DEFENDANT'S MOTION TO AMEND COUNTERCLAIM

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
DEFENDANT'S MOTION TO AMEND 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

DEFENDANT'S MOTION TO AMEND COUNTERCLAIM

COMES NOW Defendants, AWARE WOMAN CENTER FOR CHOICE, INC., a Florida corporation, EDWARD W. WINDLE, JR., and PATRICIA B. WINDLE, by and through their undersigned attorney, and move to amend the Counterclaim filed herein, and in support thereof, would state:

1. Defendants served their Answer and Counterclaim on December 22, 1997, in the above-referenced case.

2. Defendants seek additional relief specifically, declaratory and injunctive relief, actual, statutory, and punitive damages in relation to Plaintiff/Counter-Defendant RANEY's and Counter-Defendant DOES' violation of 18 U.S.C. 248 and 18 U.S.C. § 1961-1968.

3. A true and correct copy of the proposed Amended Counterclaim showing the additional FACE and RICO Count is attached hereto and is made a part hereof by reference.

4. Counsel for Defendants attempted to contact counsel for Plaintiff to determine whether he had any objections to the relief requested herein, however, counsel for Plaintiff could not be reached.

WHEREFORE, Defendants pray that this cause will be amended accordingly, and that this matter proceed pursuant to Federal Rules of Civil Procedure.

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to Christopher F. Sapp, Esq., P.O. Box 1012, Lehigh Acres, FL 33970, this 22^nd day of April, 1998.

FRESE, NASH & TORPY, P.A.
BY: LISA L. HOGREVE <signed>
Florida Bar No. 0104840
930 S. Harbor City Blvd., Suite 505
Melbourne, FL 32901
(407) 984-3300
Attorney for Defendants