Spreadbury v. Bitterroot Public Library et al
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: (406) 363-3877
Pro Se Plaintiff
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MONTANA
) Cause No: CV-ll-064-DWM-JCL
MICHAEL E. SPREADBURY
NOTICE OF PLAINTIFF
BITTERROOT PUBLIC LIBRARY,
CITY OF HAMILTON,
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
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?
Interrogatory No.2 J : What is the fact checking protocol for editors at Lee for
articles published by Defendants?
Interrogatory No. 22: What is the fact checking protocol for reporters prior to
publishing an Lee Enterprises news article?
Interrogatory No. 23: Does Lee Enterprises have the capability to edit online
comments published on Defendant Lee web sites?
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
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?
Respectfully submitted this
day of February, 2012
Michael E. Spreadbury, Self Represented Plaintiff
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