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Form 39.

08
2011
BETWEEN:
-AND-
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
DEFENDANTS
Proceeding under the Class Proceedings Act, S.N.S 2007, c. 28
Affidavit of Krista Borden
I, Krista Borden, of the city of Wainwright in the Province of Alberta 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 17, 1968. I have two older brothers and
two older sisters.
4. My early years were spent living with my mother, grandmother, and Aunt Sharon
on Ford Street in Truro. I do not recall my father being present during most of my
childhood.
5. 1 have two older brothers and two older sisters.
6. My older siblings had been taken the Nova Scotia Home for Colored Children in
approximately 1972 as my mother was no longer able to care for them.
7. I recall the day I was taken to the Home. It was October 14, 1982. I remember a
social worker, Mrs. Vedito, coming to pick me up from my home to take me to Nova
Scotia Home for Colored Children and my mother crying. I remember crying on the car
ride to the Home and Mrs. Vedito telling me "listen, shut up. You are going some place
that is going to make a better woman of yourself. You just go there and listen to the
rules."
8. About a week after I arrived at the Home, I had a doctor's appointment. Prior to
the appointment a staff member, brought me into the office and told me that all the
young girls at the Home get put on birth control pills. The staff member said that that is
why I was going to the doctor - to be put on birth control medication. After that, I was
forced to take birth control every night.
9. I recall one of the first instances of sexual abuse I endured while a resident at the
Home. It was about a week after I had arrived. I was going to visit my sister who lived
in a different building than me. On my walk over to meet my sister, another resident
named Raymond Bing called me over to talk to him. He told me how pretty he thought I
was and then grabbed me. He proceeded to grope and kiss me. I told him to stop. He
said I could only say no for so long and that I would soon find out how it was to be a
resident of the Home.
10. I reported the incident to a staff member whose name I cannot recall. I was
subsequently prohibited from going to the other building where my sister was living.
The staff were advised that I was promiscuous. As far as I know, Raymond Bing was
not punished for the assault.
11. Staff member, Herbie Desmond, sexually assaulted me on many occasions.
Herbie would often grab me as I was walking up or down the staircases at the Home.
Herbie would grab and pull me into a corner on the landing of the staircase and fondle
me and kiss me. He would often remove his penis from his pants when he assaulted
me. Herbie sexually assaulted me over 50 times while I was a resident at the Home.
12. While a resident at the Home, I had had my appendix removed. I recall this was
in February 1983. After being discharged and returning to the Home, I had a fall down
some stairs. Darryl Allison, a staff member, said that I should come upstairs so that he
could keep an eye on me. I went with Darryl. He rnade me a bed on which to lie down.
I had stomach pains, and so he began to rub my stomach. His hand began to wander
further. He told me that he wanted to teach me how to please a rnan and then forced
me to perform fellatio on him.
13. Darryl subsequently told me to follow him around wherever he went so that he
could sexually abuse me whenever he desired. Darryl sexually assaulted me over 50
times while I was a resident at the Home.
14. Staff member, Georgie Williams, use to help me with my homework. I recall on
one occasion I went into his office to for help on my homework. Georgie grabbed me
and pulled me on to his lap. He proceeded to grope and kiss me.
15. I recall being helping in the office with staff member Sherry Bernard and seeing
papers that belonged to another resident. The papers detailed incidents of abuse
between the author and staff member Mr. Sparks. Ms. Bernard photocopied the papers
and put the photocopies in the resident's folder. Ms. Bernard advised that anything I
saw in the office was not to leave the office,
/r-rA
SWORN he )
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A.D., 2012 before me: )

TERRY ROBERTS
BARRISTER SOL(C17Ufl
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