DEFENDANTS' MOTION FOR LEAVE TO FILE REPLY & SUPPLEMENTAL BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
DEFENDANTS' MOTION FOR LEAVE TO FILE REPLY & SUPPLEMENTAL BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT

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 REPLY & SUPPLEMENTAL BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT - A PENDING DISPOSITIVE MOTION

Defendants AWCC et al. respectfully move this Court for leave to file the appended Reply brief in support of the dispositive Motion for Summary Judgment. In support of this motion AWCC states that new and additional important authorities, proceedings, and information have recently been uncovered which will be of assistance to the Court. These could not be presented in the earlier memorandum in particular, the abstention argument may be affected by the previously unknown pendency of a virtually identical parallel state court case now discussed in the Reply, name Raney v. City of Melbourne, No. 97-3763-CA-X (Fla Cir Ct, Brevard, filed > 3-10-1997)[hereafter "Raney II"].

RESPECTFULLY SUBMITTED:

Roy Lucas <signed>
DC Bar #153957
c/o PO Box 1433
Melbourne, FL 32902-1433
(407) 339-4600

Susan A. England <signed>
Fla Bar #0186081
2805 Lakeview Drive
Fern Park, FL 32730-2007
(407) 339-4600

ATTORNEYS FOR DEFENDANT-COUNTERCLAIMANTS AWCC et al.
[Certificate of Service on subsequent document.]