PLAINTIFF'S MEMORANDUM IN SUPPORT OF MOTIONS TO COMPEL

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S MEMORANDUM IN SUPPORT OF MOTIONS TO COMPEL

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

PLAINTIFF'S MEMORANDUM IN SUPPORT OF THE MOTIONS TO COMPEL ANSWERS TO INTERROGATORIES BY PATRICIA B. WINDLE, EDWARD W. WINDLE, JR. AND AWARE WOMAN CENTER FOR CHOICE, INC.

BACKGROUND

Meredith T. Raney, Jr., the Plaintiff, caused Interrogatories to be served on Patricia B. Windle, Edward W. Windle, Jr., and Aware Woman Center for Choice, Inc. Partial answers were timely supplied by these parties. Plaintiff has tried to obtain the missing information through conferences with opposing counsel as shown by copies of the letters and statement for the record which are attached. These are as follows:
1. Defendant's letter of February 17, 1998
2. Plaintiffs letter of March 5, 1998
3. Defendant's letter of March 13. 1998
4. Defendant's letter of Friday, March 27, 1998
5. Plaintiff's letter of March 31, 1998
6. Plaintiffs Statement For The Record of April 1, 1998

RULES OF PROCEDURE

These Motions to Compel are brought under Rule 37 of the Federal Rules of Civil Procedure. A condition precedent to this motion required by the Local Rules is a good faith effort to resolve the questions informally with opposing counsel. Local Rule 3.01(g). This has been done.

Local Rule 3.04 requires that motions to compel discovery pursuant to Rule 37, Federal Rules of Civil Procedure shall utilize a particular format which has been done in the three motions since these motions are brought pursuant to said Rule 37.

This memorandum is filed and served as compliance with Local Rule 3.01 (a).

WHEREFORE, Meredith T. Raney, Jr., the Plaintiff, requests that his three Motions To Compel discovery will be granted.

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

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 9th day of April, 1998.

Christopher F. Sapp <signed>
Attorney