CHICAGO, February 7, 2013, (LifeSiteNews.com) – A scathing legal complaint levied against the Chicago Planned Parenthood that killed 24-year-old Tonya Reaves accuses its personnel of offering medical procedures they are “not properly qualified” to perform, delaying Reaves' emergency treatment until her death was inevitable, and displaying such indifference to her physical safety that it constituted the “abandonment of a patient.”

LifeSiteNews.com obtained a copy of the complaint filed today with the Illinois Department of Professional Regulation by Thomas Brejcha, president of the Thomas More Society in Chicago, on behalf of his client, the Pro-Life Action League.

Tonya Reaves died from a botched D&E (dilation and extraction) at the Loop Health Center Planned Parenthood on Friday, July 20 of last year after the abortionist perforated her uterus. Reaves languished for five-and-a-half hours before being transported to Northwestern Memorial Hospital.

Although Planned Parenthood may have known the cause of her heavy bleeding, there is no evidence it informed caregivers at the hospital. Instead, the hospital discovered the bleeding – perhaps more than one liter of blood in her abdominal cavity – nearly six hours after her arrival, too late to save her life.

Illinois state officials have a duty to investigate “to what extent, if any, [Planned Parenthood] did or did not provide this information to the ambulance and the hospital” and determine whether that inaction constitutes “an abandonment of this patient,” the complaint says.

At least three infractions of the state code may have taken place in Reaves' death and numerous other abortions offered at this facility, according to the letter.

The Planned Parenthood center may have been ill-equipped for the procedure, as its website at the time stated the Michigan Avenue location was “only open for birth control and EC [emergency contraception] pick up on Friday and Saturday.” That information was subsequently removed from the website.

Those beyond nine weeks of pregnancy, the website stated, would receive “a referral list.”

Reaves, who was 16 weeks pregnant at the time, underwent her abortion was at 11 a.m. Friday morning. 

(Story continues following graphic.)

The website's statements raises “serious questions about whether the Michigan Avenue facility 1) had the proper equipment to handle both the procedure Ms. Reaves underwent and any complications which might have arisen from the procedure; 2) had qualified personnel on the date of the abortion to safely complete a surgical abortion; and 3) whether this clinic continues to offer abortion services without the personnel, equipment, and facilities necessary to protect and preserve the life of women undergoing the surgery,” the complaint states.

The letter asks the state to investigate the abortionist personally, as well.

Click "like" if you want to end abortion!

If an abortionist reassured Reaves an “invasive” surgical procedure was safe in such an environment, she “may well have assumed responsibility for a procedure he or she was 'not properly qualified or competent to render' because of the inadequate setting in which the abortion was performed,” the complaint states.

Such a violation of the Medical Practice Act could be punished by revoking the physician's medical license and a fine of up to $10,000 per infraction.

The record seems to indicate the facility provided “care that appears to fall below the minimum standard of care mandated by Illinois for licensed physicians,” the complaint states, and officials must decide whether Planned Parenthood is “likely to injure additional people.”

Operation Rescue received a report that a second patient may have been injured the same day.

Today's complaint is the third legal action to be filed in the case of Reaves' tragic death. Her mother, Dorsey Johns, filed a separate lawsuit last August. Her surviving son and his father filed a second lawsuit in January. 

Read the whole complaint here.