PLAINTIFF'S ADDITIONAL SUPPLEMENT TO REPORT ON MEETING FOR JOINT PRETRIAL STATEMENT

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S ADDITIONAL SUPPLEMENT TO REPORT ON MEETING FOR JOINT PRETRIAL STATEMENT

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
CASE NO.: 97-1197-CIV-ORL

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 ADDITIONAL SUPPLEMENT TO REPORT ON MEETING FOR JOINT PRETRIAL STATEMENT

Plaintiff, Meredith T. Raney, Jr., by and through his undersigned attorney, hereby additionally supplements the report concerning the meeting for joint pretrial statement, saying:

1. A copy of the transcript of the Meeting For Joint Pretrial Statement which occurred shortly after 1:30 p.m. on December 15, 1998 at 930 South Harbor City Boulevard, Suite 505, Melbourne, Florida, is attached hereto as Exhibit "A".

2. In the transcript, it should be noted that the other attorney present is called Lisa Hargrove. However, I know that this attorney is Lisa Hogreve who has previously signed court papers in this case as an attorney for the Defendants.

3. On July 13th, I was present at Suite 505, 930 South Harbor City Boulevard, Melbourne, Florida in the same conference room with Roy Lucas; I asked him about Ms. Hogreve's future role in the case. Mr. Lucas stated that Ms. Hogreve would continue to be associated with him in the case; so that he could continue using that conference room. Thus it was that Mr. Lucas conducted the deposition of Mr, Raney again at that same room in August.

4. Ms. Hogreve is not blamed for the abbreviated meeting this past Tuesday. She provided the conference room, as usual; she got Mr. Lucas on the speaker phone; she attended the brief session and in no way presented herself as the spokesperson for the Defendants. Ms. Hogreve did all that could reasonably be expected of her, under the circumstances.

WHEREFORE, the undersigned attorney requests that the aforementioned report be additionally supplemented with this exhibit.

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

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to Roy Lucas, Esquire, Post Office Box 1433, Melbourne, Florida 32902, Susan England, Esquire, 2805 Lakeview Drive, Fern Park, Florida 32730 and to Lawrence M. Sift, Esquire, O'Connor & Meyers, PA, 2801 Ponce de Leon Blvd., 9a Floor, (Coral Gables) Miami, Florida 33134 this 17th day of December, 1998.

Christopher F. Sapp <signed>
Attorney

EXHIBIT "A"

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
CASE NO.: 97-1197-CIV-ORL

MEREDITH T. RANEY, JR.,
Plaintiff,
VS.
AWARE WOMAN CENTER FOR
CHOICE, INC, et al,
Defendants.

TRANSCRIPT OF PROCEEDINGS

A Pre-trial held in the above-entitled cause before JEANNETTE E. GROSS, Notary Public in and for the State of Florida at Large, at the law offices of Frese, Nash and Torpy, 930 South Harbor City Boulevard, Suite 505, Melbourne, Florida, commencing at 1:34 p.m. on December 15, 1998.

APPEARANCES:

On behalf of the Plaintiff:
CHRISTOPHER F. SAPP, ESQUIRE
Post Office Box 1012
Lehigh Acres, Florida 33970

On behalf of the Defendants:
ROY LUCAS, ESQUIRE
Post Office Box 1433
Melbourne, Florida 32902-1433
(Appearing telephonically)

Also Present: LISA HARGROVE

WHEREUPON,

MR. SAPP: I suggest that since you're on the phone, why don't we just go ahead and do this as a telephone conference?

MR. LUCAS: Well, it's much too complicated to do without being in person with all the documents.

MR. SAPP: Well, let's get this on the record.

MR. LUCAS: Well, they will have to talk to themselves on the record. That's all I have to say.

MR. SAPP: Miss Hargrove is present.

MS. HARGROVE: I'm not going to be involved in this because I'm not an attorney of record. You will have to work this out on your own.

MR. SAPP: Mr. Lucas was on the phone and he hung up and refused to continue with the conference.
Miss Hargrove, I'll pay for the telephone call if can we use it. If that was your concern, I'll be pleased to pay you in advance for the use of the telephone. I'm trying -

MS. HARGROVE: I don't want to be involved in this on-the-record dispute that you're having with opposing counsel on this pre-trial conference.

MR. SAPP: Miss Hargrove, I've got a copy of the Judge's order with me which specifies the time and location. Your concern was who was paying for the conference call, and I'll be pleased to pay for the call.

MS. HARGROVE: I don't think that was the problem. I requested Mr. Lucas call back if he was going to conduct a pre-trial over the phone. He indicated he was not going to conduct a pre-trial, it was too difficult to do that over the telephone because there were considerable documents that needed to be discussed, and he was incredulous that you refused to meet in Orlando. So it was his desire that it not be conducted over the phone. I'm sure we could have worked something out and the expense of the telephone is not an issue here.

MR. SAPP: It sounded like it was, which was why I was offering to pay for the use of the telephone.

MS. HARGROVE: No, not at all. My understanding from what Mr. Lucas said is he didn't intend to do this over the telephone.

MR. SAPP: Okay. I don't see any sense in us tying up your room any further. I appreciate your courtesy and my regards to Mr. Torpy.

(Concluded at 1:47 pm.)

CERTIFICATE OF REPORTER

STATE OF FLORIDA
COUNTY OF BREVARD

I, JEANNETTE E. GROSS, Notary Public, do hereby certify that I was authorized to and did report the foregoing Proceeding, and that the foregoing pages constitute a true and correct transcription, to the best of my ability, of the proceedings.

I FURTHER CERTIFY that I am neither a relative nor an employee of counsel, nor of either of the parties, and not financially interested in the event of this cause.

DATED this 15th day of December, 1998.

JEANNETTE E. GROSS, Court Reporter
STATE OF FLORIDA
COUNTY OF BREVARD

The foregoing certificate was acknowledged before me this 15th day of December, 1998, by JEANETTE E. GROSS, who is personally known to me.

Notary Public - State of Florida