The former quality-control manager for the now-defunct Peanut Corporation of America processing plant at Blakely, GA, says that her defense cannot make sense out 3 to 4 million documents that could be used at her trial. In the latest motion, federal defense attorney Thomas G. Ledford says his client, Mary Wilkerson, needs access to the index numbering system the government is using to track and locate the documents. Wilkerson is one of four former PCA executives scheduled for a federal criminal trial in February. She is charged with two obstruction of justice counts. In what’s been a continuing theme from her defense, Wilkerson wants the government to disclose its law enforcement, investigative, expert, and informant witnesses ahead of the trial. Ledford’s motion asks the government to reveal the names, employer or agency names, job titles, mailing addresses and phone numbers for all potential witnesses so that he may prepare Wilkerson’s defense. The motion specifically says the government needs to produce the “Bates Number Reference Guide” being used to organize the documents. “While the government in said response dated Sept. 6, 2013, stated that it was beginning to create a Bates Number Reference Guide, the Defendant points out that she still has not received one,” Ledford writes in his latest motion. “The Defendant hereby requests that the Government produce said Bates Number Reference Guide since it has been involved in this case about five years and the Trial is scheduled for Feb. 10, 2014, less than four months away,” the motion states. The Wilkerson defense also says it requires not only the software and hardware for the system being used by the government to manage the documents, but also training on how to use it. The government has until Nov. 15 to respond to defense motions, and many were filed in the pre-trial sparring that has marked the case so far. Wilkerson is one of four PCA executives, charged with a total of 76 federal felony counts, who will be tried together in February before U.S. District Court Judge W. Louis Sands in Albany, GA. The others are PCA’s top officers, Steward and Michael Parnell, and the former Blakely plant manager, Samuel Lightsey. The Parnell brothers have asked for separate trials. The trial involving conspiracy and fraud is occurring about five years after contaminated peanut butter and paste from PCA plants in Georgia and Texas were linked to a nationwide outbreak of Salmonella Typhimurium. The outbreak sickened 700 and killed nine people, ending with one of the largest ingredient recalls in U.S. history, involving almost 4,000 products. PCA was headquartered in Lynchburg, VA.