Pro-life group sends legal notices warning abortion groups of potential liability

A pro-life group has sent legal notices to four abortion referral or funding organizations, making them aware that sending abortion seekers to the Washington Surgi-Clinic in D.C. could result in lawsuits against them for "negligent referral."

The Details:

The notices, sent by the pro-life group Survivors of the Abortion Holocaust, detailed a "complaint and documented concerns," suggesting that referring and/or funding abortion clients to visit the D.C. facility might expose those organizations to a "lawsuit for negligent referral but may also form the basis of a large punitive damage award in the future."

The letters made clear:

Should anyone be referred to receive or obtain funding to receive the subpar care available at Washington Surgi-Clinic from this point forward after being formally put on notice, it would constitute a negligent referral, as referring physicians and agencies have been put on notice of possible subpar care occurring at the clinic.

Legal Notices Sent to Abortion Groups

The legal notices, obtained by Live Action News, were addressed to the National Abortion Federation (NAF), the DC Abortion Fund (DCAF), the Lilith Fund , and the National Network of Abortion Funds (NNAF).

Washington Surgi-Clinic's website, which is still operating at the time this article was written despite the lack of a license, reveals that it is a member of the NAF and partners with NNAF.

The legal notices, sent along with a copy of the formal complaint filed against Santangelo with the D.C. Board of Medicine, read in part:

DUTY OF CARE OF REFERRING AGENCIES AND PHYSICIANS.

It is clear that a referring agency to a healthcare provider has a duty of care to patients when choosing a physician or health care provider. A negligent referral occurs when a doctor’s failure to make a timely, appropriate referral to a specialist or a poorly chosen specialist, leads to harm or injury to the patient. This harm or injury could include a doctor’s misdiagnosis, underestimation of the seriousness of a condition, lack of knowledge, or failure to research a specialists qualifications.

It can also occur when a physician or referring agency knew or should have known the specialist was incompetent, unqualified, or unable to provide adequate care yet referred the patient anyway. To prove a claim, a patient must show the referring physician or referring agency’s lack of due diligence or knowledge of the referred physician’s ability to provide proper care. This can also form a basis of punitive or exemplary damages.

The notices added:

FACTS REGARDING THE WASHINGTON SURGI CLINIC WHICH REQUIRE...DUE DILIGENCE.

On August 18th, 2025, a 14-page complaint and documented concerns was formally submitted to the Board of Medicine in Washington, DC regarding the Washington SurgiClinic and the clinic’s current medical doctor, Dr. Cesare Santangelo.

This complaint 3 included 24 exhibits, many being direct evidence to the risk, danger, and liability Dr. Santangelo brings to patients by continuing to operate and practice. To summarize, it is known that Dr. Santangelo has neuropathy, wears a full arm cast on his right arm, has been observed to be disoriented at times, is unsteady on his feet, requires a personal caregiver for basic functioning such as walking, standing, and driving, and monitoring his falls and injuries.

The DC Board of Medicine (along with other entities) were also put on notice through the filing of these concerns and formal complaint and it was requested that they: 1) take immediate action by (at minimum) suspending the license of Dr. Santangelo and that of Washington Surgi Clinic, and 2) investigate this matter thoroughly to include but not limited to the suspected Unlicensed activity occurring at Washington Surgi Clinic and the physical and cognitive abilities of Dr. Santangelo. (A copy of this complaint is attached for your review).

Should anyone be referred to receive or obtain funding to receive the subpar care available at Washington Surgi-Clinic from this point forward after being formally put on notice, it would constitute a negligent referral, as referring physicians and agencies have been put on notice of possible subpar care occurring at the clinic.

On September 4, 2025, Live Action News conducted a search on the NAF website which revealed that despite the fact that the Washington Surgi-Clinic was not licensed, NAF was still referring abortion clients to the facility.

The legal notices claimed the abortion groups had "a duty to their clients to investigate and determine if Washington Surgi Clinic is following Standards of Care regarding late term induction abortions, umbilical cord transections (UCT’s), and dilation and evacuation (D&E) procedures for late term abortions," and "a duty to their clients to ensure Dr. Cesare Santangelo is competent and physically able to perform surgeries prior to referring any patient to Washington Surgi Clinic."

The legal notices also warned that "[f]ailure to perform such due diligence and a detailed investigation will not only expose [named organizations] to a lawsuit for negligent referral but may also form the basis of a large punitive damage award in the future."

It also noted that the organizations would "be unable to deny the possible inherently dangerous conditions that exist at the Washington Surgi Clinic" upon receipt of the letter, and instructed them to "investigate this matter fully and completely prior to referring any patients to this facility."

What are Legal Notices?

Medical malpractice attorney Mike Seibel previously explained to Live Action News the concept of filing a 'legal notice,' noting that these documents could be sent anytime an abortion business is operating outside the standard of care or is potentially placing its clients at risk.

If Big Abortion and those they collaborate with fail to take action to correct the problems, this could result in a "large punitive damage award,” Seibel claimed.

One of the best examples of a corporation being put ‘on notice’ for creating unreasonably dangerous conditions is that of the case against McDonald’s for knowingly keeping its coffee heated to temperatures with the potential to cause serious injury. Read those details here.

Background:

• Washington Surgi-Clinic, operated by abortionist Cesare Santangelo, has been entangled in multiple controversies.

• In August, Survivors filed a formal complaint against Santangelo, asserting that his practices fell outside the standard of care and endangered women; putting him and those aiding him on notice.

• Santangelo was previously recorded in an undercover Live Action investigation, stating that neither he nor his staff would provide assistance to an infant who survived abortion. In addition, the bodies of five nearly full-term aborted babies were found in medical waste obtained from his abortion facility in March 2022.

• Live Action News (LAN) recently discovered that the Washington Surgi-Clinic's license expired in early August and was not renewed.

• Prior to this report, a pro-life group made a phone call to the clinic, which has been referring patients to the National Abortion Federation. A receptionist said they hoped to resume abortions in late September.

The Bottom Line:

When women submit to late-term abortions inside outpatient facilities, they may not know that they could be putting themselves at great risk — but the abortion industry knows.

Author's Note: Live Action News has not independently verified that any of the organizations 'put on notice' have ever referred abortion clients to or funded abortions at the Washington Surgi-Clinic. This article may be updated as further information becomes available.