6. All three girls experience d sudden and severe personalit y changes. They became flat and distan t, reclusive, secretiv e, and non-com municativ e. They lost their humor and their empat hy. They began speak ing in a bizarre new lan guag e. They became unable to think critically or independently. They became dependent on the school teachers and guidance counselor who ha d 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, an d celebrates death. This has caused the elder Doe sisters to experience fantasies

o f

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 fre e. J.D . has now joined her parents a s a Plainti ff

in

this case. 9. The other two Doe daughters have, at the urging

o f

Defendants Mastoloni, Kessler, Esposito, and Sullivan, cut

off

all

o f

their communications with the rest

o f

the Doe family, including extended fam ily. They have also cut

off

all

o f

their commun ications 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 impression able high schoo l students who hav e been entrusted to their care . There is an obviou s power differential between students and t heir teachers a nd guidance counselors .

11

Defendants Mastoloni, Kessler, Esposito, and Sullivan have consistently targeted minors and pursued them until they were

o f

age in order to complete the conversion to martyrdom. Because

o f

that, Defendants Mastoloni, Kessler, Esposito, and Sullivan pose a serious danger to students, students families, and the public at large. 12 . This lawsuit seeks to hold Defendants Mastoloni, Kessler, Esposito, and Sullivan accountable for the harm they have caused, and to deter them from inflicting any future harm.

13

This lawsuit also seeks to hold Avon Public Schools accountable for its failure to properly supervise and control its employees, and for allowing its employees to engage in predatory religious indoctrinati on in school. -

14

Finally, this lawsuit seeks to hold Wellesley College accountable for its role in cooperating with Defendants Masto loni, Kessler, Esposito, and Sullivan in their scheme to indoctrinate the three Doe daughters.

SUBJECT

M TTER

JURISDICTION

AND VENUE

15

This Court has jurisdiction over all

o f

the Plaintiffs federal claims, pursua nt to 28 U.S.C.

§

1331.