Klines Charges Against Tiller Disallowd b/c Juristiction

Below are former KS A.G. Phill Kline's December 2006 charges against late-term abortionist George Tiller which were disallowed after a local judge agreed with Sedgwick County (Wichita) D.A. Nola Foulston's claim that only she had juristiction. An appeal was filed with the Kansas Supreme Court by the special prosecutor Kline hired (Kline was about to go out of office.)  Newly sworn in A.G. Paul Morrison vowed to leave the appeal alone, but changed his mind a month later, and dropped the appeal,  and thus the bad ruling's appeal was never ajudicated!  

Kline's charges were based on a finding of "probable cause" that crimes had been committed issued by Judge Richard Anderson of Topeka, and were backed up by expert witness Dr. Paul McHugh (25 year head of psychiatry at Johns Hopkins) who saw (redacted) records and said none showed evidence of meeting criteria of Kansas law as legal exceptions under the ban on aborting viable unborn babies (those able to live outside the womb at the time of the abortion.)

Paul Morrison then dropped the Kline charges himself in June of 2007 (using an unheard of and unsubstantiated "interpretation" of the law, and filed 19 charges of his own related to a different part of the same law.


IN THE
DISTRICT COURT

SEDGWICK COUNTY, KANSAS

                                                                                                                                             2006 DEC 21 4:38

STATE OF KANSAS,

Plaintiff,

    v.                                                                                                                                CASE NO. 06 CR 2961

GEORGE R. TILLER,

Defendant

COMPLAINT / INFORMATION

 

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)

PHILLKLINE

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

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.

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

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