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>>/137584/, >>/137585/, >>/137587/ STATE OF MISSOURI ANDREW BAILEY, AG Plaintiff, v. PLANNED PARENTHOOD GREAT PLAINS, STATE OF MISSOURI IN THE CIRCUIT COURT OF BOONE COUNTY THIRTEENTH JUDICIAL CIRCUIT STATE OF MISSOURI THE STATE OF MISSOURI ex rel. ANDREW BAILEY, ATTORNEY GENERAL Plaintiff, v. PLANNED PARENTHOOD GREAT PLAINS, No. __ Defendant, STATE OF MISSOURI’S PETITION FOR DECLARATORY JUDGEMENT AND INJUNCTIVE RELIEF The State of Missouri, through Andrew Bailey in his official capacity as Attorney General of Missouri, hereby petitions this Court under section 188.250, RSMo, for injunctive relief against Planned Parenthood Great Plains for violation of the laws of Missouri regarding parental consent for minors traveling for interstate abortions. I. Introduction. 1. Planned Parenthood Great Plains has a long and troubling history of failing to comply with the law. 2. Perhaps most famously, in 2018, following at least a half-decade of health-code violations, Planned Parenthood’s facility in Columbia was shut down after staff admitted to having used moldy abortion equipment on women for months. [PG 1] cont... II. Conclusion & Relief Sought Plaintiff respectfully requests that this Court: a. Declare Petitioner has shown Defendant’s conduct: i. Is reasonably anticipated to occur in the future; and/or ii. Has occurred in the past, whether with the same minor or others, and that it is not unreasonable to expect that such conduct will be repeated; b. Enjoin Defendant and all its officers, staff, employees, and agents from engaging in the following conduct to or on behalf of minors with the intention of causing, aiding, or assisting said minors to obtain an abortion without the consent or consents required by section 188.028: i. Transporting minors to obtain an abortion in and outside of Missouri, or paying for such transportation; ii. Paying for abortions in whole or in part; iii. Lodging or housing minors, or paying for such lodging or housing; iv. Creating and sending or issuing doctor’s notes or excuses for minors to leave their schools or other educational programs; v. Directing, commissioning, contracting, coordinating or scheduling with persons, including for-profit or non-profit entities, to engage in any of the aforementioned conduct, i.e., payment, transportation, lodging or housing, or doctor’s notes or excuses for minors to leave their schools or other educational programs; vi. Referring minors for abortion https://ago.mo.gov/wp-content/uploads/2024-2-29-Missouri-v.-Planned-Parenthood-Petition-for-Injunctive-Relief.pdf