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Affidavit: Harold Middleton
Affidavit: Harold Middleton
08
2011
BETWEEN:
Hfx. No. 343536
SUPREME COURT OF NOVA SCOTIA
AUBREY PELLEY and DEANNA
-AND-
rEB ~ 1 1011
PLAINTIFFS
THE NOVA SCOTIA HOME FOR COLORED CHILDREN, a body
corporate and THE ATTORNEY GENERAL OF .NOVA SCOTIA.
representing Her Majesty the Queen in right of the Province of Nova
Scotia
DEFENDANT
Proceeding under the Class Proceedings Act, S.N.S 2007, c. 28
Affidavit of Harold Middleton
I, Harold Middleton of the city of Montreal in the Province of Quebec, MAKE
OATH AND SAY THAT:
1. I have knowledge deposed to below. Where my knowledge is based on
information obtained from others, I have so stated below, and I believe that information
to be true.
2. I am providing this affidavit in support of the Plaintiffs' motion to have the within
proposed class proceeding certified as a class proceeding.
3. I was born in Nova Scotia on November 12, 1940. I have one brother and two
sisters.
4. My early years were spent living with my family in our home at 96 Sheriff Street
in Saint John, New Brunswick.
5. I have a memory of living briefly in a halfway house in Saint John,. New
Brunswick. I recall my siblings and I being taken from the halfway house to the Nova
Scotia Home for Colored Children by a lady named Ms. Bishop in approximately 1948.
6. Though my siblings were at the Home with me, I was rarely permitted to see my
two sisters or had any contact with them as the boys and girls were separated from
each other.
7. I recall that we received porridge for breakfast every day. The staff served the
same menu every week. I never received any snacks in between meals.
8. I recall that when the residents were eating at the table the staff would stand over
them with a stick. The staff only allowed us to eat so much. If a resident ate any more
then his or her share, he or she would be sent to their room and would be beaten.
recall staff member, Ms. Fowler, would administer the beatings.
9. There was never enough food to eat at the Home. I and other residents would
frequently try to steal food from the animals and hide it in the woods.
10. In the winter time, I and the other residents were forced to remain outside in the
cold. I recall being made to stay outside for hours on end in an open play area. This
area had a roof but no walls and no heat. I recall having to jump up and down in the
winter to keep myself from freezing.
11. If a resident did something wrong and no one was willing to tell on the resident,
then all residents received a beating. I received these beatings often. Staff members, Mr.
Willis and Mr. Bundy, would administer the beatings. I recall being taken to a small room
to receive the beatings. These beatings were administered with a switch. Mr. Bundy and
Mr. Willis would put my head between their knees and make me pull down my pants
and beat me with a switch on the bare behind.
12. I recall witnessing Mr. Willis and Mr. Bundy administering the same kind of
beatings to other residents. The beatings would leave myself and the other residents
with bruises and welts.
13. I do not recall being visited by anyone employed by the Children's Aid Society
while I was a resident of the Home.
14. I left the Home in approximately 1957.
SWORN TO at Montreal in the )
Province of Quebec,
this 16
1
h day of February, )
A.D., 2012 before me: )
)
. ; .
Fanie Courchesne
COMMISSIONNER OF OATHS
For the Province of Quebec