I am not sure which witnesses the State will rely upon in order to attempt to prove its case against me. Nonetheless, I undertake not to communicate with any witness, whoever he or she may be, and any other persons whose names may appear on a list of "State witnesses", to be provided by the State.

My continued incarceration can only prejudice me and creates no benefit to the State.

I respectfully submit that should I be released on bail, my release shall not disturb the public order or undermine the proper functioning of the criminal justice system.

I will comply with such conditions as the above Honourable Court may wish to impose.

I accordingly submit that the interests of justice, considerations of prejudice and the balancing of respective interests favour my release on bail.