Lawyers for Sam Bankman-Fried, the founder and former CEO of embattled crypto exchange FTX, have filed a new request for his temporary release from jail on Oct. 2, the day before his trial begins.

The legal team says the release is “necessary for preparation of [his] defense” due to the complexity of the case, according to a filing with the U.S. District Court, Southern District of New York.

Sam Bankman-Fried was originally out on bond, but that was revoked in August when a judge ruled he was likely tampering with witnesses. On Sept. 12, the court ruled against a request for Bankman-Fried’s temporary release but said that decision didn’t prohibit his lawyers from making another request. An appeals court declined to reverse the decision last week, which led to the new filing.

The legal team outlined the complexity of the case, where the U.S. government has provided a list of over 50 potential witnesses, thousands of pages of witness statements and reports and over 1300 exhibits, many of which involve complex financial records. The team argues that the lawyers need continuous access to Bankman-Fried to mount their defense.

“We submit that we are finding it exceedingly difficult as a practical matter to adequately prepare for trial with the restrictions on access currently in place. This is not a point we make lightly but it is the reality of the nature of this case,” wrote the legal team. “This case is highly technical and complex, and we need our client to help us understand the facts and explain many of the issues”

“He alone knows the facts which are also critical in preparing his defense. Unfortunately, his knowledge and insight cannot be replicated by third-party experts as they are not familiar with the underlying facts and cannot provide the necessary help,” they continued.

The lawyers offered up some conditions to potentially make the release more amenable to the judge. When not in the courtroom, Bankman-Fried would either be in the presence of his lawyers or a security guard in a temporary residence in New York City, where he would live until the trial was over.

The security guard would make sure Bankman-Fried didn’t have access to computers, the internet, cell phones, televisions or other electronic devices, and he would not be allowed to have visitors.

The lawyers said Bankman-Fried would also agree to a gag order that would prohibit him from speaking to anyone outside of his legal team, parents and brother.