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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BOONE PKARLBERG HKflk ATTDDMnVC AT 1 AW W.T. Boone (i9io-i984) KARLR. KARLBRRG(l92M9tS) James J. Benn (1944-1992) Thomas H. Boone William I,. Crowlby Randy J. Cox Robert J. Sullivan DbanA. Stensland November 4,2011 Group DeltaConsultants & Geotechnics, Inc. 9245 Activity Road, Suite 103 Cynthia k.twel San Diego, CA 92126 *£?££ Matthew B. Hayhurst Re: Michael E. Spreadbury v. Bitterroot Public Library, et al scorr m. stbarns Natasha Prinzino Jonbs Thomas J. Leonard To Whom It May Concern: *»•»R- s»ws Tracey Nhiohbor Johnson 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 Lint in theabove-referenced lawsuit filed by Michael E. Spreadbury. It isnecessary for us toobtain records relating to Michael E. Spreadbuiy. 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 or tangible things, including but notlimited to your entire file relating to former employee Michael E. Spreadbury. Mr. Spreadbury's dateof birth isHHi^^Hi^ft his social security number ends with|^| This request includes anyand all documents related toMr. Spreadbury's relationship with Group DeltaConsultants & Geotechnics, Inc., at anytime, including butnot limited to his employment as a staffgeologist with yourfirm from 1995-1996. Please complete and sign the enclosed Acknowledgment, and mail it to mealong with the requested documents no later than November 21,2011. Our office will pay copying and reasonable administrative costs associated with providing the documents. Thank you foryour cooperation. Please do not hesitate to call if you have any questions. William L. Crowley WLC:seh Encs. c: Michael E. Spreadbury (w/encs.) F:\Files\4293\4085\C0214906.WPD 201West Main St., Suite 300 | P.O. Box 9199 | Missoula, MT 59807-9199 I (TEL) 406-543-6646 (FAX) 406-S49-6804 | wwMboouekarIberg.com EXHIBIT D

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