Search Warrant
October 19 1992
Executed October 27 1992
Associated Affidavit
by Kenneth John Legat
I, Kenneth John
LEGAT of
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
3.
The
difficulty in investigating this type of allegation is that children at the
centre ranged in age from 18 months to five years. Children who have left the
centre have ranged up to nine years of age.
4.
This
causes the Police to be very careful about the way the children are
interviewed.
5.
The
children have been interviewed by specialist interviewers and psychologists
from the Department of Social Welfare's Specialist Services Unit.
6.
Each
interview has been recorded on video to enable the child to talk freely about
the allegations.
7.
To
date 127 children have been interviewed.
8.
Of
these 25 children have disclosed on video various forms of sexual abuse and
physical assaults which have occurred at either the Christchurch Civic Child
Care Centre or at other locations within the inner city.
9.
The
allegations range from indecent touching to full anal intercourse with a child
as young as four years.
10.
As
a result of the initial disclosures the suspect, Peter Hugh McGregor ELLIS, was
initially arrested and charged with representative charges, including indecent
assault, inducing indecent act and sexual violation.
11.
ELLIS
was later charged with further offences until as it stands today, he is facing
33 criminal offences in relation to various sexual and physical assaults on
children. All offences have been laid indictably and
are punishable by imprisonment.
12.
A
number of children have disclosed on video various sexual activities that have
occurred at locations around
13.
A
Police investigation has continued and identified a number of possibilities for
these locations.
14.
During
this investigation it is apparent to the officers involved that the staff of the creche have either been actively involved in
the sexual abuse of the children or have had knowledge of it and failed to take
any action.
15.
Some
of the child complainants have now disclosed that some of the creche staff have
been involved in or present at the sexual and/or physical abuse of the children
16.
Also
the Police investigation has revealed that the mother of the main offender,
Peter ELLIS, has been present during some of the offending.
17.
Police
enquiries have identified her as Leslie Alexia ELLIS, residing at Flat , 2 Street,
18.
Several
of the child complainants have stated that Peter's mother was present at an
address, along with other creche workers, when several children were both
indecently assaulted and sexually violated.
19.
Three
children have disclosed being taken by Petere ELLIS
to his mother's address and while the mother looked after two of the children,
the remaining child was made to have a bath with Peter ELLIS, during which they
were sexually violated. This happened to two of the children at this address.
20.
Several
children have disclosed being physically assaulted by a person they refer to as
Peter's mother at several addresses around
21.
As
a detective, I have been involved with the Christchurch Child Abuse Unit for
approximately two and a half years. During that time I have investigated over
75 different complaints of child abuse. These investigations have included
various offenders that have offended on multiple complainants.
22.
I
also underwent inservice training, including
discussions and conferences with psychologists and personnel at Kia Marama which is the rehabilitative unit for sexual
offenders against children. I have also attended national conferences on child
abuse investigation and attended classes in multiple offender and complainant
abuse.
23.
From
overseas studies and investigations, this type of abuse on
children have occurred in various crèches and play schools.
24.
The
abusers use various scaring and conditioning tactics, including the fear of
death, the use of pornographic videos and pain to condition the child.
25.
These
abusers and the multiple offenders that I have dealt with have often kept
detailed records, diaries and photos of their victims and the activities which
have occurred on them
26.
A
number of offenders have gone to the extent of having detailed records on
computer programs
27.
It
is not unusual for abusers to use pornographic videos to condition the children
as they see behaviour on TV and believe it to be OK.
28.
Staff of the creche and their associates are known to have had in their
possession homosexual and heterosexual pornographic videos to the extent of
having staff parties to view the tapes.
29.
Authority
is sought to search for photographs, documents, diary or diaries, computer
programs or any other record which would show the offender ELLIS and/or other
staff of the creche or other adults involved in any form of sexual physical contact
with children under the age of 17. Also any sound, video tapes or photographs
involving children.
30.
Also
any books, magazines, periodicals relating to sexual acts, homosexuality or
sexual contact with children, also documents containing information on child
sexual abuse, indicators of abuse, education on detection of child sexual
abuse.
31.
Any
instrument or device used in sexual practices as in my experience [it] is not
unusual to find this type of material in active child sexual offenders
possession.
32.
Police
have already seized a number of documents under warrant which will go to aid
the prosecution and now we need to prove who was the author
so need to locate handwriting samples.
33.
Police
are also looking for evidence as to contact outside normal creche activities
between the parties so need to locate and seize phone books, address books,
phone lists.