Dear Ministry of Justice,

I have the following request in regards to my research into the Peter Ellis case.

The ministerial inquiry’s terms of reference did not require Sir Thomas Eichelbaum “to attribute or apportion blame to particular individuals who undertook the interviews”. Nonetheless, Val Sim - the Ministry's then chief legal counsel - warned him that the “personal reputations” of the children’s interviewers, the complainants and their families were at stake.

What expertise or prior experience of administering inquiries did Val Sim possess at the time of the ministerial inquiry? What concerns, if any, has the Ministry expressed for the personal reputations of the eleven crèche workers, who were judged to have been unfairly dismissed when the Christchurch Civic Crèche closed down (as a result of the police investigation)? What concerns, if any, has Ministry expressed for Ellis’ mother, whose flat was raided by police on the suspicion that she, too, had molested children? Please provide me with all records held by the Ministry about these matters.

Prior to the publication and presentation of his final report, what criticisms, if any, did Sir Thomas make of the conviction children's evidential interviews? Prior to the publication and presentation of his final report, did Sir Thomas express general satisfaction with the quality of the conviction children's evidential interviews?

Yours faithfully,

Ross Francis