IN THE COURT OF COMMON PLEAS OF JEFFERSON COUNTY, OHIO

COMPLAINT

CIVIL CASE NO. ________________

Plaintiff, JUDGE _________________________

vs. REQUEST FOR TRIAL BY JURY

FRANCISCAN UNIVERSITY OF STEUBENVILLE

1235 UNIVERSITY BOULEVARD
STEUBENVILLE, OHIO 43952

DAVID R. MORRIER, individually, and as former Chaplain of Franciscan University of

Steubenville and Campus Minister for Student Life, and Friar and Provincial Member of the
Third Order Regular Province of the Most Sacred Heart of Jesus aka Province of the Most
Sacred Heart of Jesus, Third Order Regular of St. Francis of Penance aka The Third Order
Regular aka The Franciscan Friars, TOR
c/o SAINT FRANCIS FRIARY AT MOUNT ASSISI
141 SAINT FRANCIS DRIVE
LORETTO, PENNSYLVANIA 15940

JOSEPH LOIZZO, individually, and as former Director of the Wellness Center of Franciscan
University of Steubenville and Council Chair of the “Community of God’s Love”
149 W MCCONNELL AVENUE
WINTERSVILLE, OHIO 43953

FR. RICHARD DAVIS, TOR, individually, and as former Chairman of the Board of Franciscan
University and former Vicar Provincial of the Third Order Regular Province of the Most Sacred
Heart of Jesus aka Province of the Most Sacred Heart of Jesus, Third Order Regular of St.
Francis of Penance aka The Third Order Regular aka The Franciscan Friars, TOR
c/o PROVINCE OF THE MOST SACRED HEART OF JESUS
141 SAINT FRANCIS DRIVE
LORETTO, PENNSYLVANIA 15940

FRANCISCAN FRIARS OF THE THIRD ORDER REGULAR PROVINCE OF THE MOST

SACRED HEART OF JESUS aka PROVINCE OF THE MOST SACRED HEART OF JESUS,
THIRD ORDER REGULAR OF ST. FRANCIS OF PENANCE aka THE THIRD ORDER
REGULAR aka THE FRANCISCAN FRIARS, TOR
141 SAINT FRANCIS DRIVE
LORETTO, PENNSYLVANIA 15940

 
{00193544.1}  
 

THE RELIGIOUS AND CHARITABLE RISK POOLING TRUST OF THE BROTHERS OF

THE CHRISTIAN SCHOOLS AND AFFILIATES aka CHRISTIAN BROTHERS aka
CHRISTIAN BROTHERS SERVICES aka CHRISTIAN BROTHERS OF ILLINOIS, INC. aka
THE CHRISTIAN BROTHERS OF THE MIDWEST aka BROTHERS OF CHRISTIAN
SCHOOLS aka THE DE LA SALLE BROTHERS
1205 WINDHAM PARKWAY
ROMEOVILLE, ILLINOIS 60446

GALLAGHER BASSETT SERVICES, INC.

c/o THE PRENTICE-HALL CORPORATION SYSTEM, INC.
3366 RIVERSIDE DRIVE, SUITE 103
UPPER ARLINGTON, OHIO 43221

JOHN DOE #1, AND JOHN DOE # 2, unnamed male members of the “Community of God’s
Love” of Franciscan University

Defendants.

COMPLAINT
1. (“Plaintiff”) is a resident of , whose address

is .

2. Defendant Franciscan University of Steubenville (“Franciscan University”) is a

non-profit corporation engaged in operating an educational institution of higher learning in the city

of Steubenville, Ohio.

3. Defendant Rev. David R. Morrier (“Morrier”) is sued individually, and as and as

former Chaplain of Franciscan University of Steubenville and Campus Minister for Student Life,

and Friar and Provincial Member of the Third Order Regular Province of the Most Sacred Heart

of Jesus aka Province of the Most Sacred Heart of Jesus, Third Order Regular of St. Francis of

Penance aka The Third Order Regular aka The Franciscan Friars, TOR.

4. Defendant Joseph Loizzo (“Loizzo”) is sued individually, and as the former

Director of Wellness Center of Franciscan University of Steubenville. Although retired as the

 
{00193544.1} 2
 
 

Director of Wellness Center of Franciscan University of Steubenville, he is believed to continue

in the role as Chair Council Member of the “Community of God’s Love,” as hereinafter described.

5. Defendant Franciscan Friars of the Third Order Regular Province of the Most

Sacred Heart of Jesus, aka Province of the Most Sacred Heart of Jesus, Third Order Regular of St.

Francis of Penance aka the Third Order Regular aka The Franciscan Friars, TOR (“Franciscan

Friars”) is a religious non-profit organization whose operations include a Provincial office in

Loretto, PA; operation of Saint Francis Friary at Mount Assisi in Loretto, PA, often referred to

as the “motherhouse,” which also serves as a retirement home for the Franciscan Friars TOR; and

ownership and operation of Franciscan University of Steubenville, Ohio.

6. Defendant The Religious and Charitable Risk Pooling Trust of the Brothers of the

Christian Schools and Affiliates aka Christian Brothers aka Christian Brothers Services aka

Christian Brothers of Illinois, Inc. aka The Christian Brothers of the Midwest aka Brothers of

Christian Schools aka The De La Salle Brothers (“Christian Brothers”) operates as a nonprofit

organization located in Romeoville, Illinois in providing insurance services to certain Defendants

herein.

7. Defendant Gallagher Bassett Services, Inc. (“Gallagher Bassett”) is a global

insurance brokerage and risk management services firm headquartered in Rolling Meadows,

Illinois and doing business at 545 Metro Place South # 250, Dublin, Ohio.

8. Defendants John Doe #1 and John Doe #2 are two male members of the Community

of God’s Love, whose names and addresses are withheld for good faith privacy considerations.

General Allegations

9. When Plaintiff started as a Freshman undergraduate student at Franciscan

University in the Fall of 2006, she was 17 years old, suffering from Post-Traumatic Stress Disorder

 
{00193544.1} 3
 
 

due to years of sexual and psychological abuse, a history of self-inflicted “cuttings” on her body,

alcohol and drug abuse, and discrete episodes of suicidal ideation.

10. Based on the public reputation of Franciscan University’s mission of spirituality,

as well as educational instruction, Plaintiff sought higher education at the university not only as a

vehicle for being educated for a future career, but as an opportunity to seek spiritual guidance in

solving her psychological and addiction problems.

11. Unbeknownst to Plaintiff at the time of her admission to Franciscan University,

certain individuals connected to the university community including officials of the university,

Franciscan Friars, employees of the university, and individual members of the Franciscan

Community had been engaged in fringe, cult-like activities for decades under the public cloak of

a “Charismatic Covenant Community,” known as the “Community of God’s Love.”

12. The Community of God’s Love “online” posting claims that the Covenant of God’s

Love was originally called the “Servants of God’s Love,” and was founded in 1977, but does not

clearly state that the “servants of God’s Love” were in actuality “Servants of Christ the King.”

13. Upon information and belief, Fr. Michael Scanlan TOR, President/Chancellor of

Franciscan University of Steubenville from 1974 until 2000, was instrumental in the formation of

the aforesaid Catholic charismatic association that is now known as the “Community of God’s

Love.”

14. Upon information and belief, the current “Community of God’s Love” is an off-

shoot of another Charismatic Covenant Community known as the “Servants of Christ the King

(SOCK),” which was a branch of The Sword of the Spirit also initiated in or about 1977, in which

the aforesaid Scanlan was also instrumental. Upon information and belief, Scanlan was the “Senior

Head Coordinator” and “Top Sword of the Spirit Lieutenant” of SOCK. Upon information and

 
{00193544.1} 4
 
 

belief, Scanlan claimed to have “prophesied” the Covenant Community that became the

“Community of God’s Love” in 2017.

15. Over the years, the aforesaid Charismatic Covenant Community (SOCK), under the

primary direction and influence of Michael Scanlan, became involved in certain cult-like practices,

including, but not limited to, a “Deliverance Ministry” with the shared purpose of delivering

adherents from demonic attacks, possession and/or power (hereinafter “demonic influence”).

16. By the decade of the 1980’s, the Diocese of Steubenville was receiving numerous

complaints about the cult-like operation of said Charismatic Covenant Community, including, but

not limited to, SOCK’s attempting to isolate members and gain control over all aspects of their

daily life, intruding into their most intimate marital and interpersonal relationships, and even

breaching the silence of the confessional by advising members to talk to one or more officials of

the community about what they had related in confession.

17. In early 1991, Albert H. Ottenweller, D.D., the then Bishop of Steubenville, issued

a full report on said cult-like activities (see Ottenweller report, publically accessible); determined

that “the Community of the Servants of Christ the King should be permitted to continue its

existence, but as a diocesan association under the direction of a fully appointed diocesan priest….

but only ‘after a period of education’ as to ‘what went wrong….’”

18. Thereafter, SOCK ceased operation, and Michael Scanlan incorporated most of its

practices, including that of offering a “Deliverance Ministry,” into the Community of God’s Love,

without setting up a new community under the direction of a Diocesan Priest, as recommended by

Bishop Ottenweller.

19. Thereafter, the Community of God’s Love proselytized, supported, encouraged,

and “taught” about the merits of using the Deliverance Ministry for the purpose of delivering

 
{00193544.1} 5
 
 

adherents from demonic influence, but it was certain Franciscan Friars associated with the

university (particularly for all times relevant herein Scanlan and Morrier), who would actually

supervise and effectuate the actual practice of Deliverance Ministry sessions in their separate role

as “Priests.”

20. In so doing, Scanlan and Morrier would invite or allow certain members of the

Community of God’s Love, or others, to assist them in effectuating the deliverance sessions, and

which individuals over time became identifiable as those who actually effectuated the Deliverance

Ministry sessions of which the Community of God’s Love promoted and proselytized.

21. Both the Community of God’s Love and the ascertainable individuals who actually

implemented the Deliverance Ministry shared the purpose of delivering adherents from demonic

influence.

22. It was Scanlan’s protégé, Morrier, who, with Scanlan’s full acquiescence,

knowledge and support, utilized the cult-like teachings and practices of the Community of God’s

Love and/or Deliverance Ministry to solicit mostly troubled young female students of the

University in order to isolate and gain control over all aspects of their daily life, including mental

control over said adherents in order to feed Morrier’s own self-aggrandizement, status, and sexual

gratification.

23. This case illustrates the grave threat to our educational, religious, and other

institutions that result when fringe or extremist practices, whether religious or political, can be

manipulated for the personal, corrupt ends of an individual or group of individuals, and how said

manipulation can lead to illegal, criminal, and even violent conduct.

24. In bringing this action, Plaintiff challenges no particular religious belief of any

individual, church, or entity.

 
{00193544.1} 6
 
 

25. In bringing this action, and upon information and belief, Plaintiff believes that none

of the defendants to the present action will claim that the Deliverance Ministry sessions she was

forced to undergo were legitimate religious practices, including Morrier, who pled to one count of

criminal sexual battery against Plaintiff in the Court of Common Pleas of Jefferson County, Ohio

on or about March 11, 2022, of this year in a case styled State of Ohio v. David R. Morrier (Case

No. 21-CR-60).

26. In addition, and upon further information and belief, neither the University nor the

Franciscan Friars even believe in the charismatic practices promoted by the Community of God’s

Love and effectuated by the Deliverance Ministry. Indeed, the Franciscan Friars operate other

institutions of higher education which do not claim to be associated with a “charismatic”

philosophy and/or community. Nevertheless, the Community of God’s Love and Deliverance

Ministry were allowed to develop and flourish by the University and Franciscan Friars because of

the huge popularity and “charismatic” personality of President Michael Scanlan, under whose

influence and participation in the charismatic community and its more bizarre aspects, such as the

Deliverance Ministry, became the financial life-line of Franciscan University of Steubenville, as

well as its identity. As stated by then University President Sheridan at the time of the criminal

investigation of Morrier, relevant herein, “The Deliverance Ministry is not even Catholic.”

27. Accordingly, Defendants were able to use the cult(s) that developed from the

Community of God’s Love and/or “Deliverance Ministry” for their own corrupt goals of sexual

gratification, financial benefit, status, and/or self-aggrandizement, and to conceal and protect said

corrupt, illegal, and/or criminal conduct in which Defendants engaged, as hereinafter alleged.

28. In so doing, individual Defendants herein have usurped the legitimate, and shared

purpose of The Community of God’s Love and/or Deliverance Ministry in delivering adherents

 
{00193544.1} 7
 
 

from demonic influence, by using said shared purpose as a pretext for their own personal, corrupt

ends in the seeking to isolate and gain control over all aspects of their daily life, including mental

control over those subjected to the Community of God’s Love and/or Deliverance Ministry—for

their own corrupt ends of sexual gratification, financial benefit, status, and/or self-aggrandizement.

Certain Defendants as hereinafter alleged engaged in multiple illegal and criminal acts to promote

these corrupt ends and protect Morrier from criminal prosecution, and conceal his corrupt and

perverse actions from the rest of the Franciscan community, and citizens of Steubenville, Ohio,

for their own corrupt motives.

29. Accordingly, even before Plaintiff first entered the doors of Franciscan University

to start her undergraduate degree at the age of 17, the legitimate purpose of the Community of

God’s Love and/or Deliverance Ministry was being used for corrupt purposes by Scanlan and

Morrier, although other of the members and/or participants still believed Scanlan and Morrier to

be following its legitimate purposes, and/or were kept in the dark about the pattern of corrupt

activities resulting from the usurpation of these individuals of the aforesaid shared purpose.

30. By late 2006 (when Plaintiff started her first year at Franciscan), or early 2007,

Scanlan had taken Morrier under his wing as his leading protégé in effectuating the Deliverance

Ministry, and upon information and belief, was exploring the use of mind control techniques as

well as purported exorcisms (not legitimately approved by the Roman Catholic Church) as part of

the Deliverance Ministry.

31. For example, in or about April of 2007, Scanlan, while Chancellor of the

University, and at the expense of the University, sent Morrier to a seminar entitled “Mind Control

– An Introduction: A Seminar for Those in the Healing Professions Including Psychiatrists and

Psychologists.” The seminar focused on a supposed Manichean struggle between good and evil

 
{00193544.1} 8
 
 

for control of the world in which a cabal of Satanists, who had infiltrated all levels of government

and society, used mind control and indoctrination to “program” individuals to participate in the

spread of Satanism and by which Satanists procured victims for ritual sexual abuse and sacrifice.

According to the seminar materials, which include a mind control manual, individuals could be

victims of “transgenerational Satanism” in which said individuals and their relatives, past and

present, are caught in a web of satanic control, and that it is the therapist’s job to uncover the truth

of victim’s trauma and de-program the individuals to free them from the yoke of demonic

possession and the Satanic coven. According to the manual “The therapist is trying to understand

what it is in the client’s past that is causing such chaos, discover the blocks to healing, and uncover

the secrets that have such control over the client”; “‘Control or be controlled,’ the mind-set of the

“cult”, is deeply rooted in the psyche of the client”; that victims are often programmed to commit

suicide if therapy begins to uncover the truth of the cult’s existence and control; and that the “signs

of Transgenerational Satanism are usually self-evident after the memories of incest or other sexual

violation have been uncovered.” The manual also states that the treatment of victims of

Transgenerational Satanism and ritual trauma, due to the Satanists’ infiltration of the mental health,

counseling, and social work professions, has “largely gone underground” but victims often display

symptoms of “Dissociative Identity Disorder (DID)” and multiple personalities, to which

therapists should be attuned.

32. It was common for undergraduate students to seek “spiritual direction” from one of

the Franciscan Friars on campus in their first year of arrival. Learning that Morrier had a reputation

for helping “young, troubled women”, Plaintiff asked Morrier if he would serve as her Spiritual

Director. At first, Morrier declined, but encouraged Plaintiff to engage in other charismatic

practices with members of the Community of God’s Love, including Theophostic Prayer, and after

 
{00193544.1} 9
 
 

Plaintiff complained about her experience of same in the home of John Doe #1, Morrier decided

to serve as Plaintiff’s Spiritual Director in or about early 2007.

33. During the summer of 2008, when Plaintiff was visiting her hometown, she was

sexually assaulted by a person not associated with the Defendants herein. This assault became a

central topic of Plaintiff’s sessions with Morrier in the fall of 2008. She related both of the details

of the sexual assault, but also that she had spoken about it with another male friend who was also

a victim of sexual assault, and with whom she had once made a suicide pact. Upon learning of

Plaintiff’s suicide “pact”, Morrier insisted she also meet with a “counselor,” and Plaintiff made

arrangements through the University’s Wellness Center to seek counseling from Defendant

Loizzo.

34. Plaintiff’s first counseling session with Loizzo occurred in or about September

2008, during which time Plaintiff told Loizzo of her recent trauma and grief, and her meetings

with Morrier. When Plaintiff reported to Morrier that she had spoken with Loizzo, Morrier

demanded that Plaintiff only meet with Loizzo for counseling. Morrier also convinced Plaintiff

that he needed to be informed of what occurred at her sessions with Loizzo, and that Loizzo should

authorize the sharing of information between them (Loizzo and Morrier), which Plaintiff did.

35. Loizzo diagnosed Plaintiff with a variety of disorders, including Post-Traumatic

Stress Disorder (PTSD), substance abuse, and Bereavement disorder; but did not diagnose Plaintiff

with any demonic influences until some point after Morrier began to suggest it, which occurred

after Morrier started to subject Plaintiff to the Deliverance Ministry.

36. Morrier began to subject Plaintiff to the Deliverance Ministry at some point in

2008, because of his claim that Plaintiff’s problems were not solely as a result of psychological

issues, but that she was being attacked by demons. Based on Morrier’s claim, he started to question

 
{00193544.1} 10
 
 

Plaintiff about all of her past sexual relationships, and all aspects of her daily life, and sought to

monitor her activities for evidence of demonic attacks.

37. The initial “deliverance sessions” were individual sessions with only Morrier and a

woman by the name o , present—a “discerner of spirits” who “discerned” that

Plaintiff’s maternal great-grandmother was a victim of satanic ritual abuse (SRA) and that her

brother was currently being attacked by demons. Said initial sessions would focus on having

Plaintiff explicitly detail any and all sexual activity in which she engaged in or had ever had

engaged in, consensual or not, while Morrier delivered “renouncement” prayers to “repair” the act.

38. After Morrier had Plaintiff participate in Deliverance Ministry sessions, he adopted

a possessive and controlling posture toward Plaintiff’s personal life—prohibiting Plaintiff from

taking church sacraments from any other priest but him, banning her from any interactions with

any other priests, and ceasing her relationship with her male friend because it was “unhealthy.”

39. In the Spring of 2009, Plaintiff reported to Morrier that the male friend she had

told him about the previous semester had, in fact, committed suicide, to which Morrier smiled,

told her that it was a “blessing from God” that he killed himself, and that his death rid her of a

“negative influence in her life.”

40. In the Fall of 2009, while in confession with Morrier, Plaintiff revealed that she

recently had sex with a Franciscan University peer. Morrier then became furious, screamed at her,

and demanded to know “what is wrong with you?” At or around the same time, Plaintiff revealed

that her father had sexually abused her, and would “share” her with other men as a child.

41. From that point on, the abuse of Plaintiff “by her father” became a central theme of

Morrier’s claims of Plaintiff’s demonic influence, which by January of 2010 had developed to a

narrative by Morrier that she was actually possessed by demons, which could only be remedied by

 
{00193544.1} 11
 
 

continued deliverance sessions that included the reliving of Plaintiff’s prior abuse publically.

During this time period, Plaintiff’s chronic nightmares that she had experienced for many years,

worsened after she revealed her childhood abuse. During this time, Morrier’s control over

Plaintiff’s daily activities tightened and caused her isolation from her roommates and peers, using

in part the techniques criticized by Ottenweller in his report of 1991, techniques he learned from

the “mind control” manual referred to in ¶ 31; and including such things as monitoring her phone

calls, her whereabouts, her menstrual cycle (after Plaintiff was compelled to have an abortion,

hereinafter alleged in ¶ 63, below), time spent away from him with friends, and otherwise.

42. At around this same time, Morrier was diagnosed with cancer, and foreshadowing

a pattern of behavior that would increasingly become common, blamed Plaintiff for his cancer,

attributing it to the influence of demons.

43. After his rehabilitation from surgery, in January 2010, Morrier continued with

promoting the idea of demonic influence on Plaintiff and cult victimhood as the source of her

problems by drawing a pentagram and asking Plaintiff if she recognized the image from her

nightmares. When Plaintiff replied that she did not know, Morrier told her that her lack of memory

was evidence of Plaintiff being the victim of SRA.

44. Morrier, also explained to Plaintiff that symptoms of her mental distress, such as

PTSD, nightmares, flashbacks and fragmented memories, and insomnia, were all due to her

opening up about her past abuse, which to Morrier and Loizzo were evidence of SRA in the mind

control manual. Morrier and Loizzo claimed that because Plaintiff was seeking their help through

therapy, the demons had invaded her being, but Morrier and Loizzo could extricate them by having

Plaintiff talk about her problems. Said explanations were often “word-for-word” descriptions

 
{00193544.1} 12
 
 

gleaned from the mind control manual Morrier obtained at the seminar paid for by Franciscan

University, by and through Scanlan.

45. Morrier’s depiction of Plaintiff’s SRA focused almost entirely on her accounts of

her reported sexual abuse at the hands of her father or others. While giving her accounts, often

crying, Morrier would physically move close to Plaintiff as she recited the details of her sexual

assaults, holding her hands, and giving her face-to-face, lingering hugs.

46. During Plaintiff’s individual deliverance sessions with Morrier in the first part of

2010, Plaintiff discussed her fragmented memories, with Morrier disregarding the actual details

that Plaintiff revealed and instead fed her information from the mind control manual, insisting that

his narrative of SRA were the “truth” of her past. Loizzo did not attend these “deliverance

sessions,” but he was aware of them, approved of them, and following Morrier’s lead, started to

agree with Morrier that Plaintiff was a victim of SRA, advising Plaintiff that he had treated victims

of SRA in the past. At some point in early 2010, Plaintiff came to believe herself possessed by

demons.

47. In or about April of 2010, Morrier ramped up the SRA narrative in his deliverance

ministry sessions with Plaintiff by recommending that Plaintiff meet a SRA “specialist” who was

Morrier’s “counselor” on the topic. On or around April 24, 2010, Plaintiff, Morrier, and Plaintiff’s

roommate drove to Pittsburg to meet the “specialist,” Joe Westover, the aforementioned self-

proclaimed SRA expert who holds no professional license or is recognized as any type of authority

within the Catholic Church. Plaintiff and Morrier met with Westover for two hours. Westover

declared that she was the victim of SRA and that he could take her on for treatment at $300-$500

per session. While Plaintiff soon after phoned Westover that the price of such sessions was too

 
{00193544.1} 13
 
 

expensive, Morrier used Westover’s endorsement of Plaintiff being the victim of SRA as authority

to intensify the deliverance ministry sessions with Plaintiff.

48. In or about May 2010, a group deliverance session included , who

served as one of Morrier’s “discerner of spirits,” during which Morrier read aloud a list of different

names for Satan, and based upon Plaintiff’s reaction to hearing the names, and Morrier

determined that Plaintiff was possessed by 36 demons. Over the course of the remainder of 2010-

2013, Morrier would tell Plaintiff that she was possessed by 36 of such demons and spirits, and

that certain demons possessed and controlled specific parts of her body.

49. In or about May, 2010, the Deliverance Ministry sessions increased in time and

intensity. As earlier in 2010, Morrier’s influence in an effort to further manipulate Plaintiff,

revealed the identity of Plaintiff’s main ritual abuser, who was a man named “Brian” (based on a

real male person who had lived upstairs from Plaintiff’s birth father, who allowed said male person

to sexually abuse Plaintiff when she was 12 years old). According to Morrier, “Brian” was the

leader of a Satanic coven that controlled her and which had subjected Plaintiff to ritual abuse

during her childhood and adolescence. While discussing “Brian” during these deliverance sessions,

Morrier, in line with the mind control manual and recently added Dissociative Identity Disorder

diagnosis, would pray renunciation prayers to rid Plaintiff of “Brian’s” control while having

Plaintiff assume the roles of two versions of herself, one, the actual person – “ A,” the other

–“ B,” who was the victim of SRA, and who was also requested to repeatedly describe her

real past sexual abuse and trauma as unreal ritual abuse and trauma of the Satanic coven. According

to Morrier’s notes, these deliverance sessions were part of the “Secondary Virginity Process”

wherein Plaintiff “confessed” her past sexual history, including consensual and non-consensual

acts (i.e., SRA) by writing down the acts, with Morrier keeping the written descriptions, and

 
{00193544.1} 14
 
 

requiring Plaintiff to thereafter publically describe them in deliverance sessions and exorcisms

hereinafter alleged.

50. By the end of May of 2010, Morrier has attended an exorcism conference in

Pittsburgh, PA and decided to incorporate “exorcisms” into the Deliverance Ministry.

51. Along with Morrier’s claim that Plaintiff had to publically describe her sexual

abuse at deliverance sessions, said sessions in 2010 began to involve Plaintiff being required to

submit to the same in just a T-shirt and shorts to display her “cuts” on her body to participants,

explicitly describing sexual abuse narratives revealed in confession with Morrier (or the false

narratives fabricated by Morrier) while other participants in the Deliverance Ministry would use

spray bottles to spray her with holy water, to the point of Plaintiff becoming drenched.

52. On June 7, 2010, Plaintiff underwent the first of multiple exorcisms in Steubenville,

OH under the direction of Scanlan and Morrier, and another on June 28, 2010, although Plaintiff

was not informed that either was an “exorcism,” thinking it just another “Deliverance Ministry”

session.

53. On or about September 9, 2010, Plaintiff showed up for a Deliverance Ministry and

was told she was being taken to Pittsburgh, PA to undergo an exorcism by Morrier and certain

members of the Community of God’s Love. A Clement Machado (who was not known to Plaintiff

at the time) officiated the September 9, 2010 exorcism in Pittsburgh, PA, and was later identified

by Morrier as a “Rome-trained exorcist.”

54. After the Pittsburgh, PA exorcism of September 9, 2010, officiated by Machado,

Plaintiff underwent a total of three more exorcisms in September 2010, on the 18th, 25th, and 28th,

on the Franciscan University campus at the Finnegan Fieldhouse. Scanlan served as the “exorcist,”

with Morrier assisting. These exorcisms lasted hours and entailed men restraining Plaintiff (as had

 
{00193544.1} 15
 
 

been done at the first Pittsburgh exorcism), the placing/stuffing of a cross up the front or back of

the T-shirt Plaintiff wore, and progressing to not only the spraying of holy water, but the rubbing

of holy oil (up under Plaintiff’s T-shirt) on her body, including her breasts.

55. At the first Pittsburgh exorcism, Plaintiff was required to remove her clothes

(except for her T-shirt and shorts as had been the practice with prior “Deliverance Ministries” and

exorcisms in Steubenville, OH), so that the group could see the cuts and scars on her body – which

Morrier claimed to be evidence of possession, and not only was Plaintiff sprayed with holy water

and “drenched”, Plaintiff was also physically restrained and held down by males in attendance,

with Machado placing a crucifix under Plaintiff’s T-shirt on her bare chest and behind her back,

while having her recite sexual obscenities (which also became routine with deliverance sessions

and exorcisms in Steubenville, OH, thereafter).

56. Thereafter, subsequent to the first exorcism in Pittsburgh, PA, the Deliverance

Ministry sessions that took place in Steubenville, OH and/or Pittsburgh, PA included “restraining”

of Plaintiff by male participants and the inappropriate rubbing of holy oil on her chest and/or

placement of a crucifix under her T-shirt during these sessions. Plaintiff strained against being held

down and screamed during these supposed “exorcisms” and “Deliverance Ministry sessions” until

she collapsed from exhaustion. Morrier and the attendees took Plaintiff’s resistance as evidence of

“demons fighting back.” One of said deliverance sessions was so intense that Plaintiff was caused

to hit her head against the wall while being restrained, momentarily lost consciousness, and was

believed to have suffered a concussion.

57. By the Fall of 2010, Morrier would have “private sessions” with Plaintiff wherein

he would read from a “journal” prepared by him which described his sexual fantasies of Plaintiff,

would tell her he was having “wet dreams” about her, all he while continuing to blame Plaintiff

 
{00193544.1} 16
 
 

for his cancer diagnosis, and for his sexual desire. During confessions, Morrier would have

Plaintiff recount past sexual acts and had her make a list of sexual partners. In order to induce

stress and panic in Plaintiff during group deliverance sessions, Morrier betrayed Plaintiff’s trust

and revealed to the groups of Plaintiff’s abuse by her father. In October 2010, Morrier, had Plaintiff

write out a list of her sexual partners and then made her “re-confess” to these sexual acts. As with

all of the aforementioned manipulation by Morrier, Loizzo was aware of Morrier’s actions in

requiring Plaintiff to repeatedly recount in detail her sexual history.

58. Morrier started his course of multiple sexual batteries upon Plaintiff starting in the

fall of 2010, where he would hold private sessions with Plaintiff, have her take off her clothes,

touch her breasts, hips, buttocks, thighs, and vagina, telling Plaintiff that his touch is healing those

parts of her body—which had “demonic handles” that “aided” in her possession of demons.

Morrier then progressed to both of them being naked during sessions and penetrating her digitally

(with his fingers) and then with his penis. During confessions, Morrier would frequently

masturbate while having Plaintiff recount, over and over, the past abuse by her father.

59. Morrier continued his multiple sexual batteries upon Plaintiff from 2010 to 2013,

at which time Plaintiff had become under his complete mental control. Mostly, Morrier would

sexually abuse Plaintiff through penetration with his penis, or on a few occasions, using a crucifix.

Plaintiff denies that any of the abuse, as related to herein, was consensual on the part of Plaintiff;

and she can only describe her experiences during these times as having detached herself from

“reality” during Morrier’s multiple and continuing acts of sexual abuse. Actual sexual batteries

upon Plaintiff were perpetrated by Morrier one or more times a week from 2010 to 2013.

60. Morrier’s regular practice during the infliction of these batteries was to have

Plaintiff recount the sexual abuse by her father while he would be abusing her, and included

 
{00193544.1} 17
 
 

Morrier assuming the role of Plaintiff’s father and telling Plaintiff that she was to blame for him

(Morrier) sexually abusing her because the demons possessing Plaintiff were attacking him.

61. After Morrier started to inflict sexual batteries upon Plaintiff, he thereafter added a

SRA narrative for her to describe at her deliverance sessions and exorcisms—that Plaintiff was

being sexually abused by a fictional “Fr. Robert” who was a member of the Satanic coven

dominating Plaintiff; when in fact it was Morrier who was dominating her.

62. The increasing intensity of the Deliverance Ministry sessions over the years, with

the encouragement, support, and counseling of Loizzo, allowed Morrier and/or the

enterprise(s)/cult(s) as described herein, to take complete control over Plaintiff’s spiritual, mental

and physical life, and caused her to be of unsound mind from approximately 2010 until she was

able to report Morrier’s years of abuse, and the influence of the enterprise(s)/cult(s), to the

Steubenville Police Department in or about September of 2018.

63. In late 2011, Plaintiff became pregnant as a result of Morrier’s abuse. Morrier’s

response was that “There is no way God would punish him like that,” that “A pregnancy would

ruin his life,” and that Plaintiff needed to “take care of it.” Contrary to her religious beliefs at the

time, but under Morrier’s complete control, Plaintiff felt compelled to follow his advice and

thereafter underwent an abortion in Philadelphia one week before Christmas of 2011. When

Plaintiff informed Morrier that she had the abortion, Morrier blamed it on a fictional demon named

“Fr. Robert,” and would have Plaintiff tell the participants in subsequent deliverance sessions that

“Fr. Robert” got her pregnant but that she had “miscarried” the fetus (instead of aborting it) which

became part of the SRA narrative.

64. Also illustrative of the complete control of Morrier, now with the assistance of

Loizzo, and/or the cult(s), was the arranging by Morrier, Loizzo, and certain members of the

 
{00193544.1} 18
 
 

Community of God’s Love to remove Plaintiff from her place of residence because a self-

proclaimed “discerner” for Morrier, had “discerned” that Plaintiff was to be abducted and ritually

sacrificed by the Satanic coven on Halloween 2012.

65. To thwart this purported planned abduction and murder, Morrier and Loizzo, with

the help of the two John Does who had also acted as restrainers during Deliverance Ministry

sessions, took Plaintiff from her home and forced Plaintiff to stay in the properties and residences

of their two homes during the week leading up to Halloween 2012. At these residences, despite

Plaintiff’s protests and beggings to be allowed to go home, Plaintiff was kept in locked bedrooms

during the nights, with alarms on the doors, which was claimed to be for her “own protection”

from the “Satanic Coven,” but which only had the effect of terrorizing Plaintiff. Only after the

planned abduction did not materialize was Plaintiff was allowed to return home.

66. At certain times from 2010 to 2013, Plaintiff would have periods where she would

question the actions of Morrier’s actions and/or “spiritual direction,” but each time Plaintiff did,

University officials or Franciscan Friars chose to stay “willfully ignorant” of it. Said conduct only

reinforced in Plaintiff’s mind that she was “possessed,” or otherwise the source of the problem.

67. For example, soon after Plaintiff’s first actual sexual battery at the hands of Morrier,

and in or about November of 2010, she sought out Michael Scanlan in confession (so as to get

away from Morrier) at which time she told Scanlan that Morrier had “raped” her, to which

revelation Scanlan put his hand on Plaintiff’s shoulder, told her that he knew Morrier was a

“broken man,” but that it was she who needed to practice “emotional chastity” in her relationship

with Morrier—implying that there was nothing wrong with what Morrier was doing—and

implying he fully agreed that Plaintiff was possessed by demons.

 
{00193544.1} 19
 
 

68. In or about the summer of 2011, Plaintiff related to Franciscan University President

Dave Pivonka the nature and extent of the deliverance sessions and exorcisms that Morrier,

Franciscan University personnel, and members of the Community of God’s Love were performing,

including that they were physically restraining Plaintiff, screaming in her face, requiring her to tell

“obscenities” (although she did not bring up Morrier’s sexual batteries at the time) to which

Pivonka stated, “I’ll pray for you.”

69. In early Spring of 2013, after a failed suicide attempt, Plaintiff met with Father

Shawn Roberson, University Chaplain and tried to engage him in the nature of the deliverance

sessions, including the sexual abuse, at which time Roberson put his hand up and said, “I’m going

to stop you right there, I’m sure if I go home tonight, and ask Fr. Morrier about this, which I intend

to do, he will have a different story, so instead of sitting here gossiping, which is a sin, why don’t

we focus on why we are here and that is you and your problems.”

70. Within two days of Plaintiff speaking to Roberson, Morrier made arrangements to

see her; advised that Roberson had reported her disclosures to him, to which Plaintiff started to cry

and told Morrier that “she couldn’t do this anymore,” to which Morrier only smiled, and calmly

said, “Go ahead and tell someone. Who are they going to believe? The poor priest who is doing

everything to help you, or the possessed girl?” Morrier then proceeded to sexually batter Plaintiff

again, while she disassociated from reality.

71. Upon information and belief, Plaintiff now knows those responses to have been

consistent with Franciscan University, Franciscan Friars, and other Defendants in their continuing

effort to intimidate and/or silence Plaintiff as a victim or witness to crimes done to her and to

obstruct the bringing of Morrier and/or others to criminal accountability for said conduct, as

hereinafter alleged, which itself constitutes separate crimes under Ohio law.

 
{00193544.1} 20
 
 

72. Morrier’s continuing sexual batteries and abuse did not end until May, 2013, when

he was involuntarily removed from campus and the jurisdiction of Ohio, never to return until the

criminal proceedings against him early this year, 2022

73. On or about November 7, 2013, Loizzo wrote a letter to Davis, which detailed

information of Morrier’s Deliverance Ministry activities as they related to Plaintiff. Confirming

that the Deliverance Ministry was a “cult,” Loizzo deemed the deliverance sessions and exorcisms

as spiritual abuse in which Morrier “controlled and coerced her into believing that she was

possessed fully when she really was not at all.” Downplaying his own encouragement and

promotion of the cult(s) and/or Deliverance Ministry, Loizzo claimed that he thought that Morrier,

as a “priest,” knew more than him “…. about the extent of preternatural involvement….” in

Plaintiff’s life.

74. On or about November 15, 2013, Plaintiff met with Davis and reiterated everything

that Loizzo had previously advised him about the nature of Morrier’s “spiritual direction” and

activities, consistent with what Loizzo had previously advised, but without bringing up Morrier’s

sexual batteries at that time. Davis told Plaintiff he was “sorry,” and told her that Morrier would

be getting psychiatric treatment and would never be put in another position where he could harm

anyone in the future. Six months later, Plaintiff learned that Morrier was assigned to a Texas parish

as a Franciscan priest.

75. By the Spring of 2014, Plaintiff explained to Loizzo the specifics of Morrier’s

sexual abuse, at which time Loizzo went in “cover-up” mode, advising Plaintiff that she needed to

keep that information in therapy not only because it could harm Franciscan University and the

Franciscan Order, but such exposure would also be devastating to her as well.

 
{00193544.1} 21
 
 

76. Meanwhile, unbeknownst to Plaintiff, in complete contradiction to what he was

telling Plaintiff, Loizzo and Davis set out to have Plaintiff enter in a purported “settlement

agreement” to protect the above-named Defendants from civil and/or criminal liability. Loizzo

began to conspire with Richard Davis, and Provincial officials to keep Plaintiff from getting an

attorney and filing suit by offering continuing meager financial support at a time when he knew

Plaintiff to be in complete financial distress, had already represented to Plaintiff that he was willing

to continue to spiritually heal her, and that the Franciscan Friars were willing to continue to support

her in her severe financial distress if she did not get an attorney and kept Morrier’s sexual abuse

of her in therapy. At the time of Loizzo’s actions in this regard, and leading up to her signing of

the purported settlement agreement (attached hereto as Exhibit 1), Loizzo knew Plaintiff to have

been in overwhelming financial distress, not having any money for current living expenses and for

her last year of school at the university, and arranged with Davis on behalf of the university and

Provincial of the Franciscan Friars to set up a joint bank account with another Franciscan Friar,

Br. John Paul McMahon, to further convince her of his fraudulent representations that he would

continue to help her with her spiritual healing, and that Franciscan University and the Franciscan

Friars would continue to provide her with financial support, into which account for her use had

deposits anywhere from $12,000 to $15,000 dollars.

77. Loizzo represented to Plaintiff that the Franciscan Order and Franciscan University

would take care of Plaintiff’s financial needs in return for Plaintiff not getting an attorney and

keeping Morrier’s abuse in therapy; and that he, Loizzo, needed to continue to counsel her due to

the spiritual component of her psychological problems; which representations were made on more

than one occasion and continued up to the time she signed the purported Settlement Agreement

referred to herein in 2015. Davis also fraudulently stated that Plaintiff should feel guilt about her

 
{00193544.1} 22
 
 

own role in her conduct with Morrier—implying that Plaintiff was complicit and partially

responsible for Morrier’s conduct; as well as fraudulently represented to Plaintiff that public

exposure of the abuse would be disastrous to both the Franciscan Friars and herself.

78. As part of said scheme, Defendant Loizzo told Plaintiff that he contacted the

“insurance carrier” for the Franciscan Order, who Loizzo identified as the “Christian Brothers,”

and advised Plaintiff that they would do a complete psychological evaluation on her and then

determine an amount to pay for the harm done her; advised Plaintiff that the Christian Brothers

would fairly evaluate her claim to determine the extent of her damages by virtue of her years of

abuse, to allow Plaintiff to pay her bills and finish her last year of school at the University, but

always with the representation that after said payment, the Franciscan Friars would continue to

help her financially.

79. Instead of seeking to seek a fair evaluation of Plaintiff’s claim by Christian Brothers

as fraudulently represented, Loizzo continued to work with the Franciscan Friars, by and through

its Minister Provincial, Defendant Richard Davis, to concoct a plan to obtain a full “release of

claims” for the above-named Defendants at a time when Loizzo and the Franciscan Friars knew

Plaintiff was suffering from mental incapacity and severe mental disability, including, but not

limited to, PTSD, severe depression, and suicidal ideation with a plan.

80. On or about August of 2015, Loizzo contacted Plaintiff that she needed to meet

with Davis alone, per an email from Davis to Loizzo, at the Friary office on the University’s

campus, but did not tell her the reason for the meeting.

81. Although Plaintiff voiced concern to going to a meeting alone, Loizzo fraudulently

advised Plaintiff that he did not know what the meeting was about, but assured her that “they” had

“worked everything out” and wanted only to offer her continuing “help.”

 
{00193544.1} 23
 
 

82. When Plaintiff arrived at the meeting on or about August of 2015 (the same day

she signed the purported settlement agreement – Exhibit 1), Davis and McMahon were the only

ones present in the room, apart from one university employee, a Mary Lynn Lewis, who was

employed by the HR Department of the University, who was asked by Defendant Davis to sit in

another room while Plaintiff met with Davis and McMahon.

83. Davis thereafter began to fraudulently advise that the insurance company had

“made a determination” that Plaintiff’s “damages” were “$50,000,” and that the Franciscan Friars

wanted to pay that amount so she could finish school, and pay an additional amount in order for

Plaintiff to continue counseling with a certain Cynthia Mikita (another Franciscan University

employee and participant in activities of the cult(s)), because Loizzo was not able to continue to

see Plaintiff anymore as he would be retiring as Director of Franciscan University’s Wellness

Center.

84. Defendant Davis started the “meeting” by handing Plaintiff the purported

settlement agreement and release, and said, “we are going to have you sign this.”

85. When Plaintiff actually attempted to read the document, Davis distracted her

attention by reaching for the agreement himself (which was lying directly in front of Plaintiff on

the desk), saying, “it’s a just a bunch of legal stuff, I don’t even know what it means,” and flipping

to a certain portion of the purported agreement that stated that Plaintiff had had an opportunity to

consult with a lawyer concerning the same, which was false.

86. Defendant Davis then made comments to Plaintiff implying that Loizzo, the

university, and the Franciscan Friars believed that Plaintiff “made up” all of the complaints about

her treatment by Morrier and her years of abuse, at which time Plaintiff became terrified that they

 
{00193544.1} 24
 
 

thought she was “making everything up”; felt like she was going to vomit; started to cry,

psychologically disassociate herself from the moment; and signed the document under duress.

87. After she signed the agreement, Davis asked the others to leave and advised her

that “Fr. Dave [Morrier] never meant to hurt you. Had he known it was hurting you, he never

would have done it. He cares about you. He loves you. He just wanted best for you,” and before

Davis finished, gleefully advised Plaintiff that he didn’t know if she had heard that he was just re-

elected Provincial of the Order (as well as being Chairman of the Board of Trustees) and hoped

that Plaintiff and him could still be friends, which Plaintiff believes constitutes an admission that

Davis sought her agreement to the settlement not only individually, but on behalf of the university

and Franciscan Friars as well.

88. At the time, and under the circumstances, Defendants Morrier, Loizzo, University,

Franciscan Order, Davis, and presumably the insurance companies released in the purported

agreement knew of Plaintiff’s severe psychological condition to the point of her suicidal ideation

with a plan; that plaintiff did not have the mental capacity to bind herself to said agreement, or

was otherwise of unsound mind; and would not have signed the agreement except for the

fraudulent inducement of Loizzo and Davis as hereinbefore alleged.

89. Even after the signing by Plaintiff of the purported settlement agreement, Loizzo

fraudulently told her he didn’t know his name was going to be included in the release; that he still

needed to treat her spiritual components of her psychological problems; that she could not get an

attorney now because she released all claims and had “signed away her right to even talk about her

abuse” in the future—which fraudulent statement Plaintiff continued to believe up until September,

2018. At said time, Plaintiff regained her mental stability and courage to meet with Detective

 
{00193544.1} 25
 
 

Jonathan Sowers of the Steubenville Police Department, who suggested that Plaintiff “terminate”

her relationship with Loizzo, which she did thereafter in September of 2018.

90. Even after the signing of the purported settlement agreement in 2015, Plaintiff

continued to meet regularly with Loizzo based on his continuing representations that she had a

fragile mental state with still a largely “spiritual component,” and that she needed prayer which

she could not find anywhere else other than with Loizzo and the Franciscans Friars.

91. Upon information and belief, other female students at the university have suffered

injury to their physical, spiritual, and/or mental health by Defendants’ or other actions by the

corrupt activities of the cult(s) herein.

92. Throughout Plaintiff’s psychological and sexual abuse, she continued to suffer

from severe mental illness and psychological disability; could not separate reality from fantasy,

having come to believe that she was possessed by demons and that certain “cuttings” into her skin

(which she even now does not remember self-inflicting, but which were nevertheless consistent

with her prior mental illness) were consistent with “spontaneous” eruptions on her skin caused by

demonic possession; and believes that the combination of her continuing psychological conditions

and diagnoses, in combination with the cult(s)’ influence over her and the actions of Morrier and

Loizzo herein, caused her to be of unsound mind from on or about 2010 until September of 2018.

93. Specific and further items of damages will be taken up in connection with the

various causes of actions asserted herein against particular Defendants. However, by way of

Plaintiff’s general allegations herein, all of said wrongful conduct and continuing fraud has caused

Plaintiff, among other things as hereinafter alleged, continuing psychological impairment,

permanent psychological damage, and permanent limitations on her ability to engage in the

profession she sought to prepare for in her Franciscan education of higher learning, i.e., “clinical

 
{00193544.1} 26
 
 

psychologist,” and/or other careers or professions, and to lose certain legal rights or claims that

she could have otherwise timely brought but for the fraudulently induced settlement agreement

referred to herein.

COUNT I
VIOLATION OF OHIO REV. CODE § 2923.31 TO 2923.36, OHIO PATTERN OF
CORRUPT ACTIVITY ACT (OPCA) , AGAINST ALL DEFENDANTS

94. Plaintiff incorporates the allegations of paragraphs 1 through 55 of the Complaint

as if fully restated herein.

95. Plaintiff brings this cause of action against all Defendants for violations of the Ohio

Corrupt Practices Act.

96. All Defendants herein are “persons” as defined by R.C. § 2923.31(G).

97. Plaintiff is a person who has been injured or threatened with injury by a violation

of § 2923.32 of the Revised Code, and institutes this civil action for redress of that injury, seeking

triple damages for said loss under R.C. § 2923.34(E).

98. R.C. § 2923.31(C) defines “Enterprise” as: “Enterprise” includes any individual,

sole proprietorship, partnership, limited partnership, corporation, trust, union, government agency,

or other legal entity, or any organization, association, or group of persons associated in fact

although not a legal entity. “Enterprise” includes illicit as well as licit enterprises.”

99. The Community of God’s Love as referred to in ¶ ______, is an organization or

association with a publically posted Mission Statement as follows: “A charismatic Catholic

covenant community recognized by the Catholic Church as a private association of the

faithful in the Diocese of Steubenville, Ohio”. Although not a legal entity, the association has

the shared purpose of promoting charismatic doctrine, including, but not limited to what are called

“Gifts of the Spirit”, “Theophostic prayer”, and the “Deliverance Ministry”, including, but not

 
{00193544.1} 27
 
 

limited to, providing “charismatic” doctrine and teachings to students of Franciscan University,

the broader Franciscan community, and other charismatic adherents in the community of

Steubenville, Ohio.

100. Said organization or Association also exists separately from the actual corrupt

pattern of acts alleged herein. The Community of God’s Love is a functioning organization or

association under the definition of R.C. § 2923.31(C), and as such, is an “Enterprise” as defined

therein.

101. The “Deliverance Ministry,” while not a formal organization, association, or legal

entity, consists of a group of persons “associated in fact,” as defined in R.C. § 2923.31(C).

Accordingly, the Deliverance Ministry also meets the definition of Enterprise under R.C.§

2923.31(C).

102. Under Ohio law, a plaintiff must plead one of the following to establish and

“association in fact” enterprise: (1) an ongoing organization with a commonality of purpose or a

guiding mechanism to direct the organization; (2) a continuing unit with an ascertainable structure;

or (3) an organizational structure distinct from the pattern of predicate acts.

103. The “Deliverance Ministry” was at all times relevant herein was a continuing unit

with an ascertainable structure consisting of certain members of the Community of God’s Love,

Franciscan University officials or staff, and Franciscan Friars who have agreed to and in fact

actually participate in and effectuate the Deliverance Ministry referred to herein, which

charismatic “concept” is taught, proselytized and promoted by the Community of God’s love as

alleged herein. Said continuing unit and ascertainable structure is made up of the same group of

individuals regularly called upon to participate in the Deliverance Ministry sessions. In the

alternative, the Deliverance Ministry is an ongoing organization of individuals meeting to

 
{00193544.1} 28
 
 

effectuate Deliverance Ministry sessions with a community of purpose of delivering adherents

from demonic influence, and a guiding mechanism (individual Franciscan Friar priests who

voluntarily assume said role) to direct the organization, and/or has an organization structure

distinct from the pattern of predicate acts.

104. By the time that Plaintiff became a student at Franciscan University, Scanlan had

established a unit of ascertainable individuals who agreed to participate in “deliverance sessions”

(including exorcisms in aid of the Deliverance Ministry), which consisted of identifiable members

of the Community of God’s Love, but not all. Said unit also included certain Franciscan officials,

employees, as well as other Catholic members of the Steubenville community not affiliated with

the university.

105. Defendants herein usurped the legitimate functions of the Community of God’s

Love and/or Deliverance Ministry to use it as a pretextual vehicle for their own personally corrupt

ends—to seek to control the minds and bodies of young women and other vulnerable individuals

for their own corrupt ends of personal status, self-aggrandizement, financial gain, and/or unlawful

sexual gratification, and continuing concealment of same under the cloak of “legitimate”

charismatic activity.

106. Scanlan was the creator, organizer, and guiding mechanism of the Community of

God’s Love and the Deliverance Ministry as herein set out, although said role was distinct from

his role as President of Franciscan University from 1974 to 2000. Over the years relevant herein,

Defendant Morrier became his protégé in association of individuals in fact who performed

Deliverance Ministry sessions promoted by the Community of God’s Love, although said roles

were distinct from his role as campus Minister of Student Life. The legitimate religious functions

of the Community of God’s Love and the Deliverance Ministry over the course of years related to

 
{00193544.1} 29
 
 

herein, were usurped by Scanlan, Morrier and certain other Defendants to serving as a pretextual

vehicle for the seeking of complete spiritual, mental, and physical control over those subjected to

its practices for their own corrupt ends of personal status, self-aggrandizement, financial gain,

and/or unlawful sexual gratification.

107. Upon information and belief, the Community of God’s Love and/or Deliverance

Ministry continues to this day even after the March 11, 2022 conviction of Fr. Morrier for sexual

battery against Plaintiff, and continues to participate in the cult-like activities herein described,

including mind control, in order to assume complete control over the life and minds of its

adherents.

108. The Community of God’s Love and/or the Deliverance Ministry enjoyed a separate

existence from all Defendants as each and every Defendant was a distinct entity and/or individual

from the Community of God’s Love and/or the Deliverance Ministry.

109. In addition, the Community of God’s Love and/or Deliverance Ministry have an

organization and/or associational structure distinct from the predicate acts discussed herein, and

the defendant participants in enterprises had separate and distinct purposes from the Community

of God’s Love and/or Deliverance Ministry.

110. As discussed herein, each Defendant was involved in some corrupt activity that

constituted a pattern of corrupt activity (at least two predicate act felonies each), as hereinafter set

out; and upon information and belief, said corrupt activity consisted of more than the multiple

predicate acts involving Plaintiff detailed below. Upon information and belief, there were persons

other than her who were injured by a pattern of corrupt activities as alleged herein at all times

relevant to Plaintiff’s complaint.

 
{00193544.1} 30
 
 

111. Thus, upon information and belief, other young women were subject to the same

controlling and grooming behavior of Plaintiff by Morrier and/or a few other Franciscan Friars,

and part of the same did or would have suffered sexual abuse by Morrier had he not been removed

from Franciscan University campus or around May 2013, which upon information and belief, was

done to conceal Morrier’s wrongful conduct towards Plaintiff and/or other young women.

112. To state a civil claim under the OCPA, “a plaintiff must establish: (1) that conduct

of the defendant involves the commission of two or more specifically prohibited state or federal

criminal offenses; (2) that the prohibited criminal conduct of the defendant constitutes a pattern;

and (3) that the defendant has participated in the affairs of an enterprise or has acquired and

maintained an interest in or control of an enterprise” See Morrow v. Reminger & Reminger Co.,

L.P.A., 2009-Ohio-2665, ¶ 27, 183 Ohio App. 3d 40, 55, 915 N.E.2d 696, 708.

113. R.C. § 2923.31(E) defines “Pattern of Corrupt Activity” as: “Pattern of corrupt

activity” means two or more incidents of corrupt activity, whether or not there has been a prior

conviction, that are related to the affairs of the same enterprise, are not isolated, and are not so

closely related to each other and connected in time and place that they constitute a single event.

114. Under the OPCA, R.C. 2923.31(E) “Pattern of Corrupt Activity,” two predicate

acts must occur, that the acts must have occurred within six years of each other, and that one of

the acts must be a felony under Ohio law. R.C. 2923.31(E) also states that the predicate acts must

be “related to the affairs of the same enterprise, are not isolated, and are not so closely related to

each other and connected in time and place that they constitute a single event.”

115. The conduct of each Defendant involves the commission of two or more

specifically prohibited state criminal offenses, as hereinafter set out.

 
{00193544.1} 31
 
 

116. Predicate Act: R.C. § 2905.32 Trafficking in Persons. OPCA, R.C.

2923.31(I)(2)(a) lists Trafficking in Persons as a predicate act.

117. R.C. § 2905.32(A) & (A)(1) state that “No person shall knowingly recruit, lure,

entice, isolate, harbor, transport, provide, obtain, or maintain, or knowingly attempt to recruit, lure,

entice, isolate, harbor, transport, provide, obtain, or maintain, another person if either of the

following applies: (1) The offender knows that the other person will be subjected to involuntary

servitude or be compelled to engage in sexual activity for hire, engage in a performance that is

obscene, sexually oriented, or nudity oriented, or be a model or participant in the production of

material that is obscene, sexually oriented, or nudity oriented.” (my emphasis).

118. R.C. § 2905.32(B) states: “For a prosecution under division (A)(1) of this section,

the element “compelled” does not require that the compulsion be openly displayed or physically

exerted. The element “compelled” has been established if the state proves that the victim's will

was overcome by force, fear, duress, intimidation, or fraud.” (my emphasis).

119. Starting about September 9, 2010, Defendant Morrier transported and/or arranged

the transport of Plaintiff from Steubenville, OH to Pittsburgh, PA under the pretext of having her

undergo an exorcism but Defendants Morrier and Loizzo, intended for the purported exorcism to

maintain, strengthen, and reinforce their control over Plaintiff’s life and mental state, and with said

control compelled Plaintiff to engage in a performance that was obscene and sexually oriented.

During said exorcism, Plaintiff was compelled by duress and fear due to her believing Morrier’s,

Loizzo’s, declarations that she was possessed by demons. Said obscene and sexually oriented

performance entailed Plaintiff reciting, at Morrier’s instruction, her detailed and graphic sexual

history (consensual and non-consensual) and history of sexual abuse while participants forcibly

 
{00193544.1} 32
 
 

restrained Plaintiff, clothed only in a T-shirt and shorts, and while participants sprayed holy water

on her and placed a crucifix up her T-shirt to lay against her bare skin.

120. R.C. § 2905.32 (F)(3) states: “Material that is obscene, sexually oriented, or nudity

oriented” and “performance that is obscene, sexually oriented, or nudity oriented” have the same

meanings as in section 2929.01 of the Revised Code. The obscene and sexual performance that

occurred on or about the September 9, 2010, and continuing thereafter on several other occasions

in Pittsburgh, PA, under the pretext of an “exorcism”, comports with the legal meaning of

“obscene” and “sexually oriented” in R.C. § 2929.01 and R.C. § 2907.01, which 2929.01

references, and was participated in by Defendants Morrier, John Doe # 1 and John Doe # 2.

121. Predicate Act: Kidnapping, R.C. § 2905.01. OPCA, R.C. 2923.31(I)(2)(a) lists

Kidnapping as a predicate act. R.C. § 2905.01. Said statute, in pertinent part, provides that (A) No

person….by threat, or deception, or, in the case of a victim (A) states: “No person, by force, threat,

or deception, or, in the case of a victim…. mentally incompetent by any means, shall remove

another from the place where the other person is found or restrain the liberty of the other person

for any of the following purposes: ….(2) to facilitate the commission of any felony (such as in this

case of continuing sexual battery by Morrier of Plaintiff and/or)….(3) To terrorize..” (my

emphasis).

122. On or about October 2012, Morrier, Loizzo, John Doe #1 and John Doe #2 used

threats and deception (or any means because Plaintiff was mentally incompetent at the time) that

she was being pursued by a coven of demons who were out to sacrificially murder her; and

removed Plaintiff from the place where she was found and restrained her liberty in the homes of

John Doe # 1 and John Doe # 2, for approximately one week, against her will. At night, and despite

her protests and begging, Plaintiff was kept locked in a bedroom with an alarm on the door and

 
{00193544.1} 33
 
 

was not allowed to ever leave the room during the night. Only after the planned abduction did not

materialize was Plaintiff returned to her home. Violation of R.C. § 2905.01 is a felony offense.

This offense was participated in by Morrier, Loizzo, John Doe # 1, and John Doe # 2.

123. Predicate Act: R.C. § 2907.321 Pandering Obscenity Involving a Minor or

Impaired Person. OPCA, R.C. 2923.31(I)(2)(a) lists Pandering Obscenity Involving a Minor or

Impaired Person as a predicate act. R.C. § 2907.321(A) & (A)(1) states: “(A) No person, with

knowledge of the character of the material or performance involved, shall do any of the following:

(1) Create, reproduce, or publish any obscene material that has a minor or impaired person as one

of its participants or portrayed observers.” R.C. § 2907.01 (F) defines “obscene” as: “(F) When

considered as a whole, and judged with reference to ordinary adults or, if it is designed for sexual

deviates or other specially susceptible group, judged with reference to that group, any material or

performance is “obscene” if any of the following apply: (1) Its dominant appeal is to prurient

interest; (2) Its dominant tendency is to arouse lust by displaying or depicting sexual activity,

masturbation, sexual excitement, or nudity in a way that tends to represent human beings as mere

objects of sexual appetite.” R.C. § 2907.01 (J) defines “material” as: “Material” means any book,

magazine, newspaper, pamphlet, poster, print, picture, figure, image, description, motion picture

film, phonographic record, or tape, or other tangible thing capable of arousing interest through

sight, sound, or touch and includes an image or text appearing on a computer monitor, television

screen, liquid crystal display, or similar display device or an image or text recorded on a computer

hard disk, computer floppy disk, compact disk, magnetic tape, or similar data storage device.” (my

emphasis).

124. Starting in 2010 and spanning into 2013, when Plaintiff was of unsound mind, and

an impaired person under the Act, Morrier created and disseminated to others obscene narratives

 
{00193544.1} 34
 
 

of Satanic ritual abuse of an explicit sexual nature and had Plaintiff describe them during

Deliverance Ministry sessions and/or exorcisms as hereinafter alleged, such as that Plaintiff was

being abused by a coven of males and/or a fictional “Fr. Robert” made up by Morrier (when in

fact he was the ‘Father” who was at the time sexually abusing Plaintiff ), and forced her to publicly

“describe” them as part of the Deliverance Ministries and/or Exorcisms referred to herein, while

being restrained by males, sprayed with holy water, had her chest rubbed with oil—while tearful

and crying—which display was for its dominant appeal to the prurient interests of the male

participants referred to herein, and/or to arouse lust and/or sexual excitement of Morrier and or the

two John Does; and through the same time-span, multiple instances of Morrier requiring her to

“describe” real or sexual sins made up by Morrier during instances of her seeking confession from

him at which time he would openly masturbate in front of Plaintiff. Descriptions further entailed

portrayals of Plaintiff’s actual sexual histories, consensual, and non-consensual (such as when she

was sexually assaulted in 2010 and the sexual abuse she suffered at the hands of her father);

detailed portrayals of Plaintiff’s sexual victimhood by the coven’s satanic ritual abuse, which

included lurid and perverse accounts of violent rape; and detailed portrayals of Plaintiff’s sexual

abuse by Morrier which comprised the “Fr. Robert” accounts. The proof that these obscene

materials’ dominant appeal was to Morrier’s prurient interest is that he kept the accounts for his

own perverse and obscene sexual gratification and that he had Plaintiff recite and recount the

descriptions and portrayals while he sexually abused her and masturbated to the descriptions while

Plaintiff recited them during confession. That Morrier assumed the roles of Plaintiff’s father and

“Fr. Robert” while he sexually abused Plaintiff further speaks to these descriptions as obscene

despite Morrier’s disingenuous and false sentiments that the descriptions were part of Plaintiff’s

“deliverance”. The aforementioned descriptions lacked any serious artistic, political, and scientific

 
{00193544.1} 35
 
 

value; their sole purpose was to stoke Morrier’s prurient interest, sexually excite Morrier, and

tended to represent Plaintiff as a “mere object” of Morrier’s “sexual appetite” as Plaintiff’s

portrayal in said descriptions was as a passive subject to others’ sexual wants. Violation of R.C. §

2907.321 is a felony offense. Defendants Morrier, John Doe # 1, and John Doe # 2 participated

in said offenses.

125. Predicate Act: R.C. § 2913.47 Insurance Fraud. OPCA, R.C. 2923.31(I)(2)(c)

lists Insurance Fraud as a predicate act. R.C. § 2913.47(B)(1) & (B)(2) states: “No person, with

purpose to defraud or knowing that the person is facilitating a fraud, shall do either of the

following: (1) Present to, or cause to be presented to, an insurer any written or oral statement that

is part of, or in support of, an application for insurance, a claim for payment pursuant to a policy,

or a claim for any other benefit pursuant to a policy, knowing that the statement, or any part of the

statement, is false or deceptive; (2) Assist, aid, abet, solicit, procure, or conspire with another to

prepare or make any written or oral statement that is intended to be presented to an insurer as part

of, or in support of, an application for insurance, a claim for payment pursuant to a policy, or a

claim for any other benefit pursuant to a policy, knowing that the statement, or any part of the

statement, is false or deceptive.” R.C. § 2913.47(A)(2) defines “deceptive” as: “‘Deceptive’ means

that a statement, in whole or in part, would cause another to be deceived because it contains a

misleading representation, withholds information, prevents the acquisition of information, or by

any other conduct, act, or omission creates, confirms, or perpetuates a false impression, including,

but not limited to, a false impression as to law, value, state of mind, or other objective or subjective

fact.” (my emphasis).

126. The August 20, 2015 settlement agreement between Plaintiff and Defendants

constitutes Insurance Fraud perpetrated by Defendants Loizzo, Davis, the University, Franciscan

 
{00193544.1} 36
 
 

Friars, and Christian Brothers and Gallagher Basset, who knowingly solicited, and procured said

agreement to constitute payment of a claim pursuant to said policy (for Plaintiff’s years of abuse

by Morrier); and/or assisted, aided, abetted, or conspired with each other, or ratified said conduct

of each other, to solicit and proctor said payment, by multiple written and oral false and deceptive

statements, and/or conduct which created or confirmed a false impression as to law, value, state of

mind, or other objective or subjective facts to Plaintiff, including, but not limited to: Loizzo’s

statement to Plaintiff that any payment by the Franciscan Friars was only to help her out of her

acute financial distress by “placing a value” on her damages for Morrier’s past wrongful conduct,

but that the Franciscan Friars would continue to provide spiritual and financial support to her even

after they made such a payment to her; that before they would provide further financial assistance,

their insurance company, Christian Brothers, would do a full psychological evaluation of her

mental state; by Loizzo’s withholding of information that what he, Davis, Christian Brothers, and

Gallagher Basset were seeking was a “release of all claims” to protect themselves and Morrier,

and the University from future legal action; by preventing Plaintiff from acquiring of information

relevant to what turned out to be a purported “release agreement,” by Loizzo telling Plaintiff that

she should not get an attorney involved because that would interfere with Plaintiff’s continuing

spiritual treatment and future financial support by the Franciscan Friars; Loizzo’s and Davis’s

statements to Plaintiff that the Christian Brothers had placed a value on her damages at $50,000;

statements by Davis and (Franciscan Order in writing on the face of the purported settlement

agreement) just before having Plaintiff sign the purported settlement agreement that she had been

given sufficient time to talk to an attorney about it; Davis’ statement that the Franciscan Friars

were paying Plaintiff $50,000 for her damages attributable to Morrier’s conduct, and an extra

amount so that she could seek counseling by a person other than Morrier; Davis’s statement that

 
{00193544.1} 37
 
 

the Franciscan Friars and the university did not believe Plaintiff’s complaints about Morrier; the

withholding of information by the university, Franciscan Friars, Loizzo and Davis, Christian

Brothers or Gallagher Bassett, that the reason Loizzo requested that Plaintiff meet with Davis was

to sign a settlement agreement and release of all claims; the withholding of information by the

University, Franciscan Friars, Loizzo, Davis, Christian Brothers and Gallagher Bassett that she

was going to be presented with a purported settlement agreement and release of all claims against

Morrier, the University, the Franciscan Friars, Loizzo, Davis, Christian Brothers and Gallagher

Bassett at the meeting requested by Davis with the corrupt assistance of Loizzo and being required

to sign said purported agreement at the same meeting; by the withholding of the information from

Plaintiff prior to her signing the purported settlement agreement that Franciscan University,

Franciscan Friars, Loizzo and Davis used said information in the valuation of the claim; all of

which said deceptive conduct was the more egregious in the aforesaid’s knowledge at the time of

Plaintiff’s acute mental and financial duress, mental incapacity, unsound mind, and suicidal

ideation with a plan; by withholding information concerning said purported settlement

agreement—by handing it to Plaintiff, and when she did start to read it, diverting her attention

from reading it, and not advising her to read it before she signed it; and her being fraudulently

advised by Davis orally and the Franciscan Friars in writing (the purported Settlement Agreement)

that she had had an opportunity to consult with an attorney. The total amount of “payment” made

to Plaintiff was _________. Violation of R.C. § 2913.47, in which the value of the claim is more

than $7,500 but less than $150,000, is a fourth-degree felony. R.C. § 2913.47(C). In this case, the

value of Plaintiff’s claims purported released by the purported settlement agreement is much

greater, and said false and deceitful statements would constitute a criminal violation of a felony in

 
{00193544.1} 38
 
 

the third degree. Defendants Loizzo, Davis, Franciscan University, Franciscan Friars,

Christian Brothers, and Gallagher Bassett participated in this offense.

127. Predicate Act: R.C. § 1315.55 Money Laundering. OPCA, R.C. 2923.31(I)(2)(a)

lists Money Laundering as a predicate act. R.C. § 1315.55(A)(3) states: “No person shall conduct

or attempt to conduct a transaction with the purpose to promote, manage, establish, carry on, or

facilitate the promotion, management, establishment, or carrying on of corrupt activity.” The

August 20, 2015 “settlement agreement” between Plaintiff and Defendants constitutes money

laundering because the agreement was a transaction between the parties, conducted by Defendants,

with the purpose of carrying on the corrupt activity to cover up and immunize themselves from

liability for the claims/crimes committed by Morrier against Plaintiff and Defendants’ participation

in the Deliverance Ministry Enterprise. Violation of R.C. § 1315.55 is a third degree felony

offense. Defendants Loizzo, Davis, Franciscan University, Franciscan Friars, Christian

Brothers and Gallagher Bassett participated in said offense.

128. Predicate Act: R.C. § 2921.04 Intimidation of an attorney, victim, or witness

in a criminal case.

129. R.C. § 2921.04(A) states that “no person shall knowingly attempt to intimidate or

hinder the victim of a crime or delinquent act in the filing or prosecution of criminal charges or a

delinquent child action or proceeding, and no person shall knowingly attempt to intimidate a

witness to a criminal or delinquent act by reason of the person being a witness to that act.”

(Emphasis added).

130. Morrier intimidated and hindered Plaintiff as a victim of a crime in the filing or

prosecution of criminal charges on or about __________, as alleged in paragraph _______, with

 
{00193544.1} 39
 
 

his intimidating statements and actions in advising Plaintiff, one would believe a “possessed girl,”

and his response to her report to Roberson by of committing further sexual battery.

131. Loizzo hindered Plaintiff as a victim of multiple crimes by repeatedly telling her

not to get an attorney, to keep the crimes in therapy for her own spiritual healing, by promising

her the continuing help of the Franciscan Order, otherwise threatening her that it would be

devastating for her to come forward, and inducing her to sign a fraudulent settlement agreement,

which he thereafter told her barred her from other legal redress, and that she was bound to keep

the abuse (crimes) confidential as a result of the settlement agreement.

132. Davis intimidated and hindered Plaintiff by telling her that the Order did not believe

her, making her believe her involvement with Morrier was consensual, and otherwise threatening

her that it would be devastating for her to come forward. Morrier loved her, and that telling her as

per ¶ ____.

133. The Franciscan Friars intimidated and hindered Plaintiff by and through the actions

of its Minister Provincial, Richard Davis, as related above, and in continuing to conceal aspects of

Morrier’s abuse from public disclosure, and in continuing to conceal Morrier and Davis from the

jurisdiction of Jefferson County, Ohio as alleged herein. Defendants Morrier, Loizzo, Davis,

Franciscan University, and the Franciscan Friars all engaged in said criminal conduct.

134. Predicate Act: R.C. Section 2921.32, Obstructing Justice, provides in pertinent

part that “No person, with purpose to hinder the discovery, apprehension, prosecution, conviction,

or punishment of another for crime or to assist another to benefit from the commission of a crime,

and no person, with purpose to hinder the discovery, apprehension, prosecution, adjudication as a

delinquent child, or disposition of a child for an act that if committed by an adult would be a crime,

shall do any of the following: (1) Harbor or conceal the other person or child;…(4) Destroy or

 
{00193544.1} 40
 
 

conceal physical evidence of the crime or act, or induce any person to withhold testimony or

information or to elude legal process summoning the person to testify or supply evidence;” (my

emphasis).

135. Starting in 2013 and continuing through 2015 Defendants Loizzo, Davis,

Franciscan University and Franciscan Friars participated in several acts of obstruction of justice,

including, but not necessarily limited to, Davis and the actions of the Franciscan Friars and

University to remove and conceal Morrier from civil authorities in Jefferson County of Ohio from

2013 to 2015, when it came to learned that Morrier had been engaged in an inappropriate

relationship with Plaintiff; and continuing concealment of Loizzo’s continuing “counseling” and

statements from 2014 to 2015 thereafter; that caused her from seeking criminal or civil redress for

the abuse of Morrier; the involvement of Loizzo and Davis, individually and on behalf of the

University and Franciscan Friars, in engaging in the fraudulent scheme to have Plaintiff sign a

release of all claims for defendants, and otherwise.

136. All of the prohibited criminal conduct of the defendants as here alleged constitutes

a pattern of Corrupt Activity.

137. The aforesaid predicate acts occurred between 2010 and 2015. These predicate acts,

all of which are felonies, do not constitute a single event as, for instance, Morrier’s pandering

obscenities is distinct from Defendants’ cover up of Morrier’s sexual abuse of Plaintiff, and

demonstrates a pattern of corrupt activity carried out by use of the Enterprise(s). Further, the

predicate acts do not encompass all of the criminal and/or unlawful pattern of corrupt practices

perpetuated by Defendants. These criminal and/or unlawful acts, for which Plaintiff is bringing

claims include, other than the Predicate Acts, the following: Sexual Battery and abuse of Plaintiff

against Morrier; Breach of Fiduciary Duty against Defendants Loizzo and Morrier; Fraud in the

 
{00193544.1} 41
 
 

Inducement of the purported settlement agreement; and Negligent and/or Intentional Infliction of

Emotional Distress against Defendants Morrier and Loizzo, and others as alleged herein.

138. Because the Defendants consisted of entities distinct from the Enterprise(s) (i.e.,

Loizzo and his counseling practice at the FUS Wellness Center and his individual practice;

Franciscan University; the Province and TOR; Defendant Insurers; Defendant Morrier) with goals

and purposes separate from the Enterprise(s); and the Enterprise had goals separate from the

predicate acts themselves and a structure distinct from the predicate acts.

139. All named Defendants have participated in the affairs of the Enterprise(s) and/or

have acquired and maintained an interest in or control of an enterprise(s), as herein set out, as

required by R.C. § 2923.32. All Defendants were associated with the Community of God’s Love

and the Deliverance Ministry pursuant R.C. § 2923.32(A)(1). Defendant Morrier also assumed

control of the Deliverance Ministry pursuant to R.C. § 2923.32(A)(2).

140. Due to the aforesaid pattern of corrupt activity (predicate offenses and the other

violations detailed above, corrupt or criminal acts referred to herein, most importantly multiple

acts of sexual battery on the part of Morrier) many injuries have resulted from Defendants’

participation, interest, and/or control of, the Deliverance Ministry and/or Community of God’s

Love Enterprise(s).

141. Ohio Rev. Code Ann. § 2923.34 (J), states: “Notwithstanding any other provision

of law providing a shorter period of limitations, a civil proceeding or action under this section may

be commenced at any time within five years after the unlawful conduct terminates or the cause of

action accrues or within any longer statutory period of limitations that may be applicable.” See

also Tri-State Computer Exch., Inc. v. Burt, 2003-Ohio-3197.

 
{00193544.1} 42
 
 

142. Ohio Rev. Code Ann. § 2923.34 (J), further states: If a criminal proceeding,

delinquency proceeding, civil action, or other proceeding is brought or intervened in by the state

to punish, prevent, or restrain any activity that is unlawful under R.C. § 2923.32, the running of

the period of limitations prescribed by this division with respect to any civil action brought under

this section by a person who is injured by a violation or threatened violation of R.C. § 2923.32,

based in whole or in part upon any matter complained of in the state prosecution, action, or

proceeding, shall be suspended during the pendency of the state prosecution, action, or proceeding

and for two years following its termination.”

143. The unlawful conduct involving Defendants’ pattern of corrupt activity terminated,

or the cause of action accrued, no earlier than August 20th, 2015, at which time Plaintiff was

fraudulently induced to sign the purported settlement agreement while of unsound mind, lack of

mental capacity, and under duress.

144. Within five years of said unlawful conduct, a criminal investigation was

commenced by the Steubenville Police Department and Office in or about September of 2018, and

quickly came to involve the Prosecuting Attorney of Jefferson County, Ohio, commencing a

criminal proceeding as that term is used in Section 2923.34 (J), which suspended the operation of

the five-year statute of limitations until two years following its termination, i.e., until March of

2024.

145. Under said statutory provisions, the instant claim arising under the Corrupt

Practices Act of Ohio is timely brought.

146. In addition, or as an alternative, R.C. suspends the running of the statute of

limitations during the period of time that Plaintiff is of unsound mind. R.C. § 2305.16.

 
{00193544.1} 43
 
 

147. Upon information and belief, including current psychological evaluation, Plaintiff’s

mental condition of PTSD and/or DID, severe depression with suicidal ideation with a plan,

combined with the actions of the Cult(s)/Enterprise(s) as described herein in seeking to control all

aspects of her life and mind; and well as the mind control techniques administered by Morrier, and

the continuing fraudulent counselling of Loizzo, combined to make Plaintiff of unsound mind from

on or about 2010 until she was able to gain the courage and mental capacity to report to

Steubenville Police department in September of 2018, and ultimately terminate her relationship

with Loizzo thereafter.

148. Under Paragraph 139, this action is brought within 5 years of 2018 pursuant to R.C.

§ 2923.34(J).

149. In addition, or as an alternative, Defendant Morrier has been out of the jurisdiction

of Ohio since on or about May 2013, and the SOL has not run on Plaintiff’s claims against Morrier

individually, or as agent of the Franciscan university. R.C. § 2305.15.

150. Under that alternative, this action is timely brought pursuant to R.C. § 2923.34(J).

151. In addition, or as an alternative, Defendant Davis has been out of the jurisdiction of

Ohio since on or about 2014, and the SOL has not run of Plaintiff’s claims against Davis

individually, or as an agent of the Franciscan Friars. R.C. § 2305.15.

152. Under that alternative, this action is timely brought pursuant to R.C. § 2923.34(J).

153. In addition, or as an alternative, Defendants’ fraudulent conduct, including, but not

limited to keeping Morrier and Davis concealed from the jurisdiction from the state of Ohio, and

Loizzo’s continuing fraudulent statement to the effect that because of the purported settlement

agreement, Plaintiff was not permitted to talk to anyone about her continuing abuse by Morrier;

and needed to keep said information “in therapy” in order to continue to counsel her, protect her,

 
{00193544.1} 44
 
 

the University, and Franciscan Friars all constituted “continuing fraud” which only ended when

Plaintiff terminated her relationship with Loizzo in September of 2018.

154. Under that alternative, this action is brought within 5 years of 2018 pursuant to R.C.

§ 2923.34(J).

155. In addition, or as an alternative, Plaintiff did not know of the existence of the

Enterprise(s) engaging in a pattern of corrupt practices until she learned of same during the

investigation of the Steubenville Police department starting after September of 2018.

156. Under that alternative, this action is brought within 5 years of 2018 pursuant to R.C.

§ 2923.34(J).

157. Finally, in addition or as an alternative, this is the correct case for the court to apply

the doctrine of equitable estoppel, should said doctrine be needed as to any time period to make

Plaintiff’s claim timely.

158. To establish a prima facie case of equitable estoppel, a plaintiff must prove the

following elements: (1) that the defendant made a factual misrepresentation; (2) that it is

misleading; (3) [that it induced] actual reliance which is reasonable and in good faith; and (4)

[which causes] detriment to the relying party. See Perkins v. Falke & Dunphy, L.L.C., 2012-Ohio-

5799, ¶ 10.

159. Under Ohio law, the estoppel doctrine can be employed to prohibit inequitable use

of the statute of limitations. See Schrader v. Gillette, 48 Ohio App. 3d 181, 183, 549 N.E.2d 218,

221 (1988). “[O]ne cannot justly or equitably lull his adversary into a false sense of security, and

thereby cause the adversary to subject a claim to the bar of the statute of limitations.” Markese v.

Ellis (1967), 11 Ohio App.2d 160, 163, 40 O.O.2d 313, 315, 229 N.E.2d 70, 72.

 
{00193544.1} 45
 
 

160. “The purpose of equitable estoppel is to prevent actual or constructive fraud and to

promote the ends of justice.” Ohio State Bd. of Pharmacy v. Frantz, 51 Ohio St.3d 143, 145, 555

N.E.2d 630 (1990). “To invoke the doctrine as a bar to statute of limitations defense, however, the

plaintiff must be able to show the defendant's specific actions prevented the plaintiff from timely

filing the lawsuit.” Doe v. Archdiocese of Cincinnati, 116 Ohio St.3d 538, 2008-Ohio-67, 880

N.E.2d 892, ¶ 8–9. “For equitable estoppel to apply to toll a statute of limitations, a plaintiff must

demonstrate a defendant engaged in egregious wrongdoing or improper conduct upon which the

plaintiff reasonably relied and which prevented plaintiff from suing in time.” Boyd v. U.S., 932 F.

Supp. 2d 830 (S.D. Ohio 2013).

161. As of 2014, when Plaintiff reported to Loizzo of Morrier’s sexual abuse over a

period of three years, 2010-2013, the statute of limitations had no run on any claims or potential

claims Plaintiff may have had against any Defendants, nor had some of the actions brought herein

even accrued. Nevertheless, from that day on, Loizzo, individually and on behalf of Franciscan

University, and Davis, individually and on behalf of the Franciscan Friars, took fraudulent and

criminal action in concealing said conduct, and making fraudulent representation to Plaintiff upon

which she relied as hereinafter stated, in not seeking to file suit before now. Said fraudulent

misrepresentations and conduct as alleged throughout this Complaint are incorporated by reference

herein; but said particular fraudulent “statements of fact” by Loizzo and Davis relevant to

Plaintiff’s invocation, if necessary, of Equitable Estoppel doctrine herein include, but are not

necessarily limited to, the following:

a. Loizzo: Starting in 2014, and continuing up to the signing the “purported settlement

agreement” in 2015, Loizzo’s statements to Plaintiff that she had to keep Morrier’s

abuse in therapy in order to have her heal; that Loizzo would have to quit providing her

 
{00193544.1} 46
 
 

counseling services and that Plaintiff would lose the support of the Franciscan Friars if

she did not keep Morrier’s abuse in therapy; that Plaintiff’s illness had a “spiritual

component,” which he could treat, but not if she went to an attorney—that an attorney

could not help Plaintiff for the kind of problem she had; that Plaintiff’s report of same

would be devastating to Franciscan University, the Franciscan Friars and Plaintiff; that

the Franciscan Friars wanted to provide continuing help and financial support to

Plaintiff, which would end if Plaintiff moved the abuse “from therapy”; Loizzo

fraudulently representing to Plaintiff that Christian Brothers would do a psychological

evaluation of her and would fairly evaluate Plaintiff’s claim to determine the extent of

her damages resulting from the years of abuse, and that the Friars would help Plaintiff

and take care of her; Loizzo fraudulently advised Plaintiff that she needed to meet

Davis, alone, on August 20, 2015 and that he did not know what the meeting was about,

but that Plaintiff should go to this meeting and that it was to “help her out”; after

Plaintiff’s signing of the purported settlement agreement, Loizzo made statements to

Plaintiff such as: she had signed away her right to speak with a lawyer and could not

“disclose” the settlement agreement to others, which fraudulent fact Plaintiff believed

up until reporting same to the Steubenville Police Department in or about September,

2018; as well as his egregious conduct in fraudulently inducing Plaintiff’s signature on

the purported settlement agreement as described herein, all of which while Plaintiff was

under the complete spiritual, mental, and physical control of the cult(s) and Morrier as

described herein, by and through the efforts of Morrier and Loizzo, known to suffering

from an unsound mind, duress, and experiencing suicidal ideation with a plan.

 
{00193544.1} 47
 
 

b. Davis: his statement to Plaintiff that Franciscan University and the Francian Friars

believed Plaintiff to be complicit in the abuse by Morrier, and that the disclosure of the

abuse would be disastrous for her as well as Franciscan University and the Franciscan

Friars; promising Plaintiff that Morrier would never be put in a place of active ministry

again where he could do harm; and all his fraudulent statements and actions in

participating in, and leading up Plaintiff’s signing of the purported settlement

agreement, as hereinbefore stated in ¶ ______.

162. Plaintiff submits that this is just the type of “egregious and wrongful” conduct that

can trigger the application of the Equitable Estoppel to toll the statute of limitations pursuant to

Ohio law.

163. Plaintiff, under the above-mentioned circumstances, justifiably and reasonably

relied upon Defendants’ aforesaid fraudulent statements of fact given the nature of the cult(s) and

said Defendants’ complete spiritual, mental, and physical control of Plaintiff, and their

misrepresentations about Plaintiff not seeking an attorney and signing the purported August 20,

2015 settlement agreement while Plaintiff was of unsound mind, under duress, and/or experiencing

suicidal ideation with a plan.

164. Said fraudulent statements and fraudulent conduct of Loizzo even after the

purported settlement agreement of August 20, 2015 constitutes continuing fraud until Plaintiff

terminated her relationship with Loizzo in September of 2018; and accordingly, Plaintiff submits

that all of her claims did not accrue for statute of limitation until September of 2018.

165. As a result of actions of defendants as alleged above, Plaintiff has suffered severe

and permanent personal injuries as a result of Morrier’s multiple sexual batteries and other sexual

abuse of her from 2010 to 2013; economic loss in being directed and encouraged, to incur student

 
{00193544.1} 48
 
 

debt in the approximate amount of $500,000 over six years of higher education at Franciscan

University is a career that she is now virtually unable to perform or succeed in; only by causing

continuing and permanent psychological damage and limitations that will severely reduce her

opportunities for gainful employment; and has caused her to suffer severe emotional distress,

which will continue for the rest of her life; caused her a loss of her reputation in the community of

Steubenville Ohio, humiliation, inconvenience, and impairment of the quality of her life in the

future; and such other damages in an amount as yet unascertained, but in excess of $25,000 as will

be proven to a jury in Jefferson County, Ohio.

COUNT II
FRAUDULENT INDUCEMENT AGAINST DEFENDANTS LOIZZO, DAVIS, THE
UNIVERSITY, CHRISTIAN BROTHERS, GALLAGHER BASSET, FRANCISCAN
FRIARS, AND MORRIER

166. To bring a claim for fraudulent inducement a plaintiff must demonstrate: (1) an

actual or implied false representation concerning a fact or, where there is a duty to disclose,

concealment of a fact, (2) which is material to the transaction; (3) knowledge of the falsity of the

representation or such recklessness or utter disregard for its truthfulness that knowledge may be

inferred; (4) intent to induce reliance on the representation; (5) justifiable reliance; and (6) injury

proximately caused by the reliance.

167. Fraud in the inducement is subject to the four-year statute of limitations in R.C. §

2305.09.

168. Said Defendants fraudulently induced Plaintiff to sign the August 20, 2015

settlement agreement between Plaintiff and all Defendants.

169. Said Defendants made actual or implied false representations to Plaintiff

concerning facts of the settlement agreement and the circumstances surrounding the agreement

 
{00193544.1} 49
 
 

and/or said Defendants concealed facts when they had a duty to disclose said facts to Plaintiff.

Such actual or implied false representations and/or concealment of facts included, but were not

limited to: Loizzo’s 2015 statement to Friars that any payment by the Franciscan Friars to her was

only to help her out of her acute financial distress by “placing a value” on her damages resulting

from Morrier’s past wrongful conduct, but that the Franciscan Friars would continue to provide

spiritual and financial support to her even after they made such a payment to her; that before they

would do so their insurance company, Christian Brothers, would perform a full psychological

evaluation of her mental state; by Loizzo withholding and concealing information from Plaintiff

that what he, Davis, Christian Brothers, and Gallagher Basset were actually seeking was a “release

of all claims” to protect themselves, Morrier, and the University from legal action arising from

Morrier’s and their wrongful conduct toward Plaintiff. Said representations to Plaintiff and/or

concealment of facts from her prevented her from acquiring information relevant to what turned

out to be a purported “release agreement,” with Loizzo also representing to and convincing her

that she should not get an attorney involved in the “Morrier situation” because that would interfere

with her continuing spiritual treatment and future financial support by the Franciscan Friars.

Further actual and implied false representations and/or concealment of facts by Defendants

included: Loizzo’s and Davis’ statements to her that the Christian Brother had placed a value on

her damages at $50,000; statements by Davis, and the Franciscan Order, just before having

Plaintiff sign the purported settlement agreement, in writing on the face of the purported settlement

agreement that she had been given sufficient time to talk with an attorney about the agreement;

Davis’ statement to Plaintiff that the Franciscan Friars were paying her $50,000 for her damages

attributable to Morrier’s conduct, and an extra amount ($12,000) so that she could seek counseling

by a person other than Loizzo; Davis’ statement that the Franciscan Friars and University did not

 
{00193544.1} 50
 
 

believe her statements about Morrier, but were willing to pay her anyway; the withholding of

information by the University, Franciscan Friars, Loizzo, Davis, Christian Brothers or Gallagher

Basset that Plaintiff was going to be presented with a purported settlement agreement and release

of all claims against Morrier, the University, the Franciscan Friars, Loizzo, and Davis at the August

20, 2015 meeting requested by Davis with the corrupt assistance of Loizzo and Plaintiff being

required to sign said purported agreement at the same meeting; Davis’ statement to Plaintiff prior

to having her sign the purported settlement agreement that the University and Franciscan Friars

did not believe her allegations against Morrier; Davis’ statement to her prior to having her sign the

purported settlement agreement; the withholding of the information from Plaintiff prior to her

signing the purported settlement agreement that the University, Franciscan Friars, Loizzo, and

Davis of what information was used in the valuation of the claim; all of which said deceptive

conduct, false representation, and/or concealment of facts was the more egregious in the

aforesaid’s knowledge at the time of Plaintiff’s acute mental and financial duress, mental

incapacity, unsound mind, and suicidal ideation with a plan; the withholding of information

concerning said purported settlement agreement by Davis when he presented the agreement to

Plaintiff, and when she started to read it, his diverting her attention from being able to read it while

representing to her that he didn’t understand it either as it was just “legal mumbo jumbo”; and the

withholding from Plaintiff information contrary to what Loizzo had promised, that after accepting

the “value” of the claim as determined by Christian Brothers, that the Franciscan Order had no

intention of providing her with additional financial support.

170. As of the time of the signing of the purported settlement agreement, Defendant

Davis was acting not only individually, but in his role as Chair of the Board of Directors of the

 
{00193544.1} 51
 
 

University and Minister Provincial of the Franciscan Friars and/or the University and the

Franciscan Friars authorized and ratified such alleged conduct, with full knowledge.

171. Aforesaid actual or implied false misrepresentations and/or concealment of facts

were material in that under the circumstances said misrepresentations and/or concealment of facts

caused Plaintiff’s decision to sign the purported settlement agreement. As of the time of agreement,

Plaintiff was in dire financial distress (of which at least Defendants Loizzo, Davis, University, and

Franciscan Friars, were well apprised) and disposed to signing the agreement for financial relief.

Plaintiff had a long-running, fiduciary, patient-therapist relationship with Defendant Loizzo who

represented to her that the Friars would help her financially presently and in the future, as they had

in the past, and Plaintiff had no knowledge that Loizzo was machinating with Davis and the other

Defendants to lure Plaintiff into a settlement agreement, the details of which, she had no prior

knowledge of until the day of the settlement, and even then was prevented by Davis from even

reading the text of agreement other than the section about her having the time and opportunity to

consult an attorney. More so, and egregiously, Defendants Davis, Loizzo, Friars, and University,

Christian Brothers, and/or Gallagher Basset were aware of Plaintiff’s unsound mind and fragile

mental state and took advantage of her mental state to secure Plaintiff’s release of all claims against

Defendants by intending Plaintiff to rely on their misrepresentations and/or concealment.

Notwithstanding Christian Brothers and/or Gallagher Basset’s knowledge of Plaintiff’s mental

state at the time she signed, they ratified said unlawful conduct of said other Defendants thereafter,

with full knowledge.

172. As detailed above, Defendants had knowledge that their statements were false and

intended to mislead Plaintiff into relying on their false statement and/or concealment of facts. In

the case of Defendant insurers, Christian Brothers and/or Gallagher Basset, if they did not have

 
{00193544.1} 52
 
 

knowledge as to their statements’ falsity, they displayed recklessness or utter disregard for the

truth of their statements by never completing an actual valuation of Plaintiff’s damages and only

sought to release themselves and their clients from legal liability, and thereafter ratified said

conduct.

173. Plaintiff justifiably relied on the aforesaid statements by Defendants in that, as

discussed, she had a long-standing, fiduciary, patient-client relationship with Loizzo, whom she

trusted and sought guidance, and, as such, followed his counsel about the Friars (and Christian

Brothers) helping her and that the August 20, 2015 meeting was to “help her” and that she should

go to the meeting alone. Similarly, Loizzo used his position of trust with Plaintiff to direct her to

contact Davis in the months prior to the settlement agreement to ask for his and the Friar’s

assistance, and during that time prior to the settlement, the Friars had provided Plaintiff with

financial support and represented to her that they would assist Plaintiff financially (and spiritually).

Given this history and relationship between Loizzo and Plaintiff, and between Plaintiff and Friars,

Plaintiff had no reason to disbelieve their representations about the settlement, which were in fact

misrepresentations; and for the same reasons Defendants’ representations about the settlement did

not appear unreasonable to Plaintiff. Additionally, given Plaintiff’s continuing unsound mind and

the control that Loizzo maintained and exerted over Plaintiff, Plaintiff had further reason not to

disbelieve or find unreasonable Loizzo’s and Davis’ representations.

174. R.C. § 2305.16 excludes from the tolling of the statute of limitations, persons of

unsound mind. Upon information and belief, including, but not limited to, psychological

evaluation, Plaintiff believes to have been of unsound mind by virtue of her suffering from Post-

Traumatic Stress Disorder (PTSD), Disassociate Identity Disorder (DID), severe depression with

suicidal ideation with a plan, and otherwise under the complete spiritual, mental and physical

 
{00193544.1} 53
 
 

control of the Defendants and Cult(s) starting in 2010, and continuing until she was able to report

her sexual and psychological abuse to the Steubenville Police Department in September of 2018,

and thereafter terminate her counseling relationship with Loizzo at the suggestion of the

Steubenville Police Department.

175. The instant cause of action for Fraud in the Inducement is brought within 4 years

of September 2018 pursuant to R.C. § 2305.09.

176. In addition, Franciscan University and Franciscan Friars have fraudulently claimed

that they did not know of Plaintiff’s allegations until 2015. Plaintiff reported Morrier’s sexual

abuse to Scanlan in late 2010 or early 2011. Plaintiff again came forward with certain allegations

of sexual abuse (but not the actual sexual batteries) to Davis in 2013. Morrier was then removed

from FUS’s campus in Jefferson County, Ohio by Franciscan University and the Franciscan Friars

(believed to be institutionalized from May 2013 to October 2013), then assigned to a different

jurisdiction in Arlington, Texas wherein he served a ministry as if sexual abuse had not been

reported. Morrier was then assigned to Loretto, Pennsylvania. In 2015, it took approximately 21-

22 days to remove Morrier, where he was still engaged publicly with the Loretto Motherhouse,

including being publicly listed as a spiritual advisor, having a job title, being referred to as “Father”

publicly, and even a public celebration of his ordination/vows anniversary took place. Said

removal from the jurisdiction of Ohio was within a week of his last sexual assault.

177. Morrier continuously resided outside the jurisdiction from approximately May of

2013 until his conviction in March of 2022, at which time he has been living with others, or in jail

in this jurisdiction, but other than then had only been back for a few short visits believed to be

connected to his criminal prosecution before then.

 
{00193544.1} 54
 
 

178. O.R.C. § 2305.15 tolls the time a person is out of jurisdiction in that it provides that

“After the cause of action accrues if the person departs from the state, absconds, or conceals self,

the time of the person's absence or concealment shall not be computed as any part of a period

within which the action must be brought.”

179. Said tolling affects both Morrier, individually, and also as participant in the

Deliverance Ministry and/or the Community of God’s Love, and/or as an agent of Franciscan

University, and Franciscan Friars.

180. Similarly, after participating and acquiescence in the purported settlement

agreement referred to herein, the University and the Franciscan Friars removed Richard Davis

from the jurisdiction of Ohio, to Loretto, Pennsylvania, and Davis has thereof continuously been

residing there outside the jurisdiction of this Court, except for a few short trips back to the

jurisdiction.

181. O.R.C. § 2305.15 tolls the time a person is out of jurisdiction in that it provides that

“After the cause of action accrues if the person departs from the state, absconds, or conceals self,

the time of the person's absence or concealment shall not be computed as any part of a period

within which the action must be brought.”

182. Said tolling affects both Davis, personally, and also as agent of the Franciscan

University, and the Franciscan Friars.

183. In addition, Plaintiff did not know and/or appreciate the existence of the

Enterprise(s)’ use to facilitate fraud and other criminal acts until she learned of same during the

investigation of the Steubenville Police department starting in 2018, and continuing thereafter.

 
{00193544.1} 55
 
 

184. Loizzo’s multiple false statements of fraud, as well as the removal and concealment

of Morrier and Davis out of the jurisdiction of this Court constitute continuing fraud, tolling the

running of the statute of limitations until Loizzo was terminated in September of 2018.

185. In the alternative, said fraudulent statements constitute just such material facts that

the courts have recognized toll by virtue of the doctrine of equitable estoppel, as previously alleged

in ¶¶ ______ herein.

186. Due to Plaintiff’s reliance, of actions of Defendants as alleged above, Plaintiff has

suffered severe and permanent personal injuries as a result of Morrier’s multiple sexual batteries

and other sexual abuse of her from 2010 to 2013; economic loss in being directed and encouraged,

to incur student debt in the approximate amount of $500,000 over six years of higher education at

Franciscan University is a career that she is now virtually unable to perform or succeed in; only

by causing continuing and permanent psychological damage and limitations that will severely

reduce her opportunities for gainful employment; and has caused her to suffer severe emotional

distress, which will continue for the rest of her life; caused her a loss of her reputation in the

community of Steubenville Ohio, humiliation, inconvenience, and impairment of the quality of her

life in the future; and such other injuries and _______ as will be proven to a jury in Jefferson

County, Ohio. In addition to the extent that Plaintiff has lost any legal claims by virtue of the

running of the statute of limitations resulting from Defendants wrongful acts herein, she also lost

the full value of any such legal claims.

COUNT III
SEXUAL BATTERY AGAINST DEFENDANT MORRIER

187. Under Ohio law, battery is an intentional contact with another that is harmful or

offensive.

 
{00193544.1} 56
 
 

188. The statute of limitations for the tort of battery is one year. R.C. § 2305.111.

189. The State of Ohio has already convicted and sentenced Defendant Morrier for

criminal sexual battery (R.C. § 2907.03(A)(3)) against Plaintiff, an offense for which he is

currently incarcerated. Morrier was sentenced on March 11, 2022.

190. Between on or about October 2010 and Spring 2013 Defendant Morrier, under the

pretext of spiritual belief and practice, committed multiple sexual batteries upon the person of the

Plaintiff, wherein he abused his position of authority and trust, as spiritual director of Plaintiff, and

took advantage of Plaintiff’s unsound mind and fragile mental state to repeatedly, willfully, and

intentionally sexually abuse Plaintiff. Defendant’s horrendous sexual battery of Plaintiff is all the

more egregious given that Plaintiff sought spiritual and mental guidance and healing from Morrier,

with which he used to gain control over Plaintiff, immerse her in the cultish Deliverance Ministry

and/or Community of God’s Love, and ultimately used Plaintiff as the object of his perverse and

obscene sexual appetite while recklessly disregarding Plaintiff’s rights, safety, and well-being.

191. O.R.C. § 2305.15 tolls the time a person is out of jurisdiction.

192. The instant cause of action for Sexual Battery is brought within 1 year of March

2022 pursuant to R.C. § 2305.111.

193. As a result of actions of defendants as alleged above, Plaintiff has suffered severe

and permanent personal injuries as a result of Morrier’s multiple sexual batteries and other sexual

abuse of her from 2010 to 2013; economic loss in being directed and encouraged, to incur student

debt in the approximate amount of $500,000 over six years of higher education at Franciscan

University is a career that she is now virtually unable to perform or succeed in; only by causing

continuing and permanent psychological damage and limitations that will severely reduce her

opportunities for gainful employment; and has caused her to suffer severe emotional distress,

 
{00193544.1} 57
 
 

which will continue for the rest of her life; caused her a loss of her reputation in the community of

Steubenville Ohio, humiliation, inconvenience, and impairment of the quality of her life in the

future; and such other injuries as will be proven to a jury in Jefferson County, Ohio. 

COUNT IV
NEGLIGENT AND/OR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
AGAINST DEFENDANTS MORRIER AND LOIZZO

DEFENDANT MORRIER

194. To bring a claim for intentional and/or negligent infliction of emotional distress, a

plaintiff must show: (1) the defendant intended to cause, or knew or should have known that his

actions would result in serious emotional distress; (2) the defendant's conduct was so extreme and

outrageous that it went beyond all possible bounds of decency and can be considered completely

intolerable in a civilized community; (3) the defendant's actions proximately caused psychological

injury to the plaintiff; and (4) the plaintiff suffered serious mental anguish of a nature no reasonable

person could be expected to endure. Marconi v. Savage, 2013-Ohio-3805, ¶ 28.

195. Defendant Morrier, in his role as Plaintiff’s spiritual director from 2008 into 2013

in which he held a fiduciary duty toward Plaintiff (¶¶ . . .), was fully apprised of Plaintiff’s past

and recent history of severe trauma and sexual, physical, emotional, and psychological abuse, and

her contemporaneous and continuing fragile mental state that included suicidal thoughts and

ideation. Plaintiff divulged such information (e.g. abuse at the hands of her father, sexual assault

in 2008, the death of her grandparents, and the death by suicide of her close friend) to Morrier and

to Defendant Loizzo, who, as stated, worked in tandem to “treat” Plaintiff’s many and serious

mental health problems. Knowing of Plaintiff’s said vulnerable mental state and that she

experienced PTSD due to abuse by figures of trust and authority (e.g. her father), Morrier knew,

or at least should have known, that subjecting her to repeated violations of his position of trust and

 
{00193544.1} 58
 
 

confidence in which he sexually abused and sexually battered Plaintiff would cause her severe

emotional distress. Such obscene, perverted, abusive and harmful conduct by Morrier as alleged

herein is without doubt extreme, and well beyond all realms of decency and civilized behavior,

particularly given the fiduciary nature of their relationship. Said outrageous conduct by Morrier

directly and proximately caused Plaintiff serious emotional distress as such conduct caused her to

suffer new psychological and emotional trauma and the conduct triggered and exacerbated her

existing PTSD, flashbacks to past abuse, panic attacks, grief, suicidal thoughts and ideation, and

self-harm (cutting).

196. The severe mental anguish Morrier caused Plaintiff is of a type, like the outrageous

conduct itself, that no reasonable person could endure. Indeed, the extreme and perverted

environment that Morrier created around Plaintiff and the emotional distress she experienced and

continues to experience is of a type society wishes was confined to works of fiction, not the reality

of a vulnerable young woman who found hurt and pain from the person she trusted to help her.

197. Ordinarily, the statute of limitations for Intentional Infliction of Emotional Distress

is 4 years. R.C. § 2305.09. This claim is brought within 4 years of September 2018, during all of

which time Morrier was outside of jurisdiction of this court pursuant to R.C. § 2305.09.

198. O.R.C. § 2305.15 tolls the time a person is out of jurisdiction.

199. To the extent that Plaintiff’s instant cause of action for Intentional Infliction of

Emotional Distress falls under a 4-year statute of limitations, Plaintiff’s claim is timely filed within

4 years of September 2018. Alternatively, to the extent that Plaintiff’s instant cause of action for

Intentional Infliction of Emotional Distress falls under a 1-year statute of limitations, Plaintiff’s

claim is timely filed within 1 year of March 11, 2022, the date of Morrier’s sentencing and return

to Ohio jurisdiction.

 
{00193544.1} 59
 
 

200. In the alternative, this is a case for the application of Equitable Estoppel for the

fraudulent statements and actions of Defendant Morrier as herein set out in ¶¶ ______.

DEFENDANT LOIZZO

201. As with Defendant Morrier, Defendant Loizzo, as Plaintiff’s psychotherapist and

counselor, held a fiduciary relationship with Plaintiff and had a fiduciary duty toward her. (¶¶

from Breach of FD claim). Like Morrier, Loizzo was fully apprised of Plaintiff’s past and recent

history of severe trauma and sexual, physical, emotional, and psychological abuse, and her

contemporaneous and continuing fragile mental state that included suicidal thoughts and ideation.

Plaintiff divulged such information (e.g. abuse at the hands of her father, sexual assault in 2008,

the death of her grandparents, and the death by suicide of her close friend) to Morrier and to

Defendant Loizzo, who, as stated, worked in tandem to “treat” Plaintiff’s many and serious mental

health problems. Knowing of Plaintiff’s said vulnerable mental state and that she experienced

PTSD due to abuse by figures of trust and authority (e.g. her father), Loizzo knew, or at least

should have known, that subjecting her to the aforesaid emotionally, psychologically, and

physically strenuous and intensive deliverance sessions (group and individual) and exorcisms

would cause her severe emotional distress and harm. In a November 7, 2013 communication to

Defendant Davis, Loizzo informed Davis of his knowledge of the “emotional toll” the deliverance

and exorcism sessions had had on Plaintiff for several years. Loizzo wrote that “She and I spent

most of our time discussing the exorcisms or trying to get her to recover from the emotional distress

caused by the exorcisms. Her psychological condition became gravely worse throughout the course

of these ministries.” As such, while Loizzo had the capacity and authority to advise Plaintiff to

stop with the sessions, or to advise Morrier to put a stop to them, Loizzo did no such thing. Rather,

he negligently and/or intentionally allowed the emotionally distressing deliverance and exorcism

 
{00193544.1} 60
 
 

sessions to persist by continuing to recommend Plaintiff participate in such outrageous spiritual

“therapy.” In doing so, Loizzo’s key role in instructing Plaintiff to participate in the deliverance

and exorcism sessions is outrageous and extreme conduct for an individual in Loizzo’s position as

Plaintiff’s therapist and given the aforementioned mental state and history of Plaintiff.

202. Said outrageous conduct by Loizzo directly and proximately caused Plaintiff

serious emotional distress as such conduct caused her to suffer new psychological and emotional

trauma and the conduct triggered and exacerbated her existing PTSD, flashbacks to past abuse,

panic attacks, grief, suicidal thoughts and ideation, and self-harm (cutting).

203. The severe mental anguish Plaintiff suffered as a result of Loizzo’s actions is of a

type, like the outrageous conduct itself, that no reasonable person could endure.

204. Plaintiff’s cause of action for Intentional and/or Negligent Infliction of Emotional

Distress against Loizzo arises from Loizzo’s actions in his capacity as her therapist, and Enterprise

participant, and not due to any battery by Loizzo upon Plaintiff. Thus the statute of limitations for

Intentional Infliction of Emotional Distress is 4 years. R.C. § 2305.09.

205. Within R.C. § 2305.16 excludes from the tolling of the statute of limitations,

persons of unsound mind. Upon information and belief, including, but not limited to, psychological

evaluation, Plaintiff believes to have been of unsound mind by virtue of her suffering from Post-

Traumatic Stress Disorder (PTSD), Disassociate Identity Disorder (DID), severe depression with

suicidal ideation with a plan, and otherwise under the complete spiritual, mental and physical

control of the Franciscan Deliverance Cult starting in 2010, and continuing until she was able to

report her sexual and psychological abuse to the Steubenville Police Department in September of

2018, and thereafter terminate her counseling relationship with cult agent Loizzo at the suggestion

of the Steubenville Police Department.

 
{00193544.1} 61
 
 

206. As such, Plaintiff’s instant cause of action for Intentional and/or Negligent

Infliction of Emotional Distress against Defendant Loizzo is timely filed within 4 years of

September 2018 pursuant to R.C. § 2305.09.

207. Similarly, under the doctrine of continuing fraud, the tolling of the statute of

limitations for Plaintiff’s Intentional and/or Negligent Infliction of Emotional Distress claim

against Loizzo runs from the time in or about Spring 2014, when Loizzo first fraudulently

represented to Plaintiff that should she not get an attorney until sometime after September 2018

when Plaintiff learned, as a result of the police investigation of Morrier, of Defendants’ fraudulent

conduct, and/or terminated her relationship with Loizzo.

208. In the alternative, said fraudulent statements constitute just such material facts that

the courts have recognized toll by virtue of the doctrine of equitable estoppel, as previously alleged

in ¶¶ ______ herein.

209. As a result of actions of defendants as alleged above, Plaintiff has suffered severe

and permanent personal injuries as a result of Morrier’s multiple sexual batteries and other sexual

abuse of her from 2010 to 2013; economic loss in being directed and encouraged, to incur student

debt in the approximate amount of $500,000 over six years of higher education at Franciscan

University is a career that she is now virtually unable to perform or succeed in; only by causing

continuing and permanent psychological damage and limitations that will severely reduce her

opportunities for gainful employment; and has caused her to suffer severe emotional distress,

which will continue for the rest of her life; caused her a loss of her reputation in the community of

Steubenville Ohio, humiliation, inconvenience, and impairment of the quality of her life in the

future; and such other damages in an amount as yet unascertained, but in excess of $25,000 as will

be proven to a jury in Jefferson County, Ohio.

 
{00193544.1} 62
 
 

COUNT V
BREACH OF FIDUCIARY DUTY AGAINST DEFENDANTS LOIZZO,
MORRIER, DAVIS, TOR, AND FRANCISCAN UNIVERSITY OF STEUBENVILLE

DEFENDANT LOIZZO

210. To bring a claim for breach of fiduciary duty, a Plaintiff must demonstrate: (1) the

existence of a duty arising from a fiduciary relationship; (2) a failure to observe the duty; and (3)

an injury resulting proximately therefrom.

211. Under Ohio law, a fiduciary relationship is one in which special confidence and

trust is reposed in the integrity and fidelity of another and there is a resulting position of superiority

or influence, acquired by virtue of this special trust. See First Natl. Bank of Omaha v. iBeam Sols.,

L.L.C., 2016-Ohio-1182, ¶ 29, 61 N.E.3d 740, 754. A fiduciary duty entails a higher of standard

of care than negligence. Est. of Rusche v. Harker, 2001-Ohio-4357, ¶ 28, 118 Ohio Misc. 2d 1, 9,

769 N.E.2d 424, 430.

212. Social workers and counselors are guided by codes of ethical practice. R.C. 4757.11

and 4757.36(A)(10). See Cervone v. Boris, No. 96 CA 191, 1999 WL 689223, at *2 (Ohio Ct.

App. Aug. 27, 1999). The code of ethical practice and professional conduct constitutes the

standards by which the professional conduct of counselors, social workers, and marriage and

family therapists shall be measured. Each subject area is in a separate rule within Chapter 4757-5

of the Administrative Code.

213. The Ohio Counselor and Social Worker Board oversees licensed social workers and

counselors in the state and set the professional practice standards by which social workers and

counselors operate. The board subscribes to codes of ethics and practice standards for counselors,

social workers, and marriage and family therapists promulgated by the "American Counseling

 
{00193544.1} 63
 
 

Association" and the "National Association of Social Workers" and the "American Association for

Marriage and Family Therapy". These association standards shall be used as aids in resolving

ambiguities which may arise in the interpretation of the rules of professional ethics and conduct,

except that the board's rules of standards of ethical practice and professional conduct shall prevail

whenever any conflict exists between these rules and the professional association standards.

Chapter 4757-5-1 of the Administrative Code.

214. At all relevant times, Defendant Loizzo held a Master’s of Social Work (MSW)

degree and was a professional licensed Independent Social Worker in the state of Ohio, where he

practiced psychotherapy counseling at the FUS Wellness Center (of which he was the director),

and in private practice. From 2008 to 2018 Plaintiff was Defendant Loizzo’s counseling client and

Loizzo was her psychotherapist. Loizzo and the FUS Wellness Center, which offers counseling

and psychotherapy services to FUS students, represent to potential clients that all of the counselors

are licensed by the state of Ohio to practice psychotherapy counseling.

215. Due to the ethical and professional standards governing Loizzo’s professional

practice as a psychotherapist, the high degree of trust that Plaintiff, as a client, placed in Loizzo to

help her with her significant mental health issues, the professional, clinical knowledge and

authority that Loizzo held in diagnosing Plaintiff’s ailments (e.g. PTSD), and the significant

authority that Loizzo held over Plaintiff regarding how she should pursue her best interests, Loizzo

held a fiduciary duty toward Plaintiff.

216. Further, under Ohio law, psychotherapist, such as Loizzo, have a fiduciary duty to

clients based on confidentiality that mirrors the fiduciary duty of confidentiality held by other

mental health and health care professionals and lawyers, and breach of such fiduciary duty of

confidentiality provides a cause of action. OH ADC 4757-5-02(D). See also Biddle v. Warren Gen.

 
{00193544.1} 64
 
 

Hosp., 1999-Ohio-115, 86 Ohio St. 3d 395, 401, 715 N.E.2d 518, 523, citing MacDonald v.

Clinger (1982), 84 A.D.2d 482, 446 N.Y.S.2d 801.

217. Similarly, under Ohio law, psychotherapist, such as Loizzo, have fiduciary duty of

informed consent as to client services and clients consent to such services. OH ADC 4757-5-02(B).

This fiduciary duty of informed consent mirrors the fiduciary duty of informed held by other

mental health and health care professionals, and breach of such fiduciary duty of informed consent

provides a cause of action. See Est. of Leach v. Shapiro, 13 Ohio App. 3d 393, 395, 469 N.E.2d

1047, 1052 (1984). Additionally, like the physician-patient relationship, Loizzo, as a

psychotherapist held a fiduciary relationship with his clients, like Plaintiff, that obligated him to

exercise good faith in treating and advising Plaintiff. See Tracy v. Merrell Dow Pharms., Inc., 58

Ohio St. 3d 147, 150, 569 N.E.2d 875, 879 (1991).

218. As stated in OH ADC 4757-5-02(B)(3), “If a client because of age or mental

condition is not competent to provide informed consent, the licensee shall obtain consent from the

parent, guardian, or court appointed representative.” Plaintiff was not competent and of unsound

mind and under Loizzo’s and Morrier’s sway in summer and the fall of 2008 when Loizzo agreed

with Morrier that Morrier be apprised of what occurred in Plaintiff’s counseling sessions with

Loizzo. Loizzo then breached his overall fiduciary duty and fiduciary duty of good faith when he

convinced Plaintiff that Morrier’s participation in her counseling was in Plaintiff’s best interest.

Because Plaintiff was of unsound mind, she could not have validly consented to this arrangement

and thus Loizzo also breached his fiduciary duty of confidentiality toward Plaintiff as Loizzo

expressly allowed Morrier to know what happened during Plaintiff’s counseling sessions with

Loizzo.

 
{00193544.1} 65
 
 

219. At least as egregious as these aforesaid breaches, due to Plaintiff’s unsound mind,

she could not have provided her informed consent to Deliverance Ministry practices and exorcisms

that Loizzo convinced her would treat her mental health problems during the 2008 – 2013 time

period. OH ADC 4757-5-02(A)(5) states: “All counselors, social workers and marriage and family

therapists shall use All counselors, social workers and marriage and family therapists shall use

techniques/ procedures/ modalities in diagnosing and treating mental and emotional disorders that

are grounded in theory and/or have an empirical or scientific foundation, otherwise, they shall

define the techniques/ procedures as “unproven” or “developing” and explain to their clients the

potential risks and ethical considerations of using such techniques/ procedures and take steps to

protect clients from possible harm., otherwise, they shall define the techniques/ procedures as

“unproven” or “developing” and explain to their clients the potential risks and ethical

considerations of using such techniques/ procedures and take steps to protect clients from possible

harm.” Loizzo not only breached his overall fiduciary duty and fiduciary duty of good faith when

he convinced Plaintiff that her mental health issues were “spiritual” in nature and then encouraged

and convinced her to engage in Morrier’s Deliverance Ministry and be subjected to multiple

exorcisms, he breached his fiduciary obligation to act in Plaintiff’s best interest when he helped

arrange exorcisms and Deliverance Ministry practices that were not “techniques/ procedures/

modalities [used] in diagnosing and treating mental and emotional disorders that are grounded in

theory and/or have an empirical or scientific foundation.”

220. Likewise, Loizzo breached his fiduciary duty of informed consent when he had

Plaintiff “consent”, when she was of unsound mind, to exorcisms and Deliverance Ministry

practices that were not recognized and “proven” modalities of treatment, and Loizzo did not

explain to her that such “techniques” were unproven, the ethical considerations involved in her

 
{00193544.1} 66
 
 

participating in such “techniques”, nor that such “techniques” could harm Plaintiff. Additionally,

Loizzo breached his fiduciary duty of informed consent when he handed over his primary

responsibility for Plaintiff’s treatment to Morrier and his cult during the 2008-2013 time frame

and allowed Morrier to treat Plaintiff’s “spiritual” component through the Deliverance Ministry

and exorcisms.

221. Loizzo admitted his breach of informed consent when he wrote Fr. Richard Davis

in November 2013, informing Davis that he allowed Morrier “spiritual ministry, deliverance, and

exorcisms” to be Plaintiff’s primary form of therapy. In allowing Morrier, not a licensed

psychotherapist or mental health professional, to be Plaintiff primary counselor/therapist, Loizzo

“thought that Fr. Dave being a priest probably knew better that I did about the extent of

preternatural involvement in [Plaintiff’s] life.” Breaching his fiduciary duty led to a situation in

which Plaintiff’s therapy with Loizzo “was for all practical purposes put on hold since all of her

energy and attention and the emotional toll it took on her prevented any meaningful psychological

treatment from occurring.” Loizzo’s admission to breaching his fiduciary duty is all the more

distressing because he knew Plaintiff “became more distressed before and after each of these

sessions” (i.e. Deliverance Ministry and exorcisms) and he had doubts as to the “sessions” efficacy

on treating Plaintiff’s mental health conditions. Nonetheless, Loizzo continued in his breach,

which in his words, led to a situation in which “Her psychological condition became gravely worse

throughout the course of these ministries.”

222. R.C. § 2305.09 provides a four-year statute of limitations for breach-of-fiduciary-

duty claims.

223. Within R.C. § 2305.16 excludes from the tolling of the statute of limitations,

persons of unsound mind. Upon information and belief, including, but not limited to, psychological

 
{00193544.1} 67
 
 

evaluation, Plaintiff believes to have been of unsound mind by virtue of her suffering from Post-

Traumatic Stress Disorder (PTSD), Disassociate Identity Disorder (DID), severe depression with

suicidal ideation with a plan, and otherwise under the complete spiritual, mental and physical

control of the Franciscan Deliverance Cult starting in 2010, and continuing until she was able to

report her sexual and psychological abuse to the Steubenville Police Department in September of

2018, and thereafter terminate her counseling relationship with cult agent Loizzo at the suggestion

of the Steubenville Police Department.

224. As such, Plaintiff’s instant cause of action for Breach of Fiduciary Duty against

Defendant Loizzo is timely filed within 4 years of September 2018 pursuant to R.C. § 2305.09.

225. In the alternative, this is a case for the application of Equitable Estoppel for the

fraudulent statements and actions of Defendant Loizzo as herein set out in Paragraphs _________.

226. As a result of Loizzo’s breach of fiduciary duty, Plaintiff suffered and continues to

suffer severe psychological and emotional injury which have also damaged her professional life

and will continue to seriously injure and impair her future professional life and economic earnings.

DEFENDANT MORRIER

227. As with Defendant Loizzo, Defendant Morrier held a fiduciary relationship with

Plaintiff and thus had a fiduciary duty to her. Morrier, as Plaintiff’s spiritual director from 2008

into 2013, held a special position of trust and confidence toward Plaintiff, who placed said trust

and confidence in Morrier to help her overcome her many serious mental health and psychological

problems that Morrier, and Loizzo, convinced her were of a spiritual nature. This fiduciary

relationship was also characterized by Plaintiff divulging intimate and personal information (such

as her past physical, psychological, and sexual abuse) to Morrier as part of their spiritual director

– directee relationship. Great disparity in power between Morrier and Plaintiff was another key

 
{00193544.1} 68
 
 

feature of the fiduciary relationship between them, which empowered Morrier to exert great

influence and control over Plaintiff and enabled Morrier to exploit the trust, confidence, and

dependency of Plaintiff for his benefit.

228. While Morrier acted as Plaintiff’s spiritual director, ecclesiastical matters were not

and did not define the substance of their relationship. Rather, as stated, Plaintiff’s mental and

emotional health issues, not her “spiritual” being, were the problems to be fixed by Morrier, who

worked in tandem with Loizzo. Further, sexual, psychological, emotional, and physical abuse are

not spiritual direction or counseling. Instead, Morrier, from 2008 into 2013, under the pretext of

religious and church authority, used his director/counseling position and the intimate, personal

information Plaintiff divulged, to inflict abuse and harm upon Plaintiff for his own perverted sexual

gratification. In such blatantly exploitative scenarios as here, First Amendment religious freedom

protections are unavailable to purported religious actors. See Strock v. Pressnell, 38 Ohio St.3d

207, 527 N.E.2d 1235, 1238 (1988).

229. R.C. § 2305.09 provides a four-year statute of limitations for breach-of-fiduciary-

duty claims.

230. Within R.C. § 2305.16 excludes from the tolling of the statute of limitations,

persons of unsound mind. Upon information and belief, including, but not limited to, psychological

evaluation, Plaintiff believes to have been of unsound mind by virtue of her suffering from Post-

Traumatic Stress Disorder (PTSD), Disassociate Identity Disorder (DID), severe depression with

suicidal ideation with a plan, and otherwise under the complete spiritual, mental and physical

control of the Franciscan Deliverance Cult starting in 2010, and continuing until she was able to

report her sexual and psychological abuse to the Steubenville Police Department in September of

 
{00193544.1} 69
 
 

2018, and thereafter terminate her counseling relationship with cult agent Loizzo at the suggestion

of the Steubenville Police Department.

231. As such, Plaintiff’s instant cause of action for Breach of Fiduciary Duty against

Defendant Morrier is timely filed within 4 years of September 2018 pursuant to R.C. § 2305.09.

232. Similarly, Franciscan University and Franciscan Friars have fraudulently claimed

that they did not know of Plaintiff’s allegations until 2015. Plaintiff reported Morrier’s ongoing

sexual abuse to Scanlon in late 2010 or early 2011. Plaintiff again came forward with her

allegations to Davis in 2013. Morrier was then removed from FUS’s campus in Jefferson County,

Ohio by Franciscan University and the Franciscan Friars (believed to be institutionalized from

May 2013 to October 2013), then assigned to a different jurisdiction in Arlington, Texas wherein

he served a ministry as if sexual abuse had not been reported. Morrier was then assigned to Loretto,

Pennsylvania. In 2015, it took approximately 21-22 days to remove Morrier, where he was still

engaged publicly with the Loretto Motherhouse, including being publicly listed as a spiritual

advisor, having a job title, being referred to as “Father” publicly, and even a public celebration of

his ordination/vows anniversary took place. Said removal was within a week of his last sexual

assault. Morrier continuously resided outside the jurisdiction from approximately May of 2013

until his conviction in March of 2022, at which time he has been living with others, or in jail in

this jurisdiction, but other than then had only been back for a few short visits believed to be

connected to his criminal prosecution before then.

233. O.R.C. § 2305.15 tolls the time a person is out of jurisdiction.

234. Said tolling affects both Morrier, individually, and also as agent and participant of

the Deliverance Ministry and/or the Community of God’s Love, as an agent of Franciscan

University, and Franciscan Order.

 
{00193544.1} 70
 
 

235. In addition, Plaintiff did not know and/or appreciate the existence of the Enterprise

and its facilitation of fraud and other criminal acts until she learned of same during the

investigation of the Steubenville Police department starting in 2018, which also tolls the satute of

limitations until at the earliest, September, 2018.

236. Similarly, under the doctrine of continuing fraud as referred to in ¶¶ _____ herein,

the tolling of the statute of limitations for this claim runs from the time in or about Spring 2014,

when Loizzo first fraudulently represented to Plaintiff that should she not get an attorney until

sometime after September 2018 when Plaintiff learned, as a result of the police investigation of

Morrier, of Defendants’ fraudulent inducement, and terminated her relationship with Loizzo.

237. As a result of actions of defendants as alleged above, Plaintiff has suffered severe

and permanent personal injuries as a result of Morrier’s multiple sexual batteries and other sexual

abuse of her from 2010 to 2013; economic loss in being directed and encouraged, to incur student

debt in the approximate amount of $500,000 over six years of higher education at Franciscan

University is a career that she is now virtually unable to perform or succeed in; only by causing

continuing and permanent psychological damage and limitations that will severely reduce her

opportunities for gainful employment; and has caused her to suffer severe emotional distress,

which will continue for the rest of her life; caused her a loss of her reputation in the community of

Steubenville Ohio, humiliation, inconvenience, and impairment of the quality of her life in the

future; and such other damages in an amount as yet unascertained, but in excess of $25,000 as will

be proven to a jury in Jefferson County, Ohio.

COUNT VI
UNJUST ENRICHMENT AGAINST DEFENDANTS CHRISTIAN BROTHERS,
GALLAGHER BASSETT, LOIZZO, MORRIER, FRANCISCAN UNIVERSITY,
FRANCISCAN FRIARS, DAVIS
 

 
{00193544.1} 71
 
 

238. The elements of a cause of action for unjust enrichment are: (1) a benefit conferred

by the plaintiff on the defendant, (2) knowledge of the benefit by the defendant, and (3) retention

of the benefit by the defendant in circumstances where it would be unjust to do so.

239. A claim for unjust enrichment is subject to a six-year limitations period set forth in

R.C. § 2305.07.

240. When Defendants fraudulently induced Plaintiff to sign the purported settlement

agreement on August 20, 2015, Plaintiff conferred the monetary benefit of her sexual battery claim

against Defendant Morrier and potential other claims against Defendants for their role in fostering,

authorizing, legitimizing, and/or concealing Morrier’s conduct toward Plaintiff. While Defendants

Christian Brothers, Gallagher Bassett, Loizzo, Morrier, Franciscan University, Franciscan Friars,

and Davis asserted they would assess and place a value on Plaintiffs damages arising from

Morrier’s sexual abuse against Plaintiff, no such valuation occurred. Defendants instead secured

Defendants’ full release from “any and all claims” Plaintiff may have against Defendants and,

upon information and belief, Defendant insurers only provided funds calculated to cover Plaintiff’s

tuition and living expenses for the next year, along with purported extra funds for Plaintiff to see

a therapist. Said release, procured by fraud, between Plaintiff and Defendants for any and all claims

Plaintiff may have against Defendants is a discernable benefit that Plaintiff conferred on

Defendants.

241. Defendants were aware that the actual value (i.e. one calculated by valuation) of

Plaintiff’s sexual abuse claim against Morrier and “any and all claims” that Plaintiff may have

against Defendants were of benefit to Defendant insurers and would exceed the amount Defendants

provided Plaintiff through the August 20, 2015 “settlement”. In the days prior to the signing of the

purported settlement, Defendant Loizzo well summarized the “benefit” conferred on Defendants

 
{00193544.1} 72
 
 

when he remarked to Defendant Davis, who was in contact with Defendant insurers, that the

“amount of money she [Plaintiff] indicated to you was a small price to pay in my opinion for

helping her while keeping this entirely confidential.”

242. Since the signing of the purported settlement on August 20, 2015, Defendants have

retained said benefit under circumstances of procuring said benefit through fraudulent inducement

and continuing fraud as alleged throughout Plaintiff’s complaint. Under the circumstances of

Defendants’ fraud and continuing fraud, Plaintiff as victim of Defendants’ corruption and

Enterprise, and Plaintiff being of unsound mind at the time she signed the purported settlement,

Defendants retention of said is unjust.

243. A claim for unjust enrichment is subject to a six-year limitations period set forth in

R.C. § 2305.07.

244. Within R.C. § 2305.16 excludes from the tolling of the statute of limitations,

persons of unsound mind. Upon information and belief, including, but not limited to, psychological

evaluation, Plaintiff believes to have been of unsound mind by virtue of her suffering from Post-

Traumatic Stress Disorder (PTSD), Disassociate Identity Disorder (DID), severe depression with

suicidal ideation with a plan, and otherwise under the complete spiritual, mental and physical

control of the Franciscan Deliverance Cult starting in 2010, and continuing until she was able to

report her sexual and psychological abuse to the Steubenville Police Department in September of

2018, and thereafter terminate her counseling relationship with cult agent Loizzo at the suggestion

of the Steubenville Police Department.

245. The instant cause of action for Unjust Enrichment is brought within 6 years of

September 2018 pursuant to R.C. § 2305.07.

 
{00193544.1} 73
 
 

246. In the alternative, this is a case for the application of Equitable Estoppel for the

fraudulent statements and actions of Defendant insurers as herein set out in Paragraphs ____.

247. Wherefore, Defendant insurers as a matter of equity should be compelled to

disgorge the full amount of their unjust enrichment in an amount to be proven at trial.

COUNT VII
DEFAMATION CLAIM FOR SLANDER AGAINST THE FRANCISCAN UNIVERSITY
AND FRANCISCAN FRIARS

248. Plaintiff incorporates by reference as if fully set out herein the allegations of

paragraphs _____though ________of the present complaint.

249. Since on or about March 11, 2022, when Plaintiff publically read her Victim

Impact Statement in connection with that certain criminal proceeding in the Court of Common

Pleas of Jefferson County, Ohio, styled ___________, Defendants, upon information and belief,

have made certain public statements to the Community of God’s Love, and the greater Steubenville

Ohio community, to the effect that has made up or fabricated the story about her years

of sexual and psychological abuse by Defendant Morrier; that she is just seeking “money” for her

years of abuse by falsely claiming student debt incurred by her as a result of said abuse to continue

her education at Franciscan University; that she is “more dangerous” to the community than

Morrier ever was; that the University and Franciscan Friars did not learn of the abuse until 2015,

implying that Plaintiff was lying about having sought to report it earlier, and that said relationship

was consensual; and otherwise, by blaming her for causing harm to the University and Franciscan

Friars in coming forward with her publicly exposure of the abuse of Morrier with the complicity

and/or prior knowledge of the University and/or Franciscan Friars..

250. As a result of said defamatory statements, the University and Franciscan Friars have

caused Plaintiff to have been shunned by the Community of God’s Love; have caused her to live

 
{00193544.1} 74
 
 

in fear of retaliation by members of the Community of God’s Love and other members of the

Franciscan University or Franciscan Friars Community; has caused exacerbation of her continuing

PTSD, severe mental depression and psychological impairments and damage, and have caused her

to suffer severe emotional distress, loss of reputation in the community, humiliation,

inconvenience, and other impairment of her ability to enjoy life, all of which damages are in an

amount ascertained at this time, but well in excess of $25,000.

251. Ohio Revised Code Section ______ provides that a claim for defamation based on

slander must be brought by Plaintiff within one (?) year of said defamatory conduct.

252. This action is timely brought under said statutory provision in that said slanderous

statements have been made at times unknown, but within the year since giving her Victim Impact

Statement referred to above on or about March 11, 2022.

COUNT VIII
 DECLARATORY JUDGMENT ACTION

253. R.C. § 2721.02 provides: “Courts of record may declare rights, status, and other

legal relations whether or not further relief is or could be claimed. No action or proceeding is open

to objection on the ground that a declaratory judgment or decree is prayed for. The declaration

may be either affirmative or negative in form and effect. Such declaration has the effect of a final

judgment or decree.”

254. R.C. § 2721.03 provides in part: “Any person interested under a deed, will, written

contract, or other writing constituting a contract, or whose rights, status, or other legal relations

are affected by a constitutional provision, statute, rule as defined in section 119.01 of the Revised

Code, municipal ordinance, township resolution, contract, or franchise, may have determined any

question of construction or validity arising under such instrument, constitutional provision, statute,

 
{00193544.1} 75
 
 

rule, ordinance, resolution, contract, or franchise and obtain a declaration of rights, status, or other

legal relations thereunder.”

255. Civ.R. 57 provides: “The procedure for obtaining a declaratory judgment pursuant

to Sections 2721.01 to 2721.15, inclusive, of the Revised Code, shall be in accordance with these

rules. The existence of another adequate remedy does not preclude a judgment for declaratory

relief in cases where it is appropriate.”

256. The three essential prerequisites for a declaratory judgment claim are: (1) a real

controversy between the parties, (2) the controversy is justiciable, and (3) speedy relief is necessary

to preserve the rights of the parties.

257. First, a real, substantial, and immediate controversy exists between the parties as

Plaintiff alleges that the settlement agreement between her and Defendants was procured by

fraudulent inducement and Plaintiff would not have entered into the agreement but for Defendants’

extensive fraud. Further, said settlement continues to bind Plaintiff to its terms and conditions

which have denied Plaintiff her lawful right to pursue claims against Defendants, as set forth in

Plaintiff’s instant Complaint.

258. Second, a declaration of the rights and obligations of all parties who may be

affected thereby will resolve the aforesaid controversy and the Court is within its established

authority to determine the validity of the settlement agreement.

259. Third, speedy relief is necessary to preserve the rights of the parties as Plaintiff has

continued to suffer denial of her lawful right to bring claims against Defendants because of the

settlement and Plaintiff’s ability to bring said claims is perilously near the end of statute of

limitations for each claim as set forth in each count in the instant Complaint.

 
{00193544.1} 76
 
 

260. Wherefore, Plaintiff requests that a Declaratory Judgment be entered in her favor,

declaring as follows:

(a): That the August 20, 2015 settlement is void or voidable because of Defendants’

fraudulent inducement of Plaintiff, and the Plaintiff and Defendants are released from the

settlements’ terms and conditions and Defendants are enjoined from exercising their rights under

the settlement.

(b): Plaintiff will, if the Court determines it equitable, reimburse Defendants the proceeds

she received from the August 20, 2015 settlement.

261. The statute of limitations for a declaratory judgment action is determined by the

underlying nature or subject matter of the claim. See Naiman Fam. Partners, L.P. v. Saylor, 2020-

Ohio-4987, ¶ 13, 161 N.E.3d 83, 87.

262. Defendants’ fraudulent inducement of Plaintiff to sign the August 20, 2015

settlement agreement is the underlying subject matter of Plaintiff seeking a declaratory judgment

action regarding said “settlement.” Thus, the statute of limitations for Plaintiff’s declaratory

judgment action is the same as her claim for fraud in the inducement, 4 years, as set forth in R.C.

§ 2305.09.

263. Within R.C. § 2305.16 excludes from the tolling of the statute of limitations,

persons of unsound mind. Upon information and belief, including, but not limited to, psychological

evaluation, Plaintiff believes to have been of unsound mind by virtue of her suffering from Post-

Traumatic Stress Disorder (PTSD), Disassociate Identity Disorder (DID), severe depression with

suicidal ideation with a plan, and otherwise under the complete spiritual, mental and physical

control of the Franciscan Deliverance Cult starting in 2010, and continuing until she was able to

report her sexual and psychological abuse to the Steubenville Police Department in September of

 
{00193544.1} 77
 
 

2018, and thereafter terminate her counseling relationship with cult agent Loizzo at the suggestion

of the Steubenville Police Department.

264. The instant Declaratory Judgment action is brought within 4 years of September

2018 pursuant to R.C. § 2305.09.

265. Similarly, Franciscan University and Franciscan Friars have fraudulently claimed

that they did not know of Plaintiff’s allegations until 2015. Plaintiff reported Morrier’s ongoing

sexual abuse to Scanlan in late 2010 or early 2011. Plaintiff again came forward with her

allegations to Davis in 2013. Morrier was then removed from FUS’s campus in Jefferson County,

Ohio by Franciscan University and the Franciscan Friars (believed to be institutionalized from

May 2013 to October 2013), then assigned to a different jurisdiction in Arlington, Texas wherein

he served a ministry as if sexual abuse had not been reported. Morrier was then assigned to Loretto,

Pennsylvania. In 2015, it took approximately 21-22 days to remove Morrier, where he was still

engaged publicly with the Loretto Motherhouse, including being publicly listed as a spiritual

advisor, having a job title, being referred to as “Father” publicly, and even a public celebration of

his ordination/vows anniversary took place. Said removal was within a week of his last sexual

assault. Morrier continuously resided outside the jurisdiction from approximately May of 2013

until his conviction in March of 2022, at which time he has been living with others, or in jail in

this jurisdiction, but other than then had only been back for a few short visits believed to be

connected to his criminal prosecution before then.

266. O.R.C. § 2305.15 tolls the time a person is out of jurisdiction.

267. Said tolling affects both Morrier, individually, and also as agent and participant of

the Deliverance Ministry and/or the Community of God’s Love, as an agent of Franciscan

University, and Franciscan Order.

 
{00193544.1} 78
 
 

268. Similarly, after participating and acquiescence in the purported settlement

agreement referred to herein, the University and the Province removed Richard Davis from the

jurisdiction of Ohio, to Loretto, Pennsylvania, and Davis has thereof continuously been residing

there outside the jurisdiction of this Court, except for a few short trips back to the jurisdiction.

269. O.R.C. § 2305.15 tolls the time a person is out of jurisdiction.

270. Said tolling affects both Davis, personally, and also as agent and participant of the

Deliverance Ministry and/or the Community of God’s Love, as an agent of Franciscan University,

and the Franciscan Order.

271. In addition, Plaintiff did not know and/or appreciate the existence of the Enterprise

and its facilitation of fraud and other criminal acts until she learned of same during the

investigation of the Steubenville Police department starting in 2018, and this action is timely

brought.

272. In the alternative, the various acts of fraud by the Deliverance Ministry and/or

Community of God’s Love constitutes continuing fraud, which fraud, includes but is not limited

to, multiple false statements of continuing fraud, as did the removal and concealment of Morrier

and Davis out of the jurisdiction of this Court constitute continuing fraud, tolling the running of

the statute of limitations until Loizzo was terminated in September of 2018.

273. In the alternative, said fraudulent statements and conduct constitute just such

material facts that the courts have recognized toll by virtue of the doctrine of equitable estoppel,

as referred to in paragraphs _____ herein.

Wherefore, Plaintiff prays for compensatory damages and punitive damages to fully

redress her injuries herein, on any or all of the Counts herein.

PLAINTIFF REQUESTS A TRIAL BY JURY.

 
{00193544.1} 79
 
 

Respectfully submitted,
 
, Plaintiff,
 
 
 
By: /s/ , Esq.
Of Counsel
 

 
{00193544.1} 80