EXHIBIT 27

Case 1:20-cv-00323-LY Document 89-8 Filed 04/18/20 Page 1 of 6
1

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

PLANNED PARENTHOOD CENTER FOR 

CHOICE; et al., 

Plaintiffs,

v.

GREG ABBOTT, in his official capacity as 

Governor; et al.,

Defendants.

)

)

)

)

)

)

)

)

)

)

)

CIVIL ACTION

CASE NO. 1:20-cv-323-LY

DECLARATION OF STEPHANIE GOMEZ IN SUPPORT OF 

PLAINTIFFS’ MOTION FOR A PRELIMINARY INJUNCTION

STEPHANIE GOMEZ hereby declares under penalty of perjury that the following 

statements are true and correct:

1. I am a member of the Board of Directors of Fund Texas Choice (“FTC”), a Texas 

nonprofit corporation that provides financial assistance to Texas residents who must travel to 

access abortion care to cover the cost of transportation and accommodations. Currently, FTC 

employs 2 staff members. Our statewide Board and small staff work intentionally and thoughtfully 

to help ensure abortion access for all Texans. 

2. As a Board member, I help shape FTC’s mission and direct its strategy based on 

our clients’ experiences. Along with the other Board members, I supervise FTC’s staff, which 

includes a program coordinator. I also serve as the Board’s Program Chair and Secretary. In that 

role, among other things, I am responsible for overseeing FTC’s programmatic work and 

supporting FTC’s program coordinator.

3. I provide the following testimony based on personal knowledge acquired through 

my service at FTC and review of the organization’s business records. 

Case 1:20-cv-00323-LY Document 89-8 Filed 04/18/20 Page 2 of 6
2

FTC Background

4. FTC’s clients primarily contact us through our online intake form. Some clients are 

referred to us from abortion providers or other organizations supporting Texas residents seeking 

abortion care. We accept intakes until we have exhausted our weekly budget. 

5. Every Thursday, we review caller requests for assistance and contact each caller to 

assess their needs and develop a plan for accessing care. FTC offers travel assistance to clients 

who already have appointments and covers one hundred percent of their travel costs. We pay for 

the cost of transportation (i.e., bus fare, gas money, rideshares, or airfare), as well as the cost of 

lodging. We also help clients schedule appointments if they do not already have one. If a client 

needs assistance to pay for their abortion, we help that client secure funding from another 

organization. 

6. It is not uncommon for a client to request assistance from multiple organizations to 

secure the financial and practical resources needed to access care. We regularly work with other 

organizations supporting Texas residents seeking abortion care.

7. In 2019, FTC assisted 289 Texas residents seeking abortion care.

The Impact of the Governor’s Executive Order on Texans Seeking Abortion Care

8. I understand that the State has threatened to enforce an Executive Order by 

Governor Abbott as a ban on abortion care (the “EO”), which made abortion care virtually 

unavailable in Texas. 

9. Because of COVID-19 and Governor Abbott’s stay-at-home Executive Order, 

clients now struggle with reduced job hours, layoffs, loss of childcare, and even greater difficulty 

traveling. For example, clients who lack a reliable car have even greater difficulty finding someone 

Case 1:20-cv-00323-LY Document 89-8 Filed 04/18/20 Page 3 of 6
3

in their network to drive them to appointments. Now more often than before, flights are delayed, 

which results in longer stays at the airport, or are cancelled, which can require multiple trips to the 

airport. In addition, clients who must travel out of state for care must contend with different states’

rules regarding out-of-state travelers, which can be confusing and make the experience more 

stressful. For example, although New Mexico requires out-of-state air travelers to self-isolate for 

a period and recommends that people traveling there by other means do so, it permits all out-ofstate travelers to leave their hotels to obtain medical care. 

10. Clients are also confused by Texas’ conflicting messages about COVID-19. On the 

one hand, Texas has told them to stay at home to avoid becoming infected by COVID-19. On the 

other hand, Texas is forcing them to leave the state to access abortion care that should be available 

in-state. It has been reported that the Texas Department of Safety is ramping up enforcement of 

the Governor’s proclamation requiring travelers from Louisiana to quarantine. One client driving 

back from Louisiana was stopped by the Department of Safety.

11. Clients traveling out of state also worry about becoming infected with COVID-19 

and exposing their family members, children, or housemates after returning home. 

12. The COVID-19 outbreak has also made it harder to find lodging for our clients 

because some hotels have limited their occupancy. 

13. In addition, some clients find it harder to keep their pregnancy or abortion decision 

confidential. One client sheltered at home with her abuser feared her partner would physically 

harm her if he discovered she was pregnant. 

14. As a result of the EO, the vast majority of our clients have been unable to access 

abortion care in Texas. With assistance from FTC, clients have or plan to travel to Arizona, 

Colorado, Kentucky, Louisiana, Mississippi, New Mexico, Oklahoma, and Virginia to access care. 

Case 1:20-cv-00323-LY Document 89-8 Filed 04/18/20 Page 4 of 6
4

Clients sometimes travel to states that are farther away if there is someone in their network there 

that will provide emotional support to them while they access care in an unfamiliar place. Our 

clients have limited financial means, and many have never left their communities or traveled by 

air; because of the EO, they are forced to do so for the first time during a global pandemic.

15. In February, we assisted 24 Texas residents access abortion care, most obtained 

care in-state. 

16. After the Governor issued the EO, FTC had to twice close intake because requests 

for assistance far exceeded our resources.

17. Since March 23, 44 Texas residents contacted us seeking assistance accessing 

abortion forced to travel out of state to access abortion care as a result of the EO. Twenty-nine

people were less than 11 weeks pregnant, as measured from the first day of their last menstrual 

period (lmp), and at least one had her appointment for medication abortion cancelled as a result of 

the EO; we very rarely help clients at this gestational age travel out of state for care. Fifteen of the 

clients we assisted go out of state for care were between 11-22 weeks lmp. We were able to assist 

37 of these clients. 

18. Not all clients are able to travel out of state to obtain care. One client who could 

not obtain an abortion in Texas as a result of the EO was too scared to travel by air or to drive by 

herself to obtain care. She did not have anyone in her network who would her over ten hours, oneway to the nearest out of state abortion clinic. She still has not obtained her abortion and feels 

forced to give birth. 

19. Until recently, our weekly budget was $1500. Last month, we increased our budget 

to $2500 to meet increased client need during the COVID-19 outbreak. For the last 2 weeks, we 

exceeded our weekly budget due to client need. 

Case 1:20-cv-00323-LY Document 89-8 Filed 04/18/20 Page 5 of 6
5

20. Even before the current public health crisis and the EO, Texas made abortion 

difficult to access. Abortion providers are scarce, and some patients must travel long distances to 

their appointments, usually more than once. The COVID-19 outbreak exacerbated existing barriers 

to care. Now, the EO banning most abortion care has put our clients in crisis mode. 

21. Forcing clients to remain pregnant when they do not want to be significantly and 

adversely impacts their physical and mental well-being and exacerbates the difficulties they face 

in the current public health crisis. 

Dated: April 16, 2020

/S/ Stephanie Gomez

STEPHANIE GOMEZ

Case 1:20-cv-00323-LY Document 89-8 Filed 04/18/20 Page 6 of 6