On Oct. 31, the government filed a memorandum in United States of America v. Paul J. Manafort, Jr. and Richard W. Gates III, to advise the court of three issues prior to the scheduled Nov. 2, 2017 court appearance. First, the government outlines the current bail conditions facing the defendants, arguing that the court should find that the defendants pose a "serious risk of flight." Second, the government asks the court to designate this case "complex" under the Speedy Trial Act, 18 U.S.C. § 3161(h)(8)(B)(ii), impacting the timeline of trial. Last, the government provides the defendants notice pursuant to 18 U.S.C. § 3505 of its intent to use specific foreign bank records, or a "foreign record of regularly conducted activity," in the impending proceedings.