Spreadbury v. Bitterroot Public Library et al

Filing 279

AFFIDAVIT re 259 MOTION for Summary Judgment DEFENDANT LEE ENTERPRISES INC'S MOTION FOR SUMMARY JUDGMENT by Michael E. Spreadbury. (APP, )

Michael E. Spread bury
700 S. 4th Street

FILED

Hamilton, MT 59840

NAY - 7 2012

Telephone: [phone]

PATRICK E. DUFFY. CLERK

er'1ii>U'T';'1rri;;;;'=~"'"
DEPUTY Cl.ERK, MI8II01iLA

[e-mail]
Pro Se Plaintiff

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MONTANA

MISSOULA DIVISION

) Cause 9:llcv-064-DWM-JCL

MICHAEL E. SPREADBURY

)

Plaintiff

v.

)

BITTERROOT PUBLIC LIBRARY,

)

AFFIDAVIT OF MICHAEL

CITY OF HAMILTON,

)

E. SPREADBURY IN

LEE ENTERPRISES, INC.,

)

RE: LEE ENTERPRISES

BOONE KARLBERG, PC,

)

NEWSWORTHINESS

-------------------------)

Comes now Spreadbury with affidavit with respect to Lee Enterprises judgment of

newsworthiness in Hamilton, Montana.

First being sworn, Michael Spreadbury states as follows:

1. I am Michael E. SpreadbuI)', Plaintiff in this case.

1

Affidavit of Plaintiff in re: lee Newsworthiness

9:11-cv-0064-JCl-DWM

May 3,2012

2. I asked Editor Perry Backus of Lee Enterprises to cover an accident
involving an elected public official from Hamilton Mf September 14, 2007.
3. I sent the written request to Backus as is discovered evidence in this case, as
is a photo of a single damaged single vehicle from this accident.
4. The Ravalli Republic Editor Backus responded to me in writing that Lee
Enterprises would not cover the accident involving a public official on or
around September 14,2007 in Hamilton Montana with: "end of story".
5. Hamilton City Councilor Mike LaSalle left the scene of an injury accident
September 14,2007 documented in my photo evidence; eyewitness account.
6. Hamilton City Police Chief and Defendant Ryan Oster observed near the
accident scene; Oster sent to the FBI academy after accident occurred.
7. The Montana Highway Patrol commander, 25 years service Paul Grimsted
resigned after failing to investigate accident September 14,2007.
8. Lee Enterprises refused to cover September 14,2007 accident by a public
official as non-newsworthy; Lee Editor did not cover, even at my request.
9. I attempted to publish letter to editor, pay for advertising of the accident in
Lee Enterprises Ravalli Republic and was refused by Lee employees.
10. Perry Backus makes sworn affidavit April 4, 2012 and Apeill8, 2012
indicating I was newsworthy in Hamilton Montana, but a felony hit and run
accident September 14, 2007 by an elected public official was not.
2

Affidavit of Plaintiff in re: lee Newsworthiness

9:11-cv-0064-JCl-OWM

May 3, 2012

11. Lee refused to publish an article of the criminal act of a public official, even
at my request; deems newsworthy an article on me in oral argument as a
private citizen engaged public judicial hearing August 6, 2010.
FURTIIER AFFIANT SAITH NOT.

Before me, a Notary Public for the State and County aforesaid, appeared
Michael E. Spreadbury who is known to me or who provided photo
identification and executed the affidavit in my presence.

rA~~-::J~ ::O:---'t-_R_r_"_1.._(~_,·_il_ _ _ Name of Notary Public
,--,'

::::....--.:...!!Jc...1.2J!2l2::_j--.:...&_~;::;~.::.,5-~
____ NOtary Public Signature
~-I 0 • J 0 '_J _ _---'my commission expires
_

I, the affaint hold the above to be true, under penalty of perjury.

Respectfully submitted this;)

J day of May, 2012

K-..,'..,~.=--_-#~. _____

By:_ _ _IL::I=--_ _

Michael E. Spreadbury, Self Represented Plaintiff

3