Spreadbury v. Bitterroot Public Library et al

Filing 270

MOTION to Amend/Correct 261 Statement of Undisputed Fact,,,,, Jeffrey Brandon Smith appearing for Defendant Lee Enterprises Incorporated Motions referred to Jeremiah C. Lynch. (Attachments: # 1 Exhibit Amended Exhibit A) (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
Cause No. CV-11-064-M-DWM

MICHAEL E. SPREADBURY,
Plaintiff,
v.
BITTERROOT PUBLIC LIBRARY,
CITY OF HAMILTON, LEE
ENTERPRISES, INC., and BOONE
KARLBERG P.C.,

DEFENDANT LEE ENTERPRISES,
INC.’S MOTION TO SUBSTITUE
AMENDED EXHIBIT “A” TO
STATEMENT OF UNDISPUTED
FACTS (DKT 261-1)

Defendants.
Defendant, Lee Enterprises, Inc. (“Lee Enterprises” or “Lee”), through its
counsel, Garlington, Lohn & Robinson, PLLP, requests the Court substitute the
attached Amended Exhibit “A” for the previously filed Exhibit “A” to its
Statement of Undisputed Facts (Dkt. 261-1).
In accordance with Local Rule 7.1(c)(1), Lee’s counsel attempted to contact

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Pro Se Plaintiff to determine whether he opposes this Motion. Although Plaintiff
did not respond, Lee assumes Plaintiff would not oppose the motion since he
contacted Lee’s counsel regarding Exhibit “A” (Dkt. 261-1). However, based on
prior filings, Plaintiff may still oppose the Motion. Therefore, it is supported by
the brief filed concurrently. Counsel for the other named Defendants do not
oppose this Motion.
DATED this 20th day of April, 2012.

/s/ Jeffrey B. Smith
Attorneys for Defendant, Lee Enterprises, Inc.

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CERTIFICATE OF SERVICE
I hereby certify that on the 20th day of April, 2012, a copy of the foregoing
document was served on the following persons by the following means:
___2___
_______
___1___
_______
_______
_______

CM/ECF
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.

/s/ Jeffrey B. Smith
Attorneys for Defendant, Lee Enterprises, Inc.

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