DEFENDANTS EWW & PBW'S OBJECTIONS TO INTERROGATORIES

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
DEFENDANTS EWW & PBW'S OBJECTIONS TO 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

DEFENDANTS EWW & PBW'S OBJECTIONS TO INTERROGATORIES

Defendants, EDWARD W. WINDLE, JR. and PATRICIA B. WINDLE, by and through their undersigned attorneys, hereby object to the following interrogatories propounded by Plaintiff, and allege:

1. Defendants object to the information requested in paragraph 2 inasmuch as this information is irrelevant and not calculated to lead to the discovery of relevant evidence. Without waiving the above objection, Defendants will respond to the question as it relates to being employed by AWARE WOMAN CENTER FOR CHOICE, INC.

2. Defendants object to answering interrogatory no. 3 inasmuch as the information requested is irrelevant and not calculated to lead to the discovery of admissible evidence. Additionally, the interrogatory is vague and overbroad.

3. Defendants object to answering interrogatory no. 4 inasmuch as the information requested is irrelevant and not calculated to lead to the discovery of admissible evidence.

4. Defendants object to answering interrogatory no. 6 inasmuch as the information requested is irrelevant and not calculated to lead to the discovery of admissible evidence. Additionally, interrogatory no. 6 is vague, unclear and overbroad and Plaintiff is unable to determine specifically the information requested by Plaintiff.

5. Defendants object to answering interrogatory no. 7 inasmuch as the information requested is irrelevant and not calculated to lead to the discovery of admissible evidence. Without waiving this objection, Defendants will respond to the interrogatory as it relates to the office of AWARE WOMAN CENTER FOR CHOICE, INC., located at 1564-76 Dixie Way, Melbourne, Florida.

6. Defendants object to answering interrogatory no. 8 inasmuch as the information requested is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence.

7. Defendants object to answering interrogatory no. 9 inasmuch as the information requested is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence.

8. With regard to interrogatory no. 12, Defendants object to revealing the residential address and phone number of the individuals inasmuch as this information is confidential and in the event that the residential address and phone number of these individuals were divulged to Plaintiff, it could lead to an invasion of privacy and personal harassment; and, there is the possibility that the individual's personal safety would be compromised. Without waiving this objection, Defendants will, however, respond to the other inquiries contained within interrogatory no. 12.

9. With regard to interrogatory no. 13, Defendants object to revealing the residential address and phone number of the individuals inasmuch as this information is confidential and in the event that the residential address and phone number of these individuals were divulged to Plaintiff, it could lead to an invasion of privacy and personal harassment; and, there is the possibility that the individual's personal safety would be compromised. Without waiving this objection, Defendants will, however, respond to the other inquiries contained within interrogatory no. 13.

10. Defendants object to answering interrogatory no. 15 inasmuch as the information requested is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. Additionally, Defendants object to revealing the residential address and phone number of the individuals inasmuch as this information is confidential and in the event that the residential address and phone number of these individuals were divulged to Plaintiff, it could lead to an invasion of privacy and personal harassment; and, there is the possibility that the individual's 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