Topeka ? An anti-abortion group filed a complaint Thursday with state regulators against Dr. George Tiller. It alleges the high-profile Wichita abortion provider broke state law and gave a patient substandard care.

Operation Rescue based its complaint on medical records from Michelle Armesto, a Topeka resident who testified during a legislative committee hearing on abortion last month. She said she received an abortion from Tiller’s clinic in May 2003.

The group filed its complaint on her behalf with the State Board of Healing Arts, which licenses and regulates doctors. Troy Newman, Operation Rescue’s president, said the group wants the board to revoke Tiller’s license.

The complaint also lists a second doctor, Shelley Sella. She lives in Berkeley, Calif., but she performs abortions at Tiller’s clinic, and his Web site lists her as a staff physician. Operation Rescue said in its complaint that Sella was involved in Armesto’s abortion.

The complaint alleges Tiller’s clinic falsified its diagnosis that Armesto’s fetus could not survive outside the womb so that an abortion could be performed at 24 weeks. It also alleges the clinic didn’t wait 24 hours between first seeing Armesto and performing the abortion, as required by law.

“We’re finding a pattern of criminal activity from this abortion clinic,” Newman said during an interview. “This is information that is coming out, seeping out.”

Tiller’s attorneys have said repeatedly that the doctor complies with all Kansas laws regulating abortion.

Julie Burkhart, lobbyist for ProKanDo, a political action committee Tiller formed, called the complaint the latest “shenanigan” in a “wild witch hunt.”

“It’s a way in which to maneuver to make reproductive health care inaccessible to women,” she said.

A spokesman for Planned Parenthood in Concord, Calif., where Sella has an office, did not immediately return a telephone message. Sella has medical licenses in both California and Kansas.

Tiller, among a few in the U.S. who perform late-term abortions, also faces 19 misdemeanor charges in Sedgwick County. They were filed in June by Attorney General Paul Morrison, who alleges Tiller failed to get a second opinion from an independent physician on some late-term procedures, as required by law.

In addition, a grand jury is scheduled to convene Oct. 30 to begin another criminal investigation of Tiller. Abortion opponents gathered more than 7,800 signatures – three times as many as necessary – on a petition to impanel the grand jury.