DEFENDANTS' SUBPOENA FOR DEPOSITION DUCES TECUM (5/11/98)

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
DEFENDANTS' SUBPOENA FOR DEPOSITION DUCES TECUM (5/11/98)

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' SUBPOENA FOR DEPOSITION DUCES TECUM (5/11/98)

TO: MEREDITH T. RANEY, JR.
2488 Burns Avenue
Melbourne, Florida 32935

YOU ARE COMMANDED to appear before a person authorized by law to take depositions at the offices of Frese, Nash & Torpy, P.A., 930 South Harbor City Boulevard, Suite 505, Melbourne, Florida, on May 28 and May 29, 1998, at 10:00 a.m. on each date, for the taking of your deposition in this action and to have with you at that time and place the following:

SEE ATTACHED EXHIBIT "A"

If you fail to appear, you may be held in contempt of court. You are subpoenaed to appear by the following attorneys, and unless excused from this subpoena by these attorneys or the court, you shall respond to this subpoena as directed.

DATED on May 11, 1998.

LISA L. HOGREVE, ESQ.
For the Court
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

FRESE, NASH & TORPY, P.A.
Attorneys for Defendants
Florida Bar No. 0104840
930 South Harbor City Blvd., Suite 505
Melbourne, FL 32901
(407) 984-3300

EXHIBIT "A"

DEFINITIONS

"Document" means any written or graphic matter or other means of preserving thought or expression and all tangible things from which information can be processed or transcribed, including the originals and all non-identical copies, whether different from the original by reason of any notation made on such copy or otherwise including but not limited to, correspondence, memoranda, notes, messages, letters, telegrams, teletype, telefax, bulletins, meetings or other communication, inter-office and intra-office, telephone calls, diaries, chronological data, minutes, books, reports, charts, ledgers, invoices, worksheets, receipts, returns, computer printouts, prospectuses, financial statements, schedules, affidavits, contracts, canceled checks, transcripts, statistics, surveys, magazine or newspaper articles, releases (and any and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphs or aural records or representations of any kind, including without limitation, photographs, charts, graphs, microfiche, microfilm, video tape, recordings, motion pictures and electronic, mechanical or electric recordings or representations of any kind (including without limitation, tapes, cassettes, disks and records).

DOCUMENTS TO BE PRODUCED

1 . Any and all documents relating to Plaintiffs education, training, qualifications, job skills, certification, experience, licensure, organizational activities, and any other involvement in providing health care services to others, since Plaintiff's completion of high school, up to date.

2. Any and all documents and materials used, referred to, or incorporated by Plaintiff in providing any counseling services and/or health care services to others since May of 1994, to date.

3. Any and all letters, applications, and/or documents sent by or to Plaintiff concerning application to, or certification by, any Florida educational, licensing, or certifying agency, in any health care field, since Plaintiff's completion of high school, up to date.

4. Copies of any licenses or certifications held by Plaintiff in any occupation in Florida, if any, since completion of high school, up to date.

5. Any and all diaries and calendars relating to the whereabouts and activities of Plaintiff, and the dates of his participation in Pro-Life activities, since 1988.

6. Any and all videotapes and notes or written material of any kind pertaining to Plaintiff activities relating to AWARE WOMAN CENTER FOR CHOICE, INC., and any other Florida clinics, from 1988 to date.

7. Any and all videotapes in Plaintiffs possession relating to clinic activities in which RANEY participated, including the video of anti-abortion protestors Olsen and Unterburger chained to the fence of Defendants' West Palm Beach clinic, any and all copies of communications to or from Olsen and/or Unterburger, and all receipts for concrete, molds, and bicycle locks purchased since 1988.

8. Any and all documents, including employment records, evaluations, job applications, medical reports, resumes, CVs, pay subs, W-2's, and 1099's from 1988 to date, relating to your ability to work now and in the future, and to the offering, declining, or termination of any prior employment.

9. Any and all correspondence, agreements, understandings, and/or authorizations, to or from Plaintiff, with any and all owners, occupants, and users of the house and property across the street from AWARE WOMAN CENTER FOR CHOICE, INC., commonly known as the "staging house", address 1575 Dixie Way, from 1992 to date, pertaining to the use of said property.

10. Any and all lists, printouts, and/or compilations of license plate numbers copied by you or any other persons from vehicles in the vicinity of AWARE WOMAN CENTER FOR CHOICE, INC., from 1988 to date.

11. Any and all consents, permissions, or authorizations for Plaintiff to obtain and utilize personal information from motor vehicle registrations in Florida.

12. Letters or copies of letters to and from any person believed to be the registered owner of any vehicle(s) seen in the parking lot or vicinity of AWARE WOMAN CENTER FOR CHOICE, INC., from 1988 to date.

13. Letters or copies of letters and all other documents to or from any person in any state vehicle registration office or department concerning information about individuals with registered vehicles, from 1988 to date.

14. Copies, in any and all forms, of any and all correspondence, letters, memos, notes, or other communications concerning "Pro-Life" activities, to or from Plaintiff, made to or sent from any and all of the following individuals, organizations, or entities:

(a) Joseph Scheidler;
(b) Judy Madsen;
(c) Ed Martin;
(d) Eric Rudolph;
(e) Randall Terry;
(f) Bruce Cadle;
(g) Pat Mahoney,
(h) Andrew Scholberg;
(i) Timothy Murphy;
(j) Mark Crutcher,
(k) Operation Rescue;
(1) Operation Goliath;
(m) Rescue America;
(n) Pro-Life Action League, Inc.;
(o) Paul Hill;
(p) Michael Griffin;
(q) Americans United for Life;
(r) Life Dynamics, Inc.;
(s) ACLJ, the American Center for Law and Justice;
(t) The Rutherford Institute;
(u) Fr. Frank Pavone;
(v) Liberty Counsel;
(w) Lambs of Christ;
(x) Chris Weiss;
(y) Any church in Florida;
(z) American Family Association; and
(aa) Focus on the Family.

15. Your copies of the Supreme Court decision in Madsen v. WHC, 512 U.S. 753 (1994), and of any and all injunctions issued in that case.

16. Your copies of any and all books, articles, pamphlets, training materials and manuals, and other written materials on ways and means to interact with abortion providers, including, but not limited to:

(a) Scheidler, "Closed: 99 Ways to Stop Abortion";
(b) Crutcher, "Firestorm";
(c) "Army of God: When Life Hurts, We Can Help";
(d) "Abortion Buster's Manual," by Operation Rescue of California; and
(e) Blanchard, "Religious Violence and Abortion."

17. Any and all books, articles, pamphlets, manuals, printouts, and/or other information relating to the making of any kind of toxic chemical, gas, or explosive device.

18. Copies of any and all prescriptions issued to you from 1988 to date for any kind of medication, including those for treatment of manic depression and other mental illness.

19. Any and all written evidence in any form of continuing education in counseling by Plaintiff from 1994 to date.

20. Any and all written materials authored all or in part by Plaintiff concerning "sidewalk counseling."

21. Any and all documents since 1978 to date, pertaining to any civil or criminal proceedings in which Plaintiff was a party, witness, or other participant, including as a criminal defendant or party to divorce proceedings.

22. Copies of any malpractice insurance policy held by Plaintiff to cover errors or omissions in "sidewalk counseling", and/or other acts or omissions, and any homeowners and/or general liability policies held by Plaintiff.

23. Any and all correspondence to or from Plaintiff concerning financial support, and the analysis of possible claims, defenses, and counterclaims, in this lawsuit with any persons, enmities or organizations, other than communications with counselor Christopher Sapp, Esq.

24. Any and all correspondence, memos and/or other written material to or from Plaintiff, concerning financial support, the use of real or personal property or equipment, for Pro-Life activities, said property or equipment belonging to any church situated in Florida.

25. All local and long distance telephone records of calls, e-mails, cell phones, and other communications in the name of or used by Plaintiff from 1994 to date.

26. Any letters, titles, rental papers, or other documents pertaining to any vehicle or truck utilized by Plaintiff to stand upon and look over onto AWARE WOMAN CENTER FOR CHOICE, INC. property from 1988 to date.

27. Any binoculars owned by or in possession of Plaintiff used to observe persons, objects, or license plates on AWARE WOMAN CENTER FOR CHOICE, INC. property from a place outside said property.

28. All files, records, dossiers, and/or compilations, whether paper or electronic, assembled all or in part by Plaintiff concerning any physicians, clinic staff member, owner, defender, patient, or other person associated with AWARE WOMAN CENTER FOR CHOICE, INC. from 1988 to date.

29. Copies of any and all petitions and policy statements ever signed or endorsed by Plaintiff concerning abortion at any time up to date.

30. Copies and transcripts of any and all statements, affidavits, and depositions ever given by Plaintiff in any time or place under oath.

31. Any and all communications to or from Linda McKusick.

32. Plaintiff's personal scrapbook from the earliest Pro-Life entries up to date.

33. Any documents, letters, or other written material which you believe supports the claims you have made in this lawsuit.

34. Plaintiff's current passport, and any expired passports acquired by Plaintiff since 1988.