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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MAINE

HEARTS WITH HAITI, INC., et al.

Plaintiffs

v.

PAUL KENDRICK,

Defendant

CIVIL ACTION: 2:13-CV-00039-JAW

PLAINTIFF MICHAEL K. GEILENFELD’S

DECLARATION PURSUANT TO 28 U.S.C. § 1746

I, Michael K. Geilenfeld, depose and say as follows:

1. My name is Michael K. Geilenfeld.

2. I am a Plaintiff in the above-captioned matter.

3. I have devoted my life to enriching the lives of children in Haiti, the United

States, and abroad, and am the founder and executive director of St. Joseph Family of Haiti, an

organization that operates a network of nonprofit institutions that provide residence, room and

board, formal education, and religious education to hundreds of disabled and disadvantaged

Haitian children.

4. I have never engaged in a sexual act with anyone under the age of eighteen, and I

directly communicated that fact to Defendant Paul Kendrick February 3rd, 2011. Attached hereto

as Exhibit 1, is a true and accurate copy of e-mail correspondence dated February 3rd, 2011

between and amongst me, Kendrick, and others.

5. I have never engaged in any unlawful sexual act.

6. Neither I nor St. Joseph Family of Haiti has or had any association with Douglas

Perlitz, Project Pierre Toussaint, or Fairfield University. I have never met Douglas Perlitz or

visited Project Pierre Toussaint nor has Douglas Perlitz ever visited any institution operated by

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St. Joseph Family of Haiti.

7. Nevertheless, since January 2011 and continuing to present, Kendrick has

attempted to destroy me and St. Joseph Family of Haiti by targeting St. Joseph Family of Haiti’s

benefactors, volunteers, and fundraisers with false and heinous allegations of child sex abuse,

child neglect, malnourishment, and other mistreatment, financial impropriety, and other

deplorable conduct.

8. To date, Kendrick’s concerted efforts to destroy me, St. Joseph Family of Haiti,

and Hearts with Haiti has caused an estimated $1,582,810.56 loss in revenue, withheld or

reduced donations, withheld or reduced grant moneys, cancelled Resurrection Dance Tour of

Haiti performances, and cancelled reservations at the St. Joseph Family of Haiti guest house.

9. Information supporting valuation of pecuniary losses was produced by my

attorneys in the above-captioned matter to Kendrick’s counsel April 12th, 2013.

10. For example, attached hereto as Exhibit 2, is a true and accurate copy of e-mail

correspondence between and amongst Paul D’Oliveira, Hearts with Haiti board member and

Rotarian, and several Rotary International members in which a $38,000 grant to purchase a

Toyota SUV to transport disabled children at Wings of Hope to and from physical therapy was

cancelled because of Kendrick’s false allegations of child sex abuse.

11. Attached hereto as Exhibit 3, is a true and accurate copy of e-mail correspondence

dated April 27th, 2013 in which a July, 2013 reservation at the St. Joseph Family of Haiti guest

house valued at $8,750.00 (residence for twenty-five persons for seven days at $50 per day per

person) was cancelled by Edenton Street United Methodist Church because of Kendrick’s false

allegations of child sex abuse and financial impropriety.

12. Attached hereto as Exhibit 4, is a true and accurate copy of e-mail correspondence

dated January 31st, 2011 from Kendrick to St. Theresa’s Parish in Milwaukee, Wisconsin, a

benefactor of St. Joseph Family of Haiti. This is the earliest known communication from

Kendrick concerning me or St. Joseph Family of Haiti.

13. Attached hereto as Exhibit 5, is a true and accurate copy of e-mail correspondence

dated January 31st, 2011 from Kendrick to Hearts with Haiti board member Dr. Rolvix

Patterson.

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14. Attached hereto as Exhibit 6, is a true and accurate copy of e-mail correspondence

dated February 1st, 2011 from Kendrick to St. Cecelia’s Parish in Boston, Massachusetts, a

significant benefactor of St. Joseph Family of Haiti.

15. Attached hereto as Exhibit 7, is a true and accurate copy of e-mail correspondence

from Kendrick to numerous “blind-copied” third parties in which he solicited “sex abuse victims

of Michael Geilenfeld” for a “free consultation” with a plaintiffs’ lawyer in Boston,

Massachusetts.

16. Attached hereto as Exhibit 8, is a true and accurate copy of e-mail correspondence

from Kendrick to McGinley Media, Ltd. and several third parties targeting a 10-year-old boy,

Aiden Sommers, who helped create a software application for the benefit of Hearts with Haiti

and St. Joseph Family of 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 5, 2013 /s/ Michael Geilenfeld

Michael K. Geilenfeld

Executive Director, St. Joseph Family of

Haiti

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