DEFENDANTS' MOTION FOR LEAVE TO FILE AFFIDAVIT IN SUPPORT OF MOTION FOR PROTECTIVE ORDER

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
DEFENDANTS' MOTION FOR LEAVE TO FILE AFFIDAVIT IN SUPPORT OF MOTION FOR PROTECTIVE ORDER

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

DEFENDANTS' MOTION FOR LEAVE TO FILE AFFIDAVIT IN SUPPORT OF MOTION FOR PROTECTIVE ORDER

Defendants, AWARE WOMAN CENTER FOR CHOICE, INC., a Florida corporation, EDWARD W. WINDLE, JR., and PATRICIA B. WINDLE, by and through their undersigned attorney, hereby move for leave to file an affidavit in support of a Motion for Protective Order pursuant to Rule 26 of the Federal Rules of Civil Procedure and Local Rule 3.04. The protective order has been requested in conjunction with Defendants' Response to Plaintiff's Motion to Compel and is needed to protect Defendants from annoyance, intimidation and oppression. Defendants' counsel has in good faith attempted to confer with opposmg counsel in an effort to resolve the dispute without Court action, but those efforts have been unsuccessful. In support of this Motion for Leave to File Affidavit in Support of Motion for Protective Order, Defendants state as follows:

1 . On January 13, 1998, Plaintiff propounded Interrogatories upon each named Defendant. On February 12, 1998, Defendants served their objections to Plaintiff s Interrogatories and Answers to Interrogatories. On April 9, 1998, Plaintiff served his Motions to Compel Answers to Interrogatories. Defendants served their Response and Memorandum in Opposition to Motions to Compel Interrogatories, requesting this Court enter a Protective Order in favor of Defendants.

Defendants seek leave to file the attached Affidavit of Patricia Baird-Windle identified as Exhibit "A," to support Defendants' request for a protective order.

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 5th day of May, 1998.

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