The Defense has received authorization to make its motions available to the public. The Defense’s effort to publish its motions is designed to be responsive to concerns raised by the Reporters Committee for Freedom of the Press and the Center for Constitutional Rights. Each organization believed that the lack of access to documents filed in this proceeding resulted in the public not being adequately informed.

The Defense believes that the vast majority of the parties’ filings should be made public. However, the Government has opposed the public filing of motions due to concerns over revealing protected information. In response to the Government’s concerns, the Defense has voluntarily redacted its motions in areas where the Government opposes public release of the referenced information.

It is our intent to continue to provide our motions as soon as being authorized to do so.

Already-Litigated Motions
1) Defense Motion to Compel Depositions
2) Defense Reply to Prosecution Response to Defense Motion to Compel Depositions
3) Defense Motion for Bill of Particulars
4) Defense Reply to Prosecution Response to Defense Motion for Bill of Particulars

Discovery Motions (including Motion to Dismiss All Charges with Prejudice)
5) Defense Motion to Compel Discovey
6) Defense Reply to Prosecution Response to Defense Motion to Compel Discovery
7) Defense Motion to Dismiss All Charges With Prejudice

Main Motions for April 24-26, 2012
8) Defense Motion to Dismiss the Specification of Charge I for Failure to State an Offense
9) Defense Motion to Dismiss Specification 1 of Charge II for Failure to State an Offense
10) Defense Motion to Dismiss Based Upon Unreasonable Multiplication of Charges
11) Defense Response to Prosecution Motion to Preclude Reference to Actual Harm or Damage

Other Motions for April 24-26, 2012
12) Defense Forensic Request of Relevant Computers
13) Defense Renewal of Motion to Compel Discovery of Computers
14) Defense Request for Partial Reconsideration of Discovery Ruling