The government responded to the defendant's motion for an extension of time to file expert witness disclosures and renewed motion for extension. The government does not oppose the requested extensions. It recommends that the defendant be granted until February 16, 2009 to file expert witness disclosures and until March 2, 2009 to file any motion to dismiss the indictment.

1. Case 1:08-cr-20612-PAS Document 143 Entered on FLSD Docket 01/26/2009 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-20612-CR-SEITZ
Magistrate Judge John J. O’Suliivan
UNITED STATES OF AMERICA
vs.
TRAIAN BUJDUVEANU,
Defendant.
________________________________/
GOVERNMENT’S RESPONSE TO DEFENDANT
TRAIAN BUJDUVEANU’S MOTION FOR EXTENSION OF TIME
TO FILE EXPERT WITNESS DISCLOSURES
AND RENEWED MOTION FOR EXTENSION OF TIME
TO FILE EXPERT WITNESS DISCLOSURES
The United States of America, through undersigned counsel, files this Response to Defendant
Bujduveanu’s Motion for Extension of Time to File Expert Witness Disclosures, filed December 19,
2008 (D.E. 134), and Renewed Motion for Extension of Time to File Expert Witness Disclosures,
filed January 20, 2009 (D.E. 140), and states:
Defendant Bujduveanu requests an additional 30 days from the date of the Government's
Disclosure of Expert Witnesses within which to disclose the Defendant's Expert Witness
information, as well as an extension of the deadline for filing any motions to dismiss the Indictment.
The United States has no objection to the requested extensions, and, therefore, the United States
does not oppose the Defendant's Motions.
Accordingly, based on Defendant's Requests, the Government respectfully recommends that
this Court grant Defendant's Motions to the extent that the Defendant would have up to February 16,
2009, (30 days from the filing of the United States' Supplemental Notice of Expert Witnesses (D.E.

2. Case 1:08-cr-20612-PAS Document 143 Entered on FLSD Docket 01/26/2009 Page 2 of 3
139)), within which to file Expert Witness Disclosures, and up to March 2, 2009, to file any Motion
to Dismiss.
Respectfully submitted,
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
By: /S/ Melissa Damian
MELISSA DAMIAN
ASSISTANT UNITED STATES ATTORNEY
Fla. Bar No. 0068063
99 N.E. 4th Street, Suite 600
Miami, Florida 33132
Telephone: (305) 961-9018
Facsimile: (305) 536-4675
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3. Case 1:08-cr-20612-PAS Document 143 Entered on FLSD Docket 01/26/2009 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on January 26, 2009, I electronically filed the foregoing with the Clerk
of the Court by using the CM/ECF system which will send a notice of electronic filing to Michael
Cohen, counsel for Defendant Traian Bujduveanu.
Melissa Damian
Assistant United States Attorney
/S/ Melissa Damian
Melissa Damian
Assistant United States Attorney
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