You can read the original lawsuit here.
For those of you who are new to the site and are interested in understanding some of the assumptions and the mindset that could cause leaders to behave in ways described in the lawsuit’s allegations, this post from 2011 does a good job of connecting the dots.
What follows are some of the portions that reflect the changes in Friday’s amended filing.
Paula Poe is a female who was repeatedly sexually assaulted during her childhood at the School at CLC and at various church events convened in Maryland. Due to the nature of the lawsuit, she wishes to use the pseudonym Paula Poe to keep her identity confidential. Paula Poe brings this action on her own behalf and on behalf of those similarly situated.
FACTS REGARDING PAULA POE
Paula Poe attended the School and services at CLC beginning in kindergarten until her family moved away from Gaithersburg, Maryland. Paula Poe was repeatedly sexually assaulted by two men. The primary perpetrator was a pastor and teacher. The secondary perpetrator was a children’s ministry worker.
On multiple occasions, the two perpetrators, acting in concert, had Poe strip, and sexually molested her. These sexual molestations occurred on the School and Church premises, and at Church events, such as picnics.
On multiple occasions, the primary perpetrator sexually molested Paula Poe at the School and Church events.
On one occasion, the secondary perpetrator sexually molested Paula Poe outdoors during a Church picnic.
Upon information and belief, Paula Poe was not the only victim of this pedophilia ring operating within the School and Church.
Upon information and belief, the pedophilia ring’s victims included children who subsequently went on to prey upon other young children.
Carla Coe is a female who was repeatedly abused by Defendant Tomzcak, primarily in Maryland and Virginia. Due to the nature of the lawsuit, she wishes to use the pseudonym Carla Coe to keep her identity confidential. Carla Coe brings this action on her behalf and on behalf of those similarly situated.
FACTS REGARDING CARLA COE
Carla Coe was repeatedly assaulted by Defendant Tomczak and his co-conspirators during a 25-year period spanning her childhood and young adulthood. Defendant Tomczak assaulted Carla Coe with his hands, as well as with various instruments, including but not limited to, plastic and wooden sticks.
On multiple occasions, including occasions after Carla Coe reached the age of majority, Defendant Tomczak forced Karla Coe to strip out of her clothing against her will, and be beaten on her bare buttocks. Defendant Tomczak continued to engage in this forced undressing and beating of Carla Coe until she fled and escaped from the abuse.
On several occasions, Defendant Tomczak imprisoned Carla Coe and denied her food for extended periods of time.
Defendant Tomczak verbally admitted on one or more occasions to the individual Defendants and to the Church that he abused Carla Coe. No one reported the beatings to the secular authority.
The assaults by Defendant Tomczak and his co-conspirators’ assaults primarily occurred in Maryland and Virgina.
Grace Goe is as female who, along with her siblings, was repeatedly abused by her father while residing in Maryland. When she sought assistance from Defendants to stop the ongoing physical and sexual abuse, they failed to assist the girls, failed to report the ongoing abuse to the secular authorities, and instead alerted the abuser to his daughters’ please for aid. Due to the nature of the lawsuit, she wishes to use the pseudonym Grace Goe to keep her identity confidential. Grace Goe brings this action on her own behalf and on behalf of those similarly situated.
FACTS REGARDING GRACE GOE
Grace Goe was physically and sexually abused by her father when she was a minor and living in Maryland. Grace Goe’s father repeatedly beat her on her naked buttocks so harshly that she bled and bruised. Her father would then submerge her into an ice bath to hide the physical manifestations of the beatings.
Grace Goe’s father also repeatedly sexually abused her, making her rub his feet, which he then inserted into her vagina.
Grace Goe’s father engaged in the physical and sexual abuse toward the other children, including the male children, whose penises he repeatedly fondled.
Grace Goe and her older female sibling reported the fact of the abuse to Defendant CLC, seeking protection from their father. Grace Goe and her sibling met with Defendants Ricucci and Layman, and explained the severity of the abuse.
Rather than report the ongoing abuse to the secular authorities, Defendants informed the father that his children had reported the abuse. This led to further abuse by the father.
Karen Koe and Karl Koe are brother and sister, both of whom were sexually assaulted as children residing in Virginia. Due to the nature of the lawsuit, they wish to use the pseudonyms Karen Koe and Karl Koe to keep their identities confidential. They bring this action on their own behalf and on behalf of those similarly situated.
FACTS REGARDING KARL KOE
Karl Koe was seven years old when he was repeatedly sexually molested (approximately ten times) by the male son of a Church pastor.
The perpetrator (then aged approximately 12 or 13) molested Karl Koe in multiple locations, including the bathroom at Church. The perpetrator engaged in multiple unwanted sexual acts, including kissing Karl Koe and fondling his penis.
After Karl Koe informed his parents that he had been molested, his parents advised Defendants Ecelbarger, Gallo, Mullery and V. Hinders, as well as others, of the molestation. Defendants failed to report the molestation to the secular authorities. Defendant V. Hinders misrepresented to the parents of Karl Koe that the Church had taken care of the matter by requiring the perpetrator to attend a different church service than Karl Koe.
Defendants, including the pastor father of the predator, failed to take any steps whatsoever to prevent the juvenile sexual predator from preying upon other children. Defendants continued to permit the juvenile sexual predator to have unfettered access to children on Church premises and during Church activities, such as Home Group and Celebration.
Upon information and belief, the juvenile perpetrator may have been one of the victims of the pedophilia ring operating at the School prior to sexually molesting Karl Koe.
FACTS REGARDING KAREN KOE
Karen Koe was sexually molested by a juvenile sexual predator when she was eight years old.
Karen Koe did not tell her parents about the molestation until some years later. At that point, her parents alerted Defendants and also alerted the police.
Karen Koe’s parents learned that the juvenile sexual predator who had molested their daughter had been initially charged with raping a minor, and subsequently served time in juvenile detention. Although this fact was known to Defendants, they permitted the juvenile sexual predator unfettered access to children.
Defendants refused to cooperate with the prosecuting secular authorities, who successfully prosecuted and convicted the juvenile sexual predator on felony charges. Defendant Gallo took steps to obstruct justice, including but not limited to making misrepresentations.
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