Thank you, Madam President. Madam President, in relation to potential Defence witnesses and that they don't know, maybe they have and maybe they don't, we suggest that simply is not good enough. It has been 19 months almost since the Prosecution closed its case. It has been over 14 months since the Defence began its case. They have had access to the accused to determine who should be called since the very first day they came on this case three years ago. If they don't know by today who they need to call to address substantive issues, we suggest they are not going to know. And to leave this case open indefinitely while they continue to decide, we suggest is not proper trial management, it is not in the interests of justice, and it certainly is not part of any right of any accused. So we suggest that is not a proper basis to continue to keep this case open.
In relation to the Defence motions. As your Honour pointed out, four motions were filed on 24th, only one motion was filed prior to that. And of the four motions that were filed on the 24th, three of them were filed at 16:57, at 19:38 when the Prosecution still happened to be in its offices, a person from CMS came to our office and asked if we would accept the last filing and, of course, since we were there, we did accept the last filing. So we received these at the very end of the day on Friday.
Now, nonetheless, we do want to move things forward in this case so that we can have an end to the Defence case. We anticipate we will be able to file responses to three of the four this week. We will work very hard to see if we cannot, in fact, file responses to all of them. It may be, however, that we are only able to file responses to three of the four. Should that be the case, we will file the response to the fourth motion immediately next week, hopefully, no later than close of business on Monday, and the reason that we have to wait for some of these motions is to get information from Freetown.
So we will move very rapidly to file responses to these motions well in advance of the time that we would be allotted. We ask that your Honours impose an expedited reply schedule on the Defence, giving them between 24 and 48 hours to file any reply they might have, so that your Honours will be able to decide these motions, hopefully, during this supposed recess, or very shortly thereafter.
In relation to disclosure, the Prosecution has made disclosure based on its understanding of the disclosure rule and the jurisprudence on that disclosure. We will certainly take into account your Honours' decision of last week to see if that requires any additional disclosure on our part.
In relation to looking at this decision and applying it to all Defence witnesses, please keep in mind that the Defence filed a list of 250 some witnesses. We don't have the names of most of those witnesses. So at best --