COMPLAINT FILED 10/17/14 IN US FEDERAL COURT IN CONNECTICUT / EXCERPT
105. From approximately 1999 to 2005 when Plaintiff Bernard Michel was approximately 11 to 16 years of age, Defendant Father Carrier, while in Haiti, engaged in explicit sexual behavior and lewd and lascivious behavior with Plaintiff, including but not limited to illicit sexual acts with Plaintiff.
106. Without limiting either the generality of the immediate preceding paragraph or the specific number of instances of illicit conduct, during the time period referenced in the immediate preceding paragraph, Defendant Father Carrier coerced Plaintiff into performing illicit sexual conduct by means of implicit threats to Plaintiff. Among other things, Father Carrier fondled Plaintiff's genitals and had Plaintiff perform fellatio on Father Carrier.
107. Without limiting either the generality of the two immediate preceding paragraphs or the specific number of instances of illicit conduct, during the time period referenced above, Defendant Father Carrier provided things of value to Plaintiff in return for illicit sexual conduct, including, among other things, drawing supplies, clothes and food. Plaintiff understood that to continue to be able to attend PPT, eat meals provided by PPT, and receive an education at PPT, Plaintiff had to allow Father Carrier to sexually abuse Plaintiff.