Spreadbury v. Bitterroot Public Library et al

Filing 277

NOTICE of Filing Exhibits Exhibit A - Amended Affidavit of Perry Backus (Newsworthy) re: 259 MOTION for Summary Judgment DEFENDANT LEE ENTERPRISES INC'S MOTION FOR SUMMARY JUDGMENT, 261 Statement of Undisputed Fact,,,,, (Smith, Jeffrey)

Case 9:11-cv-00064-DWM-JCL Docurnent

270-t

Ftled 041201t2 page 1 of 4

EXHIBIT A

.-

.

-rr.,.,.i'*re,.iroil4l*idE$ds[|

-DWM-JCL Document

Case 9:3-1

Anita Harper
Jeftiey B. Smi
OARLIN
, LOI"IN & ROI}INSO}.T,
. P. O. Box 7909
350 Ryman S
Missoula, MT 59807.7909
Telephone (
) s?3 2500
Telefax (406) 23-2595
ahpoe@garli
jbsmith@garli
Attomeys for

270-t

Filed

A4l20lt2 Paqe 2 of 4

PLLT'

,com
.com
,

Lee Enterprises, Inc.

IN THE UNITEP STATES DISTRICT COURT
FOR THE DISTRICT O}'MONTANA
MISSOULA DIVISION

MICHAEL

SPREADBURY,

Cause No.

CV-l I-064-M-DWM

titf,
AMENDED AFFIDAVIT OF FERRY
BACKUS (Newsworthy)
BITTERR
CITY OF H
ENTERPRIS
I(4"RLBER

PUBLIC LIBRARY,
,TON. t,trF
, NC,, and BOONE

BTATE OF

)

:S$

Counry

ofNli

I, Perry

t.t
t'crr a

)

kus, Lreing cluly swor-n and under oath, state as lttllor.vs:
as editor of the Rat'ulli llepuhlic' on Ausnst 9, ?010. Rncl a renorter

number fyears.

Case 9:11-

-DWM-JCL Document 27A-1, Ftled 0412011,2 page 3 of 4

August 9, 2010, article ahout Mr. Sprendbury reported facts tlorn

1

in two ditl'erent matters held on August 6,2010, in causes of

separate

action brought

y Micbael Spreadbury.
two hearings were covered by the ncw$papsr because Michael

1

become newsworlhy through his numerous attention-getting

Spreadbury

c protests, and

activities"
and involved

confrofltations. Mr. Spreadbury had both crea'ted

f in mnny publio controversies at this [irne, and a numbEr of
written about his activitiEs.

articles had

controversies began trefore the August 6, 2010, hearings,

4.

controversies included, but were not limited to:

ncighbor in which Mr.
Spreadbury allcgcd the neighbor wa$ a public

A 2006 dispute with

a

nuisance;

Attenrpt to recall Ravalli Countv Attonrey, George
Corn;
Attenrpt to recall Ravalli County Sheriff, Chris
Hoffman;
d.

Complaints agairrst the Hnrnilton Police f)epartnrent;
Cornplaints agninst the local govcrntuerrtl

f.

Curnpluirrts ubout tlre Rocky Mrlurrtnin Luhs;

()

Disputc ivitlr the Bittemoot Librnry:

h.

Dispute rvith the Clity of Harniltttn;

DWM-JCL Document 270-L Filed A4l2AlL2 page 4 of 4

Case 9:11

Various lawsuits Iiled agairrst public servants involving
publip nratters; and
Vnrious inc.idEnts of public prntest or crrrnlrr:ntatinrrs irr
public locations.

6.W
forefront

of

1

report on i

th these events, Mr. Spreadbury continually kept himself in the
news, both before and after the August 9, 2010 article,

August 9,2010, article and subsequent articles were writton to
of public interest that Mr. Spreadbury had deliberately creatEd or

interjected hi
Further

ffinnt $flyeth not.

I declars
DATED

Signed a
Perry Backus.

penolty of perjury that the fbregoing is truc and conect.

u

[8 o*vorA(c',\ ,rorz.

sworn to before me orr

,n* I I

a"y

rrI{rrf

i-l . , ?012, by

(lfype or print narnc)
Residing

n

, Monlana