DEFENDANTS' REQUEST FOR ADMISSIONS

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
DEFENDANTS' REQUEST FOR ADMISSIONS

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' REQUEST FOR ADMISSIONS

Defendants, AWARE WOMAN CENTER FOR CHOICE, INC., a Florida corporation, EDWARD W. WINDLE, JR., and PATRICIA B. WINDLE, request Plaintiff, MEREDITH T. RANEY, JR., admit the truth of the following matters:

1. Plaintiff did not obtain authorization from Defendants to provide services in conjunction with its facility located at 1564 Dixie Way, Melbourne, Florida.

2. At all times pertinent to the Complaint Plaintiff was aware that Defendants did not want Plaintiff on its property or in the buffer zone.

3. Plaintiff's objective in providing "services" at the clinic is, and was to prevent abortions.

4. Plaintiff has demonstrated in the vicinity of the Clinic prior to, during, and after the events described in Plaintiff's Complaint.

5. Plaintiff's objective in demonstrating in the vicinity of the clinic is, and was, to prevent abortions.

6. Plaintiff is, and at all times pertinent to the Complaint was, a member of the anti-abortion movement.

7. Plaintiff is, and at all times pertinent to the Complaint was, a participant in the anti-abortion movement.

8. Plaintiff is, and at all times pertinent to the Complaint was, a demonstrator in the anti-abortion movement.

9. Plaintiff is, and at all times pertinent to the Complaint was, a supporter of the anti-abortion movement.

10. Plaintiff is, and at all times pertinent to the Complaint was, a spokesperson for a group or groups aligned with the anti-abortion movement.

11. Plaintiff is, and at all times pertinent to the Complaint was, an organizer or facilitator of anti-abortion demonstrations.

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 27th 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