Affidavit - Jane Mary McDonald, May 10, 2002

I, Mary Jane McDonald, of the City of Winnipeg, in the Province of Manitoba, MAKE OATH AND SAY THAT:

1. I am the Applicant in this Application. I have personal knowledge of the facts hereinafter deposed to by me, except where I state my belief and the information upon which that belief was founded. Where I state my belief upon information received, I verily believe such facts to be true. This Application pertains to a proposed action.

2. I am a member of the Congregation of the Sisters of Holy Cross, which is a religious Order of women in the Roman Catholic Church. The Congregation has a superior general and is administered by the Superior General and a General Council. The present Superior General is Sister Liette Finnerty, CSC. She is also known as the Congregational Animator. Her office is situated in the City of Saint-Laurent, in Quebec.

3. The Congregation is organized into Regions. There is a Western Region with administrative offices in Edmonton, which includes all of Western Canada. Each Region is further divided into districts. The Western Region has two Manitoba districts. Places where Sisters live together in the same domicile are referred to as Houses. (The names and boundaries of the Regions have changed. At one time, Regions were called Provinces. The present Western Region was known as the Western Canada Province).

4. I am informed by my counsel, Anthony Dalmyn, that he has had some preliminary discussions with counsel for Holy Cross, who has suggested that I was a member of the Western Region at the relevant time, and has advised that the Western Region was incorporated under a special Act of the Alberta Legislature under the name Les Soeurs de Sainte-Croix, Province Sainte-Thérese - Sisters of Holy Cross, Saint Theresa Province.

5. I have documents (which are marked as Exhibits later in this Affidavit) which indicate that I was member of a corporation representing the Canadian Provinces together, or the entire Congregation. This corporation is a corporation under Canadian law, with its head office in St. Laurent, in the Province of Quebec.

6. I am 50 years of age. My date of birth was December 27, 1951. I was born in Manchester, New Hampshire, and educated in New Hampshire. I completed high school and then I worked for a couple of years.

7. I was sexually, physically, and emotionally abused by members of my family when I was at home in Manchester.

8. I did not receive any professional therapy or counselling until April, 2001. I have had insights into my actions and emotions in therapy, and I presently understand things that I did not understand at the time that they happened.

9. In therapy, in the last year, I have had some insights into my emotions toward my family. I did not feel safe at home.

10. My family was a Catholic family and I was raised within the traditions and practices of the Roman Catholic Church. I had strong religious feelings and experienced a calling to the religious life as a member of a religious Order.

11. I joined the Sisters of Holy Cross in 1972, when I was 20. I became a postulant, and then a novice and I attended the Novitiates in Franklin, New Hampshire, Albany, New York, and Groton, Connecticut, for a period of three years for formation or training in the religious life. In the second year of Novitiate, I was assigned to teach at a grammar school (equivalent to junior High School) owned by a Catholic parish in Groton, Connecticut.

12. I proceeded through those programs with all the other women who had joined the Congregation at the same time. When I was teaching and working, I did so on a full time basis.

13. In my education as a Catholic, and in my training as a postulant and novice in the Holy Cross Order, I learned that membership in a Religious Order was not a career but a vocation or calling from God to the service of the Church, the people of God.

14. In my education as a Catholic, and in my training as a postulant and novice in the Holy Cross Order, I learned that members of a Religious Order swore vows of obedience to the Rule of the Order, and to their duly constituted superiors in the Order. The vow of obedience was explained as necessary to the good of the Order and the Church. It was a part of my religious beliefs.

15. In 1975, the New England Province invited the Respondent Wilfort to deliver a presentation on personality and human development to the Sisters of the New England Province at the Novitiate and Retreat Center in Franklin, New Hampshire. The presentation was made in the summer of 1975 and was attended by a large number of Sisters in the New England Province.

16. At the time, the Respondent Wilfort was about 40 years old. She was, at that time, the Provincial Superior of the Western Canada Province. She made it known that she had been trained in a method of therapy called "PRH" (Personality in Human Relationships) originated in France by a priest, Father Rochais. Her specialty in PRH was Affectivity which is supposed to be how to love and be loved, and to express oneself affectionately.

17. At that time, the Congregation was exploring changes in religious life, which were later implemented. Until that time, the Congregation has been heavily involved in education. The Congregation and its members later began to close schools or transfer the responsibilities for schools to other agencies, and the Sisters looked for new expressions being educators after closing our schools.

18. At the presentation, the group was divided into smaller groups, and I met the Respondent Wilfort for the first time. She was actively encouraging younger Sisters and professed Sisters who were having difficulty living in a traditional community to consider moving to Canada to the Western Canada Province. I spoke with her and shared my hopes of living in a religious community. She had some documents with her, which were evaluations of their program of formation, under the supervision of the Respondent Wilfort, written by young sisters in the Western Canada Province. She read excerpts to me. I became very interested in what she was holding out.

19. I applied to transfer to the Western Canada Province for one year and I was transferred in September 1975. I spent the next year involved in a program called a "desert year" at the Congregation's Western Canada Provincial House in Edmonton. This program was conducted by the Respondent Wilfort. At that time, the Respondent Wilfort was in charge of Formation, the education of younger sisters in the Religious life, and she was still the provincial superior for the Western Canada Province.

20. During my time in Edmonton, I was present for a meeting at which the Respondent Wilfort sought support to form a new program. I was not fluent in French and I did not understand the discussion, but I believe that the Sisters in Edmonton did not support the new program, and would not permit it to be formed in Alberta.

21. I swore promises (temporary vows) of poverty, chastity and obedience. I swore those promises at Edmonton, Alberta at Easter in 1976. Later in September 1976 I was asked to sign some documents relating to my membership in the Congregation. I signed documents in Frankin, New Hampshire. Several years later I swore perpetual vows in 1985.

22. I returned to Franklin New Hampshire for a year of study at the Congregation's College there. After that I continued my studies at a College in Manchester New Hampshire, but I did not graduate or earn a degree.

23. The Respondent Wilfort was in contact with me during the two years that I was in Franklin and Manchester, and encouraged me to come to Western Canada. She made it known that she was starting a new community and ministry in Manitoba, and she encouraged me to join her in that.

24. During my time in Edmonton and in New England, the Respondent Wilfort counselled me, using PRH techniques. Among other things, she advised and encouraged me to be be physically close to other women - including holding. This was supposed to help to heal me from my rigid fear of being held and touched.

25. Recently, in therapy, I have started to consider whether the Respondent Wilfort used the psychological techniques of the PRH program, or other psychological techniques, negligently or purposefully, while I was in Edmonton in 1975, and in her subsequent communications with me, to influence my behaviour and make me see her as a powerful spiritual leader.

26. I asked to be assigned to this new community, which I understood to be a House of Sisters of the Congregation. The house was situated in Lorette Manitoba. I was assigned to this House and I moved to the House in Lorette in May 1978.

27. When I joined the house, its members were the Respondent Wilfort, and three or four other Holy Cross sisters. There was an Oblate priest, father Raymond Beauregard O.M.I., who I understood to be a chaplain and spiritual adviser. I was informed by him and by the Respondent Wilfort that he had been the Master of Novices for the Order for many years.

28. At that time, the Respondent Wilfort was the regional superior of the Congregation in Manitoba, and the head of the House in Lorette. The authorities in the Congregation agreed that she should supervise my religious formation and act as my director of formation.

29. At the time when I first went to House in Lorette, and throughout the first few years that I was there, the senior members of the Congregation and the Superiors of the Congregation consistently favoured the Respondent Wilfort and her project with praise and support. Many superiors visited and they treated the Respondent with tangible respect and deference.

30. Sister Jeanne Dusseault was the Superior General of the Congregation for 11 years (1974-85 to the best of my recollection). She was a formidable religious leader in her own right. She visited Homes for Growth and strongly and almost unconditionally supported the Respondent Wilfort on matters with the Congregation.

31. The Respondent Wilfort was considered as a leader and a voice of moral authority in the Congregation.

32. Throughout my time at the House in Lorette, I had no contact with or direction or guidance from any other superior except the Respondent Wilfort. She had the full support of all of the authorities in the Congregation, and she had complete control of the Lorette House. In fact the authorities in the Congregation appeared to me to be deferring to her on all issues in which she had any interest.

33. When I arrived at the House in Lorette I learned that the Respondent Wilfort was calling it Maisons du Croissance, or Homes for Growth.

34. Later, I learned more about Homes for Growth. Maisons de Croissance was formed in 1977 as an unincorporated body. It was registered as a registered charity. It was incorporated in Manitoba in December 1980. My counsel has searched and a copy of the search report is marked as Exhibit A. The Respondent Wilfort was a founder of Homes for Growth and was an officer of the unincorporated body and the corporation at all material times.

35. The mission of Homes for Growth was stated by the Respondent Wilfort and other senior personnel of Homes for Growth in several documents which I received over the years, which are marked as Exhibits as below. Some of the documents are dated, and others are not dated. I have tried to place them in order, by context and content:

* Exhibit B, Homes for Growth, by Therese Fortin dated June 24, 1984

* Exhibit C, Faith, a poem by Theresa Fortin dated June 27, 1984

* Exhibit D, the Sacredness of Time, a poem by Theresa Fortin undated

* Exhibit E: Orientation Day, October 3, 1984<

* Exhibit F, "to remember"

* Exhibit G, Orientation Day September 25, 1986

* Exhibit H, The Sacredness of Persons, September 25, 1986

* Exhibit I, Orientation Day October 4, 1987

* Exhibit J, Orientation Day October 9, 1988

* Exhibit K, Homes for Growth - School of Life

* Exhibit L, The Vision of Homes for Growth Inc by Jeanne Wilfort

* Exhibit M, the Vision of Homes for Growth Inc by Raymond Beauregard.

36. Within the first few months that I was at the Homes for Growth House in Lorette, I saw many leaders from many religious Orders and communities within the Church attending programs at Homes for Growth or visiting to learn about its programs. I saw the Respondent Wilfort receiving acclaim as an innovator and leader and receiving great respect from responsible persons holding many offices in the Church in Canada, the United States and France.

37. The program of Homes for Growth included a psychological component. The Respondent Wilfort questioned each person who attended Homes for Growth about their needs and feelings. She held the view that people were all wounded and needed to be healed, and she impressed this view on everyone. If people disagreed with her, she said that they lacked insight, resisted healing, or were possessed by evil.

38. She spoke critically or negatively of professional therapists or counsellors because the majority of them did not have faith in God. She said their counselling could not heal "the whole person".

39. Her approach was supported by various writing and by the existence of other programs. There was, and has been continuing interest in the Catholic church and other Christian communities, in psychologically influenced spiritual programs. Her emphasis on woundedness and healing appeared to appeal to the main themes in the writings of well regarded spiritual writers such as the late Father Henri Nouwen, who wrote a well regarded book on pastoral ministry called "The Wounded Healer". Her theories were plausible to me and appeared to be well received in the Church.

40. I thought that the program had been approved by the appropriate authorities in the Congregation and that the Congregation knew and approved of the methods employed in that community.

41. A short while after I had arrived in Lorette, the Respondent Wilfort praised me and said that I was made for Homes for Growth.

42. The Respondent Wilfort and Father Beauregard were both active in the PRH movement and were involved in giving PRH training to various groups of people - mainly Catholic religious and Catholic lay people in Manitoba.

43. The Respondent Wilfort also suggested that I should receive PRH training, but that never came to pass.

44. The Respondent Wilfort emphasized the special character of the Homes for Growth community and insisted on confidentiality, amounting to secrecy, concerning the programs and activities of Homes for Growth, and avoiding contact with people outside the community.

45. She held counselling sessions for the members of the Homes for Growth Community. Generally the sessions were in small groups. Some member of the Homes for Growth community received private counselling, one on one, from the Respondent Wilfort, or from Father Raymond Beauregard, or from Sister Claire Marquis who was (and still is) a Holy Cross Sister.

46. In my case, the private counselling was by the Respondent Wilfort and the sessions were held in my bedroom. The counselling sessions included the Respondent Wilfort holding and hugging me. She told me that she would heal old hurts and make me a whole person, and would act as a good mother to me. She said that my mother had been evil, and that she, Jeanne Wilfort was pure goodness.

47. On several occasions, the Respondent Wilfort and Sister Claire Marquis came into my room together for counselling sessions. On several of those occasions they would both lie on the bed with me in between them. They said that I needed to be surrounded by love.

48. In the course of counselling, I disclosed the facts of my experiences at home in Manchester - the fact that I had been abused - to the Respondent Wilfort. I discussed my emotional struggle with her. Since I started to receive professional therapy in 2001, I have looked back on this and realized that she must have known that I was vulnerable and needed support and therapy.

49. A few months after this counselling started, she began to tell me that I was special. Shortly after that she came into my bedroom at night and got into my bed and undressed herself. She said she had a special sacred gift for me. She directed me to get undressed. The first time this happened, I refused to remove my underpants.

50. She said I had an evil mother and that I had to suck her spiritual goodness. She asked me to suck her breasts and I complied with that request. This conduct was repeated several times over the next few months and escalated. For the first few episodes, I would not remove my underpants. After the first few episodes I agreed. She would pull me on top of her and say that now we could be really close, and that this was much better.

51. She touched me all over my body and guided my hand to touch her body, including her genital area. She ran her hands over my body. She said this was to help me know my body. In later episodes, she would insert her fingers into my vagina. As she did this, she said it was "God's healing".

52. I did not become sexually aroused by her conduct. I could not tell if the Respondent Wilfort was sexually excited.

53. On some occasions, she insisted on bathing me.

54. At the time, I did not see these events as a sexual violation. I was not comfortable with this behaviour. At the time, I thought that her behaviour was unusual. It did not correspond to anything that I knew about religious observance, spiritual practices or psychological counselling. However it was presented by my superior in the Congregation, within the context of religious formation and personal counselling.

55. I complied with the Respondent Wilfort's demands, as stated in the preceding paragraphs, because she was my superior and counsellor. I felt that I had to comply because she was my superior, and knew what was best, and that I had to submit to this in order to keep my membership in Holy Cross and to carry out my vocation.

56. Throughout, the Respondent Wilfort said that our relationship was special and secret and should not be discussed with others. She said that what she had done was a sacred but secret matter.

57. Recently, in therapy, since April 2001, I have had further insights. I am now aware that I these events were a degrading invasion, which destroyed my dignity as a human being. I do not know whether or not the Respondent Wilfort experienced any sexual pleasure, and I am not sure if she was trying to seduce me. She exercised power over me, to the point of stripping me naked and touching me intimately.

58. After several months, I refused to comply with her demands for this conduct, and she flew into a rage and struck me. This was in 1979. After that, she became very cold to me and humiliated me in front of the community. I was excluded from meetings and events that were attended by other Holy Cross Sisters involved in Homes for Growth. I felt pressured and stressed. I lost weight.

59. The Respondent Wilfort stopped counselling me, and I received individual counselling from Father Raymond Beauregard, who was an officer and agent of the Respondent Homes for Growth. He said that the Respondent Wilfort was very hard on me, and that I was being treated worse than anyone else. He advised me that if I was to have a future with Holy Cross I must give in to Jeanne Wilfort.

60. I would not submit. In therapy, I have realized that I was beginning to isolate myself from her, and from people who were under her control or influence, in order to try to get a sense of security or safety.

61. In the summer of fall of 1979, a number of younger sisters in Western Canada Province of the Congregation were sent to Congregation's House of Formation in Saint-Laurent Quebec, for a year of formation, including theological study under the supervision of Sister Liette Finnerty.

62. The Respondent Wilfort told me that I was not going. She said that I was receiving the formation I needed in Homes for Growth. She said that I was made for Homes for Growth. She said that she had consulted with the Superior General, who had approved her decision.

63. As I stated earlier, I have had some insights into my actions and emotions since I started therapy in 2001. In therapy, recently since 2001, I have realized that the Respondent's decision had the effect of isolating me from my friends and contemporaries in the Congregation.

64. In therapy, I have realized that I felt isolated. All of my friends from home and from my noviate were back in New England, and I was alone in Lorette in the Respondent Wilfort's chosen community.

65. I left the Homes for Growth House in Lorette in 1980. I went to a House in Milner Ridge for the summer. I went to Saint-Laurent (which is a part of Montreal) for the year of formation that fall. I returned to Manitoba the following year.

66. When I left Montreal, I was told by the Superior General that I should return to Winnipeg, enroll in University and complete my degree. We believed that I needed two years of study to complete my degree. When I returned, I discovered that the University would not give credit for my college courses and that I would have to start again.

67. The Respondent Wilfort told me that I did not need a University degree. She directed me to live in the House (it was originally a House owned by the Congregation, which has since been tranferred to Homes for Growth) in Loretter and work in the garden there. After a while, a Catholic lay person who was involved in a Homes for Growth community, who was working at the Main Street project in Winnipeg, as a cook, took a holiday. The Respondent Wilfort directed me to replace her at the project. When this person returned from her holiday, she did not want to return to the Main Street project and I replaced her.

68. I continued to work there for 1 and half or 2 years until 1983. I worked on a part time basis, 2 to 3 or sometimes 4 days a week. Then I worked for the Salvation Army at Baldwin House for 2 years, until 1986. I worked on a part time basis, 3 or sometimes 4 days a week. My salary was paid to the Congregation and I received room and board and living expenses.

69. During the early 1980's Homes for Growth was expanding. It acquired several houses in Winnipeg, and certain properties owned by the Congregation in Lorette and Milner Ridge were transferred to Homes for Growth.

70. After my return from Montreal in 1981, I stayed in Lorette again for a short time, and then after I started working in Winnipeg, I moved into one of the Congregation's houses in Winnipeg. For the next few years, I lived in various Houses of the Congregation and Homes for Growth.

71. There was physical violence in Homes for Growth and in some of the Congregration's houses. I was once assaulted in a Congregation house by Sister Marie Jalbert. On at least two occasions, I witnessed the Respondent Wilfort hitting Sister Jalbert.

72. The Respondent Wilfort had a great degree of control over the lives of people in Homes for Growth and the Congregation.

73. All the Holy Cross sisters in Manitoba knew that there was an issue between the Respondent Wilfort and me, and I felt that many of them were cruel to me because they knew they had her protection and support. My perception at the time was that Home for Growth had become a cult, rather than an authentic religious community and that the Respondent Wilfort and her followers had gained influence within the Congregation.

74. In therapy, I have realized that I did not feel safe in Homes for Growth, or in the Congregation's Houses, because of the Respondent's Wilfort's influence and power in both. I have not given up my opinion that Homes for Growth was a cult. In therapy, I have had further insights into my own situation and the way that the actions of the Respondent have affected me.

75. During this time (1979 to 1986) other women who had joined the Congregation with me were being educated in Universities and receiving professional degrees. My own hope was to study behavioural science or social work and to work with the poor. This would have been a professional career in keeping with the Church's mission to the poor, which would also have allowed me to earn a salary and to contribute to the finances of the Congregation.

76. However, I was isolated within the Congregation. I had incurred the displeasure of the Respondent Wilfort and through her, other superiors in the Congregation. I was never offered a chance to go to school after 1981, and I was afraid to ask.

77. I started a poverty ministry, a drop-in center on Main Street in May 1987. It is called Our Place/Chez Nous. This was consistent the Congregation's decision to adopt an Option for the Poor as a central part of its Ministry. The Congregration agreed to support my Ministry. I tried to keep a link to the Congregation and tried to ensure that I had one or more members of the Congregation on the Board of Directors. The Congregation insisted that I had to find an independent source of funds and I recruited a volunteer board. After the first few years, the fundraising was successful enough to allow the center to pay its expense including a small stipend to me.

78. I did not have the energy or strength to deal with the public for more than 4 days a week.

79. For the next several years, after 1987, I worked independently of the control of the Respondent Wilfort. I completely left Homes for Growth, and would not attend anything connected with that group. I had some contacts with Sister Wilfort, because she was a leading member of the Congregation. As most of the other Sisters in Manitoba were supporters or members of Homes for Growth, I had very few contacts in the Congregation. For a time the Respondent Wilfort was on the Board, but I asked her to resign.

80. In the later part of the 1990's, around 1997, the Congregation went through some administrative changes. As a result of those changes, a number of Sisters who had been trained by Sister Wilfort in their formation, and/or in Homes for Growth, and who were known to me as women who looked up to Wilfort, took charge of Regional administration, and asserted authority over me and my ministry at Chez Nous/Our Place.

81. At this time I began to experience mental distress. At the same time, I was starting to experience health problems. I did not understand it at the time, but in therapy I have realized that I was losing my sense of safety, and that I did not and could not trust anyone connected with or influenced by the Respondent Wilfort and Homes for Growth.

82. When, in therapy, I have looked back at my life since 1980, I have realized that my interactions with other groups and agencies has been minimal, and that it has been difficult for me to maintain any close personal relationships. I was estranged from my family in New England and my friends back home. I was withdrawn and isolated. I did not trust anyone. I never felt safe.

83. When, in therapy, I have looked back at my life since 1980, and considered my feelings and emotions, I have seen that I had feelings of depression, helplessness, hopelessness, and shame. I had a poor body image, and I was not taking care of myself very well. I had sleep disturbances. I was prone to tears. At times, I had thoughts of suicide.

84. I did not have insight into those issues at the time. I thought that I had managed to escape from the cult and to avoid its influence in the Congregation. I thought that I was strong in my ministry and my faith.

85. In therapy, I have been trying to understand my feelings about the Respondent Wilfort's conduct. I was afraid of her, and I was afraid to disobeying her directions to keep her conduct secret. I did not believe I had a choice. All through this the time, I thought that the Superior General knew about the Respondent Wilfort's ways. It was not until many years later that I realized this was not true.

86. The Respondent Wilfort was a senior and well-respected member of the Congregation in Western Canada, and almost everyone in the Congregation appeared to hold her in high regard. Most members of the Congregation in Manitoba were also involved with Homes for Growth. Other Holy Cross sisters outside Manitoba appeared to hold her in high esteem.

87. I avoided her and I avoided other persons involved in Homes for Growth, which meant that I was isolated within the Congregation and separated from the support of the Congregation and my superiors. I thought that she was an influential person in the Congregation and that she was hostile to me. I thought she was working to punish me and undermine my ministry and to undermine my standing in the Congregation. I was very afraid of her power. I have realized in therapy that my fear was demonstrated as a negative attitude, amounting to withdrawal.

88. My reaction to the Respondent Wilfort was noticed, but not understood in the Congregation. I was informed by various women in the Congregation, who were connected to the Respondent Wilfort, that I was defective, and unable to be loved. I was informed that I was the one who had a problem, and that there was something wrong with me.

89. Our Place/Chez Nous now has its drop in center on the main floor of a building at 676 Main Street Winnipeg. There is a small suite on the third floor of the building, and I have lived there for 6 years. I was living there in December 1998.

90. In December 1998, I had a visit from Jacques Cornet who was a Franciscan brother. He had been involved in Homes for Growth. He had volunteered to work with me at Our Place/Chez Nous. When he did, he assured me that he had broken with Homes for Growth. However, he became involved with them again. I knew him to have some emotional problems, and they appeared to have been aggravated by his re-involvement with Homes for Growth.

91. At times he was very difficult. He was on this occasion and I found it hard to be near him, so I left the premises and went next door. While I was in the neighbouring building, I fell through a trap door and sustained an injury. I had a broken hip. Someone called an ambulance and I was taken to hospital, although I was soon discharged home. I later learned that Jacques Cornet had tried to contact Sister Claire Marquis to advise her of my injury, and that information about my injury reached the Respondent Wilfort. The Respondent Wilfort arrived at the Hospital and said that she was going to care for me. I was discharged into her care. This disturbed me deeply.

92. I have realized in therapy that I was traumatized by the fall and I felt vulnerable. I was afraid of her. She had, in the past, humiliated me and physically attacked me and I was afraid of her anger and her power in the Congregation.

93. I felt I had to get protection. I turned to the Congregation for protection and support. At the time, I attempted to break the Respondent Wilfort's command of secrecy and to disclose her conduct to the Congregation.

94. I had never thought about whether the Respondent Wilfort's actions had harmed me, and I had never received professional care or advice on my own mental health in the period from 1980 to May 30, 1999. I did not in fact begin to receive professional care until April 2001.

95. In May 1999, saw myself as attempting to justify myself, and to gain some understanding and respect from the Congregation. I believed that the Respondent Wilfort was leading a sort of cult, operating within the Congregation. I thought that I was being persecuted by the Respondent Wilfort and by other members of the cult within the Congregation. I thought there was a problem, which was the Respondent Wilfort's problem, and a problem for the Congregation to resolve under its own rules, and within the canon law of the Roman Catholic Church.

96. I telephoned the Superior General of the Congregation, Sister Finnerty and began to discuss my situation and the history. I wrote her a letter dated May 30, 1999, a copy of which is marked as Exhibit N. I spent about 3 hours on the telephone disclosing what had happened at the Homes for Growth House in Lorette. Her response was to say that Wilfort's conduct had been intended to be therapeutic and that it had beneficial effects.

97. She directed me to discuss these issues with Sister Lucienne Landry, who was the Regional Animator for the Western Region, based in Edmonton. I followed through and travelled to Edmonton to meet with Sister Landry, and I spoke with her frequently.

98. In my conversations with Sister Finnerty and Sister Landry, I shared some personal history with them. I told them that I had been abused, in my family as a child. I tried to explain what the Respondent Wilfort had done was especially hard on me, after my abuse as a child.

99. Sister Landry had been involved in Homes for Growth and regularly visited Manitoba for retreats and programs. I learned from her that her own experiences had been positive. She said she could not understand what parts of my experience with the Respondent Wilfort were causing my distress. She appeared to acknowledge that I was genuinely distressed and hurt. She told me that she would direct the Sisters in the Congregration who were involved in Home for Growth to leave me alone.

100. The responses of Sister Finnerty and Sister Landry to the information I presented was guarded. At first, I thought that they did not believe what I was saying. It was clear that they could not believe that I had not had a positive experience at Home for Growth. They suggested that I had problems. However they did not not suggest that I should see a therapist or offer any financial support for therapy.

101. I did not hear from Sister Finnerty again until I received a letter in January, 2000.

102. I did not receive professional care or advice on my own mental health during the period from May 30, 1999 to January 2000.

103. In therapy I have realized that I became focussed, in that period on being believed and getting the Congregation to take some action against the Respondent Wilfort in order to relieve my fear of her, for myself and others. I did not have a clear idea of what should be done.

104. In that period of time I contacted other people who had been in Homes for Growth, whom I believed to have been aware of the activities of the Respondent Wilfort with me or to have had similar experiences and shared my story with them. I learned that other people had experienced the same pattern of conduct, or similar conduct, by the Respondent Wilfort. I learned that some of them had felt harmed and had since received professional therapy. I will not identify them in this Affidavit. I have identified them to Sister Finnerty and I identified them to Archbishop Weisgerber, and to Sister Letourneau, in my interactions with them, which I will mention later in this Affidavit.

105. I heard from Sister Finnerty when she sent me a letter dated January 13, 2000, which is marked as Exhibit O. I received it during the third week in January.

106. Earlier in January 2000, I began to receive some spiritual counselling from Father Dominic Kerbrat, who is a priest (a member of the Oblate order) with a degree in psychology. I told him about the behaviour of Sister Wilfort toward me at Homes for Growth, which I have described in this Affidavit. He told me that he thought that her conduct had been abusive. He said that her conduct was one of the worst forms of sexual abuse, because the victim had a hard time recognizing that the conduct was abusive.

107. I continued in spiritual counselling with him for a short time. I was not able to continue, because I discovered, later in January 2000, that I had cancer.

108. I tried to understand what Father Kerbrat had said. He confirmed that the conduct of the Respondent Wilfort had been wrong. At the time, I did not understand that I had been harmed or how I had been harmed. Since I started professional therapy in 2001, I have realized that I might have progressed further in my understanding of those issues if I had remained in counselling with Father Kerbat, but I was not able to do that at the time, due to cancer.

109. My cancer had already progessed to the third stage. I understand that this is very advanced, very close to being incurable and terminal. In February 2000, I commenced a course of chemotherapy which lasted for 18 weeks. I was constantly nauseous. I lost my hair. I was in pain. I was exhausted and drained. My immune system was weakened and I was ill with a variety of infections.

110. In the course of the next several months, I had a radical mastectomy in July 2000, losing a breast, 13 lymph nodes and great deal of muscle tissue and connective tissue. I experienced an allergic reaction to anesthesia, which lengthened my recovery. I then had radiation therapy - a series of 30 sessions. I had to attend for therapy, to try to regain the use of my arm. It was a physically and emotionally draining process.

111. I continued with medical treatment for cancer until November 2000. My physician has finally told me, in February 2001, that my cancer is in remission, but I am still recuperating from the treatment at this time.

112. I was constantly in fear and emotional and spiritual distress. My physician advised me, from January 2001 onward that I was depressed and that I should have therapy for that. She recommended anti-depressant medication.

113. During the course of my cancer treatment, I told my personal physician that I had been abused. When she asked if I was receiving counselling, I gave her an ambiguous answer, and I resisted the idea of counselling.

114. In therapy, I have come to realize that I was fearful of trusting a therapist. I felt at the time that I was not able to deal with my issues about Sister Wilfort until after I had my cancer under control. I was communicating with my superiors, Sister Finnerty and Sister Landry during that time, as I will mention shortly, and they told me to concentrate on surviving cancer, and to trust them to take care of the situation.

115. I did not see a mental health professional or seek an opinion or assessment, or receive any counselling, therapy or treatment until April 2001. I did not know that I had mental health problems. I did not know or understand the consequences of the conduct of the Respondent Wilfort, and I did not know or believe that she had caused me to suffer psychological harm.

116. I continued to write to Sister Finnerty through the year 2000 and into 2001, as I struggled with cancer. I was also in contact with Sister Landry regularly.

117. In my letters to Sister Finnerty and my conversations with her and with Sister Landry, I continued to address the conduct of Sister Wilfort as an issue of discipline and trust within the Congregation. My letters to and from Sister Finnerty in the period after January 13, 2000 until February 2001 are marked as Exhibits:

* To Sister Finnerty, undated, Exhibit P,

* From Sister Finnerty, February 16, 2000, Exhibit Q,

* To Sister Finnerty February 16, 2000, Exhibit R,

* From Sister Finnerty April 19, 2000, Exhibit S,

* From Sister Finnerty July 14, 2000, Exhibit T,

* To Sister Finnerty July 16, 2000, Exhibit U,

* To Sister Finnerty July 18, 2000, Exhibit V,

* From Sister Finnerty July 19, 2000, Exhibit W,

* From Sister Finnerty August 15, 2000, Exhibit X,

* To Sister Finnerty December 31, 2000, Exhibit Y,

* From Sister Finnerty, February 14, 2001, Exhibit Z,

* To Sister Finnerty, April 13, 2001, Exhibit AA.

118. I was speaking to Sister Landry regularly. I trusted her and confided in her. I discussed my medical situation and my pain and my fear.

119. In the first few months of my cancer treatment, I did not discuss the issue of Sister Wilfort with Sister Landry. In the summer of 2000, when I had returned home from the hospital and started radiation therarpy, I mentioned it again. I told her that I had mentioned the conduct of Sister Wilfort to my physician. Sister Landry was upset about this. I told her that I was struggling to understand what had happened to me. I said that I felt I was not getting any support from the Congregation on that issue.

120. In the course of those discussions, I made a suggestion to Sister Landry. I knew that she was involved with some organizations in Edmonton and knew or had access to professional counsellors. I suggested she should contact some qualified professionals and get some guidance and she reacted strongly. She seemed to think that I was suggesting something and telling her to get counselling for herself, although that is not what I was saying.

121. She commented directly on the conduct of the Respondent Wilfort. She said that the Respondent Wilfort was practicing something that she had learned in Quebec in the 1960's and that it was a beneficial therapy, and that I should not question it. She said I was making something of nothing.

122. She also suggested that if I was unhappy in her Region, I should leave it and go back to the New England Region. I said that I had established myself and my ministry in Winnipeg and that I was committed to it.

123. Sister Finnerty, in her letters above and in her conversations with me, continued to avoid the issue or to tell me, in our conversations, that the conduct of Wilfort had been therapeutic and beneficial. She said that I should trust her to take care of the situation.

124. Both Sister Finnerty and Sister Landry expressed confidence in Sister Wilfort and told me that she had healing gifts and spiritual gifts.

125. In August, 2000, Sister Finnerty came to Winnipeg for a meeting and she visited me at home. Before she arrived, she had sent me a fax indicating that she did not want to hear from me about Sister Wilfort, and in fact the subject was not discussed. I did not hear from her on the subject again.

126. I became increasingly depressed, and I considered leaving the Congregation. I thought that Sister Landry and Sister Finnerty were protecting Sister Wilfort, and that they had not shown compassion or support for my concerns. At that stage, my concerns were still concerns of religious discipline within the context of the Congregation and the Church.

127. I brought my concerns to the Roman Catholic Archbishop of Winnipeg, James Weisgerber. I contacted him in December 2000, and had a meeting with him. I presented him with the facts. I mentioned my belief that Homes for Growth was a cult. I left it to him to determine if the conduct of the Respondent Wilfort was a cause for concern.

128. He said that he did not want me to worry about it while my health was bad. I gave him the names of contacts and witnesses. I was later informed by him and do verily believe that he contacted and interviewed some of them.

129. In March 2001 the Archbishop informed me that the Congregation for Religious in Rome had appointed Sister Marguerite Letourneau to make inquiries. Sister Letourneau was a member of the Sisters of Charity of Montreal, also known as the Grey Nuns. She had been the Superior General of her Order. He asked me to meet with her.

130. In March 2001, I was in a crisis. I felt suicidal. I had seen a TV program on abuse, and I called a 1-800 number and received some advice. I called Klinic, and I called the employee assistance program of the Grey Nuns. I obtained a referral to the practice of Cynthia Jordan and her associates. I spoke to her associate, Ms. Frankel. I had my first sessions with Ms. Frankel in late March 2001, and Ms Frankel assessed my case and began to treat me by psychotherapy.

131. In a letter dated April 13, 2001, addressed to Sister Finnerty, marked as Exhibit AA (above), I requested the financial support of the Congregation for a course of therapy. I was later informed that they had agreed, for a period of one year.

132. Ms. Frankel and Ms. Jordan prepared a letter to the Congregation dated April 17, 2001. I was informed and do verily believe that the letter was sent. A copy is marked as Exhibit BB to this Affidavit.

133. I was very moved when I read this letter. This was the first time I had received an opinion from a qualified professional. For the first time, I was told that the Respondent Wilfort's conduct towards me had caused significant psychological harm.

134. I did not understand the nature and degree of the harm until later in therapy, and the process has been painful. It is an incomplete process. I have continued in therapy since April, 2001, with an appointment almost every week.

135. In May 2001, I met with Sister Letourneau. I gave her the names of my contacts - other women who had been abused in Homes for Growth by the Respondent Wilfort, or who were witnesses to her behaviour. I authorized my therapist to meet with her and to disclose information, and I am informed by Ms Frankel that she met with Sister Letourneau.

136. Sister Letourneau treated me with respect and compassion. She said that she hoped that I could meet with Sister Wilfort, so that she could see the pain she has caused. I do not know what Sister Letourneau reported to the Congregation for Religious and what directions were given to the Congregation and the Respondent Wilfort.

137. In the summer of 2001, I spoke to Archbishop Weisgerber about the investigation by the Congregation for Religious. I had started to think that the Church was covering up on the issue of the Respondent Wilfort's abuse and I suggested that I would go to a lawyer to see if the Respondent Wilfort could be charged with criminal offences. He encouraged me to be patient and to wait for the results of the investigation (by Sister Letourneau).

138. He also told me that Sister Finnerty and the Congregation were providing him with negative information about me, and that he thought the same information was being given to Sister Letourneau. He advised me to avoid communicating with the Congregation.

139. The Archbishop advised me to remain in the Congregation and to look to the Congregation for the cost of various treatments and support that I required at the time.

140. One issue that arose in the summer of 2001 was a vacation. My doctor was recommending a long vacation. I was being criticized by the Congregation for other expenses, such as dental bills and I was afraid to ask the Congregation for funds for my trip.

141. Later in the summer, in August, the Archbishop told me that he did not know the results of the investigation by Sister Letourneau and would likely not get the results.

142. In the summer of 2001, in consultation with my therapist, and her supervisor Dr. Jordan, my doctor prescribed an anti-depressant medication. I have become more depressed, and I was starting to have suididal thoughts again. I realized that I have had suicidal thoughts, off and on, since 1979 when I lived in Lorette.

143. The medication has assisted in fighting depression, and since I started on the medication, I realized that I have been suffering for a long time.

144. I have realized in therapy that I have not had the energy to work full time since 1978. I have learned that there is a connection between the Respondent's Wilfort's action, and my difficulties in dealing with people, my lack of energy, and my isolation in the communities. My counsellor has told me that I am depressed and suffering from post-traumatic stress disorder, and that I am, at present, disabled.

145. I am unable to concentrate on one thing. I am not able to sit still and read. I cannot carry out tasks like balancing a checkbook. I find that I have become increasingly fragile, although my therapist expects healing to start.

146. My depression has continued. It is not predictable. I have some good days, and then bad days. I work two days a week. I never spend time with the clients alone. I am too vulnerable and it is hard for me to feel safe.

147. I have a further employment handicap. I have a high school education, for reasons explained already. I have had a very specialized and narrow working experience as I tried to pursue a vocation in the Congregation under the circumstances that I have described. My work has been limited by my ongoing depression and personal issues as described above. This is contributing to my disability, and to financial losses.

148. I have found it difficult to concentrate during religious services and I have a problem listening to preaching or liturgy in which the authority of the Church is emphasized. I have a strong, and unchanged faith in God, but I am now experiencing issues with authority.

149. In the fall of 2001 after my situation was more stable, my therapist suggested I should see a lawyer and I first met with a lawyer about this case on November 28, 2001.

150. I have found that reviewing the case with my therapist and my lawyer leads to episodes of depression, and the process has been difficult for me.

151. In December 2001, I applied to the authorities in the Congregation and the Church to be released from my vows. I wrote to Sister Finnerty on December , 2001. A copy of my letter is marked as Exhibit CC.

152. I have recently been informed by Sister Liette Finnerty that the Congregation for Religious has granted an indult. She wrote to me on March 5, 2002 and a copy of her letter is marked as Exhibit DD. The enclosures to her letter are marked as Exhibits EE, FF, GG and HH. The enclosures include copies of documents I had signed in the years that I took my vows, 1976 and 1985.

153. I have not accepted the indult or resigned from the Congregation.

154. In my knowledge of the practice of the Congregation, a departing member who leaves with the approval of the Church meets with her superiors and is treated with dignity. Sister Finnerty and Sister Landry have not offered to meet with me. A departing member who leaves with the approval of the Church normally receives transitional financial assistance, which is often calculated as an allowance of $500.00 for each year of service. This has not been paid or offered to me.

155. At first, when I turned to my superiors in 1999 I expected compassion and support. I have realized that they are concerned to suppress knowledge of the unconventional therapies administered by Sister Wilfort, and to suppress knowledge of her abusive behaviour, and the complicity of the Congregation in these matters.

156. I felt that I had received unjust adverse treatment from my superiors because I have raised issues over the practices of Sister Wilfort - not only with me but with several other people - and Home for Growth.

157. I have realized that I was sexually abused by the Respondent Wilfort and that the Respondent Wilfort used psychological techniques to affect my behaviour over a period of time starting in 1975, and including the time when I was involved with Homes for Growth, and that I have suffered harm as a result of her actions.

158. I seek leave to commence an action for damages. My proposed action is against all the Respondents in this Application. The proposed pleading would allege a cause of action for negligence, breach of fiduciary duty and deliberate misconduct by the Respondent Wilfort in the course of purported psychological counselling and therapy during my religious formation, from 1975 to 1979. The proposed pleading would allege a cause of action for assault, negligence, and breach of fiduciary duty by the Respondent Wilfort, with respect to sexual, physical and emotional abuse at the Lorette House, in 1978 and 1979.

159. I am advised by my counsel that my causes of action may be affected, in part, by the operation of a limitation provision in the Limitation of Actions Act and I seek relief.

160. I make this Affidavit in good faith.

SWORN BEFORE ME at the City of Winnipeg in the Province of Manitoba, This 10th day of May, 2002 (Signature on Original) Jane Mary McDonald


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