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 1)
I depose and say as follows:
1. I am currently a resident of I was born on
2, I grew up in an orphanage in Haiti called Central Daccueil in Carrefour. The
conditions in Central Daccueil were poor and all of the children in my orphanage wanted to
move to the orphanage of Mr. Geilenfeld, as it was nicer and had better food.
3. In 1996 I was sent to live in Mr. Geilenfeld’s orphanage. At that time I was 17
years old. Mr. Geilenfeld liked me and wrote a book about my story. I was very happy to be
living in his orphanage as the conditions were very good.
4. After moving into Mr. Geilenfeld’s orphanage, I started hearing rumors that Mr.
Geilenfeld was gay and that there were problems in the orphanage.
5. Mr. Geilenfeld would often invite one of the kids to his room to play cards at
night. Kids would receive money and candy. One night, he invited me to play cards with him at
night. While in his room, Mr. Geilenfeld started rubbing my back and asking me what my
dreams were. I told him that I wanted to go to the United States. He told me he could get me to
the United States.
6. One day he invited me to his room and kissed me on the mouth and grabbed my
penis. I was 17 years old at that time. Later that same day he bought me a walkman and gave
me tapes to play on it.
7. In the months after he gave me the walkman, Mr. Geilenfeld would tell me often
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2. how much he liked me. One day he invited me to his room and gave me new clothes. On this
occasion he put his hand in my pants and felt my penis and said he likes that very much.
8. I discussed this with my friend who also lived at the orphanage. old me
that Mr. Geilenfeld had done the same thing to him.
9. One day I confronted Mr. Geilenfeld, reminding him that he promised me a visa
to get to the United States. I asked him how he would get me to the United States without a visa
or passport. He took me back to his room, promised that he could get me to the United States,
and on this occasion he put his mouth on my penis.
10. Towards the end of the time I lived in Mr. Geilenfeld’s orphanage, a group of kids
from the United States came to visit the house. One of the visitors from North Carolina was
named Kate. I don’t remember her last name. I told Kate about what Mr. Geilenfeld was doing
with the kids at the orphanage. Kate left for the airport on a Friday to return to the United States.
On the day that Kate left, I went to the market to buy food for the orphanage. When I returned
from the market I was told by security that I could not come back inside the house. All of my
clothes were brought out of the house and I was sent to Wings of Hope, which is an orphanage
for disabled children that is not as nice as the orphanage that Mr. Geilenfeld lived in.
16. From time to time I would return to Mr. Geilenfeld’s orphanage. Kids who lived
in the orphanage would sneak food out to me. At some point Mr. Geilenfeld confronted me,
gave me an envelope with approximately $30 and told me that he never wanted to see me again.
Later, an employee of Mr. Geilenfeld gave me approximately $40 which I used to travel to the
Dominican Republic. Later, I moved to the United States where I currently live. I met Mr.
Kendrick and shared my story with him.
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3. Subscribed and sworn to by me on this 15th
day of May, 2013
/s
STATE OF MAINE
CUMBERLAND, ss. May 15, 2013
Personally appeared the above-named who first being duly sworn made
oath that the foregoing affidavit which he has signed and to which he subscribes is based on his
own personal knowledge and that the facts set forth therein are true.
Before me,
___/s/F. David Walker1
__________
Notary Public/Attorney-at-Law
1
Counsel personally witnessed the Declarant’s signature on May 15, 2013. Counsel
subsequently signed above the Notary Public/Attorney-at-Law on May 31, 2013.
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