As a Result of the Supreme Court of Canada's O'Connor

As a result of the Supreme Court of Canada's O'Connor ruling (1995) ,which of the following materials are subject to being turned over to the courts in sexual assault cases?

A) neither records kept by therapists and rape crisis counsellors nor personal diaries or letters kept by the complainant
B) records kept by therapists and rape crisis counsellors but not records kept by the complainant
C) personal diaries and letters kept by the complainant and records kept by therapists and rape crisis counsellors
D) personal diaries and letters kept by the accused but not records kept by therapists and rape crisis counsellors