PLAINTIFF'S RESPONSE TO DEFENDANTS' REPLY IN SUPPORT OF MOTION FOR LEAVE TO FILE SECOND AMENDED COUNTERCLAIM

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
RANEY V AWARE WOMAN
DOCKET / CHRONOLOGICAL FILE
PLAINTIFF'S RESPONSE TO DEFENDANTS' REPLY IN SUPPORT OF MOTION FOR LEAVE TO FILE SECOND AMENDED 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 DEFENDANTS' REPLY IN SUPPORT OF MOTION FOR LEAVE TO FILE SECOND AMENDED COUNTERCLAIM

Comes now the Plaintiff, Meredith T. Raney, Jr., by and through his undersigned attorney, who responds to the Defendants' Reply In Support Of Motion For Leave To File Second Amended Counterclaim, saying:

1. The undersigned attorney certifies that all of his Rule 3.01 (g) statements have been true and correct and in compliance with the rules of this Court. Opposing counsel, however, has intentionally misstated the facts about communication between the attorneys. The undersigned will be pleased to furnish telephone records to the Court, which demonstrate the truthfulness of the undersigned attorney and the false assertions by opposing counsel. It is plain that were the undersigned attorney to have both a dedicated facsimile line and an office e-mail address, then opposing counsel would be insisting on homing pigeons or smoke signals.

2. Opposing counsel testifies no more accurately when railing and ranting about the Case Management Scheduling Order of which he has never sought modification.

WHEREFORE, the Defendants' Motion For Leave To File Second Amended Counterclaim should be denied.

Respectfully submitted,
Christopher F. Sapp <signed>
Post Office Box 1012
Lehigh Acres, Florida 33970
(941) 368-3922
Florida Bar Number 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 Lucas, Esquire, Post Office Box 1433, Melbourne, Florida 32902, Susan England, Esquire, 2805 Lakeview Drive, Fern Park, Florida 32730 and to Lawrence-M. Sift, Esquire, O'Connor & Meyers, PA, 2801 Ponce de Leon Blvd., 9th Floor, (Coral Gables) Miami, Florida 33134 this 14th day of December, 1998.

Christopher F. Sapp <signed>
Attorney