th THE LAW FIRM t (OF TAMARA N. HOLDER. LLC April 3, 2024 ‘The Honorable Kim Foxx Cook County State’s Attorney 69 W. Washington Suite 3200 Chicago, IL 60602 The Honorable Kwame Raoul Office of the Iinois Attorney General 115 S. LaSalle Street Chicago, IL 60603 RE: REQUEST FOR RE-OPENING OF CRIMINAL INVESTIGATION INTO FORMER OBGYN FABIO ORTEGA, NORTHSHORE HOSPITAL SYSTEM [ ENDEAVOR HEALTH, AND SWEDISH COVENANT HOSPITAL Dear Hon, Foxx and Hon. Raoul: We write to urge you to conduct a full criminal investigation of the hundreds of sexual abuse allegations against former OBGYN Fabio Ortega and his employer, Endeavor Health. For over three decades, Fabio Ortega committed deplorable acts and used his position of power to sexually abuse women. He was shielded by the hospitals where he worked and was allowed to victimize hundreds of women, Presently, we are aware of roughly 500 women who have come forward seeking to hold him accountable through civil litigation. Despite the many civil lawsuits and extensive press coverage', Ortega remains free, roaming the streets of Chicago without having to reckon with the magnitude of his depraved conduct. Time is up. He must be held accountable. | Northshore Put Patients at Risk of Indicted Gynecologist: Suits (Keb. 1, 2019) ‘© Women Sue Suburban Hospital. Gynecologist over sexual Abuse claims (June 62019) ¢ Four More Wor Sue NorthShore and its Disgraced Gynecologist (June 7, 2019) © Ex-NorthShore Gynecologist Fabio Ortega Pleads Guilty to Sexually Abusing Patients (Oct. 10, 2021) °F more women sue former Chicago-area gynecologist, alleging sexual assault during exams: ine 9, 2022) rthShore agrees to pay $35 million settlement in medical negligence ease involving troubled obstetrician (April 10, 2023) ‘© Former patients of Fabio Ortega say Endeavor Health failed to protect them from an abusive doctor (March 3, 2024)Ortega’s conduct has caused his victims to suffer humiliation, shame, and emotional distress. The women who were abused report physical manifestations of this trauma including headaches, sleepless nights, and bodily aches. This sexual assault has impacted how each of these women interacts with people every day, causing them to be guarded, irritable, and in fear of any type of physical contact from both strangers and loved ones. They also have difficulties trusting healthcare providers. Ortega not only abused his position of power, but he deprived his victims of their bodily and sexual autonomy, eroded their dignity, and robbed them of their humanity. Because of the sexual assault, each of Ortega’s patients has experienced feelings of contamination and of having been defiled and desecrated. In 2021, the Cook County State’s Attomney’s Office successfully investigated and obtained a guilty plea from Ortega for aggravated criminal sexual abuse of two patients. But the landscape has changed again. Since 2021, our legal team has found hundreds of other victims and we have uncovered allegations of sexual abuse going as far back as 1991. Re-opening the investigation into Ortega will send a message that no one—not even medical doctors—is above the law. Perhaps the most troubling revelation during our years-long investigation is the inescapable conclusion that Ortega was protected by the hospital systems that employed him and, on countless occasions, these hospital systems turned a blind eye to Ortega’s misconduct. The hospitals for which Ortega worked were more worried about their reputation and financial gain than about protecting the patients—all of them women—who trusted them. It is for these reasons that we believe a criminal investigation into the conduct of these institutions is also warranted. Ortega existed and thrived because these multi-billion-dollar institutions enabled his conduct. ‘The need to investigate issues of criminal liability is made more urgent by the fact that these institutions, which documented patient complaints against Ortega, are publicly defending him and paying for his legal fees. Endeavor Health continues to deny responsibility and continues to argue in civil pleadings that Ortega did nothing wrong. In other words, Ortega’s conduct continues to be sanctioned by the hospitals for which he worked. Against this background, we believe it is essential for your offices to conduct a comprehensive criminal investigation of Ortega, the Board of Directors, Ortega’s partners, and each of the hospitals where he worked. Failure to do so would contribute to the notion that sexually abusing patients under the guise of providing medical care is permissible. A failure to conduct a comprehensive criminal investigation would undermine faith in the rule of law. We are sure that you share our outrage, disgust, and sadness reading the stories of the hundreds of women who were victimized by Ortega and these multi-billion-dollar healthcare institutions, Even though our legal team has dedicated thousands of hours to researching, litigating, and advocating for the victims, you are a erucial partner in our fight for justice. Ortega’s abuse of power and acts of sexual violence would have been horrific if done to only one patient. But these erimes are more shocking because Ortega violated hundreds of women in a deliberate and coordinated manner—shielded by his employers—for over 30 years.Our clients come from all walks of life, spanning all races and age groups. Yet there is no doubt that Ortega often targeted women who were uniquely vulnerable: recipients of Medicare and Medicaid funds, immigrant women who lacked knowledge about their rights and did not speak English, or women whose medical conditions were grave and could not find other medical care. Many of our clients are eager to cooperate with you in your investigation, and we offer our resources and legal team to assist you in any way we can. Our clients deserve justice in every form. Your offices are uniquely positioned to ensure that Ortega and the institutions that enabled him are held accountable. We urge you to act promptly so that all those who have caused irreparable harm to so many women are brought to justice. Your work will leave a lasting legacy while also making our City and State safer. On behalf of hundreds of women, we remain sincerely yours, _ yo 41 Tamara N. Holder ‘The Law Firm of Tamara N. Holder LLC 917 Doe 34 Washington Blvd., Suite 222 Chicago, Illinois 60607 Tel: 312-440-9000 Email: tamara@tamaraholder.com Michael E. Holden Daisy Ayllon ROMANUCCI & BLANDIN, LLC 321 N. Clark Street, Suite 900 Chicago, Illinois 60654 Johanna J. Raimond Law Offices of Johanna J. Raimond Ltd. 431 South Dearborn, Suite 1002 Chicago, Illinois 60605 : 312-235-6959 Email: jraimond@raimondlaw.com Email: sblandin@rblaw.net, mholden@rblaw net, dayllon@rblaw.net Tel: 312-253-862