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)

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EXHIBIT U Spreadbury files $3.6 million lawsuit X RAVAI Page I of I REI:YOM Spreadbury files $3.6 million lawsuit by SEPP JANNOTTA - Staff Reporter I Posted: Wednesday, June 9, 2010 l2:00 am Citing wrongdoing by everyone from Ravalli County Sheriff Chris Hoffman to Ravalli County Attorney George Corn to "unknown deputies," failed Hamilton mayoral candidate Michael Spreadbury has filed a 49-page civil complaint in federal district court. The suit, brought against l8 separate "natural citizens" ofthe state ofMontana, alleges the group "conspired to deprive the Constitutional rights of Plaintiff," Michael Spreadbury. In addition to the mostly Ravalli County-employed defendants, Spreadbury's complaint includes the Ravalli Republic and Supporters of Abuse Free Environments, a Ravalli County advocacy group for abused women and families known as SAFE. Spreadbury is asking for $2.6 million in damages, $l million for pain and suffering, $6,660, and $750 in storage fees, for all stemming from a dispute between Spreadbury and his neighbors on Cooper Lane in Hamilton during the latter portions of 2006. Spreadbury has three additional suits pending, one against Ravalli County, one against the City of Hamilton and another against a Hamilton librarian, two of which are related to incidents at or near the Bitterroot Public Library that led to Spreadbury's being banned from the facility, trespassing in violation of that ban and subsequently being charged with felony intimidation of the library staff member. He is seeking damages of $1.2 million in those complaints. The suit describes how, in 2006, Spreadbury had a national security clearance as a decorated employee ofthe Federal Emergency Management Agency, or FEMA. Spreadbury alleges that all involved conspired to bring charges of misdemeanor assault - he claims he was defending his property against a drunken neighbor - subsequent trials and newspaper publicity of his troubles. SAFE was named for having written a letter on behalf of the neighbor, a woman who according to charging documents sustained a cut as a result of Spreadbury throwing a glass jar at her - he claims the wound was self-inflicted' As a result - Spreadbury's suit particularly blames the newspaper - he was fired from FEMA and lost out on what would have been a lucrative career, hence the $2.6 million in lost eamings. Among a slew ofcharges ranging from negligence to abuse ofprocess to violation ofequal protection, Spreadbury is asking the fediral court to grant permanent injunctive relief to protect him from the abuses of the Ravalli County Attomey's Office, the Ravalli County Sheriffs Office and Ravalli County Justice of the Peace Jim Bailey. U.S. Magistrate Judge Jeremiah Lynch has yet to rule on whether the jury trial Spreadbury has requested can proceed. Reporter Sepp Jannotta can be reached at 363-3000 or sjannotta@ravallirepublic.com. http://www.ravallirepublic.com/news/local/crime-and-courts/article c02525d2-736e-11df-... 312612012

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