UNOPPOSED MOTION TO DISCLOSE NAMES OF EXPERT WITNESSES AND SUPPORTING OPINIONS by cocoselul

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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

								
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