AFFIDAVIT OF MEREDITH T. RANEY, JR.

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
AFFIDAVIT OF MEREDITH T. RANEY, JR.

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

AFFIDAVIT OF MEREDITH T. RANEY, JR. IN SUPPORT OF HIS MOTION FOR SUMMARY JUDGMENT AGAINST ALL OF THE DEFENDANTS

Before me, the undersigned authority, personally appeared Meredith T. Raney, Jr., who, being first duly sworn deposes and says:

1. My name is Meredith T. Raney, Jr.

2. I have read the Complaint and all of the facts stated there are true.

3. I was trained as a reproductive health services counselor in 1992. Some of the topics in which I received instruction were:

a. Pregnancy testing
b. Fetal development
c. Prenatal care
d. Abortion procedures and possible complications
e. Birth control
f. Community resources for pregnant women
g. Biblical teaching on abortion
h. Decision making

4. Also, as part of my training as a reproductive health service provider/counselor, I was shown the videos "The Silent Scream" and "Houston Proud?". A copy of these videos is included as segments 1 and 2, respectively, of the composite video tape submitted as part of this affidavit. I have also attached to this affidavit prints of some frames of the videos.

5. The facility in this case is located at 1564 Dixie Way, Melbourne, Florida. There are no signs outside of the building to show what services are available there.

6. This facility is the one described in the Madsen case which was decided by the United States Supreme Court. The boundaries of this facility include at least the private property of the owners plus the public property inside this Madsen buffer zone. It is inside this buffer zone on the public sidewalk where I offer referral information and counseling about pregnancy and its continuation and termination, as well as about adoption. Many women want to know about the maternal injuries, fatal and non-fatal, that have occurred there. Also, these women often have a great need of my help when they have been injured: physically, spiritually or emotionally while at this facility.

7. The Florida corporation, Hope Adoption Agency, is part of the facility at 1564 Dixie Way, Melbourne, Florida. I have attached to this affidavit a copy of information about this adoption agency which I obtained from the Florida Division of Corporations. I have fully supported the efforts of Hope Adoption Agency.

8. Another document that I have attached is the Declaration from one of the trial lawyers in the N.O.W. v. Scheidler case in Chicago which includes Patricia Baird Windle's testimony regarding the services, including adoption counseling, available at the facility at 1564 Dixie Way. Mrs. Windle is one of the class action plaintiffs in the Chicago case, where she is suing protesters and demonstrators for their activities at 1564 Dixie Way, Melbourne, Florida.

9. Three times while I was providing, or trying to provide, referral information and reproductive health service counseling in the facility in question, I was threatened by members of the Melbourne City Police with physical removal from the facility. Each time, the officers carried out their threats by physically removing me from the facility. Each time they told me that they were doing this to enforce the Defendants' private injunction even after I told them I was not subject to that injunction. None of these threats was based on any concern by the officers that I was violating any statute or public ordinance. The officers had obviously been requested by the Defendants to be there when I was trying to provide referral information and counseling help. Clearly, these officers were tools of the Defendants since the Melbourne City Police were not a party to the injunction, and therefore had no other reason to be there. I have no lawsuit pending against any of these policemen or the city.

10. The dates on which these FACE violations took place were January 28, 1995, April 26, 1995 and January 24, 1996. I have videotapes of each of these violations; a true copy of each is included as segments 3, 4, and 5 respectively of the composite video tape submitted as part of this affidavit. Prints from each incident are also attached.

11. I have agreed to accept in lieu of my actual damages, the statutory award of five thousand ($5,000:00) dollars per incident.

12. The Defendants have tried to muddy the water in this case because they do not like or agree with what I say. My actions were directed at helping pregnant mothers with their needs; they were done out of love and concern for these expectant mothers and their unborn children, without any desire to profit from their circumstances. They needed my help and love and that is why I was there those three times offering them referral information and counseling.

Meredith T. Raney, Jr. <signed>

State of Florida )
County of Lee )

SWORN TO and subscribed before me :this 14th day of October, 1998 by Meredith T. Raney, Jr. who identified himself by Florida Drivers License #'R500-558-46-058-0

MARILYN D KESSLER <signed>
Notary Public
My commission #CC442613 expires March 1, 1999
Bonded thru Troy Fain Insurance, Inc.

ATTACHMENTS

FLORIDA DATA ON HOPE ADOPTION AGENCY, INC.

Click here for Florida Division of Corporations data on Hope Adoption Agency, Inc. Search for "Hope Adoption Agency" under Corporate names.

DECLARATION

Thomas Brejcha hereby declares:

1. I am an attorney licensed to practice under the laws of the State of Illinois.

2. I was present in court as counsel of record for several defendants in the trial of a lawsuit entitled, N.O.W. et al, vs. Scheidler, et al, No. 86C7888, held before the United States District Court for the Northern District of Illinois, Eastern Division, on March 11, 1998, when plaintiffs presented testimony from a certain witness, namely, Patricia Baird Windle.

3. A true copy of the transcript of a portion (pp. 1201-02) of said witness' entire testimony, as recorded on pages 1201 through 1244 of the transcript, as prepared by the Official Court Reporter, Ms. Tracey McCullough, is appended hereto.

4. I make the Declaration under penalty of perjury pursuant to the laws of the United States of America on this 6th day of October, 1998.

Of Counsel:
Thomas Brejcha <signed>
Suite 1207
185 North Wabash Avenue
Chicago, Illinois 60601
Tel. 312/782-1680
Fax 312/782-1887

Transcript - Windle - direct Page 1201

past few years we have seen a few patients less, yes.
MR. CARO: Thank you. No further questions, Your Honor.
MR. SACHNOFF: I have no redirect, Your Honor.
THE COURT: All right. Thank you, ma'am, You may step down.

MS. CLAYTON: For our next Witness the plaintiffs call Patricia Windle.

PATRICIA WINDLE, PLAINTIFFS' WITNESS, DULY SWORN

DIRECT EXAMINATION

BY MS. CLAYTON:

Q. Good morning, Miss Windle. Would you please introduce yourself to the ladies and gentlemen of the jury.

A. Yes. I'm Patricia Baird Windle. I'm the founder and owner of Aware Woman's Centers for Choice in Melbourne and West Palm Beach, Florida.

Q. How long have you run the Aware Woman's clinic?

A. We opened first in Coco Beach in 1977.

Q. Would you tell us again how your clinic started.

A. Yes. We opened in Coco Beach in 1977 and then moved the clinic in 1982 to Melbourne, which is nearby, a city nearby. Later opening a tiny clinic in Port St. Lucie and then opening in West Palm Beach I believe in 1986.

Q. Please tell us what services your clinics provide.

A. We provide a full range of gynecological services ranging all the way from pregnancy tests to pelvic exams, minor cryosurgery, sexually transmitted disease testing, urinary tract infection treatment and testing, and a number of other things. We've also provided adoption counseling and assistance through the years. (Emphasis added.)

Q. Do you provide abortions along with the other services?

A. Yes. Yes.

Q. Who else works with you at the Aware Woman clinic in Melbourne?

A. We have seven employees, two doctors. My husband Ted and I in addition to the seven, and my daughter Ronnie Windle is the administrator and the clinic nurse.

Q. What did you and your husband do before starting the clinic?

A. My husband was a professional military officer. He's retired after a full career. And at the time I started the clinic I was the director of a small social service agency, the South Brevard Women's Center.

Q. Are your clinics members of the class of clinics that are bringing this lawsuit?

A. Yes, ma'am.

Q. Would you tell us when you first had contact with Operation Rescue?

A. We were warned in March of '89 that they were coming to do a major blockade in mid-April of '89 and then started [End of portion included in this DECLARATION]

VIDEO FRAMES

AWCC, Jan. 28, 1995 10:42 am, Meredith T. Raney, Jr. providing reproductive health services

AWCC, Jan. 28, 1995 10:45 am, Melbourne Police Officer arresting Meredith T. Raney, Jr.

AWCC, Apr. 26, 1995 9:46 am, Meredith T. Raney, Jr. providing reproductive health services

AWCC, Apr. 26, 1995 9:46 am, Melbourne Police Officer arresting Meredith T. Raney, Jr. Federal Marshal watches.

AWCC, Jan. 24, 1996, Meredith T. Raney, Jr. with counseling literature in hand, providing reproductive health services

AWCC, Jan. 24, 1996, Melbourne Police Officer arresting Meredith T. Raney, Jr.