Free Motion for Miscellaneous Relief - District Court of Connecticut - Connecticut

Case 3:O3—cr—O0228-JCH Document 83 Filed 02/29/2008 Page1of4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT (NEW HAVEN)
Case No. 3:03-MJ-00183 ge M>
United States of America,
Plaintiff,
vs.
Raymond Delvecchio,
Defendant.
_________________/
DEFENDANT'S MOTION FOR
PREPARATION OF TRANSCRIPTS F: E; *
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Comes now, the defendant, Raymond Delvecchio, w`rg_§esp§ct-%¤=·’
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fully seeks an order from this Court for the preparat§§g§ an) @3%
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government expense, of transcripts of the hearing heldqgéy 37
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2004 on Defendant's Motion for Competency Exam and on Jdgy 39;
2004 at which Defendant was found competent to stand trial.
In support of this request, the Defendant states the following:
1.) The Defendant, who is proceeding pro se, is
incarcerated at the Allenwood Federal Low Security
Correctional Facility located in White Deer, PA.
2.) The Defendant, a 59—year—old individual with a
tenth grade education, is relying on the assistance of
a fellow inmate in the preparation of this petition.
3.) On May 3, 2004, a hearing was held on the Defendant's
oral Motion for a Psychiatric Examination; and on July 5
30, 2004, the Court ruled in open court on the Defendant's
Motion for a Competency Evaluation.
A 4.) The Defendant, who never had an opportunity to

Case 3:O3—cr—O0228-JCH Document 83 Filed O2/29/2008 Page 2 of 4
review the report issued in response to the Court's
order that Defendant's Competency be evaluated, was
sentenced to a term of imprisonment of 174 months on~~V· ~ ·
February 23, 2005 pursuant to a plea agreement in which
the Defendant plead guilty to the charges.ofQ(1) threaten-
ing to murder a federal law enforcement officer and (2)
Y unlawful posession of firearms.
5.) The Defendant is contemplating petitioning this
Court for a determination of his actual innocence of
T the aforesaid charges and that the sentence was imposed
in violation of the Constitution or laws of the United
States.
6.) Because of the complex nature of American Jurisprudence
and the nuances of the rules governing Habeas Corpus Cases,
the Defendant can not prepare a meaningful Petition
seeking collateral review of his conviction without havinga
the opportunity to review transcripts of the hearings
held on Defendant's Motion for a Psychiatric Exam and the
Court's subsequent finding thereon.
7.) The Defendant, who is indigent and unable to per- "
sonally pay for the preparation of the aforementioned
transcripts, will be severely prejudiced if his request
for preparation of those transcripts at government P
expense were not granted.
8.) The Defendant has enclosed herewith an application

Case 3:O3—cr—O0228-JCH Document 83 Filed 02/29/2008 Page 3 of 4
to proceed in forma pauperis with supporting documentation.
9.) The Defendant is incarcerated and therefore unable
to ascertain the government's position regarding the
relief requested herein.
Wherefore, the Defendant respectfully requests an order
from the Court directing that transcripts of the hearings
conducted on May 3, 2004 and July 30, 2004 be prepared at
government expense and forwarded to the Defendant.
Respectfully submitted,
Dated: February 25, 2008 Raymond Delvecchio
r Reg.No. 15254-014
4 LSCI Allenwood
PO Box 1000
White Deer, PA 17887

Case 3:O3—cr—O0228-JCH Document 83 Filed 02/29/2008 Page 4 of 4
CERTIFICATE OF SERVICE
I, Raymond Delvecchio, do hereby certify that I have
mailed a true and correct copy of the foregoing Motion for
Preparation of Transcripts, via first-class mail to:
The Office of the U.S. Attorney
157 Church Street, 23rd Floor
New Haven, CT 06510
on this 26th day of February 2008.
Rayménd Delvecchio