[1] Witness Statement of Leoni McInroe, WITN0096001 (Royal Commission of Inquiry into Abuse in Care, 31 July 2020); Witness Statement of Leoni McInroe, WITN0096002 (Royal Commission of Inquiry into Abuse in Care, 21 March 2021); Transcript of evidence of Leoni McInroe from State Redress Hearing Phase I, TRN0000001 (Royal Commission of Inquiry into Abuse in Care, 24 September 2020).

[1] The Solicitor-General made this statement to distinguish the approach the Crown took in offering a group settlement to Lake Alice claimants from the approach taken to later historic claims of abuse. However, in evidence to our public hearing into the Lake Alice Hospital’s Child and Adolescent Unit, she clarified that the proof referred to in the file was that paraldehyde was administered, and ECT equipment used. Whether they were used for punishment was a question of fact that has not been tested, but the Solicitor-General acknowledged that there was, from the information contained in Leoni’s claim, a reasonable basis to suspect that was the case. See: Transcript of evidence of Solicitor-General Una Jagose QC for Crown Law Office from State Redress Hearing Phase II, TRN0000022 (Royal Commission of Inquiry into Abuse in Care, 2 November 2020), p. 962; Transcript of evidence of Solicitor-General Una Jagose QC for Crown Law Office from Lake Alice Child and Adolescent Unit Hearing, TRN0000397 (Royal Commission of Inquiry into Abuse in Care, 28 June 2021), pp. 856, 878.

[1] Transcript of evidence of Solicitor-General Una Jagose QC from Lake Alice Child and Adolescent Unit Hearing, p. 957.

[1]  Ibid., p. 856.

[1]  Ibid., p. 860.

[1]  Ibid., p. 855.

[1]  Ibid.

[1] Transcript of evidence of Leoni McInroe from State Redress Hearing Phase I, pp. 170-172.

[1]  Ibid., pp. 171-173.

[1] Transcript of evidence of Solicitor-General Una Jagose QC from Lake Alice Child and Adolescent Unit Hearing, p. 856.

[1] Transcript of evidence of Solicitor-General Una Jagose QC from State Redress Hearing Phase II, 3 November 2020, p. 1069.

[1] Ibid., p. 878.

[1] Witness Statement of Earl White, WITN0009001 (Royal Commission of Inquiry into Abuse in Care, 15 July 2020); Transcript of evidence of Earl White from State Redress Hearing Phase I, TRN0000001 (Royal Commission of Inquiry into Abuse in Care, 24 September 2020).

[1] White v Attorney-General HC Wellington CIV-1999-485-85 (28 November 2007); White v Attorney-General [2010] NZCA 139.

[1] Letter from Chris Mathieson, Crown Law to Sonja Cooper, Cooper Legal, regarding letter of 22 September 2006, CRL0028381 (25 September 2006), p. 2.

[1]  Ibid.

[1] Minutes by Debra Harris of White litigation team meeting on 7 December 2006 between Crown Law and Ministry of Social Development, CRL0040575 (8 December 2006), p. 52.

[1]  Email from Una Jagose, Crown Law to Garth Young, Ministry of Social Development, regarding letter edits, CRL0025722 (5 June 2009).   

[1]  Transcript of evidence of Solicitor-General Una Jagose QC from State Redress Hearing Phase II, 4 November 2020, pp. 1163-1164; Email from Una Jagose, Crown Law to David Shanks, Ministry of Social Development, regarding Crown Law’s opposition to the proposed ex gratia payment, CRL0025885 (14 June 2010).

[1]  Internal report from Zoe Griffiths to Hon Ruth Dyson, Associate Minister for Social Development and Employment, Departmental Report: Update on historic claims against Child, Youth and Family, MSD0002007 (2006), pp. 3-4.

[1]  Letter from Chris Mathieson, Crown Law to Dr Michael Cullen, Attorney-General, regarding the Whites’ historic physical and sexual abuse claim, CRL0022719 (24 January 2007); Internal Ministry of Social Development memorandum from Deputy Chief Executive, Corporate and Governance to the Leadership Team, Historical claims by former wards of the state, MSD0002030 (26 February 2007), pp. 2-3.   

[1] Handwritten notes of meeting regarding White litigation attended by Kristy McDonald QC, Crown Law and Ministry of Social Development, CRL0040575 (28 November 2006), p. 46.  

[1] Transcript of evidence of Garth Young for Ministry of Social Development from State Redress Hearing Phase II, TRN0000018 (Royal Commission of Inquiry into Abuse in Care, 22 October 2020), p. 373.

[1]  Draft opinion from Andrew Irwin, Crown Law to Zoe Griffiths, Department of Child, Youth and Family Services, regarding an offer of settlement, CRL0026754 (10 December 2002), p. 2.

[1] Ibid.

[1] Internal report from Garth Young to Anne Tolley, Minister of Social Development, Historic claims update, MSD0001056 (21 September 2017), p. 4.

[1] Transcript of evidence of Garth Young from State Redress Hearing Phase II, 21 October 2020, p. 308.

[1]  Ibid., pp. 292-294.

[1] Cooper, S., Culture of abuse and perpetrators of abuse at Department of Social Welfare Institutions: A paper based on the civil litigation proceedings of clients represented by Sonja M Cooper, MSC0000650.  

[1] File note by Lynn Martin, Crown Health Financing Agency, regarding Historic Claims Working Party Meeting on 12 February 2008, MOH0000032 (13 February 2008), p. 1.

[1] Transcript of evidence of Solicitor-General Una Jagose QC from State Redress Hearing Phase II, 3 November 2020, p. 1141.

[1] Ibid., p. 1105.

[1] Ibid., p 1006.

[1] Ibid., pp. 1024-25.

[1]  Ibid., p. 1024.

[1] Minutes by Debra Harris of White litigation team meeting on 7 December 2006 between Crown Law and Ministry of Social Development, p. 52.

[1] Transcript of evidence of Sonja Cooper and Amanda Hill for Cooper Legal from State Redress Hearing Phase I, TRN0000003 (Royal Commission of Inquiry into Abuse in Care, 1 October 2020), p. 502.

[1]   Email from Michael Hodge, Crown Law to Ministry of Social Development and Crown Law regarding Brian Manchester’s statement on departmental systems, CRL0026158 (24 April 2007).

[1]  Transcript of evidence of Sonja Cooper and Amanda Hill from State Redress Hearing Phase I, 1 October 2020, p. 481.

[1]  Transcript of evidence of Brett Dooley and David Howden for Ministry of Justice from State Redress Hearing Phase II, TRN0000026 (Royal Commission of Inquiry into Abuse in Care, 29 October 2020), p. 990.

[1]  Email from Una Jagose, Crown Law to Jacinda Lean, Department of Child, Youth and Family Services, regarding White costs, CRL0024070 (13 October 2008).

[1]  Transcript of evidence of Solicitor-General Una Jagose QC from State Redress Hearing Phase II, 4 November 2020, p. 1160; Minutes from meeting of Claims Strategy Group, MSC0000512 (12 October 2009).

[1] Witness Statement of Keith Wiffin, WITN0080001 (Royal Commission of Inquiry into Abuse in Care, 12 February 2020); Witness Statement of Keith Wiffin, WITN0080030 (Royal Commission of Inquiry into Abuse in Care, 19 April 2021); Transcript of evidence of Keith Wiffin from State Redress Hearing Phase I, TRN0000001 (Royal Commission of Inquiry into Abuse in Care, 21 September 2020).

[1] Letter from Peter Hughes, Ministry of Social Development to Keith Wiffin, regarding official information request, REL0000001917 (31 January 2007), p. 1.

[1] Excerpt from restorative justice conference between Keith Wiffin and Alan Moncrief-Wright, EXT0016710 (23 November 2011), p. 4.

[1] Transcript of evidence of Solicitor-General Una Jagose QC from State Redress Hearing Phase II, 3 November 2020, p. 1078.

[1] Witness Statement of Keith Wiffin, 19 April 2021, p. 2.

[1] The Catholic Church’s National Office for Professional Standards is currently working alongside a person who has reported this abuse to undertake an extensive investigation. To date, it has not been able to identify which Catholic institution this allegation could have been referred to.

[1] The Solicitor-General told us that what was considered to be a ‘meritorious’ claim changed over time, and initially a meritorious claim was one that would survive the ACC and limitation barriers. See: Transcript of evidence of Solicitor-General Una Jagose QC from State Redress Hearing Phase II, 2 November 2020, p. 950.

[1] The ministry did eventually try to contact Moncreif-Wright in 2010 when the case was reopened.

[1] Transcript of evidence of Garth Young from State Redress Hearing Phase II, 221 October 2020, p. 301.

[1] Ibid., 392.

[1] Ibid., p. 318.

[1] Ibid.

[1] Letter from Una Jagose, Crown Law to Jacinda Lean and Debra Mury, Ministry of Social Development, regarding next steps for various historic claims, CRL0046017 (29 January 2009), p. 2.

[1] Email between Sally McKechnie and Una Jagose, Crown Law, regarding witnesses, MSC0000336 (17 March 2009).

[1] Ibid.

[1] Email from Una Jagose, Crown Law to Garth Young, Ministry of Social Development, regarding Keith Wiffin, CRL0046254 (9 March 2009), p. 1.

[1] Letter from Una Jagose, Crown Law to Ministry of Social Development, Jacinda Lean, regarding advice on child welfare historic claims strategy, CRL0016524 (13 September 2006), p. 2.

[1] Transcript of evidence of Keith Wiffin from State Redress Hearing Phase I, 21 September 2020, p. 27.

[1] Letter from Garth Young, Ministry of Social Development to Sonja Cooper, Cooper Legal, regarding an Official Information Act request on staff information, EXT0000071 (20 February 2008), p. 3.

[1] Memorandum from Susan Tarrant, Solicitor for Historic Claims and Litigation, to Garth Young regarding Keith Wiffin’s civil claim, MSD0002382 (25 February 2008), p. 9.

[1] Transcript of evidence of Garth Young from State Redress Hearing Phase II, 22 October 2020, p. 425.

[1] Ibid.

[1] Transcript of evidence of Solicitor-General Una Jagose QC from State Redress Hearing Phase II, 3 November 2020, p. 1093.

[1] Letter from Una Jagose, Crown Law to Sarah Mitchell, Cooper Legal, regarding discovery with attached criminal conviction information of Alan Moncrief Wright, MSC0000634 (1 April 2009).

[1] Email from Una Jagose, Crown Law to Susan Hilda, Child, Youth and Family Services and Garth Young, Ministry of Social Development, regarding an alternative dispute resolution meeting with Keith Wiffin, CRL0045910_00070 (15 May 2008).  

[1] Internal email in Child, Youth and Family Services, regarding a meeting with Crown Law on Keith Wiffin (26 May 2008).

[1] Internal Ministry of Social Development memorandum from Garth Young to Iona Holsted, DCE Corporate & Governance regarding approval of ex-gratia payment, MSD0002569 (27 July 2010), p. 3.

[1] Cashmore, J., Taylor, A., Shackel, R., and Parkinson, P., A Report for the Australian Royal Commission into Institutional Responses to Child Sexual Abuse: The impact of delayed reporting on the prosecution and outcomes of child sexual abuse cases, MSC0001082 (University of Sydney Law School, 2016), p. 193.

[1] Email from Una Jagose to Edrick Child, Crown Law, regarding Keith Wiffin's settlement offer, CRL0045838 (7 April 2009).

[1] Transcript of evidence of Garth Young from State Redress Hearing Phase II, 21 October 2020, p. 301.

[1] Ibid.

[1] Transcript of evidence of Solicitor-General Una Jagose QC from State Redress Hearing Phase II, 2 November 2020, pp. 1013-1014.

[1] Witness Statement of Solicitor-General Una Jagose QC for Crown Law Office, WITN0104001 (Royal Commission of Inquiry into Abuse in Care, 28 February 2020), p. 18.

[1] Emails from Susan Hillda, Department of Child Youth and Family Services to Una Jagose, Crown Law, regarding Keith Wiffin's rejection of settlement offer and potential criminal complaint, CRL0046413 (13 May 2009), p. 1.

[1] Sir Rodney Gallen, Assessment of MSD’s Processes on Historic Claims, CAB0000014 (27 November 2009), p. 18.

[1] Internal Ministry of Social Development memorandum from Garth Young to Iona Holsted, DCE Corporate & Governance regarding approval of ex-gratia payment, p. 4.

[1] Letter from Garth Young, Ministry of Social Development to Keith Wiffin regarding the handling of his claim, WITN0080027 (6 August 2010); Letter from Peter Hughes, Ministry of Social Development to Keith Wiffin, WITN0080026 (4 August 2010).

[1] Witness Statement of Keith Wiffin, 19 April 2021, pp. 6-7.

[1] Witness Statement of Roy Takiaho, WITN0071001 (Royal Commission of Inquiry into Abuse in Care, 10 September 2020); Witness Statement of Roy Takiaho, WITN0071002 (Royal Commission of Inquiry into Abuse in Care, 10 November 2020); Transcript of evidence of Roy Takiaho from Faith-based Redress Hearing Phase I, TRN0000337 (Royal Commission of Inquiry into Abuse, 11 December 2020).

[1] Witness Statement of Murray Houston for The Salvation Army, WITN0250022 (Royal Commission of Inquiry into Abuse in Care, 29 January 2021), pp. 11-12.

[1] File note by Murray Houston regarding counter-offer for Roy Takiaho’s claim, SAL0001670 (28 January 2005).

[1] Witness Statement of Colonel Gerry Walker for The Salvation Army, WITN0249001 (Royal Commission of Inquiry in Abuse in Care, 18 September 2020), p. 6.

[1] Witness Statement of Murray Houston for The Salvation Army, WITN0250001 (Royal Commission of Inquiry into Abuse in Care, 18 September 2020), pp. 36-37. See also: table of settlement sums reached with survivors represented by Grant Cameron as compared to the sums sought by Mr Cameron on behalf of those survivors: Witness Statement of Murray Houston, 29 January 2021, Appendix, pp. 29-30.

[1] Transcript of evidence of Murray Houston for The Salvation Army from Faith-based Redress Hearing Phase II, TRN0000340 (Royal Commission of Inquiry into Abuse in Care, 17 March 2021), p. 164-165.

[1] Witness Statement of Murray Houston, 18 September 2020, p. 43.

[1] Transcript of evidence of Murray Houston from Faith-based Redress Hearing Phase II, 17 March 2021, p. 167; Witness Statement of Murray Houston, 29 January 2021, Appendix, pp. 29-30.

[1] Witness Statement of Murray Houston, 18 September 2020, p. 29.

[1] Ibid., pp. 18-19.

[1] Letter from Murray Houston, The Salvation Army, to Sonja Cooper, Cooper Legal, regarding Roy Takiaho, SAL0001672 (27 January 2005), p. 3.

[1] Transcript of interview with Roy Takiaho and Murray Houston, The Salvation Army, SAL0001633 (9 December 2004), p. 37.

[1] Transcript of evidence of Murray Houston for The Salvation Army from Faith-based Redress Hearing Phase II, TRN0000339 (Royal Commission of Inquiry into Abuse in Care, 16 March 2021), p. 144.

[1] Transcript of closing submissions of The Salvation Army from Faith-based Redress Hearing Phase II, TRN0000348 (Royal Commission of Inquiry into Abuse in Care, 29 March 2021), p. 882.

[1] Witness Statement of Robert Oakly, WITN0055001 (Royal Commission of Inquiry into Abuse in Care, 4 October 2010); Transcript of evidence of Robert Oakly from Faith-based Redress Hearing Phase I, TRN0000334 (Royal Commission of Inquiry into Abuse in Care, 8 December 2010).

[1] Email from Diocese of Nelson, Anglican Church, to Robert Oakly regarding Robert’s disclosure of abuse to the Anglican Church, EXT0000507 (19 September 2017).

[1] Witness Statement of Archbishop Philip Richardson for Anglican Church, WITN0265001 (Royal Commission of Inquiry into Abuse in Care, 12 February 2021), p. 31. 

[1] Ibid. 

[1] Letter from Cooper Legal to Bishop Steve Maina, Anglican Church, regarding claim and settlement offer for Robert Oakly, ANG0001373 (6 August 2019).

[1] Letter from Bishop Steve Maina, Anglican Church, to Cooper Legal regarding claim and settlement offer for Robert Oakly, ANG0001374 (17 October 2019).

[1] Letter from Cooper Legal to Bishop Steve Maina, Anglican Church, regarding liability of the Anglican Church for Robert Oakly’s claim, ANG0001371 (24 October 2019).

[1] Email from Cooper Legal to Robert Oakly regarding an update on his claim with the Anglican Church, WITN0055003 (15 May 2020).

[1] Letter from Sonja Cooper, Cooper Legal, to Wynn Williams regarding Robert Oakly, MSC0007449 (15 October 2020). 

[1] Letter from Bishop Steve Maina, Anglican Church, to Robert Oakly regarding apology, ANG0019720 (4 December 2020).

[1] Transcript of evidence of Bishop Peter Carrell for Anglican Church from Faith-based Redress Hearing Phase II, TRN0000341 (Royal Commission of Inquiry into Abuse in Care, 18 March 2021), p. 330.

[1] Transcript of evidence of Archbishop Philip Richardson for Anglican Church from Faith-based Redress Hearing Phase II, TRN0000343 (Royal Commission of Inquiry into Abuse in Care, 22 March 2021), p. 418.

[1] Ibid., pp. 418-419.

[1] Ibid., p. 405.

[1] Witness Statement of Emery-James Wade, WITN0292001 (Royal Commission of Inquiry into Abuse in Care, 16 March 2021).

[1] Notes of meeting with Bill Kilgallon, National Office of Professional Standards, and Sexual Assault Protocol Committee, regarding complaint of Emery-James Wade, CTH0002976_00024 (30 March 2015).

[1] Letter from Rev. Father Leonard Danvers to appointed investigators regarding terms of reference for the complaint of Emery-James Wade, CTH0002976_00023 (14 April 2015).

^[1] New Zealand Catholic Bishops Conference and Congregational Leaders, Te Houhanga Rongo – A Path to Healing: Principles and procedures in responding to complaints of sexual abuse by Clergy and Religious of the Catholic Church of New Zealand, CTH0001154 (2007).

[1] Monsignor is a canonical title given to senior priests of a diocese.

[1] Interview notes of Emery-James Wade with Patsy Gordon and Monsignor David Tonks, investigators, CTH0002841 (14 May 2015).

[1] Ibid., p. 2. 

[1] Ibid., p. 1.

[1] File note of telephone conversation between Monsignor David Tonks and Emery-James Wade, CTH0002842 (10 July 2015).

[1] Letter from Emery-James Wade’s lawyer to Monsignor David Tonks, investigator, regarding Emery-James Wade, WITN0292005 (28 August 2015).

[1] Email from Sexual Assault Protocol Committee delegate to Emery-James Wade’s lawyer, regarding Emery-James Wade, WITN0292006 (10 September 2015).

[1] Letter from Emery-James Wade’s lawyer to Monsignor David Tonks, investigator, regarding the progress of Emery-James’ claim, WITN0292005 (28 August 2015), p. 2.

[1] Email from Sexual Assault Protocol Committee delegate and Emery-James Wade’s lawyer, regarding Emery-James Wade, WITN0292007 (7 October 2015), p. 2.

[1] Ibid.

[1] Email correspondence between Sexual Assault Protocol Committee delegate and Bernard Smith, counsellor, regarding Emery-James Wade, CTH0002976_00015 (15 April to 31 May 2016), pp. 7, 9.

[1] Ibid., p. 1.

[1] Email from Sexual Assault Protocol Committee member to Bill Kilgallon, National Office of Professional Standards, regarding the Hamilton Sexual Assault Protocol Committee concerns in relation to the Emery-James Wade investigation, CTH0002976_00014 (14 June 2016).

[1] Email correspondence between Bill Kilgallon, National Office of Professional Standards, and Anthony Baker, New Zealand Police, regarding New Zealand Police investigation into Mark Brown, CTH0002962 (4 July to 10 August 2016), p. 3.

[1] Transcript of New Zealand Police Interview with Emery-James Wade, NZP0002101 (11 July 2016). 

[1] Much later, this suspicion was proved correct. In 2020, Emery Wade disclosed to police that he had been repeatedly abused by Brown over many years. New Zealand Police Report Form for Emery Wade, regarding sexual abuse by Mark Brown, NZP0002203 (21 July 2016); New Zealand Police Jobsheet, NZP0001550 (4 May 2019). In his statement for the Royal Commission into Abuse in Care Emery-James indicated he knew the abuse happened multiple times in his ninth and tenth years, but that he had blocked it out as a coping mechanism: Witness Statement of Emery-James Wade, p. 6.

[1] Email from Bill Kilgallon, National Office for Professional Standards, to Emery-James Wade, regarding his complaint to New Zealand Police, CTH0010324 (15 July 2016). 

[1] Project Restore, Transcript of Restorative Justice Conference between Emery-James Wade and Mark Brown, PRN0000002 (20 July 2017), p. 7.

[1] Letter from R.G Dough, Crown Solicitor, to Senior Sergeant Faulkner, New Zealand Police, regarding Mark Brown sentencing for sexual offending, NZP0002169 (21 August 2017).

[1] Project Restore, Transcript of Restorative Justice Conference between Emery-James Wade, Bishop Steven Lowe and Bill Kilgallon, EXT0016122 (19 December 2017).

[1] Letter from Bishop Steve Lowe, Diocese of Hamilton, to Royal Commission of Inquiry into Abuse in Care regarding Emery-James Wade case study (9 November 2021), p. 1.

[1] Project Restore, Transcript of Restorative Justice Conference between Emery-James Wade, Bishop Steven Lowe and Bill Kilgallon, p. 28.

[1] Ibid., pp. 28-29.

[1] Ibid., p. 30.

[1] Letter from Bishop Steve Lowe to Royal Commission of Inquiry into Abuse in Care regarding Emery-James Wade case study, p. 6.

[1] Ibid.

[1] New Zealand Police, Summary of Charges for Mark Brown, NZP0041688 (4 August 2020).

[1] Letter from Bishop Edward Gaines to Tony Ward, Department of Justice at Rolleston Prison, regarding dismissal of Mark Brown, NZP0001809 (20 September 1990); Letter from Fr Pat Lynch, President of Sion Catholic Community, to Bishop Denis Browne, regarding Mark Brown operating with the Sion community in England in a limited capacity, NZP0001976 (26 May 1995); Letter from Monsignor Des McCarthy to the British Embassy in Wellington, regarding Mark Brown’s expenses and visa application, NZP0002003 (30 June 1995).

[1] Letter from Bishop Denis Browne to Fr Pat Lynch, Sion Community, regarding decision not to provide Mark Brown with an opportunity at the Sion Community in England given widespread public attention of his “sexual misconduct”, NZP0001959 (30 September 1996).

[1] Briefing paper on Mark Brown, NZP0001892 (19 August 1996), pp. 3-4.

[1] Correspondence between Bishop Steve Lowe and the Holy See regarding Fr Mark Mannix Brown pleading guilty to sexual crimes against children and requesting urgent laicization, CTH0002891 (September to December 2017), pp. 10, 12.

[1] The Apostolic Nuncio is a diplomatic post of the Holy See. The Apostolic Nuncio has the rank of ambassador and he is Holy See’s representative to New Zealand. All correspondence to the Vatican goes through the Apostolic Nuncio who ensures what is being sent goes to the right office. Correspondence between Bishop Lowe and the Holy See regarding Fr Mark Mannix Brown pleading guilty to sexual crimes against children and requesting urgent laicisation, p. 1.

[1] Correspondence between Bishop Lowe and Holy See, regarding Fr Mark Mannix Brown pleading guilty to sexual crimes against children and requesting urgent laicization, p. 5.

[1] Ibid., p. 13.

[1] 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).

[1] 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).

[1] 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).

[1] 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.

[1] Letter from David Crichton to Child Youth and Family Services regarding historic claim, ORT0000224 (17 April 2001), pp. 1-4.

[1] Letter from Child, Youth and Family Services to David Crichton responding to letter of 17 April 2001, ORT0000224 (27 April 2001), p. 5.

[1] Ibid.

[1] Email from David Crichton’s partner to Ministry of Social Development regarding historic claims process (13 August 2020).

[1] Letter from Mel King, Ministry of Social Development, to David Crichton regarding historic abuse claim, MSC0002567 (11 June 2020).

[1] Ibid., p. 1.

[1] Ibid.

[1] 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.

[1] 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.

[1] 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.

[1] Email from Ministry of Social Development to David Crichton’s partner regarding historic abuse claim, MSC0002564 (19 June 2021).

[1] Email from Ministry of Social Development to David Crichton’s partner regarding historic abuse claim and apology, MSC0007483 (9 August 2021), p. 1.

[1] Letter from Linda Hrstich-Meyer, Ministry of Social Development, to David Crichton regarding apology, MSC0007484 (2 September 2021).

[1] Letter from Debbie Power, Ministry of Social Development, to David Crichton regarding apology, MSC0007476 (1 September 2021).

[1] Ibid.

[1] 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.

[1] 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.