PLAINTIFF'S SECOND MOTION FOR PROTECTION OF PERSON SUBJECT TO SUBPOENA

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

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 SECOND MOTION FOR PROTECTION OF PERSON SUBJECT TO SUBPOENA

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 on behalf of opposing counsel on May 11, 1998; and attached to the Notice of Deposition which was served by mail on May 11, 1998. Copies are attached for reference.

3. Plaintiff has already complied with the Defendants' request for production of documents and things. A copy of the Request For Production dated February 12, 1998 is attached for reference.

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

5. The subpoena was executed and served in violation of the Local Rules and the Federal Rules of Civil Procedure.

WHEREFORE, the Plaintiff moves for protection from the subpoena, together with all appropriate relief.

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 32901 this 22nd day of May, 1998.

Christopher F. Sapp <signed>
Attorney