EXHIBIT 23

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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.

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CIVIL ACTION

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

DECLARATION OF AMANDA BENNETT IN SUPPORT OF 

PLAINTIFFS’ MOTION FOR A PRELIMINARY INJUNCTION

AMANDA BENNETT, hereby declares under penalty of perjury that the following 

statements are true and correct:

1. I am a member of the non-hierarchical Board of Directors (“core member”) of the 

Bridge Collective—an Austin-based nonprofit organization that provides practical support to 

Texas residents who want to end a pregnancy but face practical and logistical difficulties accessing 

care.

2. Founded in 2012, Bridge Collective started as a team of full-spectrum doulas 

providing educational, emotional, and physical support to pregnant people seeking abortion, 

during childbirth, and soon after they gave birth. After Texas House Bill 2 shuttered abortion 

clinics across the state in 2014, client needs shifted. People did not need an abortion doula if they 

could not get to one of the few remaining in-state clinics. We accordingly shifted our focus and 

resources to supporting people seeking abortion care, specifically by providing rides. Today, we 

are an all-volunteer practical support collective providing information, rides, childcare, 

accommodation, and doula services to Texans seeking abortion care in the Austin-area.

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3. I first joined Bridge Collective as a volunteer in the spring of 2016; last summer, I 

became a core member. Over the years, I have served as an intake coordinator and volunteer 

providing rides, accommodation, and emotional support. I also help recruit and train volunteers. I 

regularly speak with volunteers about our clients’ needs concerning abortion access. I also speak 

directly with clients about their needs on a regular basis. In addition, I speak with other 

organizations providing financial and practical support to Texans seeking abortion care. 

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

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

Challenges Accessing Abortion Care in Texas

5. Bridge Collective operates a hotline and online intake system for people seeking 

assistance overcoming barriers to abortion care. Callers contact us and leave a message explaining 

their needs. An intake coordinator calls them back, usually within twenty-four hours. Currently, 

we have six intake coordinators who rotate daily. After identifying a caller’s needs, the intake 

coordinator reaches out to our network of forty active volunteers to inquire about whether they are 

available to assist the caller. If so, the intake coordinator connects the volunteer with the caller.

6. Unfortunately, we are not always able to find a volunteer to help, especially for 

callers seeking rides or childcare who live outside of Austin. Generally, our callers have abortion

appointments during work hours on weekdays, and it can be difficult to find available volunteers, 

most of whom also work during the day on weekdays. If we are unable to assist a caller, we do our 

best to connect them to another organization for assistance.

7. During the intake process, we assess the caller’s needs, including whether they have 

an appointment scheduled, and if so, where; how far along in their pregnancy they are; whether 

they need a ride and if so, how many; and whether the caller needs accommodations, and if so, for 

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how many nights. We also inquire about whether the caller needs financial assistance. Although 

we do not have the resources to provide money to our callers, we do our best to help callers secure 

funds from other organizations. Ultimately, we work closely with our callers to develop a plan for 

accessing abortion care. 

8. Our callers face many challenges to accessing abortion care in Texas. These 

challenges include lack of abortion providers, lack of access to reliable transportation, need for 

childcare, lack of emotional support for their abortion decision, an inability to take time off from 

work or school, and difficulty affording the cost of care. 

9. Texas requires most abortion patients to make at least two trips to obtain care, 

which exacerbates the barriers that people seeking abortion care in Texas face. For example, 

forcing people to make two trips requires some people to travel long distances to an abortion 

provider twice, which increases the cost of travel and makes it harder to secure transportation and 

childcare. Some people opt to stay in Austin overnight rather than make multiple long-distance

trips to a provider. That is not an option available to all clients, however. Some clients without 

childcare, for example, must return home to put their children to bed at night.

10. Delay can also make it harder for people to keep their pregnancies or abortion

confidential. Callers seek to keep their pregnancy confidential for a variety of reasons. For 

example, callers have sought to keep their pregnancy or abortion decision confidential from an 

abusive partner or parent. Some callers want to keep their pregnancy or abortion decision 

confidential because no one in their network supports their decision and they fear judgment or 

irreparable damage to their relationships with family or friends. 

11. It is not uncommon for our clients to miss an appointment or delay care because of 

difficulty overcoming barriers to care. 

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12. In 2019, over 314 Texans contacted Bridge Collective seeking assistance accessing 

abortion care. 

13. The vast majority of our callers request rides to and from appointments. We provide 

rides to people located within 100 miles of Austin, and occasionally have helped clients who live 

even farther away. We routinely travel to Killeen, which is 70 miles away, one way, where there 

is a military base. In 2019, our volunteers provided 205 rides.

14. Our volunteers also regularly provide accommodation at their homes for clients

who need a place to stay before or after their appointments, childcare during their appointments, 

company during their appointments, and emotional support during the rides to and from their 

appointments. We train all our volunteers to be supportive, non-judgmental listeners. 

Abortion Access in Texas Since the Executive Order 

15. The COVID-19 outbreak has impacted Texans’ day-to-day lives, including the 

lives of our callers. For example, a client who I recently provided a ride to lost her job after 

Governor Abbott’s stay-at-home order closed the restaurant at which she worked. 

16. The COVID-19 outbreak has also adversely impacted Bridge Collective’s ability 

to assist callers. For example, callers sometimes desire someone to accompany them to the clinic 

to provide emotional support, including while they are in the waiting room. Some callers must 

bring their children with them to the clinic and need someone to watch them during their 

appointment. Prior to the COVID-19 outbreak, our volunteers routinely accompanied clients to 

their appointments to provide emotional support, childcare, or both. Unfortunately, because of the 

need for COVID-19 related social distancing, we are unable to offer these services to our clients. 

Last month, I personally had to decline help to a caller who asked if someone could accompany 

her to her abortion appointment. 

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17. I understand that Texas has threatened to enforce an Executive Order by Governor 

Abbott as a ban on abortion care (the “Executive Order”), which has made abortion care virtually 

unavailable in Texas. 

18. Most callers are referred to us by an abortion clinic after they make their 

appointments, though sometimes callers find out about us from another source (e.g., another 

organization providing financial or practical support to Texans seeking abortion care or through 

an online search). As a result, the vast majority of our callers already have an abortion appointment 

when they contact us.

19. In March, prior to the Executive Order, thirteen people had contacted us seeking 

assistance. Since March 23, we have received only five calls, which is far less than we would 

normally expect to receive. I believe our caller volume has dramatically declined because the 

Executive Order caused most doctors in Texas to stop providing abortions. 

20. We referred two of the five callers since March 23 to other organizations for 

assistance because they were out of our service area (i.e., more than 100 miles from Austin). 

Because the Executive Order made most abortion care unavailable in Texas, one of those callers

was seeking to travel to Oklahoma to access care. 

21. Our volunteers attempted to help the other three callers obtain abortion care. 

Unfortunately, because of the Executive Order and related judicial decisions, each of their 

appointments was cancelled. To my knowledge, only one of these callers has been able to obtain 

an abortion to date.

22. One caller (who was driven by a volunteer to her state-manded pre-abortion 

appointment a week earlier) requested a ride to and from her medication abortion appointment.

The volunteer drove the caller from her home to the closest abortion clinic, which was in Austin—

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an approximately three-hour roundtrip drive. The caller had to make three appointments before 

she was able to obtain care—the first two appointments were cancelled because of the Executive 

Order and an interim court ruling. The client told us that she experienced a great deal of stress and 

anxiety throughout the process. She strongly desired an early abortion and the thought of having 

to delay her abortion to later in pregnancy was very upsetting to her. She preferred a medication 

abortion because, among other things, it felt more natural to her than a procedural abortion. In 

addition, because of COVID-19-related social distancing policies, her partner and child would not 

have been able to accompany her to a procedural abortion appointment. A medication abortion

would allow the caller to pass her pregnancy at home, surrounded by her loved ones.

23. The Executive Order gave rise to uncertainty about how, when, and even whether, 

the caller would obtain an abortion, which caused her a great deal of distress. The possibility that 

she might be delayed to a point at which she would no longer be able to obtain a medication 

abortion in Texas was very stressful for her. The Executive Order made the client feel like she was 

doing something wrong, which exacerbated her stress and anxiety. She described contending with 

these challenges as the “worst day of [her] life.” The client was ultimately able to obtain a

medication abortion. However, any additional delay would have pushed her past the gestational 

limit for obtaining a medication abortion in Texas.

24. Another caller who was eighteen weeks pregnant, as measured from the first day 

of the last menstrual period (“lmp”), called us seeking assistance accessing a dilation and 

evacuation abortion. The caller planned to travel from out of town to Austin and stay overnight 

at a hotel. She would be unable to drive herself to and from the clinic, however, because she 

would be sedated. She requested that we provide her rides between the clinic and her hotel. Her 

appointment was cancelled just after the Executive Order went into effect. After the court issued

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a temporary restraining order, she made a second appointment. Her second appointment was 

canceled after the court of appeals allowed the Executive Order to go back into effect. With 

assistance from another organization, the caller now plans to travel to New Mexico, where she 

has an appointment at an abortion clinic later this month. Traveling out of state to New Mexico 

has always been difficult for our callers, but it is even harder now due to COVID-19. For 

example, this caller worried about whether it is safe to travel to New Mexico, and she struggled 

to understand New Mexico’s rules concerning out-of-state travelers. 

25. Another caller who past the gestational limit for medication abortion in Texas

contacted us seeking a ride to an aspiration abortion appointment. Like many of our callers, her 

pregnancy was causing severe nausea. This happens so often that we ask every caller about it and 

recommend that our drivers keep nausea bags in their cars during the rides. Unfortunately, her 

March 25 appointment was cancelled due to the Executive Order. 

26. The Executive Order has significantly and adversely impacted our callers. It has 

created confusion, uncertainty, and unnecessary delay. It has forced our callers to stay pregnant 

when they do not want to be. It has exacerbated the stress of dealing with an unwanted pregnancy 

and seeking abortion care in Texas. 

Dated: April 15, 2020

/S/ Amanda Bennett

 Amanda Bennett

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