PRETRIAL STATEMENT

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PRETRIAL STATEMENT

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
CASE NO. 97-1197-CIV-ORL-19B

MEREDITH T. RANEY, JR. ,
Plaintiff,
vs.
AWARE WOMAN CENTER FOR
CHOICE, INC. , a Florida Corporation,
EDWARD W. WINDLE, JR. , and
PATRICIA B. WINDLE.
Defendants.

PRETRIAL STATEMENT

The Plaintiff, Meredith T. Raney, Jr., by and through his undersigned attorney, files this Pretrial Statement, which states as follows:

Federal Jurisdiction

The basis for federal jurisdiction is enforcement of the Freedom of Access to Clinic Entrances Act of 1994 {'FACE"), 18 U.S.C. § 248.

Statement of the Nature of the Action

Plaintiff Meredith T. Raney, Jr., brings this suit against Defendants Aware Woman Center For Choice, Inc. ("Aware Woman Center") , Edward W. Windle, Jr., and Patricia B. Windle for violation of the Freedom of Access to Clinic Entrances Act of 1994 ("FACE"), 18 U.S.C. § 248.

Statement of the Case

Plaintiff asserts that he was unlawfully interfered with, threatened, and physically prevented from providing reproductive health services at a facility performing such services by the Melbourne City Police, who were allegedly acting as Defendants' agents. On three separate occasions, Plaintiff contends that his rights under FACE were so violated. Thus he has brought the present action seeking statutory damages of $5,000. for each count, together with punitive damages, attorney's fees and costs and expenses.

The Defendants have claimed that Plaintiff was not lawfully in the facility. At first, the Defendants admitted responsibility for the actions of the Melbourne City Police; however, more recently the Windles have tried to distance themselves from this admission.

In addition, the Defendants have filed a Counterclaim, requesting that an injunction be entered against Meredith T. Raney, Jr. to prevent the filing of any more lawsuits of this nature. Defendants have expressed the fear that many more such actions will be brought; Plaintiff has responded that sincere apologies from the Defendants would be a better preventative.

Defendants are suing their insurance company in a third party action. This pretrial statement does not involve the details of that claim.

List of Plaintiff's Exhibits

1. Defendants' Memorandum In Support Of The Motion To Dismiss The Complaint, signed by Mr. Torpy, formerly the attorney for Defendants.

2. Video tape called "The Silent Scream", narrated by Dr. Bernard Nathanson, one of the founders of NARAL.

3. Video tape called "Houston Proud?", produced by Houston Pro-life Action Network.

4. Three enlarged copies of the site diagram at 1564 Dixie Way, Melbourne, Florida, showing the "buffer zone", said diagram being found at 626 So. 2d 682.

5. Video tape of the first occasion, which is the subject of Count I of the Complaint, showing the Plaintiff lawfully in the "buffer zone" on the 28th day of January, 1995.

6. Video tape of the second occasion, which is the subject of Count II of the Complaint, showing the Plaintiff lawfully in the "buffer zone" on the 26th day of April, 1995.

7. Video tape of the third occasion, which is the subject of Count III of the Complaint, showing the Plaintiff lawfully in the "buffer zone" on the 24th day of January, 1996.

8. Answers to Interrogatories by Aware Woman Center For Choice, Inc, dated the 11th day of February, 1998.

9. Answers to Interrogatories by Edward W. Windle, Jr., dated the 12th day of February, 1998.

10. Answers to Interrogatories by Patricia B. Windle, dated the 11th day of February, 1998.

11. The Plaintiff reserves the right to utilize any exhibit used by the Defendants.

12. The Plaintiff reserves the right to introduce any documents as may be appropriate for impeachment or rebuttal as permitted by law or the rules.

13. The Plaintiff reserves the right to list additional exhibits as information becomes available, especially information which may be used to prove punitive damages.

Plaintiff's List ef Witnesses

1. Meredith T. Raney, Jr.
2. Edward W. Windle, Jr.
3. Patricia B. Windle
4. Police Chief Keith Chandler
5. Former Police Captain Gary Allgeyer
6. Police Officer William L. Bearden
7. Police Officer V. A. Pryce
8. Police Officer S. W. Smith
9. Jonathan Luckey
10. Phyllis Erwin
11. Roberta Sampere
12. City of Melbourne Attorney James Reinman
13. Former Melbourne City Manager Sam Halter
14. Former Lt./Capt. Bobby Bowen
15. Lt./Major Wayne Torpy
16. Former Public Relations Police Officer Joe Davis
17. Roni L. Windle
18. Edward W. Windle "Tod"
19. Reid Windle
20. William LeStourgeon
21. Richard Vanderbilt
22. Nancy Lally
23. Graham Dugas, III
24. Christine Jagos
25. Lisa Sanford
26. Unknown U.S. Marshals
27. Joel Pinkston (Pat}
28. Joyce Cabrera

29. Plaintiff reserves the right to call any witness listed the Defendants or listed as a person whose deposition the Defendants proposed to offer.

30. Plaintiff reserves the right to call any witness as may appropriate for impeachment or rebuttal as permitted by the law the rules.

Plaintiff's List of Expert Witnesses

Plaintiff, at this time, does not anticipate the use of expert witnesses at the initial trial to prove up punitive damages because of the prohibition on discovery as to this part of the case. However, when it becomes appropriate to prove up punitive damages, the Plaintiff anticipates using financial experts who have assisted the Defendants, or have knowledge about their income and resources, together with persons such as the following who are experts in the need for pro-life counseling and referral, such as was provided by Mr. Raney.

1. Norma McCorvey, the former Jane Roe of Roe v. Wade
2. Dr. Bernard Nathanson
3. Dr. Beverly McMillan
4. Cardinal O'Connor
5. Father Frank Pavone
6. Plaintiff reserves the right to call any expert witnesses listed by the Defendants.
7. Plaintiff reserves the right to call any expert witness as may be appropriate for impeachment or rebuttal as permitted by the law or the rules.

Money Damages

Plaintiff seeks only the statutory amount of $5,000 per count in lieu ef actual damages. Determination of punitive damages has been delayed.

List of Depositions

No depositions of oral testimony will be used as evidence.

Statement of Facts Admitted

1564 Dixie Way, Melbourne, Florida is a reproductive health service facility. At the times in question, it was operated as Aware Woman Center For Choice.

Principles of Law Agreed Upon

FACE prohibits physical obstruction of persons providing reproductive health services in reproductive health service facilities.

Applicable Principles of Law to be Determined

1. The territorial boundaries of a reproductive health facility include any "buffer zone" imposed by private injunction on adjoining real estate in order to protect or promote reproductive health services therein.

2. In Florida, a husband and wife who own and control a corporation are also liable with said corporation for any civil rights violations which it commits.

3. A police officer becomes the agent of a company when enforcing a private injunction for that company, which injunction is designed to protect or promote the business of that company.

Statement of Facts to be Litigated

1. Whether the Plaintiff was on the public right of way inside the "buffer zone" on the three different occasions when he was physically obstructed.

2. Whether the Plaintiff intended to offer reproductive health services, such as counseling or referral concerning pregnancy or the termination thereof, while in the "buffer zone".

3. Whether the Melbourne City Police were enforcing the private injunction of the Defendants when obstructing the Plaintiff in the "buffer zone".

Motions or Other Matters Requiring Action

1. Defendants' insurance company and the Defendants have various Motions pending which do not directly affect the trial.

2. Defendants have pending an untimely motion concerning discovery. Also, Defendants are requesting approval of their Interlocutory Appeal. Defendants are requesting an injunction against Mr. Raney.

3. Plaintiff has no pending motions at this time. However, Plaintiff requires guidance from the Court concerning the question of punitive damages and will amend this pretrial statement according to that guidance, including submitting additional materials and proposals.

Proposed Voir Dire Questions

Plaintiff is submitting the proposed Voit Dire Questions contained in an attachment to this statement.

Proposed Jury Instructions

Plaintiff is submitting the Proposed Jury Instructions contained in an attachment to this statement.

Proposed Jury Verdict Forms

Plaintiff is submitting the Proposed Jury Verdict Forms contained in an attachment to this statement. The Verdict Form concerning punitive damages is not intended for use at the initial
trial.

Respectfully submitted,

Christopher F. Sapp <signed>
PO Box 1012
Lehigh Acres, Florida 33910
(941) 368-3922
Florida Bar No.: 0097823
Attorney for Plaintiff

Roy Lucas, Esquire <not signed>
Post Office Box 1433
Melbourne, Florida 32902
(407) 725-2413
DC Bar # 153957
Attorney for Defendants

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to Roy Lucas, Esquire, Post Office Box 1433, Melbourne, Florida 32902, Susan England, Esquire, 2805 Lakeview Drive, Fern Park, Florida 32730 and to Lawrence M. Siff, Esquire, O'Connor & Meyers, PA, 2801 Ponce De Leon Blvd., 9th Floor, (Coral Gables) Miami, Florida 33134 this 4th day of January, 1999.

Christopher F. Sapp <signed>
Attorney

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
CASE NO.: 97-1197-CIV-ORL-19B

MEREDITH T. RANEY, JR.
Plaintiff
vs.
AWARE WOMAN CENTER FORCHOICE, INC.,
a Florida corporation,
EDWARD W. WINDLE, JR., and
PATRICIA B. WINDLE,
Defendants.

PLAINTIFF'S REQUESTED VOIR DIRE

COMES NOW the Plaintiff, MEREDITH T. RANEY, JR., by and through his undersigned counsel, and files the Plaintiff's Requested Voit Dire, requesting that the Court consider asking the following questions to potential jurors during voit dire.

1. Have you, a family member, relative or close friend ever owned an abortion clinic? A. Who? B. When? C. Name of the business and location?

2. Have you, a family member, relative or close friend ever been employed in an abortion clinic? A. Who? B. When? C. Name of the business and location? D. What was the position?

3. Have you, a family member, relative or close friend ever obtained or paid for an abortion? A. What were the circumstances surrounding the abortion?

4. Have you, a family member, relative or close friend ever been involved in an abortion in which the pregnant woman was injured at the abortion clinic? A. What were the circumstances surrounding the injury?

5. Has any family member, relative or close friend ever died as the result of a botched abortion? A. What were the circumstances surrounding this death as the result of a botched abortion?

6. Do you believe that a person entering a business has the right to know what sort of business it is before going through the door?

7. Do you believe that if the business that a person is entering is an abortion clinic, this information be known before one goes through the door?

8. Do you believe that if the business that the person is entering is an abortion clinic, does that person have the right to know how many woman have been injured or killed at that clinic before going through the door?

9. Do you believe that if that business that a person is entering is an abortion clinic, does this person have the right to know that mental and spiritual risks are involved with abortions before going through the door?

10. Do you believe that if a woman is entering a business, does she have the right to know that adoptions or adoption counseling are available there before going through the door?

11. Do you believe that if a pregnant woman is entering an abortion clinic she has the right to hear of alternatives to abortion?

12. Do you believe that if a pregnant woman is entering an abortion clinic she has the right to hear of how her baby will be destroyed?

13. Do you believe that if a pregnant woman is entering a building in which both abortion and adoption assistance is available, she should be informed that both of these services are available at that same address before she enters the building?

14. Do you believe that if a pregnant woman is about to enter an abortion clinic, that she has the right to a loving expression of help and concern before she goes through the door?

15. Do you believe that if a woman is leaving an abortion clinic after just having an abortion, that she has the right to love and to help in recovering from this experience?

16. Do you believe that if a woman is injured in the course of having an abortion that she has the right to be referred to people who will help her with her needs?

17. Do you believe that a pro-life view point should be allowed equal protection with a pro-abortion view point?

18. Do you believe that pro-life volunteers who offer counseling and referral services should be protected the same as if they were providing pro-abortion counseling and referral services?

19. Have you, a family member, relative or close friend ever been employed by Aware Woman Center For Choice, Inc., Edward W. Windle, Jr. or Patricia B. Windle? A. Who? B. When? C. What location? D. Position held? E. Currently employed there? F. Reason for leaving?

20. Have you, a family member, relative or close friend ever worked for, been represented by, consulted, or been involved in a lawsuit or legal matter with any of the attorneys in this case or their offices, including attorneys who have withdrawn from representation of the Defendants?

21. Have you, a family member, relative or close friend ever been abused by police officers? A. What were the circumstances surrounding this abuse?

22. Have you, a family member, relative or close friend ever filed a lawsuit because your civil rights were violated? A. Who filed the lawsuit? B. Who was the defendant? C. What were the reasons for the lawsuit? D. Did the case go to trial? E. What was the outcome of the trial?

23. Have you or any person close to you ever been sued for violation of another person's civil rights? A. What were the circumstances?

24. Have you or any person close to you ever been sued for any reason? A. What were the circumstances?

25. Do you believe that a white male should be allowed to sue the owners of an abortion clinic for violation of his civil rights, namely the right to help pregnant women with their problems?

26. Has any person close to you committed suicide or suffered severe mental problems because of the guilt associated with an abortion? A. What were the circumstances?

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
CASE NO.: 97-1197-CIV-ORL-19B

MEREDITH T. RANEY, JR. ,
Plaintiff,
v.
AWARE WOMAN CENTER FOR CHOICE, INC.,
a Florida corporation,
EDWARD W. WINDLE, JR., and
PATRICIA B. WINDLE,
Defendants.

COURT'S INSTRUCTIONS TO THE JURY

Members of the Jury:

I will now explain to you the rules of law that you must follow and apply in deciding this case. When I have finished you will go to the jury room and begin your discussions - what we call your deliberations.

PLAINTIFF'S PROPOSED JURY INSTRUCTION NO. 1

CONSIDERATION OF THE EVIDENCE
DUTY TO FOLLOW INSTRUCTIONS
(Corporate Party Involved)

In deciding the case you must follow and apply all of the law as I explain it to you, whether you agree with that law or not; and you must not let your decision be influenced in any way by sympathy, or by prejudice, for or against anyone. A corporation and all other persons stand equal before the law and must be dealt with as equals in a court of justice.

When a corporation is involved, of course, it may act only through people as its agents; and, in general, a corporation is responsible under the law for any of the acts and statements of its agents which are made within the scope of their duties as agents of the company.

In your deliberations you should consider only the evidencethat is, the testimony of the witnesses and the exhibits I have admitted in the record - but as you consider the evidence, both direct and circumstantial, you may make deductions and reach conclusions which reason and common sense lead you to make. "Direct evidence" is the testimony of one who asserts actual knowledge of a fact, such as an eye witness. "Circumstantial evidence" is proof of a chain of facts and circumstances tending to prove, or disprove, an ultimate conclusion.

Remember that anything the lawyers say is not evidence in the case. It is your own recollection and interpretation of the evidence that controls.

Accepted ___ Rejected ___ Modified ___

Source: 11th Circuit Pattern Instructions No. 2.2 (Basic) (1990) . Modified by changing the word "employees" to "agents"

PLAINTIFF'S PROPOSED JIJRY INSTRUCTION NO. 2

CREDIBILITY OF WITNESSES

Now, in saying that you must consider all of the evidence, do not mean that you must accept all of the evidence as true or accurate. You should decide whether you believe what each witness had to say, and how important that testimony was. In making that decision you may believe or disbelieve any witness, in whole or in part. Also, the number if witnesses testifying concerning any particular dispute is not controlling. You may decide that the dispute is more believable than the testimony of a larger number of witnesses to the contrary.

In deciding whether you believe or do not believe any witness I suggest that you ask yourself a few questions: Did the person impress you as one who was telling the truth? Did the witness have any particular reason not to tell the truth? Did the witness have a personal interest in the outcome of the case? Did the witness seem to have a good memory? Did the witness have the opportunity and ability to observe accurately the things he or she testified about? Did the witness appear to understand the questions clearly and answer them directly? Did the witness's testimony differ from other testimony or other evidence?

Accepted ___ Rejected ___ Modified ___

Source: 11th Circuit Pattern Instructions No. 3 (Basic) (1990).

PLAINTIFF'S PROPOSED JURY INSTRUCTION NO. 3

IMPEACHMENT OF WITNESS

You should also ask yourself whether there was evidence tending to prove that the witness testified falsely concerning some important fact; or, whether there was evidence that at some other time the witness said or did something, or failed to say or do something, which was different from the testimony he or she gave before you during the trial.

You should keep in mind, of course, that a simple mistake by a witness does not necessarily mean that the witness was not telling the truth as he or she remembers it, because people naturally tend to forget some things or remember other things inaccurately. Of course, if a witness has made a misstatement, you need to consider whether that misstatement was simply an innocent lapse of memory or an intentional falsehood; and the significance of that may depend on whether it has to do with an important fact or with only an unimportant detail.

Accepted ___ Rejected ___ Modified ___

Source: 11th Circuit Pattern Instructions No. 4.1 (Basic) (1990).

PLAINTIFF'S PROPOSED JURY INSTRUCTION NO. 4

BURDEN OF PROOF

In this case each party asserting a claim or a defense has the responsibility to prove every essential part of their contention by a "preponderance of the evidence." This is sometimes called the "burden of proof" or the "burden of persuasion."

A "preponderance of the evidence" simply means an amount of evidence which is enough to persuade you that a claim or contention is more likely true than not true.

Where more than one claim is involved, and when more than one defense is asserted, you should consider each claim and each defense separately; but in deciding whether any fact has been proved by a preponderance of the evidence, you may consider the testimony of all of the witnesses, regardless of who may have called them, and all of the exhibits received in evidence, regardless of who may have produced them.

If the proof fails to establish any essential part of a claim or contention by a preponderance of the evidence you should find against the party making that claim or contention.

Accepted ___ Rejected ___ Modified ___

Source: 11th Circuit Pattern Instructions No. 6.2 (Basic) (1990).

PLAINTIFF'S PROPOSED JURY INSTRUCTION NO. 5

INTRODUCTION TO PLAINTIFF'S CLAIMS AGAINST DEFENDANTS

Specifically, Mr. Raney has brought a claim for three counts or incidences cf violations of his rights against Aware Woman Center For Choice, Inc., Edward W. Windle, Jr. and Patricia Windle. The claim against these Defendants, which I will define for you in a moment, are for violating a federal statute called FACE which protects people providing reproductive health services on three different occasions. You must consider each occasion or count separately and render a separate verdict as to each count or occasion. All of the Defendants deny this claim. It is your responsibility to decide whether Meredith T. Raney, Jr. has proven his claims against the Defendants by a preponderance of the evidence.

Accepted ___ Rejected ___ Modified ___

Source: Federal Jury Practice and Instructions (West) (1997 Pocket Part) §104.1

PLAINTIFF'S PRQPOSED JURY INSTRUCTION NO. 6

ELEMENTS OF PLAINTIFF'S CLAIMS

The law in this case is called FACE. It protects people from physical obstruction, such as removal from places where they want to provide reproductive health services. These services include counseling or referral assistance on matters involving pregnancy and the termination of pregnancy.

Obviously, abortion is another term for termination of pregnancy.

You have heard much about the "buffer zone" at 1564 Dixie Way, over in Melbourne, Florida and you have been shown a diagram of that location. The first thing you must decide is whether Mr. Raney had entered the "buffer zone" and was standing on the public right of way.

You will need to make this decision for each of the three Counts or incidents. Just take them one at a time starting with the incident of January 28, 1995.

Was Mr. Raney inside the 'buffer zone" on the public right of way on that date? If you decide that he was, go on to the next issue.

Was Mr. Raney's purpose for being there to offer counseling help or referral information to women - or for that matter, men too - about pregnancy or the termination of pregnancy? If you decide that he had that intent, then go on to the final issue.

Was Mr. Raney physically obstructed, threatened or intimidated there by a Melbourne City policeman whose excuse was that the policeman was enforcing the Defendants' private injunction? If the policeman charged Mr. Raney with "contempt of court" instead of some violation of a city law or state statute, that would prove to you that the excuse for obstructing Mr. Raney was, in fact, the enforcement of this private injunction. If you answer "yes" to this and to the previous questions, you have found that Mr. Raney's rights under FACE were violated by the Defendants in that particular incident, namely Count I.

Simply follow the same procedure on the other two Counts or incidents. Present in the "buffer zone" on the public right of way? Intending to provide counseling or referral information about pregnancy or abortion? Removal by the Melbourne City police while enforcing the Defendants' private injunction? Decide these issues separately for each of the three occasions.

If you answer yes to each of these questions, then the Plaintiff's rights were violated by the Defendants in each particular incident.

However, if you answer "no" to any of these questions, then the Defendants did not violate Mr. Raney's rights under FACE for the particular incident that you are discussing.

A final word about what we are calling the Defendants' private injunction. This is a court order which the Defendants obtained to protect their business from certain people and activities.

If you find that the Melbourne City police officers charged Mr. Raney with "contempt of court" in any of these incidents that finding means that your answer to the third question should be that the policeman was in fact the agent or tool of the Defendants and was obstructing Mr. Raney's efforts to provide reproductive health services.

Accepted ___ Rejected ___ Modified ___

Source: Drafted from the principles stated in 18 U.S.C. § 248; Gilbert v. Sears, Roebuck and Co. 899 F. Supp. 597 (M.D.Fla. 1995); Madsen v. Women's Health Center, Inc. 114 S.Ct. 2516 (1994); Johnson v. Weiner 19 So.2d 699 (Supreme Court of Florida, 1944); 1SA Am Jut 2d
Corporations § 852 at page 724.

PLAINTIFF'S PROPOSED JURY INSTRUCTION NO. 7

DUTY TO DELIBERATE

Any verdict you reach in the jury room must be unanimous. In other words, to return a verdict you must all agree. Your deliberations will be secret; you will never have to explain your verdict to anyone.

It is your duty as jurors to discuss the case with one another in an effort to reach agreement if you can do so. Each of you must decide the case for yourself, but only after full consideration of the evidence with the other members of the jury.

While you are discussing the case do not hesitate to reexamine your own opinion and change your mind if you become convinced that you are wrong. But do not give up your honest beliefs solely because the others think differently or merely to get the case over with.

Remember, that in a very real way you are judges - judges of the facts. Your only interest is to seek the truth from the evidence in the case.

Accepted ___ Rejected ___ Modified ___

Source: 11th Circuit Pattern Instructions No. 7.1 (Basic) (1990) . The paragraph referring to damages was omitted.

PLAINTIFF'S PROPOSED JURY INSTRUCTION NO. 8

ELECTION OF FOREPERSON EXPLANATION OF VERDICT FORMS

When you go to the jury room you should first select one of your members te act as your foreperson. The foreperson will preside ever your deliberations and will speak for you here in court.

A form of verdict has been prepared for your convenience. (Explain verdict)

You will take the verdict form to the jury room and when you have reached unanimous agreement you will have your foreperson fill in the verdict form, date and sign it, and then return te the courtroom.

If you should desire to communicate with me at any time, please write down your message or question and pass the note to the marshal who will bring it to my attention. I will then respond as promptly as possible, either in writing or by having you returned to the courtroom so that I can address you orally. I caution you, however, with regard to any message or question you might send, that you should not tell me your numerical division at the time.

Accepted ___ Rejected ___ Modified ___

Source: 11th Circuit Pattern Instructions No. 8 (Basic) (1990).

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
CASE NO.: 97-1197-CIV-ORL-19B

MEREDITH T. RANEY, JR.
Plaintiff,
v.
AWARE WOMAN CENTER FOR CHOICE, INC.,
a Florida corporation,
EDWARD W. WINDLE, JR., and
PATRICIA B. WINDLE ,
Defendants.

VERDICT FORM

Please read carefully and mark your answers to the following questions as appropriate. After you have answered all applicable questions and filled in all applicable spaces, on the last page, sign and date the form and notify the Marshal that you have concluded your deliberation.

We, the Jury, find as follows:

1. On the 28th day of January, 1995, did Aware Woman Center For Choice, Inc., Edward W. Windle, Jr. and Patticia B. Windle, acting through their agents, the Melbourne City police, violate the rights of Meredith T. Raney, Jr. under the federal law known as FACE? YES ___ NO ___

2. On the 26th day of April, 1995, did Aware Woman Center For Choice, Inc., Edward W. Windle, Jr. and Patricia B. Windle, acting through their agents, the Melbourne City police, violate the rights of Meredith T. Raney, Jr. under the federal law known as FACE? YES ___ NO ___

3. On the 24th day of January, 1996 did Aware Woman Center For Choice, Inc., Edward W. Windle, Jr. and Patticia B. Windle, acting through their agents, the Melbourne City police, violate the rights of Meredith. T. Raney, Jr. under the federal law known as FACE? YES ___ NO ___

The Foreperson should sign and date the Verdict Form.

FOREPERSON _______________________ DATE _______

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
CASE NO.: 97-1197-CIV-ORL-19B

MEREDITH T. RANEY, JR.
Plaintiff,
v.
AWARE WOMAN CENTER FOR CHOICE, INC.,
a Florida corporation,
EDWARD W. WINDLE, JR., and
PATRICIA B. WINDLE,
Defendants.

VERDICT FORM

We, the Jury, find as follows:

1. What amount of punitive damages should Meredith T. Raney, Jr. be awarded from Aware Woman Center For Choice, Inc., a corporation?

AMOUNT $____________

2. What amount of punitive damages should Meredith T. Raney, Jr. be awarded from Edward W. Windle, Jr.?

AMOUNT $____________

3. What amount of punitive damages should Meredith T. Raney, Jr. be awarded from Patticia B. Windle?

AMOUNT $___________

The Foreperson should sign and date the Verdict Form.

FOREPERSON _________________ DATE __________