Spreadbury v. Bitterroot Public Library et al

Filing 63

REPLY to Response to Motion re 51 MOTION for Partial Summary Judgment filed by Michael E. Spreadbury. (APP, )

Michael E. Spreadbury
700 S. 4th Street

FILED

Hamilton, MT 59840

JUL - 6 2011
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Telephone: [phone]

iSUWa&illWiiouiA­

[e-mail]

Pro Se Plaintiff
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MONTANA

MISSOULA DIVISION

Cause No.: CV-11-6'f-DWM-JCL
MICHAEL E. SPREADBURY

)
)

RESPONSE TO LEE

v.

)

DEFENDANT PLEADING

BITTERROOT PUBLIC LIBRARY,

)

IN RE: SUMMARY

CITY OF HAMILTON,

)

JUDGMENT

LEE ENTERPRISES INC.,

)

BOONE KARLBERG PC,

)

Plaintiff

)

Defendants

Comes now Plaintiff with response to Lee Enterprises with respect to summary
judgment before this Honorable Court.
Statement ofFacts
1. There is no "Library Property" (i.e. private property) in the City ofHamilton.

Answer to Defense, Summary Judgment

Cause CV·ll·61-M-DWM

June 28, 2011

2. A Public library, publically tax supported who leases building and a
municipality who owns the property at 306 State St. site ofthe Bitterroot Public
Property (original block #18 City of Hamilton) is taxpayer supported and therefore
is PUBLIC PROPERTY. This site is nothing but public property, not "Library
Property."
3. When a business like the Ravalli Republic Hamilton conducts business while
Spreadbury crafts handwritten note July 9,2009 requesting defamatory material
removed from their paper, there was no abusive language, not privileged court
pleading per Montana Code [I don't care to look it up anymore].
4. Substantial evidence, and undisputed fact from LR 56.1 is the United States
Constitution, ultimate law in the United States whereby no law can abridge citizen
right to peaceful assembly.
5. Spreadbury made one appointment with Library , "several interactions" is a false
statement, Germaine to republishing false information by Defendant Lee
Enterprises, and their Defense Counsel.
5. Defendants abridged Spreadbury right to peaceful assembley in Hamilton
Montana August 20, 2009.
6. Defendants are inserting non-relevant articles and information to this court
concerning my free speech November 4, 2009.
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Answer to Defense, Summary Judgment

Cause CV-ll~61-M-DWM

June 28, 2011

7. Spreadbury believes that the Montana law school does not teach its students
about the US Constitution, its protections, nor basic principles of relevancy.
8. Summary Judgment is proper before this court due to peaceful assembly, nonpleading for functional approach to immunity by Defense, and sworn duty of this
court to uphold the United States Constitution.
9. Spreadbury has right to peaceful assembly, abidged by all Defendants, acting in
color of law and violating right established in Amendment 1 US Constitution to
which 42 USC §1983 proper in this case.
10. This court is asked to uphold Spreadbury's peaceful assembly August 20,2009
and grant Summary Judgment for the Plaintiff.

~
Respectfully submitted thisZ5' day of Ju e, 2011

e Plaintiff

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