6. All three girls experienced sudden and severe personality changes. They became flat and distant, reclusive, secretive, and non-communicative. They lost their humor and their empathy. They began speaking in a bizarre new language. They became unable to think critically or independently. They became dependent on the school teachers and guidance counselor who had indoctrinated them, especially Defendant Tanya Mastoloni.
7. On information and belief, the two older Doe sisters were indoctrinated into a religious cult that promotes martyrdom, and celebrates death. This has caused the elder Doe sisters to experience fantasies of suicidal ideation and martyrdom.
8. The youngest Doe daughter, J.D., was targeted to be indoctrinated into the same belief system, but she eventually broke free. J.D. has now joined her parents as a Plaintiff in this case.
9. The other two Doe daughters have, at the urging of Defendants Mastoloni, Kessler, Esposito, and Sullivan, cut off all of their communications with the rest of the Doe family, including extended family. They have also cut off all of their communications with their friends.
10. Defendants Mastoloni, Kessler, Esposito, and Sullivan pose a serious threat to the Avon community and the public at large. They each exert significant influence over the impressionable high school students who have been entrusted to their care. There is an obvious power differential between students and their teachers and guidance counselors.
11. Defendants Mastoloni, Kessler, Esposito, and Sullivan have consistently targeted minors and pursued them until they were of age in order to complete the conversion to martyrdom. Because of that, Defendants Mastoloni, Kessler, Esposito, and Sullivan pose a serious danger to students, students' families, and the public at large.Courthouse News Service reports on the case.
UPDATE: Responding to the lawsuit, the Avon school superintendent said that the district had not previously been contacted about the allegations and the complaint has been turned over to counsel for review.