DEFENDANTS' SECOND SET OF INTERROGATORIES

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
DEFENDANTS' SECOND SET OF 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' SECOND SET OF INTERROGATORIES

Defendants, AWARE WOMAN CENTER FOR CHOICE, INC., EDWARD W. WINDLE, JR., and PATRICIA B. WINDLE, by and through their undersigned attorneys, hereby propound the following interrogatories upon Plaintiff, MEREDITH T. RANEY, JR., which interrogatories must be answered within thirty (30) days of service hereof in a manner prescribed by Rule 33 of the Federal Rules of Civil Procedure.

INSTRUCTIONS

Please insert your answers in the space provided following each question. If additional space is needed, so indicate in the space provided, and prepare your answer on a separate sheet of paper and attach.

If a privilege not to answer is claimed, identify each matter as to which the privilege is claimed, the nature of the privilege, and the legal and factual basis for each such claim

If a refusal to answer and Interrogatory is stated on the grounds of burdensomeness, identify the number or estimated number and the nature of the documents needed to be searched, the location of the documents, and the approximate number of persons, hours and cost required to conduct a search.

Answer each Interrogatory on the basis of your entire knowledge.

If all of the information furnished in an answer to all or part of any Interrogatory is not within the personal knowledge of the Affiant, identify each person to whom all or part of the information furnished is a matter of personal knowledge and each person who communicated to the Affiant any part of the information furnished.

If any Interrogatory cannot be answered in full, answer to the extent possible and specify reasons for inability to answer.

Plaintiff may, "in lieu of identifying any document" attach a true copy of such document or communication as an exhibit to their answers to these Interrogatories, along with an explicit reference to the Interrogatory to which each such attached document or communication related.

Interrogatories

1. List the name, address, and telephone number of each individual likely to have discoverable information relevant to disputed facts alleged with particularity in the pleadings, identifying the subjects of the information.
ANSWER: All of the persons identified by the various Defendants, directly or indirectly, as having discoverable information such as former customers and employees of Defendants and the Defendants themselves. This group includes persons from the U.S. Department of Justice and local law enforcement agencies such as the Melbourne police.

In addition there are various people who were formerly part of the abortion industry that can testify as to counseling and other reproductive health services and the size of the facilities; these people may include Miss Norma McCorvey, also known as Jane Roe of Roe v. Wade, Dr. Bernard Nathanson and Dr. Beverly McMillan. Also Cardinal O'Connor from New York City and Father Frank Pavone from the Vatican City may be expert witnesses. I believe that they know a great deal in general about reproductive health services.

There will be witnesses with knowledge of the Defendants' finances, assets and income to determine the appropriate punitive damages but as yet I do not know who these people are.

Some of the local people with knowledge of this case are as follows:
Graham Dugas, 401 Club Trail Apt. #2, Melbourne, Fl 32901 (407)768- 1610

Joel (Pat) Pinkston, 5755 Brabrook Ave., Grant, Fl 32949 (407)725-8816

Richard Vanderbilt, 2235 N. Smathers Cir., Melbourne, Fl. 32935 (407) 254-3925

Christine Jagos, 2655 Forest Run Dr., Melbourne, Fl. 32935 (407) 259-3347

Cheryl Palmer, 2655 Hopi Dr., Melbourne, Fl. (407) 242-2009

Roberta Sampere, 1864 Glenwood Dr., Melbourne, Fl. 32935 (407) 255- 2672

Jonathan Luckey, 1030 Sarno Rd., Melbourne, Fl. 32935 (407) 242-2572

Meredith Raney, 2488 Burns Ave., Melbourne, Fl 32935 (407) 254-5481

Joyce Cabrera, 129 Spinnaker St., Melbourne Beach, Fl. 32951 (407)724- 8639

Lisa Sanford, 1564 Dixie Way, Melbourne, Fl 32935 (407) 242-0220

Melbourne City Manager Henry Hill, former City Manager Sam Halter, former Melbourne City Attorney James Reinman, 900 E. Strawbridge Ave., Melbourne, Fl 32901 (407)727-2900

Chief Keith Chandler, Major John Short, Captain Ron Bell, former Lt. Bobby Bowen, Det. Rick Cary, former Captain Gary Allgeyer, Lt. Mark Laderwarg, Major Wayne Torpy, Sgt. Ken Olson, former Public Relations Officer Joe Davis, former Officer William Bearden, Sgt. V.A. Price, Officer S.W. Smith, Melbourne Police Dept., 650 Apollo Blvd., Melbourne, Fl. 32935 (407) 259-1211

Employees of the U.S. Marshal's Service, names unknown, who were on duty at Defendant Aware Woman Center for Choice, Inc.'s facility at 1564 Dixie Way, Melbourne, Fl. 32935 on January 28, 1995 and April 26, 1995. Persons from the Melbourne Beach Police department.

2. Identify by name, mailing address, and telephone number all business, personal, charitable, religious, and social organizations of which you have been a member in the past five years.
ANSWER: Central Baptist Church, 2503 s Country Club Road, Melbourne, Fl (407) 723-3681

Brevard County Republican Executive Committee, 2000 South Patrick Dr., Indian Harbor Beach, Fl 32937 (407) 779-3500

Christians For Life, 629 S. Wisteria Dr., Melbourne, Fl 32901 (407) 724- 5456

Christian Coalition of Brevard County, PO Box 61397, Palm Bay, Fl 32906 (407) 9521754

Women's Legal Action Coalition, PO Box 362384, Melbourne, Fl. 32936 (407) 242-6925

3. List your employment history for the past five years, including self employment, identifying employer name, address, and phone number, and the dates of employment.
ANSWER: October, 1994 - June, 1995, Wireless Broadcasting Systems of Melbourne, 4450 Eau Gallie Blvd. Suite 180, Melbourne, Fl 32934 (407) 259-5999

4. List each and every time you have been arrested for abortion clinic activity or any other activity relating to the anti-abortion movement in the past ten years, date of arrest, reason for arrest, and the arresting agency.
ANSWER: 4/92 Blocking traffic Buffalo, NY Police Dept.
2/25/93 Trespassing Cocoa Beach, Fl Police Dept.
4/9/93 Trespassing Ft. Pierce, Fl Police Dept.
4/17/93 Contempt of Court Melbourne, Fl Police Dept.
5/22/93 Contempt of Court Melbourne, Fl Police Dept.
6/5/93 Contempt of Court Melbourne, Fl Police Dept.
1/28/95 Contempt of Court Melbourne, Fl Police Dept.
4/26/95 Contempt of Court Melbourne, Fl Police Dept.
1/24/96 Contempt of Court Melbourne, Fl Police Dept

I have specified the charge for these arrests; obviously, the reason for the last three arrests was to prevent me from offering reproductive health services.

MEREDITH T. RANEY, JR. <signed>

STATE OF FLORIDA
COUNTY OF BREVARD

Before me, the undersigned authority, personally appeared MEREDITH T. RANEY, JR., who, by me being first duly sworn and cautioned, states that he executed the foregoing Answers to Interrogatories and that they are true and correct to the best of his knowledge and belief.

Sworn to and subscribed before me this 11 day of March 1998, by MEREDITH T. RANEY, JR., who is personally known to me or who has produced FL DL R500558460580, as identification and who did take an oath.

SUZANNE M. SCHMIDT <signed>
State of Florida at Large
My Commission Expires: Sep. 05, 1998

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that an original and one copy of the foregoing Answers to Second Set of Interrogatories has been delivered by hand to the office of Vincent G. Torpy, Jr., Esquire, 930 Harbor City Blvd., Suite 505, Melbourne, Florida 32901 this 11th day of March, 1998.

Christopher F. Sapp <signed>
Post Office Box 1012
Lehigh Acres, Florida 33970
(941) 368-3922
Florida Bar Number 0097823
Attorney for Plaintiff