Plaintiff's letter, 4/24/98

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
Plaintiff's letter, 4/24/98

CHRISTOPHER F. SAPP
Attorney at Law
Post Office Box 1012
Lehigh Acres, Florida 33970
(941)368-3922
April 24, 1998

Vincent G. Torpy, Jr., Esquire
930 Harbor City Blvd., Suite 505
Melbourne, Florida 32901

Re: Raney v. Aware Woman
Case Number 97-1197-CV-ORL- 19B

Dear Mr. Torpy,

I was out of state for a while and see that I have several items from you to which I should respond.

The first is your contention that my client has not complied properly with your various discovery requests. This is obviously not so as one can tell from our answers. Additionally, you failed to direct any criticism to me of our responses when I came to Melbourne earlier this month to personally resolve any holdups on discovery.

The second item concerns the amendment of your counter-claim. In general, I usually make no objection to a proper amendment which otherwise conforms to the law and to the facts of the case, especially where no change is needed in the management of the case. If there are legal or factual shortcomings to your proposed amendment, then I shall certainly object. And if changes are needed in the management of this case, then I will expect to receive full cooperation in obtaining those changes.

As to depositions being started in May: it is impossible for me to understand your proposed timing since we agreed that interrogatories, requests for production, and admissions would all be resolved at least thirty days before the start of oral depositions.

Other attorneys may be substituting for me or joining as additional counsel.

As appropriate, I will keep you informed.

Sincerely,
Christopher F. Sapp <signed>

CFS/js
copy to Meredith T. Raney, Jr