Spreadbury v. Bitterroot Public Library et al

Filing 258

NOTICE of filing Response to Lee Damage Expert Disclosure by Michael E. Spreadbury (APP, )

Michael E. Spreadbury

FILED

700 S. 4th Street

APR -.2012

PA'rR1C1( E ou
1Jf_
- FFY. CLERI(

Hamilton, Mf 59840

DEPUTY CLERI(, MISSOULA-

Telephone: (406) 363·3877
[e-mail]
Pro Se Plaintiff

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MONTANA

MISSOULA DIVISION

MICHAEL E. SPREADBURY

) Cause 9:11cv-1l-64-DWM-JCL
)

Plaintiff

v.

)

BITTERROOT PUBLIC LffiRARY,

)

RESPONSE TO

CITY OF HAMILTON,

)

LEE DAMAGE EXPERT

LEE ENTERPRISES, INC.,

)

DISCLOSURE

BOONE KARLBERG, PC,

)

-------------------------)

Comes now Spreadbury with reply to Defendant Lee Enterprises Inc. with respect

to disclosing confidential information, projected false information.

Honorable Court is given notice of release of confidential information, speculative
information that is incorrect under pretense of expert witness testimony.

1

Plaintiff Reply to LEE: protected information

Cause 9: ll-CV-11-64-DWM-JCL

April 2, 2012

Neither Boone Karlberg PC nor Lee Enterprises has not contacted "expert witness"
or damage expert witness, but merely recopied information from confidential
health information, part of which is merely speculative on the part of the Defense.
Honorable Court has previously said Plaintiff asked for the release ofprotected
health information, under investigation for release, not releasable by Subpoena
Deuces Tecum as a source ofprotected health informational.
Court is reminded of Count 23 Injunctive Relief(Doc. #10) Lee Enterprises Inc.
"to stop malicious comment, defamatory material from publication"
Spreadbury has served upon court affidavit that Health Care provider rejected any
personality disorder in individual health conference; Lee projects new condition of
"Narcissistic Disorder" never discussed or published as a diagnosed condition for
Spreadbury. This is a false and defamatory statement by Lee published with
malice without court privilege due to malice.
Lee continues to publish false information as Dr. Wahlberg was not Spreadbury's
treatment clinician, and only had an insight due to aggressive answers from
Spreadbury on a multiple choice test in 2006, not verified by any clinician.
Proof of future harm is before this court, as pled (Ln. 216-222 Doc. # 10) in 2nd
Amended Complaint.

2

Plaintiff Reply to LEE: protected information

Cause 9: ll-CV-ll-64-DWM-JCL

April 2, 2012

Difficulty with employment is also due to defendants intimidating employers as in
Defendant City Police, layoffs from work, and employers ending business, not
solely medical condition.
The difference between maintaining employment and being disabled is the nexus
of this case as the proximate cause was the treatment of Plaintiff, extreme use of
articles, online comments, and the lack of proof that Lee Enterprises can offer
online real-time discussion forums, or have online access through Lee sites. Court
has erred in allowing Communications Decency Act to Lee, actionable upon
appeal.
Lee discredits itself as false pretence of contact with medical personnel, no
contracts, or independent experts provided. As "troubled" Plaintiff, counters two
law firms, graduates from two collegiate programs, engages in stressful
employment of teaching, disaster work, Lee argument is discredited.
Plaintiff was fully capable until unreasonable actions by Defendants without due
care. Unless Defendants can obtain testimony that the sole direction ofPlaintiff
future was disability, liability attaches.
Questionable ethics apply to GLR, LEE. Publishing false information is nexus of
this case, and request for court intervention.

:3

Plaintiff Reply to LEE: protected information

Cause 9: ll-CV-ll-64-DWM-JCL

April 2, 2012

IfPlaintiff was actually Narcissistic it would be sending thank you cards to Lee
Enterprises for the 30-35 headlines and comments. The employment as teacher to
help hundreds of kids would not have happened either.
As Lee counsel can claim the #113 and #145 ranked law school it is not a good
idea to speculate or publish false infonnation in the pretext of reality. The case is
for the defamation, negligence, and tortious interference due to publishing a false
conviction.
Ability to work compared to fully disabled means severe emotional distress
occurred, and it shows the professionalism to continue that injury before this court.

'7tl\~
Respectfully submitted this l--

ay 0

'pril,2012

~///
BY:_---,f-~--h,L---------Michael E. Spreadbury, Self Represented Plaintiff

4

Certificate of Service
Cause No. 9:11-cv-ll-0064-DWM-JCL
I certifY as Plaintiff in this action, a copy ofthe below named pleading was served
upon the US District Court Missoula Division and all opposing counsel for parties
in this above named cause of action by first class mail. The following addresses
were used for service:
Response to Lee Damage Expert Disclosure

Russell Smith Federal Courthouse
Clerk ofCourt
201 E. Broadway
Missoula, MT 59803

Defendant Counsel:

Plaintiff Counsel:

William L. Crowley

Michael E. Spreadbury

Boone Karlberg PC

POBox 416

POBox 9199

Hamilton, MT 59840

Missoula MT 59807

(sel f-represented)

Anita Harper Poe/Jeffrey B Smith
Garlington, Lohn, & Robbinson PLLP
POBox 7909
Missoula MT 59807

Dated _ _ _4/2/12_ _ __

Michael E. Spreadbury, Pro Se Plaintiff