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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W.T. Boone (i9io-i984)
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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

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EXHIBIT D