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GOVERNMENT’S RESPONSE TO DEFENDANT TRAIAN BUJDUVEANU’S EMERGENCY MOTION FOR FURLOUGH

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GOVERNMENT’S RESPONSE TO DEFENDANT TRAIAN BUJDUVEANU’S EMERGENCY MOTION FOR FURLOUGH Powered By Docstoc
					Case 1:08-cr-20612-PAS        Document 107        Entered on FLSD Docket 11/03/2008            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 EMERGENCY MOTION FOR FURLOUGH

           The United States of America, through undersigned counsel, files this Response to Defendant

    Bujduveanu’s Emergency Motion for Furlough, filed October 30, 2008 (D.E.105). For the reasons

    that follow, this Court should deny the defendant's Motion.

           Defendant Bujduveanu, who is presently being held at the Federal Detention Center in

    pretrial detention, has filed an Emergency Motion seeking permission from the Court for a brief

    furlough to visit his ailing mother.

           Authority to grant furloughs to federal inmates is solely within the jurisdiction of the

    Director of the United States Bureau of Prisons. 18 U.S.C. § 3622. The United States Courts are,

    therefore, not the appropriate venue for such a request. The defendant should direct his request to

    the United States Bureau of Prisons.
Case 1:08-cr-20612-PAS     Document 107        Entered on FLSD Docket 11/03/2008          Page 2 of 3



                                            Conclusion

          For the foregoing reasons, the United States respectfully requests that this Court deny

    Defendant Bujduveanu’s Emergency Motion for Furlough.


                                              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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Case 1:08-cr-20612-PAS        Document 107          Entered on FLSD Docket 11/03/2008             Page 3 of 3



                                     CERTIFICATE OF SERVICE

            I hereby certify that on November 3, 2008, 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 Mark
    Eiglarsh, counsel for Defendant Traian Bujduveanu.



                                                          Melissa Damian
                                                          Assistant United States Attorney


                                                          S/ Melissa Damian
                                                          Melissa Damian
                                                          Assistant United States Attorney




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DOCUMENT INFO
Description: Jeff Bush, Department of Justice, ICE Agent Sammy Cruzcoriano, Jeffrey H. Sloman, Acting United States Attorney for the Southern District of Florida, David Kris, Assistant Attorney General for National Security, Michael Johnson, Special Agent in Charge, U.S. Department of Commerce, Office of Export Enforcement, Anthony V. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office of Investigations, and Amie R. Tanchak, Resident Agent in Charge, U.S. Department of Defense, Government Conspiracy,Defense Criminal Investigative Service, R. Alexander Acosta, United States Attorney for the Southern District of Florida, Michael Johnson, Special Agent in Charge, U.S. Department of Commerce, Office of Export Enforcement, Anthony V. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office of Investigations, and Christopher Amato, Special Agent in Charge of the Pentagon's Defense Criminal Investigative Service, Southeast Field Office, Revolution in Romania,R. Alexander Acosta, U.S. Attorney for the Southern District of Florida; David Kris, Assistant Attorney General for National Security; Michael Johnson, Special Agentin Charge, U.S. Department of Commerce, Office of Export Enforcement; Anthony V. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office of Investigations; and Amie R. Tanchak, Resident Agent in Charge, U.S. Department of Defense, Defense Criminal Investigative Service, Judge Patrick A. White, Judge Patricia A. Seitz, Judge John M. O’Sullivan, Attorney Mark Eiglarsh, Attorney Michael Cohen,C.I.A.,Defende Intelligence Agency,National Intelligence Agency,Department of State,Department of Navy,Interpol,F.B.I., National Security Agency, FBI Special Agent in Charge, Michael Johnson,Traian Bujduveanu,Revolution in Iran,Attorney Robert G. Amsel