Faga Savino

Faga Savino, LLP Attorneys at Law

Attorneys at Law

ECOPY

Hutchinson Metro Center 1200 Waters Place, Suite 301 Bronx, New York 10461

(718) 931-6000 tel (914) 592-0601 tel (718) 931-6056 fax

AFFIDAVITS

STATE OF NEW YORK COUNTY OF ROCKLAND

HEDWIDGE GEORGES, being duly sworn, deposes and states:

I am over the age of eighteen (18) years of age and reside at 16 South Madison Avenue, Apt. 2B, Spring Valley, New York 10977.

I am of Haitian decent and define myself as a Haitian-American.

I make this Affidavit of my own free will.

I am a duly elected Committee Member of the Rockland County Democratic Committee, having been elected same at the Democratic Primary which took place on September 9, 2008. My residence within the Town of Ramapo makes me a member of the Town of Ramapo Democratic Committee and my residence within the Village of Spring Valley makes me a member of the Village of Spring Valley Democratic Committee.

I am also the duly elected President of the Haitian American Voters and Entrepreneurs Network, ("HAVEN"), an organization formed in or about

1991 with the mission of encouraging the Haitian-American community to participate in the political process within the United States of America.

I have been an active member of HAVEN since it was established and have been intimately involved in HAVEN'S programs, including but not limited to, citizenship drives, voter registration drives, campaigns for candidates for elected office, political informational meetings for the Haitian-American community, debates for candidates for political office, and screenings for candidates for political office.

In my capacity as President of HAVEN, I have supervised, administered and operated HAVEN and it's programs.

In my experience, the Haitian-American community is highly sensitive in regard to political matters which makes it difficult to encourage members of the Haitian-American community to participate in the political process within the United States of America. I believe that this is due in part to the political unrest in the county of Haiti which causes members of the Haitian-American to distrust any political process. As a result, HAVEN has sought to educate, inform and engage members of the Haitian-American community within the County of Rockland in an effort to encourage their participation in the political process.

I have publicly supported the Ramapo Democrats For Change, their mission and worked with them to organize Haitian-Americans within the County of Rockland to assist them with their agenda in regard to building the Democratic Party within the Village of Spring Valley, Town of Ramapo and County of Rockland.

I operate a child-care program called FOCUS, located at 25 South Main Street, Spring Valley, New York. In various projects associated or affiliated with FOCUS, I work with and/or receive support from, the Village of Spring Valley, Town of Ramapo and County of Rockland. My work with FOCUS and the programs and/or projects of FOCUS is well known in the Haitian- American community and the County of Rockland.

On September 25, 2008, at approximately 12:30 P.M., I was at FOCUS and DEMEZA DELHOMME, ("DELHOMME"), entered my office. He proceeded to threaten, harass and annoy me in regard to my association with the Ramapo Democratic Party, Ramapo Democrats For Change and Rockland County Legislator Jacques Michel. DELHOMME threatened to use his association with Town of Ramapo Supervisor Christopher St. Lawrence to hurt me, my children and my business, unless I ended my affiliation and political activities with the Ramapo Democratic Party, Ramapo Democrats For Change and Rockland County Legislator Jacques Michel. He then stated that he, "Joined with Supervisor St. Lawrence to destroy Jacques Michel and

to make sure that the Haitians who work with and follow Jacques Michel are destroyed and kicked out of Rockland forever because they do not listen to me." While DELHOMME was speaking to me, he spoke in a loud, aggressive and angry manner Further, while speaking he had negative facial expressions and waived his hands and postured his body in a hostile way. As a result, I became uneasy, concerned for my well-being and was forced to leave my office due to DELHOMME'S unwelcome presence.

Thereafter, on the same day, September 25, 2008, I attended the meetings of the Village of Spring Valley Democratic Committee and the Town of Ramapo Democratic Committee at the Town of Ramapo Cultural Arts Center, located at 64 North Main Street, Spring Valley, New York 10977, with the intent of participating in the meetings of the Spring Valley Democratic Committee and the Town of Ramapo Democratic Committee.

At approximately 7:00 P.M., DELHOMME approached myself, Legislator Jacques Michel and Yolanda Michel, and stated to another individual standing in close proximity to us, "I'd like to see all of them dead, starting with Jacques Michel," while he gestured to us.

As a resident of the Village of Spring Valley, Town of Ramapo, County of Rockland and a registered voter within the Democratic Party, I believe that the actions of DELHOMME were performed in violation of my civil rights and

done in an effort to stop me from lawfully participating in the meeting of the

Ramapo Democratic Committee.

SWORN TO BEFORE ME THIS 1 DAY OF , 2008

HOWARD L CYTRYN

Notary Public, State of New York

No. 01CY6137390

Qualified in RocklandCounty

Commission Expires November 21, 20 0 7

AFFIDAVIT

STATE OF NEW YORK }

} S.S.:

COUNTY OF ROCKLAND 1

SERGO BEAUBOEUF, being duly sworn, deposes and states:

I am over the age of eighteen (18) years of age and reside at 36 Columbus Avenue, Apt. B-22, Spring Valley, New York 10977.

I am of Haitian descent and define myself as a Haitian-American.

I make this Affidavit of my own free will.

I am a duly elected Committee Member of the Rockland County Democratic Committee, having been elected same at the Democratic Primary which took place on September 9, 2008. My residence within the Town of Ramapo makes me a member of the Town of Ramapo Democratic Committee and my residence within the Village of Spring Valley makes me a member of the Village of Spring Valley Democratic Committee.

On or about September 14, 2008, I was at home when I was alarmed by pounding on my front door. DEMEZA DELHOMME, ("DELHOMME"), was at my door and screaming that he wanted me to open the door and sign

something for him. I answered the door and asked him why he was so agitated and causing a scene outside my home. Without invitation, DELHOMME entered my home, said me needed me to sign a paper because I was on the Democratic Committee and said I needed to sign "right away".

I told him that I had signed a Proxy and given it to Legislator Jacques Michel, our first Haitian-American Legislator. DELHOMME then told me, "You have signed your death condemnation because St. Lawrence told me that Jacques is a bad man and he is working with racist Jews who have paid Jacques $20,000.00 to mess up St. Lawrence's Committee." He then told me that St. Lawrence is in charge and that he can "help me or hurt me". DELHOMME then reminded me about my job with the Village of Spring Valley and said that if I acted correctly I would be "left alone".

DELHOMME then said he would come back with papers that would get me out of the Democratic Committee and would help me act correctly.

The statements, facial expressions, tone of voice, body posture and hand gestures of DELHOMME mad me extremely uncomfortable.

I was very angry when DELHOMME left. I felt my job and livelihood was threatened. As an elected official in the Village of Spring Valley, as a Village Trustee, I was and remain concerned about DELHOMME threatening my

employment. I called Jacques Michel and told him that I could not take this pressure from DELHOMME and that I would have to leave the Democratic Committee.

10. As a resident of the Village of Spring Valley, Town of Ramapo, County of Rockland and a registered voter within the Democratic Party, I believe that the actions of DELHOMME were performed in violation of my civil rights and done in an effort to stop me from lawfully participating in the meeting of the Ramapo Democratic Committee.


SERGE BEAUB0EUF

 

SWORN TO BEFORE ME THIS DAY OF 0 Cr-c-r-A-gal-, 2008

NOTARY PUBLIC

AFFIDAVIT

STATE OF NEW YORK }

S.S.:

COUNTY OF ROCKLAND }

MAXENE SAINVIL, being duly sworn, deposes and states:

I am over the age of eighteen (18) years of age and reside at 5 Bogert Place, Spring Valley, New York 10977.

I am of Haitian descent and define myself as a Haitian-American.

I make this Affidavit of my own free will.

I am a duly elected Committee Member of the Rockland County Democratic Committee, having been elected same at the Democratic Primary which took place on September 9, 2008. My residence within the Town of Ramapo makes me a member of the Town of Ramapo Democratic Committee and my residence within the Village of Spring Valley makes me a member of the Village of Spring Valley Democratic Committee.

On or about September 25, 2008, I was working as a taxi driver and my taxi was located in the proximity of Main Street in the Village of Spring Valley. I was parked on the side of Main Street, when DEMEZA DELHOMME,

("DELHOMME"), approached my vehicle and told me that he had to speak to me right away and that he had been, "trying to get a hold of you about an urgent matter because I see your name on the list with Jacques Michel." DELHOMME then asked me if I was a member of the Democratic Committee and I advised him that I was. He then asked me why I was on the Committee, what did I know about it and why I was wasting my time. He then stated that Jacques was a "bad man" working against St. Lawrence, that this was Jacques last term and that this was Jacques "last term". I was then asked by him why I was helping a bad man. DELHOMME then told me not to go to the Democratic meeting at night and that if I went to the meeting I would get into "serious trouble" because I was "not supposed to be there". Before he left the side of my vehicle, he told me that, "I know where you live and so do the St. Lawrence people."

The statements, facial expressions, tone of voice, body posture and hand gestures of DELHOMME mad me extremely uncomfortable.

I was confused and troubled by what had occurred with DELHOMME and called Legislator Jacques Michel for assistance. Jacques Michel told me that I was free to go to the meeting and not to be guided by what I had been told by DELHOMME,

Thereafter, on the same day, September 25, 2008, I attended the meetings of the Village of Spring Valley Democratic Committee and the Town of Ramapo Democratic Committee at the Town of Ramapo Cultural Arts Center, located at 64 North Main Street, Spring Valley, New York 10977, with the intent of participating in the meetings of the Spring Valley Democratic Committee and the Town of Ramapo Democratic Committee.

While at the meetings, I saw DELHOMME and asked him, "If you told me not to come to the meeting, why did you come to the meeting." Although DELHOMME did not provide me with a verbal response, he smiled and laughed at me.

As a resident of the Village of Spring Valley, Town of Ramapo, County of Rockland and a registered voter within the Democratic Party, I believe that the actions of DELHOMME were performed in violation of my civil rights and done in an effort to stop me from lawfully participating in the meeting of the Ramapo Democratic Committee.

 

AFFIDAVIT

STATE OF NEW YORK }

S.S.:

COUNTY OF ROCKLAND }

SULTAN DEMOSTHENES, being duly sworn, deposes and states:

I am over the age of eighteen (18) years of age and reside at 4 West Castle Avenue, Spring Valley, New York 10977.

I am of Haitian descent and define myself as a Haitian-American.

I make this Affidavit of my own free will.

I am a duly elected Committee Member of the Rockland County Democratic Committee, having been elected same at the Democratic Primary which took place on September 9, 2008. My residence within the Town of Ramapo makes me a member of the Town of Ramapo Democratic Committee and my residence within the Village of Spring Valley makes me a member of the Village of Spring Valley Democratic Committee.

On or about September 14, 2008, I was at home when DEMEZA DELHOMME, ("DELHOMME"), started pounding on my front door. DELHOMME was screaming that he wanted to talk to me and to sign something for him.

I answered the door and asked him what the problem was. He then said he knew that Jacques Michel was at my house and that I signed some papers for him regarding the Democratic Committee. DELHOMME then said,

You signed for the wrong man. Jacques is a bad man working for racist Jews, who pay him to make trouble for St. Lawrence. You will get into a lot of trouble with Jacques.

I told DELHOMME that I gave my papers to Jacques Michel and that was all. He responded by telling me that I should not be part of the Committee and that he would come back with papers to take me off the Committee.

The statements, facial expressions, tone of voice, body posture and hand gestures of DELHOMME mad me extremely uncomfortable.

As a resident of the Village of Spring Valley, Town of Ramapo, County of Rockland and a registered voter within the Democratic Party, I believe that the actions of DELHOMME were performed in violation of my civil rights and done in an effort to stop me from lawfully participating in the meeting of the Ramapo Democratic Committee.

 

NOTARY PUBLIC

 

HOWARD L CYTRYN

Notary Public, State of New York
No. 01CY6137390

Qualified in Rocklanci County Commission Expires November 21, 20dq

AFFIDAVIT

STATE OF NEW YORK COUNTY OF ROCKLAND

JACQUES CHALOT, being duly sworn, deposes and states:

I am over the age of eighteen (18) years of age and reside at 1 Andover Road, Spring Valley, New York 10977.

I am of Haitian descent and define myself as a Haitian-American.

I make this Affidavit of my own free will.

On September 25, 2008, I was present at the Ramapo Cultural Arts Center, located at 64 North Main Street, Spring Valley, New York 10977, with the intent of participating in the meetings of the Spring Valley Democratic Committee and the Town of Ramapo Democratic Committee.

At approximately 7:40 P.M., just after the conclusion of the meeting of the Spring Valley Democratic Committee, I observed DEMEZA DELHOMME walking from the theater's main floor to the basement of the theater, where upon information and belief, the building's main circuit breaker is located.

6. While I was watching the stairs leading to the basement of the building, I did not witness any other individuals walk down to the basement.

7 Immediately following DEMEZA DELHOMME walking to the basement, the lights in the building went out and remained out for sometime thereafter.

Following the lights going out, the people within my sight and hearing were confused, concerned, afraid and startled as a proximate result of the sudden loss of light in the premises

Upon information and belief, DEMEZA DELHOMME caused the lights to be turned off.

As a resident of the Village of Spring Valley, Town of Ramapo, County of Rockland and a registered voter within the Democratic Party, I believe that the lights being turned off were a violation of my civil rights and done in an effort to stop me from lawfully participating in the meeting of the Ramapo Democratic Committee.

HOWARD L. CYTRYN

Notary Public, State of New York
No. 01CY6137390

Qualified in RocklandCounty

Commission Expires November 21, 200

AFFIDAVIT

STATE OF NEW YORK }

} S.S.:

COUNTY OF ROCKLAND

Toni Lester, being duly sworn, deposes and states:

I am over the age of eighteen (18) years of age and reside at 17 Old Nyack Turnpike, Monsey, New York 10952.

I make this Affidavit of my own free will.

I am a registered Democratic Party voter residing within the Town of Ramapo, New York.

I went to the Town of Ramapo Cultural Arts Center located at 64 North Main Street, Spring Valley, New York on the evening of September 25, 2008 and attempted to gain entry to the theatre to attend the Democratic Party meetings being held there. At the entranceway to the premises, I was met by Ms. Patricia A. Caldwell, Chairperson of the Village of Spring Valley Democratic Committee. Ms. Caldwell stopped me from entering the building. I noticed she had also stopped two other gentlemen from entering. Ms. Caldwell stated that the meeting was open only to voting Democrats from the Village of Spring Valley. The manner of expression, statements, facial expressions, and

tone of voice of Ms. Caldwell made me extremely unsettled and uncomfortable.

Mr. Ryan Karben then appeared at the entranceway and stated that the meeting was open to any registered Democratic voter Immediately after hearing Mr. Karben's statement, I entered the building and Mr. Karben then asked me for my admittance ticket. I proceeded past him and did not, nor could not, present him with an admittance ticket because none were ever issued to voters as a requirement for attendance.

When Ms. Caldwell announced the closing of the Spring Valley Democratic Party meeting, she asked everyone to leave the theatre building despite the fact that a meeting of the Ramapo Democratic Committee was scheduled to then begin and which meeting I wanted to attend also.

I then saw Mr. Demeza Delhomme, a trustee of the Village of Spring Valley government, immediately go to the area of the stage where the theatre light switches were located. The lights of the hall were then turned off, leaving the audience of approximately 400 persons waiting for the next meeting to start in darkness. I feared for my own safety and the safety of the audience which contained a number of senior citizens sitting in darkness facing the possibility of fire, panic or other disaster, with impairment to a quick and safe egress from the building

8. As a resident of the Town of Ramapo, County of Rockland and a registered voter within the Democratic Party, I believe that the actions of DELHOMME and CALDWELL were performed in violation of my civil rights and done in an effort to stop me from lawfully attending the meeting of the Ramapo Democratic Committee.

TONI LESTER