AFFIDAVIT OF DEFENDANT PATRICIA BAIRD WINDLE

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
AFFIDAVIT OF DEFENDANT PATRICIA BAIRD WINDLE

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 DEFENDANT PATRICIA BAIRD-WINDLE

STATE OF FLORIDA
COUNTY OF BREVARD

BEFORE ME, the undersigned authority, personally appeared, PATRICIA BAIRD-WINDLE, who after being duly sworn by me according to law, deposes and states as follows:

1. My name is PATRICIA BAIRD-WINDLE, and I am an owner, President and Executive Director of Defendant, AWARE WOMAN CENTER FOR CHOICE, INC., a Florida corporation, located at 1564 Dixie Way, Melbourne, Florida. I state the foregoing based upon my personal knowledge.

2. Plaintiff, MEREDITH T. RANEY, JR., is an anti-abortion extremist who has demonstrated at AWARE WOMAN since 1989. He has also participated in various activities to cause pressure and intimidation, harassment and invade the privacy of patients, clinic workers, employees, volunteers, doctors, landlords, independent contractors, and owners.

3. Clinic personnel and owners have experienced theft of garbage from their homes. Following these thefts certain Internet postings of the contents of some of the data contained in the stolen trash began appearing on the Internet. In 1992, Plaintiff RANEY was seen in a DIXIE Way dumpster and was reported to police by a neighbor. It is evident that RANEY is participating in trash thefts in order to add to the continuing harassment and invasion of privacy, for which the Internet is the most recent medium.

4. RANEY or his counsel have been providing discovery documents not filed with the Court to anti-abortion activists for posting on "JAY'S KILLER WEB PAGE" (address: www.forerunner.com). This includes Defendants' previous answers to interrogatories. Also posted on this Web Page are all Court documents and various newspaper articles and letters pertaining to the case. If the confidential information sought by RANEY is provided without protection, this information will most definitely be published on the Internet, causing pressure, intimidation, harassment, invasion of privacy and potential harm to those whose names and addresses are divulged. Attached as Defendants' Exhibit "1" is an example of the information relating to this case already posted on the Internet. The information is often altered and distorted to strengthen their claims.

5. Plaintiff RANEY, or those working in concert with RANEY, have obtained through surveillance of the clinic the license plate numbers of thousands of clinic patients, their significant others, and titled vehicle owners of the vehicles used by patients for transport to clinic appointments. RANEY and others have subsequently invaded the privacy of those clinic patients by sending letters to the patients themselves or their family members. These patients may or may not have chosen to have their medical condition or procedure divulged to the targeted family members. I have personally seen such letters which were signed by Plaintiff, RANEY. Attached hereto as Composite Exhibit "2" are samples of letters to clinic patients from RANEY. The content of the letter reveals that RANEY's purpose in sending the letter is to obtain, among other things, the names of clinic doctors.

6. Plaintiff has also used information, which he has obtained at great effort, in order to pressure, intimidate, harass, invade the privacy of, and threaten clinic patients, doctors, employees, volunteers, etc., in an effort to stop patients from seeking, and health care workers from providing, reproductive health services at AWARE WOMAN CLINIC FOR CHOICE, INC., and other similar facilities. These efforts include, but are not limited to, the surveillance of clinic patients, employees, volunteers, doctors and owners with the use of video equipment and binoculars; the stake-out of roadways leading to AWARE WOMAN CENTER; and the tailing of clinic patients, workers and owners in Plaintiff s vehicle.

7. The Plaintiff has, after learning the identity of certain doctors, personally picketed doctors' private residences and offices. RANEY personally organized transport of the picketers and chauffeured them in buses or vans to the picket sites. The following doctors who worked at AWARE WOMAN CENTER FOR CHOICE, INC. were picketed at their homes or offices or both:

(a) Dr. Scott Boone (resigned due to harassment);
(b) Dr. Carlos Arrogante (resigned due to harassment);
(c) Dr. Frank Snydle (resigned due to the harassment);
(d) Dr. Monthree Ruangsamboon (resigned due to the harassment);
(e) Dr. Gostal Arcelin (resigned due to the harassment);
(f) Dr. Steve Coleman (resigned due to the harassment);
(g) Dr. Scott Pendergraft (resigned due to the harassment);
(h) Dr. Patrick Kelly (resigned due to the harassment);
(i) Dr. H. Ravi (resigned due to harassment); and
0) Dr. Randall B. Whitney; and
(k) others as yet unnamed.

8. Other tactics used by Plaintiff RANEY, and those in concert with him, include RANEY's stalking and blackmailing Dr. Snydle. Surveillance of doctor's homes (including that of Dr. Arrogante, Dr. Snydle, Dr. Monthree and Dr. Arcelin), and surveillance of doctors at hotels, motels, airports, and the homes of friends.

9. RANEY is a self-confessed manic depressive who is under doctor's orders to take Lithium (and possibly other drugs) for his condition. Untreated, manic depression causes loss of judgment and recklessness. RANEY has admitted to me that he does not like to take his medication because it interferes with his manic episodes. RANEY was visibly suffering from this mental disorder during a court proceeding in front of Judge Richardson in 1996. RANEY'S behavior prompted Judge Richardson to inquire, "Are you on your medication Mr. Raney?" I believe RANEY does not control his manic depression with the prescribed medication, which makes him a particularly unpredictable and dangerous individual.

10. Many of the clinic's efforts to protect the privacy of doctors that provide services therein have failed due to the extreme efforts of RANEY and those in concert with him. For example, Plaintiff RANEY has been seen by clinic workers staked-out at the highway exit used by clinic escorts.
11. The doctors have also been exposed to defamation of character and endless harassment by the posting of anti-abortion material on the Internet. The material posted includes "unwanted posters" revealing the doctors' identities and other personal information. This Internet harassment has also been directed at clinic staff and patients who have had "personal dossiers" containing personal information and photographs posted on-line. These "unwanted posters" and "personal dossiers" have also been mailed to or posted at doctor's hospitals, the doctor's private medical office and the neighborhoods in which the doctors reside. Similar fliers or unwanted posters have been distributed in the neighborhoods where staff and owners of the clinic reside.

12. When the identity of clinic landlords, or the landlords of clinic doctors are discovered, those landlords are harassed due to their affiliation with the clinic or clinic personnel. AWARE WOMAN CENTER FOR CHOICE, INC. has had one of its leases not renewed due to this harassment. Similar harassment of potential landlords and property owners has interfered with AWARE WOMAN's ability to lease and buy property.

13. Tradesmen and business persons that provide services to the clinic have been hounded in an attempt to deprive the clinic and its patients of those services. For example, RANEY, along with the anti-abortion groups with which he associates, caused roofers to walk off a re-roofing job at the clinic. A lab courier has also been harassed by RANEY and his groups in an effort to disrupt lab services. RANEY and the anti-abortion extremists with which RANEY associates have also attempted to disrupt local police protection and the services of contracted security guards.

14. Suspicious packages have been sent to both Defendants PATRICIA and EDWARD WINDLE's home, and to the AWARE WOMAN clinic, which required the assistance of the local bomb squads for detonation. One such package arrived the night before Dr. Snydle's birthday. Clinic staff and medical personnel have received threatening mail and hate mail.

15. The clinic staff has also been subjected to other acts of harassment which include the re-routing of personal or business mail by the filing of change of address forms with the post office. Out of the twelve incidents of re-routing, nine of the change of address forms were filled out from a local post offices on the same day in either 1994 or 1995. Confidential information relating to Paula Hurley's credit cards were stolen from information gleaned from garbage theft.

16. Defendants have experienced phone shut-offs, changed numbers and diverted telephone lines as additional tactics to discourage them from providing services.

17. The clinic, staff and medical personnel have been exposed to vandalism and pranks, all believed to be part of the tactics utilized by RANEY and his group to disrupt service and discourage Defendants, its staff, and medical personnel from providing reproductive health services. The acts of vandalism include the following: the dumping of Buteric acid inside and outside the Melbourne clinic in December of 1992 and the Port Saint Lucie clinic in October of 1992. Acid has been sprayed under doors, through mail slots and through holes drilled in the roofs. Butyric acid was also poured on Dr. Arrogante's Mercedes sunroof in March of 1993 and placed in Dr. Ruangsamboon's private doctor's office in Winter Springs.

18. The clinic and some doctor's offices have been defaced with spray painted graffiti. Other acts of vandalism include: the stopping up of sewer lines, numerous alarm system set-offs, and the planting of anti-abortion literature in clinic waiting rooms. Glue has been placed in the locks and doorframes of the Melbourne clinic in 1990 and 1992, with multiple incidents of the same nature occurring in the West Palm Beach clinic between 1990 and 1993. Concrete/expansion material has been placed in baby booties and dropped down toilet vent pipes to stop up sewer lines. Propane gas tanks have been tampered with, air conditioning freon lines cut repeatedly, and the entire exterior air conditioning unit was stolen from the Melbourne clinic. Numerous holes have been punched in the clinic perimeter fence to discover the identity of doctors, nails have been placed in the driveway at 1564-76 Dixie Way, Melbourne, and other AWARE WOMAN clinics, the vehicles of defenders and supporters of the clinic have had their tires punctured, valve stems removed, and gasoline drained from their car's gas tank.

19. I have indicated, where applicable, my personal knowledge of RANEY's involvement in the above-described tactics. It is my belief his involvement is far greater than the incidents to which I have testified based on my personal knowledge. The harassment Defendants and others have experienced and which I have set forth hereinabove are consistent with the tactics advocated in anti-abortion literature. I fear for my fife and the lives of my family.

FURTHER AFFIANT SAYETH NAUGHT.

PATRICIA BAIRD-WINDLE <signed>

The foregoing instrument was sworn to and subscribed before me this 5th day of May, 1998, by Patricia BAIRD-WINDLE, who is personally known to me and who did take an oath.

CHRISTINA B. MORGAN
NOTARY PUBLIC
State of Florida at Large
My Commission Expires: APR: 17, 2001

I CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to Christopher F. Sapp, Esq., P.O. Box 1012, Lehigh Acres, FL 33970, this day of 5th May, 1998.

FRESE, NASH & TORPY, P.A.
BY: LISA L. HOGREVE <signed>
Florida Bar No. 0104840
930 S. Harbor City Blvd., Suite 505
Melbourne, FL 32901
(407) 984-3300
Attorney for Defendants