Were You Abused as a Patient of Dr. James Heaps at UCLA?

You May be Entitled to Compensation. Call us at 844-999-8252 for a free consultation.

Female patients may have been sexually exploited by Dr. Heaps over the course of at least ten years. Some may have thought his conduct was inappropriate, but did not realize to what extent.

Dr. Heaps practiced at UCLA Health Center, Ronald Reagan UCLA Hospital, and UCLA Medical Group. On June 11, 2019, he was arrested and has been charged with sexual battery by fraud and one count of sexual exploitation with two patients by the Los Angeles County District Attorney’s Office. Additional patients have already come forward since this announcement.

If you were a patient and have concerns about his conduct, please contact us for a free confidential evaluation with no obligation to move forward with a case. If you decide to move forward, California law permits victims of sexual assault or abuse to remain nameless, so your case could be filed as “Jane Doe.”

THE SEXUAL ABUSE, ASSAULT, BATTERY AND HARASSMENT OF AND INJURY TO JANE DOE 1

On or about March 28, 2013, JANE DOE 1 visited HEAPS at one of the UCLA MEDICAL FACILITIES for a gynecology examination, including a pap smear. This was JANE DOE 1’s first and only visit with HEAPS. HEAPS started the appointment in his office, which was separate from the examination room. After reviewing her medical history and lulling her into a sense of safety, she was led to the examination room.

A female nurse, medical assistant or chaperone (“the female chaperone”) was present in the examination room and instructed JANE DOE 1 to disrobe completely and put on a hospital coverings, a vest that opened in front and a sheet for the waist down. JANE DOE 1 complied.

The female chaperone was present throughout the examination with HEAPS, but had her back turned and was facing away from JANE DOE 1, and could not see the front of JANE DOE or JANE DOE 1’s pelvic during the examination.

HEAPS first touched JANE DOE 1’s during what he was purporting to be a breast examination while JANE DOE 1 was sitting upright on the examination table. Instead of a breast examination that was within the standard for physicians, HEAPS, without gloves, cupped, fondled and groped her breasts. This inappropriate touching was not clinical, was confusing to JANE DOE 1 and made her uncomfortable. He eventually stopped and did not palpate or examination her breasts as a usual gynecologist would do, including performing an examination while she was supine.

Next, HEAPS performed a pap smear by using a speculum to access her cervix and swabbed her cervix. After removing the speculum, without any warning or consent, HEAPS repeatedly stroked her clitoris and vaginal lips. After stroking her genitals, HEAPS told her that she could get dressed.

After her horrifying encounter with HEAPS, JANE DOE 1 told an acquaintance that she felt that she had been violated. She was so disturbed that she never contacted HEAPS or UCLA for the results of the lab work, and found another doctor.

The pap smear and other swabs taken by HEAPS during the examination were processed at Ronald Reagan UCLA Medical Center (757 Westwood Plaza, Los Angeles, CA 90095-8358).

It was reasonably foreseeable that the tortious acts, omissions and wrongful conduct and breach their respective duties by Defendants, and each of them, would endanger the safety, health and wellbeing of Plaintiff and cause significant personal injuries and emotional distress.

As a direct and proximate result of Defendants HEAPS, THE REGENTS and DOES 1-500’s tortious acts, omissions and wrongful conduct and breach their respective duties, JANE DOE 1 has suffered, and continues to suffer personal injuries from the physical and sexual battery, physical injury, weight loss, great pain and suffering of mind and body, shock, emotional distress, physical manifestations of emotional distress, embarrassment, shame, loss of self-esteem, disgrace, humiliation and loss of enjoyment of life. Plaintiff has sustained and continues to incur economic damages, including loss of earnings and loss of earning capacity and expenses for medical treatment and services, medications and related matters, as well as noneconomic damages, the full nature and extent of which are not yet known to Plaintiff, and leave is requested to amend this Complaint to conform to proof at trial.

As a further direct and proximate result of the personal injuries caused by Defendants, in whole or part, Plaintiff has been generally damaged in a sum in excess of the jurisdictional limits of the Superior Court, Limited Jurisdiction.

Plaintiff is entitled to prejudgment interest on said damages attributable to an ascertainable economic value pursuant to Civ. Code Section 3288. Plaintiff has lost prejudgment interest pursuant to Civ. Code Section 3291, the exact amount of which Plaintiff prays leave to insert herein when finally ascertained and to confirm to proof at trial. In the event that HEAPS is prosecuted and convicted of a felony for the conduct alleged herein, Plaintiff requests leave to amend the instant Complaint, such that a request for attorneys’ fees can be made against HEAPS pursuant C.C.P. Section 1021.4.

Plaintiff reserves the right to seek leave of court to add punitive damages claims against HEAPS and/or DOES 1-500 for any “professional negligence” claims through duly noticed motion under C.C.P. Section 425.13, to the extent Plaintiff asserts any such claims. Plaintiff also separately reserves the right to seek leave of court through a duly noticed motion to add punitive damages under applicable law and statutes providing for punitive damages for the various other causes of action alleged herein.

THE SEXUAL ABUSE, ASSAULT, BATTERY AND HARASSMENT OF AND INJURY TO JANE DOE 2

In or about 1992, JANE DOE 2, a UCLA blood bank employee at the time, visited HEAPS at one of the UCLA MEDICAL FACILITIES for a gynecology examination. This was JANE DOE 2’s first and only visit with HEAPS. JANE DOE 2 had also been a student of UCLA extension glasses between approximately 1989-1992.

JANE DOE 2 was placed in an examination room and HEAPS had her disrobe completely. While she was naked, HEAPS touched JANE DOE 2’s breasts during what he was purporting to be a breast examination while JANE DOE 2 was sitting upright on the examination table. Without gloves and with both hands, HEAPS cupped, fondled and groped her breasts, telling her that they were “really firm” and they would not be like that forever. This inappropriate touching was not clinical, was confusing to JANE DOE 2 and made her uncomfortable. He eventually stopped and did not palpate or examination her breasts as a usual gynecologist would do.

Next, HEAPS performed what he was purporting to be a vaginal examination. Without warning and consent inserted his fingers into her vagina in a sexual manner, stroked her genitals and flicked at her partially-intact hymen, while asking “how often are you having sex,” and telling her “to get a dildo to use three times a week.” HEAPS finally stopped and told her she could get dressed.

After her horrifying encounter with HEAPS, JANE DOE 2 was so disturbed that she never returned to HEAPS for treatment. She was often reminded of the sexual abuse, assault, battery and harassment and discrimination, and would cringe when she saw HEAPS in the hallways of UCLA MEDICAL FACILITIES while she continued working in the UCLA Blood Bank until was able to leave that job.

It was reasonably foreseeable that the tortious acts, omissions and wrongful conduct and breach their respective duties by Defendants, and each of them, would endanger the safety, health and wellbeing of Plaintiff and cause significant personal injuries and emotional distress.

As a direct and proximate result of Defendants HEAPS, THE REGENTS and DOES 1-500’s tortious acts, omissions and wrongful conduct and breach their respective duties, JANE DOE 2 has suffered, and continues to suffer personal injuries from the physical and sexual battery, physical injury, weight loss, great pain and suffering of mind and body, shock, emotional distress, physical manifestations of emotional distress, embarrassment, shame. loss of self-esteem, disgrace, humiliation and loss of enjoyment of life. Plaintiff has sustained and continues to incur economic damages, including loss of earnings and loss of earning capacity and expenses for medical treatment and services, medications and related matters, as well as noneconomic damages, the full nature and extent of which are not yet known to Plaintiff, and leave is requested to amend this Complaint to conform to proof at trial.

As a further direct and proximate result of the personal injuries caused by Defendants, in whole or part, Plaintiff has been generally damaged in a sum in excess of the jurisdictional limits of the Superior Court, Limited Jurisdiction.

Plaintiff is entitled to prejudgment interest on said damages attributable to an ascertainable economic value pursuant to Civ. Code Section 3288. Plaintiff has lost prejudgment interest pursuant to Civ. Code Section 3291, the exact amount of which Plaintiff prays leave to insert herein when finally ascertained and to confirm to proof at trial. In the event that HEAPS is prosecuted and convicted of a felony for the conduct alleged herein, Plaintiff requests leave to amend the instant Complaint, such that a request for attorneys’ fees can be made against HEAPS pursuant C.C.P. Section 1021.4.

Plaintiff reserves the right to seek leave of court to add punitive damages claims against HEAPS and/or DOES 1-500 for any “professional negligence” claims through duly noticed motion under C.C.P. Section 425.13, to the extent Plaintiff asserts any such claims. Plaintiff also separately reserves the right to seek leave of court through a duly noticed motion to add punitive damages under applicable law and statutes providing for punitive damages for the various other causes of action alleged herein.

Dr. James Heaps Assault and Abuse Free Legal Consultation:

Call us - 844-999-8252 or fill out the form below.

We handle Dr. James Heaps Sexual Assault and Abuse cases in Alameda County, Los Angeles County, Marin County, Napa County, Orange County, Sacramento County, Santa Clara County, San Diego County, San Francisco County, San Mateo County, Sonoma County, Ventura County, and other counties across the State of California.