Spreadbury v. Bitterroot Public Library et al

Filing 238

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

Michael E. Spreadbury
700 S. 4th Street
Hamilton, MT 59840
Telephone: [phone]
[e-mail]
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