CLERK OF STATE COUNTY, GEORGIA GWINNETT COUNTY, GEORGIA 21-C-01799-8 3/9/2021 11:04 A¶
IN THE STATE COURT OF GWINNETT COUNTY¶
STATE OF GEORGIA¶
MICHAEL K. GEILENFELD¶
PLAINTIFF¶
V.¶
VALERIE DIRKSEN, INDIVIDUALLY, AND IN HER ROLE AS PRESIDENT OF INTERNATIONAL CHILDREN’S RIGHTS ADVOCATES SOCIETY, INC.,¶
Civil Action File Number:¶
21-C-01799-S4¶
AND¶
INTERNATIONAL CHILDREN’S RIGHTS ADVOCATES SOCIETY, INC.¶
DEFENDANTS.¶
JURY TRIAL DEMANDED¶
COMPLAINT FOR DAMAGES¶
Comes now Plaintiff, Michael K. Geilenfeld, and makes this Complaint against Defendants and respectfully show the Court the following:¶
1.¶
The Defendant INTERNATIONAL CHILDREN’S RIGHTS ADVOCATES SOCIETY, INC., hereinafter, ICRAS, is a corporation licensed to operate in the State of Georgia, and may be served through its registered agent, Sarah Dirksen, at her address, 1595 CHATTAHOOCHEE RUN DRIVE, SUWANEE, GWINNETT COUNTY, GA, 30024.¶
2.¶
The Defendant VALERIE DIRKSEN, INDIVIDUALLY, AND IN HER ROLE AS PRESIDENT OF INTERNATIONAL CHILDREN’S RIGHTS ADVOCATES SOCIETY, INC. is a resident of the State of Georgia. She may be served where she resides in 1595 CHATTAHOOCHEE RUN DRIVE, SUWANEE, GWINNETT COUNTY, GA. 30024.¶
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Defendants are subject to the jurisdiction and venue of this Court by virtue of their status as a joint wrongdoer or joint tortfeasor with the other Defendants.¶
4.¶
Venue of this action is proper in this court pursuant to O.C.G.A. § 14-2-510(b)(1) as Defendant corporation maintains its registered office here and Defendant VALERIE DIRKSEN, INDIVIDUALLY, AND IN HER ROLE AS PRESIDENT OF INTERNATIONAL CHILDREN’S RIGHTS ADVOCATES SOCIETY, INC is a resident of Gwinnett County.¶
BACKGROUND INFORMATION¶
Plaintiff Michael Geilenfeld, a former Brother with the Missionary Brothers of Charity, is the founder of St. Joseph Family of Haiti, hereinafter “SJF”, which operates a network of nonprofit institutions that provide residence, room & board, formal education, and religious training and education to disabled and disadvantaged Haitian children.¶
6.¶
In addition to St. Joseph Family of Haiti, Plaintiff Michael Geilenfeld founded Casa De Los Dos Rios in Higuey, Dominican Republic which provides support to disadvantaged adults and children in the Dominican Republic by supplying food, financial, and educational support to the poorest families in the area.¶
7.¶
SJF operates St. Joseph Community Outreach Center, Wings of Hope, and Leköl Sen Trinite. The SJF, which was founded by Michael in 1985 as a refuge for formerly destitute street¶
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children, grew quickly into a residence and school for more than 30 former child slaves, street children, and orphans, and led to subsequent other ministries (Wings of Hope, Leköl Sen Trinite).¶
8.¶
At the Outreach Center, the children received permanent residence, room and board, meals, arts and vocational training, and formal academic education outside the home, among other accommodations.¶
9.¶
In or around 2011, a self-proclaimed “journalist” named Paul Kendrick began to publish numerous defamatory statements against Plaintiff Michael Geilenfeld and the above-referenced organizations, falsely claiming Plaintiff sexually abused children.¶
10.¶
On or about January 31, 2011, Mr. Kendrick emailed several of the organizations’ benefactors, spreading such vile falsehoods that Plaintiff Geilenfeld sexually abused children.¶
11.¶
On or about February 1, 2011, Mr. Kendrick admitted to his associate, Bonnie Elam, that he could not and did not verify the veracity of the false statements he spread.¶
12.¶
Despite Mr. Kendrick’s admission stated in paragraph 11, however, he continued to spread the vile and disgusting allegations to several of the organizations’ benefactors.¶
13.¶
On or about February 6, 2013; a lawsuit was filed by Hearts with Haiti, Inc. and above-referenced Plaintiff Michael Geilenfeld against Paul Kendrick for defamation, false light, and¶
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tortious economic interference, CA: 2:13-cv-00039-JAW in United State District Court, District in Maine.¶
14.¶
On or about February 21, 2014, Defendant Valerie Dirksen was deposed as a nonparty witness in the CA: 2-13-cv-00039-JAW case.¶
15.¶
During that deposition, Defendant Valerie Dirksen testified that she heard Plaintiff Geilenfeld could not go to Detroit and Boston, due to the accusations stated above in or around May of 2011.¶
16.¶
Defendant Valerie Dirksen testified that she met with Homeland Security Investigators related to the sexual abuse allegations at St. Joseph’s Home in or around June 2, 2011.¶
17.¶
After the meeting described in paragraph 16, Defendant Valerie Dirksen was told the sexual abuse allegations were old, and that Plaintiff Michael Geilenfeld was innocent.¶
18.¶
On July 23, 2015, a 10-person jury in the USDC returned unanimous verdicts in favor of Hearts with Haiti, Inc. and Michael Geilenfeld against Paul Kendrick, finding that Mr. Kendrick negligently defamed Plaintiff Geilenfeld, that Plaintiff Geilenfeld had proven, by clear and convincing evidence, that Mr. Kendrick defamed him knowing the sexual abused statements were false, or with reckless disregard for their truth; that Mr. Kendrick placed Plaintiff Geilenfeld in a false light; and that Mr. Kendrick intentionally interfered with the advantageous economic relations of Plaintiff Geilenfeld.¶
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Defendant Valerie Dirksen was in attendance during the trial described in paragraph 18, including when the jury returned unanimous verdicts in favor of Hearts with Haiti, Inc. and Michael Geilenfeld, vindicating his name of the vile sexual misconduct allegations described above.¶
On April 27, 2017, the CA: 2-13-cv-00039-JAW case in USDC, District of Maine, was dismissed for lack of subject matter jurisdiction.¶
Substantially the same complaint was filed in the State of Maine Superior Court, CA: CV16-313, a copy of which was delivered to Defendant Valerie Dirksen on or about April 19. 2018.¶
GENERAL ALLEGATIONS¶
The CA: CV-16-313 case settled on August 27, 2019.¶
On February 18, 2020, Defendant Valerie Dirksen published via Facebook, an article titled, “This Guy Hunts Down Pedophiles and Beats Them with a Hammer.” Within the comments portion of her post, Defendant Valerie Dirksen published, “…That is why I have been advocating for the victims of the serial child abuser Michael Geilenfeld…” See attached screenshot of the post.¶
On January 8, 2020, Defendant Valerie Dirksen published via Facebook, an article about Plaintiff Michael Geilenfeld, falsely accusing him of sexual abuse. The article is titled, “Michael¶
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Geilenfeld Accused of Sexual Abuse for over 30 years – Stop Sexual Abuse in Haiti,” and the article depicts a picture of Plaintiff Michael Geilenfeld. See attached screenshot of the post.¶
On January 9, 2020, Defendant Valerie Dirksen published via Facebook, an article tying Jeffrey Epstein and Plaintiff Michael Geilenfeld stating, in pertinent part, “…We the people need to take back the justice system… The same is true for multiple accused pedo with current Arrest warrant and red interpol arrest warrant for rape, sexual aggression and abuse of title. Catholic Archbisoph Gregory was told about this abuse by Michael Geilenfeld of orphans in his care in Haiti in 2003!” See attached Facebook post.¶
On January 24, 2020, Defendant Valerie Dirksen published via Facebook, an article titled “Ocnam Dameus; the Government [Prosecutor] who signed the arrest warrant for multiple accused pedophile Michael Geilenfeld…,” essentially claiming that Plaintiff Michael Geilenfeld was found innocent of the vile allegations because someone had attempted to shield and protect him. See attached Facebook post.¶
A publisher named “SPEAK Project” had apparently spoken with Defendant Valerie Dirksen, in her role as President of Defendant ICRAS, where she asked SPEAK Project “to help ensure the safe-keeping of several young people who had testified against accused pedophile mobboss Michael Geilenfeld…” Such discussion was published on February 16, 2020 by SPEAK Project via the internet on its website, projectspeak.net. See attached article.¶
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Defendant Valerie Dirksen, individually and in her role as President of ICRAS, intentionally and/or negligently caused her discussion with SPEAK Project described in paragraph 27 to be published.¶
In the article published by SPEAK Project described in paragraph 27, in her role as President of Defendant ICRAS, Defendant Valerie Dirksen encouraged others to donate to the cause and directed viewers to Defendant ICRAS, website, ICRAS8.com.¶
On or about October 12, 2019, Defendant Valerie Dirksen, individually, and in her role as President of ICRAS, had written and had SPEAK Project publish, an article titled, “Michael Geilenfeld – Accused Serial Pedophile,” including a picture of Plaintiff.¶
At the end of article described in paragraphs 27 and 28, Valerie Dirksen, individually and in her role as President of ICRAS, intentionally and/or negligently caused her article described in paragraph 30 to be published again on February 16, 2020.¶
On February 18, 2020, Defendant Valerie Dirksen, individually, and in her role as President of ICRAS, published an article she drafted via Facebook. Within that article, Defendant Dirksen stated, “…The Haitian Timoun Foundation is one of several fundraising arms for the multiple accused pedophile, Michael Geilenfeld…,” among several statements, tying alleged sexual misconduct, again, to Plaintiff.¶
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33.¶
On February 18, 2020, Defendant Valerie Dirksen published via Facebook, an article titled, “Shock in Haiti to Learn Burned Church Orphanage had Budget of $6M.” Within her post, Defendant Valerie Dirksen published a comment, stating, “They had the protections of minors from the DCPJ… the same authorities who have testimony from over 20 victims of a serial child abuser, Michael Geilenfeld… See attached Facebook post.¶
34.¶
On July 31, 2020, Defendant Valerie Dirksen published a video from Glenn Beck discussing documents that were unsealed in a case involving Jeffrey Epstein. Within her post, Defendant Valerie Dirksen tied Plaintiff to Epstein, and published, “They all think they can get away with this: ThNk God there is an active arrest warrant in Haiti and interpol arrest warrant for Michael Geilenfeld.” See attached Facebook post.¶
35.¶
Upon information and belief, as of July 31, 2020, however, no “active arrest warrant” existed regarding Plaintiff. Defendant Dirksen was informed that warrant numbered 294 had long been withdrawn.¶
36.¶
On July 31, 2020, Defendant Valerie Dirksen published an article titled, “Louisiana Upholds Life Sentence to Black Man for Stealing Hedge Trimmers in 1997.” With the article, she posted, “Can’t he get a pardon? That is someone who deserves a pardon!” Within the comments of her publication, Defendant Valerie Dirksen commented and published, “… but pedos like Michael Geilenfeld who have red Interpol arrest warrants walks free? Geilenfeld is charged with rape, sexual aggression and abuse of title of the orphans in his case and he was dropped off at JFK¶
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airport by the Dominican police because the Americans would not pick him up. This makes me sick!” See attached Facebook post.¶
On August 13, 2020, Defendant Valerie Dirksen published via Facebook, an article titled, “Executive Order Blocking the Property of Persons Involved in Serious Human Rights Abuse or Corruption,” commenting, “Does that mean they will go after Michael Geilenfeld?” See attached Facebook post.¶
On August 16, 2020, Defendant Valerie Dirksen published via Facebook, an article titled, “Clergy Sexual Abuse Settlements.” Within her publication, Defendant Valerie Dirksen stated, “…Shameful and disgraceful! Archbishop Gregory in DC has known about a serial pedo who associated himself with Mother Teresa’s Missionaries of Charities as the first American brother Michael Geilenfeld who has an arrest warrant and red Interpol arrest warrant…” See attached Facebook post¶
On August 27, 2020, Defendant Valerie Dirksen published via Facebook, an article titled, commenting with her post, “another one… friends with Michael Geilenfeld” and tying the accusatory statements about the priest to Plaintiff. See attached Facebook post.¶
On December 17, 2020, Defendant Valerie Dirksen published via Facebook, an article titled, “Epstein’s “rapist” pal Jean-Luc Brunel arrested for ‘sex trafficking models,’” commenting with her post, “Brunel, not his real name was detained. It’s a good day. Interesting that the man¶
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wife of multiple accused child abuser of orphans in Haiti, michael geilenfeld, who has active arrest Aggression and abuse of title, is named Brunel too!” See attached Facebook post.¶
41.¶
On January 25, 2021, Defendant Valerie Dirksen published via Facebook, a video titled, “Stanley Lucas has done a lot of harm to Haiti, you should listen to how he created an organization to break the ass of Haiti. With her post, Defendant Valerie Dirksen published, “Stanley Lucas with multiple accused American pedophile Michael Geilenfeld in Haiti. He is very aware of the problem with human trafficking in Haiti!” See attached Facebook post.¶
42.¶
On January 30, 2021, Defendant Valerie Dirksen published via Facebook, an article titled, “Late Mother Teresa’s Order Investigate for Child Trafficking in India.” With her post, Defendant Valerie Dirksen published, “Isn’t that interesting. She was connected to an American [Michael Geilenfeld] who operated orphanages in Haiti and was accused over 10 times of sexually, physically, and emotionally, abusing orphans and abandoned children in his care. There is an outstanding arrest warrant and red Interpol arrest warrant in Haiti for his arrest. He was dropped off at JFK by Dominican police because the DR snd Haiti do not have an extradition agreement. Don’t you think the victims deserve justice? Why do people at local churches like Epiphany Lutheran Church support the pedophile but not the victims? Where has everyone gone? What about all that “brother we got your back” crap? More lies? Very sad to think all the churches are involved and so is Rotary International past President Barry Rasin. Rassin was listed as a major donor to Michael Geilenfeld but refused to help the victims. Is everything fake? See attached Facebook post.¶
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On February 4, 2021, Defendant Valerie Dirksen published via Facebook, an article titled, “German nuns ‘rented’ orphaned boys to businessmen for ‘gang bangs & orgies’ – suppressed report seen by media.” With her post, Defendant Valerie Dirksen published, “The report was so gory it was not suitable for public viewing”. Well, there was a nun who worked with Michael Geilenfeld. She took her habit off on weekends to party. She was in a lesbian relationship with one of the directors. Um ok ok. But the thing that made you really pause, was when you heard about the gay couples who would call her to say they would be in Haiti for a week, and needed an 8 year old boy. That really paralysed me. Imagine the poor orphan who would be chosen. I was thinking to myself, did he know? Was he excited at first to think he would have a week of fun and ice cream? This has continued despite the US embassy knowing what is happening in American run orphanages and ibesr the CPS of Haiti and the highest ranking members of government knowing. There is no circling back on this for me. Everyone who turned their back on the children of Haiti are responsible. There are a lot of guilty parties! See attached Facebook post.¶
44.¶
On February 23, 2021, Defendant Valerie Dirksen published via Facebook, a video depicting an image of Plaintiff Michael Geilenfeld, with the words, “Sexual Abuse in Haiti. Children trafficking in Haiti’s orphanages.” See attached Facebook post.¶
45.¶
On February 24, 2021, Defendant Valerie Dirksen published via Facebook an article, and stated, “You see how these people are fundraising and spreading propaganda through the churches? The ST joseph home for boys was never full of street kids. It was closed down in 2015 because the founder Michael Geilenfeld and his supporters were involved in sexually, emotionally¶
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and physically abusing the children in the house. There is a $3.27 bil us business in Haiti. Human trafficking is happening in these orphanages that are unregulated and unlicensed. St joseph home for boys was not licensed. Does the person on this video from the church not realize there is an arrest warrant and red Interpol arrest warrant out for Geilenfeld? The us embassy knows, the Dominicans know, former chief of police Gideon knows, current chief Leon Charles knows! They all know. How can this woman snd her church not know? Is she paid to do this? Who wrote her script? She is welcome to call me to discuss ways to help the victims become survivors!” See attached Facebook post.¶
COUNT I: LIBEL AND DEFAMATION PER SE¶
Plaintiff references and incorporates the foregoing paragraphs as if fully set forth and alleged herein.¶
Defendant Valerie Dirksen’s false and malicious statements of Plaintiff Michael Geilenfeld as published to the general public via Facebook and various other publications, as described in General Allegations of this complained, continue to injure Plaintiff Michael Geilenfeld’s reputation and continue to expose him to public hatred, contempt, and ridicule.¶
Defendant Valerie Dirksen, Individually, and in her role as President of ICRAS, and Defendant ICRAS knew or should have known, by virtue of her discussions with the Homeland Security Investigators and her attendance of the Maine lawsuit, that the vile and disgusting statements she continues to attribute to Plaintiff Michael Geilenfeld are false and will forever injure his reputation and subject him to public hatred, contempt, and ridicule.¶
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Defendant Valerie Dirksen, Individually, and in her role as President of ICRAS’s actions and conduct are imputed to Defendant ICRAS.¶
Pursuant to O.C.G.A. § 51-5-1, such statements constitute libel.¶
As a direct and proximate result of Defendants’ false and malicious statements, Plaintiff has suffered and continues to endure such ridicule from people all over the world and in the United States. Accordingly, Plaintiff is entitled to recover for the actual, consequential, and punitive damages sustained in an amount to be proven at trial.¶
COUNT II: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS¶
Plaintiff references and incorporates the foregoing paragraphs as if fully set forth and alleged herein.¶
Defendants publications of such vile and false statements amounts to intentional and/or reckless conduct.¶
Defendants conduct is and continues to be extreme and outrageous.¶
As a direct and proximate result of Defendants’ false and malicious statements and conduct, Plaintiff suffered and continues to suffer emotional distress.¶
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Plaintiff’s emotional distress is severe as he cannot ever return to a normal life and will be subject to such ridicule, contempt, and hatred due to the false, vile, and disgusting conduct by Defendants.¶
COUNT III: ATTORNEY FEES¶
Plaintiff references and incorporates the foregoing paragraphs as if fully set forth and alleged herein.¶
In defense of this action, Defendants have acted in bad faith in the underlying transaction. Plaintiff is entitled to an award of attorney fees and expenses of litigation under O.C.G.A. § 13-6-11. Plaintiff specifically prays for such an award.¶
COUNT IV: PUNITIVE DAMAGES¶
The actions of Defendants Valerie Dirksen, Individually, and in her role President of ICRAS and ICRAS in this case show willful misconduct, malice, fraud, wantonness, oppression, or that entire want of care which raises the presumption of conscious indifference to the consequences.¶
Accordingly, Plaintiff Geilenfeld is entitled to an award of punitive damages for which he specifically prays pursuant to O.C.G.A. § 51.12.5.1(d)(1).¶
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Plaintiff is entitled to and prays for an award of punitive damages in an amount to be determined by an enlightened and impartial jury.¶
WHEREFORE, Plaintiff prays as follows:¶
(a) that process issue and the Defendants be served according to law;¶
(b) that Plaintiff have a jury trial on all issues raised in this Complaint;¶
(c) that Plaintiffs have judgment against Defendants for damages sustained, attorney fees, costs, expenses of litigation, and other damages in the amount of an enlightened and impartial jury;¶
(d) that Plaintiff recover punitive damages from Defendants in an amount to be determined by an enlightened and impartial jury.¶
(e) that Plaintiff have such other and further relief as may be proper under the circumstances.¶
This 9th day of March, 2021.¶
AKIN & TATE¶
/s/ S. Lester Tate, III S. LESTER TATE, III¶
/s/ B. Ryan Coram¶
B. RYAN CORAM¶
ATTORNEYS FOR PLAINTIFF¶