Spreadbury v. Bitterroot Public Library et al
Filing
261
Statement of Undisputed Fact re: 259 MOTION for Summary Judgment DEFENDANT LEE ENTERPRISES INC'S MOTION FOR SUMMARY JUDGMENT. (Attachments: # 1 Exhibit A - Aff of Backus - Newsworthy, # 2 Exhibit B - Petition to Ravalli County, # 3 Exhibit C - Pl to Messina (10-19/2007), # 4 Exhibit D - Pet Recall Sheriff Hoffman, # 5 Exhibit Pet Recall Ravalli Co Attorney Corn, # 6 Exhibit F - Ltr Pl to McCulloch (2/10/2009), # 7 Exhibit G - Ltr Commrs to Pl (2/17/2009), # 8 Exhibit H - Ltr PL to McCulloch w Recall Pet, # 9 Exhibit I - Ltr Kimmet to PL (3/13/2009), # 10 Exhibit J - Ltr Quintana to PL (3/23/2009), # 11 Exhibit K - Ravalli Republic Article (2/19/2009), # 12 Exhibit L - Blog Bitterroot Rising (2010), # 13 Exhibit M - Blogger User Profile, # 14 Exhibit N - Crystal Cox Blog (2011), # 15 Exhibit O - Blog - Ravalli Co Sheriff Dept (8/8/2009), # 16 Exhibit P - Crystal Cox Blog (2012), # 17 Exhibit Q - Library Thing, # 18 Exhibit R - Spreadbury Youtube MT, # 19 Exhibit S - Ravalli Republic Article (11/3/2009), # 20 Exhibit T - Find My Threat Story (11/17/2011), # 21 Exhibit U - Ravalli Republic Article (6/9/2010), # 22 Exhibit V - USDC Complaint (7/30/20100, # 23 Exhibit W - Aff Backus (Standard of Care), # 24 Exhibit X - Aff Devlin (4/2/2012), # 25 Exhibit Y - Bitterroot Rising Archives (2010)) (Smith, Jeffrey)
EXHIBIT A
Anita Harper Poe
Jeffrey B. Smith
GARLINGTON, LOHN & ROBINSON, PLLP
350 Ryman Street. P. O. Box 7909
Missoula, MT 59807 -7909
Telephone (a06) 523-2500
Telefax (406) 523-2595
ahpoe@garlington.com
j bsmith@garlington. com
Attorneys for Defendant, Lee Enterprises, Inc.
IN TFIE LINITED STATES DISTRICT COURT
FOR THE DISTRICT OF MONTANA
MISSOULA DIVISION
MICHAEL E. SPREADBURY,
Cause No.
CV-l I-064-M-DWM
Plaintiff.
AFFIDAVIT OF PERRY BACKUS
(Newsworthy)
V.
BITTERROOT PUBLIC LIBRARY,
CITY OF HAMILTON, LEE
ENTERPRISES, INC., and BOONE
KARLBERG P.C.,
Defendants.
STATE, OF
County of
MONTANA
Missoula
)
:SS
)
I, Perry Backus, being duly swom and under oath, state as follows:
1.
I was editor of the Ravalli Republic on August9,2010, and a reporter
for a number of years.
l
l48l3l
2.
The August 9, 2010, article about Mr. Spreadbury reported facts from
separate hearings in two different courts held on August 6,2010, in causes
of
action brought by Michael Spreadbury.
3.
The two hearings were covered by the newspaper because Michael
Spreadbury had become newsworthy through his numerous attention-getting
activities, public protests, and confrontations. Mr. Spreadbury had both created
and involved himself in many public controversies at this time, and a number
articles had been written about his activities.
4.
These controversies began before the August 6,2010, hearings.
5.
These controversies included, but were not limited to:
a.
A 2006 dispute with a neighbor in which Mr.
Spreadbury alleged the neighbor was a public
nuisance;
b.
Attempt to recall Ravalli County Attomey, George
Corn;
c.
Attempt to recall Ravalli County Sheriff, Chris
Hoffman;
d.
Complaints against the Hamilton Police Department;
e.
Complaints against the local government;
f.
Complaints about the Rocky Mountain Labs;
g.
Dispute with the Bitterroot Library;
h.
Dispute with the City of Hamilton;
of
i.
j.
6.
Various lawsuits filed against public seruants involving
putrlic matters; and
Various incidents of public protest or confrontations in
puhlic locations.
With these events, Mr. Spreadbury continually kept himself in the
forefront of local news, both befole and after the August 9,2010 article.
7.
The August 9, 2010, article and subsequent articles were written to
report on issues of public interest ttrat Mr, Spreadbury had deliberately created or
interjected himself into.
Further Affiant sayeth not.
I declare under penalty of perjury that the foregoing is true and correct,
DATED this
J-
day
of NQ "- \
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Signed and swo:n to before me on
Perr)'Backus.
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(Type or print name)
NOTARY PUBLIC EOR THE ST ATE OF rvr€$ITAF[L c e LrFoe,dU
Residing at
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My commission expires:
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EXPtnES H0V,
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