Spreadbury v. Bitterroot Public Library et al

Filing 57

RESPONSE to Motion re 51 MOTION for Partial Summary Judgment DEF LEE ENTERPRISES INC'S BRIEF IN OPPOSITION TO PL'S MOTION FOR PARTIAL SUMMARY JUDGMENT AGAINST LEE ENTERPRISES filed by Lee Enterprises Incorporated. (Attachments: # 1 Exhibit FOUNDATIONAL AFFIDAVIT OF JEFFREY B. SMITH, # 2 Exhibit A - Affidavit of Stacey Mueller, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O) (Smith, Jeffrey)

EXHIBIT B

|{ayoral

X

candidate charged with trespass

Page

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RavalliRepublic.com

Mayoral candidate charged with trespass
by JOHN CRAMER - Ravalli Republic lPosted; Thursday, September 10,2009 12100 am
Hamilton mayoral candidate Michael Spreadbury pleaded not guilty Wednesday in Hamilton City Court to criminally
trespassing at the Bitterroot Public Library.

Spreadbury was issued a summons for the misdemeanor offense on Aug. 20 when he entered and remained unlawfully at the
library, where his privileges have been revoked. according to a complaint filed by City Anomey Ken Bell.
Spreadbury faces a maximum penalty ofa $500 fine, six months in jail and $92 in coun fees and surcharges.

City Court Judge Michael Reardon set an omnibus hearing for Nov, 2 -

a day before

Election Day - and released Spreadbury

on recognrzance,
Spreadbury, who requested a public defender, can't leave Ravalli County without the court's permission.

Thejudge also wamed him not to enter the library's property, where he was banned in June after insisting he be allowed to
put on reserve a copy ofa letter accusing local public officials ofroutinely denyingjustice to citizens.
Spreadbury,38, charactedzes himself as a public watchdog and champion of liee speech and civil rights who is dedicated to
exposing a vast criminal conspiracy in the Bittenoot Valley.

According to public records, police have responded l3 times since April 2008 to complaints about Spreadbury's behavior at
the library, the county administration building, the county clerk ofcourt's office, the Ravalli Republic, the Hamilton school
district, Marcus Daly Memorial Hospilal, KMSO 102.5 Mountain FM and the county fairgrounds.

All ofthe complaints allege that

he acted inappropriately. He has only been charged in connection with the library incident.

According to records, complaints by the library, county, newspaper and fair were related to Spreadbury's political issues.
Complaints from the hospital and school concemed his former employment at those places. The complaint from the radio
station concerned his all€gation that its broadcasts interfere \,vith his television reeeption.
The latest complaint to police occurred Friday night at the fairgrounds.
Deborah Rogala, the fair manager, said Spreadbury was holding a political placard and distributing "Michael Spreadbury for
Mayor" pencils near the rodeo entrance, which violated fair rules requiring vendors to stay in their booths.
She said Spreadbury became belligerent and argumentative when she explained the rules and asked him repeatedly to return

to his booth.
He initially refused, but then said, "You people saare me,

l'm leaving,"

and he ran off, Rogala said.

Spreadbury accuses govemment, law enforcement, prosecutors, .judges, the newspaper, the Iibrary, businesses, elected
officials and others ofincompetence, conuption, defamation, racketeering and other misconduct in a conspiracy contrclled by
County Attomey George Com that reaches fiom the Bitterroot Valley and Helena to Washington, D.C.
Spreadbury's concems apparently started in October 2006 when he was cited for allegedly assaulting a neighbor who had a
bum pile on or near their adjoining property line.

According to court records, ajury convicted Spreadbury ofmisdemeanor assault in August 2007 and he was sentenced to six
months injail with five months suspended and $514 in aourl costs and fees, but ajudgc threw out the conviction in January
2008 after ruling he had not received a timely trial.
Sinae then, Spreadbury has maintained he was "falsely" arrested, prosecuted and convicted and he has voiced his complaints
about "the system" at public meetings, on his Web site and in other venues.

In February, the county commission sent Spreadbury a letter warning him to stop harassing county employees and acting
disruptively.

http://ravallirepublic.com/news/article_8f847b03-f982-5835-a420-ba4ae44c789b.html?pri...

6ll2l20ll

J\4ayoral candidate charged with trespass

Page 2 of 2

The letter went out after county employees said he stood outside the county administration building, put a paper bag over his
head with the eyes cut out, held an American flag upside down - which is a sign ofdistress - and took photographs of himself.
Spreadbury apparently was protesting the clerk and recorder's handling ofhis failed recall petitions against local and state

officials.
In July, the Ravalli Republic sent Spreadbury a lener prohibiting him from coming onto its premises because ofhis behavior.
Spreadbury, who has threatcned to file lawsuits against the city, county and newspaper, denies acting inappropriately in all
the times that police have responded to complaints about his behavior.
Spreadbury is seeking to unseat incumbent Mayor Jerry Steele in the Nov. 3 election. His mayoral campaign slogan is
"Spread The Word."

According to his Web site, Spreadbury is a geologist, consultant and teacher and a former U.S. Department ofHomeland
Security officer.
Log on to SAygll!B9p!h!gl9!0 to comment on this and other stories.
Reporter John Cramer can be reached at 363-3300 or jg!a0911@13yelLilgpghli949!q.

http://ravallirepublic.com/news/article_8f847b03-f982-5835-a420-ba4ae44c789b.html?pri...

611212011

Mayoral candidate charged wiih trespass

Page

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6t12/2011

Page 2 of 4

Mayoral candidate charged with trespass

W

q11LL

Moss - Ravalli Repubtic

Hamilton mayoral candidate Michael Spreadbury pleaded not guilty Wednesday in Hamilton City
Court to criminally trespassing at the Bittenoot Public Library.
Spreadbury was issued a summons for the misdemeanor offense on Aug. 20 when he entered and
remained unlawfully at the library, where his privileges have been revoked, according to a

complaint filed by City Attomey Ken Bell.
Spreadbury faces a maximum penalty ofa $500 fine, six months in

jail and $92 in court fees

and

surcharges.

City Court Judge Michael Reardon set an omnibus hearing for Nov . 2 - a day before Election Day
- and released Spreadbury on recognizance.
Spreadbury, who requested a public defender, can't leave Ravalli County without the court's
permission.
The judge also warned him not to enter the library's property, where he was banned in June after

insisting he be allowed to put on reserve a copy ofa letter accusing local public offrcials
routinely denying justice to citizens.

of

Spreadbury, 38, characterizes himself as a public watchdog and champion of free speech and civil

rights who is dedicated to exposing

a

vast criminal conspiracy in the Bitterroot Valley.

According to public records, police have responded l3 times since April 2008 to complaints about
Spreadbury's behavior at the library, the county administration building, the county clerk of

court's office, the Ravalli Republic, the Hamilton school district, Marcus Daly Memorial Hospital,
KMSO 102.5 Mountain FM and the county fairgrounds.

All of the complaints allege that

he acted inappropriately. He has only been charged in connection

with the library incident.
According to records, complaints by the library, county, newspaper and fair were related to
Spreadbury's political issues. Complaints from the hospital and school concerned his former
employment at those places. The complaint from the radio station concerned his allegation that its
broadcasts interfere with his television reception.

The latest complaint to police occurred Friday night at the fairgrounds.
Deborah Rogala, the fair manager, said Spreadbury was holding a political placard and

distributing "Michael Spreadbury for Mayor" pencils near the rodeo entrance, which violated fair
rules re quiring vendors to stay in the ir booths.

http://ravallirepublic.com/news/article_8f847b03-f982-583

5-a420-ba4ae44c789b.html

6112/2011

Page 3

Mayoral candidate charged with trespass

of4

She said Spreadbury became belligerent and argumentative when she explained the rules and
asked him repeatedly to retum to his booth.

He initially refused, but then said, "You people scare me, I'm leaving," and he ran off, Rogala
said.

Spreadbury accuses government, law enforcement, prosecutors, judges, the newspaper, the library,
businesses, elected officials and others of incompetence, corruption, defamation, racketeering and

other misconduct in a conspiracy controlled by County Attomey George Com that reaches from
the Bitterroot Valley and Helena to Washington, D.C.
Spreadbury's concerns apparently started in October 2006 when he was cited for allegedly
assaulting a neighbor who had a bum pile on or near their adjoining property line.

According to court records, ajury convicted Spreadbury of misdemeanor assault in August 2007
and he was sentenced to six months in jail with five months suspended and $514 in court costs and
fees, but ajudge threw out the conviction in January 2008 after ruling he had not received a timely
trial.
Since then, Spreadbury has maintained he was "falsely" arrested, prosecuted and convicted and he
has voiced his complaints about "the system" at

public meetings, on his Web site and in other

venues.

In February, the county commission sent Spreadbury a letter warning him to stop harassing county
employees and acting disruptively.
The letter went out after county employees said he stood outside the county administration

building, put

with the eyes cut out, held an American flag upside down which is a sign of distress - and took photographs of himself.
a paper bag over his head

Spreadbury apparently was protesting the clerk and recorder's handling of his failed recall

petitions against local and state officials.

In July, the Ravalli Republic sent Spreadbury a letter prohibiting him from coming onto its
premises because of his behavior.
Spreadbury, who has threatened to file lawsuits against the city, county and newspaper, denies

acting inappropriately in all the times that police have responded to complaints about his behavior.
Spreadbury is seeking to unseat incumbent Mayor Jerry Steele in the Nov. 3 election. His mayoral
campaign slogan is "Spread The Word."

According to his Web site, Spreadbury is a geologist, consultant and teacher and a former U.S.
Department of Homeland Security officer.

http:i/ravallirepublic.com/news/article_8f847b03- f982-5835-a420-ba4ae44c789b.html

6t12/2011

Page 4 of 4

Mayoral candidate charged with trespass

Log on to RavalliRepublic.com to comment on this and other stories.
Reporter John Cramer can be reached at 363-3300 or [e-mail].

Posted in News on Thursday, September 10, 2009 l2:00 am Updated: 2:28pm.
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