Spreadbury v. Bitterroot Public Library et al
Filing
90
AMENDED COMPLAINT against Lee Enterprises Incorporated, Jerry Steele, filed by Michael E. Spreadbury. (APP, )
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J:IL£O
Michael E. Spreadbury
700 South Fourth St.
MAY 04
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Hamilton, MT 59840
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TeL (406) 363-3877
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BtPA,iTt/Cit;
2011
mS12read@hotmail.com
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IN THE UNITED STATES DISTRICT COURT
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FOR THE DISTRICT OF MONTANA
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MISSOULA DIVISION
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----------------------------------------------------------------------------------------------------
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MICHAEL E. SPREADBURY,
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Plaintiff
)
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v.
)
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BITTERROOT PUBLIC LIBRARY, )
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CITY OF HAMIL TON,
LEE ENTERPRISES INC.,
)
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BOONE KARLBERG P.C.,
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Defendants
2nd AMENDED COMPLAINT
)
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Cause: 9:2011- CV-II-0064-M-DWM
)
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This cause of action is for defamation, intentional infliction of emotional distress
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(lIED), negligent infliction of emotional distress (NIED), civil conspiracy to
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deprive constitutional rights 42 USCA § 1983, negligence in City of Hamilton,
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Ravalli County, State of Montana. Public fraud is being committed by Defendant
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Bitterroot Public Library by accepting ineligible funds as a municipality in this
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cause of action, Defendant Boone Karlberg PC is accepting these funds as counseL
"
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2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-064-M-OWM
5/5/2011
Jurisdiction
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The US District Court for Montana has jurisdiction in this matter since the
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constitutional violations, defamation, negligence occurred within the State of
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Montana which is within the confines of this courts domain. All parties in this
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case, described Id. at 41 paragraphs 1-24 below reside within the Missoula
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District of The US District Court for Montana. Jurisdiction is described within 28
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USCA §1391 (b) for local issue, 28 USC§ 1391(a)(3) for defamation, 28 USC§
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1332(a) for claim over $75,000,28 USC§ 1343 for civil rights, and 28 USC§ 1367
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for state claims.
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The Montana District has jurisdiction over constitutional torts as prescribed in 42
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USCA § 1983,42 USCA § 1985. The Federal question raised is brought under 28
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USCA § 1331,28 USCA § 1343(3).
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There are state questions which should be heard in a state court, and proper remand
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is requested for lIED, NIED causes as pled herein. This case was pled in front of
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the Montana 21 st Judicial District due to state issues which do not have jurisdiction
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in a Federal Court. Motions to dismiss by Defendants are improper prior to
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Plaintiff amending complaint for Federal jurisdiction, court is asked to set aside.
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PARTIES:
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2N~Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-064-M-OWM
5/5/2011
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1. Michael E. Spreadbury (hereafter "Spreadbury"), Plaintiff of 700 S. 4th Street,
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Hamilton Montana, is a resident of the City of Hamilton, Montana, and is
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considered a person in the State of Montana.
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2. Dr. Robert Brophy, resident of Montana, acting under individual duties,
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Bitterroot Public Library Chairman of the Trustee Board, responsible officer
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of the Bitterroot Public Library, acting in color of law, considered a person in
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the state of Montana.
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3. Trista Smith, resident ofMontana, current director of the Bitterroot Public
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Library as a replacement for Gloria Langstaff; acting in color of law, in
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individual duties, is considered a person in Montana.
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4. Nansu Roddy, resident of Montana, assistant director ofthe Bitterroot Public
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Library, acting in color of law, in individual duties, is considered a person in
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the State ofMontana.
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5. The Bitterroot Public Library (hereafter "public library"), an independent
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district, bound by the Interstate Compact as per Montana Code Annotated
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MCA§ 22-1-601. Under subsection 3(e) of this compact, an independent
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district can sue and be sued; in this jurisdiction an independent library district
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is considered a person in the State of Montana.
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2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-064-M-OWM
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5/5/2011
6. Jerry Steele, executive director of the City of Hamilton as elected Mayor,
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acting in color of law, resident of Montana, is considered a person in the State
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of Montana.
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7. Steve Snavely, Sergeant in the Hamilton Police Department, acting in color of
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law, and in individual duties, resident of Montana, is considered a person in
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the State of Montana.
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8. Detective Steven Bruner-Murphy, (hereafter: "Detective Murphy") resident of
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Montana, employed by Hamilton Police Department, acting in color of law, in
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individual duties, is considered a person in the State of Montana.
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9. Hamilton Police Chief Ryan Oster, resident of Montana, acting in color of
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law, in individual duties, and as official policymaker for the City of Hamilton,
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Montana; Chief Oster is considered a person in the State ofMontana.
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lO.Kenneth S. Bell, Hamilton City Attorney, acting in color of law, in individual
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duties, and that as official policy maker of the City of Hamilton, resident of
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Montana, considered a person in the State of Montana.
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11.Jennifer B. Lint, resident of Montana, Deputy Hamilton City Attorney, acting
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in color of law, in individual duties is considered a person in the State of
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Montana.
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2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-11-064-M-OWM
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I2.City of Hamilton, MT is considered a person in the State of Montana.
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I3.Stacey Mueller, resident of Montana, publisher of The Missoulian newspaper,
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acting in color of law, in individual duties, is responsible officer for Lee
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Enterprises Inc., considered a person in the State of Montana.
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I4.K.risten Bounds, resident of Montana, acting in color of law, in individual
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duties, former publisher of Ravalli Republic newspaper, is considered a
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person in the state of Montana.
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IS.Perry Backus, former editor Ravalli Republic newspaper, acting in color of
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law, resident of Montana, is considered a person in the State of Montana.
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I6.The Missoulian Newspaper, an affiliate of Lee Enterprises Inc., a Montana
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Corporation. As a Montana Corporation, is considered a person in the State of
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Montana.
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I7.The Ravalli Republic Newspaper, affiliate of Lee Enterprises Inc., a Montana
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Corporation. As a Montana Corporation, is considered a person in the State of
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Montana.
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I8.The Billings Gazette, affiliate of Lee Enterprises Inc, a Montana Corporation
is considered a person in the State of Montana.
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2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-II-064-M-OWM
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19.The Helena Independent Record, affiliate of Lee Enterprises Inc., a Montana
Corporation is considered a person in the State of Montana.
20.The Great Falls Tribune, affiliate of Lee Enterprises Inc. a Montana
Corporation is considered a person in the State of Montana.
21. The Montana Standard, affiliate of Lee Enterprises Inc., a Montana
Corporation is considered a person in the State of Montana.
22. William L. Crowley, resident of Montana, partner and responsible officer for
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Boone Karlberg PC law firm, acting in color of law, in individual duties, is
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considered a person in the State of Montana.
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23.Natasha Prinzing-Jones (hereafter: "Jones") resident of Montana, associate at
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Boone-Karlberg PC law firm, acting in color of law, considered a person in
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the State of Montana.
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24.Boone Karlberg PC, as a Montana Corporation is considered a person in
Montana.
Prima Facie Evidence, 42 USC §1983; Civil rights
25.The Plaintiff believes, and is prepared to show with a preponderance of the
evidence that the Defendants listed, together, individually, and as pairs
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2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-064-M-OWM
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conspired to deprive the Constitutional rights of Plaintiff. These rights are not
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limited to the Montana Constitution Article II, s. 4,6,7,17; and US
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Constitution Amendments I, V, and XIV in actions within Ravalli County,
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State of Montana, United States of America.
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26.Under the color of law, two of more Defendants wished to contrive, and
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execute criminal charges to (1) reap injury to Plaintiff character, and (2) affect
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Plaintiff employment, and (3) permanently alter public perception of Plaintiff
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to interfere with an election; keeping Plaintiff out of office, vocational
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pursuits through the course of action described in this complaint.
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27.The Defendants conspired to deprive the Plaintiff of his constitutional rights,
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through one or more unlawful acts, Plaintiff has incurred irreparable,
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substantial, and actual damages as a result; a property interest.
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28.No probable cause existed in criminal actions against the Plaintiff, executed
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by the Defendants. Common law issues are presented to the court, in addition
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to Defendants filing, contributed to criminal charges without probable cause
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filed against the Plaintiff, which contained substantial deprivations ofPlaintiff
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fundamental constitutional rights.
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29.Defendants acted with actual malice, callous indifference, and without equal
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protection or due process under the law which led to actual damages to the
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Plaintiff as described herein.
FACTUAL BACKGROUND:
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30.Spreadbury resides within City of Hamilton, County of Ravalli, State of
Montana.
31.Spreadbury met with Ms. Nansu Roddy to admit correspondence to be
admitted into public library temporary reserve holdings in May/June 2009.
32.Bitterroot public library (hereafter "public library") employee Roddy, in
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violation of policy, and public library's adopted American Library
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Association policies refused to accept Spreadbury's submission.
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33.Spreadbury utilized administrative remedies available per Roddy for
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Spreadbury to meet with library director of public library on or around June
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10, 2009.
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34.Director made appointment, cancelled, and refused to meet with Spreadbury.
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35.Director of Public library published, distributed letter June 11,2009 banning
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Spreadbury from library unlawfully, in violation of Montana Code Ann. MCA
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2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV~ll~064-M-DWM
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22-1-311 for use of library, privileges, Spreadbury's procedural due process,
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per well accepted Montana statute.
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36.Spreadbury presented library, Hamilton Police Department with sworn
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affidavit that Spreadbury had never been asked to leave public library, or
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made disruption, any willful violation of rules occurred in past 48 hours, 4
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years dated June 12,2009.
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37.Spreadbury submitted Reconsideration Request Form July 8, 2009 for
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submission request; public library did not respond to own established
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administrative remedy available to the public, Spreadbury.
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38.On July 9,2009 Spreadbury sat in waiting area of Ravalli Republic, as
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business was conducted, Spreadbury constructed a hand written request to
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Publisher Bounds not to defame Spreadbury. Ravalli Republic called
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authorities, said Spreadbury was making threats, a false and defamatory act.
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39.On July 9, 2009 Chief Ryan Oster informed Spreadbury that the Ravalli
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Republic did not want Spreadbury to have further entry at the storefront at 232
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W. Main St. Hamilton, Montana. Ravalli Republic personnel never aSKed
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Spreadbury to not return, or that his conduct was not appropriate.
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2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-11-064-M-OWM
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5/5/2011
40.Spreadbury sent July 15, 2009 letter to public library, Hamilton Police
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Department (HPD), Public Library board member citing Montana Statute
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MeA 22-1-311reinstating privileges to public library; public library Director
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has no lawful authority to remove privileges of Plaintiff.
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41.Public library board, public library, HPD did not respond to the July 15, 2009
correspondence from Plaintiff.
42.Defendant Brophy made known false statements, comments to library staff
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about Spreadbury which were published in electronic form, communicated in
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verbal form.
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43.On August 20, 2009 Spreadbury sat peacefully on public property outside
public library owned by the City ofHamilton, MT.
44.Sgt. Steve Snavely, Hamilton Police approached Spreadbury with June 11,
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2009 letter from public library, accused Spreadbury of trespass on public
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property on August 20, 2009.
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45.Sgt. Snavely intimidated witnesses to photograph where Spreadbury alleged to
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have stood in park August 20, 2009, attempt to convict Spreadbury, trespass
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on public property.
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2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-064-M-DWM
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5/5/2011
46.Ken Bell, Hamilton City Attorney on or around September 2, 2009 wrote a
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sworn complaint that Spreadbury was trespassing on Public Property August
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20,2009.
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47.Spreadbury was not given an opportunity to be heard at public library, lost
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privileges, due to not being allowed on the public library grounds, facility
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since early summer of 2009.
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48.Plaintiff summoned September 9,2009 with Misdemeanor Criminal Trespass
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on private property, property is publically owned by the City of Hamilton to
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which Plaintiff is taxpayer, has property, liberty interests in enjoying library
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privileges.
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49.0n September 10, 2009 the Ravalli Republic, a Lee Enterprise Inc., published
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a front page article with Spreadbury's likeness in color photo with full name
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and headline "Mayoral Candidate charged with Trespass".
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50.In an online comment published with the September 10, 2009 article, a
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comment was published on www.ravallirepublic.com stating that Spreadbury
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"suffers serious psychological problems and needs to seek help."
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5/5/2011
51.A separate comment published by the Ravalli Republic September 10, 2009
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story said "Spreadbury is ready for Warmsprings (referring to the Montana
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State Mental Hospital)".
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52.The Trespass on public property was republished in several Lee Enterprise
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newspapers within the State of Montana, named as parties to this cause of
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action.
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53.A photographer from the Ravalli Republic admitted to the Plaintiff that his
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editor required a picture of Spreadbury for the September 10, 2009 article.
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54.0n October 19,2009 Detective Murphy, HPD made report of Spreadbury
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stalking public library director; published sighting ofDirector former website:
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www.Bitterroot-rising.org with report # 209CR0001589 a deprivation of
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Spreadbury's established right to speak:.
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55.Spreadbury prosecuted for sitting peacefully on public property by Defendant
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Bell, Defendant Lint City of City of Hamilton in violation of established right.
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56.Bell contacted NCIC criminal database to unlawfully got criminal history on
Plaintiff for protected activity of peaceful assembly on public property.
57.Bob Brophy, Chairman BPL Board did send Plaintiff letter dated February 23,
2010 stating board was removing Spreadbury's privileges although never
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2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. at CV~11-064-M-DWM
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asked to leave public library, or demonstrated willful violation ofrules:
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requirement per Montana Code Ann MCA§ 22-1-311.
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58.Spreadbury's procedural due process rights deprived by Brophy by not having
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any ability to be heard, administrative remedy to contest action which
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deprived Spreadbury liberty interest in entering library as taxpayer in
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Hamilton, MT in 2009.
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59.Defendant Boone Karlberg, PC did publish false light information in several
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published pleadings before the Supreme Court for the State ofMontana
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stating Spreadbury frequently returned to library, although not a crime,
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published false light of actual events that occurred at the public library with
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respect to Spreadbury/public library situation.
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60.Defendant Boone Karlberg PC published several instances of false light
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information, defamation in re: criminal charge of trespassing with respect to
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Spreadbury after Boone Karlberg PC knew charge dropped August 16,2010
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within court pleadings published in District, Supreme Courts for the State of
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Montana after criminal charge was dismissed against Plaintiff.
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61.Defendant Boone Karlberg PC knew or should have known that sitting on
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public property is not a crime, charge dismissed known as Defendant Bell,
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2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-064-M-OWM
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client, employees, agents of Defendant Boone Karlberg PC sworn to uphold
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the Montana, US Constitution as Bar licensed lawyers.
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62.Defendant Boone Karlberg PC, party to cause of action William L. Crowley
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Esq. did publish in pleading Spreadbury threatened Defendant Bell, when no
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evidence of threat exists in correspondence to Bell. Crowley, Jones of Boone
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Karlberg PC engaging in malicious defamation of Spreadbury.
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63.Defendant Boone Karlberg PC acting in civil conspiracy with client Bell when
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defaming Spreadbury in published pleadings to courts in State of Montana.
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64.As Defendants continue to re-publish August 20, 2009 peaceful assembly on
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public property as criminal act by Spreadbury, causes severe emotional
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distress per well established standards before the Supreme Court for the State
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of Montana.
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65.Defendants knew, should have known that peaceful assembly on public
property is never a crime in Montana, United States.
66.Defendants knew, should have known that trespass charge was dismissed
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August 16,2010 by Honorable John Larson 4th District Court in 21 st District
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Cause No. DC-1 0-26 with Plaintiff as Defendant.
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5/5/2011
67.Every re-publication of false infonnation is considered a new case for libel
against the Defendants.
68.Defendant Perry Backus, Lee Enterprises on or around August 20,2010
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created four (4) different versions of a story pertaining to criminal trespass
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charges against Spreadbury originating from Defendant Ravalli Republic
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Newspaper in Hamilton, Montana.
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69.Defendant Perry Backus, Lee Enterprises made two Associated Press (AP)
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stories of the 4 created articles pertaining to Spreadbury and criminal trespass
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on public property.
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70.Defendant Perry Backus, Lee Enterprises Inc. published false light: Supreme
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Court "upheld" library ban, decision in Supreme Court for Montana in re:
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order ofprotection out of time appeal, order of protection, not trespassing, or
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unlawful ban from library of Spreadbury.
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71.A national newspaper published Spreadbury's name and criminal trespass
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charge based upon the Ravalli Republic, Lee Enterprises Inc. AP submissions.
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Distribution is 1.8 million readers daily, national, international distribution.
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72.Six (6) Lee Enterprise affiliates, party to this case in the State of Montana
published a version of 4 articles on or around August 20, 2010 origin from the
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i'tO Amended Complaint
Spreadbury v. Bitterroot Public Library et. at. CV-ll-064-M-OWM
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Ravalli Republic Newspaper, each affiliate has ability to publish defamatory
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comments about Plaintiff.
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73.Due to AP coverage, TV, radio, newspaper, and other news outlets throughout
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the State of Montana covered Spreadbury criminal trespass charge on or
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around August 20, 2010. Re-publication, defamation of Spreadbury's alleged
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criminal act, protected activity of peaceful assembly from August 20, 2009 is
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in-calculable damage to character, not reversible.
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74.Spreadbury was no longer considered a public official at 20:00hours
November 3,2009 as election for City of Hamilton mayor completed.
75.Defendants act in concert to devastate Spreadbury's character, "shocks
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conscience" that protected act would be criminalized, used to defame, destroy
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Spreadbury's character to the extent Defendants propagated false issue.
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76.Spreadbury was running for office at time of peaceful assembly August 20,
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2009 yet that does not allow for actual, malicious malice of Defendants
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defamation pled herein during and after Plaintiff was candidate for office.
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77.The truth can be actual malice in libel, defamation cases.
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2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. at. CV-ll-064-M-DWM
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78.Spreadbury had permanent injury to character to such an extent that severe
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and certain economic loss ensued from unlawful prosecution of peaceful
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assembly on public property in City of Hamilton, MT by Defendants.
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79. The acts of the Defendants described in paragraph 1 through 94 of this
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Complaint were done willfully, maliciously, outrageously, deliberately, and
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purposely with the intention to inflict emotional distress upon Plaintiff and
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were done in reckless disregard of the probability of causing Plaintiff
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emotional distress, these acts did in fact result in severe and extreme
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emotional distress to Spreadbury.
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80.As a direct and proximate result of the Defendant's acts alleged herein,
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Spreadbury was caused to incur severe and grievous mental and emotional
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suffering, fright, anguish, shock, nervousness, and anxiety. Plaintiff continues
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to be fearful, anxious, and nervous, specifically but not exclusively regarding
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the future possibility of wrongful defamation, summons without crime, and
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prosecution for criminal act without due cause.
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81. As a proximate result of the Defendant's actions alleged herein, Spreadbury
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has had his capacity to pursue an established course of life permanently
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destroyed by Defendants. Spreadbury has suffered permanent damage to
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lifestyle and professional life as a result of Defendant activity described in
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2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. at. CV-11-064-M-OWM
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paragraph 1 through 94. Plaintiff suffered severe emotional distress inflicted
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by actual malice of the named Defendants.
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82. This severe emotional distress was a reasonably foreseeable consequence of
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actions by Defendants on or about June 11, 2009 and ongoing. Defendants
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did not take reasonable care to avoid wrongful prosecution of Spreadbury,
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appeared to have contrived the criminal action against Spreadbury giving no
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conscience to their duties as officers of the court, in color of law.
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Spreadbury's peaceful assembly on public property was outrageously
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exaggerated, manipulated, and exacerbated by the Defendants with actual
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malice with intent to defame, destroy Spreadbury's character causing severe
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and permanent emotional distress.
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83.Defendants had position of authority over Spreadbury, or in position to affect
Spreadbury's established interests.
84.Defendants conduct was an abuse of power, position, even without authority
over Spreadbury, had position to affect Spreadbury.
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85.Defendants certain of infliction on Spreadbury, acted recklessly, outrageously
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with deliberate disregard of high degree of probability of emotional distress to
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Spreadbury.
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2ND Amended Complaint Spreadbury v. Bitterroot Public library et. al. CV-ll-064-M-OWM
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5/5/2011
86.Defendants acted with heatless, flagrant, and outrageous acts; extreme liability
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arises for Defendants with respect to emotional distress in the State of
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Montana.
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87. Mayor Jerry Steele, within office of executive of Hamilton, MT did convey
that he had knowledge that Plaintiff is Schizophrenic, a slanderous statement.
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88. Plaintiff has not ever been diagnosed with Schizophrenia.
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89. In a Ravalli Republic article dated August 9, 2010 false statements are made
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about criminal behavior, prior lawsuits filed, and comments made by Plaintiff
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in oral arguments before Judge Larson, in the 21 st Judicial district court.
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90. Plaintiff asked for correction of Ravalli Republic and then editor Perry
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Backus.
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91. Defamation by Defendant Lee Enterprises on August 24, 2010 "correction"
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of August 9,2010 article by then Editor Perry Backus publishing false light
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that Supreme Court order "upheld" Ban by Defendant Bitterroot Public
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Library, actual denial of out of time appeal, after August 9th article was
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written. False Light by Defendant Lee Enterprises, and defamation.
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92. Defendant Boone Karlberg defames Plaintiff in Defendants April 26, 2011
Answer to this court pg. 9 ,26 referred sentence is stayed, under appeal, false
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2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-064-M-OWM
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light due to August 16, 2010 dismissal of trespass charge and 60 day lapse to
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October 15,2010 sentencing in DC-09-1S4 in the 21 st Judicial District.
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93. Defendant Boone Karlberg PC alleges false information of crime in writing
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Defendants answer Apri126, 2011 pg. 9 ~27 as written Plaintiff "suggested he
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is current or past member ofthe FBI ...." Defendant alleging criminal behavior
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by Plaintiff (impersonating Federal law enforcement).
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94. The continued defamatory falsehoods, malicious prosecution for protected
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right, and conspiracy between Defendants has caused irreparable reputational,
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and vocation harm to Plaintiff who seeks relief in this honorable court.
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Negligence-Brophy/public Iibrary--Count 1
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95. Plaintiff repeats and realleges paragraphs 1-94 ofthis complaint as if fully set
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herein.
96. Library Board chairman Brophy, acting in official duties in color of law,
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wrote letter ofFebruary 23,2010 removing Spreadbury's library privileges
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without cause.
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97.Brophy/public library knew or should have known that Spreadbury was never
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asked to leave public library, willfully violated any rules of the public library.
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2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-11-Q64-M-OWM
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98.Brophyfpublic library did not allow Spreadbury administrative remedy to the
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allegations of misconduct~ allowed arbitrary removal of privi1eges~ did not
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proceed to administrative remedy for submission to library, ignored
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Spreadbury~s
written reconsideration request.
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99.Brophy's actions constituted negligence as chairman ofpublic library Board.
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100. As a result of Brophy' sf public library's negligence, Spreadbury had actual
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damages.
Abuse of Process! Brophy-public library--Count 2
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101. Plaintiff repeats, realleges paragraphs 1-100 of this complaint as if fully set
herein.
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102. Board Chairman Brophy in his administrative duties as chairman of BPL
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board wrote letter to remove Plaintiffs library privileges on February 23,
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2010.
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103. The proceeding was regular act on the part of Brophy, but not proper in the
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regular conduct of library board chairmen abiding by all laws to remove
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privileges of patrons.
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104. Due to Brophy's abuse of process at the public library, Plaintiff incurred
actual damages.
Procedural Due Process/14th Amendment-Brophy/ public Iibrary-Count 3
105. Plaintiff repeats and realleges paragraphs 1-104 as if fully set in this
complaint herein.
106. Brophy, as chairman ofLibrary board wrote Feb. 23, 2010 letter to Plaintiff
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which did not allow a remedy for Plaintiff to speak to the allegations of
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misconduct at the Library.
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107. Brophy upheld Director's June 11, 2009 letter which unlawfully took
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Plaintiff library privileges without remedy to answer the allegations of
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misconduct at library.
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108. Public library did not respond to Spreadbury's July 8, 2009 "Request for
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Reconsideration" form, nor administrative process for Spreadbury's
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submission.
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109. Since Brophy did not allow an administrative remedy for Plaintiff to address
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Board of library, other remedy, it violated Plaintiffs right to administrative
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remedy, procedural due process, or be heard on alleged deprivations of rights
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from the public library.
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I 10. Due to Brophy's, public library lack of procedural due process with respect
390
to public library privileges, request for material submission, it violated
391
Plaintiff established right to Procedural Due Process, Plaintiff incurred actual
392
damages.
393
394
395
396
397
398
DefamationlDefamation Per Se-Bropby/publie Iibrary--Count 4
III. Plaintiff repeats and realleges paragraphs 1-110 as if fully set in this
complaint herein.
112. Brophy communicated a statement about Plaintiff, in writing, orally in
official meeting, which was distributed throughout library staff.
113. Communication offalse information unprivileged, altered perception of
399
library staff as they interacted with Plaintiff, and constituted Defamation and
400
Defamation Per Se.
401
402
403
404
405
114. As a result of Brophy's Defamation and Defamation per se as officer of
public library, Plaintiff had actual damages.
Misrepresentation-Bropby-publie library--Count 5
115. Plaintiff repeats, realleges paragraphs 1-114 as if fully set forth in this
complaint.
23
2ND Amended Complaint Spread bury v. Bitterroot Public Library et. al. CV-11-064-M-OWM
5/5/2011
406
116. In February 23, 2010 letter to Plaintiff, Brophy misrepresented authority of
407
Library Board, Library director to abridge peaceful assembly in a publically
408
owned park, and to remove a patrons privilege to use a public library
409
respectively.
410
117. A Library Board only has the authority to remove a privilege of a patron
411
who willfully violates the rules of the library under MeA §22-1-311 (Use of
412
Library-Privileges).
413
414
415
118. Plaintiff was never asked to leave the library by staff, director, or law
enforcement.
119. Due to Brophy's misrepresentation, Plaintiff incurred actual damages.
1st Amendment-Roddy/public library-Count 6
416
417
418
419
420
421
422
120. Plaintiff repeats, realleges paragraphs 1-119 as if fully set forth in this
complaint.
121. Public Library staff Roddy did refuse Spreadbury's submission to the public
library.
122. Public library policy requires no rejection of written material by "right to
read", freedom of speech requires acceptance of material not profane, illicit.
24
2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-064-M-OWM
423
5/5/2011
123. By refusing Spreadbury's submission, accepted in a member Library in
424
Montana, Public LibrarylRoddy violated Spreadbury's right to speak, petition
425
government as protected in Amendment 1, US Constitution, as a result
426
Spreadbury suffered actual damages.
427
428
429
Malicious Prosecution-Public Library, City of Hamilton---Count 7
124. Plaintiff repeats, realleges paragraphs 1-124 as if fully set forth in this
complaint.
430
125. A judicial proceeding was commenced and prosecuted against Spreadbury.
431
126. The public library, City of Hamilton responsible for instigating, prosecuting,
432
and/or continuing the proceeding.
433
127. Public library, City of Hamilton acted without probable cause.
434
128. Public library, City of Hamilton actuated by actual malice.
435
129. The judicial proceedings terminated favorably for Spreadbury.
436
130. As a result of the Defendant public library, City of Hamilton actions,
437
Spreadbury sustained actual damages.
438
Tortious interference with prospective Economic Advantage
439
Defendants--Count 8
25
2ND Amended Complaint Spreadburyv. Bitterroot Public Library et. aL CV-11-064-M-OWM
440
441
442
443
5/5/2011
131. Plaintiff repeats, realleges paragraphs 1-130 as if fully set forth in this
complaint.
132. Defendants committed intentional and willful acts calculated to cause
damage to Spreadbury's reputation, and prospective economic advantage.
444
133. Defendant acts were done with actual malice, willful purpose of causing
445
damage or loss to Spreadbury without right or justifiable cause on the part
446
of the actors.
447
448
449
450
451
134. Due to Defendant's tortious interference, Spreadbury has suffered actual
damages.
"Policy or Custom" Policymaker Bell, l st,14 tb Amendments---Count 9
135. Plaintiff repeats, realleges paragraphs 1-135 as if fully set forth in this
complaint.
452
136. Defendant Bell, department head and official policymaker made new policy
453
for City of Hamilton by deciding Spreadbury's peaceful assembly on public
454
property manifested misdemeanor criminal trespass on August 20, 2009 by
455
way of sworn complaint to court.
26
2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-Q64-M-OWM
5/5/2011
456
137. Due to official policy of Defendant Bell by sworn information to the court
457
September 2, 2009, Spreadbury's right to peaceful assembly, protected Art. II
458
s. 6 Montana Constitution, 1st Amendment US Constitution deprived by
459
official policy of City ofHamilton, Montana.
460
138. As a result of Bell's official policy, Spreadbury would not enjoy equal
461
protection of the laws as protected in Art. II s. 4 Montana Constitution, 14th
462
Amendment, US Constitution.
463
139. As a result of official policy created by Policymaker Bell, City of Hamilton,
464
Spreadbury suffered actual damages by deprivation of established right.
465
Policy of Custom-Amendment 5, 14--City of Hamilton--Oster-Count 10
466
467
468
140. Plaintiff repeats, realleges paragraphs 1-139 as if fully set forth in this
complaint.
141. HPD Chief Oster, official policymaker, City of Hamilton made new policy:
469
asked Spreadbury to not enter storefront when no adverse or criminal behavior
470
occurred at the Ravalli Republic business, 232 W. Main St Hamilton,
471
Montana on July 9,2009.
27
2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-064-M-OWM
472
5/5/2011
142. By asking Spreadbury to not enter Ravalli Republic business without cause,
473
Oster deprived Spreadbury liberty interest, equal protection, protected in
474
Amendment 5,14 US Constitution.
475
476
143. As a result of official policy of City of Hamilton by policymaker Oster,
Spreadbury sustained actual damages.
Negligence-City ofHamiltonlBeIl---Count 11
477
478
479
480
481
144. Plaintiff repeats, realleges paragraphs 1-143 as if fully set forth in this
complaint.
145. Defendant Bell knew or should have known sitting on public property is not
a cnme.
482
146. Defendant Bell, knowing peaceful assembly, sitting at library not a crime
483
contacted national crime database, NCIC; adversely affects professional
484
employment for Spreadbury.
485
147. Citing Spreadbury for a crime for sitting on public property constitutes
486
negligence on the part of Bell, deprives Spreadbury right to peaceful
487
assembly, equal protection.
488
148. As a result of Bell's negligence Spreadbury suffered actual damages.
28
2ND Amended Complaint Spreadbury v. Bitterroot Public library et. al. CV-ll-064-M-DWM
Negli&ence, City of Hamilton/Snavely-Count 12
489
490
491
492
493
5/5/2011
149. Plaintiff repeats, realleges paragraphs 1-148 as if fully set forth in this
complaint.
150. Sgt. Snavely HPD knew, or should have known peaceful assembly on public
property is a protected right in Montana, US Constitution, not a crime.
494
151. Sgt. Snavely negligent in his actions August 20, 2009, ongoing in accusing
495
Spreadbury of criminal trespass while peacefully assembled on public
496
property in Hamilton, MT.
497
152. As a result of Snavely's negligence, Spreadbury suffered actual damages.
Negligence, City of Hamilton-Murpby-Count 13
498
499
500
501
153. Plaintiff repeats, realleges paragraphs 1-152 as if fully set forth in this
complaint.
154. Detective Murphy, knowingly sent several written police reports to City
502
Attorney Bell for consideration of charges when no crime occurred, reports
503
"cleared" by HPD.
29
2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-064-M-OWM
504
5/5/2011
155. Detective Murphy knew, or should have known Spreadbury did not commit
505
a criminal act with respect to the public library, especially when HPD officers,
506
Murphy cleared reports.
507
156. Detective Murphy knowingly did a domain search to on a website owned by
508
Spreadbury obtain personal information on Spreadbury when no crime was
509
committed.
510
511
157. As a result of Detective Murphy's negligence, Spreadbury suffered actual
damages.
th
512
Freedom to Speak/1 st Amendment, Abuse of Power/14 Amendment
513
HPD Det. Murphy-Count 14
514
515
158. Plaintiff repeats, realleges paragraphs 1-157 as if fully set forth in this
complaint.
516
159. Defendant HPD Detective Murphy investigated, published police report,
517
investigated Spreadbury for stalking for mentioning a "sighting" of public
518
library director on a website.
519
520
160. Spreadbury is free to speak in Hamilton, Montana, has a compact to the
United States.
30
2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll"()64-M-OWM
5/5/2011
521
161. Detective Murphy sent information to City Attorney Bell to consider charges
522
on Spreadbury when it was known by HPD that no criminal acts transpired.
523
162. Actions ofDetective Murphy demonstrate actual malice toward Spreadbury,
524
an example of abuse of power, oppressive government as protected in
525
Amendment 14 US Constitution.
526
163. Due to Murphy's deprivation of protected free speech, abuse ofpower:
527
recommending charges, investigating stalking on protected right, Spreadbury
528
had actual damages.
Negligence--Crowley/JonesiBoone Karlberg-Count 15
529
530
531
532
164. Plaintiff repeats, realleges paragraphs 1-163 as if fully set forth in this
complaint.
165. Defendant Crowley, Jones knew or should have known that trespass charge
533
was dropped on August 16,2010 against Spreadbury by the City ofHamilton,
534
Montana.
535
166. Defendant Crowley, Jones knew or should have known that Spreadbury did
536
not threaten Attorney Bell in regular written correspondence requesting public
537
information in 2010.
31
2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-064-M-OWM
538
5/5/2011
167. Defendant Crowley, Jones knew or should have known that Spreadbury
539
made Alfred plea of no contest to felony charge, under appeal as DC-09-154,
540
not convicted.
541
542
543
544
168. The publication of information in paragraphs # 157-159 constitutes
negligence by Defendants Crowley, Jones, Boone Karlberg.
169. As a result ofnegligence by Crowley, Jones, Boone Karlberg, Spreadbury
suffered actual damages.
Defamation-Crowley, Jones, Boone Karlberg=-Count 16
545
546
547
548
170. Plaintiff repeats, realleges paragraphs 1-169 as if fully set forth in this
complaint.
171. Defendant Boone Karlberg, Crowley, Jones published, republished false
549
information about Spreadbury being charged with a criminal trespass in court
550
documents in the State of Montana after case was properly dismissed, not
551
relevant to fact, background of pled case.
552
172. Defendant Boone Karlberg, Crowley, Jones published, republished false
553
light information concerning Spreadbury's actions with respect to the public
554
library.
32
2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-II-064-M-OWM
555
5/5/2011
173. Defendant Boone Karlberg, Crowley, Jones published false information that
556
Spreadbury threatened City Attorney Bell in regular requests for public
557
information in 2010.
558
559
560
561
174. The publishing of false, false light information is defmed as defamation in
Montana.
175. As a result of defamation by Defendant Boone Karlberg, Crowley, Jones,
Spreadbury suffered actual damages.
562
DeCamationlDeCamation per se--City oC Hamilton-Count 17
563
176. Plaintiff repeats, realleges paragraphs 1-175 as if fully set forth in this
564
565
complaint.
177. Defendant Bell served upon court sworn complaint September 2, 2009
566
Spreadbwy was trespassing on public property August 20, 2009 on written
567 .
public document before court.
568
178. The Hamilton Police Department published several unprivileged reports,
569
DVD, CD of interviews in re: alleged trespassing on public property,
570
unfounded harassment, and false light concerning Spreadbury interactions
571
with library, Hamilton Police.
33
NO
2
572
573
574
575
576
577
578
579
580
581
Amended Complaint Spreadbury v. Bitterroot Public Library et. at CV~11-064-M-DWM
5/5/2011
179. By publishing false light, false information, hearsay in HPD report is
defamation per se.
180. Bell put false information about Spreadbury into court documents, available
to public is considered defamation in the State of Montana.
181. As a result of defamation, defamation per se by City of Hamilton, Bell,
Spreadbury incurred actual damages.
NegligencelNegIieence per se- Lee Enterprises Inc.--Count 18
182. Plaintiff repeats, realleges paragraphs 1-181 as if fully set forth in this
complaint.
183. Defendant Lee Enterprises Inc. knew or should have known sitting on public
582
property is a protected right, Art. II section 6 Montana Constitution,
583
Amendment 1 US Constitution.
584
184. Defendant Lee Enterprises knew or should have known that publishing
585
comments about a person's psychiatric health constitutes negligence per se.
586
185. Lee Enterprises published several comments about Spreadbury's psychiatric
587
health.
34
2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. at CV-U-Q64-M-OWM
588
589
5/5/20U
186. Lee Enterprises knew, or should have known re-publishing material relating
to criminal trespass on public property establishes negligence.
590
187. Lee Enterprises knew or should have known that publishing false light
591
information such as Spreadbury "repeatedly" returning to public library,
592
Supreme Court "upholding" ban on public library for Spreadbury considered
593
defamation in the State of Montana.
594
595
596
597
598
599
188. Due to negligent and negligent per se activity by Lee Enterprises Inc.
Spreadbury suffered actual damages.
Defamation, Defamation per se, Lee Enterprises Inc.-Count 19
189. Plaintiff repeats, realleges paragraphs 1-188 as if fully set forth in this
complaint.
190. Lee Enterprises Inc. published known false information with actual malice
600
against Spreadbury making case that sitting peacefully on public property was
601
criminal trespass.
602
191. Lee Enterprises Inc. re-published, encouraged the mass-re-publication of
603
criminal trespass with respect to Spreadbury to statewide, national, and
604
international audience.
35
2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-064-M-OWM
605
606
607
608
609
5/5/2011
192. Lee Enterprises Inc. published comments about Spreadbury's psychiatric
health which constitutes defamation per se.
193. Lee Enterprises Inc. published, mass republished false light information with
respect to Spreadbury and the public library in Hamilton, Montana.
194. Lee Enterprises Inc. encouraged all statewide media outlets to publish
610
criminal trespass concerning Spreadbury peacefully assembled on public
611
property in Hamilton, MT.
612
613
614
195. Lee Enterprises Inc. officials received several written requests from
Spreadbury not to defame his character by publishing false information.
196. Due to publication, mass publication of known false information, false light
615
information by Lee Enterprises Inc considered defamation and defamation per
616
se with actual malice.
617
618
619
620
621
197. As a result of the defamation, defamation per se by Lee Enterprises Inc. with
actual malice, Spreadbury suffered actual damages.
Intentional Infliction of Emotional Distress (llEDl-Defendants-Count 20
198. Plaintiff repeats, realleges paragraphs 1-197 as if fully set forth in this
complaint.
36
2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-11-064-M-OWM
5/5/2011
622
199. Defendants were in a position to affect Spreadbury's protected interest.
623
200. Defendants unlawfully conspired to charge Spreadbury with a crime, re
624
published defamation, false light, false information about Spreadbury
625
committing a crime, caused severe emotional distress, violated Spreadbury's
626
established constitutional right.
627
201. Due to willful acts with actual malice on the part of the Defendants known
628
to cause emotional distress, Spreadbury actually suffered severe emotional
629
distress.
630
631
632
633
634
202. Due to the intentional infliction of emotional distress by the Defendants,
Spreadbury suffered actual damages.
Neglieent Infliction of Emotional Distress (NIEDlDefendants-Connt 21
203. Plaintiff repeats, realleges paragraphs 1-202 as if fully set forth in this
complaint.
635
204. Defendants were in a position to affects Spreadbury's protected interest.
636
205. Defendants negligently conspired to unlawfully charge Spreadbury with a
637
crime for peaceful assembly on public property, a protected right. Defendants
638
encouraged Lee Enterprises Inc. to publish with actual malice intra-state,
37
2ND Amended Complaint Spreadbury v. Bitterroot Public library et. al. CV-ll-064-M-DWM
5/5/2011
639
interstate, and internationally the false notion that Spreadbury committed a
640
crime by peaceful assembly in Hamilton, MT.
641
206. The negligent and unlawful charge of criminal trespass on public property,
642
intra-state publication, international publication caused Spreadbury severe
643
emotional stress.
644
207. Defendants negligent actions were willful, with actual malice, knowingly
645
executed to cause emotional distress, expected outcome: harm, injury to
646
Spreadbury.
647
648
208. Due to the negligent infliction of emotional distress by the Defendants, with
position to affect Spreadbury, Spreadbury suffered actual damages.
Iniuctive Relief-Boone Karlberg PC-Count 22
649
650
651
652
653
209. Plaintiff repeats, reaUeges paragraphs 1-208 as if fully set forth in this
complaint.
210. Spreadbury seeks an order from this Honorable Court to enjoin Boone
Karlberg PC from further defamatory statements in reference to Plaintiff.
38
2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-064-M-OWM
5/5/2011
654
211. Spreadbury never made threat to Ken Bell, trespass on public property at
655
public library dismissed, Boone Karlberg published known false information
656
about Spreadbury.
657
212.It is highly improper, unethical, and defamatory to make published
658
comments about a criminal behavior that never existed by Boone Karlberg
659
PC.
660
213. Spreadbury seeks a Cease and Desist ORDER from the court, and if
661
violated, sanctions on William L. Crowley esq. and/or Natasha Prinzing-Jones
662
esq. of Boone Karlberg PC.
663
214. Spreadbury seeks injunctive relief from court due to beJief of future harm,
664
specifically defamation through the courts, which is malicious, calculated,
665
unprofessional, and causes undue harm and injury to Spreadbury's character.
666
215. Emotional distress, defamation should not be manipulated by lawyers at
667
Boone-Karlberg.
668
216. Spreadbury reserves the right to request civil ARREST of associates at
669
Boone Karlberg PC for cause if future harm, or other sanctions this honorable
670
court feels appropriate.
671
Injuntive Relief.-Lee Enterprises Inc.--Count 23
39
2ND Amended Complaint Spreadbury v. Bitterroot Public library et. al. CV-11-064-M-DWM
672
673
5/5/2011
217. Plaintiff repeats, realleges paragraphs 1-216 as if fully set forth in this
complaint.
674
218. Spreadbury seeks a Cease and Desist ORDER from the court to stop any
675
malicious comment, defamatory material from publication in re: Spreadbury.
676
219. Lee Enterprises has published known false information, defamatory
677
comments damaging to Spreadbury since 2007 in more than 30 articles from
678
the Ravalli Republic, parties herein.
679
220. Spreadbury seeks civil ARREST of Perry Backus, per MCA§ 27-16-102(2)
680
former editor, author of at least 20 articles defamatory to Spreadbury, gave
681
permission to publish highly defamatory comments in re: Spreadbury's
682
character by the Ravalli Republic. Affidavit for this arrest will be in docket of
683
the aforementioned.
684
221. Spreadbury seeks injuctive relief due to belief that capability of future harm
685
by Lee Enterprises is likely. Spreadbury will yield to Honorable Court for an
686
additional remedies to stop malicious behavior of Lee Enterprises Inc.
687
ongoing since 2007.
688
222. Spreadbury seeks proper court order to stop future harm by Lee Enterprises
689
Inc. that attacks the good character of Spreadbury, before this court for relief.
40
2ND Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-11-064-M-OWM
690
691
692
693
5/5/2011
Injunctive Relief-Bitterroot Public Library-Count 24
223. Plaintiff repeats, realleges paragraphs 1-222 as if fully set forth in this
complaint.
224. Plaintiff respectfully requests Honorable Court find lawful privilege of
694
library use was removed improperly: no willful violation ofrules per Montana
695
statute, sworn testimony of former library director in Hamilton Municipal
696
Court. Plaintiff requests Honorable Court enjoin Bitterroot Public Library to
697
reinstate Plaintiff privileges per Montana Statute, appropriate administrative
698
remedy therein.
699
225. Plaintiff respectfully requests that honorable court finds that Bitterroot
700
Public Library violated in-house policies for patron submissions,
701
constitutional protections in State ofMontana, United States for speech of
702
Plaintiff, enjoin Plaintiffs submission as permanent entry into Bitterroot
703
Public Library collection.
704
226. Plaintiff will suffer future harm of liberty interest ifhonorable court does not
70S
impose injunctive relief on Bitterroot Public Library per well established state
706
statute, right.
707
Injunctive Relief-City of Hamilton-Count 25
41
2ND Amended Complaint Spread bury v. Bitterroot Public Library et. al. CV-11-064-M-DWM
708
709
5/5/2011
227. Plaintiff repeats, realleges paragraphs 1-226 as if fully set forth in this
complaint.
710
228. Defendant City of Hamilton, prosecuted Spreadbury for established right.
711
229. Hamilton Police Officers did not uphold Plaintiff right under Montana
712
statute to freely use public library. HPD attempted to cite/arrest Plaintiff for
713
established right. HPD investigated Plaintiff for separate established right.
714
HPD wrote several criminal reports defamatory to Spreadbury when
715
Spreadbury has liberty interest, protected right.
716
230. City Attorney Bell acted with malice prosecuting a protected act, previously
717
entered a civil courtroom in violation of state statute MCA§ 7-4-4604 to act
718
against Spreadbury.
719
231. Hamilton Municipal Judge Reardon did not write fmdings of fact,
720
conclusions of law for permanent order or protection, ordered jail time for
721
peaceful assembly on public property.
722
723
724
232. For fear of future harm, Spreadbury asks court to enjoin City ofHamilton
from knowingly, or unknowingly violating Spreadbury's established right.
Punitive Damages--Defendants-Count 26
42
2ND
725
726
727
Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-11-064-M-OWM
5/5/2011
233. Plaintiff repeats, realleges paragraphs 1-232 as if fully set forth in this
complaint.
234. Actions of defendants, acting in actual malice, with willful intent to deprive
728
right, defame Spreadbury, and intentionally cause severe emotional distress
729
entitle Plaintiff to seek punitive damages in this cause of action.
730
235. Defendant actions that have callous indifference to Spreadbury's protected
731
rights, or are willfully executed to injure or harm'are those eligible for
732
punitive damages.
733
236. Punitive damages are intended to stop future behavior ofthe Defendants.
734
237. Decisions ofofficial policymakers subject municipal government to punitive
735
damages, as Bell, Oster enacted in this cause of action for the City of
736
Hamilton, Montana.
737
238. Defendants Murphy, Snavely, Brophy, Roddy, Lee Enterprises Inc., City of
738
Hamilton, Bell, Lint, Crowley, Prinzing-Jones, Boone Karlberg PC, public
739
library acted in callous indifference, actual malice towards Spreadbury, allows
740
the grant of punitive damages under applicable statute in Montana, 42 USC§
741
1983.
742
Relief Sought by Plaintiff
43
2"010 Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-064-M-DWM
743
5/5/2011
I. Plaintiff respectively requests that the court find against the Defendants:
Plaintiff suffered special damages oflost earnings in the amount ...... $2.2M
744
1.
745
11.
Plaintiff suffered general damages for pain, suffering of.................. $2M
746
111.
Plaintiff seeks Compensatory damages for nED of ...............$535,000.00
747
IV.
Plaintiff seeks Compensatory damages for NIED of ..............$ 475,000.00
748
v.
Plaintiff seeks Compensatory damages for defamation of................. $6M
749
VI.
Plaintiff seeks Compensatory damages for §1983 of........................ $2M
750
V11.
Plaintiff seeks Punitive damages for lIED of........................$200,000.00
751
V111.
Plaintiff seeks Punitive damages for §1983 of.......................$ 645,000.00
752
IX.
Plaintiff seeks punitive damages for defamation of....................... $16M
753
Total Compensatory damages ......................... $ 10.21M
754
Total Punitive damages ................................ $ 16.845M
755
Total damages sought from Defendants .•••••••.•..•..•$ 27,055,000.00 US
756
757
II. Plaintiff seeks permanent injunctive relief:
Boone Karlberg PC ........................................................... .line 655
44
2ND
Amended Complaint Spreadbury v. Bitterroot Public Library et. al. CV-ll-064-M-OWM
5/5/2011
758
Lee Enterprises Inc ........................................................... .line 677
759
Bitterroot Public Library .....................................................line 696
760
City of Hamilton.............................................................. .line 713
761
III. Plaintiff respectfully requests a jury trial to hear this case.
762
End of Complaint.
763
764
Respectfully submitted this
765
766
767
Michael E. Spre dbury, Self Represented Plaintiff
45
Certificate of Service
Cause No. CV-II-0064-DWM
I certify as Plaintiff in this action, a copy of the below named motion was served
upon the US District Court Missoula Division and all opposing counsel for parties
in this above named cause of action by first class mail, or hand delivered. The
following addresses were used for service:
2nd Amended Complaint
Russell Smith Federal Courthouse
Clerk of Court
200 E. Broadway
Missoula, MT 59803
Defendant Counsel:
Plaintiff Counsel:
William L. Crowley
Michael E. Spreadbury
Boone Karlberg PC
POBox 416
PO Box 9199
Hamilton, MT 59840
Missoula MT 59807
( self-represented)
Jeffrey B Smith
Garlington, Lohn, & Robbinson PLLP
POBox 7909
Missoula MT 59807
Dated
5/4/1 - - - - -
]]>
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