Hope Medical Group for Women v. Kim Edward Leblanc: Second Amended Complaint
I. PRELIMINARY STATEMENT
1. This civil rights action is brought under the Constitution of the United States and 42 U.S.C. §§ 1983, to challenge Defendants’ application of La. Rev. Stat. § 37:1285, a provision of the Louisiana Medical Practice Act, to Plaintiff K.P., M.D., for performing first-trimester surgical abortions at Plaintiff Hope Medical Group for Women and for redress of the violation of her rights by Defendant Mouton’s filing of an administrative complaint against K.P. in retaliation for the commencement of this lawsuit.