An amended complaint sheds light on the horror of manipulative abuse tactics David Farley allegedly used on patients.

Warning: The following article contains graphic accounts of sexual assault that may be distressing for some readers, especially victims of sexual abuse.

PMG SCREENSHOT - Attorneys for the plaintiffs submitted an amended complaint in the lawsuit against David Farley, West Linn Family Health Clinic, Legacy and Providence. The complaint sheds new light on the manipulative tactics Farley used to abuse his patients. One-hundred-and-fourteen women and girls have joined the lawsuit alleging that former West Linn doctor David Farley, who last year moved from West Linn to St. Anthony, Idaho, abused them at West Linn Family Health Center, Providence Willamette Falls Medical Center in Oregon City, and Legacy Meridian Park Hospital in Tualatin.

An amended complaint submitted by the plaintiffs alleging sexual abuse by Farley sheds new light on the horrors he allegedly inflicted upon patients as young as infants.

Most of the alleged abuse occurred at West Linn Family Health Center, which Farley opened in 1993 and owned until last August, but some of the suit's plaintiffs assert he abused them at the Providence and Legacy hospitals in Oregon City and Tualatin. The suit now seeks $570 million in damages for the victims. When the suit was initially filed last October, the four original plaintiffs sought $40 million.

Though Pamplin Media Group has previously reported on this lawsuit, the third amended complaint, which lawyers for the plaintiffs submitted to Multnomah County Circuit Court in August, provides new details into how Farley allegedly manipulated and abused his patients as well as the possible complicity of the institutions he worked for.

Because of the nature of the allegations and ongoing litigation, Pamplin Media Group was unable to obtain certain additional information regarding Farley and his abuse of patients. Tom D'Amore, one the plaintiffs' lead attorneys in the lawsuit, declined to answer several questions sent to clarify some of the allegations in the third amended complaint. Additionally, the Oregon Medical Board declined a public records request for documents regarding complaints against Farley that were made prior to the one that resulted in the revocation of his medical license last year. The board cited Oregon statutes which exempt information related to medical exemptions from public disclosure.

Much of the alleged abuse involves Farley's ungloved and medically unnecessary touching or penetrating of patients' breasts and genitals. He also was said to have attempted to sexually stimulate numerous patients and often made sexually suggestive or other inappropriate comments while doing so.

The court document shows that some of the plaintiffs who joined the suit since it was initially filed one year ago were in infancy, 5 years old, 6 years old and 8 years old when Farley allegedly began assaulting them.

Farley coerces patients

The third amended complaint reveals the manipulative tactics — like threats, harassment and gaslighting — that Farley allegedly used to get his abused patients to return.

For six of his patients, Farley allegedly refused to perform necessary medical treatment or prescribe medicines patients needed until they submitted to his abusive breast and vaginal exams. He also offered "free treatment" to women and girls when they didn't have health care or could not afford their doctor's visits, according to the complaint.

Farley allegedly began threatening one patient by citing the risk of HPV, cervical cancer and death to coerce her into submitting to further ungloved breast and pelvic exams when she was 15 years old, He also reportedly made inappropriate comments about the girl's vagina while his ungloved hand was inside her.

When the girl showed further hesitancy about visiting Farley at West Linn Family Health Clinic, the complaint says the doctor sent harassing text messages to both her and her family until she agreed to come in for more ungloved breast and pelvic exams.

The suit also alleges that Farley performed unnecessary surgical procedures on this patient's breasts at Willamette Falls Providence Medical Center between 2003 and 2008.

The third amended complaint details Farley's alleged abuse of another young patient who visited Farley at both the West Linn Family Health Clinic and Willamette Falls Providence, whom Farley began to abuse when she was only 5 years old.

Farley continued to abuse this patient until she was in her teens. When she was 16, he falsely diagnosed her with HPV, "a condition that he claimed required her to submit to more frequent digitally penetrative exams," according to the lawsuit.

Later, he allegedly diagnosed her with an ovarian cyst to convince her to visit him at his home, where he performed an ungloved digitally penetrative pelvic exam while the patient laid on his bed.

Like with many of his other patients, Farley insisted on performing the breast and pelvic exams on the girl without a chaperone present. He reportedly "shamed" her when she asked for one.

According to the lawsuit, the "scare tactics" Farley used on this patient were common practice.

In 2018, the doctor reportedly coerced one patient into submitting to a pelvic exam by claiming another young patient died of cervical cancer that could have been detected with an exam. When this girl told Farley she'd prefer a female practitioner, Farley insisted on carrying on with the exam, allegedly telling her "I was the first person to see you naked."

Farley is alleged to have used the threat of cervical cancer to coerce at least nine other patients to allow him to perform exams.

One of these patients Farley diagnosed with an actual case of cervical cancer, though he never referred her to an oncologist.

According to the lawsuit, Farley "used this patient's religious beliefs against her, commenting on her sexual history and suggesting she had cancer as retribution for a sinful life."

The complaint describes alleged abuse of another patient, which began when she was around 12.

The girl began her first period only months after Farley performed a penetrative pelvic exam. He asked her to return for another exam.

During the second exam, Farley "removed his gloves and attempted to sexually stimulate (the patient) while making comments such as 'that feels nice' and 'that's good,'" according to the lawsuit.

Years later, when this patient was pregnant, Farley reportedly performed numerous ungloved digitally penetrative pelvic exams, which caused the patient to bleed.

"After each exam, Farley would prescribe her opiates to cope with the pain of his exams," the lawsuit stated.

This was not the only patient Farley prescribed drugs to in order to specifically deal with the horrors of his exams.

One patient, who was allegedly repeatedly abused by Farley during appointments at West Linn Family Health Clinic, developed anxiety toward visiting him at age 13. Despite this, Farley continued to perform the pelvic exams but gave the girl Ativan, an anxiety medication. He instructed her to take the medicine ten minutes before her next scheduled appointment.

Around 1996, Farley allegedly prescribed more unnecessary medication, in this instance hormone therapy, to a different 13 year old. The doctor allegedly did this to initiate the menstrual cycle of the girl, who had visited the doctor since she was very young. Once the girl's period arrived, Farley began ungloved pelvic examinations. He reportedly apologized and embraced her after the first one.

Farley becomes forceful with patients who show resistance

The complaint does not describe physical resistance by many of Farley's patients, but on the few occasions where his patients attempted to protect themselves, the doctor allegedly forced them to submit to his assault.

Court documents describe one such encounter: When Farley pulled the patient's gown down to reveal her breasts, she pulled the gown back up. Farley however forced it back down and began fondling her breasts. When the same patient resisted a pelvic exam, he is alleged to have physically pulled her legs open to perform the exam.

One patient, according to the complaint, fled the office at West Linn Family Health Center to avoid exams by Farley. The complaint describes the patient having made an appointment with a female physician assistance at the office. Farley entered the exam room instead and asked the patient's mother to leave. When the girl resisted Farley's insistence of breast and pelvic exams, he reportedly offered her "something to calm her down," which is when she fled the office.

The complaint said West Linn Family Health later called the patient to apologize.

One teenager who came to the clinic for their first ever physical reportedly requested a female nurse when Farley entered the room and began rubbing her thigh when she wore only a medical gown. Farley refused her request and carried on with his breast and pelvic exams.

Farley reacted similarly during a 2013 visit with a developmentally disabled adult who came to see him for a required physical to gain access to a specialized home. During the appointment, Farley allegedly refused to allow the patient's guardian in the room. Farley caused the patient extreme pain during a breast exam and proceeded despite her pleas for him to stop.

Clinic staff complicit?

Based on the lawsuit, other members of staff at West Linn Family Health Clinic seemingly knew about some of Farley's abuse. Some of the staff directly witnessed Farley's abuse while others made disparaging comments to patients who complained about Farley's treatment, according to the complaint.

While much of Farley's abuse took place without chaperones or other medical staff present, the lawsuit says that in some cases the doctor made sure other clinic staff were there to observe his actions with patients. More disturbing still was an encounter between a patient and nurse that took place while Farley allegedly abused the patient.

According to the third amended complaint, in 2007 one of Farley's patients at the clinic requested the presence of a female nurse after Farley fondled the patient's breasts and attempted to stimulate her clitoris.

When a nurse joined near the end of the pelvic exam, the nurse allegedly instructed the patient to "close her eyes and go to her happy place."

Though the complaint does not specify this patient's age, it describes Farley telling her "if this were the 1700s, (she) would be of normal childbearing age and it would be perfectly normal for her to be married having sex and making babies."

He also was said to have asked if he could "snip her hymen."

One patient who began visiting Farley at the clinic as a teenager endured regular breast and pelvic exams. When the patient complained to the clinic's nursing staff about the exams, they simply told her "they don't make the rules," according to the third amended complaint.

According to the complaint, Farley insisted that other clinic staff watch as one patient performed a self check of her IUD strings (a common but uncomfortable and typically private process) without the patient's permission.

On a separate occasion, Farley asked another patient to perform the same self check while a "student" watched. The complaint does not specify who this student was or why they were there.

Abuse at Providence

While most of the abuse outlined in the lawsuit occurred at Farley's own clinic, Farley reportedly abused some of his patients at Providence and Legacy hospitals in Oregon City and Tualatin, where he was allowed to practice.

One such instance allegedly occurred at Providence Willamette Falls Medical Center in 2015 in the presence of Providence nurses. The patient was reportedly a regular of Farley's at the clinic, but Farley was delivering her baby at the hospital.

The complaint states: "After delivery he performed an invasive pelvic examination of (the patient), forcing his whole arm into her vagina and causing bleeding, to the obvious concern of nurses in the room."

Farley performed another "extremely invasive and painful cervical exam which drew concern of a nurse in the room" during another patient's delivery at Willamette Falls Medical Center in 2019.

Additionally, in 2012, Farley reportedly conducted an "incredibly painful and invasive dilation procedure" on a patient at Providence, again prompting nurses in the room to comment. He then manually broke the patient's water without warning or consent, the complaint stated.

In addition to these patients, 13 other plaintiffs allege Farley abused them at the Providence hospital as well as at the clinic by performing invasive and medically unnecessary breast and pelvic exams, performing unnecessary breast surgery, forcefully removing a patient's placenta and making harassing comments about another patient's vagina during delivery of her baby.

Abuse at Legacy

Nine of the suit's plaintiffs claim they were patients of Farley at both Legacy Meridian Park in Tualatin and West Linn Family Health Clinic when they suffered his abuse.

Abuse alleged by these patients includes Farley's forceful removal of a patient's placenta, invasive and ungloved breast and pelvic exams and fondling of genitals.

In a request for dismissal submitted by the attorneys for Legacy on Sept. 28, Legacy posits that only three patients claim they were abused at Legacy.

The six other patients, while stating they were patients of Farley at both Legacy and the clinic, did not specifically state which facility the abuse occurred at.

The Legacy request for dismissal further denies the "conspiracy" between the three medical facilities alleged in the third amended complaint.

Medical institutions conspire?

The third amended complaint asserts that medical institutions that treat patients have a duty to protect those patients and posits that all three institutions where Farley allegedly abused his patients failed to do so.

"(Legacy, Providence and West Linn Family Health) held defendant Farley out to be a trustworthy and legitimate physician by continuing to advertise his services to the public, employ him, and/or allow him to treat patients at their facilities," the third amended complaint stated. "In making this false representation, the clinic defendants (Legacy, Providence and West Linn Family Health) concealed numerous complaints lodged by patients and failed to report known instances of misconduct regarding Farley's sexual abuse."

The attorneys for the plaintiffs wrote that the institutions cloaked Farley's prior sexual misconduct within a "Facade of normalcy."

The complaint asserts several instances that should have put the medical institutions on notice of Farley's problematic procedures. Providence allegedly learned of Farley's performance of pelvic exams on underage patients as early as 2012 ,while Providence staff witnessed Farley perform abusive or medically unnecessary procedures as early as 2003. The complaint also states that Providence revoked Farley's surgical privileges as early as 2017, but allowed him to return to medical duties (it was not clear why he lost these privileges).

Legacy employees reportedly witnessed Farley's abusive or unnecessary medical procedures as early as 1992 and witnessed him perform unnecessary pelvic exams as early as 2010.

The complaint alleges Family Health Clinic employees saw him perform unnecessary pelvic exams as early as 1993.

However, Legacy argues that employees' witnessing Farley's forceful removal of a patient's placenta in 1992 did not mean the hospital could reasonably foresee his future abuse.

"It is based on this isolated incident that, according to Plaintiffs, Legacy should have foreseen the risk of all instances of future sexual abuse between 1992 and 2010," Legacy attorneys wrote in the request for dismissal.

Legacy defends its innocence in Farley's alleged abuse between 2010 and 2020 with a similar justification, arguing that the "unnecessary and ungloved breast and pelvic exam" did not foreshadow Farley's other crimes.

"An exam or procedure could be 'unnecessary' for any number of reasons," Legacy's attorneys wrote.

The request for dismissal also notes Farley was never a Legacy employee, but rather a practitioner permitted to use Legacy facilities and equipment "to perform a limited range of medical procedures on his patients."

"Legacy, like many other hospitals, permits non-employee health care providers to perform certain procedures and use certain Legacy facilities if they obtain approval from Legacy through a credentialing process," Legacy attorneys wrote.

Legacy did not specify what this credentialing process entailed.

Beyond staff witnessing Farley's abuse of patients, the third amended complaint alleges the medical institution conspired to hide the doctor's propensity to sexual abuse.

"(Legacy, Providence and West Linn Family Health) engaged in a pattern and practice of ignoring complaints, failing to investigate sexual harassment and abuse complaints, deliberately concealing information from abuse victims, and contributed to a sexually hostile environment," the complaint stated.

In the request for dismissal, Legacy counters that the third amended complaint fails to adequately support its claims of conspiracy.

Legacy points out that because the plaintiffs fail to detail when and to whom complaints were lodged, there is not enough information to prove culpability of Legacy.

"Based on Plaintiffs' allegations, there is no basis upon which a jury could determine what Legacy knew and when—both critical facts for then deciding whether Legacy breached its duty," the request for dismissal stated.

D'Amore, one of the lead attorneys for Farley's victims, stated that for the hospitals, the main point this case will come down to is what they knew about Farley and when they learned it.

The complaint also notes that at one point, while Farley's license was suspended, he continued to see and abuse patients at the Family Health Clinic. The complaint did not detail when or why his license was suspended, and the Oregon Medical Board declined to provide information about complaints against Farley prior to the loss of his license last year.

Farley, West Linn Family Health and Providence did not respond to the plaintiffs' third amended complaint. The plaintiffs are expected to submit their own response to Legacy's request for dismissal and a date for oral argument has been set for Dec. 15

Lawyers for Farley, West Linn Family Health, Providence and Legacy either did not return requests for comment or declined to comment on the record.

Detective Tony Christensen, who is leading the investigation into Farley for the West Linn Police Department, declined to comment on the case.

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