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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Case 2:13-cv-00039-JAW Document 27-3 Filed 05/20/13 Page 1 of 2 PageID #: 164

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. told 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. 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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Case 2:13-cv-00039-JAW Document 27-3 Filed 05/20/13 Page 2 of 2 PageID #: 165