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Felipe N. Gomez v. Dr. Alan Braid, Case No:: Pro Choice Plaintiff

1. Felipe Gomez, a U.S. citizen from Illinois, filed a complaint against Dr. Alan Braid, a San Antonio doctor, under the new Texas Heartbeat Act. 2. The complaint alleges that on or around September 6, 2021, Dr. Braid performed an abortion where the patient was more than 6 weeks pregnant, which the Act declares is illegal. 3. Gomez is seeking a declaratory judgment from the court that the Texas Heartbeat Act is unconstitutional and violates Roe v. Wade, which established a federal right to abortion until fetal viability at around 24 weeks.

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37K views2 pages

Felipe N. Gomez v. Dr. Alan Braid, Case No:: Pro Choice Plaintiff

1. Felipe Gomez, a U.S. citizen from Illinois, filed a complaint against Dr. Alan Braid, a San Antonio doctor, under the new Texas Heartbeat Act. 2. The complaint alleges that on or around September 6, 2021, Dr. Braid performed an abortion where the patient was more than 6 weeks pregnant, which the Act declares is illegal. 3. Gomez is seeking a declaratory judgment from the court that the Texas Heartbeat Act is unconstitutional and violates Roe v. Wade, which established a federal right to abortion until fetal viability at around 24 weeks.

Uploaded by

Fares Sabawi
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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FILED

9/20/2021 9:07 AM
Mary Angie Garcia
Bexar County District Clerk
Accepted By: Martha Medellin

2021CI19920

Felipe N. Gomez Case No:


Pro Choice Plaintiff
Bexar County - 224th District Court

v. Texas Heartbeat Act (S.B. 8)

Dr. Alan Braid, Sec. 171.208 Action


Declaratory Judgment
Pro Choice Defendant

COMPLAINT

NOW COMES FELIPE GOMEZ a U.S.A. Citizen, and “person”, as defined in


Texas Heartbeat Act, Sec. 171.208, and per Sec.171.208 COMPLAINS as follows:

1. On information and belief Texas resident Defendant Braid, 5838 Joiner, San
Antonio, TX 78238, performed an abortion in Texas on or about 9.6.21
where his patient was more than 6 weeks pregnant, which Sec.
171.208(a)(1) declares is illegal.

2. Plaintiff, a USA citizen (Illinois resident) and “person” as defined in the


Texas Hearbeat Act files this suit against Defendant, MOVES the Court to
declare that the Act is Unconstitutional, and in violation of Roe v Wade.

3. The Act provides in relevant part:


“Sec. 171.208. CIVIL LIABILITY FOR VIOLATION OR AIDING OR
ABETTING VIOLATION. (a) Any person, other than an officer or employee of a
state or local governmental entity in this state, may bring a civil action against any
person who: (1) performs or induces an abortion in violation of this subchapter;
4. Plaintiff alleges that Defendant did not violate Roe v Wade, and that the Act is illegal as
written and as applied here until Roe v Wade is reversed or modified.

WHERFORE, PLAINTIFF seeks the Court Declare the Act to be illegal as written and/or as
applied to the instant facts.

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