1. UNITED STATES DISTRICT COURT DISTRICT OF MAINE HEARTS WITH HAITI, INC. ) and MICHAEL GEILENFELD, ) ) Plaintiffs ) ) v. ) Civil No. 2:13-CV-00039 ) PAUL KENDRICK, ) ) Defendant )
DECLARATION OF PURSUANT TO 28 U.S.C. § 1746 (DECLARATION 2) I being duly sworn, state as follows:
1. I am a resident o My date of birth i
2. I first met Michael Geilenfeld in 1983. Michael Geilenfeld was a Catholic Brother with Mother Theresa's Missionaries of Charity. Mr. Geilenfeld and the other Brothers would provide food to the young people in the area. Eventually, Mr. Geilenfeld invited me to live in the Brothers' house. Initially there were two of us children living in the house. I was approximately ten years old when I moved in with Mr. Geilenfeld.
3. When I moved in with Mr. Geilenfeld, I slept in a porch area with another child on a mattress on the floor. Mr. Geilenfeld used to come on to the porch and would sleep between us on the mattresses. During this time, Mr. Geilenfeld would kiss me and the other boy on the lips and play with my penis. He told us that he was our boyfriend. Later he began putting his mouth on my penis.
4. In 1984 Mr. Geilenfeld left Haiti and I continued to live with the Brothers.
5. Mr. Geilenfeld returned to Haiti in 1985. When he returned he was no longer a Catholic Brother.
6. When he returned to Haiti, Mr. Geilenfeld initially got a two room apartment and invited me and later four other children to move in with him. All of the children were under the age of 18. While living at the apartment Mr. Geilenfeld continued to molest me. He would touch my penis and put it in his mouth.
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7. Later, Mr. Geilenfeld bought a house and more Haitian children moved into his orphanages.
8. In addition to the sexual abuse, Mr. Geilenfeld would physically abuse me. He would spit on my face, slap, and punch me.
9. Approximately 20 kids lived in the house with me. I stayed in Mr. Geilenfeld's house until 1989.
11. In the late 1980s, I participated in a travelling dance troop that Mr. Geilenfeld organized to travel to the United States in order to raise money for his orphanages. This was called the Resurrection Dance Theater.
12. In 1986 or 1987, I was travelling with the Resurrection Dance Theater on a trip in Boston. On this trip, Mr. Geilenfeld came to me and said that members of the Resurrection Dance Theater had told the local Haitian community about being sexually abused by him. He asked me to go and tell the boys not to speak about the abuse because the orphanages would lose money. He gave me $50 and asked me to speak with the boys.
13. I continued to live in the house until 1989, at which point I moved to the United States.
14. In 2011, I learned of Paul Kendrick and his work regarding Haitian children. I made contact with Mr. Kendrick and told him my story about what had happened to me and what I had seen at Mr. Geilenfeld's orphanage in Haiti.
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.
Executed on May 15, 2013 /s CERTIFICATE OF SERVICE I, F. David Walker, IV, Esq., hereby certify that on May 20, 2013, I served the Declaration o electronically on counsel for Plaintiffs. /s/F. David Walker, IV F. David Walker, IV, Esq. Rudman Winchell
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