UNOPPOSED MOTION FOR MEDICAL TREATMENT

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					Case 1:08-cr-20612-PAS       Document 126        Entered on FLSD Docket 12/03/2008             Page 1 of 2



                               UNITED STATES DISTRICT COURT
                               SOUTHERN DISTRICT OF FLORIDA

                            Case No: 08-20612-CR-SEITZ/O’SULLIVAN




       UNITED STATES OF AMERICA )
                                    )
             Plaintiff,             )
       vs.                          )
                                    )
       TRAIAN BUJDUVEANU            )
                                    )
             Defendant.             )
       ____________________________ )

                      UNOPPOSED MOTION FOR MEDICAL TREATMENT

              COMES NOW, the defendant, TRAIAN BUJDUVEANU, by and through

       undersigned counsel respectfully requests this Honorable Court convene a hearing and

       conduct an inquiry about the necessity of the defendant’s receipt of certain medications

       that he is not presently receiving at the Federal Detention Center in Miami. As grounds

       therefore, your undersigned would state the following:

              1.      Traian Bujduveanu suffers from Hepatitis C, sclerosis of the liver, diabetes

       and ascytes.

              2.      Mr. Bujduveanu is in urgent need of certain medications to treat these

       conditions which can become life threatening.

              3.      These medications include pegasys, interferon, and ribovirin.

              4.      Undersigned Counsel has been informed by Mr. Bujduveanu that he is not

       receiving these medications at the Federal Detention Center.
Case 1:08-cr-20612-PAS       Document 126         Entered on FLSD Docket 12/03/2008             Page 2 of 2



              5.      Your Undersigned therefore, respectfully moves for this court to convene

       a hearing to inquire into the failure of the Federal Detention Center to properly treat Mr.

       Bujduveanu for his conditions.

              6.      Your Undersigned has spoken to Assistant United States Attorney, Melissa

       Damian, who has no objection to this motion.

              WHEREFORE, based on the foregoing, Undersigned Counsel requests leave of

       court to file this motion out of time since he was recently retained by the defendant.




                                                             Respectfully submitted,

                                                             s/ *Michael B. Cohen, Esq.*
                                                             _________________________
                                                             Michael B. Cohen, Esq.
                                                             Florida Bar No: 210196



                                    CERTIFICATE OF SERVICE

              IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing was
       furnished via CMECF this December _____, 2008 to all applicable parties.



                                                             Respectfully submitted,

                                                             s/ *Michael B. Cohen, Esq.*
                                                             _________________________
                                                             Michael B. Cohen, Esq.
                                                             Florida Bar No: 210196
                                                             6400 North Andrews Ave Ste 460
                                                             Fort Lauderdale, Florida 33309
                                                             Ph (954) 928-0059
                                                             Fax(954)928-0829

				
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