Jackson Women's Health Organization v. Amy: Complaint

12.12.08


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AMENDED COMPLAINT

Plaintiff, by and through its undersigned attorneys, brings this complaint against the defendants, their agents and successors in office, and in support thereof avers the following:

1. This is a facial and as-applied challenge to a prohibition on the performance of second-trimester abortions in Mississippi except in licensed hospitals or Ambulatory Surgical Facilities (“ASF”). House Bill 1038 (“An Act to amend Section 41-75-1, Mississippi Code of
1972, to provide that abortion procedures after the first trimester shall be performed only at an ambulatory surgical facility or hospital licensed to perform that service, and for related purposes.”) (“Act”) (attached to Complaint as Exhibit A)...


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