Miller allegedly entered a sexual relationship with Doe, who Delgado says in the filing became pregnant. As the filing claims (emphasis theirs):

Shortly thereafter, according to Joe Doe, Mr. Miller visited her at her apartment with a Smoothie beverage.

Unbeknownst to Jane Doe, the Smoothie contained an abortion bill. [sic]

The pill induced an abortion, and Jane Doe wound up in a hospital emergency room, bleeding heavily and nearly went into a coma.

The unborn child died.