D-1-Gn-21-004303 126Th
8/25/2021 11:52 AM Velva L. Price District Clerk Travis County D-1-GN-21-004303 CAUSE NO. ____________________ D-1-GN-21-004303 Chloe Jimenez THE BRIDGE COLLECTIVE § In the District Court of § Plaintiff, § § Travis County, Texas v. § § STATE OF TEXAS; GREGORY § Judicial District 126TH____ 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; 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 This case is brought to vindicate and protect fundamental and constitutional rights. Plaintiff The Bridge Collective is an all-volunteer, consensus-based, non-hierarchical practical support network, which seeks to provide practical, responsive support for abortion services and reproductive resources for Central Texans. The Bridge Collective brings this lawsuit to protect itself, its member volunteers, and the Texans it seeks to assist from Texas Senate Bill 8, set to become law on September 1, 2021, from its blatant, unconstitutional, and invalid infringements on their individual rights, and respectfully shows the Court as follows I.
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