The transcripts of the trial of Charles Taylor, former President of Liberia. More…

And I believe the Prosecution has indicated an additional 39 days would be appropriate to bring the total amount of days to 60.

Now, the basis for us seeking 90 additional days is indeed comparative analysis to other cases in like circumstances, if I might say so, before other Tribunals in this field. You know, in Sainovic, the Defence were given an additional 40 days. This is in addition to the 75 days that the ICTY Rules allow. So the total there was 115 days for the filing of the appellant's brief. In Nyiramasuhuko in the ICTR, the brief was [indiscerinble] due 75 days, and they were given an extra 60 days, and that brings the total to 135 days. That is for five of the six accused. The sixth accused was given an extra 90 days to file his appellant's brief which brought the total to 165 days.

The ICTY and ICTR schedules we say are reasonable and should be applicable to a case of this size and magnitude, although emanating from the Special Court, notwithstanding the differences between our Rules and theirs. No other Special Court case comes even close given the size of the judgement vis-a-vis this case. And there's the additional factor that we always have to consult with our client. You know, it is one thing for the Prosecution to work from their office and come up with grounds of appeal and the appellant's brief. We have to, on a weekly basis, go and consult with our client. We do so by telephone, we do so in person, and it is taxing, and it is tedious, and it is time-consuming. So these are facts that we hope the Court bears in mind when it decides on what time might be reasonable under the circumstances.

I will say about the notice that -- and this is in response to a remark by Your Honour about how is the notice different from the appellant's brief or the brief in response or the brief in reply. The notice is important, and the need for additional time, because it allows us to prepare very focused grounds of appeal. Ultimately, this is a time-saving exercise for the Court and everybody involved. If we were given less time on the notice, what Your Honour would find is a litany of grounds of appeal, not well-researched, some of which may be without merit, and we hope to avoid this. If given sufficient time to prepare a proper notice, we will have focused and precise and concise grounds of appeal, and this makes everybody's life easier in the long-run.

So those are the observations would I make in respect of those issues.

With respect to the respondent's brief given Your Honour's question, if I may proceed.

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