Spreadbury v. Bitterroot Public Library et al

Filing 137

MOTION for Sanctions by Plaintiff Michael E. Spreadbury. Motions referred to Jeremiah C. Lynch. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C) (APP, )

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October 24, 20 II
FEMA
Denver FederaJ Center
Building 710, Box 25267
Denver, CO 80225-0267
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Michael E. SpreadbulJ' v. Billerrool Public Library, el al.

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To Whom It May Concern:

This oflicc represents Defendants BittcrroOl Public Library, City of Hamilton, Dr. Robert
Brophy, Trista Smith, Nansu Roddy, Jerry Steele, Steve Snavely, Steven Bruner-Murphy, Ryan
Oster, Kenneth S. Bell and Jennifer Lint in the above-referenced lawsuit filed by Michael E.
Spread bury. It is necCSS31)' for us to obtain records relating to Michael E. Spreadbury. Enclosed
is a Subpoena Duces Tecum that has been issued pursuant to the Federal Rules of Civil
Procedure. As stated in the Subpoena, you are required to produce the lollowing:
Any and all documents or tangible things. including but not limited \0 the entire

employee or personnel file, relating to Michael E. Spread bury. Mr. Spreadbury's

date of birth is November 30,_. his social security number i

This request includes any and a!idocuments related to Mr. Spreadbury's

employment and/or contractual relationship with FEMA in your possession or

control, including but not limited to employeclcontractor job descriptions,

applications and application materials, reviews, eval uations, personnel records,

diseiplinary action/proceeding records, letters oftermination or separation,

worker's compensation liles, time records. payroll records, job restrictions, etc.

Please complete and sign the enclosed Acknowledgment, and mail it to me along with the
requested documents no later than November 3, 2011. Our office will pay copying and
reasonable adminibimtivc costs associated with providing the documents.
Thank you for your cooperation. Please do not hesitate to call if you have any questions.
Sincerclv---­

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Michael E. Sprc"dbury (w!encs,)

J. Leonard