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Complaint Narrative 01/13/2020 1am providing documented proof in the form of a recorded phone call, to the Texas Nursing Board, that Gloria Martinez, RN is in violation of the Texas Health and Safety Code by administering Mifeprex, also know as the abortion pill, to patients at Hill Top Women’s Reproductive Clinic, located at 500 E. Schuster in El Paso, TX. | placed this call to schedule an appointment for the abortion inducing drug, Mifeprex, at Hill ‘Top Women’s Reproductive Clinic on January 10, 2020. | was surprised to find that | was able to make an appointment with Gloria Martinez, RN to receive the abortion inducing drug and was reassured multiple times that she would be administering the drug. The Texas Health and Safety Code Section 171.003 states that “An abortion may be performed only by a physician licensed to practice medicine in this state.” ‘Section 171.063(1) states that, “the person who gives, sells, dispenses, administers, provides, or prescribes the abortion-inducing drug is a physician.” Gloria Martinez, RN is not a licensed physician and should, therefore, not be administering the abortion pill to women in the state of Texas. Gloria Martinez, RN is placing Texas women's lives at risk by violating the state's Health and Safety Code that was put in place to protect ensure patient safety. In addition, on September 10, 2019 myself and a colleague filed an FDA complaint against Hill ‘Top’s New Mexico location, where Gloria Martinez is the clinic manager, for performing medical abortions in violation of FDA protocols. The FDA requires that the facilities dispensing the dangerous abortion drug Mifeprex, be able to diagnose ectopic pregnancies due to the fact ‘that as of December 31, 2078, there have been 24-reported deaths connected with Mifeprex use. Our undercover investigation revealed that Hilltop Women's Clinic is not equipped to diagnose ectopic pregnancies according to their own admission. There appears to be a pattern of failing to comply with rules and regulations set forth for the administration of Mifeprex at the facilities where Gloria Martinez is employed. The total disregard by Gloria Martinez in complying with both state and federal laws is quite concerning as it poses serious life threatening consequences to the unsuspecting women who obtain services from her place of employment. ‘As of December 31, 2018, there have been 24-reported deaths connected with Mifeprex use. am requesting a full investigation of Gloria Martinez’s administration of Mifeprex and that the Board take any and all appropriate disciplinary action, including the revocation of her Texas nursing license in order to protect women who are not aware that only physician's are allowed to administer the abortion pill in the state of Texas. Additional attachments include: Audio od of recorded phone cal. “Transcript ofthe recorded phone cal -FDA Complaint against Hill Top Women's Reproductive Clinic. Tara Shaver CO: Office of the Attorney General of Texas Page 1 of 1 INDIVIDUAL'S COMPLAINT FORM ‘TO THE TEXAS BOARD OF NURSING REGARDING VIOLATIONS of the NURSING PRACTICE ACT, OTHER STATUTES, and BOARD RULES PLEASE PRINT LEGIBLY (1) INFORMATION ABOUT THE NURSE BEING REPORTED ruuname: Cilorva Martivyz _ ucense numecr: 97917 lo SOCIAL SECURITY: _ UN LAD, DATEOF BIRTH: Unknown nurse's PHONER (IS - SUZ—- 28I! nursesewpover: [till Top Women’s Reproductive. Clinic employers appress: 500 & Schuster , ¢/ Paso 1940L- ewpioverspHonee: 4IS- SY2-28 (2) INCIDENT/CONDUCT BEING REPORTED (IF MORE SPACE IS NEEDED ATTACH ADDITIONAL SHEETS) DATE(S) OF INCIDENT(S): TIME: FACILITY/UNIT: PATIENT'S NAME & DATE OF BIRTH OR OTHER IDENTIFIER: INCIDENT/CONDUCT: Please see_adtached Complain + Narrative,