PLAINTIFF'S AFFIDAVIT

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S AFFIDAVIT

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION

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

CASE NO.: 97-1197-CV-ORL-19

AFFIDAVIT OF MEREDITH T. RANEY, JR.

STATE OF FLORIDA )
COUNTY OF BREVARD)

BEFORE ME, the undersigned authority, personally appeared, MEREDITH T. RANEY, JR., who after being duly sworn by me according to law, deposes and states as follows:

1. My name is Meredith T. Raney, Jr. I live in Brevard County, Florida and I am
the Plaintiff in this lawsuit.

2. The Complaint is true: I have read it and the facts it contains are true.

3. I fully support the concept behind all adoption agencies. Specifically, I support all efforts to place unwanted or orphaned children with adoptive families undertaken by the Hope Adoption Agency which is located at the same facility as Aware Woman Center for Choice at 1564 Dixie Way in Melbourne, Florida.

4. At the times specified in the Complaint I was personally within the boundaries of the Hope Adoption Agency - Center For Choice reproductive health services facility at 1564 Dixie Way, Melbourne, Florida where I was counseling or attempting to counsel women and men as a provider of reproductive health services. I was not engaged in any anti-abortion demonstration at that place and times; nor was I violating any law, injunction, or court order. All of my activities were peaceful and I was not forcing my views or opinions on any person. I was there solely to help women and men who were in need of counseling and assistance in reproductive health matters.

5. Upon request, I can provide affidavits from persons to whom I have provided reproductive health services at Hope Adoption Agency - Center For Choice facility.

6. I have observed other providers of reproductive health services at the Hope Adoption Agency - Center For Choice, such as escorts and counselors, provide their services outside the building, apparently with the knowledge and consent of all Defendants. I have observed no one trying to stop or interfere in any way with said providing of services outside the building.

7. I did not need the permission of any of the Defendants to be within the boundaries of the facility, providing reproductive health services as specified in the Complaint.

8. The injunction described in the Madsen case does not apply to me. I am not a named respondent nor was I acting in concert with any named respondent.

9. Nevertheless, while I was providing or attempting to provide reproductive health services at the Hope Adoption - Center For Choice facility, the Melbourne City Police, as agents of the Defendants, arrested me, took me to jail, and charged me with violations of the said injunction in each of the three counts described in the Complaint. The State of Florida did not prosecute the first two charges and I was acquitted of the third charge.

FURTHER AFFIANT SAYS NOT.

MEREDITH T. RANEY, JR. <signed>

The foregoing instrument was sworn to and subscribed before me this 29th day of October, 1997, by Meredith T. Raney, Jr., who is personally known to me or who has produced FL Driver's License, as identification and who did take an oath.

Rebecca A. Culp <signed>
NOTARY PUBLIC #CC450351
State of Florida at Large
My Commission Expires: April 3, 1999

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the forgoing has been furnished by U.S. Mail to Vincent G. Torpy, Jr., 930 S. Harbor City Blvd., Suite 505, Melbourne, Florida 32901, this 30th day of October, 1997.

Christopher F. Sapp <signed>
Attorney For Plaintiff
Post Office Box 1012
Lehigh Acres, Florida 33970
(941) 368-3922
Florida Bar Number: 0097823