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

1 Case 3:03-cr-00117-DJS Document 19 Filed 06/O3/2005 Page 1 of 2 I
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
JOHN DELGADO, z ,
Defendant-movant, E CRIM. N0. 3:03cr0011(DJS) l
2 cxvxt N0. 3:04cv1796(DJS)
vs. : I,
UNITED STATES OF AMERICA, E i7 l
Q May 25, 2005 j
Respondent. ° ,
DEFENDANTYS MOTION FOR TRANSCRIPTSrAND'i `] L5
John Delgado, defendant—movant herein pgp sg, respectgplly
moves for copies of-his 7/27/03 guilty plea transcript, and his
10/27/03 sentencing transcript. Delgado also moves for time to
submit a proper reply to the government's 12/30/OA response to
his pending 28 U.S.C. § 2255 motion. In support, Delgado submits
the following:
1. On October 5, 2005 Delgado submitted a motion to vacate,
set aside, or correct sentence pursuant to 28 U.S.C. § 2255.
2. In his motion, Delgado has advanced claims which relate
to the record of his July 27, 2003 guilty plea and his October l
27, 2003 sentencing. Because Delgado's claims may be supported
by those transcripts, he respectfully seeks copies at government
expense.
3. Although the issues advanced are not fully aired because
of the lack of transcripts (which Delgado has previously [
requested copies of), the government submitted a response on
December 30, 2004. Because the plea and sentencing transcripts T
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Case 3:03-cr-00117-DJS Document 19 Filed 06/O3/2005 Page 2 of 2
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are necessary to make a meaningful argument in support of I
Delgado's § 2255 motion, he respectfully seeks 45 days from the `
date the transcripts are received by him to have a proper E
memorandum of law in support of his § 2255 motion, and combined §
reply to the government's filing, submitted.
Accordingly, Delgado respectfully requests: (1) that the
Court grant his request for copies of his 7/27/O3 plea transcript
and 10/27/03 sentencing transcript at government expense; and (2)
that the Court grant him 45 days from the date he receives those
transcripts to submit his combined supportive memorandum of law
and reply to the government's 12/20/04 filing. 5
Respectfully submit;ed, E
WO éyga , Df0_%-—-ln-
Reg. No. 15155-UI4
FCI Otisville
P.O. Box 1000
Otisville, NY 10963
CERTlFICATE.0F-SERVICE 5
It is herby certified that a copy of the foregoing was
deposited in the legal mailbox at FCI Otisville, postage prepaid, i
addressed to: - i
Thomas V. Daily, AUSA '
United States Attorney's Office
450 Main Street, RM. 328
Hartford, CT 06103 -
By: ,__ , -
O B gél 0
2 1