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					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 Court's

   "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.


              PLAINTIFF'S 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
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")
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
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
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.
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.
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.
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
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
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
    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.
OCPVaXMC JU^i Parties shall ^ Qn)y ^ w.messes ljsted shaU ^ permjtted tQ testjfy ^^ good cause IS shown ^ ^g 1S intended to to
S/»0+Anh^3a2£JI wiied ^ tr.a| furnish opposing counsel with awritten list containing the names and addresses of ail fact witnessesno prejudice be
                         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.

   /VtfthA-31 20ll Plaintiffmust furnish expert be permiued tQ Defendant, alongwith the summaries/reports required by Local Rule 16 l.K, experts
   UUUVUC^i-^mi AMe ^^ w.inesses sha||witness listto the testjfy wjthin ^ fourteen day perjod thereat, Piaint.ff shall make .tsand only
                         available for deposition by Defendant.

   l)tfr/*W if\20li Defendantmust furnish expert ^.^ ^ ^.^ wjthin ^^ dfly perjod Pearler, Defendan, Rule make experts
   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
                          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 party's 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 Defendant's brief.




                                                                        [Attachment A]
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/O'SULLIVAN

TRAIAN BUJDUVEANU,

                  Plaintiff,
v.



ANA GINSPERT and DISMAS
CHARITIES, 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 civil
matter 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 Attorney's 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-Defendant's Counsel)


         (Date)                       (Signature-Defendant's Counsel)

                                                      [Attachment B]
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/O'SULLIVAN

TRAIANBUJDUVEANU,

              Plaintiff,

v.



ANA GINSPERT and DISMAS
CHARITIES, 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-Defendant's
                                                                      t>
         (5^)                           (Signature-Defendant's Counsel) iVs^-
                                                                                   \<*^*^




                                                [Attachment C]
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 LESHOTA'S 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 Court's

   ruling on Defendant's 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.
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 Marshall's 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
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
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
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 LESHOTA'S 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
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
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 Marshall's 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
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
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

				
DOCUMENT INFO
Description: United States Courthouse,Southern District Of Florida,Traian Bujduveanu v. Dismas Charities,Ana Gispert,Derek Thomas,Lashanda Adams,Mental and Physical Torture at Dismas Charities,Abuse at Dismas Charities,Civil Rights Violations at Dismas Charities,Illegal Search And Seizure at Dismas Charities,Discrimination and Reverse Discrimination at Dismas House,Abuse at Dismas Charities 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 LASHANDA Defendants. _________________________________________/ PLAINTIFF TRAIAN BUJDUVEANU’S SECOND SET OF INTERROGATORIES TO DEFENDANTS ANA GISPERT, DEREK THOMAS AND LASHANDA ADAMS � � Plaintiffs, Traian Bujduveanu, Pro Se, pursuant to the Federal Rules of Civil Procedure, propound the CM/ECF - Live Database - flsd 09/09/2011 18:13 AMS, MEDIATION, REF_DISCOV U.S. District Court Southern District of Florida (Miami) CIVIL DOCKET FOR CASE #: 1:11-cv-20120-PAS Bujduveanu v. Ginspert et al Assigned to: Judge Patricia A. Seitz Referred to: Magistrate Judge Andrea M. Simonton Cause: 28:1346 Tort Claim Plaintiff Traian Bujduveanu represented by Traian Bujduveanu 5601 W Broward Blvd. Plantation, FL 33317 954-316-3828 PRO SE Date Filed: 01/12/2011 Jury Demand: Plaintiff Nature of Sui CM/ECF - Live Database - flsd 13/09/2011 14:31 AMS, MEDIATION, REF_DISCOV U.S. District Court Southern District of Florida (Miami) CIVIL DOCKET FOR CASE #: 1:11-cv-20120-PAS Bujduveanu v. Ginspert et al Assigned to: Judge Patricia A. Seitz Referred to: Magistrate Judge Andrea M. Simonton Cause: 28:1346 Tort Claim Plaintiff Traian Bujduveanu represented by Traian Bujduveanu 5601 W Broward Blvd. Plantation, FL 33317 954-316-3828 PRO SE Date Filed: 01/12/2011 Jury Demand: Plaintiff Nature of Suit CM/ECF - Live Database - flsd 16/09/2011 17:07 AMS, MEDIATION, REF_DISCOV U.S. District Court Southern District