trial, came under intense criticism. At the trial Zelas identified behavioural symptoms shown by the complainant creche children that were "consistent" with child sexual abuse. She had prepared a detailed chart for the trial, which showed the myriad symptoms displayed by each of the complainant children that she said were consistent with sexual abuse, and essentially claimed it was more likely a child had been abused if they exhibited a cluster of some of the 20 or so behavioural symptoms she catalogued. However, Tess Patterson said that even in 1993, there was no evidence of behaviours specific to child abuse and certainly no clusters, and criticised Zelas for not sufficiently considering that troubling behaviours could be due to other factors. Zelas was further criticised for writing a long letter to the police in August 1992 expressing serious concerns about leading parental questioning and intense interrogation before some of the children's interviews, but during cross-examination she failed to repeat "for the court the very serious concerns she had expressed in her letter" to the police. In final submissions on 12 October 2021, Ellis' counsel Rob Harrison said an "abundance" of evidence was available that showed the complainant children had taken on information from a variety of sources before their formal interviews and either regurgitated that information or used it to create accounts. As an example of how a child could be "readied" to give false accounts, Harrison highlighted a letter from August 1992 from the mother of a complainant child (Child 5) about an evidential interview with her child had been cancelled because of her questioning. In the letter the mother also claimed the child told her about another two Christchurch creches being involved in sexual abuse and other workers at the Civic creche being sexual offenders. The two creches were never investigated, and Harrison asked the Supreme Court why this was the case if the police were confident Child 5's evidence was not contaminated. He also asked why the police never charged Ellis with multiple counts of sodomy based on what Child 5 claimed in his fifth and sixth interviews. The letter also mentioned that the counsellor with whom the child was in therapy wanted Satanic ritual abuse expert Pamela Hudson to come to New Zealand to assist in the case. Bridget Irvine, counsel for Ellis, said in further submissions that the interviews of the children were below best practice,