Though his rambling, but otherwise perceptive, Pro Se letter to the Court states that the enclosed material constituted his grounds for a New Trial, Richard Chichakli appears to have already selected his points on appeal. The defendant wrote to the trial judge, in one letter advising that he wants a new Stand-By counsel, for the reason that counsel has not contacted him regarding any post-verdict matters, and in another letter, detailing his reasons for a new trial.
Chichakli, who has failed to cite to any primary authority in his letter, persists in asserting that the trial was flawed. I will quote herein his issues, making minor adjustments for grammar, and to replace non-legal terms, but otherwise verbatim. Remember, he is composing this material while in custody, in a temporary location, and without any legal or clerical support. We call those adverse conditions, and if you have never had that experience, consider yourself informed that it is a trying experience.
(1) The defendant was not afforded a fair opportunity to prepare a complete defense, in violation of his Constitutional Rights.
(2) A non-expert witness was allowed to testify as an expert.
(3) His cross-examination of government witnesses, regarding their credibility, was denied.
(4) The Government conspired with the Bureau of Prisons to obstruct justice, and deny the defendant his Constitutional Right to prepare and present a complete defense.
(5) The jury communicated prejudicial comments to the Court, and they therefore could not render an impartial and fair decision.
The Court has scheduled a conference with all parties; Chichakli's pending post-trial motions remain pending, and the scheduled sentencing date is fast approaching, so a ruling should issue soon; Stay tuned.