Case 1:08-cr-20612-PAS Document 292 Entered on FLSD Docket 08/29/2012 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AMERICA
CASE NO: 08-20612-CR
SECOND MOTION FOR RELIEF TO TRAVEL TO SEEK MEDICAL TREATMENT
OUTSIDE THE UNITED STATES
COMES NOW, Defendant, Traian Bujduveanu (hereinafter referred to as
“TRAIAN”), by and through his undersigned counsel, respectfully requests that this Honorable
Court grant a Motion for Relief to Seek Medical Treatment outside the United States. As ground
therefore, TRAIAN would state as follows:
1. TRAIAN has an extensive medical record suffering from a number of medical issues
including but not limited to Hepatatis C, Liver Cirrhosis, and Diabetes. Due to the
combination of all his medical issues, TRAIAN has been in and out of medical visits
prior to, during and post his release of the Federal Bureau of Prisons.
2. All records are available to the Court if required to be produced including those
conducted while TRAIAN was in Bureau of Prisons and those conducted subsequent
at Nova Southeastern University medical campus. Included within these reports are
indications that TRAIAN has had extensive fatigue in the last five months and a loss
of appetite. TRAIAN has suffered from extreme weight loss during this same time
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3. Subsequent to his visit at Nova Southeastern University, TRAIAN has found a new
medical treatment consisting of stem cell. This new medication is being conducted in
Kiev, Ukraine. TRAIAN is seeking this Honorable Court’s relief to seek medical
treatment outside the United States for this fact.
4. Stem cell treatments are not currently being conducted in the United States. They
have not been approved by the FDA and as such, treatment such as the one sought by
TRAIAN are not provided in the United States. TRAIAN has been in
communications with the EmCell clinic in Kiev, Ukraine and they have been open to
conducting medical treatments on TRAIAN.
5. The EmCell clinic is registered with the United States but cannot conduct its medical
treatments inside the country due to the regulations with the FDA which have been
under review for some time.
6. Denying TRAIAN the opportunity to seek medical treatment of his choice is
tantamount to restricting his ability to live.
7. TRAIAN has already commenced treating with the Emcell clinic in Kiev, Ukraine
and is currently needing travel for the date of September 18, 2012 to Romania where
he has been placed by the Director of the Hepatology Department of Fundeni
Hospital, in Bucharest, by Prof. Conf. Florin Caruntu, in a clinical trial.
8. Defense Counsel has not spoken with AUSA Karen Gilbert in regards to this Motion
but a prior motion regarding the same issue was not objected and the Government
stated that so long as TRAIAN traveled for Medical Treatment purposes they would
not object so long as an itinerary was provided to probation.
9. Defense Counsel has spoken with Probation Officer Ms. Bonita Holmes on August
29, 2012 and Probation does NOT object for TRAIAN to travel for medical purposes
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as he has indicated that he is very sick and needs adequate treatment outside the
WHEREFORE, TRAIAN seeks that this Honorable Court grant the Defense’s
Motion for Relief to Travel to Seek Medical Treatment outside the United States if this
Honorable Court deems that such is necessary and just.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was electronically
noticed through the CM/ECF system to AUSA Karen Gilbert at the US Attorney’s Office on this
29th day of August, 2012.
/s/ Nayib Hassan
Nayib Hassan, Esq., Fla Bar No. 20949
Attorney for Defendant
LAW OFFICES OF NAYIB HASSAN, P.A.
6175 NW 153 St., Suite 221
Miami Lakes, Florida 33014
Tel. No.: 305.403.7323
Fax No.: 305.403.1522
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