Complaint: Gervil St. Louis V. Perlitz ET Al.

United States District Court for the District of Connecticut
August 8, 2013

http://www.bishop-accountability.org/complaints/Haiti/2013_08_08_Gervil_St_Louis_v_Perlitz_et_al.pdf

[Complaint : Gervil St. Louis v. Perlitz et al ]

Gervil St. Louis aka St. Louis Gervil v. Perlitz, Carrier, Carter, Haiti Fund, Fairfield University, Jesuits, Order of St. John, and Order of Malta, Complaint, U.S. District Court of Connecticut, Case 3:13-cv-01132-VLB

2. Perlitz, Father Carrier, Fairfield University, the Order of Malta, Carter, and the Haiti Fund established a residential school in the Republic of Haiti, the poorest country in the Western Hemisphere. This school, Project Pierre Toussaint, a/k/a Project Venerable Pierre Toussaint (“PPT”), purported to provide services to the poorest children of Haiti, many of whom lacked homes and regular meals. Perlitz, residing in Haiti, was the director of PPT, which provided him with an image of substantial trust and authority.

3. Perlitz used that trust and authority to sexually molest Plaintiff and numerous other minor boys who attended PPT. Perlitz also threatened to withhold food and shelter from the impoverished children in his care if they did not comply with his sexual demands, in effect forcing them to earn their food and shelter by trading sexual favors for those necessities.

4. The other Defendants assisted Perlitz by providing him the means to travel to and stay in Haiti and by providing him the means to operate PPT in this manner. They failed to provide appropriate guidelines and supervision for the operation of PPT. They disregarded warning signs that should have alerted them to the improper nature of Perlitz’s relationship with some of the boys in his care and continued to provide funds to PPT long after it was, or should have been clear, that Perlitz was abusing the trust that had been placed in him. At least one Defendant other than Perlitz actively took steps to prevent enforcement of laws meant to protect minors from the conduct in which Perlitz engaged.

13. Fairfield University hired Perlitz in connection with PPT and retained him during the relevant time period. At all relevant times, Fairfield University had a duty to exercise due care in its hiring and retention, including its hiring and retention of Perlitz. At relevant times, Fairfield University had a duty to supervise and direct Perlitz, to exercise due care in doing so, a duty not to knowingly benefit financially from participating in a venture engaged in activities in violation of 18 U.S.C. § 1591, and a duty not to facilitate Perlitz’s travel to Haiti knowing that Perlitz was travelling to Haiti to engage in illicit sexual conduct.

99. In or around 2007, when Plaintiff Gervil St. Louis was approximately 15years of age, Defendant Perlitz, while in Haiti, engaged in explicit sexual behavior and lewd and lascivious behavior with Plaintiff, including but not limited to illicit sexual conduct with Plaintiff.

100. Without limiting either the generality of the preceding paragraph or the specific number of instances of illicit conduct, during the time period referenced above, Defendant Perlitz coerced Plaintiff into performing illicit sexual conduct by means of implicit threats to Plaintiff. Among other things, Perlitz fondled Plaintiff and engaged in acts of sodomy with Plaintiff.