There are two aspects to this answer, one of which is covered by solicitor-client privilege or the claim of solicitor-client privilege, but I take your point regarding what was testified to at the prior occasion. I'm not here to give out a legal opinion on the validity of that claim of privilege.
There were discussions around that issue. I'm not authorized to disclose them to this committee, absent direction from Madam Chair and the committee, so there's part of the answer that I cannot provide unless ordered to.
In relation to the second part of the answer, what I would say and what I think is important for the committee to understand, is that the issue of refusals had not crystalized at any point in my investigation. That is because of the conclusion that I drew, along with my law partner Alex Smith and supported by my law associates at the firm, that I should not interview the remaining players, absent the statement from the complainant. I needed her version of events to push forward in my investigation.
Once the criminal proceedings concluded, I focused my efforts on speaking with the complainant's counsel and attempting to facilitate obtaining that statement so that I would be equipped to move forward in my investigation. As I indicated in my opening statement, ultimately by September of 2020, after 18 months of those efforts not arriving to the place I had hoped they would, I closed the investigation without prejudice to reopening it at a later date—and, as I indicated, we are here now.