Spreadbury v. Bitterroot Public Library et al

Filing 288

Brief/Memorandum in Support re 287 MOTION to Compel Participation in Pretrial Order filed by Kenneth S. Bell, Bitterroot Public Library, Robert Brophy, Steven Bruner-Murphy, City of Hamilton, Jennifer B. Lint, Ryan Oster, Nansu Roddy, Trista Smith, Steve Snavely, Jerry Steele. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I) (Crowley, William)

Bill Crowley
From:
Sent:
To:

Bill Crowley
Monday, May 07, 2012 10:08 AM
'[e-mail]'

Cc:

Crystal Trenary; Kate Palmer; Kandy Jenkins; Shannon Holdsambeck; Tasha Jones; Thomas
Leonard; Tina Sunderland

Subject:

FW: SENT ON BEHALF OFWILLIAM L. CROWLEY - Spreadbury v. Bitterroot Public Library

We disagree with the assertions in youremail below. In any event, theyare immaterial to moving the matter, including
the pretrial order, forward. The only two portions of the pretrial order which we need to work together on are the

Nature Of The Action and the Agreed Facts. If you don't agree with something that is stated, it gets removed. Also, you
can propose something different. Ifwe don't agree with it, it is not included. You can draft your own "Plaintiff's

Contentions". Those do not require agreement by the opposing party. They are included as drafted by you. Next, ifyou
disagree with what is listed as Plaintiff's trial time, just advise what length of time you expect for Plaintiff's case. That
will go in the pretrial statement. Further, you can identify whatever legal issues you believe exist, and those will be
added to the pretrial order. You are correct that the FINAL pretrial order is not due until May 31, 2012. However, custom

and practice (and the scheduling order) require the parties to work on it in advance of May 31. Consequently, please
provide us with a list of your contentions and your exhibit, discovery and witness lists, if any. We will add those to the
pretrial order. In addition, please advise whatever modifications to Nature of the Action, Agreed facts, Plaintiffs trial

time and Legal issues which you propose. Ifyou are not going to do these things, please advise so we can notify the
Court. As to your phone call, I would appreciate it if you would direct any phone calls to myself or my Partners, Tasha
Jones or Tom Leonard. My paralegal, Shannon, works very hard and is top-notch. She is a very fine woman. She doesn't
deserve to be spoken to in the way in which you spoke to her.
From: Shannon Holdsambeck

Sent: Monday, May 07, 2012 9:15 AM
To: Bill Crowley

Subject: FW: SENT ON BEHALF OF WILLIAM L CROWLEY - Spreadbury v. Bitterroot Public Library

From: Michael Spreadbury [mailto:[e-mail]]
Sent: Monday, May 07, 2012 8:46 AM
To: Shannon Holdsambeck

Cc: [e-mail]; [e-mail]

Subject: RE: SENT ON BEHALF OF WILLIAM L. CROWLEY - Spreadbury v. Bitterroot Public Library
Dear Mr. Crowley,

The Pretrial information is not due until May 31, 2012. While I fully understand you feel reshaping the information, and
rules dont apply to you committing fraud in Missoula Montana representing both an entity that does not exist, and a nonmunicipal entity such as the Hamilton Library with public funds, the US Department of Justice feels there is a large
problem here as do I.

I disagree with the pretrial order and feel it is silly to think getting away with fraud is acceptable.
Michael Spreadbury

Banned from the Bitterroot Public Libary

http://wethepeoplemt.bloqspot.com/2012/03/bitterrroot-public-library-hamilton.html
Steve Bullock's bid on the Montana Governor 2012 is UP IN SMOKE

http://www.montanaattornevqeneral.com/2012/04/up-in-smoke-steve-bullock-for-qovernor.html
l

EXHIBIT A

EXHIBIT A