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 D

I, Mchael Spreadbury do attest that the following is frue and I swear to this.with
penalty of perjury if these facts are not true.

a

Recall Petition:
To the Honorable Regina Plettenberg, Ravalli County Election Administrator:
We the undersigned qualif,ed electors of Ravalli County, Montana respectfully petition
that an election be held as provided by law on the question of whether Chris Hoffinan'
holding the office of Ravalli Counfy Sheriffshould be recalled for the following reasons:

INCOMPETENCE:
Ravalli County SheriffChris Hof8aan knowingly allowed deputies to violate civil rights
of Ravalli County Residents. At time of traffic stops and law enforcement operations,
free speech was halted by selective h:rning offcommunication equipme'lrt which records
all communication between deputy and suspect. This transcript of communication is used
in court to convict suspects. Further incompetence is the gathering of evidence: in a nonequal manner. This puts justice in jeopardy for Ravalli County residents.

OATH OF OFFICE:
Ravalli County Sheriffbas violated his swom oath of office by not uphold'ng the
Montana Constitution Article II Section Itr as it pertains to inalienable rights granted to
all Montana citizens to protect property and enjoy a healthy environment. Sheriff
Hoffman allowed toxic smoke to enter the residence of 29I Cooper Lane and allowed
deputies to cite the resident at that address for protecting the property from attack which
ociuned on October 10, 2006. This evidence describes two counts of violating a state
constitutional oath.
Signed this 26tr day of Jan

Michael Spreadbury

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MCA 2-16-600 Montana Recall Act
Recall of Ravalli County Sheriff
Legal Warning:

A person who knowingly signs a name other than his (or her) own to this pctition or who signs his (or her)
name more than once upon a petition to recall the same officer at one election or who is not, at the time be
signs this petition a qualified elector (registere.d voter) of dre State of Montan4 County of Ravalli entitlcd
to vote for the successor of the elected officer to be recalled or the successor or successors of the officcr or
ofticer who have the aulhorily to appoint the posidon held by the appointed officer !o be rEcalled is
punishable by a fine of no more than $500 or imprisonment in the county jail for a term not to excecd 6
months , or both, or imprisonment in the state prison system not to exceed 10 years or both,

Recall Petition:
To the Honorable Regina Plettenberg, Ravalli County Electjon Adminisuator:

We the undersigned qualified electors of Ravall County, Montana respectf,r]ly petition
that an election be held as provided by law on the question of whether Chris Hoffrnan,
holding the office of Ravalli County Sheriff should be recalled for the following reasons

i

INCOMPETENCEI
Since July, 2006 Sheriff Hofuan has not protected tle community along South Cooper
Lane Hamilton, Montana from Hazardous Conditions, including toxic chemicals,
invasive species, and fire danger. The Ravalli County Sheriff department lgnored a
community petition to address these problems in luly, 2006; this petition is on permanent
record at tbe Ravalli Counry Clerk and recorders Office,215 S. 4th St. Hamilton, MT.
OATH OF OFFICE:
Ravalli County Sheriff has violated his sworn oath of office by not upholding the
Montana Constitution Arlicle II Section III as it pertains to inalienable rights granted to
all Montana citizens. Sheriff Hoffman has not protected Ravalli County citizen's right to
a healthy environnent, nor their right to defend property frorn attack.
"
BY HIS (OR IIER) SIGNATURE EACH SIGNER CERTIFIES:
I have personally signed this petition; I am a qualified elector of the State of Montan4

and County of Ravalli, and my residence address and Post Office address are correctly
written afLer my name to best of my knowledge and belief,

Signature

Pridted last name

Address where

registered

Date

I

4.

6.
7.
8.
9.

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Ravalli Recali
PO Box 416
Hamiiton MT 59840

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MCA 2-16-600 Montana Recall Act
Recall of Ravalli County Sheriff
Legal Warning:

A person who lnowingly si8:rs a name other than his (or ber) own to this petition or who sigus his (or her)
name more than once upon a petition to recall the same of6cer at one election or who is no! at the time he
signs this petitior a qualified elector (registered voter) of the SEte of Montaaa, Cormty of l{availi entided
to vote for tbe successor ofthe elected offiosl to be rccalled or the succossor or successors ofthe officcr or
ofiicer wbo have the authority to appoiut the position held by tbe appointcd officer o be recalled is
punisbable by a fue of no more tban $500 or irprisonmenl iD the county jail for a term not to qceed 6
months , or botb, or imprisonmeqt in the state plison system lot to exoeed 10 years or both.

Recall Petition:
To the Honorable Regina Plettenberg, Ravalli Cowrty Election Administrdtor:

We tle undersigned qualified electors of Ravalli County, Montana respectfullypetition
that an election be held as provided by law on the question of whetler Chris Hofuan,
holding the office of Ravalli County Sheriffshould be recalled for the following reasons:
INCOMPETENCE:
Ravalli County SheriffCbris Hoftnan knowingly allowed deputies to violate civil rights
of Ravalli Cormty Residents. At time of traffic stops and law enforcement operatlons,
free speech was halted by selective tuning offcommunication equipment which records
all communication between depury and suspect. This transcript of communicafion is used
in court to couvict flrspects. Further incompetence is the gatlering of evidcnce: in a nonequal manner. This puts justice in jeopardy for Ravalli County resideots.

OATH OF OFFICE:
Ravalli County Sheriff has violated his swom oath of office by not upholding the
Montana Constitution Article II Section Itr as itpertains to inalienable rigbts granted to
all Montana citizeus to protect property and enjoy a healthy environment. Sheritr
Hoftnan allowed toxic smoke to enter tle residence of 291 Cooper Lane and allowed
deputies to cite the resident at tbat address for protecting the property from attpk which
occu:red on October 10,2006. This evidence describes two counts ofviolating a state
constitutional oath
BY HIS (OR HER) SIGNATTIRE EACH SIGNER CERTIFIES:
I have penonally sigred this petition; I am a qualified elector of the State of Montana,
and County of Ravalli, and my rosidence address and Post Offrce address are corectly

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Signature

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2.
3.
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5.
6.
7.

8.
9.
10.

Ravalli Recall
PO Box 416
Hamilton MT 59840

Printed last

name

(Address where

registered)

Date