I have, your Honour. I have three points to make in response to the application.
The first point is that this is not a timely application by the Defence. It is quite a different thing for the Prosecution to ask that protective measures be rescinded, but it is a different matter entirely for the Defence to come along at the last moment and ask that protective measures be rescinded, particularly as they have had ample notice of the fact that these protective measures do exist.
The second point, your Honour, is that there is a video in existence. It is a video that does not disclose in any way that the person shown on the video is to be a witness in proceedings and so it's not relevant in our submission to make an application based on the fact that this particular man has shown himself in a video. It doesn't indicate that he is going to be a witness at all in the video.
The third issue that I wish to address is the current security situation and the interplay of Rule 75. It has to be shown - the measures continue except if it can be shown that there has been a change. Your Honours as recently as January this year made a finding in a decision of - I'm sorry, 10 January 2008 your Honours made a decision and a finding that you were satisfied that the potential threats to the security of witnesses still exist and that is as at January 2008.
This proposed witness does hold fears. He holds fears for himself and his family and as your Honours have already decided that the security situation that existed at the time still existed as at January this year. Those are my submissions.