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									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
                                                                           MIAMI DIVISION

                                                                         CASE NO: 08-20612-CR




                        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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Case 1:08-cr-20612-PAS Document 292 Entered on FLSD Docket 08/29/2012 Page 2 of 3

        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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Case 1:08-cr-20612-PAS Document 292 Entered on FLSD Docket 08/29/2012 Page 3 of 3

             as he has indicated that he is very sick and needs adequate treatment outside the

             United States.

             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.

                                             Respectfully submitted,

                                             /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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