
Plaintiff suffered general danages for pain, suffering, mental anguish, of $lM
918 iii.
Plaintiff suffered partial compensatory damages of $6,660 which consists of Defense
919
attomcy fees, and bail bond.
920 iv.
Plaintiff incurred moving and storage costs of $750.00
921 v.
Plaintiff seeks adequate punitive damages, or what is determined by the court to be
922
suitable.
923
924
48
Case 9:1 0-cv-00049-DWM Document
925
2
Filed 05/1 1/1
0
Page 49 of 49
Plaintiff is suing for pennanent i4iuttctive relict trcmthe District Court:
(RCSO), Id. at 4E6 Paragraph
151
926
Ravalli County Sheriff Office
927
Ravalli County Attomey's Office (RCAO). Id. at 443 Paragraph 134
928
Justice Bailey, Justices wirhin Ravalli
& Missoula Counties. Id. at 467 Paragraph 142
929
930
Total Compensatory Damages to be proven al triat by Plaintiff: $ 3' 615' 78200
931
a.
Punitive Damages set aside to trial to punish Dcfendants malicious conduct
932
b.
Plaintiff seeks any reasonable court costs paid for this court action.
933
c,
Plaintiff is willing to yield to eny other relief courl may offer.
934
Demend for.Iurv Trial
93s
jury frial to rcsolve this rnatter. FRCP 38(b) allows for all
936
Spreadbury respectfully requests
937
triable issues to be before ajury trial.
938
a
of May, 2010
Dated tbis
-day
939
940
941
942
Michael Spreadbury, Pro Se Plaintiff
49
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