PLAINTIFF'S FIRST SET OF INTERROGATORIES TO PBW

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

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 PBW

TO: PATRICIA B. WINDLE
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, Patricia B. Windle, 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: Patricia Baird-Windle, 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, President and Executive Director.

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 Gary Allgeyer, Police Officer Ken Olsen, City of Melbourne Attorney James Reinman, former City Manager Sam Halter, former Lt./Capt. Bobby Bowen, Captain George Douglass, Lt./Major Wayne Torpy, former Public Relations Police Officer Joe Davis and many various officers on site whose names I do not recollect.

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. Susan Hill of Raleigh, North Carolina, Mike Doughney and Lauren Nizeley of Maryland, Alan Pollack, Edward W. "Ted" Windle, Roni L. Windle, Edward W. "Tod" Windle, Reid Windle, Eleanor Smeal, Catherine Spillar, Alice Cohan, Nancy Koisin-Kintigh, Frank Oliveri, Lynn Bumpus-Hooper, Andrew Douglass, Phil Long, Nicole Youngman, and others whom I do not recall. After the news was posted on the Internet, I had many casual conversations consisting of two to five casual sentences of general conversation with a number of people as were most of the conversations listed above.

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. Other than the arresting officers listed in interrogatory no. 11 above, I do not know who may have witnessed the "events."

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, but I believe that Mr. Raney's associates who might feel they have a similar complaint may sue me and my company. Mr. Raney's associates include a large group of people who are and have been seen with some regularity at the clinic, including the group who call themselves "sidewalk counselors," those who are seen visiting the house across the street and conferring with Mr. Raney in the vicinity of the site, and those who make pronouncements publicly about the clinic. These people are all identified under the terms anti-abortion, anti-Aware Woman Centers for Choice fanatics/persons. These numbers are large, in excess of 30. Some of their names are known, others are not. These include, but are not limited to the following: Raymond Unterberger, William LeStourgeon and members of his family, Eric Olson, Mark Hall, Allen and Norma Munroe, the Vanderbilts, Nancv Lally, Jay Rogers, Graham Dugas III, Sheila Eschenberg, Cecilia (last name I think is Stansfield), Dwayne Satabe, Lonnie Salberg and members of his family, Cheryl Palmer, Christine and Ron Jagos, and others. It is possible that the list might include virtually everyone who has been arrested at the clinic, a record that I do not have, plus others who have not been arrested.

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.

Patricia B. Windle <signed>

STATE OF FLORIDA
COUNTY OF BREVARD

SWORN TO AND SUBSCRIBED before me this 11th 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.