DEFENDANT MEREDITH RANEY'S ANSWER AND AFFIRMATIVE DEFENSES

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
OCALA WOMEN'S CENTER V CITY OF OCALA
DOCKET / CHRONOLOGICAL FILE
DEFENDANT MEREDITH RANEY'S ANSWER AND AFFIRMATIVE DEFENSES

IN THE UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
OCALA DIVISION
Case No.: 98-371-CIV-OC-10C

OCALA WOMEN'S CENTER, INC.,
et al.,
Plaintiffs,
vs.
CITY OF OCALA, et al.,
Defendants.

DEFENDANT MEREDITH RANEY'S ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF'S COMPLAINT

COMES NOW the Defendant, MEREDITH RANEY, by and through his undersigned counsel, and files this Answer to Plaintiff's Complaint, and states as follows:

Defendant, MEREDITH RANEY, denies each and every allegation contained in any and all headings, footnotes and/or unnumbered paragraphs.

1. Without knowledge and therefore denied.
2. Without knowledge and therefore denied.
3. Without knowledge and therefore denied.
4. Without knowledge and therefore denied.
5. Without knowledge and therefore denied.
6. Without knowledge and therefore denied.
7. Without knowledge and therefore denied.
8. Without knowledge and therefore denied.
9. Without knowledge and therefore denied.
10. Without knowledge and therefore denied.
11. Without knowledge and therefore denied.
12. Without knowledge and therefore denied.
13. Without knowledge and therefore denied.
14. Without knowledge and therefore denied.
15. Without knowledge and therefore denied.
16. Without knowledge and therefore denied.
17. Without knowledge and therefore denied.
18. Without knowledge and therefore denied.
19. Without knowledge and therefore denied.
20. Admitted as to residence of Raney in Melbourne only, without knowledge and therefore denied as to all remaining allegations.
21. Without knowledge and therefore denied.
22. Without knowledge and therefore denied.
23. Without knowledge and therefore denied.
24. Without knowledge and therefore denied.
25. Without knowledge and therefore denied.
26. Without knowledge and therefore denied.
27. Without knowledge and therefore denied.
28. Without knowledge and therefore denied.
29. Without knowledge and therefore denied.
30. Without knowledge and therefore denied.
31. Without knowledge and therefore denied.
32. Without knowledge and therefore denied.
33. Without knowledge and therefore denied.
34. Without knowledge and therefore denied.
35. Without knowledge and therefore denied.
36. Without knowledge and therefore denied.
37. Without knowledge and therefore denied.
38. Without knowledge and therefore denied.
39. Without knowledge and therefore denied.
40. Without knowledge and therefore denied.
41. Without knowledge and therefore denied.
42. Without knowledge and therefore denied.
43. Without knowledge and therefore denied.
44. Without knowledge and therefore denied.
45. Without knowledge and therefore denied.
46. Without knowledge and therefore denied.
47. Without knowledge and therefore denied.
48. Without knowledge and therefore denied.
49. Without knowledge and therefore denied..
50. Without knowledge and therefore denied.
51. Without knowledge and therefore denied.
52. Without knowledge and therefore denied.
53. Without knowledge and therefore denied.
54. Without knowledge and therefore denied.
55. Without knowledge and therefore denied.
56. Without knowledge and therefore denied.
57. Without knowledge and therefore denied.
58. Without knowledge and therefore denied.
59. Without knowledge and therefore denied.
60. Without knowledge and therefore denied.
61. Without knowledge and therefore denied.
62. Without knowledge and therefore denied.
63. Without knowledge and therefore denied.
64. Without knowledge and therefore denied.
65. Without knowledge and therefore denied.
66. Without knowledge and therefore denied.
67. Without knowledge and therefore denied.
68. Without knowledge and therefore denied.
69. Without knowledge and therefore denied.
70. Without knowledge and therefore denied.
71. Without knowledge and therefore denied.
72. Without knowledge and therefore denied.
73. Without knowledge and therefore denied.
74. Without knowledge and therefore denied.
75. Without knowledge and therefore denied.
76. Without knowledge and therefore denied.
77. Without knowledge and therefore denied.
78. Without knowledge and therefore denied.
79. Without knowledge and therefore denied.
80. Without knowledge and therefore denied.
81. Without knowledge and therefore denied.
82. Denied.
83. Without knowledge and therefore denied.
84. Without knowledge and therefore denied.
85. Denied.
86. Without knowledge and therefore denied.
87. Without knowledge and therefore denied.
88. Without knowledge and therefore denied.
89. Without knowledge and therefore denied.
90. Without knowledge and therefore denied.
91. Without knowledge and therefore denied.
92. Without knowledge and therefore denied.
93. Without knowledge and therefore denied.
94. Without knowledge and therefore denied.
95. Without knowledge and therefore denied.
96. Without knowledge and therefore denied.
97. Without knowledge and therefore denied.
98. Without knowledge and therefore denied.
99. Without knowledge and therefore denied.
100. Denied.
101. Denied.
102. Denied.
103. Denied.
104. Without knowledge and therefore denied.
105. Without knowledge and therefore denied.
106. Without knowledge and therefore denied.
107. Denied.
108. Denied.
109. Denied.
110. Without knowledge and therefore denied.
111. Without knowledge and therefore denied.
112. Denied.
113. Denied.
114. Denied.
115. Denied.
116. Denied.
117. Without knowledge and therefore denied.
118. Quote is admitted as true, without knowledge and therefore denied as to remaining allegations.
119. Without knowledge and therefore denied.
120. Quote is admitted as true, without knowledge and therefore denied as to remaining allegations.
121. Without knowledge and therefore denied.
122. Without knowledge and therefore denied.
123. Without knowledge and therefore denied.
124. Without knowledge and therefore denied.
125. Without knowledge and therefore denied.
126. Without knowledge and therefore denied.
127. Defendant re-alleges and incorporates by reference the foregoing allegations and deny that any relief is warranted.
128. Denied.
129. Denied.
130. Denied.
131. Denied.
132. Denied.
133. Denied.
134. Denied.
135. Denied.
136. Denied.
137. Denied.
138. Denied.
139. Denied.
140. Denied.
141. Denied.
142. Denied.
143. Denied.
144. Denied.
145. Denied.
146. Denied.
147. Denied.
148. Denied.
149. Denied.
150. Denied.
151. Defendant does not understand what "counterclaim plaintiffs" exist and states he is without knowledge and therefore denies this allegation.

152. WHEREFORE, Defendant Raney respectfully requests this Honorable Court to deny all relief requested by Plaintiff and to award attorney's fees and costs pursuant to 42 U.S.C. Section 1988 for defense of this frivolous action, as well as any other relief deemed appropriate by this Honorable Court.

AFFIRMATIVE DEFENSES

1. The Complaint fails to state a claim upon which relief may be granted.
2. The Complaint fails to join necessary parties as required by Fed.R.Civ.P 17 and 19.
3. Unclean hands.
4. Latches.
5. Statute of Limitations bars this action.
6. Plaintiffs have failed to mitigate damages, if any.
7. Independent, efficient, intervening and superceding actions of third parties caused or contributed to any damages claimed by Plaintiffs, thereby breaking any chain of causation between Defendant Raney's acts or omissions.
8. Defendant hereby reserves any other defenses which may become known through discovery.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been served on all parties required to be served, by depositing same, sufficient first class postage affixed, in a United States mailbox this 10th day of March, 1999, addressed to the following:

ROY LUCAS
Post Office Box 1433
Melbourne, FL 32902-1433

SCOTT ROST
228 Park Avenue North
Winter Park, FL 32789

PATRICK G. GILLIGAN
7 East Silver Springs Blvd.
Suite 500
Ocala, FL 34470

VIRGIL W. WRIGHT, III
Post Office Box 5549
Ocala, FL 34478-5549

MATHEW D. STAVER
Post Office Box 540774
Orlando, FL 32854

JOHN W. JOLLY, JR.
Post Office Box 669
Tallahassee, FL 32302

CAROL A. FALVEY
Post Office Box 2720
Ocala, FL 34478-2720

Frederick H. Nelson <signed>
Trial Attorney
Florida Bar No. 0990523
American Liberties Institute
P.O. Box 547503
Orlando, FL 32854-7503
(407) 786-7007 - voice
(407) 786-2705 - fax
Attorney for Defendant
Meredith Raney