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UNOPPOSED MOTION TO DISCLOSE NAMES OF EXPERT WITNESSES AND SUPPORTING OPINIONS

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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

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Case 1:08-cr-20612-PAS Document 125 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 TO DISCLOSE NAMES OF EXPERT WITNESSES

AND SUPPORTING OPINIONS

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

undersigned counsel who respectfully requests that this Honorable Court enter an order

compelling the government to disclose the name of its expert witnesses and opinions and

bases therefore, required by Rule 16 of the Federal Rules of Criminal Procedure as well

as Rule 701, 702, and 701 et seq. of the Federal Rules of Evidence. As grounds therefore,

your undersigned would state the following:

1. In its initial discovery disclosure the government indicated that certain

experts will be called to testify that a number of parts allegedly sold by the defendant

were on the prohibited export lists delineated by the Department of State and the

Department of Commerce.

2. To date the government has not disclosed either names of the experts, their

opinions, or their bases therefore.

Case 1:08-cr-20612-PAS Document 125 Entered on FLSD Docket 12/03/2008 Page 2 of 2

3. The government has an obligation to disclose the names of these witnesses

and their underlying opinions and reports if any, in order to go forward with this case.

See United States v. Holland, 223 Fed Appendix 891, 2007 Westlaw 1229042 (11th Cir.

2007) See also United States v. White, 492 F. 3rd 380 (6th Circuit 2007).

4. Undersigned counsel is unable to proceed with the retention of his experts

concerning their opinions on this matter until he receives the government disclosures.

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

Damian, who has no objection to this motion, and who anticipates this disclosure can be made

by on or before December 17th, 2008.

WHEREFORE, based on the foregoing, undersigned counsel respectfully

requests this said motion be GRANTED.

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