10 Q. Dr. Anand, do you have an opinion as to whether the

11 fetus can feel pain more intensely at certain periods of

12 gestation?

13 A. What we have noted from studies in premature infants is

14 that they have a much lower threshold for pain, meaning they

15 are more sensitive to pain than the full term infant. In

16 fact, some types of pain are three times greater sensitivity

17 in the pre-term baby as compared to the full term neonate.

18 And the full term neonate is more sensitive to pain than the

19 two-year-old child, and the two-year-old child is more

20 sensitive to pain than the six years old or 8eight ,

21 10-year-old child. So there is a much greater sensitivity

22 to pain earlier in development and there are clear

23 developmental reasons for that.
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6 Q. So what period of gestation would you say the fetus is

7 most sensitive to pain?

8 A. I would say between 20 and 30 weeks of gestation is the

9 greatest sensitivity to pain. This is based on multiple

10 lines of evidence. Not just the lack of descending

11 inhibitory fibers, but also the number of receptors in the

12 skin, the level of expression of various chemicals, neuro

13 transmitters, receptors, and things like that.

14 Q. Is there medical consensus that the fetus feels pain to

15 a greater sensitivity at that gestational period?

16 A. Yes, there is.
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17 Q. So, Doctor, do you have an opinion as to whether the

18 partial-birth abortion procedure causes pain to the fetus?

19 A. If the fetus is beyond 20 weeks of gestation, I would

20 assume that there will be pain caused to the fetus. And I

21 believe it will be severe and excruciating pain caused to

22 the fetus.

23 Q. What do you mean by severe and excruciating pain?

24 A. You see, the threshold for pain is very low. The fetus

25 is very likely extremely sensitive to pain during the

1 gestation of 20 to 30 weeks. And so the procedures

2 associated with the partial-birth abortion that I just

3 described would be likely to cause severe pain, right from

4 the time the fetus is being manipulated and being handled to

5 the time that the incision is made, and the brain or the

6 contents, intracranial contents, are sucked out.