PLAINTIFF'S RESPONSE TO REQUEST FOR ADMISSIONS

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S RESPONSE TO REQUEST FOR ADMISSIONS

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 RESPONSE TO REQUEST FOR ADMISSIONS

Meredith T. Raney, Jr., by and through his undersigned attorney, hereby responds to the Request For Admissions served by Defendants, Aware Woman Center For Choice, Inc., Edward W. Windle, Jr., and Patricia B. Windle, saying as follows:

1. Neither admitted nor denied. This request assumes that defendants had the authority to lawfully prevent Meredith T. Raney, Jr. from performing reproductive health services such as counseling and referral at the facility located at 1564 Dixie Way, Melbourne, Florida which is not true. Meredith T. Raney, Jr. admits that he lawfully provided reproductive health services at 1564 Dixie Way, Melbourne, Florida.

2. Neither admitted or denied. With hindsight Meredith T. Raney, Jr. can say that defendants did not want him performing reproductive health services within the facility since they harassed, threatened and physically mistreated him by use of Melbourne City Police officers. However, since Meredith T. Raney, Jr. was lawfully performing these reproductive health services, he did not expect defendants to violate his rights under FACE. Further, Meredith T. Raney, Jr. does not admit that he was unlawfully on the property of defendants.

3. Denied. Meredith T. Raney, Jr.'s objective in providing reproductive health services was to express love and concern for all - mothers, children, and fathers - who came to the facility. It is true that Meredith T. Raney, Jr. believes that problems can be solved without the intentional taking and destruction of innocent human life.

4. Admitted in part and Denied in part. Meredith T. Raney, Jr. was clearly acting only as a provider of reproductive health services at the times specified in the complaint. At times previous and subsequent to those specified in the complaint he has on several occasions been part of pro-life demonstrations in the vicinity of the Aware Woman Center For Choice, Inc. and other places. Subsequent to the times specified in the complaint, Meredith T. Raney, Jr. has continued to provide reproductive health services at the present facility.

5. Denied. Meredith T. Raney, Jr.'s objective has always been to display love of God and neighbor.

6. Denied. Meredith T. Raney, Jr, is pro-life. Persons such as Paul Hill are anti-abortion and feel that they can solve problems by killing other innocent human beings.

7. Denied. The response is basically identical to number 6. Meredith T. Raney is pro-life and shares that view with most Americans.

8. Denied. This response is basically the same as the previous two items.
Meredith T. Raney, Jr. is pro-life.

9. Denied. This response is basically the same as the several preceding ones.

10. Denied. This response is basically the same as the several preceding ones.

11. Denied. This response is basically the same as the preceding ones. Meredith T. Raney, Jr. does not believe that violence and the intentional destruction of innocent human beings are the appropriate ways to solve problems. The problems of our fellow innocent human beings, large or small, born or unborn, male or female, are solved by expressions of love and by compassion. Meredith T. Raney, Jr. does not believe that killing fellow innocent human beings can be a legitimate means to an end.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was sent by U.S. Mail to Vincent G. Torpy, Jr., Esquire, 930 S. Harbor City Blvd., Suite 505, Melbourne, Florida 32901 this 30' day of March, 1998.

Christopher F. Sapp <signed>
P.O. Box 1012
Lehigh Acres, Florida 33970
(941)368-3922
Florida Bar Number 0097823
Attorney for Plaintiff