PLAINTIFF'S RESPONSE TO MOTION TO AMEND COUNTERCLAIM

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S RESPONSE TO MOTION TO AMEND COUNTERCLAIM

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 MOTION TO AMEND COUNTERCLAIM

Meredith T. Raney, Jr., the plaintiff, by and through his undersigned attorney responds to the defendants Motion To Amend Counterclaim, saying:
1. Moving counsel did not make a good faith effort to confer with the undersigned and is in violation of Local Rule 3.01(g).
2. Plaintiff has supplied video tapes of all three episodes described in his complaint, together with all discovery requested by the defendants, which all show that there is no factual basis for the proposed amended counterclaim.

WHEREFORE, the Plaintiff, Meredith T. Raney, Jr., requests that the relief sought by the Defendants be denied.

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

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 8th day of May, 1998.

Christopher F. Sapp <signed>
Attorney