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Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
Joint shedilling report
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Joint shedilling report

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  • 1. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 1 of 22 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA CASE NO.: 11-20120-CIV-SEITZ/SIMONTON TRAIAN BUJDUVEANU, Plaintiff, vs. DISMAS CHARITIES, INC., ANA GISPERT, DEREK THOMAS and ADAMS LESHOTA Defendants. JOINT SCHEDULING REPORT The Plaintiff, Traian Bujduveanu and Defendants Dismas Charities, Ana Gispert, Derek Thomas and Adams Lashanda, by and through undersigned counsel, and pursuant to the Courts "Order Requiring Joint Scheduling Report", hereby submit this Joint Scheduling Report. A. STATEMENT OF THE FACTS AND OF THE CASE Plaintiff Traian Bujduveanu, a former Federal Inmate, has filed a Complaint against Residential Reentry Center (RRC)/Half Way House, Dismas, and three of its employees, Gispert, Thomas and Lashanda. PLAINTIFFS SUMMARY OF CONTENTION & RELIEF SOUGHT This is an individual action brought by Plaintiff Traian Bujduveanu, a former federal inmate, against (i) Dismas Charities, Inc., owner and operator of Dismas Charities Halfway House in Dania Beach, Florida, at which Plaintiff was sent by the Federal Bureau Of Prisons, after he was released from Federal Custody to Community Custody;(ii) individual Defendants Ana Gispert, Director of Dismas Charity Halfway House in Dania Beach, Florida, Derek
  • 2. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 2 of 22 CASE NO.: 11-20120-CIV-SEITZ/SIMONTON Thomas, Assistant Director of Dismas Charities halfway house in Dania Beach, Florida, and Lashanda Adams, Counsel of Dismas Charities halfway House in Dania Beach, Florida. ("An inmate must be assigned COMMUNITY custody status, prior to transfer to a CCC") (PS5100.08) Plaintiffs claims against Dismas Charities, Inc. and the Defendants, allege violations of Illegal Search and Seizure, False Arrest, Unlawful Imprisonment, Violation of Constitutional Rights, Unlawful Discrimination of Race, National Origin, Ethnic Groups and Ancestry, Reverse Discrimination under the color of state and federal law, Discriminatory Harassment, Intentional Infliction of Mental Distress, Deliberate Indifference, Negligence and Gross Negligence, by failing to ascertain the medical condition of the Movant complaints of feeling ill. Plaintiff sues Defendants Ana Gispert, Derek Thomas and Lashanda Adams both in their personal capacity and their official capacity as employees of Dismas Charities, Inc. for violation of Plaintiff s : a. First Amendment of the United States Constitution, for Freedom of Speech and retaliation; b. Fourth Amendment of the United States Constitution, defining the right to be free from unlawful seizure of his property or person; c. Fifth Amendment of the United States Constitution, defining the rights to due process. d. Eight Amendment of the United States Constitution, defining the right to be free from cruel and unusual punishment. d. Fourteen Amendment of the United States Constitution rights to procedural due process pursuant to 42 U.S.C. 1983 ("Due Process")
  • 3. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 3 of 22 CASE NO.: 11-20120-CIV-SEITZ/SIMONTON e. Violation of state laws of the State Of Florida, to include False arrest and imprisonment, Assault and battery; Malicious Prosecution, Abuse of process, Negligence, and Gross Negligence. f. Unlawful discrimination of race, national origin, ethnic groups and ancestry under the color of state and federal law. g. Infliction of Mental Distress, h. Deliberate Indifference. i. Negligence and Gross Negligence by failing to ascertain the medical condition of the Plaintiff complaints of feeling ill. Plaintiff brings this action for general, compensatory, and punitive damages, prejudgment interest, costs and Court fees, and other appropriate and just relief resulting from Defendants unlawful conduct. DEFENDANTS SUMMARY Defendants contend that Plaintiff, Traian Bujduveanu, was transferred from Federal Correctional Institute Coleman Low to Dismas Charities, Inc.s Dania Facility on July 28, 2010. Dismas Dania facility is a Residential Re-Entry Center for federal inmates, such as Plaintiff, to serve out a remaining percentage of their sentence before release. Plaintiff was serving a 35 month sentence for conspiracy to violate the International Emergency Economic/Power Act, the Iranian Transactions Regulations, and the Arm/Export Control Act. Plaintiff was scheduled for release from Dismas on January 3, 2011. On or about September 28, 2010, Plaintiff was transferred to home detention. He remained on home detention until October 15, 2010, at which time he was returned to the Dania
  • 4. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 4 of 22 CASE NO.: 11-20120-CIV-SEITZ/SIMONTON facility for violating a condition of his home detention and the possession, manufacture, or introduction of a hazardous tool. The underlying incident occurred on October 13, 2010, where Plaintiff was discovered driving an automobile without proper authorization. The vehicle was located at the Dania facility and was subsequently searched after Plaintiff was observed by staff and then admitted that he had been operating the vehicle without authorization. A mobile/cellular telephone was found inside the vehicle, which Plaintiff acknowledged. A Disciplinary Report by Dismas staff was then prepared and signed by the Plaintiff on October 15, 2010. In addition, an Incident Repot was also prepared by Dismas on October 20, 2010, and forwarded to the Bureau of Prisons. Also on this day, Dismas advised the Bureau of Prisons that Plaintiff was terminated from the residential re-entry center due to the accumulation of the Incident Report, three prior Disciplinary Reports, and general noncompliance with program rules and regulations. He was, therefore, taken into custody by the U.S. Marshall Service and transported to the Federal Detention Center in Miami, where he remained until his release 81 days later. Plaintiff originally filed with this Court a Motion for Return of Property against Dismas and Ana Gispert, the Director of the Dania facility on January 12, 2011. The Motion was preceded by a certified letter from Dismas to Plaintiff dated January 5, 2011, advising him that his belongings were being held at the facility awaiting someone to pick them up. As of current day, the items remain at Dismas. On March 28, 2011, Plaintiff filed a Complaint against Dismas, Ana Gispert, Derek Thomas and LaShanda Adams (improperly named as Adams Lashota) seeking $3.1 million dollars in compensatory damages and $500,000 in punitive damages for a total of $3.6 million
  • 5. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 5 of 22 CASE NO.: 11-20120-CIV-SEITZ/SIMONTON dollars against the Defendants. The Complaint contains 50 paragraphs of "factual allegations" filed by a laundry list of four alleged Federal Theories of Recovery and six alleged state law theories of recovery. The Defendants filed a Motionto Dismiss the Complaint which is pending. No counterclaims are expected. B. UNCONTESTED AND STIPULATED FACTS None. C. LIST OF LEGAL ELEMENTS AND DEFENSES ASSERTED The Plaintiffs list of the legal elements for each claim is as follows: a. First Amendment of the United States Constitution, defining the right to freedom of expression; b. Fourth Amendment of the United States Constitution, defining the right to be free from unlawful seizure of his property or person; c. Fifth Amendment of the United States Constitution, defining the rights to due process. d. Eight Amendment of the United States Constitution, defining the right to be free from cruel and unusual punishment. d. Fourteen Amendment of the United States Constitution rights to procedural due process pursuant to 42 U.S.C. 1983 ("Due Process") e. Violation of state laws of the State Of Florida to include False arrest and imprisonment, Assault and battery; Malicious Prosecution, Abuse of process, Negligence, and Gross Negligence.
  • 6. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 6 of 22 CASE NO.: 11 -20120-CIV-SEITZ/SIMONTON f. Unlawful discrimination of race, national origin, ethnic groups and ancestry under the color of state and federal law. g. Infliction of Mental Distress, h. Deliberate Indifference. i. Negligence and Gross Negligence by failing to ascertain the medical condition of the Plaintiff complaints of feeling ill. j. Plaintiff brings this action for general, compensatory, and punitive damages; pre-judgment interest, costs and Court fees; and other appropriate and just relief resulting from Defendants unlawful conduct. Defendants have asserted the following defenses: The Defendant has not raised defenses at this time. Instead, the Defendants filed a Motion to Dismiss the Complaint. In the Motion to Dismiss, the Defendants alleged that the Complaint fails to allege the specific facts and allegations necessary for any cause of action. Instead the Complaint simply names a cause of action (i.e. abuse of process) without stating the legal and factual elements for the cause of action. The Complaint fails to delineate which Defendant is being sued for which specific cause of action. The Complaint also fails to allege any cause of action against certain Defendants. Even if the factual allegations in the Complaint are accepted as true, the Complaint fails to properly plead causes of action. The Complaint also fails to allege any violations of Federal or State law by any Defendant. Without any proper and sustainable Federal or State cause of action, this lawsuit should be dismissed.
  • 7. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 7 of 22 CASE NO.: 11-20120-CIV-SEITZ/SIMONTON D. WHETHER DISCOVERY SHOULD BE CONDUCTED IN PHASES OR LIMITED TO CERTAIN ISSUES The Parties do not believe that discovery should be conducted in phases or limited to certain issues. E. A DETAILED SCHEDULE OF DISCOVERY FOR EACH PARTY Plaintiff and Defendants have attached their discovery schedules to this Report. F. PROPOSED DATES AND DEADLINES See attached Schedule on the form provided by the Court. G. ESTIMATED LENGTH OF TRIAL This case will be tried by a jury and is estimated to last 4-7 days. H. LIST OF PENDING MOTIONS Defendants filed a Motion to Dismiss which is not ripe as the Plaintiff has not presently filed a response brief and Defendants have not filed a reply brief. The Motion to Dismiss was filed on May 4, 2011. There are no other matters presently set before this court other than Joint Scheduling Report and Motion to Dismiss And Incorporated Memorandum of Law in Support by Dismas Charities, Inc. However, Plaintiff intends to file Motion to Strike Motion to Dismiss and Incorporated Memorandum of Law in Support of the defendants. I. UNIQUE LEGAL OR FACTUAL ASPECT REQUIRING SPECIAL CONSIDERATION Unknown at this time pending the determination of the Motion to Dismiss. The Plaintiff is pro se.
  • 8. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 8 of 22 CASE NO.: 11-20120-CIV-SEITZ/SIMONTON J. STATEMENT OF NEED OR AGREEMENT TO REFER MATTERS TO MAGISTRATE JUDGE The Parties agree that the Magistrate can hear all non-dispositive motions. The Parties agree that the District Court Judge should try this matter and rule on dispositive motions and pre trial motions. The Parties agree that the District Court Judge shall be the one to try this matter in front of a jury. K. LIKELIHOOD OF SETTLEMENT In light of the demands of the Plaintiff and settlement conversations to date, settlement is unlikely. The Parties are willing to discuss settlement. L. ANY LOCAL RULE 16.1B MATTERS Unknown at this time pending determination of the Motion to Dismiss. The parties certify that their Rule 26 disclosures will be made at the time of the preparation of this Report. The parties certify that their Rule 26 disclosures have been made at the time of the preparation of this Report. DATED: DATED: ,: V W TRAIAN BUJDUVEANU, PRO SE DAVID S. CHAIET, ESQUIRE Pro Se Plaintiff Attorneys for Defendants 5601 W. Broward Blvd. Eisinger, Brown, Lewis, Frankel Plantation, FL 33317 & Chaiet, P.A. (954)316-3828 4000 Hollywood Boulevard orionav(S),msn.com Suite 265-South Holly (954) dchaiettoetsingftfiavy.com TRAIAN BUJDUVEANU, PRO SE DAVID 57CHAIET, ESQUIRE Fla. Bar No. 963798
  • 9. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 9 of 22 CASE NO.: 11-20120-CIV-SEITZ/SIMONTON CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 19th day of May, 2011, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are authorized to receive electronically Notices of Electronic Filing. Isi David S. Chaiet DAVID S. CHAIET, ESQUIRE Florida Bar No. 963798
  • 10. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 10 of 22 CASE NO.: 11-20120-CIV-SEITZ/SIMONTON SERVICE LIST Traian Bujduveanu v. Dismas Charities, Inc., et al. Case No..: 11-20120-CIV-SEITZ/SIMONTON United States District Court, Southern District of Florida Traian Bujduveanu Pro Se Plaintiff 5601 W. Broward Blvd. Plantation, FL 33317 Tel: (954) 316-3828 Email: orionav@msn.com 10
  • 11. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 11 of 22 Case 1:11-cv-20120-PAS Document 11 Entered on FLSD Docket 02/03/2011 Page 5 of 7 Case Management Deadline Worksheet ft tJ.AU.5-V 5 .2QII Joinder of parties and amendment of pleadings.S/»0+Anh^3a2£JI wiied ^ tr.a| furnish opposing counsel with awritten list containing the names and addresses of ail fact witnessesno prejudice beOCPVaXMC JU^i Parties shall ^ Qn)y ^ w.messes ljsted shaU ^ permjtted tQ testjfy ^^ good cause IS shown ^ ^g 1S intended to to opposing party. The parties are under acontinuing obligation to supplement discovery responses within ten (10) days ofreceipt or other notice of new or revised information. UUUVUC^i-^mi AMe ^^ w.inesses sha||witness listto the testjfy wjthin ^ fourteen day perjod thereat, Piaint.ff shall make .tsand only /VtfthA-31 20ll Plaintiffmust furnish expert be permiued tQ Defendant, alongwith the summaries/reports required by Local Rule 16 l.K, experts available for deposition by Defendant. W(USZaflfr_M>A*ii ^ ^^ w^cnes ^ ^witness list to the Plaintiffalong^with the summaries/reports required by Local shall 16. l.K.itsand only l)tfr/*W if20li Defendantmust furnish expert ^.^ ^ ^.^ wjthin ^^ dfly perjod Pearler, Defendan, Rule make experts available for deposition by Plaintiff. X)ce.embcr llo,ZULi A" discovery must be completed. Tw^l,- [u 2QJI All dispositive pretrial motions and memoranda oflaw must be filed. Aminimum of fifteen (15) weeks is required for the Court VCLCOOOec JJA, fc*J. ^^ dispositive motions prior to filing ofthe joint pretrial stipulation. If no dispositive motions will be filed, clearly note this fact in the Joint Scheduling Report. A04jQLS±J& ^1 Mediation must be completed. (The parties should select the earliest date to maximize resolution of the case in amanner that promotes client and judicial economy.) Jan ii/im 1U 20l2 (a) Joint pretrial stipulation must be filed pursuantto Local Rule 16.1 ,E. The pretrial stipulation shall include Plaintiffs non-b.nding ^^ breakdown ofdamages with corresponding amounts; the witness lists shall be pared down to those witnesses the parties actually intend to call at trial; and the exhibit lists shall identify the witness introducing each exhibit. The parties shall meet at least one (1) month prior to the deadline for filing the pretrial stipulation to confer on the preparation ofthat stipulation. The Court will not accept unilateral pretrial stipulations, and will strike, sua sponte, any such submissions; and (b) Joint proposed jury instructions (for jury cases) or conclusions of law (non-jury cases) outlining (1) the legal elements of Plaintiffs claims, including damages, and (2) the legal elements of the defenses raised; and (c) Joint Summary ofRespective Motions in Limine must be filed. The Summary shall contain acover page providing the style ofthe case and an index ofthe motions in limine. The Summary shall also include for each evidentiary issue: (0 aone (1) page motion identifying the evidence sought to be precluded at trial and citing legal authority supporting exclusion; and (//) aone (I) page response to the motion providing astatement ofthe purpose for which the challenged evidence would be offered and citing legal authority in support ofadmission ofthe challenged evidence. The parties shall work together to prepare the Summary. Prior to submission ofthe Summary, the parties are encouraged to resolve evidentiary issues through stipulation. tiALIAUL li 2MI Final proposed jury instructions or findings of fact and conclusions of law must be submitted. (A courtesy copy shall be hand- JU -u-") "+ delivered l0 Chambers on 3.5 diskette, WordPerfectformat), each partys list indicating each witness who will testify at trial, aone sentence synopsis of the testimony, and in consultation with opposing counsel, indicate the amount oftime needed for direct and cross examination. finrl ,iHil Pretrial conference. Usually 50 minutes are allotted for pretrial conference unless the parties or the Court, sua sponte. indicate a greater time is needed. <WL^ >MZ Trial Date. llnk/UulA Date ofany other deadline the parties adopt as part oftheir case management plan, including Daubert or Markman hearing. In cases the parties anticipate aMarkman hearing, counsel must provide dates for the exchange ofproposed disputed claim terms, and due dates for Plaintiffs brief and Defendants brief. [Attachment A]
  • 12. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 12 of 22 Case 1:11 -cv-20120-PAS Document 11 Entered on FLSD Docket 02/03/2011 Page 6 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 11-20120-CIV-SEITZ/OSULLIVANTRAIAN BUJDUVEANU, Plaintiff,v.ANA GINSPERT and DISMASCHARITIES, INC., Defendant. ELECTION TO JURISDICTION BY AUNITED STATES MAniRTB ATF JUDGE FOR FINAL DISPOSITION OF MOTIONS In accordance with the provisions of28 U.S.C. 636(c), the undersigned parties to the above-captioned civilmatter herebyjointly and voluntarily elect to have aUnited States Magistrate Judge decide the following motions and issue a final order orjudgment with respect thereto: Yes No * 1. Motions for Costs 2. Motions for Attorneys Fees Yes No 3. Motions for Sanctions Yes No 4. Motions to Dismiss Yes No 5. Motions for Summary Judgment Yes No 6. Other (specify) (Date) (Signature-Plaintiffs Counsel) (Date) (Signatuir>*hrhTtTTfs Cdunsel) <A>^ °v* (Date) (Signature-Defendants Counsel) (Date) (Signature-Defendants Counsel) [Attachment B]
  • 13. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 13 of 22 Case 1:11-cv-20120-PAS Document 11 Entered on FLSD Docket 02/03/2011 Page 7 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 11-20120-CIV-SEITZ/OSULLIVANTRAIANBUJDUVEANU, Plaintiff,v.ANA GINSPERT and DISMASCHARITIES, INC., Defendant. ELECTION TO JURISDICTION BY A tttmitfxi STATES MAGISTRATE JUDGE FOR TRIAL Inaccordance withthe provisionsof28 U.S.C. 636(c),the undersignedpartiesto the above-captioned civil matter herebyjointly and voluntarily elect to have aUnited States Magistrate Judge conduct any and all further proceedings in the case, including TRIAL, and entry offinal judgment with respect thereto. (5^) (Signature-Plaintiffs Counsel) (5^) (Signature-Plaintiffs Counsel) (Date) (Signature-Defendants t> (5^) (Signature-Defendants Counsel) iVs^- <*^*^ [Attachment C]
  • 14. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 14 of 22 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA CASE NO.: 11-20120-CIV-SEITZ/SIMONTON TRAIAN BUJDUVEANU, Plaintiff, vs. DISMAS CHARITIES, INC., ANA GISPERT, DEREK THOMAS and ADAMS LESHOTA Defendants. DEFENDANTS DISMAS CHARTIES, INC., ANA GISPERT, DEREK THOMAS AND ADAMS LESHOTAS DISCOVERY SCHEDULE Defendants Dismas Charities, Inc., Ana Gispert, Derek Thomas and Adams Lashanda, incorrectly identified as Adams Leshota (collectively "Defendants") pursuant to the Federal Rules of Civil Procedure and the Southern District of Florida Local Rules, hereby file their discovery schedule as follows: Written Discovery: Defendant Dismas propounded initial interrogatories and requests for production upon the Plaintiff on April 28, 2011. Additional written discovery may be needed following the Courts ruling on Defendants motion to dismiss. Defendants hope to complete written discovery on or before September 15, 2011, which will include requests for production, requests for admissions and interrogatories.
  • 15. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 15 of 22 11-20120-CIV-SEITZ/SIMONTON Depositions: Defendants intend to set the Plaintiff for depositions sometime in August 2011. Defendants anticipate defending the depositions of Dismas, Gispert,Thomas and Lashanda. Defendants may need to depose representatives of the United States Marshalls Service and Federal Bureau of Prisons, along with the Plaintiffs wife and son. These depositions will likely be set in September or October 2011. Expert Discovery: At this time expert discovery is not anticipated unless the Plaintiff presents a claim for physical or mental injury. If so, then Defendants will need to retain an expert in the appropriate medical specialty. Respectfully submitted, EISINGER, BROWN, LEWIS, FRANKEL, & CHAIET, PA. Attorneys for Defendants 4000 Hollywood Boulevard Suite 265-South Hollywood, FL 33021 (954) 894-8000 (954) 894-8015 Fax BY: /S/ David S. Chaiet DAVID S. CHAIET, ESQUIRE FBN: 963798
  • 16. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 16 of 22 11-20120-CIV-SEITZ/SIMONTON CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 19th day of May, 2011, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are authorized to receive electronically Notices of Electronic Filing. Isi David S. Chaiet DAVID S. CHAIET, ESQUIRE Florida Bar No. 963798
  • 17. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 17 of 22 11-20120-CIV-SEITZ/SIMONTON SERVICE LIST Traian Bujduveanu v. Dismas Charities, Inc., et al. Case No..: 11-20120-CIV-SEITZ/SIMONTON United States District Court, Southern District of Florida Traian Bujduveanu Pro Se Plaintiff 5601 W. Broward Blvd. Plantation, FL 33317 Tel: (954) 316-3828 Email: orionav(a),msn.com
  • 18. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 18 of 22 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA CASE NO.: 11-20120-CIV-SEITZ/SIMONTON TRAIAN BUJDUVEANU, Plaintiff, vs. DISMAS CHARITIES, INC., ANA GISPERT, DEREK THOMAS and ADAMS LESHOTA Defendants. DEFENDANTS DISMAS CHARTIES, INC., ANA GISPERT, DEREK THOMAS AND ADAMS LESHOTAS DISCLOSURES PURSUANT TO RULE 26 OF THE FEDERAL RULES OF CIVIL PROCEDURE AND CERTIFICATE OF INTERESTED PERSONS Defendants Dismas Charities, Inc., Ana Gispert, Derek Thomas and Adams Lashanda, incorrectly identified as Adams Leshota (collectively "Defendants") pursuant to the Federal Rules of Civil Procedure and the Southern District of Florida Local Rules, hereby makes their initial disclosures: Traian Bujduveanu 5601 W. Broward Blvd. Plantation, FL 33317 PWMK at Dismas Charities, Inc. 141 N.W. 1st Avenue Dania Beach, FL 33004
  • 19. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 19 of 22 11-20120-CIV-SEITZ/SIMONTON Ana Gispert Dismas Charities, Inc. 141 N.W. 1stAvenue Dania Beach, FL 33004 Derek Thomas Dismas Charities, Inc. 141 N.W. 1st Avenue Dania Beach, FL 33004 Adams Lashanda Dismas Charities, Inc. 141 N.W. 1st Avenue Dania Beach, FL 33004 PWMK at the United States Marshalls Service Federal Courthouse Square 400 N. Miami Avenue, 6th Floor Miami, FL 33128 PWMK Federal Bureau of Prisons-Miami Detention Center 33 Northeast 4th Street Miami, Florida 33101-9118 Wife and Children of Traian Bujduveanu 5601 W. Broward Blvd. Plantation, FL 33317
  • 20. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 20 of 22 11-20120-CIV-SEITZ/SIMONTON 1. Defendants hereby discloses the following documents which may support their defenses as follows: 1. Dismas file on Mr. Bujduveanu. 2. United States Marshalls file on Mr. Bujduveanu. 3. United States Federal Bureau of Prison file on Mr. Bujduveanu. 4. Manuals and handbooks of Dismas for residents and other released inmates. 2. No other disclosures are required to be made by the Defendants pursuant to Rule 26 at this time. Respectfully submitted, EISINGER, BROWN, LEWIS, FRANKEL, & CHAIET, PA. Attorneys for Defendants 4000 Hollywood Boulevard Suite 265-South Hollywood, FL 33021 (954) 894-8000 (954) 894-8015 Fax BY: /S/ David S. Chaiet DAVID S. CHAIET, ESQUIRE FBN: 963798
  • 21. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 21 of 22 11-20120-CIV-SEITZ/SIMONTON CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 19th day of May, 2011, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are authorized to receive electronically Notices of Electronic Filing. Isl David S. Chaiet DAVID S. CHAIET, ESQUIRE Florida Bar No. 963798
  • 22. Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 22 of 22 11-20120-CIV-SEITZ/SIMONTON SERVICE LIST Traian Bujduveanu v. Dismas Charities, Inc., et al. Case No..: 11-20120-CIV-SEITZ/SIMONTON United States District Court, Southern District of Florida Traian Bujduveanu Pro Se Plaintiff 5601 W. Broward Blvd. Plantation, FL 33317 Tel: (954) 316-3828 Email: orionav@msn.com

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