Search Warrant
June 16 1992

Associated Affidavit
by Robin Alistair Nicholl


I, Robin Alistair NICHOLL of Christchurch make oath and say as follows:


1.                       In November 1991, the Christchurch Child Abuse Unit began investigating allegations of sexual abuse at the Christchurch Civic Child Care Centre


2.                       The suspect in this enquiry was a man who had worked at the centre and had been employed there since 1987. He is Peter Hugh McGregor ELLIS. He resides at 70 Tancred Street, Christchurch


3.                       ELLIS was arrested in early April 1992 and to date has been charged with representative offences against eight children. These offences occurred while at the centre or other locations while in the care of ELLIS.


4.                       Charges range from indecent touching to full anal intercourse with achild as young as four years. The offences in relation to this are indecent assault, inducing an indecent act, sexual violation. All offences are punishable by imprisonment.


5.                       Difficulty investigating this sort of allegation is that the children at the centre range in age from 18 months to five years. This causes the Police to be very careful about the way the children are interviewed and consequently takes some time.


6.                       Of the children who had disclosed abuse by ELLIS away from the creche, one child,                   , has clearly disclosed abuse at his house.


7.                       It has been confirmed by                   mother,                   that Peter ELLIS baby-sat                   at a house he was living in at the time in Hereford Street


8.                       ELLIS was interviewed in relation to offences disclosed by                   on 8 June 1992. He confirmed that he had baby-sat                  at 404 Hereford Street but denied abusing her.


9.                       Other children have disclosed abuse at an unknown house which has been described by them as having an upstairs.


10.                    404 Hereford Street is a large two story house. It is occupied by                   . He is not known to Police.


11.                    Children have variously described the activities that have taken place at the unknown location as having their photograph taken, playing with dolls and having a bath with ELLIS. They have also disclosed abuse by a person other than ELLIS at this address.


12.                    A warrant is therefore sought to enable Police to enter 404 Hereford Street and to search for dolls, photographs or other evidence indicating the premises may have been used to commit offences of child abuse and also to allow Police to photograph the premises.