1. THAT I am a Plaintiff in the above proceeding, and as such have knowledge of the following facts and matters deposed to, save and except where same are stated to be based upon information and belief, and where so stated I verily believe same to be true.

2. THAT as a resident of Victoria, British Columbia, I am a person who stands to be harmed or killed by the general destruction which may result from the Canadian governemnt's policy of allowing nuclear armed and nuclear powered ships to berth in Victoria and Esquimalt harbours.

3. THAT my motivation for becoming a Plaintiff stems from my hatred of the hypocracy presently prevailing in our magnificent Canada whereby our federal government pretends our country is still a leading peacemaker in the world and generously shares our blessings, while simultaneously promoting preparation for nuclear war, greater arms trade, and tightening our border against refugees and poor immigrants. I loathe the self-rightiousness whereby Canada claims to be a nuclear free country, yet our government participates in testing Cruise missiles for delivering nuclear warheads and persists in welcoming nuclear powered and armed ships into our harbours.

4. THAT everything I have heard about nuclear fission, including the research of Dr. Rosalie Bertell and a tour, usually reserved for scientists, of the Russian nuclear physics institute at Dubna last July, causes me to fear and abhor it in its basic violence against nature and in its insidious power to damage and destroy living cells, even at low levels of radiation.

5. THAT I came into active work for world peace in late 1983, after hearing the electrifying speech of Darlene Keju of the Marshall Islands, to the three thousand present at the Assembly in Vancouver of the World Council of Churches. She told of the tumours in her own body and in many of her people, together with many other illnesses and deaths, since the testing by United States military of atomic bombs on their islands 25 - 35 years earlier. They were told it was "for the good of all mankind".

6. THAT I sailed to the Marshall Islands in May and June, 1984, with an American crew of eight on a sailboat, Pacific Peacemaker. In visiting among the people I saw for myself what had been kept very secret, the utterly devastating effect of nuclear testing on the previously healthy, happy island populace. Many people were ill, and their way of life was thoroughly destroyed by radiation contamination of their atoll, their land, and their waters. The Australian film, "Half Life", portrays this clearly.

7. THAT in July, 1991, I spent a few days in Kiev, Ukraine, travelling with an International Lanterns for Peace Exchange project. We were welcomed and accompanied by peace activists there. We were entertained by children who had been irradiated in the nuclear disaster at Chernobyl, and we were invited into their homes. We came to know something of the horror and dismay of families there, some with symptoms and some with no symptoms yet. We saw the heartache and anger of people kept uninformed by their government. We learned that their children were under constant medical examination, without reports being given to their families. These were beautiful, gifted children, who presented entire professional level performances. They live 80 kilometres from the nuclear plant which that affected much of the world in 1986.

8. THAT I remember, too, from my trip with the Pacific Peacemaker the grotesque, black nuclear reactor that Westinghouse almost finished building at Bataan, Phillipines, in 1984, on an earthquake fault, charging two billion dollars for what they built in the United States for 500 million dollars. I wonder about the reported leakages of radioactive water into Lake Ontario from Darlington plants.

9. THAT in a lifelong career in heath service nursing, I have come to recognize the frailty of human nature; to recognize the absolute inability of human beings, particularly the male, to handle power unless they have the humility to perceive that their power comes not from themselves. This humility is well illustrated in the life of Jean Vanier. As a health nurse for almost 40 years, I have seen close up the effect of fatigue, anxiety, distraction and anger in causing life threatening errors. It is the combination of intoxication with power and the propensity for human error, that makes completely unacceptable the presence of nuclear reactors and warheads in our midst.

10. THAT on Saturday, November 18, 1991, the U.S.S. Texas, a nuclear powered naval crusier, carrying 8 Tomahawk cruise missiles (each with the fire power of 20 Hiroshima) and two Azrack missiles, invited the Canadian public aboard as the ship was at Esquimalt naval dock, berthed by invitation of the Canadian government. The U.S.S. Texas had just come down from Nanoose Bay, where it had been testing sea to air missiles. This ship is one of the many U.S. naval nuclear warships which has visited our ports and water this year.

11. THAT a number of the Raging Grannies of Victoria, of which I am a member, accepted the invitation to tour the vessel and observe the armaments proudly displayed. The Grannies then put on their hats, placed a teacloth on a hatch with tea cups, teapot, and tea, and invited the commander of the U.S.S. Texas to have tea and hear our deep concerns, some of them written, about his vessel and its contents in our urban harbour. The ship's commander admitted he was very embarrassed, having never had this type of thing happen on his ship. In response to the Grannie's concerns over a nuclear accident in Esquimalt harbour, the ship's commander stated: "That is no business of mine, That is the Base's responsibility." Later, the Canadian base commander, Lieutenant Commander Gibson, sternly escorted the Grannies from the U.S.S. Texas.

12. THAT my life's work in public health nursing has always been directed primarily toward health and prevention of illness. Prevention of a nuclear accident in our urban harbours should obviously be the sensible emphasis of policies. All alternatives would be very costly and likely futile. Prevention is the solution for the dangers from nuclear reactors and warheads. My understanding is that present plans at Canadian Forces Base Esquimalt to react to nuclear accident are completely inadequate. A nuclear accident in our harbours presents an unthinkable scenario, with consequences for a time span of generations.

SWORN in the City of Victoria, Province of British Columbia, November, 1991

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