The lies:

Following is a summary of the facts which the Petitioner believes constitutes immediate risk of serious harm to the child( ren ) (see attached affidavit(s) for additional facts).

Heather Willis is in immediate risk of serious harm due to emotional abuse and threat of sexual abuse. Heather is currently residing with Robert Dailey, DoB 12-17-50 and Edward Brown, DoB 12-2-42 , who are unable and unwilling to provide any information regarding who Heather's legal custodians are nor are they able to provide any identification for Heather or proof of guardianship. It is a fear that this child has been abducted or is a runaway. Both the Westbrook Police and Child Protective Services have been denied access to meet with Heather to ensure her safety and well-being. Due to the nature of the pornographic business that is established in the home off of Heather's bedroom, the fact that Robert Dailey admits to sleeping in the bedroom with Heather Willis, and the fact that there is a lack of information concerning Heather's parentage and lack of identification of the child, the Department of Human Services believes that Heather Willis is in immediate risk of serious harm.




IN RE: Heather Willis

I, Meghan J Lyons for the State of Maine Department of Human Services, being following is true to the best of my knowledge and belief:

duly sworn state that the

Detective Steve Lyons with the Westbrook Police Department contacted Child Protective Services on this date with concerns for the family of Patricia and Robert Daily (12/17/50) of 17 East Bridge Street in Westbrook. Also in the home are Heather Willis (11/15/90), Christina Brown (10/20/87) and Eddie Brown (12/2/42). Heather told detectives that she is the step granddaughter of Robert, Christina is allegedly the cousin of Robert and Eddie claims to be Christina's uncle. There is no information indicating the children's parentage. Det. Lyons states that neither child had any identification, and Robert Dailey and Edward Brown refused to give any information verbally or through documentation stating who is legally responsible for these two minor females currently occupying the residence.

Det. Lyons states that he and Det. Desjardin went to the Daily residence on 7/8/03 as part of an ongoing investigation into allegations that Robert has been harassing someone by mail and sending unsolicited hard core pornography. When the detectives arrived at the residence, Robert, Eddie, Heather and Christina were present. Patricia was allegedly working at the Maine Mall in Portland. There was no evidence in the home to support that Patricia Dailey is living at the residence, when police went to her alleged work site they were informed that she is not working for the summer.

Det. Lyons states that he was shown to the girls' bedroom. Robert told the detectives that the girls share a bed and that he sleeps on the couch in the same room. It is unknown at this time where Eddie is sleeping as he states that he is just visiting the family (license states he is from Plant City, FL). Through another door located off the girls' bedroom is a "home office" for Robert's business Red's Realm of Romantic Restraint. The business consists of selling and swapping adult pornography. One would have to go through the girl's bedroom to enter the room where Robert maintains his business noted above. Det. Lyons states that this room would be easy for the girls to access and that both girls showed knowledge of what was in the room and what Robert's business entails. When Det. Lyons spoke with Heather Willis he asked whether she has been involved in any sexual contact she stated, "No I'm a virgin". Det. Lyons stated that Heather said this with hesitance and made no eye contact during this conversation.

The detectives asked if they could look inside the office and were permitted to do so. Upon closer investigation, it was noted that the room was filled with pornographic videos, magazines and a business computer. The materials within the detectives' sight clearly depicted adults engaged in sexual activities. Both minor girls living in the home are aware of the business that Robert operates and the materials that are in the office.

Det. Lyons and Child Protective Services are concerned about the proximity and relative ease of access of the office (containing pornographic materials) to the girls' bedroom, the fact that Robert shares the girls' bedroom, the lack of information concerning the girls' parentage, and the lack of any identification for either girl.

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