PLAINTIFF'S MOTION FOR CERTIFICATION OF INTERLOCUTORY APPEAL

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S MOTION FOR CERTIFICATION OF INTERLOCUTORY APPEAL

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 CERTIFICATION OF INTERLOCUTORY APPEAL

COMES NOW Plaintiff, by and through counsel, and moves this Honorable Court to allow the interlocutory appeal of this Court's Order dated June 5, 1998, denying Plaintiff's Motion to Compel discovery. In support of this Motion, Plaintiff offers the following grounds:
1 . Plaintiff's discovery of Defendants' financial information is relevant to Plaintiff's demand for punitive damages;
2. There will be no opportunity for meaningful discovery of this information once the trial in this matter has commenced, thus denying Plaintiff's due process rights and unfairly prejudices his opportunity to prosecute this case.
3 The Magistrate's Order conflicts with the Case Management Order of the District Judge;
4. The Magistrate's Order conflicts with the decisions of the Middle District of Florida as previously cited in Plaintiff's Motion to Compel;
5. The Magistrate's Order conflicts with the procedures specified in the Federal Rules of Civil Procedure relating to discovery, particularly as to federal causes of action, and,
6. Plaintiff's counsel certifies that he has complied with Local Rule 3.01 (g) in that he has attempted to resolve these issues with opposing counsel.

Respectively submitted,
Christopher Sapp <signed>
Attorney For Plaintiff
Meredith T. Raney, Jr.
P.O. Box 1012
Lehigh Acres, FL 33970
(941) 368-3922
Florida Bar Number 0097823

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by US Mail to Vincent G. Torpy, Jr., Frese, Nash, & Torpy, P.A, 930 S. Harbor City Blvd., Suite 505, Melbourne, FL 32901 16th day of June, 1998.
Christopher F. Sapp <signed>