I have not forgotten that either.
I'll move on, then, to the preparation for the Pre-trial Conference.
Mr. Khan, you've already indicated to the Court that there are no special defences and that you will not be filing a statement, and I will presume that situation stands. So most of what, therefore, comes under 73 will relate to Mr. Rapp's office.
Mr. Rapp, how are you progressing on the matters for a Pre-trial Conference? I think we've covered some of them already, actually.
MR. RAPP: Well, the most critical thing I think that the Pre-trial Conference is tied to is the pre-trial brief and the so-called final list of witnesses. Our position is that we want time to make sure that the selected list of witnesses that we place into that pre-trial brief are the best witnesses and the ones that, in fact, will be called.
We would prefer to have the order for the filing of the pre-trial brief and for the list of witnesses to be fixed 42 days before the trial date, on the same day that unredacted disclosure is due for the first witnesses. Of course, the Trial Chamber can require that it be earlier than that, and that's within the hands of the Trial Chamber. I believe it's then provided that the Pre-trial Conference would then be conducted after that was filed.
We would be concerned about having to complete the witness list in the final sense until we've had an opportunity to see each of the witnesses, and particularly to determine which witnesses we may want to offer by written testimony under 92 bis rather than oral testimony.
Obviously, whenever the order is made, whenever the Trial Chamber orders us to do this, we will provide the pre-trial brief, lay out our legal theories of the case, state who the witnesses are, provide summaries to the extent they haven't been provided before, and state exactly to what count each of those witnesses will be testifying. But that list may be longer the earlier we're required to do it, because we have to reserve the ability to include sometimes multiple witnesses if we haven't had an opportunity to speak to -- members of the trial team haven't had an opportunity to speak to these witnesses. And they're not quite halfway through meeting with these witnesses at this time.
But as I indicate, we'd prefer that that be 42 days beforehand, but we will meet the Court's requirements to provide --