PLAINTIFF'S RESPONSE TO DEFENDANTS MOTION TO FILE THIRD PARTY COMPLAINT AGAINST INSURERS

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S RESPONSE TO DEFENDANTS MOTION TO FILE THIRD PARTY COMPLAINT AGAINST INSURERS

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 DEFENDANTS MOTION TO FILE THIRD PARTY COMPLAINT AGAINST INSURERS

The Plaintiff, Meredith T. Raney, Jr., by and through his undersigned attorney, hereby responds to Defendants' motion to file third party complaint against insurers, saying:

1. Plaintiff acknowledges that he has filed a well-founded complaint against Defendants under which said Defendants are all obviously liable to Plaintiff for substantial damages and other sums for their three violations of FACE.

2. Plaintiff has no objection to the Defendants bringing their insurers to this cause in order that said insurers can be subjected to liability for the payment of considerable sums to the Plaintiff.

WHEREFORE, Plaintiff acknowledges the desirability of requiring the Defendants' insurers to be part of this action so that Plaintiff can recover all of his damages, costs, expenses and other sums from all persons who are liable therefore.

Respectively submitted,

Christopher F. Sapp <signed>
Post Office Box 1012
Lehigh Acres, Florida 33970
(941) 368-3922
Florida Bar No. 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 Lugas, Esquire, Post Office Box 153957, Melbourne, Florida 32902 and to Susan England, Esquire, 2805 Lakeview Drive, Fern Park, FL 32730 this 19th day of August, 1998.

Christopher F. Sapp <signed>
Attorney