The CTV News investigation into allegations of sexual misconduct by Patrick Brown began with a tip that he had made a “financial contribution” as part of a settlement with a female Parliament Hill staffer with whom he’d “engaged in some sort of sexual misconduct/ harassment” while an MP, according to a CTV court filing.

In a statement of defence filed Friday in response to the former Ontario PC leader’s defamation lawsuit against the network and its journalists, CTV offers new details concerning both its reporting process and the allegations its sources made against Brown. In particular, the document describes the genesis of the investigation and offers a fuller picture of claims made by the two accusers, as well as other tips (such as the above) that CTV was unable to substantiate.

None of the claims in Brown’s suit, nor CTV’s statement of defence, have been proven in court. Through Joseph Villeneuve, Brown’s general counsel and friend, who is not directly involved with the CTV suit, Brown also denies there having been any settlement on Parliament Hill.

Brown has adamantly denied engaging in any inappropriate conduct and, in his lawsuit, accuses CTV News of engaging in “false, malicious, unfair, and irresponsible reporting” that “subverted the democratic process in Ontario.” According to his statement of claim, the Brown-led Ontario PC party had been “set to overtake the Wynne Liberals” before CTV’s story “delivered an almost immediate death blow to Mr. Brown’s reputation and political career.” (On Tuesday, Brown announced he will be running for chair of Peel Region this fall.)

In its response, CTV maintains that it and its reporters (including Lisa LaFlamme, Rachel Aiello, and Glen McGregor, all named in the suit) acted responsibly in carrying out journalistic activities in the public interest.

CTV’s full statement of defence is embedded below, alongside Brown’s original statement of claim, but here are some of the most notable parts:

• According to the CTV filing, the initial tip about Brown came in on July 21, 2017, to Travis Dhanraj, then a reporter with CTV sister station CP24. Dhanraj, who along with CP24 is named in Brown’s lawsuit, was advised by his source that a “sexual misconduct/ harassment” incident with a female Parliament Hill staffer “had not been reported to the police, but that the House of Commons’ Board of Internal Economy (‘BOIE’) — the body that presides over administrative and financial matters respecting the House of Commons, its premises, staff and members — had been made aware of it.” Per the statement of defence, Dhanraj was told that “as a condition of settlement with the Parliament Hill staffer, Brown had to provide an admission of guilt and apology” as well as “a financial contribution.” (It’s unclear if the contribution was said to have been made directly to the staffer.) Dhanraj hit a roadblock in his reporting — since BOIE matters are kept confidential, he was unable to substantiate the tip — but returned to the story following the emergence of the #MeToo movement that fall. (Villeneuve tells CANADALAND that “there was never any procedure or settlement via Parliament” and that the BOIE matter “never happened.”)

• “In November 2017,” the filing states, “a different source also advised Dhanraj that there may have been an incident on a federal Progressive Conservative Youth Federation (‘PCYF’) bus in 1999 that may have led to police involvement. CTV did not report on this incident because it was unable to verify the allegation.” (Villeneuve says the incident “never happened.”)

• In the course of looking into tips concerning Brown’s alleged activities at a Barrie nightclub called The Bank — including one involving “a young woman’s father intervening to request that Brown leave his daughter alone” — a colleague told Dhanraj about the woman who would ultimately become the first of the two accusers in CTV’s story. Around the same time, Dhanraj participated in a conference call with staff in CTV News’ Ottawa bureau, including online producer Rachel Aiello, who “indicated that she may know of another accuser with a similar story involving Brown.” She had already begun looking into the story following a late November profile of Brown in the Toronto Star that she found to be “incongruous” with what she had heard about him. (Villeneuve says he’s verified that “no father ever contacted” Brown.)

• In his suit, Brown alleges that Aiello and the second accuser had been co-workers at The Hill Times. In its statement of defence, CTV notes that Aiello had first been told of the allegations by the second accuser while working at The Hill Times but that they would not comment on confidential sources.

• CTV’s filing states that in a January 8th email following an earlier phone conversation with Dhanraj, the first accuser summarized her allegations, writing, “I was the age 17-18 I know I was for sure underage” when she ended up at Brown’s house “for some drinks” after a night out. “He asked if he could give me a tour of his house. When we got to the bedroom he closed the door and pulled out his penis. He told me to suck it. I remember being very uncomfortable and I sucked it for a second then realized I needed to leave and it wasn’t a good situation.” She later reiterated her recollection of her age in a subsequent interview with CTV News anchor and senior editor Lisa LaFlamme. (In addition to his having denied the encounter unfolded as alleged, Brown’s suit contends that CTV “failed to fact check” the claim that the first accuser was in high school at the time. In a subsequent article approximately two weeks after the original report aired, CTV reported that the woman had realized she had erred in her recollection of the date. “Rather than apologize to Mr. Brown for their egregious error,” his suit states, “the defendants treated their false, malicious, and defamatory reporting in relation to Accuser 1 and the innuendo of illegal conduct as inconsequential.”)

• After CTV’s Ottawa bureau took over the story from CP24’s Dhanraj, senior political correspondent Glen McGregor interviewed the second accuser, who described her experience meeting and getting hired to work for Brown, and the 2013 incident she characterized as a sexual assault. She further said, according to CTV’s filing, that “while working for Brown in the summer of 2014, Accuser 2 was required to drive Brown to various events and, in the course of doing so, Brown made numerous inappropriate comments about sexual relations he had had with other women.” She said he also told her “that he believed it would be difficult to run for leadership of the party without a wife and kids” and “he wished he could ‘find someone like [her] who was 26 or older to marry him.’” (On the evening of last month’s provincial election day, Brown announced his engagement to Genevieve Gualtieri, who had previously interned for him and was 23 when she spoke to the Star in defence of his character earlier this year.)

Cast my ballot tonight in #MississaugaLakeshore with my fiancé Genevieve. Voting is our democratic duty. Don’t forget to vote! #onpoli pic.twitter.com/pYPIojxKUb — Patrick Brown (@patrickbrownont) June 7, 2018

• To Brown’s contention that CTV’s McGregor provided him insufficient time and detail to properly respond to the allegations — emailing him to request an interview just hours before the intended broadcast — CTV responds that neither Brown nor his lawyer made a request for additional time, instead choosing to issue a statement and hold a press conference.

• “In the weeks following the news reports of January 24/25, 2018,” CTV states, “a number of people came forward with allegations of other discreditable conduct by Brown, which were followed up by CTV. As an example, one woman came forward with a detailed account of Brown’s conduct dating back to his time as a leader of the federal Progressive Conservative Youth Federation. However, after conducting some due diligence, CTV decided not to report the third accuser’s account in part because it was determined that she was a supporter of the Ontario Liberal Party.” (Brown, Villeneuve says, “has no knowledge of this and denies any such incident.”)

• In his suit, Brown claimed, “The devastating impact of the Defamatory Words, and the innuendo arising from them was heightened by the way in which the defendants edited the January 24 Broadcast and subsequent broadcasts: The defendants showed Accuser 1’s and Accuser 2’s faces in shadow, warned viewers of graphic content, and in respect of Accuser 2, cut to McGregor as interviewer, nodding and with a serious expression on his face, all of which cast Mr. Brown in the worst possible light to viewers.” CTV responds: “Accuser 1’s face was not depicted at all. Accuser 2’s face was shown in silhouette format because she would only agree to be interviewed on-camera if her privacy was respected. This is not an unusual or unreasonable request for someone who claims to have been the victim of sexual misconduct.” As for McGregor’s demeanour, CTV explains he “had a serious expression on his face during the interview with Accuser 2 because the subject matter was serious. It would not have been appropriate to have any other expression.”

CANADALAND has previously reported that Brown — who is seeking $8 million in damages — hired a crisis team in an attempt to clear his name via a series of Facebook posts attacking his accusers, as well as through sources offered to competing outlets who cast doubt on the accusers’ versions of events. After his comeback campaign, Brown briefly entered the Progressive Conservative leadership race to replace him, then dropped out following news reports concerning his involvement in the alleged rigging of a PCPO nomination contest and questions regarding his personal finances and deal that fell through involving a friend and eventual PCPO candidate agreeing to buy Brown’s stake in a restaurant and two million Aeroplan miles for $375,000.

With additional reporting by Jaren Kerr.

Patrick Brown v. CTV statement of defence by CANADALAND on Scribd

Brown v. CTV et al_ by Katie Dangerfield on Scribd