DENIAL AND TRAVERSE OF AFFIRMATIVE DEFENSES AND ANSWER TO COUNTERCLAIM

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
DENIAL AND TRAVERSE OF AFFIRMATIVE DEFENSES AND ANSWER TO COUNTERCLAIM

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-19B

DENIAL AND TRAVERSE OF AFFIRMATIVE DEFENSES

Meredith T. Raney, Jr. denies and traverses each and every affirmative defense raised by defendants, Aware Woman Center for Choice, Inc., Patricia B. Windle, and Edward W. Windle, Jr. in the answer and affirmative defenses.

ANSWER TO COUNTERCLAIM

Meredith T. Raney, Jr. answers the Counterclaim, saying:

1. Meredith T. Raney, Jr. admits that FACE provides for injunctions; that he was inside the boundaries of the facility in question; and that he was not a paid employee of Defendants. He further admits that he has filed suit against the Defendants under FACE.

2. Meredith T. Raney, Jr. denies or is without knowledge as to the balance of the material allegations of the Counterclaim.

3. With regard to the others who were persecuted by Defendants, Meredith T. Raney, Jr. suggests that Defendants apologize to all such persons rather than pray for this Court's protection from potential lawsuits seeking appropriate redress. Sincere apologies from Defendants should deter much litigation.

WHEREFORE, Plaintiff, Meredith T. Raney, Jr. asks that the relief sought in the Counterclaim be denied.

Respectfully submitted,
Christopher F. Sapp <signed>
Attorney At law
Post Office Box 1012
Lehigh Acres, Florida 33970
(941) 368-3922
Florida Bar Number 0097923

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to Vincent G. Torpy, Jr., Esquire, 930 Harbor City Blvd., Suite 505, Melbourne, Florida 32901, this 10th day of January, 1998.

Christopher F. Sapp <signed>
Attorney