PLAINTIFF'S FIRST SET OF INTERROGATORIES TO AWCC

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

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

PLAINTIFF'S FIRST SET OF INTERROGATORIES TO AWCC

TO: AWARE WOMAN CENTER FOR CHOICE, INC.
c/o Vincent G. Torpy, Jr., Esquire
903 Harbor City Blvd., Suite 505
Melbourne, Florida 32901

Pursuant to the Case Management Report filed in this cause and the Federal Rules of Civil Procedure, Plaintiff, Meredith T. Raney, Jr., has this date served upon the Defendant, Aware Woman Center For Choice, Inc., the following Interrogatories, numbered 1 through 18, to be answered separately in writing and under oath within 30 days from the service hereof.

INTERROGATORIES

1. What is the name and address of the person answering these interrogatories, and, if applicable, the person's official position or relationship with the party to whom the interrogatories are directed?
ANSWER: Patricia Baird-Windle, owner, President and CEO and Executive Director of Aware Woman Center for Choice, Inc., 1564-76 Dixie Way, Melbourne, FL 32935.

2. Please list the names, dates of employment, residence address, mailing address and telephone numbers, of all your employees for the past five years.
ANSWER: See objections served simultaneously herewith.

3. Please list the officers of this corporation for the past five years, including residence address, mailing address, and telephone number, together with the specific office held and the duration of such tenure.
ANSWER: See objections served simultaneously herewith. Patricia Baird-Windle, President; Edward W. Windle, Vice President/Secretary and Treasurer through December 31, 1997. Beginning 1/1/98, Patricia Baird-Windle holds all corporate offices. Address for each is Aware Woman Center for Choice, Inc., 1564-76 Dixie Way, Melbourne, FL 32935. Phone (407) 242-0220.

4. Please list all directors of this corporation for the past five years including the residence addresses, mailing addresses and telephone numbers, together with the specific office held and the duration of such tenure.
ANSWER: See objections served simultaneously herewith. Patricia Baird-Windle and Edward
W. Windle, through 12/31/97. Beginning 1/1/98, Patricia Baird-Windle is the sole director. Addresses stated hereinabove.

5. Is this corporation the holder of a Sub-Chapter S election for income tax purposes and has it been so treated for tax purposes at any time the past five years?
ANSWER: No.

6. Please describe the formality taken by Aware Woman Center for Choice, Inc. in the making and execution of its corporate decisions.
ANSWER: See objections served simultaneously herewith.

7. At what locations does Aware Woman Center for Choice, Inc. conduct business? And state the owner of each location together with the residence address and mailing address of each owner and the owner's telephone number.
ANSWER: See objections served simultaneously herewith. The owner of the building located at 1564-76 Dixie Way, Melbourne, FL is the Revocable Trust of Patricia Baird-Windle.

8. Please list all occupational or business licenses and permits of the corporation for the past five years and the qualifications needed to obtain such licenses, together with the name and address of the issuing agency.
ANSWER: See objections served simultaneously herewith.

9. Please state if you have been a party within the past five years, either as plaintiff or defendant, in a lawsuit or administrative action, other than the present matter, and, if so, state whether you were plaintiff or defendant, the nature of the action and the date and place in which such action was filed.
ANSWER: See objections served simultaneously herewith.

10. What business or occupational organizations has this corporation been a member of the past five years, stating the mailing address thereof and any qualification for membership?
ANSWER: See objections served simultaneously herewith.

11. What sort of business has Aware Woman Center for Choice, Inc. operated at 1564 Dixie Way, Melbourne, Florida the past five years?
ANSWER: Women's reproductive health.

12. What goods and services have been available to the public at 1564 Dixie Way, Melbourne, Florida during the past five years?
ANSWER: Annual gynecological examinations, including laboratory tests; birth control education, injections, insertions and prescriptions, abortion-decision counseling and education; abortion and related support services (laboratory testing and ultrasonography).

13. What has been the physical dimension of the facility at 1564 Dixie Way, Melbourne, Florida during the past five years?
ANSWER: The building is approximately 3000 square feet. I do not know the actual dimensions of the facility.

14. What signs have been posted during the past five years at 1564 Dixie Way, Melbourne, Florida anywhere outside the building informing the public as to the nature of goods and services available at this address, and what exactly do the signs state?
ANSWER: See objections served simultaneously herewith.

15. What organizations and persons have provided security for the business operations at 1564 Dixie Way, Melbourne, Florida during the past five years and how were they compensated? Please state the residence and mailing address together with the telephone number of all such organizations and persons and describe their duties and obligations at this location and the time when such services were provided.
ANSWER: See objections served simultaneously herewith. Members of the Melbourne Police Department, 650 Apollo Blvd., Melbourne, FL, (407) 259-1211; compensated with money. Members of the U.S. Marshal Service, address and phone number unknown; compensated with money. Members of the Brevard County Sheriffs Department, 700 S. Park Ave., Titusville, FL, (407) 633-2123; compensated with money. Various volunteers, do not remember their names; they were not compensated.

16. What persons have volunteered their services at 1564 Dixie Way,
Melbourne, Florida during the past five years? Please state residence address and mailing addresses together with telephone numbers and a description and dates of the services volunteered.
ANSWER: See objections served simultaneously herewith. Jonathan M. Luckey, Roberta Sampere, Phyllis Erwin and various others; the names of which I do not recall.

17. Who has information concerning your income, financial net worth an ot er similar accounting or economic information for the past five years? Please include residence and mailing addresses and telephone numbers of such persons.
ANSWER: See objections served simultaneously herewith.

18. Who have the shareholders at this corporation been the past five years? Please state their residence address and mailing address and telephone numbers.
ANSWER: See objections served simultaneously herewith.

AWARE WOMAN CENTER FOR CHOICE, INC.
By: Patricia Baird-Windle <signed>
Title: Pres. & CEO

STATE OF FLORIDA
COUNTY OF BREVARD

SWORN TO AND SUBSCRIBED before me this 11th day of Feb. 1998, by Patricia Baird-Windle, as PRESIDENT of Aware Woman Center for Choice, Inc., who is personally known to me and who did take an oath.
PAULETTE ELDER <signed>
NOTARY PUBLIC
My COMMISSION # CC 698708 EXPIRES: November 25, 2001