VERIFICATION AND AFFIDAVIT OF EDWARD WINDLE

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
VERIFICATION AND AFFIDAVIT OF EDWARD WINDLE

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
NO. 97-1197-CV-ORL-19

AWARE WOMAN CENTER, et al.,
Third Party Plaintiffs,

-versus-

SPHERE DRAKE INSURANCE CO PLC, et al.,
Third Party Defendant Insurers,

VERIFICATION AND AFFIDAVIT OF EDWARD WINDLE

EDWARD WINDLE, being duly sworn, states as follows:

1. I am an insured and defendant in the underlying action and a third party plaintiff seeking indemnification and damages from Odyssey Re, Sphere Drake, and Westco.

2. I am familiar with the Third Party Complaint and verify that the factual allegations therein and true and accurate to the best of my information and belief, 'and are documented sufficiently in the exhibits as to present no factual disputes.

3. Neither I, my wife Patricia Baird Windle, nor any employee of AWCC has ever assaulted . Meredith Raney or asked any person or police officer to do so. We have had no control, authority, or employer relationship over the police, and have in fact had great difficulty persuading them to enforce the law against anti-abortion harassers.

4. I obtained the insurance coverage involved here through the Pilkington agency. I sought Comprehensive General Liability and was not told of any other additional liability coverages. Nor did Pilkington nor Sphere tell me of any particular exclusions to watch out for. It was my understanding that this was comprehensive and general coverage for all kinds of unintended liability incidents, over which I and AWCC would have no control, such as faked accidents by the anti-abortion harassers, slips & falls, tripping, and unpredictable arrests. I never heard such incidents might not be covered. Raney's actions certainly were not intended nor known to me in advance.

5. It is important to the survival of the clinic that the insurance we paid so excessively for be real and effective, instead of illusory, and we believe our insistence upon coverage and damages is totally fair and reasonable.

Sworn to and signed this 14th day of September, 1998, by Edward Windle before a Notary Public.

Edward W. Windle <signed>