The government filed a motion requesting a two-week extension to respond to the defendant's motion for return of property. Several items seized from the defendant's home during a 2008 search warrant were identified in the defendant's motion. The government is working to obtain affidavits from law enforcement agents regarding the status and location of the items. Due to the recent identification and location of some items, the government requires additional time to compile the necessary documentation for its response. The motion requests extending the response deadline from April 23rd to May 7th to allow time for completion of the affidavits and paperwork.

1. Case 1:08-cr-20612-PAS Document 261 Entered on FLSD Docket 04/21/2010 Page 1 of 4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-20612-CR-SEITZ
UNITED STATES OF AMERICA
vs.
TRAIAN BUJDUVEANU,
Defendant.
________________________________/
GOVERNMENT’S MOTION FOR EXTENSION OF TIME
TO FILE RESPONSE TO DEFENDANT’S MOTION FOR RETURN OF PROPERTY
COMES NOW, the United States of America, by and through the undersigned Assistant
United States Attorney, and respectfully moves this Court for an extension of time to file a
Response to Defendant’s Motion for Return of Property, filed April 6, 2010 (DE:259), and states
as follows:
On April 6, 2010, Defendant Traian Bujduveanu filed a Motion for Return of Property.
Although Defendant Bujduveanu raises numerous matters in said Motion, the relief sought therein
is a request for the return of certain property seized from Defendant Bujduveanu’s residence during
execution of a search warrant at the residence in June 2008. Specifically, Defendant appears to seek
the return of the Defendant’s wife’s computers, cash found in his residence, a black leather
briefcase, two laptop cases, and two computer memory sticks. The Government has worked
diligently to locate each of the items noted in the Defendant’s Motion. The Government notes that
there is a substantial amount of evidence in this case which is spread among multiple law
enforcement agency storage facilities. To date, the majority of the items have been identified and

2. Case 1:08-cr-20612-PAS Document 261 Entered on FLSD Docket 04/21/2010 Page 2 of 4
located.
In light of recent law in this Circuit (see, e.g. U.S. v. Juan Carlos Palacios Gonzalez, Case
No. 09-14538 (11th Cir. April 15, 2010)), the Government is required to submit affidavits in support
of its response regarding the property at issue. At this time, the Government is working to obtain
affidavits and supporting documentation from the appropriate law enforcement agents and evidence
custodians regarding the property at issue. However, given that some of the property has only been
identified or located as recently as this week, the Government has not yet had the opportunity to
obtain all of the necessary documentation.
Therefore, the Government is now seeking an extension of time in which to respond to
Defendant’s Motion to give the Government sufficient time to complete the necessary collection and
compilation of information, affidavits, and documentation. Undersigned counsel for the United
States believes that we will have all of the necessary paperwork within approximately two weeks.
This Court issued an Order, dated April 7, 2010, requiring a Response to Defendant’s Motion be
filed by April 23, 2010 (DE:260). The United States is therefore seeking a two-week extension of
time from April 23, 2010, to respond to the Defendant’s Motion for Return of Property.
The requested extension of time is not for the purpose of delay, but rather to ensure a proper,
accurate, and complete Response on behalf of the United States.
Due to the fact that Defendant is in custody, undersigned counsel was unable to contact
Defendant to determine whether he would agree to the requested extension.

3. Case 1:08-cr-20612-PAS Document 261 Entered on FLSD Docket 04/21/2010 Page 3 of 4
WHEREFORE, the United States respectfully requests that this Court grant its Motion for a
two-week extension of time, and order that its Response in the above-captioned case be due on May
7, 2010.
Respectfully submitted,
JEFFREY H. SLOMAN
UNITED STATES ATTORNEY
By: /S/
Melissa Damian
Assistant United States Attorney
Florida Bar No. 0068063
99 Northeast 4th Street
Miami, Florida 33132-2111
Tel: (305) 961-9018
Fax: (305) 536-4675

4. Case 1:08-cr-20612-PAS Document 261 Entered on FLSD Docket 04/21/2010 Page 4 of 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on April 21, 2010, 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 via U.S. Mail to Traian Bujduveanu, pro se, Reg # 80655-004,Federal Correctional
Complex-Coleman, Low, P.O. Box 1031, Coleman, FL 33521.
Melissa Damian
Assistant United States Attorney