PLAINTIFF'S MOTION FOR PROTECTION OF PERSON SUBJECT TO SUBPOENA AND OBJECTIONS TO PRODUCTION FOR INSPECTION AND COPYING

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S MOTION FOR PROTECTION OF PERSON SUBJECT TO SUBPOENA AND OBJECTIONS TO PRODUCTION FOR INSPECTION AND COPYING

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 MOTION FOR PROTECTION OF PERSON SUBJECT TO SUBPOENA; MOTION TO QUASH SUBPOENA; OBJECTIONS TO PRODUCTION FOR INSPECTION AND COPYING

Comes now the Plaintiff, Meredith T. Raney, Jr., by and through his undersigned attorney, saying:

1. These Motions were preceded by good faith effort on the part of moving counsel to confer with opposing counsel in order to resolve these issues; such effort was not successful. Moving counsel has complied with Local Rule 3.01(g).

2. The Subpoena For Deposition Duces Tecum was issued for opposing counsel on May 4, 1998; a copy thereof is attached hereto for reference.

3. Plaintiff has already complied with the Defendants request for production of documents.

4. The intention of the Defendants in issuing said subpoena was to impose undue burden and expense upon Meredith T. Raney, Jr. in violation of the Federal Rules of Civil Procedure.

5. Meredith T. Raney objects to the production of the items and documents specified in said subpoena because the demand is untimely, burdensome, and is meant to harass and annoy said Plaintiff and to libel and diminish improperly the character of said Plaintiff.

6. The Motion To Quash is based upon the unreasonable time for compliance, the creation of undue hardship and the possible required disclosure of privileged or protected matters.

WHEREFORE, the Plaintiff moves for protection from the subpoena, files objections to the production of any items or papers sought thereby, and requests that this subpoena be quashed by the Court, together with all appropriate relief.

Respectively submitted,
Christopher F. Sapp <signed>
Post Office Box 1012
Lehigh Acres, Florida 33970
(941)369-3922
Florida Bar Number 0097923
Attorney for Meredith T. Raney, Jr.

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, 930 S. Harbor City Blvd., Suite 505, Melbourne, Florida 32901 this 11th day of May, 1998.

Christopher F. Sapp <signed>
Attorney

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 OBJECTIONS TO PRODUCTION FOR INSPECTION AND COPYING

Comes now the Plaintiff, Meredith T. Raney, Jr., by and through his undersigned attorney, saying:

1 . These Objections were preceded by good faith effort on the part of moving counsel to confer with opposing counsel in order to resolve these issues; such effort was not successful. Moving counsel has complied with Local Rule 3.01(g).

2. The Subpoena For Deposition Duces Tecum was issued on behalf of opposing counsel on May 11, 1998; and later served on the Plaintiff A copy of the subpoena is attached for reference.

3 . The Objections are based upon the unreasonable time for compliance with the command, the creation of undue hardship and the required disclosure of privileged or protected matters., and demonstrate that the subpoena itself is meant to harass and annoy and libel said Plaintiff.

4. Other objections may be raised in the event that Defendants' request these items in a timely manner.

5. Defendants have previously served a Request For Production with which Plaintiff has fully complied.

WHEREFORE, the Plaintiff files objections to the production of any and all items sought by said Subpoena For Deposition Duces Tecum.

Respectfully submitted,
Christopher F. Sapp <signed>
Post Office Box 1012
Lehigh Acres, Florida 3397
(941) 368-3922
Florida Bar Number 0097823
Attorney for Meredith T. Raney, Jr.

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, 930 S. Harbor City Blvd., Suite 505, Melbourne, Florida, this 22nd day of May, 1998.

Christopher F. Sapp <signed>

Attorney
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