affidavit - lorne theophilus[1]

8/18/2019 Affidavit - Lorne Theophilus[1]

1/10

eadfor yourself, an affidavit by Miss

Clemar Beverely Hippolyte given to the

Courts of St. Lucia by her.

This

affidavit

can be obtained

from the

Court by interested persons.


2/10

My name is

Clemar Beverely

Hippolyte. I live

at Ravine

Chabot

)[am 26years

old I am

an

attorney t

Law

attached with the

Law-

Firm

of

Larcher ~ M and Associates. On

Saturday 15

th

JIiI1\ilIlY 2005, I arrived at work at about 9:45 am. I n:mained there for

the

greater

part

of

the

m ~

At

abOut 12:10

pm

I

received

a telephone call

on

my

cell

phone

from

Lome

TheophilU$ a fellow colleague

and

friend.

He

asked me what I was up

to.

I

told

him that

was

just

packing to leave

the

office to 8ttenc\ a meeting at

the

St.

, Joseph s Convent Secondary School at Cedars.

The

meeting

WBlS

SUPP sed

to

start at

1:OOpm. He told me that

he was

stressed so I said

ok

J

would conle over to see him for

about five

minutes and

then

we would

leave.

He agreed He also tx)ld

me

that he would

drop me to the school. I then left for

lQ s

supermarket to purchase

:)ome

foodstuff for my

mom and that took approximately 10-15 minutes. Then I ~ i v ,mother telephone call

onmy cell phone ftom

Lome

Theoplius asking me whether I

fuui

cbmged my

mind

,about

the

drop and

coming

to see him

and

I said no I had not but

that

I was in

the

supermarket

doing some groceries.

He

then told me when I was close e1 ..ough to his, office that, I

should telephone him and he would m to

open

the door to his o:flfice for me. I did just

that.

When I

a... 'rived in his

office it was approximately

12:3Opm. He

was

dressed in what

appeared

to be

a grayish shirt

and

a pair of blue jeans. The

first thiJ1lI8tbat

struck

me was

that his office

was

somewhat dark so I asked him

how

come

he doing work

in

such

poor

light.

He

replied that

he

was

having a terrible

headache

and that

the

light

was

affecting

his eyes. I thought nothing

of

it; I just believed'him and £ ~ i ok. We went into

.

his office. The office was

in

a pale lilac.,On the left hand side of the office there

was

a, book shelfand directly adjacent to that

was

his desk. Behind the desk

was

a black

.

,

lawyer's chair and

in

front were three client chairs. There was'nothiJng on the wall. I sat

in

one of the

client's seal

and he sat in

the

lawyer s

chair. He

U I ~ t h u m b l i n g through

some

papers

on

his desk and didn t look like he w s getting rnuclL done. So I told him

- ,

lopk (ileacly you

are

,not going,to get

much

done

now

so could

we

,just leave. By

then

it

approximately 12:35 pm. He said ok and ~ across

to ~

I was seating. He

pulled

me up

gently.

I

stood

~ then he

h ~

me. I took a_ deej> breath to

show

my

.

disComfort then I said ok

now

lets go. I then pulled

He

said we

'

will but

just

not

right now. He

then

started

,kiSsing

my

neck

my face and 1D:Y lips but I

did not

respond to

him.

I just

pushed him

off

me and

said

stop

and just

let's

b c ~ i 8 U S C the

girls were

, ·

.J


3/10

waiting for me and I need to get

to

the meeting. I then took my hand and proceeded

in the

direction

of

the door which was

slightly

ajar. He

cpmc;

up to me pushed the door

closed and locked it. At

that

pointI started feeling even more uncomfortftble and so I told

him what

the

fuck are you doing?

He

told me to relax mid not

to WOlT)

and

he

told me

that he wanted me really badly. Then he

pulled

me away form the i ~ o o r ~ started

touching me all over and tried to suck my breast. I pulled my two hands, over my breast

and told him to stop

it and that

I wanted to leave. In fact I even told bini that

I

wolild go

y myself

if

he didn t want

to

drop

me

again.. He said.ok

we

are going to leave and he

would drop me but not before he gets what he wants from me. He thenpushed his body

unto mine and pushed me against his desk

and started

feeling me up aU over again and

started kissing me. I kept

trying to

push him

off

ofme because it didnl t feel right and I

wanted

to

leave. Hecontinuedm spite

of

my several

request

to

stop. I told

him

lookI am

serious and I want you to stop now and I want to go up to the school I am late for the

meeting.

~ h e · s a i d o k a n d

sort of1iftedme from offhis

desk

as I W8S:about to leave be

again pushed his body unto mine and pushed me against the waIl and started kissing me

on

my neck

and

face. I was wearing a black top that pulled across

the bust

area and tied

in the back and a white palazzo pair ofpants with a zip to the back and

tl.pull

string to the

front. I had on black underwear. He then unzipped my pants andstartfn feeling me up

again. He then tried

10

pull

downmy pants but

I

held on

to

the

two

sides making

it

a little

difficult for him to do so. But then my bands were occupied and so he proceeded to

touch my vagina. I then bent over in such a way that

he

made it difficultfor

him to

touch

me. But he didn t let up. He then pushed me down on the floor. I let go ofmy

pants and

used my elbows 10 brace the

faIl.

He then proceeded to. pull down my

pants

and

y

underwear together. He pulled them

down

to a little below my knee. I then placed both

hands

one on top the other

to

cover my vagina. He then pulled

m r

hands apart

and

said

let me see that cut you keep complaining

about

He then kissed my lI agina and said I

don t see what you complaining about. I don t see why you so embatLiassed about your

I

cut.

My legs we shut tightly

together

at

that

point. He then put

his

knee: between my legs

and pulledthemaparl I

begged him to stop but to no

.vail:.

He placed himself

betWeen

my legs. Then he Pulled down he

pants

and underwear.,

He,

then placed all

of

his weight

on my left thigh. Tlleq 4P ontmd

JJ1- ,

pm ~ ~ ~ ofmy v,agina.

Hedidn t

. '


4/10

/

/

use a condom. I felt a sudden

pain

and let out a

cry.

He

told me

to

relwc

t

told

him

please

stop you are hurting

me.

I feeling a

lot

ofpain in

my lower

abdominal area. I

told

him so.

I

told him

he

was hurting my operation But

he

didn't liste:n. He then started

gyrating up

and down

inside of

me. He kept

on having sex with

me. 1 kept telling

him

to

stop and that he was hurting me.

He

said no he wasn't stopping andtbat he was calling

ilie shorts now. He said that I had him horny for the

longest

while

:now

and I was not

giving in to him.

He

said

he

knows

that

left up

to me and

from

my

t ~ w i o ~ behavior

he

coUld tell that I

was

never going to give in to him so

he taking

what

lir

can get now. He

said

last Saturday I had him horny as ever so much so that he felt lil'"e

he

was going

to

burst a vessel. He said

that s

not happening today: And he continued

ii

have sex with me.

I toldhim I was going to ifhe didn't let me go now. He said go ahead no one will

hear you. I tried pushing him offand scratching him I even

tried

to bite him. I kept saying

you re hurting

me

please I am begging you stop. I was crying I toklhim

that he

didn t

have

to

do

this I told him he

Could

get any girl he wanted I told him 1bte didn't have

to

do

this

to

me because eventually I would have given in anyway. I was jllJSt not ready now. I

told him

that

so

that

he

could

stop.

He

didn't.

He

wiped

my tears.

~

kept

on

crying.

Then I shut my eyes and just went somewhere else

in

my

mind

fur a few seconds. Then I .

heard him say are you

just

going to

lie there and

play

dead. I opened my eyes, and said

what

the

hell you think. He contiJiuedriding

up

and down inside ofDOle really bard. I was

feeling a

lot

of

pain

in my abdominal

area,

and

in

my

vagina

I corltinued ~

im

please stop.

He

then said

ok

I

will

get off

you

i you re sure that that 's what you want. I

said yes please.

He

raised his upper body offof

me as

nbe

was goin8;to get offbut the he

¥

remained

inside ofme and

put

himself in a stooping position and sliill not removing his ..

penis form inside ofme and started sort of hoping his way inside me. I just kept on

crying. I

was in·

so much

pain.

I felt pain

between

my legs

especiall,r

on my left

thigh.

I

felt pain in my abdominal

area.

I was feeling nauseated. I just

n ~ e to

die. I also felt

very :frail and weak. I stopped fighting him. I

closed

my eyes andl

just

prayed

that

he·

.

.

would stop.

My left

thigh

was

trembling. He then

said

I like a 'Woman whose legs

tremble.

He

then.

placed

my

left

leg

over

his shouIdeJf

and

confinuecL ramming inside

of

me. At that point the phone began to ring. I opened r

and

witb

tears

in them I said

please go

answer

your phone.

He said he

is

not.

,omg

to

IltnSWle '

the phone

i

it's

.

,

3


5/10

important

the

person would

call

back.

I

said

but

it

could

be

your wife

it

~ u l d

be

about

your

daughter he

said they would

call back I

continue

crying

and praying. He continued

to have

sex

with me. That I felt as though he was about to climax so I

begged him

I said

please

don t

ejaculate inside of

me

please don t. He said

he

was

not

going

to he

would

never do

that.

The phone

rang

yet a second time.

This

time

it

rang incessallrt1y. It

did

not

stop ringing. I don>t recall what happened whetherhe came inside

of

me I t not. But then

I heard him say

are

you sure you want me to stop. I said yes ..• please. I was still

crying.... Then he removed his penis from inside of

lIle

and

went

across to answer the

phone but by then the person had hung up. I

tired

to grab my clothes

but

was nearer to

them than I was

so

he grabbed them. I said you don t give me my clothes then I

will

leave here like this half a k e d ~ He said no you wouldn t. He then

put

his body against

mine

and then started

touching me again but my vaginal area was sore·and I couldn t

stand

it

I

told

him

please stop it that

he

was hurting me.

He

then

kissed me

again

and

again on my

mouth

my I keptmy

mouth

shut I didn t

respond to

him

I filtt so

weak

I

felt

dirty and

useless.

I felt

so

stupid thinking

that this

was

all

my

fault. I

e r ~ e

him

for

my

clothes

and

then

he

finally gave

them

to me. I

then

asked

him

to use

bathroom.

He

handed me some baby wipes and I took

them

and then

he

showed llle to where the

bathroom was

I

then locked myself

in

the

bathroom

and

I

vomited and just cried and

cried. I didn t use the baby wipes. I placed it on the toilet

tank

Then I gained a little

control and then I washed my face , picked up the baby wipes and then left the bathroom.

I went into his office. I was feeling very weak and I could barely walk.

My

inner thigh

and my lower abdominal area was hurting me. I felt so sore. I handed him his baby i p e ~ ,

picked up my stuffand was about to leave. He then said no Clemar you can t leave I will

drop

you

I

told you

I would drop you didn t I? I told

him it

was

ok

and tbat I would walk.

He

said no you

w ll

not

walk

I

am

not going to let

you

walk: ok I said ok. Then

he

left

for the bathroom and I proceeded to the front door. But I couldn>t move very quickly. I

was n

so much pain.

By

the time I got to the front door

he had

CODle back from

the

bathroom and he·walked towards me. He then said

you

weren t about to leave without

me were you? He came opened the door which was locked and

we

botllleft. He gave

me

a drop to

the

Convent He was talking to

me all

along

the; way as

nothing happened.

He

was carrying normal conversation. I never

responded. I

was

angry

ancl

frustrated.

I

was

4


6/10

hurt physically and emotionally. I

just

wanted to get to the

school

My anger and

frustration was apparent on my face.

He

said fix your face Clemar. I didn t I kept on

frowning. He then stopped talking for a little while. I relaxed a little.

He

said seems your

face only tied up when I open my mouth. I didn t respond. He dropped me and came out

of the vehicle and

he

left. When I got to the school I couldn t see straight t was

approximately 1:45 pm. I

was

trying to :finil

my

close friend Lisa. I

kept

shouting

her

name. Then she responded and

proceeded to

where I was

standing.

We

then

went outside

and I could not contain myselfany longer. I started to bawl. I was screaming and crying

and

holding onto

the

pole right out side

the

chapel.

I

cried

and

cried.

I

cried really loudly

because

of

how

I

felt

but

mostly because

I

was

in

so much

pain

Then Lisa

took

me

and

put me

in

her vehicle. She started questioning me I didn t respond I just.cried and cried.

Then she left the vehicle for a brief while. When she came

back

I was still crying she

told

me

to

try

to contain myself because everyone is going

to

hear me. Eventually I

stopPed screaming. I just wept bitterly. I then told her I wanted to go to the bathroom.

At

that point I felt like I wanted

to

throw up I went

to

the bathroom washed my face and

pulled

myself

together. I went back into the hall where

the

other

girls

were

and

joined the

meeting. Then

my

phone rang

it

was

my

best

friend

Mya

Daniel from Barbados. I

walked

out of the meeting

to take the

call. I walked to the

lab

area burst into

tears and

told her

exactly

what

had

happened

Everything

in

detail. I told her that at about 12:10

pm

I

received a telephone call on my cell phone from Lome Theophilus a fellow colleague and

friend.

He

asked me

what

I

was

up to and I told him that

was

just packing to leave the

office to attend a meeting

at

the

S t

Joseph s Convent Secondary School

at

Cedars.

meeting was supposed to start

at

1

:OOpm

He then told me

that

he

was stressed

so I said

ok I would come over

to

see him for about five minutes and then we would leave. He

agreed

He

also

told me

that he

would

drop

me

to

the

schooL

I

told her

that I

then left for

JQ s supennarket to purchase some foodstuff for my mom and that took approximately

10-15 minutes. I told her that I received another l ~ o n call on my cell phone from

Lome

Theoplius asking

me whether I

bad changed

my

mind

about the

drop

and

coming

to

see

him

and I said no I bad not but that I

was

in the supermarket doing some groceries.

He then

told

me

when. I was close enough

to

his office

that l

should telephone him

and he

would come to open the door to his office for me I did jUst

that

I told her

that

when I


7/10

/

arrived in his office it was approximately 12:3Opm. I told her that the

first

thing

that

struck me was

that

his office was somewhat

dark

and that I bad asked him how come he

was doing work in such poor light He replied that he having a terrible headache and

that

the light w s affecting his eyes. I told her

that

I

bad

thought nothing of it at the tiJ;ne;

I just believed him. I told her that

we

went into his office and that I sat

in

one of the .

client s seat while he sat in the lawyer s chair. He

was

thwnbling through some papers on

his desk and didn t look like he was getting much done. So I told him look clearly you

are not going to get much done now

so could we just v e By then it was approximately

12:35 pm. I told her

that

he

said ok; that

we

would leave but

just

not right now. I told

her

that he started kissing my neck

my face

and

my

lips but that I did not respond to him. I

just

pushedhim off me and said stop it and just let s

go

because the girls were waiting for

me and I need to get

to

the meeting. I told

her

that I took my

hand

bag and

proceeded in

the direction of the door which

was slightly

ajar; that he come up to me pushed the door

closed and locked it I told her that

at that

point I started feeling even more uncomfortable

and

so

I

told

him.

what

the fuck are you doing? I told her

that

he to comfort me and

assured me

that

I should not worry;

and

that

he wanted me

really

badly;

that

I told

him

to

stop it

and

that I wanted to leave.

In fact

I even told

him that

I would go

by

myself he

didn t want

to

drop me

again.

I told her that he said ok and that we are going to leave and

that he would drop me but not before he gets what he wants from me; that he

pushed

his

body

unto mine

and

pushed

me against his desk and

started feeling me up

all

over again

. .

.

and started kissing me. I told her that I kept trying to

push

him off

of

me because it

didn t feel right and I

wanted

to leave; and that he continued in spite of my several

. .

request

to

stop. I told her

that

I told

him

I was serious and I wanted

him

to

stop

now

and

I wanted to go

up

to the

sChool

as I

was

late for the meeting. That he said ok and sort of

liftedme from offhis desk. I toldber that I was wearing a black top that pulled across the

bust area and tied in the back and a whitepalazzo

pair

of pants with a zip 10 the back and

a pull string to the ~ t I

had

on black.underwear• 1 told her that he then

unzipped

my

pants and started. feeling me

up

again. He then tried to pull down my pants but I held on

to the two sides making it a little difficult for him to do so. I explained to her that as my

bands were occupied he proceeded to touch my v a g i n a ~ ~ I bentover in h a waytbat

he

made

it

difficult for him to touch

me.

But

he

didn t

let

up.

I then

went

on to

ex lain

6

.

/


8/10

/

/

the following detail: that

pushed

me down on the floor; that I let go

ofm)r

pants

nd ISed

my elbows to brace the fall;

that

be then proceeded to pull down my pants and my

mtderwear together;

that

he pulled them down to a little below my knee; that my legs

were shut tightly together

t

that point; that he then put

his

knee betwi:en my legs and

pulled

them

apart;

that I begged him to stop but to no avail; that he: placed

himself

between my legs; that he then he

pulled

down his pants and

underwEm;

that he then

placed all ofhis weight on my left thigh; that be then entered me; he puthis penis inside

of

my

vagina;

that

he

didn t use a condom

and th t

I felt a sudden

pain

tloolet out

a

cry;

that

be then told me

to

relax;

that

I begged him please stop

y u

me hurting me and

th t

I

was feeling a lot ofp in nmy lower abdominal area; that I told

bUn

he was hurting my

operation, but

he didn t listen; he

then

started

gyrating

up and downltnside ofme- be

kept on having sex with me; that

-

I kept telling him to stop and that

he was

hurting me;

that he told me no he wasn t stopping and that he was calliDg the shorts now; that he said

th t

I had him horny for the longest while now and I

was

not giving in mhim. He said be

knows that left up to me and from my previous behavior he could tell

that

I was never

going to give

in to

him so he taking what he can get now;

th t

last Sat.urday I

had

him

horny as ever so much so that he felt like he was going to burst a vessel and that he said

that s not

happening

today;

that

he continued to have sex with me; that I[ told him I was

going to scream ifhe didn t let me go now; that

he

said go

ahead

no

will

hear you. I

1ried pushing him oft; I scratched him and v n bit

him;

that I kept telling that he

was hurting me and I kept

begging

him to pleasestop. I told her

th t

I was crying and told

him

that

he didn t have to do

this

I told him he could get any girl he wanted; that he

didn t have to 40 this

to

me because eventually I would have given in

an,rway.

I was just

not ready now;

that

I was trying everything to

get

him

to

get

off

of

me

SCI

I told

him

that

so in.hope that he would stop. I told her that he didn t,

he

just wiped my tears. I told her

that I just kept on

th t

I shut my eyes and just went somewllere else nmy mind

for a few seconds; that I

heard

him say are you

~ o i n

to e there land play dead. I

opened my eyes, and said

what

the hell do you think; I told her

that

he ,eontinued riding

up and down inside

of

me

really

hard;

th t

I was feeling a lot of pain

my abdominal

area,

and

in my

vagina

I continued begging

him

please,stop;

that

he

th.en

said ok

he

wiD

get

off

me I

was

sure

th t

that s

what

I wanted. I told her

that

I said

J es

please;

th t

I

7


9/10

.

just

kept on crying. I was in so mueh

pain.

That I felt

pain

between my legs especially on

my

left thigh

and

I felt pain in my abdominal area. That I felt nauseate4 and I justwanted

to die. I told her

that

I also felt very

frail

and weak and that I bad stopped fighting him;

th t I closed my eyes and just prayed that he would stop; that )),ly left thigh was

trembling;

that

he then said that he liked a woman whose legs

tremble:;

that I continued

crying and praying . I told her that

he

continued to have sex

with

me. That when I

felt

as

though he was about to climax I begged him

to

avoid ejaeulatinginside of me; that he

said he

was

not going to he would never

do

that; I

don i

reca11

what happened whether he

came inside

of

me or not. But then I heard

him

say are you sure you want me to stop. I

said yes .•. please. I told her that I was still

crying•...

That he then l eD10Ved

his

penis

from inside ofme; that I felt SQ

weak

I felt dirty and useless; that I felt so stupid thinking

that this

was all my fault; that I begged

him

for my clothes and then

he

finally gave them

to me. That I then asked

him

to usc the bathroom That I then locked myself

in the

b3tbroom and I vomited and just

cried

and

cried;

that I gained a little c:ontrol and

then

I

washed my face

, and

then left the

bathroom;

that I went into

his o.ffi\ce.

I

was

feeling

very Weak. and

I

could barely walk. My inner thigh and my lower abdominal area was

hurting me. I felt so sore. I picked up my stuffand was about to leave;tbat he then told

me

that

I couldn t leave and

that

he would drop me; that I told

him

it Vlras ok and

that

I

would walk. He said no you will not walk I

am

not going

to

let you walk ok. I said

ok.

Then

he

left for the bathroom and I proceeded

to

the front door

but

that I couldnlt move

very quickly. I was in so much pain. By the time I got to the front door he had come back

from the bathroom and he walked towards me. He gave inc a drop to tltle Convent and

was talking to me

all

along the

way

as nothing happened;

that

I

never

~ s p o n e

I

told

her that I was angry and frostmted. I was hurt

physically

and emotionally. I just wanted to

get to the school. I told her that he dropped me and came out of the vehicle and he left. I

was crying incessantly. She then told me to take the phone to Lisa and·based on

their

conversation

I was

taken

to the Tapion Hospital.

The

nurse on call SlSketI me what

was

the matter

.1

told her that I

was

raped. They said

they

could deal with 1he matter for

policy reasons and then the emergency doctor on call referred us to Victoria Hospital.

The emergency doctor on call at Tapion ealled Victoria:Hospital and told

llhem

to expect

us. Upon arrival and

baving

been aware of the situation;we were adviS ed t.) go

to

em

to

8


10/10

make a report and get the

presence

ofa female police officer. Which Ire

did.

We returned

lb

lbe

Victoria

Hospital

where I was

examined by

Doctor

Gilford

in the

presence of

WPC Philipa

FIavien.

Samples were taken

and

put into a sealed··envelope

and

the

envelope was sealed and signed by myself the doctor

and

the Police (Jlfficer. I was then

discharged. On Monday 1 J h January 2005 at approximately 3:30 PUl I went to the

gynecologist Dr. Herbert anus accompanied by WPC 362 Flavien. ][ was thoroughly

examined

t

the

end

of

which

Dr.

Manus a prescription and

t e C O D l J ; l l ~ d e d

counseling and then I left.

I lenwBeverly mppolytc am

willing

to pursue this matter in court.

. I herpby that the above statement

is

true and correct.

Signed:

Dated:

his24

th

day ofJanuary 2005

affidavit - lorne theophilus[1]

Documents