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Port au Prince, 4th of November 2015

To:
Chief of the Tribunal of Premiere Instance
of Port au Prince
Palace of Justice
Court of Action

Honorable Chief,

The following individuals, Xxxxxxx Xxxx, Xxxx Xxxxxxx, Xxxxxxx Xxxxxx, Xxxxxxx Xxxxx, Xxxxxx Xxxxxxxx, Xxxxxxxxx Xxxxxxxx, Xxxxxxxxxx Xxxxxx, are all identified respectively and nationally as:  xx-xx-xx-xxxx-xx-xxxx, xx-xx-xx-xxxx-xx-xxxx, xx-xx-xx-xxxx-xx-xxxx, xx-xx-xx-xxxx-xx-xxxx, xx-xx-xx-xxxx-xx-xxxx, who reside in the Port au Prince area, and are legally represented by Chief Attorney Jacky C. Pierre, Advocat au Barreau of Croix-de Bouquets, identified by his license number 003-329-303-7, B-1551599, B-1551601, with is offices located at 361 Angle Rue Stenio Vincent et Grande Plaine, Croix-des-Bouquets.

Please permit me to explain:

The above charges brought by the court of Port au Prince against Michael Geilenfeld for rape and sexual aggression.  After legal consultation with the magistrate judge of Petion-ville, at the request of the court on 22nd October, 2015 a search warrant was issued to investigate at the orphanage located at Delmas 91, in order to confirm the physical presence of minors and to take all the testimony and evidence into custody.  During this process, three minors were found at the property, this, after he had been ordered to not have minors on site.  This resulted in a warrant being issued against Michael Geilenfeld for sexual aggression, rape and abuse of authority.  Michael Geilenfeld was to go  in front of the court to explain the acts committed on the victims.  He was no where to be found, thus an immediate arrest warrant was issued.

Furthermore, a letter was addressed to the responsible parties of the St. Joseph’s Home for Boys Orphanage dated the 31st of January 2014 by the Haitian Child Welfare Services, known as l’institut bien-etre social et de recherches (IBESR) which simply ordered the orphanage to close down for abuse and taking advantage of the vulnerability and insecurity of minors, meanwhile the doors of the orphanage remained open which is against the law.

Recent information, coming from informed sources lead us to believe that American donors, and other contributors are still sending money to this orphanage on behalf of Michael Geilenfeld for his administration which should have already been closed according to the formal instructions of IBESR.

In consideration of the above, the plaintiffs, request the Honorable Doyer, to allow the provincial court judge of Petion-ville or his subordinates to take immediate action to seal the gates and doors of the St. Joseph’s Home for Boys Orphanage at Delmas 91, and to secure all fixtures and furniture, and keep them safe from Michael Geilenfeld’s use.  Moreover, equally order all banks, namely Unibank, Sogebank, Banque Nationale de Credit, Capital Bank, Banque Populaire Haitienne and other to place a hold on the accounts so that no funds will be disbursed, or transferred on accounts belonging to St Joseph Home for Boys, Wings of Hope and Trinity House Orphanages and Michael Geilenfeld and all who are responsible for the orphanages until the final decision of the competent court authority.  This is to be carried out by a bailiff from your court for the following request.

Deepest Respects.

Jacky C. Pierre, av

Order of the Court

I, Bernard Sainvil, Provincial Court Judge of Port au Prince; have reviewed the request of the article above and the other documents in the file.

Considering that the plaintiffs have presented reasonable grounds to support the demand to seal the property and block the funds from the bank, that are given the authorization to freeze the accounts associated with the orphanages of St. Joseph Home for Boys, Wings of Hope and Trinity House in the name of Michael Geilenfeld and/or any other responsible parties.

Considering the law:
Permits a Justice of the Peace of Petion-ville or his charges to act to seal the gate, the entrance doors and the furniture and fixtures and affects in the house at the orphanage of St. Joseph Home for Boys at 91 Delmas, in the Petion-Ville community; Formally order the banks, namely Unibank, sogebank, capital bank, banque nationale de credit, to block, and freeze the money of the orphanage of St. Joseph Home for Boys, Wings of Hope and Trinity House in the name of Michael Geilenfeld and/or other responsible parties.  Commit the bailiff Josue Cadet of the Tribunal to take necessary action to carry out this order; The urgency of this permits the use of any means necessary to carry out this ordinance from the date signed below.

Signed at the palace of justice the 4th of November, 2015.

Bernanrd Sainvil, Magistrate Judge

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