DEFENDANT AWCC'S OBJECTIONS TO PLAINTIFF'S INTERROGATORIES

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
DEFENDANT AWCC'S OBJECTIONS TO PLAINTIFF'S INTERROGATORIES

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

DEFENDANT AWCC'S OBJECTIONS TO PLAINTIFF'S INTERROGATORIES

Defendant, AWARE WOMAN CENTER FOR CHOICE, INC., by and through its undersigned attorneys, hereby objects to the following interrogatories propounded by Plaintiff, and alleges:

1. Defendant objects to the information requested in paragraph 2 inasmuch as it is overbroad and specifically, requesting the names of Defendant's employees for the past five years is not relevant to the subject matter of the litigation and not reasonably calculated to lead to the discovery of admissible evidence. Additionally, Defendant objects to providing the names and residential addresses and telephone numbers for these employees inasmuch as this information is confidential and if divulged to Plaintiff, it could lead to an invasion of privacy and personal harassment; and, there is the possibility that the individuals' personal safety would be compromised.

2. Defendant objects to providing the residential address and telephone number as requested in interrogatory no. 3 inasmuch as this information is confidential and if divulged to Plaintiff, it could lead to an invasion of privacy and personal harassment; and, there is the possibility that the individuals' personal safety would be compromised. Without waiving the above objection, Defendant will provide the business address and business telephone numbers.

3. Defendant objects to providing the residential address and telephone number as requested in interrogatory no. 4 inasmuch as this information is confidential and if divulged to Plaintiff, it could lead to an invasion of privacy and personal harassment; and, there is the possibility that the individuals' personal safety would be compromised.. Without waiving the above objection, Defendant will provide the business address and business telephone numbers.

4. Defendant objects to interrogatory no. 6 as the question is vague, unclear and overbroad, and Defendant is unable to determine exactly what information Plaintiff is requesting.

5. Defendant objects to providing the residential address and phone number as requested in interrogatory no. 7 inasmuch as this information is confidential and if divulged to Plaintiff, it could lead to an invasion of privacy and personal harassment; and, there is the possibility that the individuals' personal safety would be compromised. Additionally, Defendant objects to the information requested in interrogatory no. 7 as the information requested is not relevant to the subject matter of the litigation and not reasonably calculated to lead to the discovery of admissible evidence with regard to any other location of AWARE WOMAN CENTER FOR CHOICE, INC., other than 1564-76 Dixie Way, Melbourne, Florida. Without waiving the above objections, Defendant will state the owner of the building located at 1564-76 Dixie Way, Melbourne, Florida, and the owners' business address and phone number.

6. Defendant objects to providing the information requested in interrogatory no. 8 as the information requested is not relevant to the subject matter of this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Additionally, Defendant objects to the information requested in interrogatory no. 8 as being vague and overbroad.

7. Defendant objects to providing the information requested in interrogatory no. 9 as the information requested is not relevant to the subject matter of this litigation and not reasonably calculated to lead to the discovery of admissible evidence.

8. Defendant objects to providing the information requested in interrogatory no. 10 as the information requested is not relevant to the subject matter of this litigation and not reasonably calculated to lead to the discovery of admissible evidence.

9. Defendant objects to providing the information requested in interrogatory no. 14 as the information requested is not relevant to the subject matter of this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Defendant has already admitted in its answer to Plaintiff's Complaint that it does provide reproductive health services and constitutes a facility as provided by 18 U.S.C. 248(e)(1).

10. Defendant objects to providing the information requested in interrogatory no. 15 as being overbroad in requesting the names of the organizations and persons who have provided security for the business for the past five years and then, for the past five years to state the time when such services were provided. Additionally, Defendant objects to providing the residential address and telephone number as requested in interrogatory no. 15 inasmuch as this information is confidential and if divulged to Plaintiff, it could lead to an invasion of privacy and personal harassment; and, there is the possibility that the individuals' personal safety would be compromised. Without waiving the above objections, Defendant will answer this interrogatory as to the various organizations that provided security for the business operations at 1654-76 Dixie Way, Melbourne, FL. Additionally, without waiving the above objections, Defendant does not know the residential address and telephone number of the individual U.S. Marshals, police officers or deputy sheriffs.

11. Defendant objects to providing the residential address and phone number as requested in interrogatory no. 16 inasmuch as this information is confidential and if divulged to Plaintiff, it could lead to an invasion of privacy and personal harassment; and, there is the possibility that the individuals' personal safety would be compromised. Additionally, Defendant objects to the information requested in interrogatory no. 16 as being overbroad in requesting the names of the persons who have volunteered during the past five years. Lastly, Defendant objects to providing a "description" of the services volunteered as this information is not relevant to the subject matter of the litigation and not calculated to lead to the discovery of admissible evidence. Without waiving the above three objections, Defendant will provide information as to the names of the persons who volunteered their services at the AWARE WOMAN CENTER FOR CHOICE, INC., on the three different dates Plaintiff was arrested as referred to in Plaintiff s Complaint.

12. Defendant objects to providing the information requested in interrogatory no. 17 as the information requested is not relevant to the subject matter of this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Additionally, Defendant objects to providing the residential address and telephone number as requested in interrogatory no. 17 inasmuch as this information is confidential and if divulged to Plaintiff, it could lead to an invasion of privacy and personal harassment; and, there is the possibility that the individuals' personal safety would be compromised.

13. Defendant objects to providing the information requested in interrogatory no. 18 as the information requested is not relevant to the subject matter of this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Additionally, Defendant objects to providing the residential address and telephone number as requested in interrogatory no. 18 inasmuch as this information is confidential and if divulged to Plaintiff, it could lead to an invasion of privacy and personal harassment; and, there is the possibility that the individuals' personal safety would be compromised.

I HEREBY 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 12th day of February, 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