Spreadbury v. Bitterroot Public Library et al

Filing 186

RESPONSE to Motion re 177 MOTION, 176 MOTION to Quash, 178 MOTION for Order/Judgment filed by Kenneth S. Bell, Bitterroot Public Library, Robert Brophy, Steven Bruner-Murphy, City of Hamilton, Jennifer B. Lint, Ryan Oster, Nansu Roddy, Trista Smith, Steve Snavely, Jerry Steele. (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, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P) (Crowley, William)

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BOONEPKARLBERG QSA ATTORNEYS AT LAW P.C. W.T. Boone (I9I0-I9M) KARLR. KARLDER0(192M9SS) James J. Benn(I944-i992) November 4,2011 Educator Licensure (Certification) Program Montana Office of Public Education 1201 ll,h Avenue, 1st Floor P.O. Box 202501 Helena, MT 59620-2501 Thomas H.Boone William L. Crowley Randy J. Cox Robert J. Sullivan Dean A. Stensland Cynthia K. Thiel Ross D. Tillman James A. Bowditch Matthew B. Hayhurst Scott M. Stearns Natasha Prinziko Jones Thomas J. Leonard Re: Michael E. Spreadbury v. Bitterroot Public Library, et al. Julie R.Sirrs Tracby Neighbor Johnson To Whom It May Concern: This office represents Defendants Bitterroot 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 Lintin theabove-referenced lawsuit filed by Michael E. Spreadbury. It is necessaiy for usto 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 following: Any and all documents ortangible things, including but notlimited to your entire file relating to Michael E. Spreadbury. Mr. Spreadbury'sdateofbirthis ^^^HH^HH his social security number ends with^^l This request includes any and all documents related to certification and licensure of Michael E. Spreadbury as a teacher during the period 1994 to present. Please complete and sign the enclosed Acknowledgment, and mail it to me along with the requested documents no later than November 21,2011. Our office will pay copying and reasonableadministrative costs associated with providing the documents. Thank you for yourcooperation. Please do nothesitate to call if you haveanyquestions. Sincerely,; William L. Crowley WLC:seh Encs. c: Michael E. Spreadbury (w/encs.) F:\Files\4293\4085\00214907.WPD 201 West Main St., Suite 300 | P.O. Box 9199 | Missoula, MT 59807-9199 I(TEL) 406-543-6646 (FAX) 406-549-6804 | wwmboonekarlber&com EXHIBIT J

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