PLAINTIFF'S AFFIDAVIT

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S AFFIDAVIT

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

AFFIDAVIT OF MEREDITH T. RANEY, JR.

STATE OF FLORIDA
COUNTY OF BREVARD

BEFORE ME, the undersigned authority, personally appeared, MEREDITH T. RANEY, JR., who after being duly sworn by me according to law, deposes and states as follows:
1. My name is Meredith T. Raney, Jr. I live in Brevard County, Florida and I am the Plaintiff in this lawsuit.
2. The Complaint for this lawsuit (Doc. No. 1) is included in this Affidavit by reference. I have read the Complaint and the facts it contains are true and correct.
3. I am a full time provider of reproductive health services.
4. I began providing reproductive health services at Defendant AWCC's facility in late 1989.
5. I have had many conversations with Defendant Patricia Baird-Windle. She has informed me that she supported adoption as an alternative to abortion and that she in fact has her own adoption agency.
6. I later verified with the Florida Division of Corporations that she does indeed have Hope Adoption Agency, Inc., a Florida non-profit corporation, located at the same facility as Defendant AWCC, 1564 Dixie Way. The Corporate Document Number is N48993, filed 05/20/1992. The corporation is active as of 06/20/1998 and filed their latest annual report on 07/21/1997. The officers are Defendant Patricia Baird-Windle, Defendant Edward W. Windle, Jr. and Roni L. Windle.
7. I told Defendant Patricia Baird-Windle that I would volunteer to help with any and all adoption efforts of her adoption agency.
8. I volunteer work for Hope Adoption Agency, Inc., 1564 Dixie Way, Melbourne, FL 32935.
9. I have completed a counseling course put on by Pregnancy Resources, Inc., 110 Bry-Lynn Dr. in W. Melbourne, Florida, 32904. Course topics include:
*Pregnancy Testing
*Fetal Development
*Prenatal Care
*Abortion Procedures
*Birth Control
*Community Resources for Pregnant Women
*Biblical teaching on abortion
*Decision making
10. In addition to this counseling course, I have continued to familiarize myself with new and additional information in the subject area in which I offer reproductive health services.
11. On April 8, 1993, Defendant AWCC, et. al., was issued an injunction that prohibited named respondents from entering a 36 foot wide portion of public property that reached from the Dixie Way property line of the Hope Adoption - Center For Choice facility to the opposite edge of the Dixie Way pavement. This included all of the public paved street and the public sidewalk on the Hope Adoption - Center For Choice facility side of Dixie Way for the entire length of the subject property line along Dixie Way. This public property has become generally known as the "36 foot buffer zone" or just "buffer zone."
12. I am not one of the named respondents on this injunction.
13. Defendants used this injunction to effectively incorporate this 36 foot buffer zone into their facility. Persons approved by Defendants, or their agents, were allowed free access to the buffer zone. Persons not approved were arrested by the Melbourne Police at the direction of Defendants, or their agents.
14. I provide reproductive health services in the buffer zone part of Defendant AWCC's facility. At all times relevant to this litigation, I was providing reproductive health care services there in a lawful and peaceful manner.
15. I have been arrested three times because I was providing reproductive health services in this facility. The dates of these arrests are 01/28/95; 04/26/95; and, 01/24/96.
16. In all three cases, the charges were dismissed.
17. In all three cases, my arrest was recorded on videotape.
18. These arrests had the purpose and effect of unlawfully using force to intimidate me and to interfere with my ability to dispense reproductive health services in this facility.
19. I learned that Melbourne Police Department had a full-time presence with marked police car at the Hope Adoption - Center for Choice facility only during the times when abortions were being performed by Defendant AWCC.
20. It was apparent that Defendants, their agents, or those working in concert with them directed members of the MPD in some capacity. This has subsequently been independently confirmed to me by individual police officers.

FURTHER AFFIANT SAYS NOT.

MEREDITH T. RANEY, JR. <signed>

The foregoing instrument was sworn to and subscribed before me this 23rd day of June, 1998, by Meredith T. Raney, Jr., who is personally known to me or who has produced FL Driver's License, R500-558-46-058-0, as identification and who did take an oath.

Cathy F. Triplett <signed>
NOTARY PUBLIC
State of Florida at Large
My Commission Expires: 9-1-2001