AFFIDAVIT OF SEAN DOHERTY

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
AWARE WOMAN V RANEY
DOCKET / CHRONOLOGICAL FILE
AFFIDAVIT OF SEAN DOHERTY

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
CASE NO.: 99-05-CV-ORL-18
DISPOSITIVE MOTION

AWARE WOMAN CENTER FOR CHOICE, INC., et al.,
Plaintiffs,
v.
MEREDITH T. RANEY, et al.,
Defendants.

AFFIDAVIT OF SEAN DOHERTY

STATE OF NEW YORK
COUNTY OF QUEENS

BEFORE ME, the undersigned authority, personally appeared Sean Doherty, who being by me first duly sworn, deposes and says as follows:

1. The facts and matters stated herein are based upon my personal knowledge.

2. I am the Chief Executive Officer of TML Information Services, Inc. ("TML"). As such, I am authorized to make this affidavit on TML's behalf.

3. TML is an information service. TML provides or enables access by multiple users to computer servers.

4. TML provides the services referenced in paragraph 3 to the State of Florida. TML provides these services to the State of Florida pursuant to a "Contract for Network Services for Public Access to the Florida Department of Highway Safety and Motor Vehicles" dated May 1, 1992, (the "Network Services Contract"). Pursuant to the Network Services Contract, TML provides access to certain public records established and maintained by the State of Florida. A true and correct copy of the Network Services Contract is attached as Exhibit "A."

5. Defendant Meredith Raney was approved by the State of Florida to access its public records as set forth in the Network Services Contract.

6. I am under no disability or incapacity that would render me incompetent to testify to the facts and matters stated in this affidavit.

Sean Doherty <signed>
Affiant

STATE OF NEW YORK
COUNTY OF QUEENS

The foregoing instrument was acknowledged before me this 29th day of June, 1999, by SEAN DOHERTY who is personally known to me or has produced U. S. DOT ID #17405 as identification.

Melinda Bloom <signed>
Notary Public
Commission No. 41-4963628
State of New York