PLAINTIFF'S FIRST SET OF INTERROGATORIES TO EWW

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

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 EWW

TO: EDWARD W. WINDLE, JR.
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, Edward W. Windle, Jr., the following Interrogatories, numbered 1 through 15, to be answered separately in writing and under oath within 30 days from 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: Edward W. Windle, Jr., 1564-76 Dixie Way, Melbourne, FL 32935.

2. Please list the names, business address, dates of employment, including self employment, where you have worked in the past five years.
ANSWER: See objections served simultaneously herewith. I have worked for Aware Woman Center for Choice, Inc. for the last five years.

3. Please list all occupational or business licenses held by yourself during the past five years, the agency issuing such licenses and the original date of issuance, when they expire and the qualifications needed to obtain such licenses.
ANSWER: See objections served simultaneously herewith.

4. What business related organizations have you been a member of in the past five years, stating the mailing address thereof, and any qualifications for membership?
ANSWER: See objections served simultaneously herewith.

5. Please state in detail your relationship with Aware Woman Center for Choice, Inc. during the past five years.
ANSWER: Co-owner, Vice President and Business Manager for the past five years up through December 31, 1997.

6. Please describe your part in the operation of Aware Woman Center for Choice, Inc. during the past five years.
ANSWER: See objections served simultaneously herewith.

7. At what physical locations has Aware Woman Center for Choice, Inc. conducted business during the past five years
ANSWER: Aware Woman Center for Choice, Inc. has conducted business during the past five years at 1564-76 Dixie Way, Melbourne, FL.

8. Please list all business or occupational schools, courses or classes that you have attended, including the result, date, location and sponsor and the purpose for which they were taken during the past five years.
ANSWER: See objections served simultaneously herewith.

9. Please state if you have been a party, either plaintiff or defendant, in a lawsuit or administrative action, other than the present matter during the past five years, 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. With whom in the city of Melbourne, including its police department, have you directly and indirectly communicated about the business activities of Aware Woman Center for Choice, Inc., and its need for security and police protection during the past five years?
ANSWER: Police Chief Keith Chandler, Police Captain John Short, former Police Captain GaryAllgeyer, and Police Officer Ken Olsen.

11. What persons employed by the city of Melbourne, including its police department, have any personal knowledge as to the facts or allegations of the present lawsuit? Please include residence and mailing addresses and telephone numbers where these are known to you.
ANSWER: The arresting officers on the three different dates of arrest: William L. Bearden, V.A. Pryce, and S.W. Smith.

12. With whom have you discussed the facts and allegations of this lawsuit, other than with your attorneys and persons associated with them? Please include residence and mailing addresses and telephone numbers where they are known to you.
ANSWER: See objections served simultaneously herewith. Patricia Baird-Windle.

13. Whom do you know that witnessed in any way the events described in or alleged by the pleadings in this case, including yourself if you are such a witness? Please include residence and mailing addresses and telephone numbers where they are known to you, together with a synopsis of what each person witnessed.
ANSWER: See objections served simultaneously herewith. See answer to interrogatory no. 11. Also, possibly Jonathan Luckey and Phyllis Erwin. I do not know for sure that they witnessed the "events" and therefore, I would not know exactly what each of these persons witnessed.

14. What are the names and addresses of the persons that you believe may sue your company or yourself as indicated in your counterclaim? Please state the perceived basis for the proposed or threatened litigation.
ANSWER: I cannot list the names and addresses of the persons that may sue my company or myself, as indicated in my Counterclaim because I do not know the identity of these persons. The perceived basis for the proposed or threatened litigation would be the same as Plaintiff, Meredith Raney's basis for this litigation.

15. Who besides yourself has information concerning your income, financial net worth and other similar accounting or economic information for the past five years? Please include residence and mailing addresses and telephone numbers where they are known to you.
ANSWER: See objections served simultaneously herewith.

Edward W. Windle, Jr. <signed>

STATE OF FLORIDA
COUNTY OF BREVARD

SWORN TO AND SUBSCRIBED before me this 12th day of February 1998, by Patricia B. Windle who is personally known to me and who did take an oath.
Paulette Elder <signed>
NOTARY PUBLIC, My commission #CC698708 expires: 11/25/2001.