November 9, 2017
By email: AGO@state.ma.us
The Honorable Maura Healey
Attorney General of Massachusetts
One Ashburton Place
Boston, Massachusetts 02108-1518
Re:

Complaint Against Attleboro Women’s Health Center/Abundant Hope
Pregnancy Resource Center

Dear Attorney General Healey:
Campaign for Accountability (“CfA”) respectfully requests that you investigate the Attleboro
Women’s Health Center and/or Abundant Hope Pregnancy Resource Center for engaging in
deceptive business practices in violation of Massachusetts law.
Background
In 2010, the Attleboro Women’s Center filed articles of incorporation with the Secretary of the
Commonwealth of Massachusetts.1 According to the articles of incorporation, the organization’s
purpose was to “care for women, children and all others adversely impacted by an unplanned
pregnancy, especially those considering abortion” and to “mobilize all in our greater Attleboro
community to provide a Christian response to abortion and those suffering and at risk.”2 In 2011,
amended articles of incorporation were filed to change the name of the organization to Abundant
Hope Pregnancy Resource Center (“Abundant Hope”),3 and in 2014, a certificate of change of
principal address was filed to reflect the organization’s move to 182 East Street, Attleboro,
Massachusetts.4 All annual reports and other corporate filings since that time have been filed
under the East Street address and the name Abundant Hope.5
Abundant Hope is “a Christian pro-life ministry” that is “sustained by the Church community
and individuals who have a passion to save the life of the unborn.”6 It “exists to share the love of
Christ and to offer free services to educate women on their pregnancy options.”7 It is an affiliate
of Heartbeat International, a network of crisis pregnancy centers that instructs its affiliates to
1

Articles of Incorporation of the Attleboro Women’s Center, Inc., filed July 2, 2010.
Id.
3
Articles of Amendment of the Attleboro Women’s Center, Inc., filed Jan. 25, 2011.
4
Certificate of Change of Principal Address of Abundant Hope Pregnancy Resource Center, Inc., filed Sept. 30,
2014.
5
See e.g. Annual Report of Abundant Hope Pregnancy Resource Center, Inc., filed Nov. 8, 2016.
6
https://ahprc.org/about-us/.
7
Id.
2

611 Pennsylvania Ave., S.E.  #337  •  Washington, D.C. 20003  •  (202) 780-5750 
campaignforaccountability.org 

 Honorable Maura Healy
November 9, 2017
Page 2
“hide their anti-abortion motives by giving their centers neutral-seeming names…, situating them
near abortion clinics, and scrubbing their Christian beliefs from their websites.”8 During the
hours of 9 a.m. to 3 p.m. Monday, Tuesday, and Thursday,9 Abundant Hope provides pregnant
women with “lab-quality pregnancy tests, options counseling, material resources, community
referrals and a pro-woman, prolife message.”10 Abundant Hope continues to operate at 182 East
Street.11
Earlier this year, a website was created for an organization called the Attleboro Women’s Health
Center, 12 and last month, a green awning was installed at 182 East Street with the words
“Attleboro Women’s Health Center.”13 The Center shares its address with Abundant Hope,14 has
the same business hours, and the websites for both organizations are registered to Darlene
Howard, Abundant Hope’s executive director.15 According to a Center employee, Attleboro
Women’s Health Center operates under the same “umbrella” as Abundant Hope.16 Attleboro
Women’s Health Center’s stated mission is to “empower women to make informed decisions
about an unplanned pregnancy” and “provide[] quality, safe, accessible reproductive
healthcare.”17
Attleboro Women’s Health Center’s website offers a pregnancy quiz, a description of medication
and surgical abortion procedures, pricing information for such procedures, and a form by which
to make an appointment.18 At the appointment, the website says, a counselor will “provide
information about the abortion options that may be available to you at this point in your
pregnancy and answer any questions you may have about the abortion pill or surgical
abortion.”19 It further states that the price of an abortion can range from $420-$3500, that a
number of factors influence the cost, and that a visitor should make an appointment to “discuss
your individual situation.”20 In sum, “[i]f you’re pregnant and wondering how can I [sic] get an
8

Amy Littlefield, Massachusetts Fake Clinic Unveils New Way to Trick Those Seeking Abortion Care, Rewire, Oct.
24, 2017, available at https://rewire.news/article/2017/10/24/massachusetts-fake-clinic-unveils-new-way-trickseeking-abortion-care/; Meaghan Winter, Why Are Crisis Pregnancy Centers Not Illegal?, Slate, June 17, 2015,
available at
http://www.slate.com/articles/double_x/doublex/2015/06/crisis_pregnancy_centers_three_legal_strategies_for_bring
ing_them_down.html.
9
https://ahprc.org/contact-us/.
10
https://ahprc.org.
11
Id.
12
As of late last year, there was no website for the Attleboro Women’s Health Center. See http://awhc.net/ (Oct. 2,
2016), retrieved from https://web.archive.org/web/20161002092433/http://awhc.net/. However, by June of this year,
a website had been created. See Attleboro Women’s Health Center Home Page (June 10, 2017), retrieved from
https://web.archive.org/web/20170610122939/http://awhc.net/.
13
Littlefield, Rewire, Oct. 24, 2017.
14
https://awhc.net/contact-us/.
15
https://whois.icann.org/en/lookup?name=awhc.net; https://whois.icann.org/en/lookup?name=ahprc.org.
16
Littlefield, Rewire, Oct. 24, 2017.
17
https://awhc.net.
18
https://awhc.net/free-online-pregnancy-test/; https://awhc.net/abortion-pill-ru-486/; https://awhc.net/abortion-helpattleboro-ma/; https://awhc.net/faqs/; https://awhc.net/contact-us/.
19
https://awhc.net.
20
https://awhc.net/faqs/.

 Honorable Maura Healy
November 9, 2017
Page 3
abortion, visit Attleboro Women’s Health Center.”21 Only by navigating to the website’s
“About” page and scrolling to the bottom is it possible to learn that the Attleboro Women’s
Health Center does not “offer, recommend or refer for abortions or abortifacients.”22 This refusal
to “offer, recommend or refer for abortions” seems incompatible with a promise to “discuss the
abortion methods that may be available” and provide “answers to any questions” a woman may
have. In addition to this inconsistency, however, the Attleboro Women’s Health Center website
is riddled with exaggerations and inaccuracies regarding abortion.
On the website’s pages for both “Abortion Pill” and “Surgical Abortion” is a paragraph entitled
“Psychological Risks.” According to the site, these “range from irritability, difficulty sleeping,
depression and even post-traumatic stress disorder.”23 Women who “have undergone an abortion,
and are experiencing any unusual feelings or symptoms,” are advised to contact the Center to
speak with a “qualified Client Advocate.”24
Contrary to these assertions, the American Medical Association recently published a study
reporting that there is no evidence that abortion harms women’s mental health. In fact, the study
concluded that “being denied an abortion may be associated with greater risk” of “adverse
psychological outcomes.”25 An earlier study similarly concluded that “abortion was not a
statistically significant predictor of subsequent anxiety, mood, impulse-control, and eating
disorders or suicidal ideation.”26
Also on the Abortion Pill page is the italicized statement, “If you have only taken the first pill
and are regretting your decision, it may still be possible to save your pregnancy. Visit
abortionpillreversal.com or call 1-877-558-033327 right away to find the treatment center nearest
you.”28
In reality, the so-called abortion pill reversal process is based on a “study” of just seven women
who underwent an experimental treatment after taking the first of two pills that induce an
abortion.29 Notably, the study was conducted by two physicians who now serve as the Medical
Director and Research Director of Abortion Pill Reversal.30
21

https://awhc.net.
https://awhc.net/about/.
23
https://awhc.net/abortion-pill-ru-486/; https://awhc.net/abortion-help-attleboro-ma/.
24
Id.
25
M. Antonia Biggs, PhD, Ushma D. Upadhyay, PhD, MPH, Charles E. McCulloch, PhD, and Diana G. Foster,
PhD, Women’s Mental Health and Well-being 5 Years After Receiving or Being Denied an Abortion: A Prospective,
Longitudinal Cohort Study, 74 JAMA Psychiatry 169 (2017), available at
https://jamanetwork.com/journals/jamapsychiatry/article-abstract/2592320.
26
Julia R. Steinberg, Charles E. McCulloch, and Nancy E. Adlera, Abortion and Mental Health: Findings From the
National Comorbidity Survey-Replication, 123 Obstetrics and Gynecology 263 (2014), available at
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3929105/pdf/nihms-541175.pdf.
27
The phone number and website are associated with Abortion Pill Reversal, a program of Culture of Life Family
Services, located in San Diego, California.
28
https://awhc.net/abortion-pill-ru-486/.
29
Sofia Resnick, How a Falsehood Becomes a Law: Abortion Reversal as Case Study, Rewire, Mar. 21, 2017,
available at https://rewire.news/article/2017/03/21/falsehood-becomes-law-abortion-reversal-case-study/.
30
https://www.abortionpillreversal.com/page/7-About%20Our%20Team/.
22

 Honorable Maura Healy
November 9, 2017
Page 4
The so-called study’s findings have been roundly debunked. The American Congress of
Obstetricians and Gynecologists, for instance, says they “are not supported by the body of
scientific evidence, and this approach is not recommended in ACOG’s clinical guidance on
medication abortion.”31 A literature review by another group of physicians found that evidence is
insufficient to determine whether the abortion pill reversal treatment has any effect and,
moreover, that “[l]egislation requiring physicians to inform patients about abortion reversal
transforms an unproven therapy into law and represents legislative interference in the patient–
physician relationship.”32
Finally, the Attleboro Women’s Health Center is located less than a mile from Four Women
Health Services (“Four Women”), an actual abortion clinic that has been operating in Attleboro
since 2003.33 Four Women offers abortions, annual gynecological exams, birth control
information and prescriptions, STD testing, hormone therapy, ultrasounds, and other health
services.34 Its mission is to “empower women to make informed decisions that support their
privacy, dignity and self-respect.”35 Attleboro Women’s Health Center appears to have
appropriated this mission statement nearly verbatim on its recently created website, where the
Center explains it was “founded to empower women to make informed decisions about an
unplanned pregnancy that support their privacy, dignity and self-respect.”36
Violations of Massachusetts Law
Unfair and Deceptive Business Practices
Under Massachusetts law, it is unlawful to engage in “[u]nfair methods of competition and unfair
or deceptive acts or practices in the conduct of any trade or commerce.”37 If a person is found to
be in violation of the law, a court can restrain the person from continuing to engage in such
activity, impose “a civil penalty of not more than five thousand dollars for each such violation,”
and require the person “to pay the reasonable costs of investigation and litigation of such
violation, including reasonable attorneys’ fees.”38
Attleboro Women’s Health Center appears to have engaged in unfair and deceptive business
practices in a number of ways. First, it appears to be deliberately trying to confuse and deceive
31

American Congress of Obstetricians and Gynecologists, Medication Abortion Reversal, available at
https://www.acog.org/~/media/departments/state%20legislative%20activities/2015AZFactSheetMedicationAbortion
Reversalfinal.pdf.
32
Daniel Grossman, Kari White, Lisa Harris, Matthew Reeves, Paul D. Blumenthal, Beverly Winikoff, and David
A. Grimes, Continuing pregnancy after mifepristone and “reversal” of first-trimester medical abortion: a
systematic review, 92 Contraception 206 (2015), available at http://www.contraceptionjournal.org/article/S00107824(15)00226-7/pdf.
33
http://www.fourwomen.com/aboutfourwomen.php.
34
http://www.fourwomen.com/gynecologicalcare.php.
35
http://www.fourwomen.com/aboutfourwomen.php.
36
https://awhc.net/.
37
Mass. Gen. Laws Ch. 93A § 2(a).
38
Mass. Gen. Laws Ch. 93A § 4.

 Honorable Maura Healy
November 9, 2017
Page 5
consumers seeking abortion services. The Center opened less than a mile from Four Women – an
actual abortion clinic; its website claims that the Center provides “information about the abortion
options that may be available”; and in what would otherwise be a remarkable coincidence, it has
a mission statement nearly identical to that of the very abortion clinic situated nearby. In sum,
any consumers visiting the Center’s website undoubtedly would believe the Center provides
information about abortion services.
In addition, Attleboro Women’s Health Center deliberately provides false medical information
about abortion on its website, where it states that abortion causes mental health problems and
that medication abortions can be reversed. Thus, it appears the Center is intentionally attempting
to deceive women about the risks of abortion in an effort to dissuade them from seeking
abortions.
Finally, Attleboro Women’s Health Center may be engaging in unfair and deceptive acts by
insufficiently separating itself and its operation from that of Abundant Hope, with which it
shares an address, business hours, and a website registrar. Attleboro Women’s Health Center
promises to provide full and accurate information regarding abortion services while operating
under the umbrella of Abundant Hope, an unabashedly pro-life organization that promotes
“abstinence/sexual integrity” and seeks to save “the life of the unborn.” The alleged divergent
missions of Attleboro Women’s Health Center and Abundant Hope, combined with their
overlapping operations, further suggests there is a purposeful attempt to confuse consumers,
which may constitute unfair and deceptive business practices.
Untrue and Misleading Advertisements
Massachusetts law prohibits a person from placing an advertisement regarding a service “with
intent to sell or in any way dispose of” that service that “contains any assertion, representation or
statement of fact which is untrue, deceptive, or misleading.”39 A violation of the prohibition on
untrue, deceptive, or misleading advertisements is punishable by “a fine of not less than one
thousand nor more than two thousand dollars.”40
By advertising that it provides information about abortion services, attempting to draw women in
so they can be persuaded not to seek abortions, and by providing false information about
abortion on its website, Attleboro Women’s Health Center is providing untrue and misleading
information about the services it leads consumers to believe it offers in apparent violation of the
law.

39
40

Mass. Gen. Laws Ch. 266 § 91.
Id.

 Honorable Maura Healy
November 9, 2017
Page 6
Advertising for Services with Intent Not to Provide the Services
Massachusetts law prohibits placing an advertisement offering to sell a service with the intent not
to sell the service.41 A violation of the law is punishable by “a fine of not less than five hundred
nor more than one thousand dollars or by imprisonment for not more than one year.”42
As detailed above, Attleboro Women’s Health Center’s website describes the methods of
abortion available to women, provides cost estimates for those methods, suggests that women
visit the clinic if they are seeking to obtain an abortion, and provides a portal for online
appointment requests. Therefore, the Center appears to be advertising abortion services that it
intends not to offer in apparent violation of the law.
Unauthorized Use of Corporate Name
To effect a name change, Massachusetts corporations are required to file amended articles of
incorporation.43 Abundant Hope appears to be operating as Attleboro Women’s Health Center,
yet does not appear to have filed an amendment to its articles of incorporation in apparent
violation of Massachusetts law.
Conclusion
Massachusetts law requires businesses to market services honestly and fairly, without attempting
to trick or deceive consumers. Those individuals seeking information about abortion services
and/or abortions, like consumers seeking any other services, have the right to expect that they
will not be victimized by dishonest and unfair business practices. Further, women seeking
information about abortion or seeking abortions may not file complaints with the Office of the
Attorney General after having been deceived by the Attleboro Women’s Health Center. As a
result, CfA respectfully requests that the Office of the Attorney General immediately initiate an
investigation into the business practices of the Attleboro Women’s Health Center and Abundant
Hope and hold them accountable for any violations of law. Thank you for your attention to this
matter.
Sincerely,

Katie O’Connor
Legal Counsel
Campaign for Accountability

41

Mass. Gen Laws Ch. 266 § 91A.
Id.
43
Mass. Gen. Laws Ch. 155 § 10.
42