The government responds to the defendant's motions for early termination of supervised release, relief for medical treatment, and relief to lift a self-employment restriction. The government objects to early termination and lifting the restriction but does not object to medical treatment. It argues early termination is not warranted given the defendant's history of non-compliance. It also argues the proposed new business in petroleum import/export could present problems due to the defendant's past conduct involving Iran and such businesses. The government concludes the motions for early termination and lifting the restriction should be denied but the motion for medical treatment should be granted with appropriate documentation and travel information provided to probation.

1. Case 1:08-cr-20612-PAS Document 290 Entered on FLSD Docket 05/29/2012 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-20612-CR-SEITZ
UNITED STATES OF AMERICA
vs.
TRAIAN BUJDUVEANU,
Defendant.
________________________________/
GOVERNMENT’S RESPONSE TO DEFENDANT’S MOTIONS
COMES NOW the United States of America, by and through the undersigned Assistant
United States Attorney, and responds to Defendant’s Motion for Early Termination of Supervised
Release, Relief for Medical Treatment, and Relief to Lift Self Employment Restriction (DE 288).
The United States objects to the Early Termination of Supervised Release and Lifting of the Self-
Employment restriction, however, does not object to the defendant receiving appropriate medical
treatment.
Early Termination of Supervised Release
Defendant is seeking to have his supervised release terminated on the basis of the need for
the medical treatment. However, supervised release can be continued even with the necessary travel
for medical treatment. The defendant has completed less than half of his three years. Moreover,
prior to supervised release, when defendant was placed in a half-way house near the end of his
imprisonment, he was unable to comply with the restrictions and was returned to FDC (violations
fully described in DE 26 and 103 of S. Dist. Fla., case number 11-20120-Civ-SEITZ). Thus, this
defendant should not receive the benefit of early termination.

2. Case 1:08-cr-20612-PAS Document 290 Entered on FLSD Docket 05/29/2012 Page 2 of 3
Relief to Seek Medical Treatment Outside the United States
The Government has no objection to medical treatment as long as defendant can provide
sufficient information to his Probation Officer about where and when he is traveling to receive the
treatment.
Relief to Lift Self-Employment Restriction
This court has previously dealt with the issue of defendant’s self-employment. In an Order
dated August 22, 2011 (DE 283), this court explained how the defendant should properly resolve
the issue of any potential employment by discussing it with his Probation Officer. This procedure
should remain in place.
According to Florida Corporate records, defendant has already incorporated a new business,
PELAGUS INTERNATIONAL TRADING, LLC (8/1/2011).
The intended business field of petroleum import and export does present a potential problem
in that the conduct underlying his conviction involved Iran, who like many countries are involved
in the petroleum business. Embargoed countries, such as Iran, have an active petroleum and drilling
business and actively seeks to obtain replacement and new related equipment. As shown in the
underlying criminal conduct, the defendant has business contacts in Iran. Thus, this field lends itself
to a high chance future violations.
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3. Case 1:08-cr-20612-PAS Document 290 Entered on FLSD Docket 05/29/2012 Page 3 of 3
Conclusion
Accordingly, the motions for early termination and lifting of the self-employment restriction
should be denied. The motion for medical treatment should be granted as long as defendant provides
to his Probation Officer appropriate documentation about the treatment and his travel to receive the
treatment.
Respectfully submitted,
WIFREDO A. FERRER
UNITED STATES ATTORNEY
By: s/ Karen E. Gilbert
KAREN E. GILBERT
ASSISTANT U.S. ATTORNEY
FL BAR # 771007
99 N.E. 4th Street
Miami, Florida 33132
(305) 961-9161
Fax: (305) 536-4675
Karen.gilbert@usdoj.gov
CERTIFICATE OF SERVICE
I hereby certify that on May 29, 2012, I electronically filed the foregoing document with
the Clerk of the Court using CM/ECF.
s/ Karen E. Gilbert
Karen E. Gilbert
Assistant United States Attorney
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