1) The defendants filed a brief in response to the plaintiff's motion to compel production of documents. 2) The defendants agreed to produce documents but want inspection to occur at their attorney's office rather than at the defendant organization's office, due to the plaintiff's legal restrictions being near felons. 3) The defendants request that the plaintiff's motion be denied since they agreed to produce documents according to the rules by making them available at their attorney's office.

1. Case 1:11-cv-20120-PAS Document 57 Entered on FLSD Docket 09/09/2011 Page 1 of 4
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 LESHOTA’S BRIEF IN RESPONSE TO PLAINTIFF’S MOTION TO COMPEL
RESPONSES TO REQUEST FOR PRODUCTION
Defendants Dismas Charities, Inc., Ana Gispert, Derek Thomas and Lashanda Adams,
incorrectly identified as Adams Leshota (collectively “Defendants”) by and through their
undersigned counsel and file their Brief in Response to Plaintiff Traian Bujduveanu’s
(“Plaintiff”) Motion to Compel Responses to Request for Production and states as follows:
1. Plaintiff has filed a Motion to Compel Responses to Requests for Production
against the Defendants. (Docket number 53). As the Defendants have agreed to produce the
requested documents at their counsel’s office as they are kept in the course of business, the
Defendants have complied with Federal Rule of Civil Procedure 34 (2)(E). The rule states:
(E) Producing the Documents or Electronically Stored Information. Unless otherwise
stipulated or ordered by the court, these procedures apply to producing documents or
electronically stored information:
(i) A party must produce documents as they are kept in the usual course of
business or must organize and label them to correspond to the categories in the
request;

2. Case 1:11-cv-20120-PAS Document 57 Entered on FLSD Docket 09/09/2011 Page 2 of 4
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
2. The document inspection cannot occur at Dismas’ offices because as a condition
of the Plaintiff’s supervised release from prison, he is not allowed contact or to be around
convicted felons. As convicted felons live at Dismas, the Plaintiff should not return to Dismas.
Further, since Dismas is represented by counsel and does not want direct contact with the
Plaintiff on their premises, the inspection of documents should occur at Dismas’ counsel’s office,
which is actually closer to the Plaintiff’s home than Dismas’ offices. Lastly, Dismas is willing to
produce the documents upon payment of copying costs by the Plaintiff.
3. Accordingly, Plaintiff’s Motion must be denied as Defendants have timely and
properly responded to the Request for Production by stating that the inspection of documents will
be permitted at Defendants’ counsel’s office.
WHEREFORE, Defendants Dismas Charities, Inc., Ana Gispert, Derek Thomas and
Adams Lashanda, incorrectly identified as Adams Leshota respectfully request that Plaintiff’s
Motion be denied and that the Court grant any further relief it deems appropriate.
EISINGER, BROWN, LEWIS, FRANKEL,
& CHAIET, P.A.
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
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3. Case 1:11-cv-20120-PAS Document 57 Entered on FLSD Docket 09/09/2011 Page 3 of 4
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 9th day of September, 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.
__/s/ David S. Chaiet_______________
DAVID S. CHAIET, ESQUIRE
Florida Bar No. 963798
3

4. Case 1:11-cv-20120-PAS Document 57 Entered on FLSD Docket 09/09/2011 Page 4 of 4
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
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