Kline is an idiot and provides a convenient target with which to tar all pro-life people. His disregard for the Constitution he allegedly serves is appalling (not just here, where he files charges that he had to know would be immediately tossed, but in many other cases). I am glad he has been bounced.
How did Kline disregard the Constitution?
What are the many other cases where he disregarded the Constitution?
To the other posters, it will come as no surprise to you that the judge who threw this out is a Democrat. Tiller funds almost all the liberal causes in this state. If he went down, their funding would go too.
You will likely be attacked by the fanatics as "Pro-death".
Would you please show me what part of the Constitution gives one the right to murder/abort a child in the last part of a pregnancy? What about the very young child that is brought in for an abortion? What is the legal age of consent in KS? 10 years, 12 years old, 13 years old. Could it be that these children were raped and what happened to the rapist? Nothing, that's what. At least, the AG was attempting to right this wrong.
No, you are an idiot. A late term abortion performed on a 10 year old is evidence of rape that even you should recognize.
"His disregard for the Constitution he allegedly serves is appalling (not just here, where he files charges that he had to know would be immediately tossed, but in many other cases). I am glad he has been bounced."
Disregard for the Constitution? He had subpeonas for those 90 records. That means a judge signed off on them being turned over based on the evidence Kline showed the judge.
What part of the Constitution do you think was disregarded?
===============
The appalling disregard for the constitution is the denial of life, liberty and the pursuit of happines of 50,000,000 murdered persons.
These cases were "immediately tossed" by a traffic judge (in the pocket of Tiller) after being signed off on by two senior judges. Read charges for yourself (experienced as you are on Constitutional and one also presumes KS Constitutional issues:
These are just the 30 cases from 2003 on Tiller (who gained his expertise aborting women and girls at the side of his father, who performed illegal, back alley abortions in motels, etc.
COMES NOW the State of Kansas by Phill Kline, Kansas Attorney General, and for Complaint / Information against the above-named Defendant, alleges and states:
COUNT ONE
Unlawful Late Term Abortion
K.S.A. 65-6703
Class A Non Person Misdemeanor
That on or about July 22, 2003, in Sedgwick County, State of Kansas, the defendant, GEORGE R. TILLER, did, then and there, contrary to the statutes of the State of Kansas, unlawfully perform or induce or caused to be performed or induced an abortion on a 14 year old pregnant child when the fetus was viable and had a gestational age of 22 weeks or more, to wit: 26 weeks, by failing to determine that (1) the abortion is necessary to preserve the life of the pregnant woman; or (2) a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, to wit: In file #30,.patient ID #072203LN, the defendant wrongfully relied on a diagnosis of Anxiety Disorder NOS or Adjustment Disorder with mixed anxiety and depressed mood, to determine that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman when such diagnoses do not establish that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, in violation of K.S.A. 65-6703.
COUNT TWO
Failure to Report Justifications for K.S.A. 65-6703 Late Term Abortion
Class A Non Person Misdemeanor
That on or about and after July 22, 2003, in Sedgwick County, State of Kansas, GEORGE R- TILLER did, then and there, contrary to the statutes of the State of Kansas, unlawfully, after performing or inducing or causing to be performed or induced an abortion, to wit: file #30, patient ID #072203LN, state record #005956, on a viable fetus having a gestational age of 22 or more weeks, to wit: 29 weeks of age, did report that the fetus was not viable and therefore did not report the actual determination of fetus viability, nor the reasons for such determinations, nor the basis for the determination that the abortion was necessary to preserve the life of the pregnant woman or that a continuation of the pregnancy would cause a substantial and irreversible impairment of a major bodily function of the pregnant woman in writing to the medical care facility hi which the abortion was performed for inclusion hi the report of the medical care facility to the secretary of health and environment under K.S.A. 65-445 and amendments thereto, in violation of K.S.A. 65-6703.
COUNT THREE
Unlawful Late Term Abortion K.S.A. 65-6703
Class A Non Person Misdemeanor
That on or about July 8, 2003, in Sedgwick County, State of Kansas, the defendant, GEORGE .R. TILLER, did, then, and. there, contrary to the statutes of the State of Kansas, unlawfully perform or induce or caused to be performed or induced an abortion oil a 10 year old pregnant child when the fetus was viable and had a gestational age of 22 weeks or more, to wit: 28 weeks, by failing to determine that (1) the abortion is necessary to preserve the life of the pregnant woman; or (2) a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, to wit: In file #31, patient ID #070803GG, the defendant wrongfully relied on a diagnosis of Major Depressive Disorder, Single Episode, to determine that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman when such diagnosis does not establish that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, in violation of K.S.A. 65-6703.
COUNT FOUR
Failure to Report Justifications for K.S.A. 65-6703 Late Term Abortion
Class A Non Person Misdemeanor
That on or about and after July 8, 2003, in Sedgwick County, State of Kansas, GEORGE R. TILLER did, then and there, contrary to the statutes of the State of Kansas, unlawfully, after performing or inducing or causing to be performed or induced an abortion, to wit: file #31/ patient ID #070803GG, state record #005970, on a viable fetus having a gestational age of 22 or more weeks, to wit: 28 weeks of age, did report that the fetus was not viable and therefore did not report the actual determination of fetus viability, nor the reasons for such determinations, nor the basis for the determination that the abortion was necessary to preserve the life of the pregnant woman or that a continuation of the pregnancy would cause a substantial and irreversible impairment of a major bodily function of the pregnant woman in writing to the medical care facility in which the abortion was performed for inclusion in the report of the medical care facility to the secretary of health and environment under K.S.A. 65-445 and amendments thereto, in violation of K.S.A. 65-6703.
COUNT FIVE Unlawful Late Term Abortion K.S.A. 65-6703 Class A Non Person Misdemeanor That on or about July 15, 2003, in Sedgwick County, State of Kansas, the defendant, GEORGE R. TILLER, did, then and .there, contrary to the statutes of the State of Kansas, unlawfully perform or induce or caused to be performed or induced an -abortion on a 15 year old pregnant child when the fetus was viable and had a gestational age of 22 weeks or more, to wit: 28 weeks, by failing to determine that (1) the abortion is necessary to preserve the life of the pregnant woman; or (2) a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, to wit: In file #32, patient ID #071503LJ, the defendant wrongfully relied on a diagnosis of Major Depressive Disorder, Single Episode, to determine that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman when such diagnosis does not establish that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, in violation of K.S.A. 65-6703.
COUNT SIX
Failure to Report Justifications for K.S.A. 65-6703 Late Term Abortion
Class A Non Person Misdemeanor
That on or about and after July 15, 2003, in Sedgwick County, State of Kansas, GEORGE R. TILLER did, then and there, contrary to the statutes of the State of Kansas, unlawfully, after performing or inducing or causing to be performed or induced an abortion, to wit: file #32, patient ID #071503JL, state record #005976, on a viable fetus having a gestational age of 22 or more weeks, to wit: 28 weeks of age, did fail to report the basis for the determination that the abortion was necessary to preserve the life of the pregnant woman or that a continuation of the pregnancy would cause a substantial and irreversible impairment of a major bodily function of the pregnant woman in writing to the medical care facility in which the abortion was performed for inclusion in the report of the medical care facility to the secretary of health and environment under K.S.A. 65-445 and amendments thereto, in violation of K.S.A. 65-6703.
COUNT SEVEN
Unlawful Late Term Abortion K.S.A. 65-6703
Class A Non Person Misdemeanor
That on or about November 18, 2003, in Sedgwick County, State of Kansas, the defendant, GEORGE R. TILLER, did, then and there, contrary to the statutes of the State of Kansas, unlawfully perform or induce or caused to be performed or induced an abortion on a 16-year old pregnant-child when the fetus was viable and had a gestational age of 22 weeks or more, to wit: 29 weeks, by failing to determine that (1) the abortion is necessary to preserve the life of the pregnant woman; or (2) a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, to wit: In file #59, patient ID #111803LR, the defendant wrongfully relied on a diagnosis of Major Depressive Disorder, Single Episode, to determine that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman when such diagnosis does not establish that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, in violation of K.S.A. 65-6703.
COUNT EIGHT
Failure to Report Justifications for K.S.A. 65-6703 Late Term Abortion
Class A Non Person Misdemeanor
That on or about and after November 18, 2003, in Sedgwick County, State of Kansas, GEORGE R. TILLER, did, then and there, contrary to the statutes of the State of Kansas, unlawfully, after performing or inducing or causing to be performed or induced an abortion, to wit: file #59, patient ID #111803LR, state record #010373, on a viable fetus having a gestational age of 22 or more weeks, to wit: 29 weeks of age, did fail to report the basis for the determination that the abortion was necessary to preserve the life of the pregnant woman or that a continuation of the pregnancy would cause a substantial and irreversible impairment of a major bodily function of the pregnant woman in writing to the medical care facility in which the abortion was performed for inclusion in the report of the medical care facility to the secretary of health and environment under K.S.A. 65-445 and amendments thereto, in violation of K.S.A. 65-6703.
COUNT NINE
Unlawful Late Term Abortion K.S.A. 65-6703
Class A Non Person Misdemeanor
That on or about July 30, 2003, in Sedgwick County, State of Kansas, the defendant, GEORGE R. TILLER, did, then and there, contrary to the statutes of the State of Kansas, unlawfully perform or induce or caused to be performed or induced an abortion on a 19 year old pregnant woman when the fetus was viable and had a gestational age of 22 weeks or more, to wit: 27 weeks, by failing to determine that (1) the abortion is necessary to preserve the life of the pregnant woman; or (2) a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, to wit: In file #33, patient ID #073003CS, the defendant wrongfully relied on a diagnosis of Major Depressive Disorder, Single Episode, to determine that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman when such diagnosis does not establish that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, in violation of K.S.A. 65-6703.
COUNT TEN
Failure to Report Justifications for K.S.A. 65-6703 Late Term Abortion
Class A Non Person Misdemeanor
That on or about and after July 30, 2003, in Sedgwick County, State of Kansas, GEORGE R. TILLER did, then and there, contrary to the statutes of the State of Kansas, unlawfully, after performing or inducing or causing to be performed or induced an abortion, to wit: file #33, patient ID #073003CS, state record #005988, on a viable fetus having a gestational age of 22 or more weeks, to wit: 27 weeks of age, did report that the fetus was not viable and therefore did not report the actual determination of fetus viability, nor the reasons for such determinations, nor the basis for the determination that the abortion was necessary to preserve the life of the pregnant woman or that a continuation of the pregnancy would cause a substantial and irreversible impairment of a major bodily function of the pregnant woman in writing to the medical care facility in which the abortion was performed for inclusion in the report of the medical care facility to the secretary of health and environment under K.S.A. 65-445 and amendments thereto, in violation of K.S.A. 65-6703.
COUNT ELEVEN
Unlawful Late Term Abortion K.S.A. 65-6703
Class A Non Person Misdemeanor
That on or about August 19, 2003, in Sedgwick County, State of Kansas, the defendant, GEORGE R. TILLER, did, then and there, contrary to the statutes of the State of Kansas, unlawfully perform or induce or caused to be performed or induced an abortion on a 22 year old pregnant woman when the fetus was viable and had a gestational age of 22 weeks or more, to wit: 31 weeks, by failing to determine that (1) the abortion is necessary to preserve the life of the pregnant woman; or (2) a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, to wit: In file #37, patient ID #081903EW, the defendant wrongfully relied on a diagnosis of Major Depressive Disorder, Single Episode, to determine that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman when such diagnosis does not establish that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, in violation of K.S.A. 65-6703.
COUNT TWELVE
Failure to Report Justifications for K.S.A. 65-6703 Late Term Abortion
Class A Non Person Misdemeanor
That on or about and after August 19, 2003, in Sedgwick County, State of Kansas, GEORGE R. TILLER did, then and there, contrary to the statutes of the State of Kansas, unlawfully, after performing or inducing or causing to be performed or induced an abortion, to wit: file #37, patient ID #081903EW, state record #006402, on a viable fetus having a gestational age of 22 or more weeks, to wit: 31 weeks of age, did fail to report the basis for the determination that the abortion was necessary to preserve the life of the pregnant woman or that a continuation of the pregnancy would cause a substantial and irreversible impairment of a major bodily function of the pregnant woman in writing to the medical care facility in which the abortion was performed for inclusion in the report of the medical care facility to the secretary of health and environment under K.S.A. 65-445 and amendments thereto, in violation of K.S.A. 65- 6703.
COUNT THIRTEEN
Unlawful Late Term Abortion K.S.A. 65-6703
Class A Non Person Misdemeanor
That on, or about August 5, 2003, in Sedgwick County, State of Kansas, the defendant, GEORGE R. TILLER, did, then and there, contrary to the statutes of the State of Kansas, unlawfully perform or induce or caused to be performed or induced an abortion on a 15 year old pregnant child when the fetus was viable and had a gestational age of 22 weeks or more, to wit: 26 weeks, by failing to determine that (1) the abortion is necessary to preserve the life of the pregnant woman; or (2) a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, to wit: In file #38, patient ID #080503KC, the defendant wrongfully relied on a diagnosis of Major Depressive Disorder, Single Episode, to determine that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman when such diagnosis does not establish that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, in violation of K.S.A .65-6703.
COUNT FOURTEEN
Failure to Report Justifications for K.S.A. 65-6703 Late Term Abortion
Class A Non Person Misdemeanor
That on or about and after August 5, 2003, in Sedgwick County, State-of-Kansas, GEORGE R. TILLER did then and there, contrary to the statutes of the State of Kansas, unlawfully, after performing or inducing or causing to be performed or induced an abortion, to wit: file #38, patient ID #080503KC, state record #006408, on a viable fetus having a gestational age of 22 or more weeks, to wit: 26 weeks of age, did fail to report the basis for the determination that the abortion was necessary to preserve the life of the pregnant woman or that a continuation of the pregnancy would cause a substantial and irreversible impairment of a major bodily function of the pregnant woman in writing to the medical care facility in which the abortion was performed for inclusion in the report of the medical care facility to the secretary of health and environment under K.S.A. 65-445 and amendments thereto, in violation of K.S.A. 65-6703.
COUNT FIFTEEN
Unlawful Late Term Abortion K.S.A. 65-6703
Class A Non Person Misdemeanor
That on or about August 5, 2003, in Sedgwick County, State of Kansas, the defendant, GEORGE R, TILLER, did, then and there, contrary to the statutes of the State of Kansas, unlawfully perform or induce or caused to be performed or induced an abortion on a 15 year old pregnant child when the fetus was viable and had a gestational age of 22 weeks or more, to wit: 28 weeks, by failing to determine that (1) the abortion is necessary to preserve the life of the pregnant woman; or (2) a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, to wit: In file #39, patient ID #080503JY, the defendant wrongfully relied on a diagnosis of Acute Stress Disorder, to determine that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman when such diagnosis does not establish that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, in violation of K.S.A. 65-6703.
COUNT SIXTEEN
Failure to Report Justifications for K.S.A. 65-6703 Late Term Abortion
Class A Non Person Misdemeanor
That on or about and alter August 5, 2003, in Sedgwick County, State of Kansas, GEORGE R. TILLER did, then and there, contrary to the statutes of the State of Kansas, unlawfully, after performing or inducing or causing to be performed or induced an abortion, to wit: file #39, patient ID #080503JY, state record #006585, on a viable fetus having a gestational age of 22 or more weeks, to wit: 28 weeks of age, did fail to report the basis for the determination that the abortion was necessary to preserve the life of the pregnant woman or that a continuation of the pregnancy would cause a substantial and irreversible impairment of a major bodily function of the pregnant woman in writing to the medical care facility in which the abortion was performed for inclusion in the report of the medical care facility to the secretary of health and environment under K.S.A. 65-445 and amendments thereto, in violation of K.S.A. 65-6703.
COUNT SEVENTEEN
Unlawful Late Term Abortion K.S.A. 65-6703
Class A Non Person Misdemeanor
That on or about August 12, 2003, in Sedgwick County, State of Kansas, the defendant, GEORGE R. TILLER, did, then and there, contrary to the statutes of the State of Kansas, unlawfully perform or induce or caused to be performed or induced an abortion on a 15 year old pregnant child when the fetus was viable and had a gestational age of 22 weeks or more, to wit: 25 weeks, by failing to determine that (1) the abortion is necessary to preserve the life of the pregnant woman; or (2) a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, to wit: In file #40, patient ID #081203SP, the defendant wrongfully relied on a diagnosis of Major Depressive Disorder, Single Episode, to determine that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman when such diagnosis does not establish that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, in violation of K.S.A. 65-6703.
COUNT EIGHTEEN
Failure to Report Justifications for K.S.A. 65-6703 Late Term Abortion
Class A Non Person Misdemeanor
That on or about and after August 12, 2003, in Sedgwick County, State of Kansas, GEORGE R. TILLER did, then and there, contrary to the statutes of the State of Kansas, unlawfully, after performing or inducing or causing to be performed or induced an abortion, to wit: file #40, patient ID #081203SP, state record #006591, on a viable fetus having a gestational age of 22 or more weeks, to wit: 25 weeks of age, did fail to report the basis for the determination that the abortion was necessary to preserve the life of the pregnant woman or that a continuation of the pregnancy would cause a substantial and irreversible impairment of a major bodily function of the pregnant woman in writing to the medical care facility in which the abortion was performed for inclusion in the report of the medical care facility to the secretary of health and environment under K.S.A. 65-445 and amendments thereto, in violation of K.S.A. 65-6703.
COUNT NINETEEN
Unlawful Late Term Abortion K.S.A, 65-6703
Class A Non Person Misdemeanor
That on or about August 19, 2003, in Sedgwick County, State of Kansas, the defendant, GEORGE R. TILLER, did, then and there, contrary to the statutes of the State of Kansas, unlawfully perform or induce or caused to be performed or induced an abortion on a 15 year old pregnant child when the fetus was viable and had a gestational age of 22 weeks or more, to wit: 26 weeks, by failing to determine that (1) the abortion is necessary to preserve the life of the pregnant woman; or (2) a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, to wit: In file #41, patient ID #081903AG, the defendant wrongfully relied on a diagnosis of Acute Stress Disorder, to determine that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman when such diagnosis does not establish that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, in violation of K.S.A. 65-6703.
COUNT TWENTY
Failure to Report Justifications for K.S.A. 65-6703 Late Term Abortion
Class A Non Person Misdemeanor
That on or about and after August 19, 2003, in Sedgwick County, State of Kansas, GEORGE R. TILLER did, then and there, contrary to the statutes of the State of Kansas, unlawfully, after performing or inducing or causing to be performed or induced an abortion, to wit: file #41, patient ID #081903AG, state record #006598, on a viable fetus having a gestational age of 22 or more weeks, to wit: 26 weeks of age, did fail to report the basis for the determination that the abortion was necessary to preserve the life of the pregnant woman or that a continuation of the pregnancy would cause a substantial and irreversible impairment of a major bodily function of the pregnant woman in writing to the medical care facility in which the abortion was performed for inclusion in the report of the medical care facility to the secretary of health and environment under K.S.A. 65-445 and amendments thereto, in violation of K.S.A. 65-6703.
COUNT TWENTY ONE
Unlawful Late Term Abortion K.S A. 65-6703
Class A Non Person Misdemeanor
That on or about November 4,2003, in Sedgwick County, State of Kansas, the defendant, GEORGE R. TILLER, did, then and there, contrary to the statutes of the State of Kansas, unlawfully perform or induce or caused to be performed or induced an abortion on a 15 year old pregnant child when the fetus was viable and had a gestational age of 22 weeks or more, to wit: 25 weeks, by failing to determine that (1) the abortion is necessary to preserve the life of the pregnant woman; or (2) a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, to wit: In file #55, patient ID #1I0403BB, the defendant wrongfully relied on a diagnosis of Major Depressive Disorder, Single Episode, to determine that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman when such diagnosis does not establish that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, in violation of K.S.A. 65-6703.
COUNT TWENTY TWO
Failure to Report Justifications for K.S.A. 65-6703 Late Term Abortion
Class A Non Person Misdemeanor
That on or about and after November 4, 2003, in Sedgwick County, State of Kansas, GEORGE R. TILLER did, then and there, contrary to the statutes of the State of Kansas, unlawfully, after performing or inducing or causing to be performed or induced an abortion, to wit: file #55, patient ID #110403BB, state record #010134, on a viable fetus having a gestational age of 22 or more weeks, to wit: 25 weeks of age, did fail to report the basis for the determination that the abortion was necessary to preserve the life of the pregnant woman or that a continuation of the pregnancy would cause a substantial and irreversible impairment of a major bodily function of the pregnant woman in writing to the medical care facility in which the abortion was performed for inclusion in the report of the medical care facility to the secretary of health and environment under K.S.A. 65-445 and amendments thereto, in violation of K.S.A. 65-6703.
COUNT TWENTY THREE
Unlawful Late Term Abortion K.S.A. 65-6703
Class A Non Person Misdemeanor
That on or about August 26, 2003, in Sedgwick County, State of Kansas, the defendant, GEORGE R. TILLER, did, then and there, contrary to the statutes of the State of Kansas, unlawfully perform or induce or caused to be performed or induced an abortion on a 14 year old pregnant child when the fetus was viable and had a gestational age of 22 weeks or more, to wit: 25 weeks, by failing to determine that (1) the abortion is necessary to preserve the life of the pregnant woman; or (2) a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, to wit: In file #43, patient H) #082603TK, the defendant wrongfully relied on a diagnosis of Acute Stress Disorder, to determine that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman when such diagnosis does not establish that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, in violation of K.S.A. 65-6703.
COUNT TWENTY FOUR
Failure to Report Justifications for K.S.A. 65-6703 Late Term Abortion
Class A Non Person Misdemeanor
That on or about and after August 26, 2003, in Sedgwick County, State of Kansas, GEORGE R. TILLER did, then and there, contrary to the statutes of the State of Kansas, unlawfully, after performing or inducing or causing to be performed or induced an abortion to wit: file #43, patient ID #082603TK, state-record #006604; on a viable fetus having-a: gestational age of 22 or more weeks, to wit: 25 weeks of age, did fail to report the basis for the determination that the abortion was necessary to preserve the life of the pregnant woman or that a continuation of the pregnancy would cause a substantial and irreversible impairment of a major bodily function of the pregnant woman in writing to the medical care facility in which the abortion was performed for inclusion in the report of the medical care facility to the secretary of health and environment under K.S.A. 65-445 and amendments thereto, in violation of K.S.A, 65-6703.
COUNT TWENTY FIVE
Unlawful Late Term Abortion K.S.A. 65-6703
Class A Non Person Misdemeanor
That on or about September 9,2003, in Sedgwick County, State of Kansas, the defendant, GEORGE R, TILLER, did, then and there, contrary to the statutes of the State of Kansas, unlawfully perform or induce or caused to be performed or induced an abortion on a 15 year old pregnant child when the fetus was viable and had a gestational age of 22 weeks or more, to wit: 25 weeks, by failing to determine that (1) the abortion is necessary to preserve the life of the pregnant woman; or (2) a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, to wit:. In file #44, patient ID #090903JC, the defendant wrongfully relied on a diagnosis of Major Depressive Disorder, Single Episode, to determine that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman when such diagnosis does not establish that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, in violation of K.S.A. 65-6703.
COUNT TWENTY SIX
Failure to Report Justifications for K.S.A. 65-6703 Late Term Abortion
Class A Non Person Misdemeanor
That on or about and after September 9, 2003, in Sedgwick County., State of Kansas, GEORGE R. TILLER did, then and There, contrary to the statutes of the State of Kansas, unlawfully, after performing or inducing or causing to be performed or induced an abortion, to wit: file #44, patient ID #090903JC3 state record #008238, on a viable fetus having a gestational age of 22 or more weeks, to .wit: 25 weeks of age, did fail to report the basis for the determination that the abortion was necessary to preserve the life of the pregnant woman or that a continuation of fee pregnancy would cause a substantial and irreversible impairment of a major bodily function of the pregnant woman in writing to the medical care facility in which the abortion was performed for inclusion in the report of the medical care facility to the secretary of health and environment under K.S.A. 65-445 and amendments thereto, in violation of K.S.A. 65-.6703.
COUNT TWENTY SEVEN
Unlawful Late Term Abortion K.S.A. 65-6703
Class A Non Person Misdemeanor
That on or about November 4,2003, in Sedgwick County, State of Kansas, the defendant, GEORGE R, TELLER, did, then and there, contrary to the statutes of the State of Kansas, unlawfully perform or induce or caused to be performed or induced an abortion on a 18 year old pregnant woman when the fetus was viable and had a gestational age of 22 weeks or more, to wit: 25 weeks, by failing to determine that (1) the abortion is necessary to preserve the life of the pregnant woman; or (2) a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, to wit: In file #58, patient ID #110403KH, the defendant wrongfully relied on a diagnosis of Anxiety Disorder NOS or Acute Stress Disorder, to determine that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman when such diagnoses do not establish that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, in violation of KSA 65-6703.
COUNT TWENTY EIGHT
Failure to Report Justifications for K.S.A. 65-6703 Late Term Abortion
Class A Non Person Misdemeanor
That on or about and after November 4, 2003, in Sedgwick County, State of Kansas, GEORGE R. TILLER did, then and there, contrary to the statutes of the State of Kansas, unlawfully, after performing or inducing or causing to be performed or induced an abortion, to wit: file #58, patient ID S110403KH, state record #010150, on a viable fetus having a gestational age of 22 or more weeks, to wit: 25 weeks of age, did fail to report the basis for the determination that the abortion was necessary to preserve the life of the pregnant woman or that a continuation of the pregnancy would cause a substantial and irreversible impairment of a major bodily function of the pregnant woman in writing to the medical care facility in which the abortion was performed for inclusion in the report of the medical care facility to the secretary of health and environment under K.S.A. 65-445 and amendments thereto, in violation of K.S.A. 65-6703.
COUNT TWENTY NINE
Unlawful Late Term Abortion K.S.A. 65-6703
Class A Non Person Misdemeanor
That on or about November 4, 2003, in Sedgwick County, State of Kansas, the defendant, GEORGE R. TILLER, did, then and there, contrary to the statutes of the State of Kansas, unlawfully perform or induce or caused to be performed or induced an abortion on a 13 year old pregnant woman when the fetus was viable, and had a gestational age of 22 weeks or more, to wit: 25 weeks; by failing to-determine that (1) the abortion is necessary to preserve the life of the pregnant woman; or (2) a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, to wit: In file #53, patient ID #110403TDS, the defendant wrongfully relied on no established diagnosis, to determine that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman when such diagnoses do not establish that a continuation of the pregnancy will cause a substantial and irreversible impairment of a major bodily function of the pregnant woman, in violation of KSA 65-6703.
COUNT THIRTY
Failure to Report Justifications for K.S.A, 65-6703 Late Term Abortion
Class A Non Person Misdemeanor
That on or about and after November 4, 2003, in Sedgwick County, State of Kansas, GEORGE R. TILLER did, then and there, contrary to the statutes of the State of Kansas, unlawfully, after performing or inducing or causing to be performed or induced an abortion, to wit: file #53, patient ID #110403TDS, state record #010117, on a viable fetus having a gestational age of 22 or more weeks, to wit: 25 weeks of age, did report that the fetus was not viable and therefore did not report the actual determination of fetus viability, nor the reasons for such determinations, nor the basis for the determination that the abortion was necessary to preserve the life of the pregnant woman or that a continuation of the pregnancy would cause a substantial and irreversible impairment of a major bodily function of the pregnant woman in writing to the medical care facility in which the abortion was performed for inclusion in the report of the medical care facility to the secretary of health and environment under K.S.A. 65-445 and amendments thereto, in violation of K.S.A. 65-6703.
(Phill Kline’s signature)
PHILL KLINE
KANSAS ATTORNEY GENERAL
(Stephen D. Maxwell’s signature)
STEPHEN D. MAXWELL
SENIOR ASSISTANT ATTORNEY GENERAL
STATE OF KANSAS, COUNTY OF SEDGWICK, ss:
I, Phill Kline, do solemnly swear, to the best of my knowledge and belief, that the matters set forth in the Complaint / Information are true, so help me God.
(Phill Kline’s signature)
PHILL KLINE
KANSAS ATTORNEY GENERAL
SUBSCRIBED AND SWORN to before me this 21 of December, 2006.
(Eric Yost’s signature)
Judge of the District Court Div.12
Witnesses
Thomas Williams
Jared Reed
Dr. Ann Kristin Neuhaus (abortionist who took 5th until granted immunity from prosecution - then give testimony against Tiller.)
Steve Cavanaugh
Clerk of the District Court—3rd Judicial District
Dr. Paul McHugh
Dr. Lome Phillips
Lorna Jansen
Gina Bowes
Sealed documents attached in support of Cgmplaintftpformation:
1) Affidavit of Dr. Paul R. McHugh, M.D. Johns Hopkins Medical Center
2) Affidavit of Special Agent In Charge Thomas D, Williams
3) Transcript of sworn statement by Dr. Arm Kristin Neuhaus, M.D. Note: Abortionist who testified against Tiller.
4) Transcript of sworn statement by Dr. Lorne Phillips, KDHE
5) Copies of 15 KDHE report forms
6) Copies of 15 medical files, patient identification redacted