Spreadbury v. Bitterroot Public Library et al

Filing 238

NOTICE of filing Pltf Interrogatories, Discovery by Michael E. Spreadbury (Attachments: # 1 Attachment D) (APP, )

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Michael E. Spreadbury 700 S. 4th Street Hamilton, MT 59840 Telephone: (406) 363-3877 mspread@hotmail.com Pro Se Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA MISSOULA DIVISION ) Cause No: CV-ll-064-DWM-JCL MICHAEL E. SPREADBURY ) Plaintiff v. ) NOTICE OF PLAINTIFF BITTERROOT PUBLIC LIBRARY, ) INTERROGATORIES, CITY OF HAMILTON, ) DISCOVERY REQUESTS LEE ENTERPRISES, INC., ) r d TO LEE BOONE KARLBERG, PC, ) ------------------) Comes now Spreadbury with judicial notice of interrogatories served upon Defendants in this cause of action before this Honorable Court: Interrogatory No. 19: Describe how Lee Defendants are internet service providers in Montana or elsewhere; what web sites for Lee have chat rooms, or provide internet access. Answer: 1 Interrogatory No. 20: Ifthe product Lee develops in Montana is printed newspapers or news source websites, how are the Defendants anything but newspaper publishers, and providers ofnews infonnation? Answer: Interrogatory No.2 J : What is the fact checking protocol for editors at Lee for articles published by Defendants? Answer: Interrogatory No. 22: What is the fact checking protocol for reporters prior to publishing an Lee Enterprises news article? Answer: Interrogatory No. 23: Does Lee Enterprises have the capability to edit online comments published on Defendant Lee web sites? Answer: Interrogatory No. 24: Within the August 9, 2010 Ravalli Republic article why did no personnel from Lee discover the false fact of conviction for disturbing the peace against Plaintiff? Answer: Interrogatory No. 25: In the attempt at correction published August 24, 20] 0, why did the text indicate a correction to an August 9, 2010 article with infonnation from August 10,2010, and other false infonnation? Answer: (I y'l:;"\ Respectfully submitted this 25 day of February, 2012 Michael E. Spreadbury, Self Represented Plaintiff 2

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