PLAINTIFF'S MOTION FOR PROTECTION FROM UNTIMELY DEPOSITIONS

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S MOTION FOR PROTECTION FROM UNTIMELY DEPOSITIONS

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 FROM UNTIMELY DEPOSITIONS

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. Notices for Deposition were served by regular U.S. Mail by opposing counsel on May 11, 1998; copies thereof are attached hereto for reference.

3. The earliest date for depositions by the method of notice described above is June 1, 1998.

4. In spite of the time limitation imposed by the Federal Rules of Civil Procedure and the Local Rules, the Defendants persist in seeking untimely discovery in order to annoy, embarrassment, oppress, and unduly burden the Plaintiff.

WHEREFORE, the Plaintiff moves for protection from the untimely taking of depositions and requests that all appropriate relief be granted.

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, Jr., Esquire, 930 S. Harbor City Blvd., Suite 505, Melbourne, Florida 32901 this 22nd day of May 1998.

Christopher F. Sapp <signed>
Attorney