RCMP Corporal Greg Horton today filed an affidavit in Ontario Superior Court, asking for access to bank files and saying he has "reasonable grounds" for believing that the files contain evidence of defrauding the Senate of Canada "by deceit, falsehood or other fraudulent means."

Cpl. Horton has been investigating the Duffy affair for several months. An earlier affidavit, filed in June, was the subject of a Tyee article in July.

In the present affidavit, posted on Scribd. by Postmedia parliamentary reporter Jordan Press, Cpl. Horton writes:

I have reasonable grounds to believe and do believe that offences contrary to an Act of Parliament have been committed, to wit:

• Michael Duffy between February 23, 2009 and April 20, 2012 at Ottawa, Ontario, being an official in the Senate of Canada, did commit breach of trust in connection with the duties of his office by awarding consulting contracts for little or no value for service, contrary to Section 122 of the Criminal Code.

• Michael Duffy between February 23, 2009 and April 20, 2012 at Ottawa, Ontario did by deceit, falsehood or other fraudulent means defraud the Senate of Canada of $64,916.50 by awarding consulting contracts for little or no value for service, contrary to section 380(1) of the Criminal Code.

Cpl. Horton goes on to specify the records of two Bank of Nova Scotia accounts as likely to contain evidence of the offences. In the overview section of the affidavit, he notes that his investigation has determined that Senator Duffy hired a friend, Gerald Donohue, as a consultant over a four-year period. He then states:

5. Duffy's friend, Mr. Gerald Donohue, has been interviewed by investigators [and] has acknowledged that he produced no tangible worked product for Duffy. He stated that he was paid for conducting Internet research and providing verbal advice. Based on the investigation to date, I believe he was awarded contracts and paid an inflated rate for the type of service purportedly provided. For the first three fiscal years during which Duffy was a Senator, Mr. Donohue submitted annual invoices to the Senate for lump sum payments. The amounts before taxes were $10,000 (2008/09), $13,300 (2009/10), and $12,000 (2010/11). For the fiscal year of 2011/12 he submitted monthly invoices for $2000 per month for a total of $24,000. The complete circumstances of these contracts and payments will be explained in the Grounds for Belief.

The accounts, Cpl. Horton explains, were used by Donohue to cash or deposit his cheques from the Senate. He also notes: "The transaction supporting documents will assist investigators in identifying where the money went after it was deposited, as Donohue claims that he personally did not receive any of that money."

Crawford Kilian is a contributing editor of The Tyee.