PLAINTIFF'S SECOND MOTION TO QUASH SUBPOENA

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S SECOND MOTION TO QUASH SUBPOENA

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 SECOND MOTION TO QUASH SUBPOENA

Comes now the Plaintiff, Meredith T. Raney, Jr., by and through his undersigned attorney, saying:

1 . These Motions were preceded by good faith effort on the part of moving counsel to confer with opposing counsel in order to resolve these issues; such effort was not successful. Moving counsel has complied with Local Rule 3.01(g).

2. The Subpoena For Deposition Duces Tecum was issued on behalf of opposing counsel on May 11, 1998; and later served on the Plaintiff. A copy is attached for reference.

3. This Motion is based upon the unreasonable time for compliance with the command, the creation of undue hardship and the required disclosure of privileged or protected matters; the subpoena is meant to harass and annoy and libel said Plaintiff

4. The subpoena, and its service on Plaintiff, has been utilized as an improper device to evade the Local Rules and the Federal Rules of Civil Procedure.

WHEREFORE, the Plaintiff requests that this subpoena be quashed by the Court and that all appropriate relief be granted.

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

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to Vincent G. Torpy, Jr., Esquire, 930 S. Harbor City Blvd., Suite 505, Melbourne, Florida 32901 this 22nd of May, 1998.

Christopher F. Sapp <signed>
Attorney