"On April 18, 1998 at approximately 7 a.m., I witnessed a patient deliver an intact fetus in the toilet of a bathroom in the waiting room area. After expelling the baby and the afterbirth, the patient walked to the operating room because there are no wheelchairs. I opened the fetal sac so that the fetus could be weighed. The weight was approximately 3029 grams. It was a very big fetus. My impression is that at Midtown Hospital a procedure will be done at any gestational age as long as the patient has the money."

-Affidavit of Employee B, a certified surgical technician and a former employee of Midtown Hospital. (May 20, 1998)

"I witnessed patients frequently expelling fetuses on the floor and in the toilet. It happened frequently throughout each day the abortion procedures were done at Midtown Hospital which are Tuesday, Thursdays, Fridays and Saturdays. This problem was especially prevalent on Fridays and Saturdays because the facility was crowded with more patients than we could handle."

-Affidavit of Employee B, a certified surgical technician and a former employee of Midtown Hospital. (May 20, 1998)

"I never saw the doctors or the anesthesiologist do any pre-operative work-ups on the patients prior to the patients going into the operating room. The doors to the surgery area are always open. Sterilization standards are not followed. On one occasion when I was cleaning a speculum, I took it apart to clean it and was told by the operating room supervisor not to take the instrument apart."

-Affidavit of Employee B, a certified surgical technician and a former employee of Midtown Hospital. (May 20, 1998)

"When I worked at another abortion clinic, it took two days to complete the procedure for second trimester abortions. The patients underwent laminas insertions and stayed in the hospital overnight with either a nurse or a tech. The staff who stayed with the patients would examine the cervix. The patients were also attached to a fetal monitor so their contractions, not the heartbeat, could be monitored. When the contractions were close enough, the patients were taken to the operating room. At Midtown Hospital none of these precautions are taken. Women are allowed to expel fetuses whenever and wherever with no concern for the patient. When I would attempt to comfort the women, I was that told this was not my job."

-Affidavit of Employee B, a certified surgical technician and a former employee of Midtown Hospital. (May 20, 1998)

"I observed that the chairs in the pre-op area where the patients sat are not clean. The patients are told to bring their own sanitary pads. Most women lay on the floor in the pre-op area. Once I attempted to get some sterile sheets for the patients to lay on and was told by the operating room supervisor that if 'they can lay up and get pregnant then they can come in here and deal with the procedure.’"

-Affidavit of Employee B, a certified surgical technician and a former employee of Midtown Hospital. (May 20, 1998)

"The head, extremities and cord of a fetus were observed in the biohazard area. The fetus had hair and fully formed fingernails and was in a clear, plastic, ziplock bag. The bag containing the fetus lacked a label or other identifying information, making it impossible to validate the age of the fetus in correlation with the patient's medical record. A staff member stated that the fetus was about 26 weeks old and that sometimes the fetuses were much larger and older."

-Affidavit of Rosemary Wilder, a nurse surveyor for the Healthcare Section of the Office of Regulatory Services. (Feb. 19, 1998)

"The facility did not have a hopper and were pouring bloody secretions down the decontamination sink, where instruments were being washed. The sink was red-stained."

-Affidavit of Rosemary Wilder, a nurse surveyor for the Healthcare Section of the Office of Regulatory Services. (Feb. 19, 1998)

"The physician and surgical technician did not wash or scrub their hands before or between cases."

-Affidavit of Rosemary Wilder, a nurse surveyor for the Healthcare Section of the Office of Regulatory Services. (April 6, 1998)

"The facility did not monitor patients in the pre-operative room that had received Pitocin and Cytotec. The combination of these medications induces labor and results in spontaneous abortion. I saw patients experiencing extreme pain. I observed patients in obvious distress and they were not attended to by staff."

-Affidavit of Rosemary Wilder, a nurse surveyor for the Healthcare Section of the Office of Regulatory Services. (April 6, 1998)

"The facility lacked the ability to monitor and recover more than one patient at a time."

-Affidavit of Rosemary Wilder, a nurse surveyor for the Healthcare Section of the Office of Regulatory Services. (April 6, 1998)

"The facility did not have policies for cardiopulmonary resuscitation."

-Affidavit of Rosemary Wilder, a nurse surveyor for the Healthcare Section of the Office of Regulatory Services. (April 6, 1998)

"The facility is dirtier than it was at the time of my last on-site observation. There was enough dirt and debris to scoop up with my hands in various places in the facility."

-Affidavit of Rosemary Wilder, a nurse surveyor for the Healthcare Section of the Office of Regulatory Services. (May 14, 1998)

"The facility lacked documentation that the certified registered nurse anesthetists are qualified to work in that capacity."

-Affidavit of Rosemary Wilder, a nurse surveyor for the Healthcare Section of the Office of Regulatory Services. (May 14, 1998)

"The crash cart did not contain emergency medications as required by the policy of the facility including Dantrium, iced normal saline and Pronestyl."

-Affidavit of Rosemary Wilder, a nurse surveyor for the Healthcare Section of the Office of Regulatory Services. (May 14, 1998)

"The ultrasound room was heated by a space heater placed on top of a desk."

-Affidavit of Peggy Quattlebaum, a nurse surveyor for the Healthcare Section of the Office of Regulatory Services. (Feb. 19, 1998)

"Medical records for patients were inconsistent and lacking in standard information. The medical information of a patient that according to staff delivered a fetus in the commode, stated that the patient delivered fetus and placenta in the recovery room."

-Affidavit of Peggy Quattlebaum, a nurse surveyor for the Healthcare Section of the Office of Regulatory Services. (Feb. 19, 1998)

"Upon entering the surgical area, I observed a portable stereo outside the operating room. The volume on the stereo was extremely loud. Staff located in the surgical area and portions of the hallway would not be able to hear requests for assistance or cries from patients in distress."

-Affidavit of Peggy Quattlebaum, a nurse surveyor for the Healthcare Section of the Office of Regulatory Services. (April 6, 1998)

"I observed that little or no effort had been given to correcting the housekeeping and maintenance conditions that had been cited before. I went into the ladies bathroom in the main waiting room area and I observed brown covered stains splattered on the wall behind the commode. There was no soap in the bathroom and there was not a faucet handle on the hot water tap. The cleaning schedule indicated that the bathroom had not been cleaned since Feb. 10, 1998..."

-Affidavit of Peggy Quattlebaum, a nurse surveyor for the Healthcare Section of the Office of Regulatory Services. (May 14, 1998)

"The facility...through its failure to adequately document medical records, repeated delays in providing access to inspect the facility, retention of apparently unqualified personnel and failure to correct deficiencies that have been repeatedly cited, demonstrates to me that it is not able to provide appropriate patient care. The facility is a health hazard to patients."

-Affidavit of Peggy Quattlebaum, a nurse surveyor for the Healthcare Section of the Office of Regulatory Services. (May 20, 1998)