Court File No. 40752/96

ONTARIO COURT

(GENERAL DIVISION)

BETWEEN

PERRY DUNLOP

Plaintiff

-and-

 CLAUDE SHAVER, CARL JOHNSTON, JOSEPH ST. DENIS, LUCIEN BRUNET, BRENDON WELLS, THE CORNWALL POLICE SERVICES BOARD, CORNWALL POLICE SERVICE, DOUGLAS SEGUIN, THE ROMAN CATHOLIC EPISCOPAL CORPORATION FOR THE DIOCESE OF ALEXANDRIA CORNWALL IN ONTARIO, MALCOLM MACDONALD 

Defendants

 AFFIDAVIT OF RON LEROUX

 I, Ron Leroux, of the Town of Norway, Maine (United States of America), solemnly swear that: 1. I currently live in Norway, Maine with my family. Prior to my moving to Maine, U.S.A. on or about February, 1994, I lived in Summerstown, Ontario, Canada for approximately twenty-six (26) years. 

2. I presently work as a contractor in the construction industry and as a contractor in the painting industry. 

3. I am currently (49) forty-nine years old and my date of birth is January 23, 1947. I was born in Cornwall, Ontario. My parents are the Late Osborne Leroux and Mrs. Zilda Rose Leroux. 

4. I lived in a house on the St. Lawrence River one door away from Mr. Ken Seguin house. I was very good friends with Mr. Ken Seguin. We often went for coffee together, he would come to my place as I would go to his. We also often went for meals together and my wife would frequently make him supper. 

5. Being a close neighbour and very good friend of Ken Seguin, I knew a lot about what was going on in his life. I attended his house daily. I also did lots of work at St. Andrews Parish House and some work at Malcolm Cameron’s summer residence. 

6. I was at several parties at Ken Seguin’s house, Malcolm Cameron’s summer residence and St. Andrew’s Parish House where I observed among others: 

1. Bishop Eugene LaRocque 

2. Malcolm MacDonald 

3. Ken Seguin 

4. Chief Claude Shaver 

5. Murray MacDonald 

6. Milton MacDonald 

7. Ron Wilson 

8. Father Gary Ostler 

9. Father Kevin Maloney 

10. Father David Ostler 

11. Father Rory MacDonald 

12. Gerry Renshaw 

13. Father Charles MacDonald 

14. Mark Menard 

15. David Silmser 

16. XXXXX [C-5]

17. David Latraielle 

18. Gino 

19. Daniel Flipson 

20. Sylvain Flipson 

21. Stuart McDonald 

22. Harvey Berry, Jr. 

23. Robert Renshaw 

24. Fred Renshaw

 25. Bob Varley 

26. Travis Varley 

27. Dale Crowder 

28.  XXXXX [C-8]

29. Stuart McDonald 

30. Al Laplante 

31. Fern Touchette 

32. Kara Berry 

33. Joss Van Deepen 

34. Male prostitutes both adults and juveniles, altar boys and several others 

7. I can advise and have witnessed a "clan" of pedophiles which were comprised of the following people: Bishop Eugene Larocque; Father Charles MacDonald; Father Donald B. McDougald; Father Bernard Cameron; Father Kevin Maloney; Father Gary Ostler; Father David Ostler; Father Ranald (Rory) MacDonald; Claude Shaver (ex-Chief of Police of Cornwall); Mr. Ken Seguin; Late Msgr. R.J. MacDonald; Late John McPhail; Late John Donihee; Late Norman Loney; and Malcolm MacDonald, Q.C. 

8. I have witnessed sexual improprieties, molestations, fondling, oral sex, intercourse (anal) between the above-named "clan " members and minors through the period of 1957 or 1958 to 1993. These sexual improprieties with minors (male) occurred at Cameron’s Point, Summerstown, Ontario; Birch Avenue, Fort Lauderdale, Florida, U.S.A.; Saltaire Motel, Fort Lauderdale, Florida, U.S.A. Lot 17, Concession 1, R.R.#1, Cornwall, Ontario; Malcolm MacDonald summer residence, Stanley Island, Ontario; Malcolm Cameron’s Law Office, Pitt Street, Cornwall, Ontario and St. Andrews Parish House. 

9. I have also seen pictures of minors possessed by Malcolm MacDonald. Malcolm MacDonald advised that he took all the pictures himself with a Polaroid Camera. I visually recognized some of the minors in the pictures who were naked and/or exposing their penis and genitals. I recognized Mr. Mark Menard; XXXX [C-5]; Davis Silmser and Bob Varley in these pictures. All of these minors would have been between the ages of (14) fourteen to sixteen (16) with the exception of Mark Menard, who would have been between (17) seventeen and nineteen (19). These pictures were stored in Malcolm’s middle desk drawer of his office which remained unlocked at all times. Malcolm often left the drawer open with these pictures exposed. Malcolm’s legal secretary, Connie, would have seen these pictures on numerous occasions. In fact, Malcolm took some of the "minor" pictures in his own office. He (Malcolm) also had several other pictures of minors in which I do not know by name. 

10. Malcolm MacDonald also possessed several "Kiddy Porn" tapes which he stored in his residence library at Captain MacDonald Rd., Cornwall, Ontario. Malcolm also had more pornographic pictures and sex toys at his home residence. 

11. Malcolm MacDonald also possessed "Kiddy Porn" magazines at his summer residence, Stanley Island Lake. Malcolm also had "Kiddy Porn" tapes at this summer residence during the summer months. 

12. I owned and operated, with XXXX [C-8], a renovation company called XXXXX. Our business office was located in the outer front office in Malcolm MacDonald law office. The walls were very thin and you easily overheard any of Malcolm’s conversations even with the door shut. Myself, XXXXX [C-8] and Connie, Malcolm’s Secretary, were privy at different times to private conversations of Malcolm’s. 

13. The "Clan’s" regular meeting spots were Ken Seguin’s home in Summerstown; Malcolm Cameron’s summer residence on Stanley Island and St. Andrews Parish House. I observed "clan" members at these meeting spots all the time, some more frequent than other. Other "clan" meetings were held at Cameron’s Point and Birch Avenue Area, Fort Lauderdale, Florida. 

14. I have observed Claude Shaver at Ken Seguin’s home, at Birch Avenue, Fort Lauderdale and at Malcolm Cameron’s summer residence. Mr. Claude Shaver was definitely a "clan" member and was very good friends with Malcolm MacDonald, Father Charles MacDonald, Ken Seguin and Bishop Eugene Larocque. I observed Mr. Claude Shaver talking with young male prostitutes on Birch Avenue, Fort Lauderdale. I observed these male prostitutes to be approximately thirteen (13) to fifteen (15) years old. 

15. I observed Bishop Larocque talking to young male prostitutes on Birch Avenue, Fort Lauderdale. I observed these male prostitutes to be approximately thirteen (13) to fifteen (15) years old. I also observed Bishop Larocque in the late 1950’’s or early 1960’’s, as a Father, performing inappropriate, illegal and perverse sexual acts with minors, Altar Boys, at Cameron’s Point. In fact, Eugene Larocque committed illegal, inappropriate and perverse sexual acts against myself while I was a minor. I also observed him fondling and molesting other Altar Boys at a cottage at Cameron’s Point. I attended with Stan Legalais and was dropped off by an adult as we were both too young to drive. During this party, I observed a ceremonious ritual of candles in the Altar Boys rectums with sheets over them. These Altar Boys were walking around with the candle in the rectum and the sheet over them with no clothes on, during this ceremony, several members of the clergy were fondling these young boys, and molesting them. I specifically remember Bishop Larocque (who was then a priest), Father Cameron and Father McDougald molesting and fondling these Altar Boys. In fact, all of the aforementioned priests also committed illegal, inappropriate and perverse sexual acts against myself as a minor. The place, Cameron’s Point, was occupied by a priest that drowned in his boathouse in the mid-sixties. This ritual went on on a weekly basis. 

16. I also observed Ron Wilson at Birch Avenue, Ft. Lauderdale. 

17. It was well known that Birch Avenue was a pick-up point for minors, who were prostitutes and was a problem area for the local police. Most of these minors were males. The Marlin Beach Hotel was also a well known haven for male prostitutes, mostly minors, the clan members called this area the "Gaff". 

18. Malcolm and Ken Seguin frequented the "Gaff" area at Ft. Lauderdale yearly. I observed sexual improprieties with minors by Malcolm at Saltaire Motel. 

19. On or about mid-December, 1992, I attended Ken Seguin house and found him in a state of depression. I observed him at 5:30 a.m. in his pyjamas on the ice behind his home. He was suicidal. I immediately went outside and talked him back into his place. At this time he told me about the allegations against him made by David Silmser. He also told me there was another person involved. I brought him to Florida to help him recuperate. 

20. I returned to Ft. Lauderdale on or about February 3 or 4, 1993 by myself. I return to Canada on or about early March, 1993 to find my home in a complete mess as if someone had searched my home. I received a telephone call from the O.P.P. Lancaster, Ontario advising me that they had done a search of my house and that they found a leather suitcase and weapons. The officer asked me to go to the Station and I went the next day. When I arrived, I was greeted by an O.P.P. officer, 6’3 or 6'4 in height, who talked to me about the leather suitcase. He asked me if I owned the suitcase and I replied "No". He seemed to not want me to leave with the suitcase. He asked me if I knew what was in the suitcase and I replied "No". He then said that he knew what was in the suitcase and advised that it contained pornographic tapes. I signed a release form and left the suitcase at the O.P.P. station. This officer advised me that he was going to destroy these tapes. I then returned home. 

21. A few hours after returning from the O.P.P. station, I attended Ken’s house to ask him what was going on as he had agreed to take care of my home during my trip. Ken Seguin was also suppose to look after my dog. I was infuriated and asked him about this suitcase. Ken Seguin admitted that it was his suitcase and that it contained personal pornographic tapes with his handwriting on them. Ken also stated that it was his tape collection from over the years and that he wanted them out of his house. He said that he was under investigation for a sexual assault and that these tapes would "clinch" a conviction against him. Ken said that it would ruin him. Ken was extremely apologetic. I also observed destroyed tapes and probation documents in a bin at my home, on the upper floor outside the master bedroom bathroom, I was surprised to find the destroyed tapes and documents. 

22. On or about March, 1994, in the presence of my wife, Cindy Leroux, I advised an O.P.P. officer and an Ottawa officer of these tapes. Both officers stated that they knew nothing of these tapes but would look into it. 

23. I plead guilty on Malcolm’s advice to an "unsafe storage" charge and was fined $300.00. 

24. From March, 1993 to end of August, 1993, I am privy and present during several conversations between Malcolm, Ken Seguin and Father Charles MacDonald. Malcolm advises to Ken Seguin not to worry as he was going to take care of the allegations against him and Father Charles MacDonald. I remember a heated discussion between Malcolm and Ken Seguin on or about May, 1993 in which Malcolm stated that he had the connections to take care of the allegations and that he was the person to do it. He also stated that he was going to talk to the Chief and would settle things. He told Ken to stop being so paranoid about things. 

25. On or about June or July, 1993, Ken Seguin advised me that "Heidi" was in charge of the case and that it wasn’t going to go anywhere. He appeared happy about this. 

26. On or about June or July, 1993, I started to hear the name Stuart McDonald being discussed by Malcolm and Ken Seguin. Ken advised that the allegations against him and Father Charlie were not going to go anywhere as Stuart McDonald was now looking into it. I continued to hear the name Stuart McDonald frequently from Ken during the months of June, July and August, 1993. 

27. On or about a Friday evening in late August, 1993-early September, 1993, I was told by Ken Seguin that there is going to be a gathering a Malcolm’s summer home on Sunday. He stated that Bishop Larocque, Claude Shaver, Ron Wilson, Malcolm, Father Charlie, and others would be in attendance. He said they were having a get together on the Island. 28. On the Sunday morning at approximately 8:30 a.m., myself and Ken are having a coffee in Ken backyard. Malcolm arrives and states that he has steaks, beer and booze for an army. Malcolm states that a lot of important people are showing up for dinner today. Malcolm stated that Ron Wilson, Claude Shaver, Bishop Larocque, Stuart McDonald, Brunet, a Judge from his drinking days, and Father Charlie would be in attendance. At approximately 11:30 or so, I observed Malcolm turn into Ken Seguin’s driveway. I then observed Murray MacDonald exit Ken’s back door. I clearly observed Murray in the back yard. Afterwards, Shaver arrived with two (2) other males. They exited the car and I observed the two (2) other males to be Stuart McDonald and another cop. They go to Ken’s wharf and get into Malcolm’s boat. They, Malcolm, Claude, Stuart and the other cop, head towards the Island and wave at me as they are leaving. A second vehicle arrives with two (2) males in it. They exit the car and I observe Bishop Larocque and another priest. Both of them go to Ken’s wharf and Malcolm had returned. Just before they were to leave, Malcolm, Bishop Larocque and the priest, Father Charles MacDonald arrived in his car with another priest, Rory MacDonald.They immediately went to join the others in the boat. I remember that Ken went and got a red milkbox from his boathouse as Malcolm’s boat only had four (4) seating capacity. I was in Ken’s backyard, approximately 15 to 20 feet from the boat as the five (5) of them pulled away for the Island. I told Ken I would put his phone away as I thought he was going to join them. Ken advised me he was going to go in his own boat and they proceeded to leave. A fourth car pulled up along the front of Ken’s house, stopped for a few seconds and left towards the marina. I observed Ron Wilson and waved to him. He waved back. I observed two (2) other males in the car with Ron Wilson. I then observed Ken Seguin leave alone for the Island. On or about 3:30 p.m. to 4:30 p.m., Ken returns alone and pulls up to my wharf. Ken advises me that he has a new lease on life and seems elated. He advises me that the allegations against him are settled and the he can get on with his life.  

29. Ken Seguin advised me that a bunch of "V.I.P.’s" were on the Island. 

30. After the Sunday meeting on the Island, Ken seemed revived for a few weeks. Then something happened and he started to get nervous again. He advised me that calls were starting again and that a cop was not going to let it go. Ken mentioned the name Dunlop, in fact, he said "fucking Dunlop". I started to observe in late September, October and November, 1993, a great deal of traffic at Ken’s house. Father Charlie and Malcolm attended very frequently in the evenings. I observed Ken getting more and more nervous; and more and more depressed. He was suicidal. 

31. Approximately two weeks before Ken’s death, Ken advises me on a planned hit against Dunlop and family. I would go over to his house daily during this two (2) week period. Ken would violently throw-up, was loosing weight and was extremely sick. Ken was in this state of mental disarray because a family (Dunlop’s family) was going to be killed. In fact, I was present at a meeting between Malcolm, Ken and Father Charlie, for a brief period, where they openly discussed the killing of Dunlop the Cop and his family. Father Charlie was the most vocal and enraged stating that he hated Perry Dunlop, and that Dunlop and family will be disposed of. Malcolm stated that Dunlop is not going to let it go. Malcolm said that he had inside information from the Chief that Dunlop was not going to let it go. They continued to discuss the planned attack and I left to go home. Approximately two (2) days later, at Harv’s Diner, Malcolm and Ken are sitting across from each other and talk about Dunlop. Ken seems to want to discuss it, but Malcolm says not here. Ken then says "where are we going with this now" and Malcolm responds "I don’t want to talk about it here and now, it’ll be taken care of, stop being so paranoid. I keep telling you about your paranoia." 

32. The next day, I arrive at Ken’s home in the evening and he is a total mess. Ken is on the couch wrapped in a blanket and he is shaking. Ken refuses to do anything. He says that he does not deserve to live anymore, all queers are scumbags. Ken also states "I feel bad for this poor cop and his family. They want to get rid of them. They are going to rub them out." Ken says "I don’t deserve to live. I just want to die." Ken proceeded to cry and lay on the couch. I sat with him for thirty ( 30) minutes or so, and went home as he fell asleep. 

33. A few days later, at Harv’s Diner again, Malcolm and Ken seemed very tense. Ken advised Malcolm that he could not function anymore and that something better be done right now. I can’t go on like this. Ken asked Malcolm if he had heard anything more on the cop, Malcolm said I will talk to you at my office. 

34. Approximately four (4) to five (5) days prior to Ken death, a male in a Mercedes Benz showed up in front of Ken’s home and got out of the car. The car was facing towards town, I asked him if he was looking for someone. He said he was from Ottawa and was a Land Developer looking to buy property. His phone rings in the car and reached into shut it off. As he reached in I noticed a gun on his belt. I asked him if he was a cop and he advised that he was a Land Developer. He asked me "who lives in this house" as he is pointing towards Ken Seguin’s home. I advise that it is Ken Seguin’s home. He said the lots are small and made small talk. In retrospect, I find it strange that this person was looking at Ken’s home. 

35. Ken Seguin committed suicide on the night of November 24, 1993. 

36. A few days prior to November 24, 1993, Ken advised that he was going to draft a confession in a report form and quit his position. He was attempting to figure out his pension and talked about the points system. Ken stated that he was going to write it all down in a report. The report was later verified by Joss Van Deppen at Ken’s funeral. Joss advised me at the funeral that Ken had left a full report on his desk. He also stated that he told Ken to watch his step for years, Malcolm had also stated that Ken Seguin had left a report on his desk. 

37. At the funeral, Malcolm made his way to me and told me to keep my mouth shut. He said whatever you know and whatever Ken said, "keep your mouth shut". I questioned Malcolm on his involvement in Ken’s death. He said that he was only a messenger boy and became angered. He then left. 

38. I, later that day, with my wife and son Dustin returned to Wilson’s funeral home to talk with Ron Wilson. He, Ron Wilson, stated that they were all into it up to their necks. He specifically named Claude Shaver, Bishop Larocque, Malcolm, Father Charlie, a Crown Attorney and then he stopped. He then stated that they will eventually get to the bottom of all of it. I stated there were others. He stated "Oh yes". 

Ron Wilson then repeated the names of Claude Shaver, Bishop Larocque, the Catholic Church, Diocese of Alexandria, Malcolm MacDonald, Father Charles MacDonald and a Crown Attorney as been into it up to their necks and they will get to the bottom of it. I left shortly thereafter. 

39. I make this affidavit no other or improper purpose. 

SWORN BEFORE ME at the ) 

Town of Newmarket, in the

Regional Municipality of York ) 

This 13 day of November, 1996 ) __

A Commissioner, etc. _______________                             Ron Leroux

Ron's Inquiry Recantations and Testimony 

(1) Cameron's Point and the ritual

(2) Who's on or off "The List"?

(3) Joss Van Diepen incriminated