Search Warrant
October 19 1992
Executed October 27 1992

Associated Affidavit
by Kenneth John Legat


I, Kenneth John LEGAT 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


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 Christchurch.


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, Christchurch.


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 Christchurch.


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.