Amicus Curiae Brief — Cano v. Baker (No. 06-162)

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MOTION FILED ¢)

SEP 1 - 2006 No. 06-162

——

In The

Supreme Court of the Anited States

SANDRA CANO, FORMERLY KNOWN

AS “MARY DOE” OF DOE V. BOLTON,

Petitioner,

THURBERT E. BAKER, Attorney General of the State

of Georgia, PAUL L. HOWARD, JR.., District Attorney

of Fulton County, Georgia, RICHARD PENNINGTON,

Chief of Police of the City of Atlanta,

Respondents.

On Petition For A Writ Of Certiorari

To The United States Court Of Appeals

For The Eleventh Circuit

MOTION FOR LEAVE TO FILE BRIEF AMICI

CURIAE AND BRIEF AMICI CURIAE OF THE

NURTURING NETWORK, HEARTBEAT

INTERNATIONAL, CARE NET, NATIONAL

INSTITUTE OF FAMILY AND LIFE ADVOCATES,

ABORTION RECOVERY INTERNATIONAL

NETWORK, AND CHRISTIAN LEGAL SOCIETY

IN SUPPORT OF PETITIONER

Counsel for Amici Curiae

SAMUEL B. CASEY GEORGE R. GRANGE II

CHRISTIAN LEGAL SOCIETY Counsel of Record

8001 Braddock Road, SCOTT J. WARD

Suite 300 ROBERT W. MALONE

Springfield, Virginia 22151 GAMMON & GRANGE, P.C.

(703) 642-1070 8280 Greensboro Dr.,7th FI.

McLean, Virginia 22102

(703) 761-5000

COCKLE LAW BRIEF PRINTING CO (800) 225-6964

OR CALL COLLECT (402) 342-2831

MOTION FOR LEAVE TO FILE BRIEF

AMICI CURIAE

Amici curiae The Nurturing Network (TNN), Heart-

beat International, Inc. (Heartbeat), Care Net, The Na-

tional Institute of Family and Life Advocates (NIFLA),

The Abortion Recovery International Network (ARIN), and

the Christian Legal Society (CLS) have sought the consent

of the parties to participate in this matter by the filing of

the enclosed brief. A consent letter from counsel for Peti-

tioner to file this brief is on file with the Clerk in accor-

dance with Rule 37.3, but counsel for Respondents has

withheld consent, necessitating this motion.

This motion and the enclosed brief are filed in support

of the Petitioner Sandra Cano to inform the Court of the

interests of amici in this case and to show how significant

medical, scientific, and psychological developments in the

33 years since this Court’s decisions in Doe v. Bolton, 410

U.S. 179 (1973), and its companion case Roe v. Wade, 410

U.S. 113 (1973), render continued application of the

decision in Doe unjust.

As set forth more fully in the “Statements of Interest of

Amici Curiae” section of the attached brief, amici TNN,

Heartbeat, Care Net, NIFLA, and ARIN are §501(c)(3)

nonprofit organizations involved in caring for women who

encounter an unexpected pregnancy or its aftermath.’

* Amici CLS is a nonprofit interdenominational association of

Christian attorneys, law students, law professors, and judges. CLS and

many of its members not only advocate on behalf of the inalienable

right to life, but also work to create a society that will embrace and care

for both mother and child. To this end, CLS and many members have

worked to help develop legal and social mechanisms to address the

needs of women who might otherwise pursue abortions and to assist

(Continued on following page)

Amici collectively have more than one hundred years

experience caring for women who have undergone abor-

tions. As national organizations whose affiliated members,

professional staff, and volunteers have collectively worked

directly with the hundreds of thousands of women who

encounter crisis pregnancies, many of whom have experi-

enced or will soon face harmful post-abortion symptoms or

conditions harmful- to their physical and psychological

health, amici have direct and vital interests in protecting

women from the various harms abortion yields that were

not known or considered by the Court when it rendered its

opinions in Doe and Roe. Amici have witnessed and now

care for tens of thousands of women who are now report-

ing how abortion has harmed them. Amici have every

reason to believe that many more women will be coming

forward to report the harm abortion has done and is doing

to them.

Amici submit this brief to address two critical factual

assumptions made by the Court in Doe and Roe that have

changed since those decisions were rendered. First, con-

trary to the expressed assumption that abortion helps

women, amici have first-hand experience that abortion

poses significant and grave risks to the health of women

far exceeding the health risks and other concerns posed by

carrying their children to term. Second, in the 33 years

since Doe and Roe were decided, an infrastructure of care

has developed in the United States offering a variety of

practical and compassionate alternatives to abortion for

women that-simply did not exist in 1973. These alterna-

tives mean that an unwanted pregnancy no longer must

organizations, such as the other amici, that care for women who are

considering or have undergone abortions.

result in an unwanted and burdensome child, a dashed

career, or an abortion. Amici have been intimately and

extensively involved in the development of these alterna-

tives and continue to provide this care and support to

hundreds of thousands of pre- and post-abortive women

each year.

The experience of amici in providing thi« extensive

ongoing care to so many pre- and post-abortive women

offers an important analytical complement to and a unique

perspective on the factual, legal, and constitutional issues

presented by the pending petition. Amici therefore respect-

fully urge that the Court grant this Motion For Leave To

File Brief Amici Curiae.

Respectfully submitted,

Counsel for Amici Curiae Z

SAMUEL B. CASEY GEORGE R. GRANGE II

CHRISTIAN LEGAL SOCIETY Counsel of Record

8001 Braddock Road, Scott J. WARD

. Suite 300 ROBERT W. MALONE

Springfield, Virginia 22151 GAMMON & GRANGE, PC.

(703) 642-1070 8280 Greensboro Dr.,7th FI.

McLean, Virginia 22102

(703) 761-5000

QUESTIONS PRESENTED

Should the original judgment in Doe v. Bolton, 410

U.S. 179 (1973), be vacated under Federal Rule of

Civil Procedure 60 due to the substantially changed

factual and/or legal conditions that make it no longer

just or equitable for prospective application?

Is Petitioner Sandra Cano entitled under Federal

Rule of Civil Procedure 60 to any relief, substantive

or procedural?

Should the Court, at a minimum, require the district

court to hold a hearing to afford fundamental due

process that would lead to determining whether Doe

v. Bolton should be reexamined?

Does the district court have a role in preparing the

factual basis in a Federal Rule of Civil Procedure

60(b) motion based on Agostini v. Felton, 521 U.S. 203

(1997)?

TABLE OF CONTENTS

Page

QUESTIONS PRESENTED ...........0:ceccosressssosecsereeeses i

TATE OF CITI oa scsncscscsseveesesdenseevierossvcvsesss ii

_ SABLE OF AUPHORITIRG ....-.n.cccescscssescevsevsesivoverses v

STATEMENTS OF INTEREST OF AMICI CURIE ....... i

SUMMARY OF THE ARGUMENT............cccccccseseeeees 2.

RISO MIIOE ccisisesnsereiscctenisveeses Pidiiiiem cae acu 4

I. The Petition Should Be Granted To Permit

The Federal Courts To Consider Significant

Changes In The Material Facts Regarding

The Harm Abortion Causes Women And Al-

ternatives To Abortion That Were Not Known

At The Time Of This Court’s Decision In Doe

ERI a AMEE ET IN Hide Cy LEI 4

A. This Court Has The Legal Authority To

Grant Petitioner’s Motion Under Its

Construction Of Rule 60(b) In Agostini

And Of Stare Decisis In Casey.............6066 4

B. Amici Can Provide Substantial Evidence

Of Changed Facts And Factual Under-

standings To Support Granting Peti-

tioner’s Rule 60(b) Motion......................4. 7

II. The Serious, Pervasive, Long-Term Psycho-

logical Consequences That Amici Have Wit-

nessed And Currently Care For In The Lives

Of Hundreds Of Thousands Of Post-Abortive

Women Are Substantial Factual Changes

That Support Granting The Petition.............. 9

IT].

iil

TABLE OF CONTENTS — Continued

Page

A. “If Only I Had Known”: The Nurturing

Network’s 20-Year Experience Counsel-

ing And Caring For Thousands Of Post-

I Pi va cccstenrecdssctczcitcerorsscievene

B. The Consistent Experience Of Heartbeat

International’s Affiliates Is That Abor-

tion Harms Women So Deeply And So

Often That Most Affiliates Now Offer

Post-Abortion Counseling Programs To

Address The Depression, Anger And Re-

gret Post-Abortive Women Suffer.............

C. Care Net’s Affiliated Pregnancy Resource

Centers Annually Serve More Than

100,000 Women Suffering From The Ad-

verse Impacts Of Abortion Upon Their

ITS csicitaeiapuinssicecienaeicibneadencemeesioanaeinds

The Availability Of Operating Networks Of

Agencies Offering Better Alternatives To

Abortion — More Protective Of The Physical,

Psychological, Social, Spiritual And Legal In-

terests Of Women And Their Children —- Is A

Substantial Factual Change That Supports

CECT TO FI sc ca svevnniiscecnecesessccsssodeanes

A. Heartbeat International Affiliates Offer

A Wide Range Of Free Women’s Health

Services Not Available When Doe Was

NI cee es ro

B. Care Net Mobilizes An Extensive Network

Of Staff And Volunteers To Help Women

Find Alternatives To Abortion Or To Recover

From The Harms Of Abortion .....................

TABLE OF CONTENTS ~- Continued

Page

C. The Nurturing Network Provides -Post-

a onereorececees 20

CO a iii ccc veccesccrcnncesccesese 20

PS ig 0) SRR App. 1

TABLE OF AUTHORITIES

Page

CASES:

Agostini v. Felton, 521 U.S. 203 (1997)... 2, 3, 6, 7

Doe v. Bolton, 410 U.S. 179 (19738).............cccceseseeeeees passim

McCorvey v. Hill, 385 F.3d 846 (5th Cir. 2004), cert.

denied, 543 UB. 1154 (2OG6)........cccrcccvesecercevsceseveseerss 5 Me

Planned Parenthood v. Casey, 505 U.S. 833 (1992) ......2, 3, 4, 11

Planned Parenthood v. Casey, 510 U.S. 1309 (1994)

I CIE I iii ie 6

Roe v. Wade, 410 U.S. 113 (1973)........... cee eeeeeeeeeeeee passim

Rufo v. Inmates of Suffolk County Jail, 502 US.

SEE ATID ih iiiccitisdrianeieidccitacnidiaasisisigapisaisbcincakdamiauaasdadecaieia 6

Stenberg v. Carhart, 530 U.S. 914 (2000)......... eee 6

RULES AND REGULATIONS

Federal Rule of Civil Procedure 60(b)...................... passim

OTHER SOURCES:

Mary Cunningham Agee, “The Health Risks of

Abortion,” panel presentation for Family Re-

search Council (April 2002), at www.nurturing

i sinsiicsivtnntecervicsinindinteminibiciticabunenditabnanaiensia 13

Mary Cunningham Agee, “The Nurturing Network:

Serving the Urgent and Practical Needs of Moth-

ers in Crisis: Personal Reflections of the Founder

Based Upon Twenty Years of Compassion in Ac-

TABLE OF AUTHORITIES —- Continued

Page

“A List of Major Psychological Sequelae of Abor-

tion,” Fact Sheet Courtesy of the Elliot Institute,

Springfield, illinois, 1997 (available at www.

| RIT Ra IO MI ETE EEE 10

Justice Harry Blackmun, Remarks Before the

Franco-American Colloquium on Human Rights

(1979) (transcript available in the Harvard Law

School Library), quoted in- Note, The Changing

Social Vision of Justice Blackmun, 96 HARV. L.

ees: Be SD iaicscasss bcd iteasdnwadiasb odcacdbaamaerea iakoabLaameeabeuat 5

Henry J. Friendly, The Courts and Social Policy:

Substance and Procedure, 33 U. MIAMI L. REV. 21

a 5

Gissler, Mika, Berg, Cynthia, Bouvier-Colle, Marie-

Héléne & Buekens, Pierre (2004), Methods For

Identifying Pregnancy-Associated Deaths: Popu-

lation-Based Data From Finland 1987-2000,

Paediatric & Perinatal Epidemiology 18 (6), 448-

CEES ok RSENS SS aR 79? Aer DSLAM SONY OSE es 17

Peggy Hartshorn, Ph.D., “Pregnancy Help Centers:

Prevention, Crisis Intervention, Healing: Putting

It All Together,” in Back to the Drawing Board:

The Future of the Pro-Life Movement, Teresa R.

Wagner, ed. (South Bend, Ind.: St. Augustine’s

I IEEE diirisicdiatiniicelidslacusistnunsavenniiddainnnandaces 14, 18, 19

Heartbeat International, “Worldwide Directory of

Life Affirming Pregnancy Services,” at www.

heartbeatinternational.org...............::::::eeeseeeeees 15, 17, 18

Note, The Changing Social Vision of Justice

Blackmun, 96 HARV. L. REV. 717 (1983) ....0.....ccceeee cece eee 5

Report of the South Dakota Task Force To Study

NE I, BID cdicclacniccrtincsnivcabdnccnnentemedvenoueventts 8, 9, 10

TABLE OF AUTHORITIES — Continued

Page

“The Ministry of Care Net” (2004 brochure)......... 15, 19, 20

Pregnancy Decision Health Centers (PDHC) “An-

nual Report, 2003,” and “Board Report: 3rd

Quarter 2004” (published in the PDHC “Annual

I ITEP cictdocssvncvunihansddixsccnrnsesvasecassnnusdtaceitvosencdinial 15

STATEMENTS OF INTEREST OF AMICI CURIAE’

The Statements of Interest of amici curiae are set out

in Appendix A hereto. Amici curiae Heartbeat Interna-

tional, Inc, Care Net, The Nurturing Network (TNN),

Abortion Recovery Inter-national Network (ARIN), and

National Institute of Family and Life Advocates (NIFLA)

are all 501(c)(3) not for profit organizations involved in

caring for women who encounter an u ‘expected pregnancy

or its aftermath. Amici Christian Legal Society (CLS) is a

nonprofit interdenominational association of Christian

attorneys, law students, law professors, and judges. CLS

and many of its members not only advocate on behalf of

the inalienable right to life, but also work to create a

society that will embrace and care for both mother and

child.

As national organizations whose affiliated members,

professional staff and volunteers have collectively worked

directly with hundreds of thousands of women who en-

counter crisis pregnancies, many of whom have experi-

enced or will soon face harmful post-abortion symptoms or

conditions harmful to their physical and psychological

health, amici have direct and vital interests in protecting

women from the various harms abortion yields that were

not known or considered by the Court when it rendered its

opinion in Doe v. Bolton. Because amici have witnessed

and now care for the thousands of women who are now

reporting how abortion has harmed them, and because

amici have every reason to believe that many more women

will be coming forward to report the harm abortion has

done and is doing to them, amici urge this Court to grant

certiorari, vacate the rulings below and remand with

* This amici curiae brief is submitted in support of the Petitioner.

By letters filed with the Clerk of the Court, Petitioner has consented to

the filing of this brief. Respondent has withheld consent. Pursuant to

Supreme Court Rule 37.6, amici disclose that: (1) no counsel for a party

authored this brief in whole or in part; and (2) no person or entity, other

than the amici curiae, their supporters, or their counsel has made a

monetary contribution to the preparation of this brief.

instruction to hold an evidentiary hearing so that Peti-

tioner may demonstrate that the facts and factual under-

standings underlying the Doe decision have so materially

changed as to make its further prospective application

neither just nor equitable.

SUMMARY OF THE ARGUMENT

This Court has indicated that when the facts support-

ing a constitutional decision — even a “watershed” decision,

such as Doe v. Bolton, 410 U.S. 179 (1973) — “have so

changed, or come to be seen so differently, as to have

robbed the old rule of significant application or justifica-

tion,” that decision should be reexamined, and modified or

even overruled, by this Court.’ Yet such reexamination

cannot occur unless those changed material facts may be

introduced into evidence before a court with authority to

consider them.

Submission of evidence of significantly changed facts

and factual understandings is precisely the purpose of

Petitioner’s underlying Rule 60(b) motion. The majority

opinion in Doe was based upon significant factual assump-

tions that were believed true at the time but have since

been proved incorrect or false. Petitioner’s motion prof-

fered voluminous evidence of such material factual

changes and asked that the District Court conduct an

evidentiary hearing. The District Court denied that

motion.

This Court’s decisions in Agostini v. Felton and in

_ Planned Parenthood v. Casey provide the critical constitu-

tional principles that permit this Court to grant Peti-

tioner’s petition. Both articulate the principle that

significant changes in the facts or law underlying an

earlier constitutional decision of this Court warrant

> See Planned Parenthood v. Casey, 505 U.S. 833, 854-55 (1992)

(O'Connor, Kennedy, and Souter, JJ., plurality opinion) (hereinafter

“Joint Opinion”).

revisiting and even reversing that decision.’ Casey pro-

vides the corollary that such action may be required not

only by changes in the facts per se, but also by changes in

the way that such facts have come to be seen or under-

stood.’ Finally, Agostini establishes that Rule 60(b)(5) is

the appropriate mechanism for a party to the earlier

decision to seek such reexamination and reversal.”

Amici submit this brief to address two substantial

“factual” presumptions made by the Court that have

changed since the decision in Doe. First, contrary to the

expressed presumption in Doe and Roe’ that abortion

helps women, the amici have first hand experience that

abortion poses significant and grave risks to the health of

women far exceeding the health risks and other concerns

posed by carrying their children to term. Second, in the 33

years since Doe was decided, an infrastructure of care has

developed for women offering a variety of practical and

compassionate alternatives to abortion that simply did not

exist in 1973. These alternatives mean that an unwanted

pregnancy no longer has to result in an unsafe pregnancy,

an unwanted and burdensome child, a dashed career, or an

abortion.

Amici therefore respectfully urge this Court to grant

the petition, vacate the rulings below, and remand this

case to the District Court with instructions to conduct an

evidentiary hearing and determine in the first instance

whether there are significant changes in the facts and

factual understandings underlying the Doe decision that

make its prospective application unjust or inequitable.

* See Agostini v. Felton, 521 U.S. 203, 215 (1997); Casey, 505 U.S.

at 854-55, 863 (Joint Opinion).

* See Casey, 505 U.S. at 854 (Joint Opinion) (overruling earlier

constitutional decision warranted where “facts have so changed, or

come to be seen so differently, as to have robbed the old rule of signifi-

cant application or justification”) (italics added).

* See Agostini, 521 U.S. at 238-40.

" Roe v. Wade, 410 U.S. 113 (1973).

ARGUMENT

I. THE PETITION SHOULD BE GRANTED TO PERMIT

THE FEDERAL COURTS TO CONSIDER SIGNIFICANT

CHANGES IN THE MATERIAL FACTS REGARDING

THE HARM ABORTION CAUSES WOMEN AND AL-

TERNATIVES TO ABORTION THAT WERE NOT

KNOWN AT THE TIME OF THIS CouURT’S DECISION

IN DOE v. BOLTON.

A. This Court Has The Legal Authority To

Grant Petitioner’s Motion Under Its Con-

struction Of Rule 60(b) In Agostini And Of

Stare Decisis In Casey.

Whenever the facts supporting a _ constitutional

decision of this Court “have so changed, or come to be seen so

‘differently, as to have robbed the old rule of significant

application or justification,” that decision should be re-

examined by this Court.® Even a “watershed” constitutional

decision, such as Doe v. Bolton, should be overruled or

modified when justified based upon “facts, or an understand-

ing of facts, changed from those which furnished the claimed

justifications for the earlier constitutional resolutions.”

Yet such re-examination cannot occur unless the

material facts that “have so changed, or come to be seen so

differently,” may be introduced into evidence before a court

with authority to consider them. Submission of such

evidence and consideration of such changed facts and

factual understandings is precisely the purpose of Peti-

tioner’s underlying Rule 60(b) motion. That motion asked

that the District Court conduct an evidentiary hearing

regarding material factual changes that might require

vacating the 1973 judgment in Petitioner’s favor in the

original Doe litigation.

* See Planned Parenthood v. Casey, 505 U.S. 833, 854-55 (1992)

(O’Connor, Kennedy, and Souter, JJ., plurality opinion) (hereinafter

“Joint Opinion”).

* See Casey, 505 U.S. at 863 (Joint Opinion).

Petitioner’s motion arises from her recognition that

the relevant scientific, medical, legal, and philosophical

facts as they exist and are understood today do not sup-

port the position she took and the relief that she obtained

and, more significantly, do not support the majority

opinion in Doe.” The majority opinion in Doe was based

upon a significant number of factual assumptions that

were believed true at the time but have since been proved

incorrect or false." Most of the medical and scientific

information considered by the Court and relied upon in

Justice Blackmun’s majority opinions in Doe and in Roe

was introduced for the first time in the Supreme Court,”

or uncovered by the research of individual Justices.” In

this respect, Petitioner’s Rule 60(b) motion seeks to permit

the development of the full factual record that should have

been developed in the original litigation of this matter.“

Indeed, Petitioner has submitted uncontroverted evidence that

the factual record upon which relief was granted in Doe was in her case

simply false and that she “neither wanted nor sought an abortion.”

Compare Doe, 410 U.S. at 185-86, with Affidavit of Sandra Cano,

Petitioner’s Appendix at 34-43.

" See Doe v. Bolton, 410 U.S. 179, 208 (1973) (Burger, C.J.,

concurring) (“I am somewhat troubled that the Court has taken

[judicial] notice of various scientific and medical data in reaching its

conclusion”).

" See, e.g., Henry J. Friendly, The Courts and Social Policy:

Substance and Procedure, 33 U. MIAMI L. REv. 21, 37 (1978) (noting

thet the medical and scientific information introduced in Roe and Doe

was presented for the first time at the Supreme Court level).

‘* Justice Blackmvn later explained that he personally conducted

much of the research ‘or the Roe majority opinion at the Mayo Clinic

library. See Justice Aarry Blackmun, Remarks Before the Franco-

American Colloquium on Human Rights 14-15 (1979) (transcript

available in the Harvard Law School Library) (stating *..at opinion in Roe

was based upon “research, personally and very .rivately performed,

[which] was, I believe, rewarding”), quoted in Note, _ .e Changing Social

Vision of Justice Blackmun, 96 HARV. L. REV. 7! ° 723 n.34 (1983).

* Amici expect that, if this Court grants tne petition and permits

the Rule 60(b) motion to proceed in District Court, substantial] evidence will

be submitted not only by Petitioner, but also by a number of intervenors

and amici on both sides of the issue. This will result in the development

(Continued on following page)

The extensive evidence that Petitioner proffered to the

District Court demonstrates that these material facts and

factual understandings have significantly changed since

this Court issued its decisions in Doe and Roe in 1973, and

indeed even since the subsequent decisions in Casey and ©

in Stenberg v. Carhart.” Yet the District Court refused to

hold an evidentiary hearing, nor even to consider any of

this evidence, ruling that Rule 60(b)(5) did not permit any

relief after the passage of so many years.” The District

Court’s treatment of Rule 60(b) is inconsistent with this

Court’s statements regarding that Rule. As this Court has

stated, such an effort by a party to seek relief from pro-

spective application of the earlier judgment is a “proper

application of Rule 60(b)(5),”" particularly where, as here,

there has been “a significant change either in factual

conditions or in law.””

. In Casey, although presented with none of the compel-

ling medical, scientific, psychological, and other evidence

that Petitioner now seeks to provide, the Court, while

reaffirming Roe’s and Doe’s “central holding,” nevertheless

adjusted the requirements of Roe and overruled parts of several

and testing of an extensive factual record that will greatly aid the District

Court, the Court of Appeals, and ultimately this Court in carrying out their

respective responsibilities as explained in Casey and Agostint.

° Stenberg v. Carhart, 530 U.S. 914 (2000).

2004), Pet. App. at 21-31. Cf. Planned Parenthood v. Casey, 510 US.

1309, 1313-14 (1994) (Souter, Circuit Justice) (noting, in denying

plaintiffs’ application for stay of Court of Appeals’ mandate pending

petition for certiorari, that plaintiffs “had been given a fair opportunity

to develop the record in the District Court” where “the original District

Court opinion ... contains 287 detailed findings of fact and carries

every indication that the applicants were given broad latitude to

introduce evidence, call witnesses, and elicit testimony”).

" See Agostini v. Felton, 521 U.S. 203; 238-40 (1997).

* Sev id. at 215, citing Rufo v. Inmates of Suffolk County Jail, 502

U.S. 367, 384 (1992) (appropriate to grant a Rule 60(b)(5) motion when

the party seeking relief can show “a significant change either in factual

conditions or in law”).

earlier rulings that had extended Roe’s application. Petitioner's

Rule 60(b)(5) motion now seeks to submit for consideration by

the courts (and ultimately by this Court”) precisely what was

not considered in Casey: “serious and substantial evidence .. .

that goes to the heart of the balance Roe [and Doe] struck

between the choice of a mother and the life of her unborn

child.” Granting certiorari will allow this Court the opportu-

nity to thoroughly and thoughtfully consider the substantial

changes in the medical, scientific, psychological, and other facts

and factual understandings regarding abortion in America.

Petitioner contends, and amici agree, that these changed

facts and factual understandings demonstrate that prospec-

tive application of Doe is no longer just or equitable. But this

Court need not resolve that question to grant certiorari.

Indeed, this Court may not yet have a sufficient factual record

upon which to resolve such a question — as it would if Peti-

tioner were allowed to proceed with her Rule 60(b) motion in

the District Court. Consequently, amici respectfully urge this

Court to grant the petition, vacate the rulings below, and

remand this case to the District Court with instructions to

conduct an evidentiary hearing and determine in the first

instance whether there are significant changes in the facts

and factual understandings underlying the Doe decision that

make its prospective application unjust or inequitable.

B. Amici Can Provide Substantial Evidence

Of Changed Facts And Factual Under-

standings To Support Granting Peti-

tioner’s Rule 60(b) Motion.

Amici’s extensive experience in providing support,

counseling, and care to women contemplating abortion and

* Consistent with Agostini, the ultimate determination whether to

overrule or modify Doe obviously must rest with this Court. See

Agostini, 521 U.S. at 237-38.

*® See McCorvey v. Hill, 385 F.3d 846, 850 (Sth Cir. 2004) (Jones, J.,

concurring).

to women dealing with the significant psychological,

physiological, emotional, spiritual, and medical conse-

quences of having had abortions enables these amici to-

provide substantial evidence of changes in critical facts

and factual understandings to support Petitioner’s Rule

60(b) motion. The most significant factual changes relate

to the issue, central in Doe and Roe, of the health of the

mother, in two primary ways. =

First, Doe and Roe were premised upon the factual

assumption (now demonstrably wrong) that the termina-

tion of an unwanted pregnancy through an abortion

provided a safe end to a short-term crisis that would allow

a woman to return to a normal and a productive life. The

years that have passed since Doe have made clear that for

a substantial number of women the crisis does not end

after their abortions.” These women cannot just “get over”

the experience of their abortions. Instead, a great many of

these women are psychologically devastated as they

realize that they have aborted their unborn children. For

these women, abortion is not a relatively safe and easy

solution to a crisis pregnancy but the beginning of a much

greater crisis.

Second, Doe and Roe were premised upon the factual

assumption and understanding that abortion is the only

option available to enable most women to avoid the emo-

tional and financial burdens of pregnancy and even more

of motherhood. That assumption is also now demonstrably

wrong. There are now a myriad of practical and compas-

sionate alternatives to abortion that simply did not exist

in 1973. An extensive infrastructure of care is now avail-

able to women in crisis pregnancies throughout the United

States. This care network allows women to avoid the grave

emotional and financial hardships that some women once

*" See, e.g., Report of the South Dakota Task Force To Study

Abortion (Dec. 2005), included in Petitioner’s Appendix to the Petition

for Certiorari (“Pet. App.”) at 289-411 and referred to hereinafter as

“Task Force Report,” at 362-66.

faced in giving birth, while at the same time allowing

them to avoid the emotional harms of an abortion.

II. THE SERIOUS, PERVASIVE, LONG-TERM PSYCHO-

LOGICAL CONSEQUENCES THAT AMICI HAVE WIT-

NESSED AND CURRENTLY CARE FOR IN THE LIVES

OF HUNDREDS OF THOUSANDS OF POST-ABORTIVE

WOMEN ARE SUBSTANTIAL FACTUAL CHANGES

THAT SUPPORT GRANTING THE PETITION.

Doe and Roe were founded largely ‘pon several

essential factual assumptions: (1) that un unwanted

pregnancy presents a short-term crisis; (2) that an abor-

tion will provide a “health” benefit to the woman facing

such a crisis by allowing her to return to a normal life; and

(3) that abortion is a relatively rare and safe procedure

without lasting harmful effects on the woman.” With the

dramatic increase of abortions since the Doe and Roe

decisions, the unexpected and tragic consequences of

abortion are emerging and establish the need to reexamine

these assumptions.”

* See Roe, 401 U.S. at 149. The Doe and Roe Court further

assumed that a woman’s decision to obtain an abortion would be a

medical decision made by or in conjunction with the woman’s physician

and that such relationship of professional medical care would alleviate

any health or safety issues. See Roe, 410 U.S. at 149-50; Doe, 410 U.S.

at 190-91. As the evidence offered by Petitioner below and lodged with

this Court shows, nothing could be further from the truth today. To the

contrary, as tens of thousands of women have told amici, most women

don’t even meet a doctor until their abortion is underway. Similarly,

most such women report that the informed medical consent required in

every state in other forms of professional medical care was either

absent or grossly inadequate as they approached the decision to abort.

See, e.g., Task Force Report, Pet. App. at 313, 352.

* According to the Alan Guttmacher Institute’s estimates for the

years 1973-2000 and the National Right to Life Committee’s (NLRC)

estimates for the years 2001-2004, more than 45,000,000 abortions

have been reported in the United States since Doe was decided in 1973.

See NRLC web site at http:/Awww.nrlc.org/abortion/facts/abortionstats.

html. Based upon their collective experience caring for post-abortive

women, amici estimate at least 75% of those women have suffered from

(Continued on following page)

In 1973, neither this Court nor the women who have

since undergone abortions could have known of the psy-

chological and physiological harms that legalized abortion

would cause such women.” The presumption communi-

cated by Doe, Roe, and their progeny is that “abortion is

legal and therefore it must be safe as weil.” However, the

experience of amici, in working with hundreds of thou-

sands of women yearly since the Doe decision, parallels the

extensive factual findings presented in the Report of the

South Dakota Task Force To Study Abortion, Pet. App. at

289-411, and in the affidavits of experts David C. Reardon,

Ph.D. and Theresa Burke, Ph.D. (see Pet. App. at 236-37)

regarding the complications and ill-effects of abortion. The

harmful psychological effects include post-abortion trau-

matic stress disorder; suicide, suicidal attempts, and

suicidal ideation requiring psychiatric care and/or the use

of psychotropic drugs; sleep disturbance (including recur-

ring nightmares); sexual dysfunction; increased smoking,

alcohol and drug abuse; eating disorders; abuse and/or

neglect of their living children; chronic relationship

problems (including divorce); and repeat abortions.” These

changed factual circumstances, further documented below

by amici, warrant this Court’s attention under Rule 60(b),

or are currently suffering psychological or physical harm from their

abortions. The magnitude of this harm to women’s health, as well as the

“downsizing” of America’s population by abortion (ranging from a

population loss by age group of between 10.2% and 27.4%, excepting

only the age group 45 years or older in 2000), now presents serious

implications for women’s health, social security, and immigration policy.

These implications cannot be adequately addressed by our democratic

institutions until this Court considers the material factua) and legal

circumstances that were not known when Doe and Roe were decided.

* This brief addresses only the psychological effects of abortion as

experienced by the women counseled by the amici and their affiliates.

* See “A List of Major Psychological Sequelae of Abortion,” Fact

Sheet Courtesy of the Elliot Institute, Springfiéld, Illinois, 1997 (from

www.afterabortion.org), at Appendix (“App.”) 3-14.

particularly since this Court is the only public institution

with the constitutional authority to do so.”

A. “If Only I Had Known”: The Nurturing

Network’s 20-Year Experience Counseling

And Caring For Thousands Of Post-Abortive

Women.

The Nurturing Network (TNN) is extensively involved

in working with women suffering from post-abortion

trauma. Approximately 50% of such women have already

experienced at least one abortion at the time they contact

TNN for help.” Many such women served by TNN express

fear about having to go through another abortion, great

remorse, and strong conviction not to add to the emotional

anguish already endured. They often share a sense of

having been betrayed and then abandoned by those who

convinced or pressured them to pursue abortion.

TNN has found that the forces and influences that

tend to drive women to abortion are an immediate attempt

to escape from shame, hope for greater economic security,

and the hope of saving a fragile relationship. However, the

actual testimonies of the betrayed and abandoned women in

TNN’s files expose the miscalculations and illuminate the

disillusionment that follow their abortions. Most women

identify four primary sources of pressure or coercion that led

* As Judge Edith Jones succinctly pointed out in her concurring

opinion in McCorvey v. Hill, 385 F.3d 846, 852 (5th Cir. 2004): “[T]he

problem inherent in the Court’s decision to constitutionalize abortion

policy is that unless the Court creates another exception to the moot-

ness doctrine, the Court will never be able to examine its factual

assumptions on a record made in court. . .. Hard and social science will

of course progress even though the Supreme Court averts its eyes... .

One may fervently hope that the Court will someday acknowledge such

developments and re-evaluate Roe and Casey accordingly.”

* See “The Nurturing Network: Serving the Urgent and Practical

Needs of Mothers in Crisis: Personal Reflections of the Founder Based

Upon Twenty Years of Compassion in Action” written by TNN President

and founder Mary Cunningham Agee, at App. 15-29.

them to abortion: the father of the baby, forcing a choice

between the relationship with him or the baby; parents,

forcing a choice between continued support or the baby;

employers, forcing a choice between continued employ-

ment or the baby; and peers, forcing a choice between

continued social standing or the baby. Each ultimatum

threatens to impose an emotional toll calculated to force

the pregnant woman to make a desperate choice.”

And yet, as the testimonies in the Appendix indicate,

it is primarily the woman alone who suffers the agonizing

remorse, the hidden grief, and the debilitating guilt from

undergoing the abortion. Thus, most women who have

chosen abortion do so not out of “freedom of choice” but out

of a desperate sense that they have no choice at all. Under

these circumstances, most post-abortive women come to

believe that the only “freedom” an abortion affords is

experienced by those “significant others” who have much

to lose if the pregnancy continues. Another tragic but all

too frequent occurrence among post-abortive women is

that after expressing regret in having made the “choice” to

abort, many become pregnant again in an effort to remedy

their error and “recreate” their deceased child, only to then

experience yet another abortion, because these same

influences convince them once again that it is the only

“practical” thing to do.

The President and founder of TNN, Mary Cunning-

ham Agee, describes her extensive experience during the

past twenty years addressing post-abortion trauma in

women:

“If only I had known.” This is the haunting la-

ment that I hear almost daily on the toll free cri-

sis hotline of The Nurturing Network. Since

founding this charitable organization almost

twenty years ago, I have been invited by literally

thousands of frightened, wounded women to un-

derstand the painful circumstances of their trou-

bled lives.... They call desperately seeking

* Id.

immediate, practical assistance in order to avoid

an abortion procedure which almost half of our

clients have already experienced in a prior preg-

nancy.

[Ajlmost all of them would tell you that if they

could erase just one decision in their lives, it

would be the irreversible one that ended the life

of their unborn child. Their grief is difficult to

capture here in a few words because it is always

tinged with a sense of having been betrayed.

These women consistently describe the panic and

loneliness that sets in when those whom she has

trusted create fatal trade-offs between their role

in her life and her child. How can she help but

feel tricked and manipulated by boyfriends, par-

ents, friends and employers who conveniently

wash their hands of her maternal needs and

choose to describe her unborn child as an incon-

venience and even a threat. None of these ac-

complices, of course, will ever live out the

permanent consequences of an abortion decision

the way she will and so her sense of abandon-

ment and isolation is profound.”

B. The Consistent Experience Of Heartbeat

International’s Affiliates Is That Abortion

Harms Women So Deeply And So Often

That Most Affiliates Now Offer Post-

Abortion Counseling Programs To Ad-

dress The Depression, Anger And Regret

Post-Abortive Women Suffer.

Since the founding of Heartbeat International in 1971,

its affiliates have also worked with many thousands of

* See “The Health Risks of Abortion,” a panel presentation for The

Family Research Council offered by Mary Cunningham Agee, President

& Founder of The Nurturing Network, in April 2002, at App. 30-37. For

the testimonies referred to in Ms. Cunningham Agee’s address, quoted

above, see App. 23-29.

women who suffer emotionally from having undergone

abortions. Although the term “post abortion syndrome”

had not yet been coined in the early 1970’s, the Heartbeat

International affiliate pregnancy centers quickly began to

see suffering women who had one or more abortions. In

consulting with professionals to develop programs to help

these women, the centers were advised on the one hand

that abortion did not have any damaging effects on

women. Yet, on the other hand, the centers were cautioned

that volunteers (“nonprofessionals”) should not get in-

volved for fear that post-abortive women might become

suicidal. This advice only confirmed what the centers were

experiencing — that for a significant number of women, the

choice to abort their unborn children left them deeply

psychologically harmed.”

The President of Heartbeat International, Dr. Peggy

Hartshorn, has personally received hundreds of calls,

letters, and personal contacts from women seeking post-

abortion help who expressed depression, anger, and regret

as a result of a past abortion. Heartbeat International’s

experience in working with such women over the years

further substantiates the research findings of Dr. Reardon

and Dr. Burke” with regard to the psychological harm the

women they work with are experiencing. Due to the great

number of post-abortive women seeking such help, Heart-

beat International advises its affiliates to have professional

counselors available as resources and referrals, and over

two-thirds of the pregnancy resource centers affiliated with

Heartbeat International now offer post-abortion programs.

For example, one Columbus, Ohio Heartbeat International

affiliate, Pregnancy Decisions Health Centers (PDHC),

*° Peggy Hartshorn, Ph.D: “Pregnancy Help Centers: Prevention,

Crisis Intervention, Healing: Putting It All Together,” published in Back

to the Drawing Board: The Future of the Pro-Life Movement, Teresa R.

Wagner, ed. (South Bend, Ind.: St. Augustine’s Press, 2003), as ex-

cerpted for the Court’s reference at App. 38-48 (hereinafter “Harts-

horn”).

* See Pet. App. at 236-37.

reports that in the period 2002 to 2004, more than 55% of

the post-abortive women they served reported “unresolved

feelings” and “regret” with regard to past abortions.”

Heartbeat International is not alone in these findings — it

calculates that at least 785 of the 2,026 pregnancy re-

source centers it has identified in the United States now

offer post-abortion programs to help women who are

suffering from symptoms of post-abortion trauma.”

C. Care Net’s Affiliated Pregnancy Resource

Centers Annually Serve More Than 100,000

Women Suffering From The Adverse Impacts

Of Abortion Upon Their Health.

Care Net is a network of over 800 pregnancy resource

centers that provide support, care and resources to pregnant

women. In 2004, 101,000 women and 2,710 men participated in

Care Net pregnancy center post-abortion counseling and

education support groups in this nation. One of Care Net’s

affiliates reports that 75% of the women it serves have experi-

enced past abortions and struggle with the grief from the

experience. In response, more than 450 Care Net pregnancy

centers now offer recovery support groups to women and men

who have experienced the trauma of a past abortion.”

* See Pregnancy Decision Health Centers (PDHC) “Annual Report,

2003,” and “Board Report: 3rd Quarter 2004” (published in the PDHC

“Annual Report, 2004”), at App. 49-62.

* Id. See also Heartbeat International’s “Worldwide Directory of

Life Affirming Pregnancy Services,” at www.heartbeatinternational.org.

* “The Ministry of Care Net” (2004 brochure), at App. 63-68.

III. THE AVAILABILITY OF OPERATING NETWORKS OF

AGENCIES OFFERING BETTER ALTERNATIVES TO

ABORTION — MORE PROTECTIVE OF THE PHYSICAL,

PSYCHOLOGICAL, SOCIAL, SPIRITUAL AND LEGAL

INTERESTS OF WOMEN AND THEIR CHILDREN - IS

A SUBSTANTIAL FACTUAL CHANGE THAT SUPPORTS

GRANTING THE PETITION.

This Court’s opinions in Doe and Roe were premised

upon a profound concern for the distress and difficulties

that the Court assumed bringing an unwanted child into

the world would have upon the mother psychologically and

financially. The Roe majority opinion identified the specific

harm it believed would result from denying a prégnant

woman the choice to terminate her pregnancy:

Specific and direct harm medically diagnosable

even in early pregnancy may be involved. Mater-

nity, or additional offspring, may force upon the

woman a distressful life and future. Psychologi-

cal harm may be imminent. Mental and physical

health may be taxed by child care. There is also

the distress, for all concerned, associated with

the unwanted child, and there is the problem of

bringing a child into a family already unable,

psychologically and otherwise, to care for it. In

other cases, as in this one, the additional difficul-

ties and continuing stigma of unwed motherhood

may be involved.”

All of these identified harms except the first arise not from

pregnancy per se but rather from motherhood and child

care.” The Court was concerned that women often had

* 410 U.S. at 153. Cf. Casey, 505 U.S. at 853 (Joint Opinion)

(stating that one view on the abortion issue “is that the inability to

provide for the nurture and care of the infant is a cruelty to the child

and an anguish to the parent.”).

* To the extent that the Court addressed medical risks from

pregnancy, its conclusions in Doe and Roe were predicated, in signifi-

cant part, on the conclusion that induced abortion was safer than

childbirth. Since that time, proponents of abortion have continued to

(Continued on following page)

only a few options: single parenthood with the prospect of

poverty, a dashed career, adoption with the attendant

stigma, or a costly and, in most states, illegal “back alley”

abortion. Moreover, there were few material and social

resources available to pregnant women to help them

through the pregnancy and afterward.

However, over the 33 years since Doe and Roe were

decided, an extensive infrastructure of care offering

practical support to pregnant women facing crisis preg-

nancies has developed. In the public realm, this includes

the recent “Safe Haven” or “Baby Moses” laws adopted in

most states. In the private realm, a network of nearly

3,500 organizations has arisen throughout the United

States offering practical support to women facing crisis

pregnancies.” The development of the infrastructure is

make this argument based largely upon data from the Centers for

Disease Control comparing rates of death for childbirth to the rate of

death associated with abortion based exclusively upon death certificate

information. However, in 2004, researchers from the National Research

and Development Center for Welfare and Health in Finland published a

study disclosing that 94% of maternal] deaths associated with abortion

are not identifiable from death certificates alone. Proper tracking of

pregnancy-associated deaths requires linking death certificates to the

deceased women’s entire medical records. The study shows that the

long held presumption that abortion is associated with fewer deaths

than childbirth does not hold up once the pregnancy history of women is

actually investigated using record linkage. Previously, it has been

claimed that the mortality rate associated with abortion was 1/6th that

of childbirth. But these estimates were based on information gathered

only from death certificates or other public records. Proper identifica-

tion of pregnancy records, the study found, reveals that the death rate

associated with abortion is actually three times higher than that of

childbirth. See Gissler, Mika, Berg, Cynthia, Bouvier-Colle, Marie-

Héléne & Buekens, Pierre (2004), Methods For Identifying Pregnancy-

Associated Deaths: Population-Based Data From Finland 1987-2000,

PAEDIATRIC & PERINATAL EPIDEMIOLOGY 18 (6), 448-455.

” Currently, pregnancy resource centers outnumber the abortion

clinics by 1,283 in the United States. This figure is based on the report

from Life Dynamics (at www.ldi.org) that there are currently 743

abortion clinics in the United States, as compared with the 2,026

pregnancy resource centers in the United States listed in the Heartbeat

International’s Worldwide Directory of Life Affirming Pregnancy

(Continued on following page)

exemplified by Heartbeat International’s “Worldwide

Directory of Life Affirming Pregnancy Services” (“Direc- |

tory”). While the initial Directory listed less than 80

organizations providing alternatives to abortion, the 2004

Directory listed 5,162 organizations. Of those organiza-

tions, 3,471 were in the United States. These included

approximately 2,026 pregnancy resource centers offering

pregnant women medical services, hotline counseling and

other support services, clothing, and/or housing; nonprofit

adoption agencies; social service agencies; and groups that

offer post-abortion support. The Directory also lists 507

professional social service agencies; 319 maternity homes;

166 nonprofit adoption agencies; 27 counseling hotlines;

and 54 independent post-abortion programs.

A. Heartbeat International Affiliates Offer A

Wide Range Of Free Women’s Health Ser-

vices Not Available When Doe Was De-

cided.

Amici Heartbeat International is an association of

pregnancy resource centers, medical clinics, maternity

homes and nonprofit adoption agencies serving over 850

affiliates in the United States and in 33 countries. Heart-

beat International was formed in 1971 as a loose federa-

tion of independent organizations that sought to network

with each other primarily in the “crisis intervention”

arena, offering pregnant women support and referrals to a

variety of services in the community such as medical care,

housing, material aid, and social services.”

Today, most pregnancy resource centers offer to

women facing an undesired pregnancy a wide range of

services completely free of charge. Typical services include

pregnancy tests, crisis intervention for deciding among

alternatives, peer or professional counseling, support

Services, at http://www.heartbeatinternational.org/worldwide_directory.

asp.

* See Hartshorn, at App. 38-48.

groups, adoption support, parenting classes, shelter,

material aid, community referrals, and community educa-

tion programs. Many also offer professional services

needed for adoption, medical care, childbirth classes, legal

assistance, financial assistance, housing, and similar

services. Some Heartbeat International affiliated centers

now offer a wide range of medical and health services

including sexually transmitted disease testing, pap

smears, prenatal care, abuse recovery, post-abortion

programs, and ultrasound technology.”

B. Care Net Mobilizes An Extensive Network

Of Staff And Volunteers To Help Women

Find Alternatives To Abortion Or To Re-

cover From The Harms Of Abortion.

Amici Care Net is one of the largest pro-life organiza-

tions in the infrastructure of pregnancy resources centers.

Care Net represents a network of over 800 pregnancy

resource centers, which include approximately 2,400 paid

staff and 30,000 volunteers. Care Net affiliates provide

services similar to those of Heartbeat International to

more than 250,000 young women each year. These affili-

ates provide alternatives to abortion to more than 100,000

women each year. Care Net’s affiliates serve women in

crisis pregnancy situations in three primary ways: inter-

vention, prevention, and reconciliation.” As part of the

process of healing and reconciliation, more than 450 of

Care Net’s affiliated centers also offer recovery support

groups to women and men who have experienced the

trauma of a past abortion.

m ot

* “The Ministry of Care Net” (2004 brochure), at App. 63-68.

C. The Nurturing Network Provides Post-

birth Care For Mothers And Their Babies.

This infrastructure of care developed to provide

women with alternatives to abortion does not end after the

children are born. The Nurturing Network (TNN) main-

tains over 42,000 volunteer resource members who provide

for all of the urgent and practical needs of women with

unplanned pregnancies focusing heavily on this post-birth

aspect of care for mothers. Like Heartbeat International

and Care Net, TNN seeks to provide for every aspect of a

pregnant woman’s needs, frem initial pregnancy testing to

delivery of her baby and provision of information on

parenting and adoption. TNN’s volunteers include licensed

counselors, nurses, social workers, and others, who seek to

provide information to the women regarding available

resources. They also conduct detailed evaluations of the

women’s needs, and provide comprehensive plans of

assistance that incorporate the appropriate services of

TNN and other organizations.”

CONCLUSION

For all the foregoing reasons, amici respectfully urge

this Court to grant the petition for writ of certiorari.

Respectfully submitted,

Counsel for Amici Curiae

SAMUEL B. CASEY GEORGE R. GRANGE II

CHRISTIAN LEGAL SOCIETY Counsel of Record

8001. Braddock Road, Scott J. WARD

Suite 300 ROBERT W. MALONE

Springfield, Virginia 22151 GAMMON & GRANGE, P.C.

(703) 642-1070 8280 Greensboro Dr.,7th FI.

McLean, Virginia 22102

(703) 761-5000

September 1, 2006

“ See Agee, supra note 25, at App. 15-16.

App. 1

STATEMENT OF INTEREST OF AMICI CURIAE

Heartbeat International, Inc. is a national association

of life-affirming pregnancy resource centers, medical clinics,

maternity homes and nonprofit adoption agencies. Heartbeat

International currently serves over 850 affiliates in the United

States and in 33 countries, providing the education, training

and support they need to serve women facing unexpected

pregnancies. Heartbeat International also provides a World-

wide Directory of Life Affirming Pregnancy Services, a com-

prehensive source that identifies organizations providing

alternatives to abortion. Heartbeat International is committed

to the principle that it is tragic to tell a woman that her only

option is to take the life of her child.

CareNet is a network of over 800 pregnancy resource

centers, all of which provide support, care and resources to

pregnant women. More than 450 CareNet affiliate pregnancy

centers offer recovery support groups to women and men who

have experienced trauma arising from past abortions.

The Nurturing Network (TNN) is an international

charitable organization that works with over 42,000 volunteer

resource members who provide for all of the urgent and

practical needs of women with unplanned pregnancies. TNN

has served over 17,000 pregnant women and unborn children

with its practical compassion.

The Abortion Recovery International Network

(ARIN) is an affiliate organization dedicated to connecting like-

minded abortion re very programs with over 250 affiliates

(“partners”) that pruvide post-abortion counseling, care, and

assistance in various locations around the world. It has devel-

oped the first online directory solely committed to listing abortion

recovery programs within the United States and abroad. ARIN

also assists in the design and development of new post-abortion

programs for stand-alone recovery agencies, as well as the

programs already existing in pregnancy resource centers.

App. 2

The National Institute of Family and Life Advo-

cates (NIFLA) supplies legal services and consultation to

pregnancy help centers nationwide. Founded in 1993, NIFLA

now serves a membership of 850 pregnancy resource centers

in 48 states. Nearly 400 of these centers are either operating

as medical clinics or are preparing to do so in the near future.

NIFLA’s services to its members include: legal review and

audit of pregnancy resource center documents, legal consulta-

tion and education of centers, board training for center

governing boards, publication of educational materials and

training manuals, training in the development of medical

clinic status, training of nurses and doctors in the provision of

ultrasound services, and the publication of bulletins that

highlight legal and medical concerns for pregnancy resource

centers. NIFLA places an emphasis on the conversion of

pregnancy resource centers into licensed medical clinics, to

enable them to provide to the women they serve a variety of

medical services such as: pregnancy diagnosis, pregnancy

confirmation via ultrasound examination, and testing and

treatment for sexually transmitted diseases.

The Christian Legal Society (CLS), founded in 1961,

is a nonprofit interdenominational association of more than

3,000 Christian attorneys, law students, law professors, and

judges. Since 1975, CLS’s Center for Law and Religious

Freedom has litigated and educated on behalf of the inalien-

able right to life. CLS and many of its members not only

advocate on behalf of the inalienable right to life, but also

work to create a society that will embrace and care for both

mother and child. To this end, they have worked to help

develop legal and social mechanisms to address the needs of

women who might otherwise pursue abortions and to assist

organizations, such as the other amici, that care for women

who are considering or have undergone abortions.

App. 3

Fact Sheet Courtesy of the Elliot Institute,

PO Box 73478 Springfield, IL 62791-7348

A List of Major Psychological Sequelae

of Abortion

REQUIREMENT OF PSYCHOLOGICAL TREATMENT:

In a study of post-abortion patients only 8 weeks after

their abortion, researchers found that 44% complained of

nervous disorders, 36% had experienced sleep distur-

bances, 31% had regrets about their decision, and 11% had

been prescribed psychotropic medicine by their family

doctor. (2) A 5 year retrospective study in two Canadian

provinces found significantly greater use of medical and

psychiatric services among aborted women. Most signifi-

cant was the finding that 25% of aborted women made

visits to psychiatrists as compared to 3% of the control

group. (3) Women who have had abortions are significantly

more likely than others to subsequently require admission

to a psychiatric hospital. At especially high risk are

teenagers, separated or divorced women, and women with

a history of more than one abortion. (4)

Since many post-aborted women use repression as a

coping mechanism, there may be a long period of denial

before a woman seeks psychiatric care. These repressed

feelings may cause psychosomatic illnesses and psychiatric

or behavioral in other areas of her life. As a result, some

counselors report that unacknowledged post-abortion

distress is the causative factor in many of their female

patients, even though their patients have come to them

seeking therapy for seemingly unrelated problems. (5)

POST-TRAUMATIC STRESS DISORDER (PTSD or

PAS): A major random study found that a minimum of

App. 4

19% of post-abortion women suffer from diagnosable post-

traumatic stress disorder (PTSD). Approximately half had

many, but not all, symptoms of PTSD, and 20 to 40 percent

showed moderate to high levels of stress and avoidance

behavior relative to their abortion experiences. (6) Because

this is a major disorder which may be present in many

plaintiffs, and is not readily understood outside the coun-

seling profession, the following summary is more complete

than other entries in this section. PTSD is a psychological

dysfunction which results from a traumatic experience

which overwhelms a person’s normal defense mechanisms

resulting in intense fear, feelings of helplessness or being

trapped, or loss of control. The risk that an experience will

be traumatic is increased when the traumatizing event is

perceived as including threats of physical injury, sexual

violation, or the witnessing of or participation in a violent

death. PTSD results when the traumatic event causes the

hyperarousal of “flight or fight” defense mechanisms. This

hyperarousal causes these defense mechanisms to become

disorganized, disconnected from present circumstances,

and take on a life of their own resulting in abnormal

behavior and major personality disorders. As an example

of this disconnection of mental functions, some PTSD

victim may experience intense emotion but without clear

memory of the event; others may remember every detail

but without emotion; still others may reexperience both

the event and the emotions in intrusive and overwhelming

flashback experiences. (7)

Women may experience abortion as a traumatic event for

several reasons. Many are forced into an unwanted abor-

tions by husbands, boyfriends, parents, or others. If the

woman has repeatedly been a victim of domineering

abuse, such an unwanted abortion may be perceived as the

App. 5

ultimate violation in a life characterized by abuse. Other

women, no matter how compelling the reasons they ave

for seeking an abortion, may still perceive the termination

of their pregnancy as the violent killing of their own child.

The fear, anxiety, pain, and guilt associated with the

procedure are mixed into this perception of grotesque and

violent death. Still other women, report that the pain of

abortion, inflicted upon them by a masked stranger

invading their body, feels identical to rape. (8) Indeed,

researchers have found that women with a history of

sexual assault may experience greater distress during and

after an abortion exactly because of these associations

between the two experiences. (9) When the stressor lead-

ing to PTSD is abortion, some clinicians refer to this as

Post-Abortion Syndrome (PAS).

The major symptoms of PTSD are generally classified

under three categories: hyperarousal, intrusion, and

constriction.

Hyperarousal is a characteristic of inappropriately and

chronically aroused “fight or flight” defense mechanisms.

The person is seemingly on permanent alert for threats of

danger. Symptoms of hyperarousal include: exaggerated

startle responses, anxiety attacks, irritability, outbursts of

anger or rage, aggressive behavior, difficulty concentrat-

ing, hypervigilence, difficulty falling asleep or staying

asleep, or physiological reactions upon exposure to situa-

tions that symbolize or resemble an aspect of the trau-

matic experience (eg. elevated pulse or sweat during a

pelvic exam, or upon hearing a vacuum pump sound.)

Intrusion is the reexperience of the traumatic event at

unwanted and unexpected times. Symptoms of intrusion

in PAS cases include: recurrent and intrusive thoughts

App. 6

about the abortion or aborted child, flashbacks in which

the woman momentarily reexperiences an aspect of the

abortion experience, nightmares about the abortion or

child, or anniversary reactions of intense grief or depres-

sion on the due date of the aborted pregnancy or the

anniversary date of the abortion.

Constriction is the numbing of emotional resources, or the

development of behavioral patterns, so as to avoid stimuli

associated with the trauma. It is avoidance behavior; an

attempt to deny and avoid negative feelings or people,

places, or things which aggravate the negative feelings

associated with the trauma. In post-abortion trauma

cases, constriction may include: an inability to recall the

abortion experience or important parts of it; efforts to

avoid activities or situations which may arouse recollec-

tions of the abortion; withdrawal from relationships,

especially estrangement from those involved in the abor-

tion decision; avoidance of children; efforts to avoid or

deny thoughts or feelings about the abortion; restricted

range of loving or tender feelings; a sense of a foreshort-

ened future (e.g., does not expect a career, marriage, or

children, or a long life.); diminished interest in previously

enjoyed activities; drug or alcohol abuse; suicidal thoughts

or acts; and other self-destructive tendencies.

As previously mentioned, Barnard’s study identified a 19%

rate of PTSD among women who had abortions three to

five years previously. But in reality the actual rate is

probably higher. Like most post-abortion studies, Bar-

nard’s study was handicapped by a fifty percent drop out

rate. Clinical experience has demonstrated that the

women least likely to cooperate in post-abortion research

are those for whom the abortion caused the most psycho-

logical distress. Research has confirmed this insight,

App. 7

demonstrating that the women who refuse followup

evaluation most closely match the demographic character-

istics of the women who suffer the most post-abortion

distress. (10) The extraordinary high rate of refusal to

participate in post-abortion studies may interpreted as

evidence of constriction or avoidance behavior (not want-

ing to think about the abortion) which is a major symptom

of PTSD.

For many women, the onset or accurate identification of

PTSD symptoms may be delayed for several years. (11)

Until a PTSD sufferer has received counseling and

achieved adequate recovery, PTSD may result in a psycho-

logical disability which would prevent an injured abortion

patient from bringing action within the normal statutory

period. This disability may, therefore, provide grounds for

an extended statutory period.

SEXUAL DYSFUNCTION: Thirty to fifty percent of

aborted women report experiencing sexual dysfunctions, of

both short and long duration, beginning immediately after

their abortions. These problems may include one or more

of the following: loss of pleasure from intercourse, in-

creased pain, an aversion to sex and/or males in general,

or the development of a promiscuous life-style. (12)

SUICIDAL IDEATION AND SUICIDE ATTEMPTS:

Approximately 60 percent of women who experience post-

abortion sequelae report suicidal ideation, with 28 percent

actually attempting suicide, of which half attempted

suicide two or more times. Researchers in Finland have

identified a strong statistical association between abortion

and suicide in a records based study. Thely] identified 73

suicides associated within one year to a pregnancy ending

either naturally or by induced abortion. The mean annual

- App. 8

suicide rate for all women was 11.3 per 100,000. Suicide

rate associated with birth was significantly lower (5.9).

Rates for pregnancy loss were significantly higher. For

miscarriage the rate was 18.1 per 100,000 and for abortion

34.7 per 100,000. The suicide rate within one year after an

abortion was three times higher than for all women, seven

times higher than for women carrying to term, and nearly

twice as high as for women who suffered a miscarriage.

Suicide attempts appear to be especially prevalent among

post-abortion teenagers.(13)

INCREASED SMOKING WITH CORRESPONDENT

NEGATIVE HEALTH EFFECTS: Post-abortion stress is

linked with increased cigarette smoking. Women who

abort are twice as likely to become heavy smokers and

suffer the corresponding health risks. (14)

Post-abortion women are also more likely to continue

smoking during subsequent wanted pregnancies with

increased risk of neonatal death or congenital anomalies.

(15)

ALCOHOL ABUSE: Abortion is significantly linked with

a two fold increased risk of alcohol abuse among women.

(16) Abortion followed by alcohol abuse is linked to violent

behavior, divorce or separation, auto accidents, and job

loss. (17) (see also New Study Confirms Link Between

Abortion and Substance Abuse)

DRUG ABUSE: Abortion is significantly linked to subse-

quent drug abuse. In addition to the psycho-soc.al costs of

such abuse, drug abuse is linked with increased exposure

to HIV/AIDS infections, congenital malformations, and

assaultive behavior. (18)

App. 9

EATING DISORDERS: For at least some women, post-

abortion stress is associated with eating disorders such as

binge eating, bulimia, and anorexia nervosa. (19)

CHILD NEGLECT OR ABUSE: Abortion is linked with

increased depression, violent behavior, alcohol and drug

abuse, replacement pregnancies, and reduced maternal

bonding with children born subsequently. These factors

are closely associated with child abuse and would appear

to confirm individual clinical assessments linking post-

abortion trauma with subsequent child abuse. (20)

DIVORCE AND CHRONIC RELATIONSHIP PROB-

LEMS: For most couples, an abortion causes unforeseen

problems in their relationship. Post-abortion couples are

more likely to divorce or separate. Many post-abortion

women develop a greater difficulty forming lasting bonds

with a male partner. This may be due to abortion related

reactions such as lowered self-esteem, greater distrust of

males, sexual dysfunction, substance abuse, and increased

levels of depression, anxiety, and volatile anger. Women

who have more than one abortion (representing about 45%

of all abortions) are more likely to require public assis-

tance, in part because they are also more likely to become

single parents. (21)

REPEAT ABORTIONS: Women who have one abortion

are at increased risk of having additional abortions in the

future. Women with a prior abortion experience are four

times more likely to abort a current pregnancy than those

with no prior abortion history. (22)

This increased risk is associated with the prior abortion

due to lowered self esteem, a conscious or unconscious

desire for a replacement pregnancy, and increased sexual

activity post-abortion. Subsequent abortions may occur

App. 10 7

because of conflicted desires to become pregnant and have

a child and continued pressures to abort, such as aban-

donment by the. new male partner. Aspects of self-

punishment through repeated abortions are also reported.

(23)

Approximately 45% of all abortions are now repeat abor-

tions. The risk of falling into a repeat abortion pattern

should be discussed with a patient considering her first

abortion. Furthermore, since women who have more than

one abortion are at a significantly increased risk of suffer-

ing physical and psychological sequelae, these heightened

risks should be thoroughly discussed with women seeking

abortions.

NOTES:

1. An excellent resource for any attorney involved in

abortion malpractice is Thomas Strahan’s Major Articles

and Books Concerning the Detrimental Effects of Abortion

(Rutherford Institute, PO Box 7482, Charlottesville, VA

22906-7482, (804) 978-388 [sic].) This resource includes

brief summaries of major finding drawn from medical and

psychology journal articles, books, and related materials,

divided into major categories of relevant injuries.

2. Ashton, “They [sic] Psychosocial Outcome of Induced

Abortion”, British Journal of Ob&Gyn., 87:1115-1122,

(1980).

3. Badgley, et.al., Report of the Committee on the Opera-

tion of the Abortion Law (Ottawa:Supply and Services,

1977)pp.313-321.

4. R. Somers, “Risk of Admission to Psychiatric Institu-

tions Among Danish Women who Experienced Induced

App. 11

Abortion: An Analysis on National Record Linkage,”

Dissertation Abstracts International, Public Health 2621-

B, Order No. 7926066 (1979); H. David, et al., “Postpartum

and Postabortion Psychotic Reactions,” Family Planning

Perspectives 13:88-91 (1981).

5. Kent, et al., “Bereavement in Post-Abortive Women: A

Clinical Report”, World Journal of Psychosynthesis (Au-

tumn-Winter 1981), vol.13,nos.3-4.

6.- Catherine Barnard, The Long-Term Psychological

Effects of Abortion, Portsmouth, N.H.: Institute for Preg-

nancy Loss, 1990).

7. Herman, Trauma and Recovery, (New York: Basic

Books, 1992) 34.

8. Francke, The Ambivalence of Abortion (New York:

Random House, 1978) 84-95.

9. Zakus, “Adolescent Abortion Option,” Social Work in

Health Care, 12(4):87 (1987); Makhorn, “Sexual Assault &

Pregnancy,” New Perspectives on Human Abortion, Mall &

Watts, eds., (Washington, D.C.: University Publications of

America, 1981).

10. Adler, “Sample Attrition in Studies of Psycho-social

Sequelae of Abortion: How great a problem.” Journal of

Social Issues, 1979, 35, 100-110.

11. Speckhard, “Postabortion Syndrome: An Emerging

Public Health Concern,” Journal of Social Issues, 48(3):95-119.

12. Speckhard, Psycho-social Stress Following Abortion,

Sheed & Ward, Kansas City: MO, 1987; and Belsey, et al.,

“Predictive Factors in Emotional Response to Abortion: King’s

Termination Study — IV,” Soc. Sci. & Med., 11:71-82 (1977).

App. 12

13. Speckhard, Psycho-social Stress Following Abortion,

Sheed & Ward, Kansas City: MO, 1987; Gissler, Hemminki

& Lonngqvist, “Suicides after pregnancy in Finland, 1987-

94: register linkage study,” British Journal of Medicine

313:1431-4, 1996.C. Haignere, et al., “HIV/AIDS Preven-

tion and Multiple Risk Behaviors of Gay Male and Run-

away Adolescents,” Sixth International Conference on

AIDS: San Francisco, June 1990; N. Campbell, et al.,

“Abortion in Adolescence,” Adolescence, 23(92):813-823

(1988); H. Vaughan, Canonical Variates of Post-Abortion

Syndrome, Portsmouth, NH: Institute for Pregnancy Loss,

1991; B. Garfinkel, “Stress, Depression and Suicide: A

Study of Adolescents in Minnesota,” Responding to High

Risk Youth, Minnesota Extension Service, University of

Minnesota (1986). ;

14. Harlap, “Characteristics of Pregnant Women Report-

ing Previous Induced Abortions,” Bulletin World Health

Organization, 52:149 (1975); N. Meirik, “Outcome of First

Delivery After 2nd Trimester Two Stage Induced Abortion:

A Controlled Cohort Study,” Acta Obsetricia et Gyne-

cologica Scandinavia 63(1):45-50(1984); Levin, et al.,

“Association of Induced Abortion with Subsequent Preg-

nancy Loss,” JAMA, 243:2495-2499, June 27, 1980.

15. Obel, “Pregnancy Complications Following Legally

Induced Abortion: An Analysis of the Population with

Special Reference to Prematurity,” Danish Medical Bulle-

tin, 26:192-199 (1979); Martin, “An Overview: Maternal

Nicotine and Caffeine Consumption and Offspring Out-

come,” Neurobehavioral Toxicology and Tertology, 4(4):421-

427, (1982).

16. Klassen, “Sexual Experience and Drinking Among

Women in a U.S. National Survey,” Archives of Sexual

Behavior, 15(5):363-39 ; M. Plant, Women, Drinking and

App. 13

Pregnancy, Tavistock Pub, London (1985); Kuzma &

Kissinger, “Patterns of Alcohol and Cigarette Use in

Pregnancy,” Neurobehavioral Toxicology and Terotology,

3:211-221 (1981).

17. Morrissey, et al., “Stressful Life Events and Alcohol

Problems Among Women Seen at a Detoxification Center,”

Journal of Studies on Alcohol, 39(9):1159 (1978).

18. Oro, et al., “Perinatal Cocaine and Methampheta-

mine Exposure Maternal and Neo-Natal Correlates,” J.

Pediatrics, 111:571-578 (1978); D.A. Frank, et al., “Cocaine

Use During Pregnancy Prevalence and Correlates,” Pedi-

atrics, 82(6):888 (1988); H. Amaro, et al., “Drug Use

Among Adolescent Mothers: Profile of Risk,” Pediatrics

84:144-150, (1989)

19. Speckhard, Psycho-social Stress Following Abortion,

Sheed & Ward, Kansas City: MO, 1987; J. Spaulding, et al,

“Psychoses Following Therapeutic Abortion, Am. J. of

Psychiatry 125(3):364 (1978); R.K. McAll, et al., “Ritual

Mourning in Anorexia Nervosa,” The Lancet, August 16,

1980, p. 368.

20. Benedict, et al., “Maternal Perinatal Risk Factors

and Child Abuse,” Child Abuse and Neglect, 9:217-224

(1985); P.G. Ney, “Relationship between Abortion and

Child Abuse,” Canadian Journal of Psychiatry, 24:610-620,

1979; Reardon, Aborted Women -— Silent No More (Chi-

cago: Loyola University Press, 1987), 129-30, describes a

case of woman who beat her three year old son to death

shortly after an abortion which triggered a “psychotic

episode” of grief, guilt, and misplaced anger.

21. Shepard, et al., “Contraceptive Practice and Repeat

Induced Abortion: An Epidemiological Investigation,” J.

Biosocial Science, 11:289-302 (1979); M. Bracken, “First

App. 14

and Repeated Abortions: A Study of Decision-Making and

Delay,” J. Biosocial Science, 7:473-4 31 (1975); S. Henshaw,

“The Characteristics and Prior Contraceptive Use of U.S.

Abortion Patients,” Family Planning Perspectives,

20(4):158-168 (1988); D. Sherman, et al., “The Abortion

Experience in Private Practice,” Women and Loss: Psycho-

biological Perspectives, ed. W.F. Finn, et al., (New York:

Praeger Publ. 1985), pp98-107; E.M. Belsey, et al., “Predic-

tive Factors in Emotional Response to Abortion: King’s

Termination Study-IV,” Social Science and Medicine,

11:71-82 (1977); E. Freeman, et al., “Emotional Distress

Patterns Among Women Having First or Repeat Abor-

tions,” Obstetrics and Gynecology, 55(5):630-636 (1980); C.

Berger, et al., “Repeat Abortion: Is it a Problem?” Family

Planning Perspectives 16(2):70-75 (1984).

22. Joyce, “The Social and Economic Correlates of Preg-

nancy Resolution Among Adolescents in New York by Race

and Ethnicity: A Multivariate Analysis,” Am. J. of Public

Health, 78(6):626-631 (1988); C. Tietze, “Repeat Abortions

— Why More?” Family Planning Perspectives 10(5):286-

288, (1978).

23. Leach, “The Repeat Abortion Patient,” Family Plan-

ning Perspectives, 9(1):37-39 (1977); S. Fischer, “Reflection

on Repeated Abortions: The meanings and motivations,”

Journal of Social Work Practice 2(2):70-87 (1986); B.

Howe, et al., “Repeat Abortion, Blaming the Victims,” Am.

J. of Public Health, 69(12):1242-1246, (1979).

Reardon, Ph.D.

www.afterabortion.org

App. 15

THE NURTURING NETWORK:

SERVING THE URGENT AND PRACTICAL NEEDS

OF MOTHERS IN CRISIS

Personal Reflections of the Founder

Based upon Twenty Years of Compassion in Action

It is an honor to be invited to address you about a topic

that matters more to me than any other. Instead of ad-

dressing the myriad of vital issues concerning the termi-

nation of life for an unborn child, let us focus today upon

the life and well-being of another victim, the mother. I

believe that it is time to shift our emphasis from the

obvious harm that abortion causes an unborn child to the

tragedy it inflicts upon the life of the mother.

Introduction:

My name is Mary Elizabeth Cunningham Agee. I am the

mother of three children, one of whom died in a second

term miscarriage twenty years ago on January 8th. It was

this personal loss that riveted my heart and redirected my

mind to the pivotal societal issue that we are addressing

today.

You might appreciate knowing a little more about the

person whose perspective you are about to hear. Please

allow me to introduce myself:

Professional Background:

You may recognize my name as having been one of the

first women in America to “break the glass ceiling” by

serving in the Senior Management of two Fortune 100

Companies as the Vice President of Strategic Planning in

the 198C . I wrote a best-selling autobiography about my

App. 16

experience at the Bendix Corporation and Joseph E

Seagram & Sons and was twice voted by World Almanac

as one of the “Twenty-five most influential women in

America.” I have been given the opportunity to share my

thoughts about corporate culture, women in business and

professional ethics at the Commonwealth Club, in the Wall

Street Journal, Reader’s Digest and Newsweek, and on

many prime time television shows including Barbara

Walters, Peter Jennings, Donahue, the Today Show and

Good Morning America.

Educational Background:

My education includes a BA with Honors from Wellesley

College (’73) where I was elected to Phi Beta Kappa and

received two Danforth nominations in Moral Philosophy

and Ethics. I have also earned an MBA from the Harvard

Business School (’79) and studied Law and Jurisprudence

at Notre Dame University and Trinity College in Dublin,

Ireland. I have been awarded six honorary doctorates

primarily for my work over the past two decades in trying

to alleviate the suffering of thousands of women and

children whose circumstances have caused them to be

vulnerable to abortion.

Particular Expertise:

My primary expertise on the topic we are addressing today

is based upon two decades of experience as the Founder

and President of the Nurturing Network (TNN.) TNN is

an international charitable organization comprised of over

42,000 volunteer resource members who provide for all of

the urgent and practical needs of women with unplanned

pregnancies. Over 17,000 pregnant women and unborn

App. 17

children have been served through the practical compas-

sion of the Nurturing Network during the past twenty

years.

While I must admit that it took the personal anguish of a

mid-trimester miscarriage for me to grasp the horror of

prenatal death, it has taken the daily, life-saving activity

of the Nurturing Network to teach me the importance of

translating my reverence for human life into concrete

action. This growing awareness enabled me to not look

back for even one moment to the comfort and grandeur of

an executive suite in midtown Manhattan. I chose to leave

that way of life and a six figure salary for the far more

rewarding and, I dare say, more vital work of managing

and directing the Nurturing Network.

Viewpoint:

While TNN’s mission has had nothing to do with debating

the merits of abortion or trying to remove that alternative,

the performance of my counseling role has required me to

listen to the unsolicited testimonies of literally thousands

of women. To a person, each woman has shared her pro-

found regret and lingering emotional wounds as a result of

an abortion experience. It is this unexpected, and yet,

undeniable revelation that compels me to share what I

have learned with you.

When the option of abortion was first presented for your

consideration, scientific and anecdotal evidence was very

limited. Since 1973, valuable medical and scientific re-

search has been conducted and revealing anecdotal testi-

monies have been collected. The insights gleaned from

these sources offer a compelling case for reevaluating a

App. 18

procedure that was once considered to be a safe and

private solution for women in crisis.

Unlike thirty years ago, we now have a generation of

women who are prepared to open their private lives and

expose their wounds in the hope that their experience

might prevent others from the grief and emotional harm

that they have known. I hope that you will agree that we

cannot afford to turn a deaf ear to these women who

provide such an eloquent witness to the dangers caused by

a procedure made available to them in the hope of provid-

ing assistance.

At the close of my remarks, I will share several moving

testimonies of actual TNN clients who profoundly regret

their choice of abortion. Their words convey an anguish

and loss that the passage of time or euphemistic rhetoric

cannot repair. Their experience is a haunting reminder

that what many once hoped would provide a “reproductive

freedom” within a woman’s “private choice” has, instead,

resulted in a prison of tragic regrets for a generation of

women who now know that they deserve better than

abortion.

TNN Facts:

Approximately 50% of all TNN clients have already

experienced at least one abortion at the time they contact

us for help. This fact is revealed in either an initial toll

free phone call requesting assistance, a referral from a

local crisis pregnancy center, a first counseling session, or

a confidential online questionnaire.

App. 19

What the Clients Are Saying:

TNN clients express fear in having to “go through” another

abortion. They candidly share their profound remorse and

the conviction that they do not want to augment the

emotional anguish they have already endured. They often

share a sense of having been betrayed and then aban-

doned by those who convinced or coerced them into having

an abortion.

It may be difficult to imagine how utterly sincere and

blatantly honest these confidential counseling sessions are

between a TNN counselor and a client. More often than

not, I do not have the opportunity to meet a TNN client in

person. Our relationship usually takes place in the rela-

tive privacy of a phone call or by internet which seems to

afford more freedom to express what their hearts have

wanted to say for many years. A bond of trust is readily

established when a client discovers, often for the first time

in her life, that TNN wants nothing from them: No fees, no

baby to adopt, no promises, no work in exchange for our

services.

To more fully understand the wrenching sadness and

lasting regret that TNN clients describe following an

abortion, it may be worth examining the forces and influ-

ences that drive a woman to make this choice: An immedi-

ate escape from shame, the possibility of enhanced

economic security, the hope of saving a fragile relationship.

The actual testimonies of the betrayed and the abandoned

in TNN’s client files expose the miscalculations and

illuminate the disillusionment that inevitably follows:

App. 20

Most women readily identify four primary sources

of pressure or coercion that lead to an abortion

“choice”:

e The father of the baby: “It is our relationship

or the baby.”

e The parents: “It is either our financial sup-

port or the baby.”

e The boss: “It is either your job or the baby.”

e The peers: “It is either your social standing or

the baby.”

Of course, none of these tradeoffs have anything

to do with offering a woman in crisis the “free-

dom to choose.” Each ultimatum threatens to

impose an emotional toll calculated to force her

to make a desperate choice. And yet, as the at-

tached testimonies indicate, she alone will suffer

the agonizing remorse, the hidden grief, the de-

bilitating guilt.

Most women who have chosen abortion do so not

out of “freedom of choice” but out of a desperate

sense that they have no other choice.

Most women believe that the only “freedom” an

abortion affords is experienced by those “significant

others” who have much to lose if she continues her

pregnancy.

Most women express regret in having made the

“choice” to abort and many become pregnant again

in an effort to remedy their error and “recreate”

their deceased child.

App. 21

¢ Most women admit that very practical needs influ-

enced their decision to abort a pregnancy. I have

heard many say:

“If only I had been offered an alternative

educational opportunity; my peers were so

cruel when they found out that I was preg-

nant.”

“If only I could have been given a different

job; the father of the baby was my boss and I

just couldn’t put up with his ridicule and

pressure every day at work.”

“If only I could have had a peaceful, affirm-

ing place to live; my parents were so disap-

pointed in me that every day would have

been emotionally devastating living at

home.”

“If only I could have seen a good counselor to

help me understand what I was about to do

and what was at stake.”

“If only I could have had some financial sup-

port for college, rent and medical bills; my

parents withdrew all support and I just

couldn’t make ends meet.”

Listening to these women articulate what forms of practi-

cal support would have permitted their pregnancy to

continue is how the Nurturing Network was actually

formed. Before founding TNN, I interviewed and listened

to hundreds of women who shared the practical needs that

were not met when their own support networks let them

down. These unmet needs had directly led to their abor-

tion “choice” and helped to write the strategic plan that

formed the Nurturing Network.

App. 22

CONCLUSION:

There have been other times in history when a solution

initially considered to be helpful or at least useful was

eventually exposed as being dangerous and even harmful.

It requires a certain humility, honesty «ad open minded-

ness to admit when a judgment must change in light of

new and more compelling facts. This is what the women

whose painful experiences are captured in the attached

testimonies are calling for today.

The simple but profound truth is that abortion has not

turned out to be the private, painless, safe solution that

many had hoped it would be. Yes, it is quicker and seem-

ingly less complex than alternative solutions. It surely is

final. But the living testimonies of TNN clients reveals

that this procedure, often sought in haste and without a

full understanding of the emotional risks, has inflicted

profound and lasting harm a generation of women. Their

voices say better than anyone else ever could: Women

deserve better than abortion. It is time for this tragedy to

end.

I need only to reflect upon the thousands of women whom

I have had the privilege of serving since founding the

Nurturing Network to say with conviction that the binding

of deep wounds end the healing of broken hearts is an

intensely intimate and time-consuming process. In a

society that prides itself on finding quick fixes and expedi-

ent solutions to any inconvenience or problem, it is under-

standable that we would seek a short cut to solve the crisis

of an unplanned pregnancy. But time and experience

reveal that no fast solution exists without causing pro-

found and lasting harm to both the mother and the child.

App. 23

The simple truth is that there is no efficient or effective

substitute for what my two decades of experience tells me

every woman in crisis yearns for most of all: Love and

practical compassion. She does not seek our hand-washing

absolutions or an easy means of hiding or “getting rid of

her problem”. A generation of women now courageously

stands ready to teli us of a sobering reality: Abortion does

not heal, it harms. It silences a beating heart... and breaks

a mother’s too.

ADDENDUM: FROM TNN CLIENT FILES

HEARTBREAKING:

TNN counsels thousands of post-abortive, grieving women.

Here are several actual examples in each client’s own

words:

SARAH: TNN Valentine Card 2004

“I was not able to carry through with my pregnancy. I

wanted to say, ‘No,” but couldn’t gather the strength given

the extreme pressures. I am completely overwhelmed with

grief and depression beyond anything that I can describe.

If only I had know about your Nurturing Network a month

ago. I can’t forget how exposed and humiliated I felt lying

on that table. The pain, sense of loss and crippling night-

mares just won't let up. I can’t work and have lost my job.

I have lost everything! Will there ever be peace for some-

one like me?”

TRACEY: “Heart to Heart” Newsletter, Mother’s

Day 1992

I read about your organization in Ligourian and it is as

though a prayer was answered. I am twenty-eight and

App. 24 —~

gave birth to a son September 29, 1991. Since then I have

been looking for an — outlet for my intense feelings and

need to help someone else by sharing my personal experi-

ence in not going through with an abortion.

_ I was raped (the acquaintance variety) and have endured

all of the post-traumatic syndrome symptoms. The father

of the baby threatened to “throw me down the stairs” to

get rid of ‘it” when I told him I thought I was pregnant. I

went to a clinic to find out for sure if I was pregnant and

told their counselor what had happened to me. She as-

sumed that I wouldn’t want to keep the baby due to the

situation and scheduled my appointment.

I drove directly to the father of the baby’s apartment and

on the way there, the light looked different. The sky was

brighter. the clouds bigger and fuller, the sun more vivid

than I remembered. I was slowly waking up from my

shock and realizing I had a baby inside me... . something I

had-wanted since I was nine years old. I had been in a

relationship where the man couldn't have children and it

nearly ruined us because I wanted children so badly, and

here I was planning to get rid of one. I desperately wanted

this man to marry me out of a sense of obligation as a

father. After six hours of unsuccessful pleading, I left and

planned to run my truck off a cliff.

Having been thoroughly humiliated and insulted. I turned

to the man I left a year earlier (and still loved) and he

helped me for the weeks and months it took to decide the

fate of my child. He said to me. “We'll find a way. We'll

make it work:” Hearing these words gave me strength and

hope. and I’ve learned what a real father is. He’s a man

who fights for your life, makes life possible, and loves you

in spite of everything.

App. 25

I was lucky I know ... not everyone has someone to turn

to like your Network. But the point is the same, if you

open yourself to the possibility of this incredible love that

a child generates, people and things open up for you.

We have a beautiful, héalthy, energetic. tranquil boy and

there isn’t a day that goes by that I don’t think about what

I almost did. Well, that is pretty much it. I would like to be

able to share this and the rest of my experiences so that

maybe someone in a similar situation can benefit sooner,

and not go through the agony and torture I did. I would

very much like to volunteer as an inspirational counselor

and perhaps offer my services as an artist in some way.

Please find a place for me as this would mean the world to

me.

My son. Henry. has been on my lap for much of this letter

and at three months, thinks he can type! Thank you for

letting me share my story with you. Please call if I can be

of help right away. Again, thank you for your organization.

I wish I had known about you sooner.

JOANN: “Heart to Heart” Newsletter, Thanksgiv-

ing 1992

“In December, I lived through what today is so glibly

referred to in the press as ‘date rape.’ Two weeks later I

graduated with honors with a freshly minted MBA ...

only to have my dreams shattered. Any course of action,

other than abortion, would have meant total abandonment

by my family. When I asked for support, the aggressor

accused me of ‘emotional’ rape and then abandoned me. I

have kept this secret to myself until now.

App. 26

Last fall I had surgery for ovarian cancer and am now

unable to have children. When I die I will leave no legacy.

Had I known about the Nurturing Network, I would have

carried the child to term and my story would have had a

happy ending. If I encounter someone in the future whom

you may be able to help, I will tell them about your Net-

work. If only I had known...”

TONI: “Heart to Heart Newsletter,” Mother’s Day

1993

“Ten years ago, Toni, married and a mother of two, found

herself facing an unintended pregnancy. A baby simply did

not fit into her career plans nor into her family’s work

schedule. Seeking the advice of her obstetrician, Toni was

assured that an “early pregnancy termination” was the

best alternative and that he had never heard of anyone

having any adverse effects from this procedure. Tony [sic]

chose to abort her baby and struggled with this decision

for many years. Through painful years of grieving and

professional counseling she now shares her heartache and

hopes with Mary:

My wish is that I had known about The Nurturing Net-

work. It would have taken so little to convince me to have

our child. On this Mother’s Day, I urge other abortion

victims to come forth with their heartbreaking stories in

the hopes of bringing an end to this national tragedy. I

want to assure you that there is no need to suffer in

silence anymore. Compassion, understanding and support

is available and is only a phone call away.”

App. 27

JANE: TNN Valentine Card 1995

“When I found out that I was pregnant, I felt frightened

and trapped. I felt that if I continued my pregnancy, I

risked humiliating my family whom I love dearly. The

thought of my boyfriend leaving me and the knowing looks

of my friends at work was beyond anything that I could

bear.

Deciding to end my pregnancy was the loneliest moment of

my life. I knew then that this ‘choice’ would bring a sad-

ness that would never leave me. A day doesn’t go by that I

don’t think of what I lost. Perhaps it would help me to heal

if I could encourage someone else who is feeling as desper-

ate as I did. Please keep up the work you are doing! I only

wish I’d known about you sooner.”

MARGARET: TNN Valentine Card 1997

“Many years have passed since I was 23, frightened,

unemployed and facing the stark reality of an unplanned

pregnancy alone. I felt trapped with no idea of where to

turn knowing that my family would be deeply humiliated

and angry beyond words. I made the desperate choice to

abort my son because I could think of no other way to go

forward.

The pain of that choice will forever haunt me in the quiet

moments of every day. Just last week I learned about your

Network. If I could help even one mother who is feeling as

desperate as I was, I would be so grateful.”

JANET: TNN Valentine Card 1998

“On February 7, 1995, I had an abortion. One week ago, I

picked up my sister’s issue of Today’s Christian Woman. As

App. 28

I was flipping through the pages, I ran across your article

and cried throughout the whole reading. I wish this article

was put on every corner and available at every place that

provides abortion. If only I had known about your Net-

work, my baby could have been saved. I miss my baby so

much. I think I understand how God is helping me to heal.

I think He wants me to do something like you are doing.

How can I help someone else avoid this pain and loneli-

ness?”

KIM: TNN Valentine Card 1999

“Several years ago, I had a second trimester abortion. My

uterus was punctured and emotionally I was devastated.

Years of grief have taken their toll on me. I only wish I had

known about the Nurturing Network back then. I am

pregnant again and after many calls you are the only place

that has given me hope. What a comfort it is to know there

is an organization such as yours. I know that as I work

through the practical needs of my pregnancy with your

kind staff, I will be able to deal with the emotional wounds

still scarring my heart.”

MARTHA: TNN Valentine Card 2001

“Many years have passed since my senior year in college

when I felt deserted by almost everyone important to me

and made the desperate choice to abort my child. I could

think of no other way to go forward. The fear that haunted

me then was not being able to finish my education and

fulfill my dream to become a teacher. The fear that haunts

me now in the quiet of each day is that no matter what I

accomplish professionally, I will never hear my child’s

voice or laughter. I can only hope that at least one mother

App. 29

who may be feeling as alone and trapped as I was will read

my letter. I am living proof that your work is needed.”

App. 30

THE HEALTH RISKS OF ABORTION

PANEL PRESENTATION FOR FAMILY RESEARCH

COUNCIL BUILDING A CULTURE OF LIFE

Offered by Mary Cunningham Agee

President & Founder

The Nurturing Network

April 2002

“If only I had known.” This is the haunting lament that I

hear almost daily on the toll free crisis hotline of the

Nurturing Network. Since founding this charitable organi-

zation almost twenty years ago, I have been invited by

literally thousands of frightened, wounded women to

understand the painful circumstances of their troubled

lives. Let me assure you that they do not call to express

satisfaction in their “reproductive freedom” to terminate

the life of their unborn child. They call desperately seeking

immediate, practical assistance in order to avoid an

abortion procedure which almost half of our clients have

already experienced in a prior pregnancy.

This is why the Nurturing Network was founded: to

provide all of the practical support a mother in crisis needs

in order to choose life for her unborn child. Our 32,000

member resources are located in all 50 states and in 27

foreign countries. We offer individually tailored solutions

that include medical, emotional, financial, educational,

employment and residenfial assistance to any woman

whose own support network has let her down. I am happy

to share that we have had the indescribable joy of assist-

ing almost 15,000 mothers and children. Their personal

stories and courageous testimonies are what have contrib-

uted to the insights that I am sharing with you today.

App. 31

I must admit, therefore, that my perspective on the topic

of abortion is about as detached or philosophical as that of

a medic on the front line of an active combat zone.

I have come to know this topic up close and in living color

through the tragic life stories of women who believed the

marketing rhetoric about this allegedly sate [sic] and easy

procedure. And yet, almost all of them would tell you that

if they could erase just one decision in their lives, it would

be the irreversible one that ended the life of their unborn

child. Their grief is difficult to capture here in a few words

because it is always tinged with a sense of having been

betrayed. These women consistently describe the panic

and loneliness that sets in when those whom she has

trusted create fatal trade-offs between their role in her life

and her child. How can she help but feel tricked and

manipulated by boyfriends, parents, friends and employ-

ers who conveniently wash their hands of her maternal

needs and choose to describe her unborn child as an

inconvenience and even a threat. None of these accom-

plices, of course, will ever live out the permanent conse-

quences of an abortion decision the way she will and so her

sense of abandonment and isolation is profound.

While I am tempted to fill our time together with poignant

anecdotes from our client files, I believe that an objective

review of a few facts might be just as persuasive. The data

that I am about to share has not been gleaned from biased

sources, but rather, from medical and social scientists with

no ax to grind. Their rather startling research findings

only confirm what our common sense and the clients of the

Nurturing Network have said for years: Abortion is far

from being a safe procedure. It was, after all, this false

assumption about the safety of this procedure that led the

United States Supreme Court in to strike down every

App. 32

federal, state and local law regulating its practice. The

premise of their decision was that the advances of modern

medicine had removed the need for any regulation of the

procedure since it was now “relatively safe.”

Clearly, the facts no longer support this assumption and,

in fact, expose the glaring error at the root of our country’s

national policy toward abortion. The following data shows

that abortion is actually dangerous to the health of women

— both physically and psychologically — and, therefore,

should be at least regulated if not outright prohibited.

The data that I am about to share was made readily

available in a report generated by the Elliot Institute.

While I cannot include all of the findings listed on their

web site, I would like to acknowledge them for providing

such well-documented statistical information. I will be

drawing heavily upon this for the statistical part of my

presentation.

National statistics on abortion show that 10% of women

who undergo this procedure suffer from immediate compli-

cations. (1) Over one hundred different complications have

been associated with induced abortion. “Minor” complica-

tions include: infections, bleeding, fevers, chronic abdomi-

nal pain, gastro-intestinal disturbances, vomiting, and Rh

Sensitization. The nine most common “major” coinplica-

tions are infection, excessive bleeding, embolism, ripping

or perforation of the uterus, anesthesia complications,

convulsions, hemorrhage, cervical injury and endotoxic

shock. (2) Can you imagine what an honest warning label

might read like for such a procedure?!

While the immediate complications of abortion are usually

treatable, these complications frequently lead to even more

serious long-term reproductive damage.. For example, one

App. 33

common outcome of abortion related infections is sterility.

Researchers have reported that as many as 5% of aborted

women are left inadvertently sterile. (3)The risk of steril-

ity is even greater for women who are infected with a

venereal disease at the time of an abortion.(4)

In addition to the risk of sterility, women who acquire

post-abortal infections are five to eight times more likely

to experience ectopic pregnancies.(5) In fact, between 1970

and 1983, the rate of ectopic pregnancies in the U.S. has

risen four-fold! (6) It is worth noting that 12% of all

maternal deaths are due to ectopic pregnancy. (7) And

other countries who have legalized abortion have also seen

the same dramatic rise in ectopic pregnancies. (8)

Cervical damage is another leading cause of long term

complications following abortion. According to one hospital

study, 12.5% of first trimester abortions required stitching

for cervical lacerations. (9) Another study found that

lacerations occurred in 22% of aborted women. (10) And

women under the age of 17 have been found to face twice

the normal risk of suffering cervical damage. (11)

Whether microscopic or macroscopic in nature, the cervical

damage which results during abortion frequently results

in a permanent weakening of the cervix. This weakening

may result in an “incompetent cervix”, a serious medical

condition in any pregnancy that often results in miscar-

riage or premature birth. According to one study, symp-

- toms related to cervical incompetence were found among

75% of women who undergo forced dilation for abortion.

(12)

To put this risk in context, cervical damage from previ-

ously induced abortions significantly increases the risk of

miscarriage, premature birth and complications of labor

App. 34

during later pregnancies by 300 to 500%! (13) The repro-

ductive risks of abortion are especially acute for women

who abort their first pregnancy. A major study of first

pregnancy abortions found that almost half, or 48%, of

women experienced abortion-related complications in later

pregnancies. Women in this group experienced 2.3 miscar-

riages for every one live birth. (14) And another researcher

found that among teenagers who aborted their first

pregnancies, 66% subsequently experienced miscarriages

or premature birth of their second pregnancy. (15)

When this risk of increased pregnancy loss is projected on

the population as a whole, it is estimated that aborted

women lose 100,000 “wanted” babies each year due to

latent abortion morbidity. (16) In addition, premature

births, complications of labor, and abnormal development

of the placenta all can result from latent abortion morbid-

ity and each are leading causes of handicaps among

newborns. (17) Considering premature deliveries alone, it

is estimated that latent abortion morbidity results in 3000

cases of acquired cerebral palsy among newborns each

year. (18) And, finally, since these pregnancy problems

pose a threat to the health of the mothers too, women who

have had abortions face a 58% greater risk of dying during

a later pregnancy. (19)

There are similar shocking statistics that expose the

serious psychological risks associated with abortion. Since

this topic has been assigned to Dean Gladys Sweeney, I

will not cover this topic in my remarks. But I cannot

conclude my thoughts without at least stating that the

emotional scars of this decidedly unsafe procedure -are

every bit as devastating as the physical ones we have just

discussed.

App. 35

It is my hope that by sharing this data, you will be moved

to inform others who are at risk for an abortion procedure.

It is a cruel and unconscionable for any of us to remain

silent in the face of new scientific evidence that undenia-

bly points to the health risks of this procedure for women.

It is time for those in a position of policy-making power to

correct the errors of the past and protect the next genera-

tion of women from further exploitation and damage.

Thank you.

Footnotes: 1. Frank, et al, “Induced Abortion Operations

and Their Early Sequelae”, Journal of the Royal College of

General Practitioners (April 1985), vol 35, no 73, pp 175-

180. 2. Reardon, Aborted Women-Silent No More, (Chi-

cago: Loyola University Press, 1987). 3. Wynn and Wynn,

“Some Consequences of Induced Abortion to Children Born

Subsequently”, British Medical Journal (March 3, 1973),

and Foundation for Education and Research in Child

Bearing (London, 1972) 4. Wilke, Abortion: Questions and

Answers, (Cincinnati, Hayes Publishing Co., 1985). 5.

Chun, et al. Effects of Induced Abortion on Subsequent

Reproductive Function and Pregnancy Outcome, Univer-

sity of Hawaii (Honolulu, 1981) 6. Atrash, et. Al., “Ectopic

Pregnancy in the U.S., 1970-1983” MMRW, Center for

Disease Control, vol.35, no. 2ss9.29ss. 7. “Annual Ectopic

Totals Rose Steadily in 1970’s But Mortality Fell”, Family

Planning Perspectives (1983) vol,15,p.85. 8. Hilgers, “The

Medical Hazards of Legally Induced Abortion,” in Hilgers

and Horan, eds, Abortion and Social Justice (New York:

Sheed and Ward, 1972). 9. Wilke, Handbook on Abortion,

(Cincinnati, Hayes Publishing Co., 1979). 10. “Abortion in

Hawaii”, Family Planning Perspectives (Winter 1973) 5(1):

Table 5. i1. Schulz, et. Al., “Measures to Prevent Cervical

Injury During Suction Curettage Abortion”, The Lancet

App. 36

(May 28, 1983),pp 1182-1184. 12. Wren, “Cervical Incom-

petence — Aetiology and Management”, Medical Journal of

Australia (December 29, 1973), vol 60. 13. Harlap and

Davies, “Late Sequelae of Induced Abortion: Complications

and Outcome of Pregnancy and Labor”, American Journal

of Epidemiology (1975). Vol 102, no.3; Hogue, “Impact of

Abortion on Subsequent Fecundity”, Clinics in Obstetrics

and Gynecology (March 1986), col.13,no.1. 14. Lembrych,

“Fertility Problems Following Aborted First Pregnancy”,

eds. Hilgers, et al., New Perspectives on Human Abortion

(Frederick, MD.: University Publications of America,

1981). 15. Russel, “Sexual Activity and Its Consequences

in the Teenager”, Clinics in Ob&Gyn, (Dec 1974). Voll,

no.3, pp 683-698. 16. Reardon, Aborted Women-Silent No

More, (Chicago: Loyola University Press, 1987). 17. Hogue,

Cates and Tietze, “Impact of Vacuum Aspiration Abortion

on Future Childbearing: A Review”, Family Planning

Perspectives (May-June 1983), col.15, no.3. 18. Reardon,

Aborted Women-Silent No More, (Chicago: Loyola Univer-

sity Press, 1987). 19. Reardon,

Mary Cunningham Agee, President and Founder

To reach our Communication and Development Office

please feel free to contact us at:

The Nurturing Network

PO Box 1489

White Salmon, WA 98672

800-TNN-4MOM 509-493-4026 (Phone) 509-493-4027 (Fax)

tnn@nurturingnetwork.org

Home

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New!

App. 37

Articles and Speeches | | College Network | | Women of

Courage

Founder’s Profile | | Culture of Life | | What is Clustering?

Suggestion Box

Last updated Tuesday, November 19, 2002

App. 38

Parts of the following are excerpted from an essay written

by Peggy Hartshorn, Ph.D., President cf Heartbeat Interna-

tional, published in Back to the Drawing Board: The

Future of the Pro-Life Movement, Teresa R. Wagner, ed.,

(South Bend, Ind.: St. Augustine’s Press, 2003).

Pregnancy Help Centers: Prevention, Crisis

Intervention, Healing: Putting It All Together

by Peggy Hartshorn, Ph.D.

The burgeoning numbers and types of alternatives to

abortion services and affiliating organizations also tell

much about our response to the devastating effects of

abortion. The first printed (i.e. mimeographed) directory of

contact names and semi-organized centers in the United

States contained about 75 entries. The most recent Heart-

beat Internationa: Directory contains 3,471 entries in the

U.S. Approximately 2,026 are pregnancy centers (about

479 of which have added medical services), and about 80%

of those are members of one or more of 9 affiliating organi-

zations: Baptists for Life, Grand Rapids, MI; Birthright,

Atlanta, GA; Care Net, Sterling, VA; Christian Life Re-

sources, Milwaukee, WI; Heartbeat International, Colum-

bus, OH; International Life Services, Los Angeles, CA;

National Institute of Family and Life Advocates, Freder-

icksburg, VA; National Life Center, Woodbury, NJ; and

Save-A-Life, Birmingham, AL.

The rest of the entries consist of 507 professional sccial

service agencies, such as Catholic Charities, also known

for providing alternatives to abortion; 319 Christian

maternity homes; 166 non-profit, Christian adoption

agencies; 27 hotlines; and 54 independent post abortion

programs (the vast majority are housed within pregnancy

centers). °

App. 39

The History of our Network

The types of organizations reflect our response to the

women, girls, and families who have been coming to us for

help for over 30 years. In the late 60’s and 70’s we pre-

sumed these women were in short term crisis. Now we

recognize them as the walking wounded who need much

more than simple crisis intervention.

The birth of pregnancy centers in the U.S. was not a result

of Roe v. Wade but of the earlier movement to liberalize

abortion laws state by state. Concerned people realized

that with the carefully crafted message that abortion was

sometimes the reluctant, humane, even loving choice;

some women would be influenced to abort their babies

unless they had help and support. The work was generally

seen as service, a humanitarian effort, an outreach of one

caring individual to another, although the motive was

from deeply held religious values and beliefs.

The first formal alternatives to abortion service organiza-

tion was Birthright, founded in Canada in 1968.’ Centers

using the Birthright name soon spread to the United

States. A strict Charter, established in 1971, is still fol-

lowed by all Birthrights. Their vision was that you could

not save the baby without “saving” (or serving) the mother,

and vice versa.

A similar woman-and-baby-centered vision was held by

the Alternatives to Abortion, formed in 1971 (now known

as Heartbeat International) in the United States." The

founders established a loose federation of independent

organizations that could network with and learn from each

other. This seemed right for the entrepreneurial United

States, where a variety of small organizations had already

sprung up, starting in the late 60’s, from California to New

App. 40

York, some operating out of pro-life doctors’ offices,

churches, or even homes.

While AAI often called itself the “service arm of the pro-

life movement,” they and Birthright considered themselves

quite distinct from Right to Life, the lobbying and educa-

tional arm. Their role was primarily “crisis intervention.”

Once the woman knew she had a friend and could be

connected, by referral, to a variety of services in the

community (medical care, housing, material aid, and social

services), the presumption was that their work had been a

“success.” The mother was safe, and therefore the baby

would be safe.

By the 1980’s and certainly in the 1990’s, as abortions

continued and affected not only women but everyone

connected with them, as the culture became more accept-

ing of “sex for recreation,” as sexually transmitted diseases

surged and AIDS emerged, as marriage declined and the

disintegration of the two-parent family continued, the

“disconnect” between the original theory and reality

became evident.” In response, new values and visions

within the pregnancy center movement emerged.

The Baby-Centered Vision: The first influence was the

baby-centered approach. It soon brought centers, in

general, into disrepute, but eventually led to a movement

from within toward real credibility. In the late 1970's,

perhaps due to frustration that the lobbying and educa-

tional branch had not passed a Human Life Amendment

and abortion numbers were skyrocketing, a more pro-

active influence came into the pregnancy center move-

ment. Centers were urged to advertise alongside abortion

clinics in the yellow pages (the phone book indexes re-

ferred readers to the same headings, such as Clinics and

App. 41

Birth Control Information, for both abortion services and

abortion alternatives), show slides to clients of fetal

development and aborted babies, and, in general, use

every possible method to save the baby at risk for abor-

tion. A small number of “Problem Pregnancy Centers”

influenced by this approach emerged.”

In 1987, an orchestrated effort by Planned Parenthood

resulted in television and magazine exposés on these

centers. Stories, written by undercover reporters posing as

clients and using hidden cameras and tape recorders,

ironically faulted the centers for not being totally “up

front” and transparent.”

Congressional hearings were held, but pregnancy centers

were forbidden from testifying in their own defense, so, in

the public arena, pregnancy centers had a “black eye.”

Many involved in centers felt the embarrassment and

shame, and supporters began to wonder if their own center

was operating unethically. Centers began to be suspicious

of each other. The boomerang effect even caused some to

think they needed to “warn” potential clients, in ads and

on the phone, of their pro-life values. Client numbers

decreased in many areas.

The attacks resulted not in the end of pregnancy help

centers, the intention of our opponents, but eveniually in

strengthening of the centers. In 1993, NIFLA, the Na-

tional Institute of Family and Life Advocates, was founded

specifically to provide legal education and training to help

centers become more professional and protect themselves

from frivolous tort claims (such as assault and battery for

touching a client without her permission), and NIFLA

spearheaded the development of the first insurance

program to protect centers for “counselor liability.””

App. 42

The Medical Vision: Some centers in California had been

accused of “practicing medicine without a license” for

providing urine pregnancy tests, and pro-choice word-

smiths began to label all centers “fake clinics.” Meanwhile,

‘in the medical field, ultrasound was emerging as a new

diagnostic tool for pregnancy. NIFLA soon envisioned real

clinics not only doing pregnancy testing but also using

ultrasound to diagnose pregnancy, and pioneered a medi-

cal model for centers either licensed by the state or work-

ing under the license of a private physician. The potential

of ultrasound to help abortion-vulnerable mothers bond

with their babies was clear.

More and more centers today are adding ultrasound

services for abortion-vulnerable clients. True to their

entrepreneurial nature, centers are taking the original

model even further, with some adding STD testing, pap

smears, natural family planning, prenatal care, birthing

centers, and even well baby care. Some are becoming

“hub” medical clinics and encouraging other centers to

refer clients to them for ultrasound and other medical

services. As we partner with doctors, nurses, and other

medical personnel to bring a more pro-life and holistic

approach to the care of women, we are beginning to see a

ripple effect influencing the medical community.

Ironically, the original baby-centered approach, that

provided ammunition to discredit centers, eventually led

to more professionalism and credibility. Ironically too, our

opponents certainly hoped to eliminate all baby pictures.

Instead, still pictures have been replaced by images of

“live action” ultrasound provided by licensed medical

personnel that alluws women not only to have an accurate

diagnosis of pregnancy at a very early stage (thereby

App. 43

helping their decision-making process), but also to bond

with their babies in utero.

In the early 1980’s, Evangelical Christians came into the

pro-life service movement in large numbers, and they were

a “breath of fresh air” to those who had been carrying the

ball since the late 60’s. Christian Action Council (CAC)

had been formed in 1975, primarily as a pro-life educa-

tional and lobbying organization, and it soon saw the need

for pregnancy centers. Their first pregnancy center was

opened in 1980. In 1984, CAC launched Sanctity of Hu-

man Life Sunday on the Sunday closest to January 22, in

an effort to educate and motivate Evangelical churches

nationwide. The service arm of this organization eventu-

ally took priority, the education and lobbying arm of CAC

was eliminated, and CAC was renamed Care Net in 1994,

to emphasize their network of renamed Pregnancy Care

Centers.

The value of the work of pregnancy centers as Christian

ministries has been enhanced by the involvement of Focus

on the Family, which, in the 1990’s, developed a program

to support pregnancy centers with educational materials

and a ministry office.

The Healing Vision: In the early 70’s, we had begun to

see clients who had already had one or more abortion and

were thinking of another, and we had begun to be ap-

proached by post abortive women who wanted to help

other women avoid the tragic mistakes they had ‘made.

The term “post abortion syndrome” had not yet even been

coined. When we consulted professional counselors for

help, they either denied that abortion had any ill effects or

they cautioned us, as volunteers and nonprofessionals, not

App. 44

to get involved for fear that post abortive women might

become suicidal.

Early attempts were made in some AAI centers to create

post abortion programs that were “nondenominational and

nonsectarian.” However, when centers were confronted

with the need for post abortion healing programs, many

moved from the service model to a ministry model, realiz-

ing that they had to choose a basis for their program and

the obvious choice was Biblical. As a result, pregnancy

centers have been pioneers in developing post abortion

programs for men and women that take the form of sup-

port groups, Bible studies, or one-on-one discussions.

Organizations have formed whose sole mission is to

provide and promote post abortion programs, many of

which have their roots in pregnancy centers.

We have also come to realize in pregnancy centers that

almost all of our clients have broken sexual integrity. They

are wounded by casual sex and broken trust, sexual abuse,

incest, date rape, and/or abortion. By the 1980’s and

certainly by the 90’s, most of our clients had grown up in a

post Christian era. Most were not even born in the

“quaint” time when abortion was illegal and marriage was

the default option if there was a crisis pregnancy. Crisis

intervention alone is sometimes effective in keeping such

clients from jumping off a cliff (i.e. not choosing an abor-

tion), but they are still left with broken limbs and severely

damaged internal organs, like broken hearts and souls.

Life change and healing are necessary. Our centers have

sometimes become “revolving doors,” where clients come

back time and again for pregnancy tests. Providing on-

going support, education, and healing is becoming a

priority in our movement, and new programs are being

App. 45

introduced in an effort to provide healing and restoration

so clients can actually regain their sexual integrity.

The Prevention Vision: Abstinence education, like post

abortion healing, also had its beginnings in pregnancy

centers, since we had to develop an approach when the

client had a negative test, a more common result than the

positive test. In the 1980’s, as we witnessed more and

more clients with multiple sexual partners and sexually

transmitted diseases, it became clear that we needed to

move the abstinence message outside the pregnancy

center, and especially into the schools. All over the country,

entrepreneurial center volunteers and staff who had a

heart for prevention began to give classroom presentations

and inspirational assemblies. Abstinence curricula and

speakers began to proliferate and many centers started

abstinence education programs in schools and in the

community and consider “prevention” a major part of their

mission.

Tax-funded abstinence education programs, have ex-

panded dramatically and reached more and more schools

and communities (and teen pregnancy and sexual activity

rates have declined.). Pregnancy centers have been pio-

neers in the abstinence field. Many centers now have a

prevention program that is equal to or even greater in

scope and funding than their crisis intervention program,

and some of the best national abstinence education pro-

grams have their roots in our centers.”

The Marriage Vision: We have not ignered the growing

evidence, placed before our eyes in the person of our

client, that the deterioration of marriage in our culture

over the past 30 years has led to a dangerous situation

for single mothers and their children. The statistics are

App. 46

overwhelmingly convincing that children raised with both

biological or adoptive parents do best in terms of econom-

ics, education, physical and mental health, and many

other factors related to security and happiness. Children

do the least well in all of these measures when raised by

single mothers where the fathers are absent. While we

have always upheld the value of adoption and marriage,

few of our clients choose marriage or adoption. For many

of them, raised in an era in which divorce is rampant and

co-habitation is common, marriage is a foreign concept.

Many centers are experimenting with programs and

materials to get the fathers committed to being involved

during the pregnancy and after the baby is born. For

example, the founder of Boston’s “A Woman’s Concern

Pregnancy Health Centers,” a Baptist minister, initiated a

program called “Dad’s the Man” to envision males about

their role as husbands and fathers. As a result, the pastor

has been asked to officiate at several marriages of center

clients. The movement is committed to trying to help turn

the tide back toward marriage (and adoption), toward

more security for both women and children.

Today

We have grown tremendously in terms of numbers and

kinds of centers, of professionalism, of breadth and depth

of programs (prevention, intervention, healing). Sadly, our

growth has mainly been due to the increasingly devastat-

ing effects of abortion (and related sexual mores) in our

culture, as more and more wounded and scarred women

(men and children) seek us out for help and we respond to

the needs. We are seeing more and more casualties inside

our pregnancy centers.

App. 47

Today, pregnancy centers offer many services including,

but certainly not limited to, pregnancy tests, material

help, maternity clothing, baby items and parenting

classes. They offer referrals for adoption, medical care,

childbirth classes, legal assistance, financial assistance,

housing, and many other services that women facing an

unexpected pregnancy need. And it’s all provided at no

cost. Our volunteers come alongside women and offer

solutions that women can live with. As a society, we can do

better than to tell a woman that her only option is to take

the life of her child. A caring society reaches out and helps

those mothers who are in a difficult situation. Rather than

telling her that her solution is to kill her child, our centers

provide real, practical help so that she can choose life for

her child. If a woman is feeling pressured into an abortion

by those around her, or by financial circumstances, she

isn't really being given a “choice.” Our centers are striving

to change that.

Many of our centers are branching out in an effort to meet

the needs of women by providing ultrasounds, STD test-

ing, prenatal care, natural family planning, abuse recov-

ery, and post abortion programs.

What ties all of the diverse centers together in the alterna-

tives to abortion movement is sexual integrity, whose

absence is the root of abortion. By sexual integrity, we

mean that sexual relationship, unconditional love, mar-

riage between man and woman, children, and God, all go

together. [f we try to remove one of these from the equa-

tion we have almost all of the modern social ills (abortion,

but also rampant divorce, co-habitation, fatherlessness,

STD's, loveless marriages, promiscuity, child abuse, and

more). Sexual integrity is what all pregnancy centers are

about: prevention, so sexual integrity is protected and

App. 48

valued; intervention, when crisis occurs because sexual

integrity is not being lived out; and healing, so sexual

integrity can be restored.

' Birthright was founded by the late Louise Summerhill in Toronto,

Canada. The Birthright USA central office is located in Atlanta,

Georgia.

“ AAI was founded in Toledo, Ohio, by the late John Hillabrand,

M.D., an obstetrician/gynecologist, and Mrs. Lore Maier, an immigrant

from Germany who had served as a court reporter at the Nuremburg

Trials following World War II. Now called Heartbeat International, the

central office is in Columbus, Ohio.

“ For research on the decline of the family and marriage, with

attendant social problems, see a variety of papers by The Heritage

Foundation, Washington, DC, www.heritage.org. For statistics on the rise

of sexually transmitted diseases and AIDS, see studies by The Medical

Institute, Austin, TX, www.medinstitute.org.

" A manual, written by Bob Pearson over 20 years ago, which

promoted this baby-centered vision, is still quoted extensively by

NARAL on its web site to discredit pregnancy centers, even though

most people in the movement have never even seen the manual.

* See “The Making of a Controversy: The History of the Conspiracy

Against Pregnancy-Help Centers,” a Special Report (vol. iii, no. 3) by

Life Decisions International, Washington, DC. Also available on their

web site at www. interlife.org.

“ Thomas Glessner, J.D. (chairman of the Board of the Seattle

pregnancy center, victimized by the NARAL smear campaign of the

1980’s) founded and still leads NIFLA, which has also published

newsletters detailing the court cases brought against pregnancy

centers.

™ For example, Abstinence Clearinghouse, the only national

organization that tracks and evaluates all abstinence until marriage

programs (and also publishes a Directory of these programs and holds

annual conferences for abstinence education providers) was founded in

1997 by Leslee Unruh, also founder of the pregnancy center in Sioux

Falls, South Dakota.

App. 49

[LOGO] Pregnancy Decision

Health Centers

Annual Report

2003

[Excerpts]

;, ,OUR'MISSION ® "c=...

The mission of Pregnancy Decision Health Centers is to

empower individuals to make healthy life choices consis-

tent with the intrinsic value of every human life.

We seek to provide caring services for responsible sexual

values and alternatives to abortion to as many individuals

as possible in the central Ohio area. We focus especially on

individuals considering abortion because they lack infor-

mation or support. We do this through programs which

provide pregnancy testing and intervention; pregnancy

confirmation through medical examination and = ultra-

sound; mentoring and nurturing support; linkage to

community resources; education and training; post abor-

tion support; adoption support; material aid; housing

referrals for pregnant girls and women; and abstinence

education in the community.

We provide consultation to groups who share our vision,

and we serve as a leader in the community and movement

at large for responsible sexual values and alternatives to

abortion.

.. OUR PRINCIPLES OF SERVICE

—_

Services promote life-affirming choices for pregnancy

and sexuality. |

2. Services are presented in a loving, caring, non-

judgmental manner.

App. 50

3. Services are presented to people of all races, cultures,

and creeds.

4. Services are confidential.

Services promote abstinence as the positive life choice

for unmarried persons.

ee eo me

Sanctity of every human life

Chastity (abstinence outside of marriage; faithfulness

within marriage)

Marriage and Family

Personal responsibility

Self-help

Dignity of work

Knowledge and wisdom

Community

Church.

10. Prayer

eo Pen ees f &

These values are rooted in and flow from the Christian

faith of PDHC Board, Staff, and Volunteers.

ny HISTORY OF PREGNANCY DECISION 3

Oe “HEALTH CENTERS =~ & me

PDHC exists today because of the dream of a few couples

in 1978. Since then, so_many others have made this

dream their own. These founding couples had helped

pregnant women in their own homes, but knew more had

to be done. With $500 and 10 volunteers, their vision, to

reach out with loving and practical alternatives to abor-

tion, was realized with the opening of our ist client office

App. 51

and 24-hour Hotline in January, 1981. The first year God

blessed their efforts with 3,109 client visits and calls, and

they knew this was the beginning of a local mission effort

to extend help to girls and women in need.

Over the next 23 years our programs of help and support

expanded along with the numbers of volunteers, support-

ers, and crisis intervention offices. In 2003 PDHC operated

5 health services offices, a 24 hour hotline, two ultrasono-

graphy medical clinics, a post-abortion healing program,

abstinence education, and several continuing care pro-

grams to meet the physical, emotional and spiritual needs

of mothers, fathers, and babies, both born and unborn. As

a result, trained staff and volunteers served 19,616 indi-

viduals with health services and 14,371 students with

abstinence education services in 2003, a record number.

A key to our health and growth has been the commitment

to good stewardship of the funds entrusted to PDHC by

our donors, most of whom are individuals and families.

Due to the generosity of donors and volunteers, our

services have always been provided at no cost to

teens, women, and men who seek our help. The

following chart is a window into our history.

1981 2003

ty of People Served 3109 33,987

# of FT & PT Paid 0 32

Employees FTE 27.5

# of Volunteers 10 286

Wt of Offices 1 5

Since our inception, approximately 3000 abortion-

vulnerable women have chosen life for their children

App. 52

With each new client need, PDHC strategically answered

with a creative new service. The three most noteworthy in

our history were the purchase of the Chrysalis House in

1990, the opening of our own Medical Clinic in 1995, and

the initiation of an abstinence until marriage education

program in the public schools in 1998.

The purpose of the Chrysalis House was to have a place

for our Life Plan program to provide prenatal, parenting,

and life-skills education. This program, (formerly “Part-

ners”) was recognized by the Ohio Department of Health

for our excellent work with mothers with a high-risk of an

unhealthy birth.

The opening of our Medical Clinic was as instrumental to

our life-affirming ministry as the opening of our first

office. The Clinic is staffed with volunteer physicians,

sonographers, and nurses who provide pregnancy confir-

mations, physician consultations, and ultrasounds to

women considering abortion. The powerful truth of the

ultrasound picture has resulted in many abortion-

vulnerable clients choosing life for their babies. Since

1995, we have seen more than 2,368 of our most abortion

vulnerable clients at the clinic.

1996 marked another significant advancement in our

work, with a nurse manager overseeing each neighborhood

office and the medical clinic. The nurse managers and

health service volunteers invite local medical & social

service providers and the local church to join in providing

for the needs of clients who visit PDHC.

Reestablishing an abstinence education program in the

school system became an obvious need as we constantly

counseled with single girls and women in our offices who

had never had anyone speak to them of the advantages of

App. 53

abstinence to their physical and emotional health. We

understand that we are fighting an uphill battle, as we try

to undo the false message of ‘safe sex’ and ‘condom use’

that Planned Parenthood and others have indoctrinated

into students, parents, and educators for more than 40

years.

Since our inception, at least 3,000 abortion-vulnerable

women have chosen life for their child, and an additional

3,000 women who were struggling with an abortion

decision decided to consider other options. Hundreds of

women have been emotionally restored from a previous

abortion decision, thousands of women and students have

made a commitment to end destructive sexual activity,

many. have opened their hearts to God’s love, and thou-

sands more have benefited from our programs.

In our 1999 strategic plan we addressed a concern that we

had become too inwardly focused and allowed the huge

social service needs of our clients to shift our priorities

away from the abortion vulnerable client. We committed to

reevaluate our programs and return our priorities to the

original vision of:

e Seeking to provide caring services for responsible

sexual values and alternatives to abortion to as many

individuals as possible in the central Ohio area.

¢ Focusing especially on individuals considering abor-

tion because they lack information or support.

° Providing consultation to groups who share our

vision, and serving as a leader in the community and

movement at large for responsible sexual values and

alternatives to abortion.

As we entered the new century, we remained committed to

constantly reviewing our locations and services and

App. 54

adjusting to serve the needs of the community. In 2001, we

opened a new flagship center/north office, we revamped

our programs and services consistent with our mission,

adjusted our office hours to better meet client needs,

added professional hotline staff, reached out to churches to

partner with us in serving client support and healing

needs, expanded our school abstinence program, upgraded

our volunteer training program, and recommitted to

assisting other groups who share our vision, partnering

with Heartbeat International to train pregnancy center

workers nationally and internationally.

In 2001, we also began a growth campaign, Legacy of Life

... A Plan for Growth, to purchase the building at 665 E.

Dublin-Granville Rd. and expand our programs and

community outreach. Through year-end we had received

$690,000 in pledges.

In 2002, we began the initial stages of a new strategic

plan, which calls for partnering with groups throughout

central Ohio to reach any abortion-vulnerable person in

this area. We also received a grant to expand our media

outreach to -abortion vulnerable girls and women, to

purchase an additional ultrasound and expand medical

clinic services by training an additional PT nurse in

sonography in order to open a second location, and to

expand our fundraising abilities. We served a record

number of clients and students (28,737) and had a record

357 life decisions from abortion minded clients with

another 293 saying they would reconsider their options.

During 2002, our founder and Board of Directors Chair-

man for 22 years, eggy Hartshorn retired from the Board of

Directors, moving to the Advisory Board and Emeritus Board

Chairman. Longtime Board member, Linda Augspurger,

App. 55

was elected Chairman, Executive Director Joyce Wilson

became President and Debra Neybert became Executive

Director, as we restructured our staffing to accommodate

the significant growth we have experienced. We moved

into a new phase of development that always occurs when

a founder retires.

We reached a new milestone in 2003 when the Pregnancy

Care Center of Fairfield County merged with PDHC, and

in May we reopened their office which had closed in 2002.

We began the 2nd phase of our Legacy of Life Growth

Campaign. We opened a second medical clinic location at

the East Office, and at the invitation of Christian Assem-

bly Church, began planning our 6th office location at 4099

Kar! Road (their former Christian School building) to open

in 2004.

We enter 2004 in awe of what God has done and continues

to do through thousands of faithful staff, volunteers, and

donors over the past 23 years. The Creator and Sus-

tainer of all life is Faithful.

* HEALTH SERVICES CLIENTS

_. WHEALTH | : - ocr [eee TOTAL 4 Tec YEAR to YEAR “% °¢

CLIENT VISITS;| = Re eit eee ee Ee Fe

309 2,800 3,109 ed

678 4,100 4,778

1,010 4,500 5,510

o: 6,700. 8,929

2,892 8,600 11,492

| | pee ES eR) * 086

3,320 8,700 12,020

3,230 9,727 12,957

3,344 9,270 12,614

3,331 9,923 13,254

3,833 “11,805 15,638

3,871 10,717 14,588

3,919 10,841 14,760

4,037 10,680 14,717

3,757 7,694 11,451

4,045 9,451 13,496

3,908 10,368 14,276

2,810 8,933 11,743

3,154 10,122 13,276

3,227 10,810 14,037

3,750 9,874 13,624

4,432 14,554 18,986

5,115 14,501 19,616

74,245 212,770 287,015

-CEIENT VISITS BY OFFICE

| GERMAN

YEAR EAST WEST NORTH OSU VILLAGE | LANCASTER

199] 16% 14% 7% 8% 55%

1992 15% 13% T% 9% 56%

1993 14% 14% 8% 8% 36%

1994 15% 11% 8% 9% 57%

1595 14% 15% 8% 11% 52%

1996 15% 11% 8% 12% 54%

se a eeopeey WEE SER) Te FX: i te ate

1997 21% 11% 2% | 16% 49%

1998 23% 11% NA 22% 44% >

a =]

1999 23% 13% NA 19% 45% a

2000 19% 3% 1% 25% 53%

a . — aie — =

2001 19% | NA 17% 23% 41%

2002 17% NA 29% 19% 34%

2003 17% NA 37% 18% 27% 96 clients |

* Lancaster Office Open May through December of 2003 - Served 96 Clients

[: “ REASON FOR HEALTH SERVICEVISIT .— E

YEAR TEST OR SUPPORT | MATERIAL AID OTHER [| TOTAL # —

< CLIENTS

199] 87% es OE | % 3833

1992 82% ae “3% | 3871

1993 87% 9% 4% 3919

| _—+1994_ 83% 10% ™% 4037

1995 83% 10% 7% 3757

1996 83% 10% ™% 4045

1997 - 87% 7% 6% | 3908 :

1998 84% 10% 6% | —~28i0

1999 83% 10% ™% ] 3154

2000 83% 12% - 5% 3227

2001 89% a ae 2% a ee

| __ 2002 78% 12% | 10% | 4432

77% 12% | us ‘| S115

"HEALTH SERVICES CLIENT DEMOGRAPHICS. — *« |

RACE | 2000 | 2001 | 2002] 2003 EDUCATION 2000 | 2001 | 2002 | 2003

White | 54% | 52% | 47% | 48% | <High School Grad. -=| 33% | 33% | 35% | 33%

. Black: | 39% | 42% | 41% |45% | High School Grador> “| 62% | 67% | 65% | 67%

~~ Other: . T™% | 6% | 8% | % etn a oe

INCOME MARITAL STATUS

oe Single = = ‘| 78% | 82% | 76% | 83%

“Dependent | 24% | 32% | 30% | 30% Married 17™% | 18% | 16% | 17%

< $10,000 | 26% | 29% [20% | 28% : ie

"> $10,000 | 34% | 35% |35% |34% | AVERAGE AGE _ 224 | 225 | 22.7 | 229

e wee oe 2083 HEARTS CHANGED/ | LIVES. SAVED ee z

ge * HEALTH SERVICES OFFICES-CRISIS INTERVENTION wt om

== DESCRIPTION ~ 1999 2000- | 2001 | 2002 2003

# of clients seen 3154 3227 2997 3883 3918

# of pregnancy tests performed 2707 2686 2452 2910 2805

Ab-minded or und before test 590/22 | 662/25 722/29 | 882/30 | 1090/39

Abort/Und before test who tested + 271 365 315 402 501

*PDHC had 4 offices in 1997,1998, 1999, 3 offices in 2000, 4 offices in 2001 & 2002, and 5 in 2003.

MEDICAL CLINIC CRISIS INTERVENTION gee iny

.._. ‘DESCRIPTION: 1999 | 2000 2001 2002 2003

# of days clinic open 40/77% 45/85% 77/92% | 144/91% 159/88%

# of clients scheduled 412 672 661 1027 1034

No shows 216 /52% 348/52% 347/52% | 458 /45% 532/51%

Clients seen 182 /44% 324/48% 317/48% | 549/53% 502/49%

Decision after follow-up

“| will parent” 78 [43% 141/44% 168/54% 265/48% 231/46%

“| will make adoption plan” 1 /0% 6/2% 6/2% 3/1% 6/1%

“Undecided/considering 14 18% 52/16% 16/5% 97/18% 25/5%

other options” :

Still planning to abort 20 /11% 33/10% 46/15% 62/11% 42/8%

Miscarried/not pregnant 9 /5% 14/4% 10/3% 28/5% 20/4% ul

Not reachable 60 /33% 82/25% 68/22% 96/17% 183/36%

| HOTLINE CRISIS INTERVENTION

DESCRIPTION 1999 2000 2001 --| 2002 2003

Total # of Calls 10,066 10,810 9.874 14,554 14,501

Total # of Client Calis* 7,983 8,469 7,282 10,679 12,556

Total # of New Contact Calis** 4,439 4,327 3,778 5,761 5,811

Leith

VERVIEW STAT

Services 2001 2002 2003

Clients seen-Client Offices 3188 2997 3883 3918

Pregnancy tests 3071 2452 2907 2805

Abortion vulnerable before test 599 722 847 1090 _

Still Abort. Vul. after 307 255 310 346

counseling

Pregnant clients making 10 il 10 4

adcption plaa

Clients affiliated with Christian — 1178 1719 2460 2104

church

Clients reporting past abortions | 386/12% | 441/15% 545/14% | 558/14%

Clients with unresolved 210/54% 234/53% 313/57% 308/55%

feelings/regret at

Clients seen at medical clinic 324 317 549 502

Still Abort. Vul. after follow-up 85/26% 62/19% 159/29% 67/13%

Hotline calls 10,201 9,874 14,554 | 14,501

Total client calls 7,282 8,723 10,858 12,556

Client calls from Yellow Pages 2,690 2,281 1,862 1,850

Client calls from TV, Radio, & 1,357 913/70/98=

Billboard | ce eae a 1,081

Abortion Related Calls aa 1997 1961 "7 2,524 3,177

"Life Decisions — i Se 357 453

"Spiritual Discussion me “| 821 1,804 2,045

Shared Christ 187 475

Clients who Accepted Christ 54

Maternity clothes clients 137 152 - im ae

Baby layettes provided | 227 201 283 327

HLE.A.R.T. (Post-Abortion 58 71 | 48 45

Healing)

Students served in abstinence — 8.242 10,005 10,681 14,371

programs (school year) i

Teachers served 622 859

Schools Served 42 62 56

| Volunteers 300 — 320 260 286 a4

Dollar vaiue of volunteer hours | $204,354 $223,963 $170,573 $135,709

Dollar value of staff donated $45,269 $ 58,121 82,932

hours

TOTAL 218,641

09 ‘ddy

App. 59

_ Other PDHC Programs at:a Glance

Program 1999 2000 2001 2002 | 2003

materi 6 167 238 201 283 327

# of Clients Receiving a Baby Layette

# of Clients Receiving Maternity Clothes 160 143 137 259 323

H.E.A.R.T.(Post Abortion Recovery Workshops)

# of Workshops Held 7 15 17 13 8

# of Women Attending a Workshop 30 65 m1 48 45

Healthy Choices Abstinence Program

/99 (3 mos.) _ 1999/2000 school yr. 2000 2001 2002 2003

Students served } 939 8428 8242 10,005 10,681 11,946

Total encounters 23,273 29,925 20,556 65,003 59,730

Average # of 2.76 3.63 pF 6.09 5

encounters

Teachers 51 460 622 859

School systems 2 4 8 14 13 16

Total Middle Schools 3 4 7 13 20 27

Total High Schools 2 k 14 21 22 25

| Elementary Schools 6 6 - 0 0

Other ae 15 2 2

Private Schools | 2 8 2 2

Total Students served 2002/2003 School Year -- 14,371

App. 61

PREGNANCY DECISION

HEALTH CENTERS

BOARD REPORT

3rd Quarter 2004

Presented to the Board of Directors

i PDHC OVERVIEW STATISTICS

SERVICES 2003 1* Qtr 2* Ot 3° Ot

Totals 2004

Client visits-Client Offices 3918 1129 1199 1195

ancy test 2805 677 726 727

vuinerable clients 1090 426 462 449

Birth Control Failures 360 345 392

Abstinence Counseling 414 428 426

Still Abort. Bul. After counseling _ 346 150 162 192

clients making adoption 14 4 4 1

Clients affiliated with Christian 2104 571 560 534

church

Clients reporting past abortions 558/14% | 135 138 104

Clients with unresolved 308/55% | 87/61% | 89/65% | 51/77%

feeli at ,

Clients seen at medical clinic 502 154 146 102

Still Abort. Vul. After follow-up 67/13% 17/11% | 16/11% | 25/25%

Hotline calls 14,501 3765 3692 3860

Total client calls 12,556 3158 3167 3352

calls from Yellow P: 1,850 523/17% |553/17.5%)j621/18.5

ient calls from 7 V, Radio, & 913/70/98=1 75 72 54

Billboard ,081

JAbortion Related Calts 3,177 815/26% | 699/22% | 761/23%

\Life Decisions 453 165 118 86

App. 63

[LOGO]

The Ministry of Care Net

Care Net is one of the largest pro-life organizations in the

evangelical network of pregnancy centers in North Amer-

ica, helping to save_over-100,000 babies from abortion each

year, Care Net represents about 2,400 paid staff, 5,000

board members and over 450,000 volunteers. This team of

dedicated Christians is ministering to over 250,000 young

women who come to the centers each year, struggling with

the fear of being pregnant and alone.

Care Net has been promoting, equipping and developing

pregnancy centers for over twenty years. We support over

800 pregnancy centers across the United States and

Canada.

Care Net’s pregnancy centers are building a culture of life

in this nation in three primary areas:

e Prevention —_—__--

e Intervention

e Reconciliation

Prevention

Committed pregnancy center staff and volunteers pre-

sented the message of sexual abstinence to over 800,000

students in classrooms and civic organizations across

North America in 2003. In addition, the individual clients

of pregnancy centers received lifestyle counseling, empha-

sizing the importance of sexual abstinence until marriage.

Pregnancy center volunteers engage in honest dialogue,

encouraging their clients to recognize their self-value and

make a plan for purity in their lives.

App. 64

Intervention

For more than twenty-eight years, Care Net has assisted

hundreds of pregnancy centers in becoming life-protecting

shelters of hope to women trapped in the despair of an

unplanned pregnancy. Life affirming options such as

parenting and adoption are presented with care and

compassion to women, men and families in need. Tangible

helps such as material assistance and limited medical care

are offered to the financially challenged. Care Net’s

pregnancy centers provide educational classes on child-

birth and parenting. Many pregnancy centers also offer job

skills training by way of computer classes. All the services

provided by Care Net’s pregnancy centers are free and

confidential. Pregnancy centers are impacting our nation

for good.

Reconciliation

Beneath the patina of reproductive rights lies three

generations of women, men and families that have suf-

fered the emotional trauma of a past abortion. Approxi-

mately 3,750 abortions occur daily in this country. Of this

number, 43% of these abortions are sought by women who

identify themselves as Protestant and 27% from women

who are Catholic. Women who identify themselves as

Christians obtain two-thirds of the abortions in America.

Equipping pregnancy centers to minister effectively in the

area of post-abortion recovery is a primary mission of Care

Net. In the words of many women and men who have

sought relief from the aftermath of abortion,

“No one ever told me I would feel this way.”

App. 65

Four hundred and fifty-four Care Net pregnancy centers

offer recovery support groups to women and men who have

experienced the trauma of a past abortion. Care Net has

produced vital post-abortion resources, leadership training

and cutting edge information for our network of pregnancy

centers to utilize with their clients, and cultivate the

emotional healing desired after an abortion occurs.

In 2004, 101,000 women and 2,710 men participated in

Care Net pregnancy cénter post-abortion counseling and

education support groups in this nation. Women and men

experiencing post-abortion grief report an increase in

alcohol and drug use, episodes of crying, nightmares, or

anger with those involved with the abortion. The last

stage of grief is acceptance.

Post-abortion counseling and education support groups

enable women and men to restore the value of their

children who were lost to abortion. Through post-abortion

support groups, women and men experience forgiveness,

expressing gratitude for a safe environment in which they

can express their grief.

As of March 19, 2003, Care Net’s affiliates have responded

to at least one survey in the past year. Of the affiliated

organizations that have responded to our surveys, 75%

indicated that they had a post-abortion support group for

women.

Care Net Programs

The Option line

The Option Line call center is operated and managed by

Care Net and Heartbeat International. It is our newest

effort to provide women in crisis with real help 24 hours a

App. 66

day, seven days a week. The Option Line is serving 3,500

women each month. Six out of ten women who call this

help line are considering abortion.

The Option Line provides:

« 24/7 phone coverage

* Bilingual consultants

« Computerized center locator system

= Calls patched through to nearest conter

The Urban Initiative

Care Net is planting new pregnancy centers in urban

areas where abortion clinics greatly outnumber pregnancy

centers. African American and Hispanic women represent

only 25% of the population, yet they receive 57% of all

abortions. Women deserve more than just one choice.

Ultrasound Legislation

Care Net continues to lobby congress to pass the Informed

Choice Act, a bill that will enable pregnancy centers to

receive grants for ultrasound machines. Seven out of ten

abortion-minded women who see an ultrasound choose life

for their unborn children. Last year, Care Net conducted a

poll of women and found that 87% of women see ultra-

sound access as very important.

Multi-Media Campaign

Billboards

In 2003, Care Net placed over 6,000 billboards across the

country. Our billboard campaign is in its 8th year of

App. 67

operation. Thirteen percent of women calling the Option

Line do so after seeing a billboard.

TV Commercial

In 2003, Care Net produced a quality 30-second TV com-

mercial and is currently airing it on MTV, Lifetime, E-

Entertainment, BET, and Oxygen.

Yellow Pages

The majority of the 35% of women calling the Option Line

call center do so after seeing an ad in the Yellow Pages,

making it the best performing of all media in which to

advertise. In 2003, Care Net will place 30 ads in metro

areas across the U.S.

Care Net Publications

Center of Tomorrow Journal

Care Net’s new quarterly journal with in-depth research

on emerging programs and services for pregnancy centers.

Care Net Report

Care Net’s flagship publication, currently in its fifth year

of circulation.

Serving With Care and Integrity

Care Net’s new volunteer training manual.

App. 68

Sanctity of Human Life Sunday

Care Net’s annual brochure, jointly published with Front-

lines.

History of Care Net

Care Net actually began as the Christian Action Council,

in 1976. Dr. Harold O. J. Brown founded this organization,

with the counsel and encouragement of Rev. Billy Graham

and the late Francis A Shaeffer. The first pregnancy center

was started in Baltimore in 1980; since then, the number

of Care Net pregnancy centers has grown to over 800. Care

Net was founded to make up for the consistent failure of

political and legal efforts to restore protection to the

unborn.

App. 62

Description 1" Qtr 2° Qtr | 3° Qt | 4° Qr 2003 2002

Totals Totals

Religious Affilitation #reporting | #reporting| #reporting | #reportin 2002

* None 216 265 209 211 901] 994/26%

* Non-Christian Religion 35 47 44 33 159] 184/5%

* Christian 508 556 578 462 2104} 2460/63%

Spiritual Interaction & Resources Given

Opportunity to share Christ cae. 56 84 34 343 187

General Spiritual Discussion * 388 504 516 154 2045 1804

Client Accepted Christ 7 10 7 8 32 27

Unsure if client accepted Christ 53

Client already a Christian 172 293 ry 1127

Church Referrals Given Od 104 112 103 417 437

*couldn't find this stat in Access

Past Abortions

#/%Clients Reporting Past

Abortion(s} 166/16% | 168/16% | 118/14% | 106/12% | 558/20% 545

%reporting unresolved feelings or

regret 70/48% 85/52% | 77/54% | 76/72% | 308/55% | 313/57%

#/%requesting contact about

HEART (interest) 80/55% 79/46% | 56/40% | 49/46% | 264/47% | 169/34%

Material Aid/Service

Layettes 73 91 77 86 327 283

Maternity Clothes 59 85 86 93 323 259

Preg. Verification 49 49 72 70 240 150

Walk-ins 498 516 557 410 1981 2179

Appts. Made from Hotline 611 2367

Appointments 344 463 470 482 1759 1498

New Clients 551 608 738 536 2433 |2092/54%

Previous Clients 288 372 385 416 1461 |1603/41%

Demographics

Single 639 748 639 398 2424 3023

Married 139 131 147 96 513 669

Black 329 412 357 278 1376 1575

White 343 398 397 347 1485 1796

Other 61 81 65 20 227 291

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.