David Crichton
Dealing with ministry an “appalling” experience
David was placed into care at the age of one, by his mother. David’s mother was unable to care for him because she had serious mental health difficulties and an unstable financial position.[i] His mother first placed him in St Barnabas Babies’ Home in Wellington. Over the next four months David was placed under the guardianship of the Director of Presbyterian Social Services Association (now known as Presbyterian Support Central) and had two different foster placements, before ending up in The Salvation Army Residential Nursery at 18 months old. He went on to spend the rest of his childhood in the care of various foster families, State and faith-based institutions.
The Department of Social Welfare was involved in his care throughout most of his childhood, and at the age of 14 he became a ward of the State. He was moved constantly between different homes and institutions – at least 40 times by his reckoning, although the exact number will never be known because of a lack of records. Most placements were in foster care homes, arranged by the Presbyterian Support Services Association and the Department of Social Welfare. David also spent time in “family homes” and a nursery run by The Salvation Army and at the State-run Epuni Boys’ Home in Lower Hutt.
David’s father, who was Samoan, was not around when he was born. David’s records suggest his mother and her family held disparaging views about Samoans. He grew up believing he was Māori. His mother gave him the last name Mohi, the surname of his mother’s husband at the time. Records held by State agencies and Presbyterian Support Central show they knew who his father was, but they never tried to contact him, or David’s extended paternal and maternal family about providing care for him. Some of his extended family members lived 20 minutes away from him while he was at Epuni Boys’ Home. David has no recollection of meeting his father or connecting with his Samoan aiga, or family, and culture. At 14, he was allowed to briefly attend his father’s funeral.
David suffered physical, emotional and psychological abuse, as well as cultural neglect while in care. Staff physically and psychologically abused him. Other children in care physically abused him. He also suffered sexual abuse at Epuni Boys’ Home, and at a foster home. At 14, he was placed in a foster home with John (not his real name), who was responsible for his care. John regularly gave him drugs and sexually abused him. John was later convicted of sexual offending against other boys – offending that took place just a few years before David lived with him.
With almost no photographs and family to help piece together his past, David’s care records are valuable to him. They are all he has to try to make sense of what happened in the first 18 years of his life, and why. It was from these records, some of which he did not receive until he was 30, that he discovered he was Samoan, not Māori.
Impact of abuse
The consequences of his time in care have been profound and enduring. In his early 20s, he was convicted of firearm and cannabis offences and theft. He spent time in prison for this. He said his offending was a direct result of his abuse and the substance addiction he developed after being given alcohol and drugs as a child. His convictions make it very difficult for him to find work. He said he found it belittling and embarrassing to have to explain his convictions and absence from the workforce when applying for jobs. The clean slate scheme does not apply to him because he was given a jail sentence. His convictions also prevent him from travelling overseas with his family.
Of all the abuse he suffered, David said the erasing of his Samoan identity had had the most damaging impact on him and his aiga. He spent all his childhood, youth and early adult life believing he was Māori. He covered himself in Māori tattoos in the belief he was Māori. Discovering his Samoan heritage sent his life into a spin. His whole life had, he felt, been a lie. It took him 15 years to fully accept his true ethnicity, and as part of that acceptance he changed his last name to Crichton, his father’s surname. David’s partner and children have had to learn to cope with the “dark cloud” that would descend on David from time to time – an adjustment he said they should never have had to make.
Unsatisfactory results
David has spent more than 25 years trying to get redress of one sort or another. His first priority was to get copies of his records so he could piece together his childhood. The vast number of placements and lack of records made this a challenging task. David has come to accept that some periods in his life, including who was responsible for his care and what happened to him and why, will forever remain beyond his reach. For this reason, any scraps of information about his childhood and original family are precious to him. He has also sought redress from some of the institutions responsible for his care and has found the results nowhere near good enough, particularly his experience with the Ministry of Social Development. What he really wants is genuine and unreserved apologies from the institutions concerned, a financial payment that recognises the actual costs of trying to overcome the trauma inflicted on him, counselling and wellbeing services – including for his partner and children, who have themselves suffered trauma as a result of who he had become – and the quashing of his criminal convictions, which he describes as a continuing punishment 30 years on.
Record requests
Trying to piece together the records from his time in care has been complicated, distressing and exhausting. David’s records are inadequate, redacted, missing or destroyed. Those he has been able to locate often do not match his experience, forcing him to the dispiriting conclusion that so much about his life will remain forever hidden.
In November 1996, aged 29, David asked the Department of Social Welfare for his complete file and any information held on any possible brothers or sisters who might have also been placed in foster care. In February 1997, David received a handful of documents, most heavily redacted. In March 2002, he made a further request for his complete file and this time received a larger portion of documents.
He went on to make more requests, and every time portions of his file would arrive, heavily redacted or with the word “deleted” sprawled across many pages. Those records not redacted often did not match with David’s experience or left out significant events in his life, such as two attempted suicides while living with John. David said the redactions left him with a feeling that everyone knew more about his life than he did. The Ministry of Social Development, the department’s successor, told us it couldn’t find his original unredacted files, and that one of David’s files was listed as missing.
Between 2016 and 2020, David asked Presbyterian Support Central three times for his files on his time at Berhampore Children’s Home in Wellington. At first it denied he had been in its care, but when he supplied documentary proof, it replied that a fire in its file storage office on 30 December 1989 may have destroyed information it held about him.
In response to this inquiry, Presbyterian Support Central was able to locate seven documents that made passing references to David. We physically inspected Presbyterian Support Central’s files and found five more, but there was no detailed record of his time in their care. Presbyterian Support Central said a fire in 1989, lit by an arsonist, at the Berhampore Children’s Home had destroyed some of the home’s records, including some of the children’s files. It said David’s files could have been among those lost in the fire, but it had no way of knowing what was lost. As a result, most of David’s information about his time with Presbyterian Support Central was via his State records.
At the time of writing, David had yet to seek records from other places because there were so many periods in his life where he did not know who was responsible for his care or for how long. As part of our inquiry, we requested David’s files from other institutions and organisations that were responsible for his care, including The Salvation Army and Open Home Foundation, each of which was involved in David’s care for periods of his childhood.
The Salvation Army gave us two documents recording when David entered its residential nurseries (where David had been placed) and some other admission information but was otherwise unable to find a file specific to David’s time in its care. It said this was “unfortunately, not surprising” because files at its residential nurseries were generally less detailed than those kept by its children’s homes.[ii] It also said its record-keeping practices had not always been as thorough as they are now, and that there are gaps in the historical documentation held, although The Salvation Army said it uses its best endeavours to find any relevant information about survivors when requested.[iii] The Open Home Foundation said it did not hold any information about David. It told us that, despite digitising all files it held about persons in its care, a search resulted in no results for David’s file. According to the Open Home Foundation, this suggested he was unlikely to have been in its care.[iv] However, records held by the State and Presbyterian Support Central suggest David was in Open Home Foundation care between 1979 and 1980.
Redress efforts
David decided to concentrate his redress efforts on the two institutions responsible for his care for the longest periods – Presbyterian Support Central and Child, Youth and Family Services (a division of the Department of Social Welfare, later the Ministry of Social Development). He made a claim to the Child, Youth and Family Services in April 2001 and more than 20 years later is still pursuing it. In that first approach in 2001, he wrote asking for guidance on how to make a claim because no formal claims process existed at that time.[v] In his letter, David said he considered he had grounds for making a financial claim against the department for the abuse he suffered while a ward of the State. He said he had been deprived of knowledge about his true identity, the root cause of many of the problems in his life. David also told them John had sexually abused him and other boys, and that he understood John had spent time in prison for sexual offending against children. He expressed his concern about John continuing to work with children in the community.
Later that month, the department replied, acknowledging his letter, but pointing out that it was not in a position to respond until it had received a “formal statement of claim” setting out his “allegations in detail, together with any causes of action in tort that you believe you may have against the [d]epartment”.[vi] It ended by suggesting he seek legal advice, and noted that the department would be able to assess his claim once it had been “formulated”.[vii] The letter’s legal terminology made him feel intimidated and anxious, so he sought legal advice. However, the estimated fee was so big he was put off using a lawyer or making a claim.
It was not until 14 years later, in 2015, that he made a fresh attempt at a claim, this time to the department’s successor, the Ministry of Social Development. David put together a table detailing some of the placements where he had suffered serious abuse, details of the abuse suffered, by whom and the impact of the it had on him.
In June 2016, David attended an interview with two ministry staff members to go through the details of his claim. He found them to be empathetic, supportive and considerate. The ministry later gave him approximate dates by which it would reach certain milestones in the assessment process. However, the dates came and went without contact from the ministry. David chased up the ministry for information. It offered new dates but again failed to deliver anything. This became the pattern for the next four years. The ministry never initiated contact. David said this continual and fruitless pursuit of information left him feeling anxious, frustrated and angry. He said he often had emotional outbursts and was short-tempered at the times he was expecting updates from the ministry – updates that never materialised. He felt like his life was on hold.
Settlement offer
In June 2020, four years after his first meeting and five years after making his claim, the ministry asked for a meeting to explain the outcome of his claim. The ministry asked him to come to its offices, but David insisted on meeting at his local marae. Two staff turned up. A taxi waited outside for them. David said this small detail spoke volumes. David’s partner opened the meeting with a karakia to acknowledge the sensitive discussions about to happen and to place protection around those involved.
David began the meeting by reading aloud an essay written by his daughter Brooke. The essay was about the effect her father’s abuse and cultural neglect in care had had on her and their family. It contained a passing reference to the family’s belief that some of David’s documents had been falsified – a point one staff member immediately disputed once he had finished reading the essay. To David’s mind, this showed they had come to dispute, not listen to, his account of his experience.
The two staff members went on to tell him he had not been placed in the care of his extended Samoan family because they did not want him – a distressing claim that had no basis in fact because his Department of Social Welfare files contained no record of any attempt by it to contact his wider family about the possibility of caring for him. The ministry’s view appeared to be based only on information collected by the department from David’s mother, who, as stated, was mentally unwell and prejudiced against Samoans. As it turned out, when David later connected with his aunt as an adult, she told him that she would have taken him in if she knew he was in care and not with his mother. The staff members also said David’s father did not contribute to his upbringing because he was paying maintenance for his other children when, in fact, David was his only child. Again, the ministry appeared to have relied only on information gathered by the department, which itself had relied only on information gathered from David’s mother.
The two ministry staff also relied on David’s incomplete department files to dispute David’s account of his experience in care, most notably his allegation of having been sexually abused by John. They said his files recorded he had been happy while living with John and so they would have to accept that as there was no information to the contrary. David found it extremely distressing to hear this, given he had told the ministry he had twice attempted to take his own life while living with John. But the staff members gave little weight to this information because there was no record of it in his department files.
David told them John was a convicted child-sex offender. However, they disputed this claim, saying the ministry had contacted Police to see if John was known to them, but the ministry had not yet received any response. Instead of trying to find out more, they spoke of John’s good standing and the positive character references provided as part of his application to become a “caregiver”. They told David the ministry had disregarded the part of his claim relating to John’s sexual abuse on the basis there was insufficient information and would reconsider this decision only if David provided more information. In a later complaint to the ministry, David’s partner described this part of the kōrero with the ministry staff as “nothing short of unacceptable”.[viii] In the five years since David had made his claim of sexual abuse by John (and 19 years since he first told the ministry), the ministry had not found out anything about John’s conviction history. If it had, it would have uncovered convictions for sexual offending against other boys.
The staff also told him the ministry would accept responsibility for his abuse in care only from the date he became a ward of the State at 14, even though he had been in State care before that time. They suggested making a claim to Presbyterian Support Central for any abuse suffered before that age and gave him the organisation’s contact details, which turned out to be incorrect.
The ministry staff produced a settlement letter that, in effect, rejected many of the most important elements of his claims.[ix] He could not understand why the ministry accepted some allegations and not others, although he felt his incomplete – and inaccurate – department files provided the ministry with a convenient basis for rejecting David’s own memory of events. The letter said the ministry had not tested the evidence or reached any conclusion about whether the allegations were proven but had “taken into account” some of them and not others in coming up with a settlement sum.[x] Those it had taken into account were grouped in appendix A of the document. Those it had not taken into account were listed in appendix B. More than half of David’s allegations were put in appendix B, including all his claims before the age of 14. Appendix B also included his claim that the department, and then the ministry, had fostered and failed to correct the belief that he was Māori (since he had readily identified as Māori at the time, and the ministry said it therefore had no responsibility for this incorrect belief or undoing it); his claim of having been sexually abused by John (because there was “not sufficient information”); and his claim that the Department of Social Welfare had failed to record his two suicide attempts (which the ministry said would not have amounted to a practice failure). It also placed in this appendix his claim that he had been put in secure confinement for many weeks as punishment for running away from Epuni Boys’ Home. It said information on his file suggested he had been elsewhere at the time he alleged this confinement took place.
The letter said the ministry agreed to settle his claim on the basis that it did not accept any legal liability for “what has happened”.[xi] It was prepared to offer, in full and final settlement of his claim, a letter of apology from the ministry’s chief executive, a payment of $15,000 and $400 towards consulting a lawyer about the offer. The offer letter appeared to require David to agree to the settlement before he received any apology and David understood from discussion with the ministry staff that this was true.
After explaining the settlement offer, the two ministry staff abruptly left without following any of the marae protocol, such as a karakia or sharing food to bring the meeting to a close. David considered the way they delivered the offer, the culmination of five years of waiting, to be highly insensitive. It was also, to his mind, a rushed formality so they could return to their waiting taxi. The ministry told us it had been improving its claims process since 2018, and now required staff to run a “culturally responsible service”. [xii] However, its representatives on the marae that day in 2020 did not provide such a service.
David considered $15,000 fell far short of reflecting the loss and trauma he had suffered, the impact the abuse had had on his life, and the expense of trying to rebuild his life. He also objected to the fact that the apology was conditional on signing the settlement offer. He did not accept it.
Spurred on by the failed meeting, and in preparation for asking for a review of his claim, David made requests under the Official Information Act 1982 and the Privacy Act 1993 for all information about how the ministry had assessed his claim. The 20-working-day deadline to produce this information passed without a response. David called the ministry and arranged a phone call with a member of its historic claims team. During that phone call, the staff member repeatedly told him she did not understand why he had made the requests or what he wanted. She spoke over him, interrupted him and repeated herself. David found her so rude and insensitive, and the whole phone call so distressing, that he later made a complaint to the ministry.
In the meantime, David and his partner contacted Police to try to get further information about John’s convictions themselves. A senior police officer contacted the ministry in July 2020 to say Police had received a request from David, and although they could not provide information directly to him, they did have information about John’s criminal history that they could provide if the ministry required it.[xiii] The ministry staff member replied saying she would add the email to the file and that “we may need to come back to you to request this information in the future.”[xiv] The ministry did eventually request the information almost a month later, and Police informed it of John’s conviction.
Eventual apologies but no resolution yet
Six years have passed since making the claim in 2015 and it remains unresolved. In June 2021, the ministry told David certain “high level” legal issues were delaying some claims, including his, and these would need to be resolved before it could finalise his claim.[xv] It could not say what these matters were because they were legally privileged. It apologised for the delay, but could give no further details, including any estimate of when it might resolve these matters. David said he felt the ministry used delay tactics to draw out the redress process and consistently failed to do as it promised.
In July, the day after David gave evidence to one of this inquiry’s public hearings, the ministry contacted David asking whether he would like an apology in advance of the outcome of the review of his claim, and if so, whether he had any thoughts about what it should contain. He replied suggesting it look at the evidence he had given during the public hearing for ideas.
In August, the ministry came back to David to say senior managers were working on the approach it should take to his apology letter. It also said higher officials and other government departments were still grappling with the legal issues mentioned in its June correspondence that were holding up his claim.[xvi]
In September, David received a letter of apology from the general manager of the ministry’s historic claims unit[xvii] as well as one from the ministry’s chief executive.[xviii] The general manager’s letter related to his experience of the historic claims process. She apologised for a miscommunication by staff who said the ministry’s offer of an apology in June 2020 was conditional on his signing the settlement documentation first. This was not the case. She said his evidence had prompted the ministry to revise how it presented settlement documents, so it was clear an apology was not contingent on acceptance of an offer. She expressed appreciation for bringing the matter to the ministry’s attention so it could avoid this confusion with other survivors in future. She acknowledged David’s experience of the claims process, assured him it took claimants’ feedback seriously, and vowed to continue to improve how it dealt with claimants. She also apologised for the delay in reviewing his claim but assured him the ministry was doing everything it could and would give him an answer as quickly as possible.
The chief executive’s letter related to his experiences of care. In her letter, she said many people had stressed to the ministry the importance of being heard, of receiving an apology, and of knowing that the organisation had learned from its mistakes. She acknowledged the information he had given the ministry’s historic claims team and noted that he had “described experiencing abuse and mistreatment at a number of placements”. The chief executive also noted that he described abuse by a “caregiver”, a term David is particularly upset about, because to him, he did not provide care at all. The letter also acknowledged the evidence he had given about the impact of discovering he was Samoan. She said: “I want to apologise to you. You had a right to be well cared for and kept safe as a young person in the care of the State. It was our responsibility to take steps to ensure that this was your experience.”[xix]
David said both letters were disingenuous, wooden and lacking in the basic elements of a personal apology. They sounded like apologies but said nothing meaningful. Neither letter took any responsibility for any of the abuse, and neither gave any indication whether the ministry accepted the abuse happened. Prevention was unquestionably important, but what he was looking for was an apology that referred specifically to his abuse and its impact on him and his family. The chief executive’s letter showed she had listened to what he was saying, but the whole thing boiled down to just a three-line apology and was without substance, genuineness or humanity. To have waited so long for such paltry apologies was, he said, deeply disappointing – and in marked contrast to the letter he received from Presbyterian Support Central.
Overall, he found the experience of dealing with the ministry “appalling”. At the time of writing, he had still not received an answer on the ministry’s review of his claim. He said he has abandoned any hope of a meaningful apology and is now concentrating on getting a meaningful financial payment.
Presbyterian Support Central
Presbyterian Support Central, or the Presbyterian Support Services Association as it then was, took David into its care for at least eight years. On three occasions, David contacted it but was never told he could make a complaint. In June 2021, after we tried to obtain David’s records, Presbyterian Support Central asked us to pass on a message to David, addressed to “Mr Mohi”, containing an apology for failing to respond satisfactorily on the three occasions he made contact. It invited him to make contact again, if he wished to make a complaint.[xx]
David considered this message a brief, transactional exchange and definitely not an apology. Presbyterian Support Central later wrote to us to say the message was never intended as an apology for any abuse David had suffered, but rather for its failure to be able to locate any of his records.[xxi]
After David gave evidence at one of our public hearings, Presbyterian Support Central’s chief executive wrote to him to apologise for the abuse he suffered while in its care and to acknowledge his evidence, as well as to invite him to make contact when he was ready. The chief executive said both he and the former chief executive were present at the hearing when David and his daughter gave evidence and that they were deeply moved and saddened by what he heard. He acknowledged the terrible treatment David suffered as a child and his separation from his Samoan heritage and family. He also acknowledged the lasting damage this had had on him and members of his family. He offered a “deep and profound apology” for the harm he had suffered and expressed the hope that the courage he had shown in speaking publicly would help him on his path to healing.
The chief executive said Presbyterian Support Central wanted to understand what it could do to help David and his family. He suggested counselling services and other supports. He said they did not expect to find any specific file on David but would conduct a fresh search for any documents that might help him piece together the early years of his life.
The chief executive said his organisation was committed to working with him to help him on his journey to wholeness and wanted to ensure it was done on David’s terms at a time that suited him. He welcomed the possibility of meeting David at a time and place of his choosing and suggested perhaps David’s local marae. He ended the letter thanking David for his bravery in speaking out.
David and his family found this to be a genuine apology because it showed thoughtfulness and insight and, importantly, addressed the matters that were most important to him.
After receiving the apology from the chief executive, David and his family arranged to meet with the chief executive, the former chief executive and a general manager. David and his family chose to meet with them at home. Presbyterian Support Central brought along a photo of David they had found. It was an opportunity for them to again see in person the impacts the abuse had on David and his family, and to apologise face-to-face. Presbyterian Support Central showed cultural awareness and sensitivity in their approach to the meeting. David and his family were appreciative of the kindness and proactivity shown by Presbyterian Support Central. He is continuing his discussions with Presbyterian Support Central.
Summary and findings
David’s claim was complicated by his many placements and the scantiness of his records, but by far the biggest hurdle to prompt and meaningful redress was the obstructive and insensitive approach taken by the Ministry of Social Development.
The Ministry of Social Development and its predecessor the Department of Social Welfare:
- gave inconsistent and inadequate responses to David’s requests for records
- had poor record-keeping processes, resulting in the loss of David’s full unredacted records
- responded to David’s attempted claim in a legalistic and obstructive manner
- did not act on David’s concerns for children still under John’s care
- took too long to consider David’s claim and make a settlement offer, and has still not finalised the claim
- failed to investigate John’s conviction history, until David went to Police directly for this information
- failed to keep David updated on the progress of his claim
- failed to understand or incorporate cultural values that were important to David into the redress process
- demonstrated a lack of understanding of the impact of the cultural neglect David experienced
- placed too much reliance on David’s inadequate files and too little on his account of the abuse in rejecting parts of his claim
- failed to offer a meaningful apology
- failed to recognise cultural neglect as part of the abuse David suffered
- offered a financial payment that did not adequately reflect the impact of the abuse on David or his family
- interacted with David in a way that did not uphold his mana, recognise his trauma or respond to his cultural needs.
Presbyterian Support Central:
- failed to adequately respond to David’s initial request for records
- caused needless distress to David by denying he was in its care
- failed to offer David the opportunity to make a complaint on any of the three occasions he made contact to ask for his records
- has since taken significant steps to remedy these past failings, including
- made an apology that was comprehensive and genuine
- rechecked all its records for any additional information about David
- showed cultural awareness and sensitivity in its interactions with David and his family
- undertook to work with David to provide redress that would address his and his family’s needs.
We will cover David’s experiences in more detail in a report summarising our inquiry into abuse of Pacific people in care.
[i] Witness Statement of David Crichton, WITN0456001 (Royal Commission of Inquiry into Abuse in Care, 9 July 2021); Transcript of evidence of David Crichton from Tulou – Our Pacific Voices: Tatala e Pulonga, TRN0000406 (Royal Commission of Inquiry into Abuse in Care, 28 July 2021).
[ii] Email from Bell Gully, for The Salvation Army, to Royal Commission of Inquiry into Abuse in Care regarding Notice to Produce No. 6, MSC0007487 (22 June 2021).
[iii] Letter from Bell Gully, for The Salvation Army, to Royal Commission of Inquiry into Abuse in Care regarding records held by The Salvation Army in relation to David Crichton, MSC0007474 (15 July 2021).
[iv] Letter from Don Irwin, Open Home Foundation, to Coral Shaw, Royal Commission of Inquiry into Abuse in Care, in response to Notice to Produce No. 1, MSC0007493 (26 May 2021), pp. 1-2.
[v] Letter from David Crichton to Child Youth and Family Services regarding historic claim, ORT0000224 (17 April 2001), pp. 1-4.
[vi] Letter from Child, Youth and Family Services to David Crichton responding to letter of 17 April 2001, ORT0000224 (27 April 2001), p. 5.
[vii] Ibid.
[viii] Email from David Crichton’s partner to Ministry of Social Development regarding historic claims process (13 August 2020).
[ix] Letter from Mel King, Ministry of Social Development, to David Crichton regarding historic abuse claim, MSC0002567 (11 June 2020).
[x] Ibid., p. 1.
[xi] Ibid.
[xii] Transcript of evidence of Linda Hrstich-Meyer for Ministry of Social Development from State Redress Hearing Phase II, TRN0000020 (Royal Commission of Inquiry into Abuse in Care, 23 October 2021), pp. 497-498.
[xiii] Email from Adrian Ross, New Zealand Police, to Ministry of Social Development regarding David Crichton’s request for information, MSD0011608 (17 July 2020), p. 5.
[xiv] Email from Ministry of Social Development to Adrian Ross, New Zealand Police, regarding David Crichton’s request for information, MSD0011608 (17 July 2020), p. 4.
[xv] Email from Ministry of Social Development to David Crichton’s partner regarding historic abuse claim, MSC0002564 (19 June 2021).
[xvi] Email from Ministry of Social Development to David Crichton’s partner regarding historic abuse claim and apology, MSC0007483 (9 August 2021), p. 1.
[xvii] Letter from Linda Hrstich-Meyer, Ministry of Social Development, to David Crichton regarding apology, MSC0007484 (2 September 2021).
[xviii] Letter from Debbie Power, Ministry of Social Development, to David Crichton regarding apology, MSC0007476 (1 September 2021).
[xix] Ibid.
[xx] Email from Simpson Grierson, for Presbyterian Support Central, to Royal Commission of Inquiry into Abuse in Care, regarding Notice to Produce No. 1, MSC0007486 (3 June 2021), p. 1.
[xxi] Letter from Simpson Grierson, for Presbyterian Support Central, to Royal Commission of Inquiry into Abuse in Care clarifying that previous correspondence with David Crichton was not an apology, MSC0007475 (22 July 2021), p. 3.