Original Petition and Request for Declaratory Judgment Page 1 and Ultra Vires Finding, and Application for Temporary Restraining Order And/Or Anti-Suit Injunction
8/31/2021 11:59 PM Velva L. Price District Clerk Travis County D-1-GN-21-004504 CAUSE NO.D-1-GN-21-004504 ____________________ Ruben Tamez LILITH FUND FOR § In the District Court of REPRODUCTIVE EQUITY, INC., § § Plaintiff, § Travis County, Texas § v. § § Judicial District 53RD____ STATE OF TEXAS; GREGORY § ABBOTT, in His Official Capacity as § Governor of the State of Texas; § KEN PAXTON, in His Official § Capacity as Attorney General of the § State of Texas; STATE SENATORS § BRYAN HUGHES, § PAUL BETTENCOURT, § BRIAN BIRDWELL, § DAWN BUCKINGHAM, § DONNA CAMPBELL, § BRANDON CREIGHTON, § BOB HALL, KELLY HANCOCK, § JOAN HUFFMAN, § LOIS KOLKHORST, § EDDIE LUCIO, JANE NELSON, § ANGELA PAXTON, § CHARLES PERRY, § CHARLES SCHWERTNER, § DREW SPRINGER, and § LARRY TAYLOR, in Their Official § Capacities as a Texas State Senators; § STATE REPRESENTATIVES § SHELBY SLAWSON, § DUSTIN BURROWS, § BRISCOE CAIN, § STEPHANIE KLICK, and § JEFF LEACH, in Their Official § Capacities as a Representatives in the § Texas House of Representatives; § TEXAS RIGHT TO LIFE, an § organization; and JOHN SEAGO, § and JOHN DOES 1-10, § § Defendants. § § PLAINTIFF’S ORIGINAL PETITION AND REQUEST FOR DECLARATORY JUDGMENT PAGE 1 AND ULTRA VIRES FINDING, AND APPLICATION FOR TEMPORARY RESTRAINING ORDER AND/OR ANTI-SUIT INJUNCTION PLAINTIFF’S ORIGINAL PETITION AND REQUEST FOR DECLARATORY JUDGMENT AND ULTRA VIRES FINDING, AND APPLICATION FOR TEMPORARY RESTRAINING ORDER AND/OR ANTI-SUIT INJUNCTION Abortion funds provide resources, financial assistance, emotional support, case management, advocacy and education, in support of their missions to provide non-judgmental, compassionate care to people in need of an abortion in Texas. Integral to their purpose is to foster reproductive justice, which includes removing barriers to abortion access through community education.
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