Yes, please, Mr President. We have attempted throughout, within the limitations of the resources available to us, to be as helpful as we possibly can to the Prosecution.
Now, dealing seriatim with the matters raised by Ms Hollis, first of all witness numbers. Yes, we are aware that the list of witness summaries served by us do approach the figure of 250. However, it is important to note, from statistics provided to me by my case manager, that the total disclosure for the Prosecution was some 332 witnesses, of whom some 200 were listed as being core witnesses and back-up witnesses, and eventually some 91 were called.
Now, that being so, it seems to us that the number of summaries served by us in the circumstances cannot be regarded as excessive. Furthermore, we did indicate on previous occasions that our investigations are ongoing and so consequently we are unable to complete the sifting process, which I indicated to your Honours on an earlier occasion was an important aspect of the preparations we were conducting.
I have further indicated that not all of the witnesses named by us in that schedule will be called. So consequently, whereas we hear the concerns being expressed by Ms Hollis regarding the length of the case, I for one certainly have no intention of being here for another four years.
Now, so far as the provision of a list of core and back-up witnesses are concerned, we see no provision in any rule or procedure which requires us to provide that. And, in any event, given that our investigations are ongoing, it would be extremely difficult for us to provide such a list to the Prosecution because for us to attempt to do so might well fall foul of the inadequacies and errors which my learned friend has already pointed out in the list of 250 witnesses or so we've called. And so, consequently, rather than open ourselves up to further criticism, it seems best in the circumstances, to my mind, that we restrict ourselves to the orders made by your Honours on a previous occasion. That is, disclosure some three weeks in advance, or is it two weeks, of the names of our witnesses and we will abide by that.
The third point, experts. We have indicated clearly that the three particular witnesses, the numbers of which have been provided by Ms Hollis, are not experts. There is perfectly adequate provision within the rules of evidence, and no doubt the Prosecution will be quick to interrupt and comment if we were to elicit from those witnesses opinion evidence which falls foul of the rule against the provision of such evidence by non-experts. So we feel that there is adequate protection for the Prosecution in that regard, and so consequently we do not see that this Court needs to make any further orders in that respect.
So far as monthly lists of witnesses are concerned, I wish we were in the happy position of having sufficient resources to be able to research all matters carefully enough to be able to provide such information that far in advance. Unfortunately, we are not in that position and consequently we will not be in a position to provide that. And the same goes for a list of exhibits a month in advance.
Now, the final matter I want to deal with is the change of position by the Prosecution so far as access to the accused. It will be recalled that on the occasion when this matter was discussed it was the Prosecution who raised this issue and helpfully provided the Court with a copy of an authority from the ICTY dealing with the matter. We are somewhat concerned that they have now used the pretext of certain suspicions raised regarding contact between the accused and certain individuals, a matter which has not been thoroughly investigated by those who have direct responsibility for those matters, that they should have used that to now seek to have this complete about-face in their position.
Now, when my learned friend asks that any contact should be monitored, I am unclear. Does that include any contact between Mr Taylor's lawyers and him, or what are we talking about? Are we talking about the monitoring of telephone conversations? That happens at the moment, in any event. Because the very matter raised by Ms Hollis came about because his calls are monitored and because transcripts were available of those conversations. So what in addition is being asked for in terms of protective measures, if I might style it such, in order to ensure that Mr Taylor's every word is monitored by a third party?
In our submission, there is no need for any additional measures in this regard. Additionally, we submit that there should be no change in the position adopted and ordered by this Court on a previous occasion that we can indeed have access to Mr Taylor during the giving of his evidence. I have said our investigations are ongoing. We will need access to him in order to ensure that those are efficiently and adequately carried out and the last thing I would accept is any suggestion that any such contact between us and Mr Taylor is monitored. I am not willing to accept that at all.