PLAINTIFF'S MOTION AND MEMORANDUM TO AMEND CASE MANAGEMENT AND SCHEDULING ORDER

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S MOTION AND MEMORANDUM TO AMEND CASE MANAGEMENT AND SCHEDULING ORDER

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 AND MEMORANDUM TO AMEND CASE MANAGEMENT AND SCHEDULING ORDER SO AS TO PROVIDE ADDITIONAL TIME FOR DISCOVERY

Plaintiff, Meredith T. Raney, Jr., by and through his undersigned attorney, hereby respectfully moves for an enlargement of time to complete discovery together with a corresponding amendment of the Case Management and Scheduling Order, in support thereof saying:

1. Plaintiff has been prevented from obtaining orderly and systematic discovery because he has been at least temporarily barred from obtaining certain information from Defendants particularly in support of his claims for punitive damages,

2. Plaintiff is requesting an enlargement of al least ninny (90) days from the final resolution of his attempt to resolve this legal impasse in order to complete his discovery.

3. This motion from enlargement of time is made before the expiration of the period originally prescribed for the completion of discovery by the Plaintiff.

WHEREFORE the Plaintiff, Meredith T. Raney, Jr., hereby requests an enlargement of the time permitted him for discovery and a corresponding modification of the Case Management and Scheduling Order.

MEMORANDUM

Plaintiff, Meredith T, Raney, Jr., by and through his undersigned attorney, attaches this Memorandum in support of the foregoing Motion in compliance with the Local Rules, saying:

1. The undersigned attorney hereby certifies that he has discussed this Motion with opposing trial counsel, Roy Lucas, Esquire; that Mr. Lucas has no objection to the Motion and the granting of the enlargement of time sought therein. Local Rule 3.0l (g) has been complied with.

2. This Motion is brought pursuant to Rule 6(b) of the Federal Rules of Civil Procedure before the expiration of the period originally prescribed in the Case Management and Scheduling Order previously entered in this case.

3. Plaintiff has shown that the granting of this Motion is appropriate as he will be deprived of due process otherwise.

WHEREFORE, Plaintiff, Meredith T. Raney, Jr., has demonstrated that the time for completion of his discovery should be enlarged.

Respectfully submitted,
Christopher F. Sapp <signed>
PO Box 1012
Lehigh Acres, Florida 33970
(941) 368-3922
Florida Bar No. 0097823
Attorney for Plaintiff

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to Roy Lucas, Esquire, Post Office Box 153957. Melbourne, Florida 32902 and to Susan England, Esquire, 2805 Lakeview Drive, Fern Park, Florida 32730 this 11th day of September, 1998.

Christopher F. Sapp <signed>
Attorney