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)

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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

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