PLAINTIFF'S MOTION TO CONDUCT LIMITED DISCOVERY

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S MOTION TO CONDUCT LIMITED DISCOVERY

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
CASE NO. 97-1197-CIV-ORL-19B

MEREDITH T. RANEY, JR.,
Plaintiff,
VS.
AWARE WOMAN CENTER FOR CHOICE, INC., a Florida Corporation, EDWARD W. WINDLE, JR., and PATRICIA B. WINDLE
Defendants.

MOTION TO CONDUCT LIMITED DISCOVERY

COMES NOW, Plaintiff Meredith T. Raney, by and through Counsel and pursuant to Fed. R. Civ. P. 26 and the instructions of the Magistrate at the Pretrial Conference of February 16, 1999, and moves this Honorable Court to allow Plaintiff to conduct limited discovery relevant to Plaintiff's punitive damage claim in his Complaint. In support of this Motion, Plaintiff offers the attached Memorandum in Support.

CERTIFICATION OF COMPLIANCE WITH LOCAL RULE 3.01(g)

Plaintiff's counsel has conferred with Defense counsel Roy Lucas in a good faith effort to resolve the issues raised by this Motion. Counsel have been unable to agree on the resolution of the Motion.

Respectfully submitted,
Michael R. Hirsh <signed>
Admitted Pro hac Vice
125 TownPark Drive
Suite 300
Kennesaw, GA 30144
770-420-8224
404-713-4400 (facsimile)
and
Christopher F. Sapp
Attorney for Plaintiff
Meredith T. Raney, Jr.
P.O. Box 1012
Lehigh Acres, FL 33970
(941) 368-3922
Florida Bar Number 0097823

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by US Mail this 24th day of February, 1999 to the following:

Roy Lucas
P.O. Box 1433
Melbourne, FL 32902-1433

Susan England, Esq.
2805 Lakeview Drive
Fern Park, FL 32730

Lawrence M. Sift, Esq.
O'Connor & Meyers, PA
2801 Ponce de Leon Blvd., 9th Floor
Miami, FL 33134

Michael R. Hirsh <signed>