Thank you, Madam President. I can reiterate what I said last week about the prospect of calling other witnesses. I'm not ruling it out completely, but I think it's unlikely that we would call any other live witnesses.
Madam President, the position as far as the Defence is concerned, is this: A few weeks ago, the Court ordered that we conclude the calling of evidence by 12 November. We are obviously two months ahead of that, so we have obviously saved a considerable amount of time in the interim. We still have, and are still working on, a number of written motions. What we would invite the Court to do is, in effect, to give us the same time period as the Court gave the Prosecution after they finished calling live evidence and we would make the following proposition for the consideration of the Court and the parties.
You will recall that the Prosecution completed the re-examination of their last witness on 30 January 2009. On 9 February 2009, there was then a status conference. There were still some outstanding motions to be dealt with at that time.
On 19 February 2009, there was a further status conference at which a number of oral decisions were handed down by the Court, and the Court then ordered a final status conference on 27 February 2009, at which the Prosecution formally closed their case. So that was a four-week period.
Madam President, what we would submit would be an appropriate timetable is as follows: We still have, as I've indicated, a number of written motions to submit to the Court; we hope certainly to have some of those in by the end of this week.
The Court has already indicated quite some time ago now that at the end of the Defence oral evidence, we would get the rest of our annual summer leave. We are assuming that's a two-week period. We would invite the Court to give us the two weeks leave but within the four-week period that we say corresponds to the four weeks that the Prosecution had between the end of their last live witness and the formal closing of their case. And it seems to us that an appropriate timetable would be to take us to the end of this week as a sitting term, and, as I've indicated, we hope to get some of our outstanding motions lodged by the end of this week, then to have a two-week vacation, and then a final week to consider what decisions, if any, the Court has handed down on any written motions that were still outstanding because, of course, it may well be that the Court renders decisions that either party would then want to consider appealing. And then have a final status conference at the end of that four-week period, on which date we would formally close our case.
So, in effect, what we would submit would be an appropriate way forward is to give us the same amount of time as the Prosecution but during that time for us to have the remaining two weeks of the summer vacation.
None of the suggestions that we are putting forward are written in stone. It's a proposal, and obviously others may have different views and we are perfectly willing to take on board any suggestions other than to vary the proposal that we've put forward, but we hope that is a proposal that makes sense, is administratively convenient, and would enable us then to close our case a full month before the time that you had originally ordered us to call the last witness by.
Madam President, those are the submissions I make at this stage. I don't know if anyone on the Bench has any questions of us as to any of the matters that I've raised but, if not, then obviously you'll want to hear from Ms Hollis.