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Brian Dueck's examination (2)


33

156 Q Would you undertake to provide the first time

that you may have been provided the name Marie

Klassen?

A It would have been in the disclosures of the

children as we went through it, that was the

first time I'd ever heard it.

157 Q There are many hours of disclosures by the

children, there are many notes and statements,

and the audio tapes and video tapes are

enormous. I just ask you to make an inquiry to

determine when you may have heard the name Marie

Klassen used in the context of sexual abuse of

children?

A I would suggest it would be in those disclosures

of 1990.

158 Q Okay. So October of 1990?

MR. GERRAND: Well, the interviews took place

over October-November of 1990. You have been

provided with copies of the transcription of

those interviews. The witness's evidence is

that's the first disclosure of the name, the

identification.

MR. BORDEN: I appreciate that.


34

159 Q So what you are telling us, then, is of course,

in the disclosure the name Marie Klassen comes

up?

A That's right.

160 Q Now after the children refer to Marie Klassen

did you pay her a visit?

A I don't believe so.

161 Q Did you know by the fall of 1991 that Marie

Klassen was at least in a wheelchair from time

to time, and I'm not saying confined to a

wheelchair, did you know that she was in a

wheelchair?

A Not till the fall of 1990 -- or, I should say,

at the time of the arrests in July of 1991, no.

162 Q Prior to the arrests of July of 1991, had you

determined that Marie Klassen had a medical

condition called right bilateral hemiparesis?

A No, I hadn't.

163 Q Had you learned that she was paralyzed on one

side, have you ever learned that?

A I've learned it since, yes.

164 Q When did you first learn that she was paralysed

on her right side?

A I think it was after the arrests or at the time

of the arrests.

165 Q Did you know that Marie Klassen was a member of


35

the Canadian National Institute for the Blind?

A No.

MR. BORDEN: Do you have the glasses here,

please?

166 Q Do you know that today, that she was, in fact, a

member of CNIB?

A No.

167 Q Prior to your making the arrest of Marie Klassen

was there at any time that you visited her home

to look at the layout or the location of various

rooms that the children may have been in?

A No.

168 Q I present to you glasses that belonged to Marie

Klassen, have you ever seen these glasses

before?

A No, I haven't.

MR. BORDEN: I'm going to have them just

marked for identification.

MR. GERRAND: Well, I don't think so. I object

to your marking them for identification. The

witness has said he's never seen them and you

can't present them as evidence.

MR. BORDEN: That's fine.

169 Q So you've never seen those glasses, that's what

your counsel said?

A That's what I'm saying.


36

170 Q And you didn't know she was a member of CNIB?

A No, I didn't.

171 Q Did you ever have an occasion to talk to her by

phone?

A Not that I recall.

172 Q Did you recall her slurred speech at any time?

A No.

173 Q Did you ever see her walking?

A The day that we arrested her, yes.

174 Q So the day that you arrested Marie Klassen she

was, in fact, walking?

A Well, I believe she had a walker.

175 Q Oh, she had a walker?

A Yes.

176 Q Did you ever mark in your notes to prosecutors

that, in fact, she was in a walker?

A No, I don't think so.

177 Q Did you show up and arrest Marie Klassen?

A Yes, I did.

178 Q Prior to your arresting her did you do an

investigation of Marie Klassen in relation to

the following: the location of her home?

A Yes.

179 Q The address of her home?

A Yes.

180 Q Did you determine the actual position of her


37

bedroom as it relates to the kitchen?

A No.

181 Q Did you go inside her home prior to your

arresting her?

A No.

182 Q Did you ask for a search warrant to actually

investigate her home?

A No.

183 Q Did you ask for a search warrant to seek from

that home any physical evidence?

A No.

184 Q And is it your evidence today that at no time

did you talk to Marie Klassen?

A Not that I recall.

185 Q At the time that you visited Marie Klassen for

the first time you said that she was in a

walker?

A I believe she was using a walker, yes.

186 Q Now you're saying the words "I believe she was

using a walker," was she using a walker or not?

A I believe she was, yes.

187 Q And where did you see her walk from or to?

A I saw her through the front window of the home

as we rang the bell.

188 Q And what was she walking from?

A I don't recall.


38

189 Q And where was she walking to?

A Towards the back of the house.

190 Q The back of the house. So you were able to see

through a window, then?

A Right.

191 Q That she was walking on a walker to the back of

the house?

A Right.

192 Q Did you at any time go and report to Matt

Miazga, the prosecutor, one of the defendants

here, or Sonja Hansen, one of the defendants

here, or any other person with the prosecutors

department, that you saw Marie Klassen actually

use a walker?

A I don't believe so.

193 Q When did you determine that she was, in fact, in

a wheelchair?

MR. GERRAND: He hasn't --

A I haven't said I did.

MR. GERRAND: -- given that evidence, Mr.

Borden.

194 Q MR. BORDEN: Okay. So you had never been

given that evidence, Officer, that she was, in

fact, using a wheelchair?

A No.

195 Q Did you see her at a preliminary hearing


39

involving her case?

A No, I never attended the preliminary hearing.

196 Q So you never had a chance to meet her, then,

other than on the day and date that you laid the

charges against her?

A That's right.

197 Q The allegation against Marie Klassen was made by

Michael, was it?

A The girls, as well.

198 Q All right. Let's start with Michael, what did

you understand the allegation as it relates to

Marie Klassen to be?

A The allegations were of touching, of sexual

touching. I don't recall specifically, I'd have

to look at the transcripts.

199 Q Did Michael Ross say that Marie Klassen was, in

fact, sexually touching him?

A That's right.

200 Q And how was that, as you recall it?

A As I say, I don't recall specifically, I recall

that generally as the disclosure.

201 Q Did you recall how many times Marie Klassen may

have touched Michael, according to his

allegations?

A I don't recall.

202 Q Do you recall where those may have happened?


40

A There were several locations, as I recall, the

children talked about Marie and her husband

having lived with Pam Klassen, there were

different homes. I don't recall specifically.

I don't think the children ever said specific

addresses.

203 Q So you're saying that in all the disclosures

regarding Marie Klassen the children didn't say

where these acts occurred?

A Are we talking street locations?

204 Q Any location.

A I don't recall them ever naming a street

location for that, no.

205 Q When you visited Marie Klassen for the purpose

of laying criminal charges against her, what

address did you show up at?

A I believe it was 524 Avenue K North.

206 Q Do you know how long Marie Klassen had actually

lived at 520 [sic] Avenue K North?

A I don't recall right now.

207 Q Did you think that some of the acts may have

occurred at that residence?

A I'm not sure.

208 Q Did you know where Marie Klassen was alleged to

have lived prior to 524 Avenue K North?

A I can't recall off the top of my head, no.


41

209 Q Did you ask for search warrants in relation to

any of the houses that Marie Klassen may have

lived in between the years 1987 and 1991?

A No, I did not.

210 Q Did you ever get any bedding or sheets from any

of my clients' homes that might contain saliva

or semen or blood?

A No.

211 Q Why was that, Corporal [sic] Dueck?

A Because I had no -- I had no justification for

looking for search warrants for any of that.

212 Q The children had alleged that there were sexual

acts that occurred in each one of these homes --

A Right.

213 Q -- belonging first to Dale and Anita and then to

the home of Pam Klassen and her father, Peter?

A Right.

214 Q And her mother, Marie?

A Right.

215 Q Why did you make a decision not to go into those

homes and to take from them certain clothing,

bedding and the like?

A Well, I think you know, Mr. Borden, that

information has to be recent and, certainly,

none of that information was recent enough to

obtain a search warrant to search for anything.


42

216 Q All right.

A The children had been out of the home for well

over a year by the time those disclosures were

made.

217 Q Is it not the case, Superintendent Dueck, that

in the basement of certain homes there were

allegations of sexual acts?

A Right.

218 Q And sometimes on the bare basement floor?

A I don't recall bare basement floor ever being

said. I recall the children saying that there

were blankets or those sorts of things.

219 Q Did you ever make inquiries in each one of those

houses as to the nature of the basements and

whether there was even a place to conduct these

kinds of sexual acts?

A No.

220 Q Did you ever go down into the basements?

A No.

221 Q Did you ever determine whether there was any

beds or sofas in the basements?

A No.

222 Q Did you ever determine whether there were any

mattresses or --

A No.

223 Q -- other like furniture that might have been


43

used for sexual acts?

A No.

224 Q when the children described being on the floor

of any of these houses, including the basements,

did you ask any further questions as you recall

as to the nature of the bed?

MR. GERRAND: Ask any questions of whom?

MR. BORDEN: Fine.

225 Q We're at a point now where we're talking about

your interviews with the children, and Michael,

for instance, may have said, well, we had been

touched improperly by Peter Klassen. Did you

ask him on what kind of device or bed he may

have been touched?

MR. GERRAND: Don't answer that question. All

of the questions and answers with respect to the

interviews have been transcribed and are

reproduced. I don't think it's fair to ask this

witness at this stage what he asked and what he

didn't ask. It was 12 years ago and I don't

think he can remember all that kind of detail.

226 Q MR. BORDEN: Mr. Gerrand has indicated

that we have all of the evidence. In other

words, we have all of the tapes of your

interviews with the children; would you agree

with that?


44

A As I understand you do, yes.

MR. GERRAND: If you have a specific question

with respect to a question that was put during

those interviews, put the specific question to

the witness.

MR. BORDEN: No, that's fine.

227 Q Your counsel, however, has said that we have

everything here --

MR. GERRAND: No, I haven't said that. I have

said that you have the transcripts of the

interviews. You are now asking Superintendent

Dueck about interviews of the children that were

conducted in the fall of 1990, you're asking him

specific questions about those interviews. The

transcriptions of those questions and answers

that were put to those children are here for

you. My point was, I'm not sure that it's fair

to put to the witness general questions about

what was said and what was not said during those

interviews when the words that were used have

been produced to the plaintiffs and counsel is

familiar with them. It doesn't seem to me that

it's fair to ask him about generalities when we

have the specific evidence.

MR. BORDEN: I appreciate that very much.

228 Q Your counsel has just indicated that we have


45

everything, essentially, in a time period of the

fall of 1990, October-November there were

interviews that you had with the children?

A Right.

229 Q And your counsel has said that if we want to

know what you asked all we have to do is look at

the transcripts of those interviews; is that

correct?

A I would say so, yes.

230 Q And that whatever you may have asked will be

found there in the transcripts?

A Yes.

231 Q MR. BORDEN: Or on the video tapes themselves,

Mr. Gerrand. Is that correct, Superintendent

Dueck?

A I would say so, yes.

232 Q Or in the audio tapes, if any audio tapes were

made of those interviews; is that correct?

A That's right.

233 Q Right. So let me deal now with something else.

Did you have any interviews with any of the Ross

children that were not video taped or audio

taped?

A No. Where I questioned them?

234 Q Yes.

A No.


46

235 Q Because I understand that you actually visited

Mr. Thompson and his wife at a Taco Time in the

fall of 1989 and that was not video taped, that

was not audio taped?

A Right.

236 Q According to your evidence that wasn't even

written down --

A Right.

237 Q -- because you can't seem to find any of the

recording of that?

A That's right.

238 Q Were there any other times other than on video

or audio that you met with those children?

A I met with them at Carol Bunko's, I would stop

in when they were in for their therapy.

MR. BORDEN: Well then, that's what I'm

getting at, Mr. Gerrand, I had asked him the

specific question whether in his interviews with

the children whether or not he had asked them --

A I didn't interview the children at Carol Bunko's

though.

239 Q Okay, fine. Let's make this very clear.

A Sure.

240 Q The only interviews that you had with the

children, then, began in about October and

November of 1990; is that correct?


47

A That's right.

241 Q And all of the interviews that you had with the

children were, in fact, recorded?

A That's right.

242 Q They were either recorded by an audio tape or

video tape?

A They were all recorded by video tape, there were

no audio tapes.

243 Q So that, as you understand it, we have been

provided with all of the video tapes?

A That's right.

244 Q Mr. Gerrand said all we have to do is look at

those video tapes, then, to determine the

questions that you did ask?

A That's right.

245 Q And now, for the record, was there any other

time that you had discussions with the children

other than on those video tapes?

A Discussions regarding disclosure or just

visiting them?

246 Q Just visiting them.

A Certainly I visited them. But we did not

discuss any allegations in those visits.

247 Q And so, if I were to ask you whether you wanted

the children to be more precise in the location

of certain sexual acts, again, your counsel has


48

said all we have to do is look at the video

tapes for the answers?

A That's right.

248 Q Did you know the plaintiff, Pamela Klassen?

MR. GERRAND: When?

249 Q MR. BORDEN: At any time, did you know the

plaintiff, Pamela Klassen, at any time?

A The first I heard of Pamela Klassen was during

disclosures, and certainly I met her after that.

250 Q And when you met her, did you meet her for the

first time when you were arresting her, as well?

A No.

251 Q Did you have a meeting with Pamela Klassen at

any time prior to her arrest?

A Yes, I did.

252 Q And did you actually interview her?

A I tried to, yes.

253 Q You tried to interview her. Where did you try

to interview Pamela Klassen?

A At her home.

254 Q And at her home in Saskatoon; is that correct?

A That's right.

255 Q Was that the same home, 524 Avenue K North,

Saskatoon?

A No.

256 Q What home was that at that time?


49

A I believe it was in the 200 R South.

257 Q 200 Avenue R South is where she lived. Who did

she live with at that time?

A I have no idea, other than her living there.

258 Q Prior to your meeting with Pamela Klassen, prior

to your talking with her, did you determine

whether this lady had a criminal record?

A No, I did not.

259 Q Prior to your arresting Pamela Klassen did you

determine whether she had a criminal record?

A Yes, I did.

260 Q And did she?

A I don't recall. I don't think so, but I don't

recall.

261 Q You have your documents and, again, I'm sure

that you reviewed your documents. Are you

saying that you don't recall whether Pamela

Klassen had a criminal record or not?

A I don't recall.

262 Q Are you saying, then, that prior to the arrest

of Pamela Klassen you may or may not have made

inquiries as to whether she had a criminal

record?

A I'm sure I made inquiries as to whether she had

a criminal record, I just don't recall whether

she had one or not.


50

263 Q I've indicated who my plaintiffs are, my

clients, did any of those plaintiffs or clients

have criminal records?

A Yes, I believe Richard Klassen did.

264 Q Did any other person have a criminal record?

A Not that I recall.

265 Q For instance, did Marie Klassen have a criminal

record?

A As I said, not as I recall.

266 Q Prior to your laying charges against Pamela

Klassen, did you have the opportunity to visit

with a prosecutor and at that time talk about

the case and see whether or not there was

sufficient evidence to even lay charges --

A Yes, I did.

267 Q -- against Pamela Klassen? And who did you

visit at that particular time?

A Who did I visit?

268 Q Yes.

A The file was taken by Matt Miazga and Sonja

Hansen and that's who I conferred with.

269 Q When did you first meet Matt Miazga regarding

allegations of the Ross children against the

plaintiffs in this case?

A I believe it would have been early June of 1991.

270 Q And was it at that time that Sonja Hansen, one


51

of the defendants in these proceedings, was also

appointed to --

A I'm not sure she was there --

271 Q -- assist with the prosecution?

A I'm not sure she was there for the first meeting

I had with Matt Miazga, but she was there after

that, yes.

272 Q And when you met Matt Miazga in June of 1991, as

it relates to Pamela Klassen, did you provide

information to him regarding her?

A I had left the file there approximately the end

of April, at the prosecutor's office, so it

could be reviewed.

273 Q Do you have the file here for view, so I could

get it marked?

(Discussion off the record)

MR. BORDEN: Mr. Gerrand, in order to ensure

that your client has the file that he presented

to Matt Miazga, we'll take a short break so you

have a chance to review that with him. I don't

want him saying this is the file unless, in

fact, it was. He's just indicated some of the

pages attached to that weren't there at the time

he presented it to Mr. Miazga. Would you like

some time?

MR. GERRAND: Okay, we'll review that. But


52

that's his memory.

(Examination recessed briefly, then reconvened)

MR. GERRAND: We've reviewed a number of our

disclosed documents. The question was, I think,

of Inspector [sic] Dueck, whether or not he

recalled what file material was given to the

prosecutor's office in the spring of 1991. He's

reviewed the documents and in our statements as

to documents, in these defendants' statement as

to documents, the documents numbered 531(a)

through 610 are, to the best of Superintendent

Dueck's recollection those documents that were

given to the prosecutor that spring.

A I'd like to make one other clarification here.

You had asked earlier regarding Dr. Jon Conte

and I saw this in here regarding discussing with

him. Now the report that I left -- I still

don't recall speaking to him -- the report says

"we spoke to him" and to the best of my recol-

lection I believe that could have been Liz

Newton, but certainly it was not me that spoke

to him regarding the ritualistic allegations

that were laid against the Rosses and White.

274 Q MR. BORDEN: I'd like to deal with that now

and get this put away. You never dealt with Dr.

Jon Conte?


53

A Not that I recall, no.

275 Q You never saw anything from Dr. Jon Conte in

relation to these charges?

A No.

276 Q You saw Dr. Jon Conte at a seminar?

A That's right.

277 Q You may have received some written material from

Jon Conte that may have been disseminated at the

seminar?

A That's right.

278 Q But as it relates to the cases against the

Kvellos and the Klassens your evidence is and

has been that whether charges were laid or not

had nothing to do with an opinion of a Dr. Jon

Conte?

A That's right.

279 Q There is a reference made to someone having had

a conversation or correspondence with Dr. Conte?

A Right.

280 Q You think that that person may have been Liz

Newton?

A That's what I believe.

281 Q Did Liz Newton provide you with a copy of

anything from Dr. Jon Conte?

A Other than at the seminar, no.

282 Q Did you ask Liz Newton, prior to your laying


54

charges, whether or not she had any information

that might be helpful from any one of these

experts at the two seminars?

A We certainly spoke about that whole area, but

again, I would go back to the police view of

that being that there is no such thing as

ritualistic abuse, it's either sexual or

physical abuse in the Criminal Code, as you're

well aware. So there was nothing there that

would help to lay charges.

283 Q I heard your evidence loud and clear on that, so

I'm just going to ask you now, for the record,

prior to your laying charges of sexual abuse of

children, did you rely on the evidence of a Dr.

Jon Conte?

A No.

284 Q I would like to disregard the words satanic or

ritual in my next questions, I'm talking only

about sexual abuse of children.

A Right.

285 Q Prior to your laying charges against any of the

plaintiffs did you solicit an expert opinion

from anyone regarding sexual abuse of children?

A Well, I would say that there were several.

There was, I believe, a medical examination of

the children by Dr. Joel Yelland. Certainly I


55

spoke to, as I indicated earlier, to Carol

Bunko-Ruys, who I considered an expert in that

area, and I relied on their opinion regarding

these allegations, yes.

286 Q When you said you relied on Carol Bunko-Ruys

because she was an expert in that area, you

must, then, mean she was an expert in the area

of sexual abuse of children?

A That's right.

287 Q Did you rely, then, on any written material from

Carol Bunko-Ruys in that regard?

A No.

288 Q Did you attached to any documents you may have

given the prosecutor any written opinion of a

Carol Bunko-Ruys?

A No.

289 Q Did you attach the opinion of any other person,

such as the opinion of Liz Newton, regarding the

sexual abuse of the Ross children?

A No. As I recall the only documents that were

attached were the medical exams of Dr. Joel

Yelland.

290 Q As you went through the interviews with the

children you must have determined that there was

an issue of the credibility of the children

that's going to arise, that is, whether they


56

were going to be believed; is that correct?

A In any of those cases, yes.

291 Q Yes. And that's what you're saying, as a member

of the morality department you dealt with

children on a daily basis?

MR. GERRAND: He hasn't said that he was a

member of the morality department.

A Youth Section.

292 Q MR. BORDEN: I'm sorry, the Youth Section, all

right. And in relation to being a member of the

Youth Section you would have dealt with

children?

A That's right.

293 Q And it's always a question of whether the

children should be believed?

A I believe in -- if I can state this -- in 1990

the police relied very much on the fact that all

child experts, if we can call them that, social

workers, therapists everywhere told us that

children did not lie about things like this.

And that's certainly advice that we took from

them.

294 Q You had been a member of the Youth Division of

the police service for about a year and a half

before charges were laid; is that correct?

A That's correct.


57

295 Q And during that period of time it became almost

philosophical that as it relates to sexual abuse

children do not lie. Would you say that would

be the --

A I wouldn't say it was philosophical. What I was

saying is that's what we kept hearing from the

experts, from the social workers, from the

therapists, that children don't lie.

296 Q You must have reached a point where you, then,

believed in that premise, that as it relates to

sexual abuse children don't lie?

A I would suggest that certainly I would take that

premise into consideration, but I can't say that

I totally ever believed it.

297 Q All right, fine. Since you didn't totally

believe it you were able, then, to interview

three children, Michael Ross, Kathy Ross,

Michelle Ross, and there were some pretty

bizarre allegations that they made -- am I

correct in asserting that they were pretty

bizarre allegations at times?

A Yes, I would say so.

298 Q And since you didn't really completely believe

that children don't lie and you knew credibility

would come into issue, did you solicit the

advice of any other expert as it relates to


58

credibility matters?

A Other than those that I've named?

299 Q Yes.

A No.

300 Q All right. And because it's credibility issues

and you didn't totally believe children don't

lie, then you would want at least a written

report, I would assume, from one of these

experts. Carol Bunko-Ruys, did you get one from

her?

A No.

301 Q Did she ever tell you that children don't lie?

A I don't recall her specifically saying that, but

certainly that was the talk. You know, I want

to qualify that, as well, when you talked about

bizarre behaviours. I think that children can

also be made to believe that some of these

things were being done or happening. When we

talk about the Ross children, they were four and

six years old, or three and five at that time,

and much, much younger when they were in their

own birth home. And I certainly am open to the

fact or recognize that children can be made to

believe that something like this is going on.

302 Q All right. What you're saying, then, is that

children don't outright lie of their own


59

volition, that they may believe in the very

things they say?

A That's right.

303 Q And that may have been happening in relation to

Michael, Kathy and Michelle in the interviews in

October and November of 1990?

A I wouldn't say in all of them because, again, we

relied on physical evidence there as well.

304 Q If I can just take you back, then, to this area

of children don't lie, and that premise. Did

you receive an opinion from Carol Bunko-Ruys

that these children, Michael, Michelle and

Kathy, were telling the truth?

A Yes, I believe I did.

305 Q All right. And when you received that

information that they were telling the truth,

did you put that to writing?

A When I received the opinion from her?

306 Q Yes.

A Well, other than the occurrence reports, no.

307 Q So that when she said, as your expert, as part

of the loosely-knit team, the children are

telling the truth, you must have put that down

in an occurrence report or some other memorandum

somewhere?

MR. GERRAND: He didn't say that.


60

MR. BORDEN: He didn't say what? I'm sorry.

MR. GERRAND: He didn't say that he put the

verbal statement of Bunko-Ruys into a report.

He said whatever he put was put into the report

and he specifically said he wasn't certain if

that had been put into the report.

MR. BORDEN: All right, fine, Mr. Gerrand.

Then, I guess, all we have to do is look at the

report and we'll find that answer there, that's

what you're saying. Am I correct?

MR. GERRAND: That's his evidence.

MR. BORDEN: That's his evidence, all right.

308 Q So now, you may or may not have put in a report

to Mr. Miazga the opinion of Carol Bunko-Ruys.

Did you see, when we gave you time to review

your documents --

A I didn't review that whole document, no.

MR. BORDEN: All right. Let's have that

marked, then, we'll have it marked as our first

exhibit today. And that is the whole book of

documents, if you don't mind, which would be --

MR. GERRAND: Well, I do mind.

MR. BORDEN: Which would be 531(a) through

610.

MR. GERRAND: Just a minute, please. There are

other documents attached to that that were, in


61

the witness's evidence, likely not part of the

material that was provided to the prosecutors in

the spring of 1991; is that correct??

A That's right.

MR. BORDEN: And that's fine. I think that

what we could do is just mark as Exhibit P-1

those documents, 531(a) to 610.

MR. GERRAND: Sure.

MR. BORDEN: And then the blue sheets which

are at the back of that document, P-1, we will

disregard.

EXHIBIT P-1: FILE PROVIDED TO PROSECUTOR'S OFFICE IN THE

SPRING OF 1991, COMPRISING DEFENDANTS' DOCUMENTS 531(a) TO

610 (NOT INCLUDING ATTACHED BLUE SHEETS)

309 Q We had been talking about the credibility of the

children and there was a point where we talked

about bizarre allegations. Now what is bizarre

to me may not be bizarre to you. But there must

have been a point when, in the interviews, you

said some of these allegations of the children

just don't make a lot of sense. Was there a

point?

A No, I don't believe I ever thought that. I

really felt that these children had experienced

this in some way. Whether the acts had actually

happened -- and here I'm talking specifically


62

about the allegations against their birth

parents and Donald White.

310 Q Yes.

A At no time in the interviews did I ever believe

that the allegations they made against your

plaintiffs, or did I ever doubt that they

weren't real, that they weren't true.

311 Q All right.

A Against White and the Rosses, certainly you had

to have a look at that. But I believed that --

I always believed that the children had

experienced something that made them believe, at

least, that this event had occurred.

312 Q There were allegations of cutting up of babies?

A Right.

313 Q And was that always in relation to the natural

parents or the Ross parents?

A That's right.

314 Q And there was also this idea of eating bats;

same?

A Right.

315 Q The idea of eating eyeballs?

A Right.

316 Q There was the drinking of blood?

A That's right.

317 Q Was that also in relation to the natural


63

parents?

A Only to them, yes.

318 Q And in relation to the cutting up or the

bruising of the children, was that in relation

to the Ross children?

A As I recall it was only to them.

319 Q And to the Ross parents?

A Right.

320 Q So that when we're talking about all of these

allegations of babies and blood, all of that, in

your judgment related to a different time, not

the time that they resided with the Klassens?

A Well, as I recall it. Again, it's all in the

transcripts of the interviews.

321 Q But as you recall things today?

A That's right.

322 Q When it came to actual physical wounds to any of

the children, was it your belief that all those

had occurred at a former time, not when the

children resided with my clients?

A The allegation of being wounded?

323 Q Yes.

A Yes, I believe it did, yeah.

324 Q So that at the end of the day and having regard

to these interviews of October-November of 1990,

was there a period of time when you thought,


64

well, they may have been abused by the Klassens

but nothing else happened other than the sexual

abuse itself? I mean, be clear, you never

believed that there was the cutting up of babies

at the Klassen houses?

A No, I did not.

325 Q Or any of these allegations of devil worship?

A No.

326 Q Of drinking of blood?

A No.

327 Q Of eating of faeces?

A No.

328 Q Of killing of dogs?

A No.

329 Q Was there ever a time when you believed that at

the Klassen and Kvello home there was sexual

abuse to a dog?

A I don't recall. I don't believe so, but I don't

recall.

330 Q All right, so your evidence today is you don't

believe so?

MR. GERRAND: No, his evidence was he didn't

believe so and he didn't recall.

331 Q MR. BORDEN: Yes, all right. So you don't

recall whether there was any scenario involving

sexual abuse to or involving sexual activities


65

with a dog?

A I don't recall.

332 Q All right.

A We're talking here specifically in the Klassen-

Kvello homes?

333 Q Right.

A No, I don't recall.

334 Q I think it would be fair to say, then, and I'm

taking this from what you're saying today, that

when it comes to any one of the plaintiffs you

believed there was sexual abuse?

A That's right.

335 Q But the sexual abuse was sort of one-on-one, and

that is, Diane with one of the children?

A That's what was disclosed, yes.

336 Q Rick with another one of the children; is that

correct?

A That's right.

337 Q But from your recollection, there was no other

activity that took place during the sexual acts,

in other words, the taking of pictures or the

consuming of blood or other intoxicants?

A No, I think the children indicated there was

some taking of pictures in some of the homes, in

your plaintiffs' homes. I don't recall exactly

which ones but, again, they're in the


66

transcripts.

338 Q Sure. So what you're saying, then, is there

might have been the taking of pictures as you

recall today, but not any of these other things

that may have occurred at the Ross house, the

drinking of blood?

A Not the drinking of blood, no.

339 Q Not the killing of babies?

A Right.

340 Q Not the eating of bats?

A Right.

341 Q Or anything like that?

A That's right.

342 Q Now is there anything, in your evidence today,

that you regard as really bizarre, I mean

something that happened at the Kvello or Klassen

home that was just really outlandish, it just

didn't fit?

A No, not that I recall.

343 Q I mean it was bad enough you thought there was

sexual acts going on with these people and these

children; right?

A I agree with that.

344 Q But there wasn't anything beyond the sexual

acts?

A I would suggest that's enough. But, yeah.


67

345 Q Sure, I give you that much.

A Yeah.

346 Q You said that there were pictures that may have

been taken?

A The children, I believe they alleged some

pictures being taken at some of the homes, I

don't recall specifically which ones.

347 Q Right. Now, in all of your investigation of the

Klassens and Kvellos, my clients, my plaintiffs,

did you find any pictures?

A We never searched any of the homes.

348 Q Did you find any pictures, whether you searched

or not, did anyone give you any pictures?

A No.

349 Q Did you see any pictures involving any of these

sexual acts?

A No.

350 Q Did you see any pictures which depicted anyone

of the plaintiffs with the children?

A No.

351 Q Did you see them in pictures involving birthday

parties?

A No, I never saw any pictures of them with any of

the plaintiffs.

352 Q Did you see any video of the Klassens with these

children?

A No.

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