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 E

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

a

Recall Petition:
To the Honorable Regina Plettenberg, Ravalli County Election Admioistrator:
We tbe mdersiped qualified electors of Ravalli County, Montaaa reqpectfrrlly petition that an electiou be
held as provided by law on the question of whether George H. Corn, holding the office of Ravalli County
Aftomey should be recalled for the following reasons:

INCOMPEUNCE:
The County Attorney committed state and federal constitutional crimes against Ravalli
County residents to improperly prosecute them in court. The County Attomey did not
take action when approached pertaining to ongoing criminal endangerment. This
endangerment is from continuous violation of state fire code from July 2006 to April
2007;the County Attomeybeing aware of these violations from two visits from the
Deputy State Fire Marshall in October 2006 and taking no legal action to protect Ravalli
County resideirts from danger, even when petitioned by 10 neigbbors within %m1la

OATH OF OFFICE:
Ravalli County Attomey has violated his swom oath of office by not upholding the
Montana Constitution Article II Section ltr; inalienable rights granted to all Montana
citizens. The Ravalli County Attorney has not protected citizen's right to 1) a healthy
environme,::t and 2) their State protected right to protect properly from attack. Count I
of this evidence of this is allowing toxic chemicals and smoke to inr:ndate the property at
291 Cooper Lane which forced evacuations and eventual fleeing properly in late October,
2006. Count 2 involves attempting to prosecute an individual who protected his property
from attack on October 10,2006.

Michael Spreadbury

Notarized by

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MCA 2-16-600 Montana Recall Act
Recall of Ravalli County Attorney
l,egal Waming:

A person who knowingly signs

a name other than his (or her) own to this petition or who signs his (or her)
name more than once upon a petition to recall the same officer at ong election or who is not, at the time he
signs this petition a qualifed elcctor (rcgistered voter) of the State ofMontaaa, County of Ravalli entitled
to votc for the successor ofthe elected officer to be recalled or the successor or successors of the offrcer or
ofhccr who have the authority to appoint the position held by the appointcd officer to be recalled is
punishablc'by a fine of no more than $500 or imprisonment in the county jail for a term not to exceed 6
montls , or both, or imprisonment in the state prison system not to excccd 10 ycars or both.

Recall Petition:
To the Honorable Regina Plenenberg, Ravalli Counfy Election Administrator:

We the undersigned qualihed electors of Ravalli County, Montana respectfully petition
that an election be held as provided by 1aw on the question of whether George H. Corn,
holding tbe office of Ravalli County Attomey should be recalled for the following
reaEons:

INCOMPETENCE:
Since July, 2006 the Ravalli County Anorney office did not return phone calls from
county residents, or make appointnents as requested, or take action when approached in
person pertaining to a dangerous and potentially criminal situation. The Ravalli County
Attomey ignored a community petition to address these problems in July, 2006; this
petition is on permanent record at the Ravalli County Clerk and Recorders Office, 215 S.

4tI

St. Hamilton,

MT 59840.

OATH OF OFFICB:
Ravalli County Sheriff has violated his sworn oath of office by not upholding the
Montana Consdtution Article tr Section Itr as it pertains to inalienable rights granted to
all Montaua citizens. Mr. Com, has not protected Ravalli County citizen's right to a
healthy environment, nor their right to defend property from attack.

BY HIS (OR }MR) SIGNATURE EACH SIGNER CERTIFIES
I have personally signed this petilion; I'am

:

qualified elector of the State of Montana,
and County ofRavaili, and my residence address and Post Office address are correctly
written after my name to best of my knowledge and belief.
Signature

Printed last name

a

Address where registered

Date

I.
2.

5.
6.
7.
8.

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Ravaui

Recar]

poBox4l6

Harnilton MT 59840

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MCA 2-16-600 Montana Recall Act
Recall of Ravalli County AttorneY
Legal IVarning:
A person who knowingly sips a natne olhcr than his (or her) own to this Pctition or who signs his (or her)
name more than once upou a petition to recall the same officer at one electiou or who is not, at the timc hc
signs this petition a qualified elector (registercd voter) ofthe State ofMontana, Cormty ofRavalli cntitled
to vote for the successor ofthe elecled offic€r to be recalied or the successor or successors oftbe officer or
officer who lave rle authority 1o appoint tbe position held by tbe appointed officer to be recalled is
punishable by a fine of no more than $500 or iryrisonmeot in the county jail for a term not to exceed 6
months , or bot\ or iroprisonucnt in the state Prison systsm not to exc€ed l0 years or botL

Recall

Petition:

'

To the Honorable Regina Plettenberg, Ravalli County Election Administator:
We the undenigped qualified electors of Ravalli Couoty, Montana respectfi:.lly petition that an electiou be
held as provided by law on the questioa of whethcr George H. Com, holding the office of Ravalli County
Attomey should be recalled for the following reasons:

INCOMPETENCE:
The Counfy Atlomey committed state and federal constitutional crimes against Ravalli
Cormty residents to improperly pro$ecute thEm in court. The County Attorney did not
take action when approached pertaining to ongoing criminal endangerment, This
endangerment is fiom continuous violatiou of state ftre code from July 2006 to April
2007 the County Attomey being aware of these violations from fwo visits from the
Deputy State Firo Maxshall in October 2006 and taking no legal action to pmtect Ravalli
County residents from dauger, even when petitioned by l0 neigbbors within % mile.
OATH OF OFFICE:
Ravalli County Attorney has violated his swom oath of office by not upholding tle
Montana Constitution Article tr Section III; inalienable rights $antedto all Montana
citizens. The Ravalli County Attomeyhas not protected citizeo's right to l) a healthy

environmeut and2) their Stateprotectedright toprotectproperlyfromattack Count I
of this evidence of this is allowing toxic che,micals and smoke to inundate the proporty at
291 Cooper Lane which forced evacuations and eventual fleeing properfy in late October,
2006. Count 2 involves attempting to prosecute an individual who protected his property
from attack ou October L0,2006.

BY HIS (OR HER) SIGNATTIRE EACH SIGNER CERTIFIES:

I have porsonally signed this peiition; I am a qualified elector ofthe State ofMontan4 aod County of
Ravalli, and my resideace address ald Post OfEce address are conectly written after my name to best
uy knowledge and belief.
---Post Offi ce Address----------------

Signature
1.

J.

5.

6
7.
8.

10.

Ravalli Recall
PO Box 416
Hamilton MT 59840

Printed last name

(Addre.ss where

registered)

of

Date