Spreadbury v. Bitterroot Public Library et al

Filing 262

MOTION in Limine DEFENDANT LEE ENTERPRISES INC'S MOTIONS IN LIMINE Jeffrey Brandon Smith appearing for Defendant Lee Enterprises Incorporated Motions referred to Jeremiah C. Lynch. (Smith, Jeffrey)

Anita Harper Poe
Jeffrey B. Smith
GARLINGTON, LOHN & ROBINSON, PLLP
350 Ryman Street • P. O. Box 7909
Missoula, MT 59807-7909
Telephone [phone]
Telefax [phone]
[e-mail]
[e-mail]
Attorneys for Defendant, Lee Enterprises, Inc.

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MONTANA
MISSOULA DIVISION
MICHAEL E. SPREADBURY,

Cause No. CV-11-064-M-DWM

Plaintiff,
DEFENDANT LEE ENTERPRISES,
INC.'S MOTIONS IN LIMINE

v.
BITTERROOT PUBLIC LIBRARY,
CITY OF HAMILTON, LEE
ENTERPRISES, INC., and BOONE
KARLBERG P.C.,
Defendants.

COMES NOW Defendant, Lee Enterprises, Inc. ("Lee Enterprises" or
"Lee"), through its counsel, Garlington, Lohn & Robinson, PLLP, and respectfully
brings these Motions in Limine to exclude any evidence, testimony, opinions or
argument at trial concerning the following matters.
1.

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Motion in Limine No.1: Portrayal of Lee Enterprises and Appeal to

Local Bias;
2.

Motion in Limine No.2: Failure to Call Witnesses;

3.

Motion in Limine No.3: Conduct of Discovery;

4.

Motion in Limine No.4: Golden Rule Argument;

5.

Motion in Limine No.5: Exclusion of Comments on Pretrial Motions;

6.

Motion in Limine No.6: Plaintiff s Closing Argument;

7.

Motion in Limine No.7: Order of Witnesses;

8.

Motion in Limine No.8: Statements Made By Unavailable Witnesses;

9.

Motion in Limine No.9: Liability Insurance;

10.

Motion in Limine No. 10: Matters Already Decided;

11.

Motion in Limine No. 11: Other Articles Not At Issue;

12.

Motion in Limine No. 12: Plaintiff s Opinion Testimony;

13.

Motion in Limine No. 13: Speculative Statements Unsupported By

Evidence;
14.

Motion in Limine No. 14: Unrelated Complaints and Character

Attacks; and
15.

Motion in Limine No. 15: Expert Testimony.

These Motions are supported by the brief filed concurrently. Lee has
attempted to contact Plaintiff to determine whether he opposes these motions.
Although Plaintiff did not respond, based on prior filings, Lee assumes Plaintiff

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opposes these motions.
DATED this lith day of April, 2012.

lsi Jeffrey B. Smith
Attorneys for Defendant, Lee Enterprises, Inc.

CERTIFICATE OF SERVICE
I hereby certify that on the 11 th day of April, 2012, a copy of the foregoing
document was served on the following persons by the following means:

2
1

CMlECF
Hand Delivery
Mail
Overnight Delivery Service
Fax
E-Mail

1.

Michael E. Spreadbury
P.O. Box 416
Hamilton, MT 59840
Pro Se Plaintiff

2.

William L. Crowley
Natasha Prinzing Jones
Thomas J. Leonard
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants Bitterroot Public Library, City of Hamilton, and
Boone Karlberg P.C.

lsi Jeffrey B. Smith
Attorneys for Defendant, Lee Enterprises, Inc.

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