PLAINTIFF'S RESPONSE TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT AGAINST INSURER

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S RESPONSE TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT AGAINST INSURER

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 RESPONSE TO DEFENDANTS' MOTION FOR PARTIAL SUMMARY JUDGMENT AGAINST THE INSURER

The Plaintiff, Meredith T. Raney, Jr., by and through his undersigned attorney, hereby responds to the Defendants' Motion For Partial Summary Judgment Against Their Insurer, saying:

1. Plaintiff, Meredith T. Raney, Jr., has no objection to the entry of such a partial summary judgment if the same is predicated on the facts of this case which have been correctly pleaded by the Plaintiff and which clearly establish liability to Plaintiff for three violations of FACE by Defendants.

2. Plaintiff does object strenuously, however, to the smears, innuendo, misrepresentations and mis-statements of fact utilized by the Defendants in the various portrayals of this case as contained in the Memorandum used to support their motion.

WHEREFORE, Plaintiff, Meredith T. Raney, Jr., hereby requests that whatever determination is made be based on the correct and true recitation of the facts of this case, same being found in the Complaint.

Respectfully submitted,
Christopher F. Sapp
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 1433, Melbourne, Florida 32902, Susan England, Esquire, 2805 Lakeview Drive, Fern Park, Florida 32730 and to Lawrence M. Siff, Esquire, O'Connor & Meyers, PA, 2801 Ponce de Leon Blvd., 9th Floor, (Coral Gables) Miami, Florida 33134 this 7th day of October, 1998.

Christopher F. Sapp <signed>
Attorney