Motion to compel second request for production of documents,first and second set of interrogatories

IN THE UNITED STATES DISTRICT COURT FOR

THE SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1 I-ZOIZO-CIV-SEITZ/SIM ONTON

TRAIAN BUJDUVEAN U,Plaintiff,

VS.

DISM AS CHARITIE :S INC., ANA GISPERT,

DEREK THOM AS and ADAM S LASHANDA

Defendants.

FILED by -. D.C.

y y. jo j y yj y y j

STEVEN K t LARIMOREc L -E :R K L3

.s' ' nlsl .- cT.s. o. o f FLA. - MIAMI

M OTION TO COMPEL SECOND REOUEST FOR PRODUCTION OFDOCUM ENTS. FIRST AND SECOND SET OF INTERROGATORIES

Pursuant to Federal Rule of Civil Procedure 26.1 .H.2, the Plaintiff respectfully

requests the Court to enter its Order compelling the Defendants to respond properly

and m eaningfully to the Plaintiff's Second Request For Production Of Documents,and First Set and Second Set of Interrogatories to the Defendants, and in support

thereof would respectfully show unto the Court as follows:

1. BACKGROUND

l . On August 24s 201 1, the M ovant served its First lnterrogatories upon the

Defendants by US Post Office delivery to Counsel for Defendants, and a copy to each

of Defendans, of which is attached as Exhibit ''A'' for the Court's convenience.

2. On August 30, 201 1, The M ovant served its Second Set Of lnterrogatories to theDefendants and Second Request For Production Of Documents, of which is attached

as Exhibit t1B'' for the Court's convenience.

3. On September 9,201 l M ovant received responses from Defendants, a copy of

which is attached as Exibit éEC'' for the Court's convenience.

4. The Parties' efforts to reconcile their differing positions in this case have been

unavailing, and the Plaintiff now seeks appropriate relief 9om the Court. (Exhibit D )

5. Discovery is a stage of the proceedings entirely separate and apal't from trial. Theidea is to encourage full disclosure of a1l relevant facts and circumstances. Rules have

been shaped to assure that each party knows all of the relevant facts and

circumstances so that it can be fully presented to the trial judge.

Case 1:11-cv-20120-PAS Document 58 Entered on FLSD Docket 09/16/2011 Page 1 of 76

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6. The Defendants' positions with respect to discovery in this case are contrary to the

the spirit of the Federal Rule of Civil Procedure 26.1 . By failing reasonably to

respond to M ovant's requests, the Defendants attempt to frustrate M ovant's efforts to

prepare for trial and have caused the M ovant to expend valuable time preparing its

M otion to Compel and seeking altemate modes of proof with respect to the matters

embraced by M ovant's discovery.

7. By its Request For Production Of Documents and lnterrogatories, the M ovant seeks

to discovery the Defendants' ,among other things: direct and indirect contacts with

executive, legislative and other public officials and employees of the Federal

Govermnent regarding, the issues raised by the claim s in this case; the protection

Defendants have relied upon for many years, not to be investigated by the State and/orFederal Government; Defendants personal contact with employees of the State and

Federal Govem ment; the legal documents issued by legal authorities in this case; the

abuse and discrimination practiced by the defendants', prior lawsuits againstDefendants for discrimination and similar illegal acts; receiving money for favors,

from the residents by Defendants and Dismas Charities employees; evidence of

communications between Plaintiff and Defendants; widespread corruption; names ofa11 Dismas Charities employees who have participated or were witness to theincidents', and other action regarding the issues raised by the claims or defenses in this

lawsuit.

8. The Defendants' responses, attached as Composite Exhibit ''C,'' uniformly objectedto the above Interrogatories and variously stated, in essence, that the matters sought to

be discovered by the Plaintiff were overbroad and confusing, not reasonably

calculated to lead to the discovely of admissible evidence, intended for harassment,personal and confidential information. The Defendants' responses were in other

particulars vague and evasive, and improperly limited pursuant to alleged claims that

Plaintiff s requests were intended for harassment.

9. Logic dictates and Fed. R. Civ. P. 26. 1 . provides that the M ovant is entitled todiscovery pertaining to the full range of unprivileged matters relevant to the issues

presented in the complaint and in the defenses asserted by the Defendants. By their

Objections, the Defendants are attempting improperly to evade proper discovery andto redefine the M ovant's claims and to unduly restrict discovery in this case, contrary

to law.

10. The M ovantts Interrogatories are appropriate and reasonably calculated to lead to

the discovery of admissible evidence which pertains to conduct of the Defendants

which is relevant to the issues raised in the litigation. Any claims by the Defendantsthat such information might be intended for harassment should fall on deaf ears and

they should be compelled to provide answers which are responsive to the Plaintiff s

requests.

1 1 . By their responses in Composite Exhibit ''C,'' the Defendants have failed to

comply with the Federal Rule of Civil Procedure 26.1 and the Orders of this Coul't

with respect to discovely in this case.

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12. ln an attempt to mislead the M ovant and this Court, Defendents made thefollowing statement in one of their responses: çû-l-he premises have surveillance

cameras. The cameras are monitored by staff. The tapes from the time of the alleged

occun-ences do not exist''

1 3. The video surveillance equipment at Dismas Charities, in Dania, Florida, do no

use any tapes. lnstead data collected from the surveillance cameras is stored on acomputer hard drive in a digital format which acts as a Digital Video Recorder. The

Operating System as well as Remote Viewing software enables the user to monitor

the security system via computer, over the internet.

14. Data has been erased from the computer hard drive due to the fact that itrepresented damaging evidence against Dismas Charities. Federal Bureau Of Prisons

Regulations requires that a11 data be archived and kept for 30 years.

l5. Data containing a11 communications between the M ovant and Defendants, which

would otherwise reveal facts and bring light into this case, is also not available. BOP

require that a11 data be archived and kept for 30 years.

15. ln al1 requests for production of documents and lnterrogatories the Defendantshave managed to send copies of four documents only, one of them being Conditions

Of Home Confmement, which does not mention any telephone violation of any kind,

and three other highly dubious documents, which are under investigation by the

M ovant. Two of these documents are attached as an Exhibit CEE'' for the Court's

Convenience.

16. ln a conversation with CCM Director, Mr. Carlos Rodriguez on September 12,

201 1, 9:30 Am, he stated that he is çtnot aware of existence of this document, that

CCM M iami never charged the M ovant with any violation, thus an investigation was

never carried out by the BOP, and a report for violation does not exist since there was

no charge.'' This Coul't will have to ask the Defendants how they have managed toobtain this dubious document and from whom, as this represents a criminal act.

17. Carlos Rodriguez, Director CCM M iami, representing B.O.P., did not personally

participate in the specific contents, creation or implementation of this document. ln

contrary to Defendants response, no BOP charges or reports against M ovant exists.

(çEThe matter was investigates by Dismas Charities, lnc., the united States MarshallsService and the Federal Bureau Of Prisons. Any reports if any, are in possession of

the respective entity.''. . ..)

H. LEGAL STANDARD

The federal discovely rules are liberal in order to assist in the preparation for trial

and settlement of litigated disputes. See Bond v. Utreras, 585 F.3d 1061, 1075 (7thCir. 2009),. see also Kodish v. Oakbrook Terrace Fire Prot. Dist., 235 F.R.D. 447, 450(N.D. 111. 2006) (tçthe scope of discovery should be broad in order to aid in the searchfor truth'l.

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'' Pre-trial discovery typically is ''accorded a broad and liberal treatment. . . . Thisbroad right of discovery is based on the general principle that litigants have a right to

every man's evidence and that wide access to relevant facts serves the integrity and

fairness of the judicial process by promoting the search for the truth.''tllShoenv

.Shoen,5F.3dl289,1292(9 Cir. l993)(interna1 quotations and citationsomitted).

A contention interrogatory allows a plaintiff to learn the factual bases of the opposing

party's defense, see Prat't v. Tam 464 F.3d 730, 733 (7th Cir. 2006), and is notobjectionable if it asks for an opinion that relates to a fact or the application of a 1awto fact. See Fed.R.CiV.P. 33(a)(2).

çt-l-here is no iron curtain drawn between the Constitution and the prisons of this

country.'' Wolff v. M cDonnell, 41 8 U.S. 539, 555-56 (1974).

The public has an interest in knowing who is intluencing or attempting to influence

their public oftkers, for what purpose, the means adopted to that purpose, and the

results achieved. (citations omitted). f iberty L obby, Inc., 390 F.2d at 492.

111. CONCLUSION

Defendants failed to respond to M ovant's written Discovery requests. Pursuant to

Rule 37, Defendants should be compelled to respond without any objection.

M ovant cannot make a case unless Defendants participate in the discovery process,and he is not in a position where he can indulge Defendants' use of tEstall tactics'' in

order to gain time. Time for Discovery is too short.

M ovant was never charged with any violation, by any legal authority.

W HEREFORE, premises considered, the M ovant respectfully requests the Coul't to

enter an Order compelling the Defendants to respond properly and meaningfully to

the Plaintiff's Second Request For Production Of Documents, and First Set and

Second Set of Interrogatories to the Defendants, and for such other and further relief

to which the Plaintiffjustly may be entitled.

Date: September l4, 201 1

Res ectfully submitted, ?!!

/z'/ ///Z A/ZCTJ/Z/

TRAIAN BUJDUVEANU, PRO SE

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CERTIFICATE OF SERVICE

l hereby certify that on or about SEPTEM BER 14, 201 1 a tnle and correct copy of the

foregoing document was served upon the following via the United States Postal

Service, First Class M ail:

Dismas Charities, Inc.,

14 1 N.W . 1 St. Avenue

Dania, FL 33004-2835

Ana GispertDismas Charities,lnc.

l41 N.W . 1 St. Avenue

Dania, FL 33004-2835

Derek ThomasDismas Charities,lnc.

l41 N.W . 1 St. Avenue

Dania, FL 33004-2835

Lashanda Adams

Dismas Charities,lnc.

l41 N.W . l St. AvenueDania ,FL 33004-2835

David S. Chaiet,Esquire

Attorney for Defendants

4000 Hollywood Boulevard

Suite 265-South

Hollywood,FL 33021

EXECUTED ON THIS 14th DAY OF SEPTEM BER, 20l 1

> . /

TRAIAN BUJDU E U, PRO SE

5601 W . BROW ARD BLVD.,

PLANTATION, FL 33317


EXHIBIT A




CASE NO.: l I-ZOIZO-CIV-SEITZ/SIM ONTON

TRAIAN BUJDUVEANU,

Plaintiff,

VS.

DISM AS CHARITIE IS lNC., ANA GISPERT,

DEREK THOM AS and ADAM S LASHANDA

Defendants.

PLAINTIFF TRM AN BUJDUVEANU'S FIRST SET OF

JNTERROGATORIES TO DEFENDANTS ANA GISPERT. DEREK THOMASAND LASHANDA ADAM S

Plaintiffs, Traian Bujduveanu, Pro Se, pursuant to the Federal Rules of CivilProcedure, propound the following lnterrogatories to be answered under oath byDefendants, Dismas Charities,lnc., Ana Gispert, Derek Thomas and Lashanda Adam s

,

within thirty (30) days of service hereof.

INSTRUCTIONS

1. These lnterrogatories are continuing in character so as to require you to tilesupplementary answers if you obtain further or different information before trial.

2. Pursuant to , you are under a duty seasonably to amend any answer to theseinterrogatories for which you learn that the answer is in some material respect

incomplete or incorrect and if the additional or corrective information has nototherwise been made known to us during the discovery process or in writing.

3. For any interrogatory or part of an interrogatory which you refuse to answer under

a claim of privilege, submit a sworn or certified statement from your cotmsel or one

of your employees in which you identify the nature of the information witllheld;specify the grounds of the claimed privilege and the paragraph of these interrogatories

to which the information is responsive; and identify each person to whom theinformation, or any part thereof

, has been disclosed.

4. Answer each interrogatory f'ully. If you object to any interrogatory, state thereasons for objection and answer to the extent the interrogatory is not objectionable. Ifyou are unable to answer an interrogatory fully, submit as much information as is


available, explain why your answer is incomplete, and identify or describe a11 other

sources of more complete or accurate information.

5. For any record or document responsive or relating to these interrogatories which

is known to have been destroyed or lost, or is otherwise unavailable, identify each

such document by author, addressee, date, number of pages, and subject matter', andexplain in detail the events leading to the destruction or loss, or the reason for the

unavailability of such document.

6. No agreement, understanding, or stipulation by the Department of Justice or any

of its representatives purporting to modify, limit, or otherwise vary these

interrogatories shall be valid or binding on the Department of Justice unless

confirmed or acknowledged in writing (or made of record in open court) by a dulyauthorized representative thereof.

7. Unless otherwise stated, these Interrogatories refer to the time, place, and

circumstances of the occurrence mentioned or complained of in the Complaint.

8. W here name and identity of a person is required, please state full name, home

address and also business address, if known.

9. W here knowledge or information in possession of a party is requested, suchrequest includes knowledge of the party's agents, representatives, and unless

privileged, his attorneys, and includes knowledge obtained from other persons or

sources, even if such

knowledge would be hearsay under applicable law, and even if the person receiving

such information did not believe it, failed to confinn its validity, disregarded it, or had

other knowledge that cast doubt on the information.

l 0. ln the event that any document requested by these interrogatories or to which

you refer in your answers to these Interrogatories is withheld on the basis of a claim

of privilege, set forth for each document withheld:

(a) A description of the factual and legal basis for the claim of plivilege or objectionin sufticient detail so as to permit the court to determine the validity of the claim or

objection;

(b) A general description of the document including its size, length, form and subjectm atter',

(c) The name and address of the personts) or entity involved in the creation of thedocument',

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(d) The date on which the document was created;

(e) The names and addresses of a1l persons who have had access to the documentfrom the time of its creation to the present;

(9 The date on which the document was created; and

(g) The name and address of the present custodian of the document, and the namesand addresses of all persons who have received copies, summaries, or explanations of

the document.

l l . ln the event that any document to which you refer in your answers to these

Interrogatories has been destroyed or discharged, or has otherwise left your

possession, custody and control, set forth:

(a) A general description of the document including its size, length, form and subjectl'natter-

(9 The date, manner, and reasonts) for destruction or discard', and

(g) The names and addresses of persons authorizing and carrying out the destructionor discard of the document.

12. These interrogatories are addressed to all Defendants in this case.

DEFINITIONS

l . The word ''documents'' is used in these lnterrogatories in the broad and liberal

sense and means written, typed, printed, recorded or graphic matter, however stored,

produced or reproduced, of any kind and description and whether an original, master,

duplicate or copy, including, but not limited to, papers, notes, accounts, books,

advertisements, letters, memoranda, notes of conversations, contracts, agreements,drawings, telegrams, electronic mail, tape recordings, communications, including

inter-office and intra-oftke memoranda, reports, studies, worldng papers, corporaterecords, minutes of meetings, notebooks, bank deposit slips, bank checks, cancelled

checks, diaries, diary entries, appointment books, desk calendars, photographs,

transcriptions or sotmd recordings of any type of personal or telephone conversationsor negotiations, meetings or conferences or things similar to any of the foregoing, and

to include any data, information or statistics contained within any data storage

modules, tapes, discs, diskettes, or other memory device, or other information

retrievable from any storage systems, including, but not limited to, computer-


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generated reports and printouts. The word ''document'' also includes data compilationsfrom which information can be obtained and translated, if necessary, by the

respondent through detection devices in a reasonably usable form. lf any document

has been modified by the addition of notations or otherwise, or has been prepared in

multiple copies which are not identical, each modified copy or unidentical copy is a

separate ''document.''

2. Defendants means Dismas Charities,inc., Ana Gispert, Derek Thomas, LashandaAdam s.

3. The term tr ismas Charities'' means Dismas Charities,lnc.,the corporation

operating 28 halfway houses, in 18 states, with the headquarter in Louisville,

Kentucky, and the business operated at 141 N.W . 1 St. Avenue, Dania, Florida 33304-

2835 (in whatever business form, including corporation, close corporation,partnership, limited partnership, unincorporated association, proprietorship, S

comoration, limited liability company, or any other form), including any real propertyowned, leased or otherwise occupied at that location, personal property of any kind at

that location, and any other rights commonly attributed to the business known as

dçDismas Charities,lnc,,'' including by way of example and not limitation, tradenames, liquor licenses, copyright and trademark rights.

3. As used herein, the term ''communications'' shall mean sign language, any oral or

written utterance, notation, or statement of any nattzre whatsoever, by and to

whomsoever made, including, but not limited to, correspondence, conversations,

dialogues, discussions, interviews, consultations, agreements and other

understandings between or among two or more persons.

4. As used herein, the term ''or'' appearing in any lnterrogatory should not be read soas to eliminate any part of the lnterrogatory, but, whenever applicable, it shall have

the same meaning as the term ''and.'' For example, an lnterrogatory stating ''support or

refer'' shall be read as ''support and refer'' if an Answer that does both can be made.

5. ''Complaint'' means the complaint tiled in the above referenced action.

6. ''You '' '' our'' or ''your company'' refers to Defendants Dismas Charities,lnc., Ana, y

Gispert, Derek Thomas and Lashanda Adams, the party to whom the lnterrogatories

are addressed', in both their individual capacity, and its successors, assigns,employees, agents, attorney, and a1l other persons pum oting to act on their behalf.

4. The phrase ''describe in detail'' as used in these interrogatories includes a request

for a complete description and explanation of the facts, circumstances, analysis,

opinion and other information relating to the subject matter of a specitk interrogatory.

5. ''ldentify'' when referring to an individual, corporation, or other

entity shall m ean to set fol'th the name and telephone number, and if a corporation or

other entity, its principle place of business, or if an individual, the present or last


known home address, his or herjob title or titles, by whom employed and address ofthe place of employment.

6. ''ldentify'' or ''identity'' means to state or a statement of:

a. in the case of a person other than a natural person, its name, the address of its

principal place of business (including zipcode), its telephone number, and the name ofits chief executive oftker, as well as, if it has a person other than a natural person that

ultimately controls it, that other person's name, the address of that person's principal

place of business (including zipcode), that other person's telephone number, and thename of that other person's chief executive oftk er;

b. in the case of a namral person, his or her name, business address and telephonenumber, employer, and title or position;

c. in the case of a communication, its date, type (e.g., telephone conversation ordiscussion), the place where it occurred, the identity of the person who made thecommunication, the identity of the person who received the communication, the

identity of each other person when it was made, and the subject matter discussed;

d. in the case of a document, the title of the document, the author, the title or position

of the author, the addressee, each recipient, the type of document, the subject matter,the date of preparation, and its number of pages; and

e. in the case of an agreement, its date, the place where it occurred, the identity of allpersons who were parties to the agreement, the identity of each person who has

knowledge of the agreement and al1 other persons present when it was made, and the

subject matter of the agreement.

''Including'' means including, but not limited to.

8. ''Person'' means any natural person, corporation, company, partnership,jointventure, firm, association, proprietorship, agency, board, authority, commission,

office or other business or legal entity, whether private or governmental.

9. ''Relating to'' means containing, constimting, considering, comprising,

concerning, discussing, regarding, describing, reflecting, studying, commenting orreporting on, mentioning, analyzing, or referring, alluding, or pertaining to, in wholeor in pal't.


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INTERROGATORIES

l . State your full name, home address (and a11 addresses for the last ten (10) years,social security number, date of birth, marital status and your employer's name and

address. lnclude in your answer who lived with you in the last ten (10) year period.

2. State if you ever been convicted of a crime. If so, state as to each conviction the

specific crime and the date and place of conviction.

3. State if you ever been a party, either plaintiff or defendant, in a lawsuit other thanthe present matter, and if so, State whether you were plaintiff or defendant, the namre

of the action, and the date and court in which suit was filled.

4. ldentify each employee, agent and/or servant or any other person with personal

knowledge of the facts pertaining to the occurrence,and indicate those who were eye

witnesses, and state the substance of their knowledge and articulate their expected

testimony. For each such individual, identify his or herjob title andjob functionbeing performed by that individual at the time of these incidents, and the surnmary of

what knowledge the witness has,and articulate their expected testimony.

5. If anyone investigated this matter for you including, but not limited to, medical

experts, private investigators or insurance adjusters, state their namets) andaddresstes), and state whether such investigation was reduced to writing, and thesubstance of their investigation and findings. If said investigators obtained any

signed, recorded, transcribed or oral statement from any individual, identify theperson who gave the statement and the present custodian of such statement.

6. ldentify each person interviewed concerning these incidents. For each such person

state the date of the interview; the substance of the interview and if the interview was

recorded and/or transcribed.


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7. ldentify a1l persons to whom you have given signed statements regarding those

incidents, the date thereof, and the name of the person in whose custody each is at thistime.

8. Identify each and every written report made by any person concerning theincidents.

9. State whether or not the Premises were equipped with a video surveillance cameraand, if so, whose responsibility it was on the dates of the occurrence to monitor the

surveillance camera and whether there are still tapes from the dates of the occurances

and the week both before and after the occurance.

10. lf you know of the existence of any pictures, photographs, plats, visual recorded

images, police reports, diagrams or objects relative to the occurrence, the Plaintiff'sphysical condition or the scene of the occurrence, identify the substance of such

recording and the present custodian of each such item .

t l . State whether you consumed any drugs, medicines, or alcoholic beverages within

twenty-four (24) hours prior to said occurrence, the place where such drugs,medicines, or alcoholic beverages were obtained

, the nattlre of the drtlgs, medicines,or alcoholic beverages, and the amount thereof.

l2. Do you believe that you did everything that you could to prevent these

incidents. Set forth everything that you did to avoid these incidents that occurred. Isthere anything you wish you had done differently'?.

l3. Identify any procedures which you followed, at and before the time of the

occurrence, concerning Plaintiff's medical needs and issues.


l4. Identify all Dismas Charities employees that were aware of the fact that Traian

Bujduveanu was taken by ambulance to Broward Hospital, and that he spent most ofthe night ,beforet the arrest and removal,in the emergency room at Broward Hospital,

due to pain and discomfort of liver and abdomen ?

15. Identify al1 Dismas Charities employees that were aware of the fact that ALL

driving documents of Traian Bujduveanu, including DMV Driving Record, Copy ofvalid Florida Driving License, copy of valid insurance issued by Allstate lnsurance

Co., and even a personal letter from the director of DM V in Tallahassee, Florida,were in his file for some times, at Dismas Charities Halfway House ?

l6. State whether or not the Premises were equipped with a video surveillance camera

and, if so, whose responsibility it was on the dates of the occurrence to monitor the

surveillance camera and whether there are still tapes from the dates of the occurances

and the week both before and after the occurance and if you have photographs, film s,

motion pictures or videotapes or other picmres relevant to the issues in this case

showing the scene of this occurrence at the time of or after its happening, showing

basically how it was then or now, or of the Plaintiff at any time after this occurrence,

or the materials involved in this occurrence? If so, state the date of each, the person

taking the photographs and describe the content of each.

l7. State the name, address and occupation of each person whom you propose to call

as an expert witness, including in your answer the subject matter on which each suchexpert is expected to testify, the substance of the findings and opinions to which such

expert is expected to testify, and a summary of the grounds for each opinion of each

such expert. Attach copies of the resmne or curriculum vitae of each such person, as

well as copies of a1l written reports made by any proposed expert. Identify allcommunications, written or oral, you have had with these individuals.

l 8. ldentify a11 documents that you intend to introduce into evidence at trial,including documents the expert or experts that you intend to have testify on your


behalf at trial have reviewed and/or relied upon in forming their opinions, or are

otherwise relevant to this case. lnclude in your answer whether you have photographs,films, motion pictures or videotapes or other pictures relevant to the issues in this casc

showing the scene of this occurrence at the time of or after its happening, showing

basically how it was then or now, or of the Plaintiff at any time after this occurrence,

or the materials involved in this occurrence? State the date of each, the person taking

the photographs and describe the content of each.

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1, TRAIAN BUJDUVEANU,Ce/A that l have this 24st day of August,zol 1 served atrue and correct copy of the foregoing PLAINTIFF TRM AN BUJDUVEANU'S

FIRST SET OF INTERROGATORIES TO DEFENDANTS DISM AS

CHARITIESJNC.,ANA GISPERXDEREK THOMAS AND LASHANDAADAM S, Upon Defendants, by causing to be deposited with the United States Postal

Services, First Class M ail, proper postage affixed thereto, addressed as follows:

Dismas Charities,lnc.14 l N .W . l St. Avenue

Dania, FL 33004-2835

Ana Gispert

Dismas Charities,lnc.141 N .W . 1 St. Avenue

Dania, FL 33004-2835

Derek Thomas


14 l N .W . l St. AvenueDania, FL 33004-2835

Lashanda Adams


l41 N.W . 1 St. AvenueDania ,FL 33004-2835


Attorney for Defendants

4000 Hollywood BoulevardSuite 265-South

Hollywood,Flw 33021

EXECUTED ON THIS 24th DA OF AUGUST, 20) l. 6

/ /# > zeTRAIAN B JDUVEANU, PRO SE



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$

EXH IBIT B


IN THE UNITED STATES DISTRICT COURT FORTHE SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1 1-20120-ClV-SElTZ/S1M ONTON

TRAIAN BUJDUVEANU,

Plaintiff,

DISM AS CHARITIES lNC., ANA GISPERT,

DEREK THOMAS anJ ADAMS LASHANDA

Defendants.

PLAINTIFF TRM AN BUJDUVEANU'S SECOND SET OF

INTKRROGATORIES TO DEFENDANTS ANA GISPERT.DEREK THOMASAND LASHANDA ADAM S

Plaintiffs, Traian Bujduveanu, Pro Se, pursuant to the Federal Rules of CivilProcedure, propound the following Interrogatories to be answered under oath by

Defendants, Dismas Charities,lnc., Ana Gispert Derek Thomas and Lashanda Adams,

within thio (30) days of service hereof.

INSTRUCTIONS

1. These lnterrogatories are continuing in character so as to require you to file

supplementary answers if you obtain further or different information before trial.

2. Pursuant to , you are under a duty seasonably to amend any answer to theseinterrogatories for which you learn that the answer is in some material respect

incomplete or incorrect and if the additional or corrective information has not

othelw ise been made known to us during the discovery process or in writing.

3. For any interrogatory or part of an interrogatory which you refuse to answer under

a claim of privilege, submit a sworn or certified statement from your cotmsel or one

of your employees in which you identify the nature of the information withheld;specify the grounds of the claimed privilege and the paragraph of these interrogatories

to which the information is responsive; and identify each person to whom the

information, or any part thereof, has been disclosed.

4. Answer each interrogatory fully. lf you object to any interrogatory, state thereasons for objection and answer to the extent the interrogatory is not objectionable. lfyou are unable to answer an interrogatory fully, subm it as much information as is


available, explain why your answer is incomplete, and identify or describe a11 other

sources of more complete or accurate information.

5. For any record or document responsive or relating to these interrogatories whichis known to have been destroyed or lost

, or is otherwise unavailable, identify eachsuch document by author, addressee, date

, number of pages, and subject matter; andexplain in detail the events leading to the destruction or loss

, or the reason for theunavailability of such docum ent.

6. No agreement, understanding, or stipulation by the Department of Justice or anyof its representatives purporting to modify

, limit, or othcrwise vary theseinterrogatories shall be valid or binding on the Department of Justice unless

confirmed or acknowledged in writing (or made of record in open court) by a dulyauthorized representative thereof.

7, Unless othem ise stated, these Interrogatories refer to the time, place, and

circumstances of the occurrence mentioned or complained of in the Complaint.

8. W here name and identity of a person is required, please state full name, home

address and also business address, if known.

9. W here knowledge or information in possession of a party is requested, such

request includes knowledge of the party's agents, representatives, and unless

privileged, his attomeys, and includes knowledge obtained from other persons or

sources, even if such

knowledge would be hearsay under applicable law, and even if the person receiving

such information did not believe it, failed to confilnn its validity, disregarded it, or had

other knowledge that cast doubt on the information.

10. ln the event that any document requested by these interrogatolies or to which

you refer in your answers to these lnterrogatories is withheld on the basis of a claim

of privilege, set forth for each document withheld:

(a) A description of the factual and legal basis for the claim of privilege or objectionin sufficient detail so as to permit the court to determine the validity of the claim or

objection',

(b) A general description of the document including its size, length, form and subjectm atter;

(c) The name and address of the personts) or entity involved in the creation of thedocument;

2


(d) The date on which the document was created;

(e) The names and addresses of all persons who have had access to the documentfrom the time of its creation to the present;

(9 The date on which the document was created; and

(g) The name and address of the present custodian of the document, and the namesand addresses of a11 persons who have received copies, summaries, or explanations ofthe document.

l l . In the event that any document to which you refer in your answers to these

lnterrogatories has been destroyed or discharged, or has othem ise left your

possession, custody and control, set forth:

(a) A general description of the document including its size, length. form and subjectm atter;

(9 The date, manner, and reasonts) for destruction or discard; and

(g) The names and addresses of persons authorizing and carrying out the destructionor biscard of the document.

These interrogatories are addressed to all Defendants in this case.

DEFINITIONS

1 . The word ''documents'' is used in these lnterrogatories in the broad and liberal

sense and means written, typed, printed, recorded or graphic matter, however stored,produced or reproduced, of any kind and description and whether an original, master,duplicate or copy, including, but not limited to, papers, notes, accounts, books,advertisements, letters, memoranda, notes of conversations

, contracts, agreem ents,drawings, telegrams, electronic mail, tape recordings, communications

, includinginter-office and intra-office memoranda, reports

, studies, working papers, cop oraterecords, minutes of meetings, notebooks, bank deposit slips

, bank checks, cancelledchecks, diaries, diary entries, appointment books, desk calendars, photographs,

transcriptions or sound recordings of any type of personal or telephone conversations

or negotiations, meetings or conferences or things similar to any of the foregoing, andto include any data, information or statistics contained within any data storage

modules, tapes, discs, diskettes, or other memory device, or other information

retrievable from any storage systems, including, but not limited to, computer-


generated reports and printouts. The word ''document'' also includes data compilationsfrom which information can be obtained and translated

, if necessary, by the

respondent through detection devices in a reasonably usable fonn. If any documenthas been modified by the addition of notations or otherwise, or has been prepared in

multiple copies which are not identical, each modified copy or unidentical copy is a

separate ''document.''

2. Defendants means Dismas Charitiessinc., Ana Gispert, Derek Thomas, Lashanda

Adams.

3. The tcrm çtDismas Charities'' means Dismas Charities,lnc.,the corporation

operating 28 halfway houses, in 18 states, with the headquarter in Louisville,

Kentucky, and the business operated at 141 N.W . 1 St. Avenue, Dania, Florida 33304-

2835 (in whatever business form, including corporation, close corporation,partnership, limited partnership, unincop orated association, proprietorship

, S

corporation, limited liability company, or any other form), including any real propertyowned, leased or othem ise occupied at that location, personal property of any kind at

that location, and any other rights commonly attributed to the business known as

ttDismas Charities,lnc,,'' including by way of example and not limitation, trade

names, liquor licenses, copyright and trademark rights.

3. As used herein, the term ''communications'' shall mean sign language, any oral or

written utterance, notation, or statement of any nature whatsoever, by and to

whomsoever made, including, but not limited to, correspondence, conversations,

dialogues, discussions, interviews, consultations, agreements and otherunderstandings between or among two or more persons.

4. As used herein, the term ''or'' appearing in any lnterrogatory should not be read soas to eliminate any part of the Interrogatory

, but, whenever applicable, it shall havethe same meaning as the term ''and.'' For example, an Interrogatory stating ''support orrefer'' shall be read as ''support and refer'' if an Answer that does both can be made.

5. ''Complaint'' means the complaint filed in the above referenced action.

6. ''You '' '' our'' or ''your company'' refers to Defendants Dismas Charities,lnc., Ana, y

Gispert, Derek Thomas and Lashanda Adams, the party to whom the Interrogatories

are addressed; in both their individual capacity, and its successors, assigns,employees, agents, attorney, and a11 other persons purpoting to act on their behalf.

4. The phrase ''describe in detail'' as used in these interrogatories includes a request

for a complete description and explanation of the facts, circumstances, analysis,

opinion and other infonnation relating to the subject matter of a specitk interrogatory.

5. ''ldentify'' when refening to an individual, corporation, or other

entity shall mean to set forth the name and telephone number, and if a corporation orother entity, its principle place of business

, or if an individual, the present or last


known home address, his or herjob title or titles, by whom employed and address ofthe place of employment.

6. ''ldentify'' or ''identity'' means to state or a statement of:

a. in the case of a person other than a natural person, its name, the address of its

principal place of business (including zipcode), its telephone number, and the name ofits chief executive officer, as well as, if it has a person other than a natural person that

ultimately controls it, that other person's name, the address of that person's principal

place of business (including zipcode), that other person's telephone number, and thename of that other person's chief executive officer;

b. in the case of a natural person, his or her name, business address and telephone

number, employer, and title or position;

c. in the case of a communication, its date, type (e.M., telephone conversation ordiscussion), the place where it occurred, the identity of the person who made thecommunication, the identity of the person who received the communication, the

identity of each other person when it was made, and the subject matter discussed;

d. in the case of a docum ent, the title of the document, the author, the title or position

of the author, the addressee, each recipient, the type of document, the subject matter,the date of preparation, and its number of pages; and

e. in the case of an agreement, its date, the place where it occurred, the identity of a11

persons who were parties to the agreement, the identity of each person who has

knowledge of the agreement and all other persons present when it was made, and the

subject matter of the agreement.

''lncluding'' means including, but not limited to.

8. ''Person'' means any natural person, corporation, company, partnership, jointvenmre, firm, association, proprietorship, agency, board, authority, commission,office or other business or legal entity, whether private or governmental.

9. ''Relating to'' means containing, constituting, considering, comprising,

concerning, discussing, regarding, describing, reflecting, studying, commenting orreporting on, mentioning, analyzing, or referring, alluding, or pertaining to, in whole

or in part.


INTERROGATORIES

1. Describe in details why Plaintiff, W hile at Dismas House, was never allowed to

attend religious services on Sundays, at any of the two Orthodox churches, located 16

minutes away from Dismas Charities House. (GPS Time Distance). Also explain whyhe was not allowed to attend religious services even when he was on Home

Confinement.

2. Describe in details why Defendants never issued any receipts to the Plaintiff's, for

Confiscated Personal Property, that should be signed by Dismas Charities House staff,and receipts for the lnmate Property Rettlrfl, that should bc signed by Dismas

Charities House staff and Plaintiff.

3. Describe in details the limitations of Dismas Charities disciplinary discretions andthe limitations of sanctions they can apply on residents. Provide details of any serioussanctions required approvals, as required under the contract with the government.

Date: August 30, 201 l

X . .

/ /# 7 zz KzKs-'uzv

TRAIAN BUJDUVEANU, PRO SE



1, TRAIAN BUJDUVEANU,CeIXW that I have this 30 day of August,zol 1 served atrue and correct copy of the foregoing PLAINTIFF TRAIAN BUJDUVEANU'S

SECOND SET OF INTERROGATORIES TO DEFENDANTS DISM ASCHARITIES,INC.,ANA GISPERT,DEREK THOM AS AND LASHANDA

ADAM S, Upon Defendants, by causing to be deposited with the United States Postal

Services, First Class M ail, proper postage affixed thereto, addressed as follows:


l4l N.W . l St. AvenueDania, FL 33004-2835

Ana Gispert


14 1 N.W . l St. Avenue

Dania, FL 33004-2835


141 N.W . 1 St. AvenueDania, FL 33004-2835

Lashanda Adam sDismas Charities,lnc.

141 N.W . 1 St. Avenue

Dania ,FL 33004-2835


Attorney for Defendants4000 Hollywood Boulevard

Suite 265-South

Hollywood,FL 33021

EXECUTED ON THIS 30 DAY F APGUST, 1 1 !

/ // /zJ/ /<TRAIAN BUJ UVEANU, PRO SE5601 W . BROW ARD BLVD.,



UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDA

CASE NO.11-20120.CIV-SElTZ/S1M ONTON

TRAIAN BUJDUVEANU

Plaintiff,

DISMAS CHARITIES,INC.NANA GISPERT,

DEREK THOM AS,LASHANDA ADAM SDefendants.

PLAINTIFF'S SECOND REOUEST FOR PRODUCTIONOF DOCUM ENTS AND ELECTRONICALLY STORED INFORM ATIONS

TO DEFENDANTS DISMAS CHARITIESJNC..ANA GISPERX DEREKTH OM AS AND LASHANDA ADAM S.

Plaintiffs, Traian Bujduveanu, pursuant to Rule 34 of the Federal Rules of CivilProcedure, hereby request that Defendants Dismas Charities, Inc., Ana Gisperq Derek

Thomas and Lashanda Adams produce the originals of documents described below

within thirty (30) days of service of this notice to be at the address as set forth in theFirst Amended Complaint or at such other time and location as the parties may

muttlally agree.

DEFINITIONS

For purposes of this Request for Production of Documents, the following definitionsshall apply unless othenvise specifically indicated:

A. The word ''document'' shall mean any written or graphic matter or other means

of preserving thought or expression, and all tangible things from which information

can be processed or transcribed, including, but not limited to, correspondence,

memoranda, notes, messages, letters, telegrams, teletyped messages, bulletins, diaries,chronological data, minutes, books, reports, charts, ledgers

, invoices, worksheets,receipts, computer printouts, schedules, affidavits, contracts, transcripts, surveys,graphic representations of any kind, photographs, graphs, microfilm

, video tapes, taperecordings, motion pictures or other film.

B. All documents produced shall be in both hard copy fonnat and electronic media,to the extent the documents exist in electronic media. If the documents once existed in

1


electronic media but were deleted, Defendants shall produce mirror image copies of

the electronic media from which the documents were deleted or shall produce theelectronic media.

C. ''M irror image copies'' means true and exact copies of the electronic mediaincluding the portion of the electronic media from which material has been deleted.

D. ''A11 documents and electronic media relating to'' means any and a1l documents or

communications that constimte, comprise, contain, embody, reflect, identify, state,

refer directly or indirectly to or are in any way relevant to the particular subject matteridentified in the request.

E. lf any Request is deemed by Defendants to call for the production of documents

covered by the attorney/client or work product privilege, and Defendants withholdsaid documents on the basis of one or both of the privileges, provide a descliption of

the document and the grounds for withholding the document.

F. lf any documents responsive to these requests have been destroyed, describe said

documents and the reasons for their destruction and state the date on which saiddocuments were destroyed. If any such destroyed documents existed in electronic

media, provide the electronic media from which the documents were destroyed.

G. ''Person'' mcans any natural person; public or private corporation, whether

organized for profit ; governmental entity ; partnership; association; cooperative; jointventure; sole proprietorship ; or other legal entity . W ith respect to a business entity,

the term ''person'' includes any natural person acting formally or informally as anemployee, officer, agent, attorney, or other representative of the business entity.

H. ''Policy'' means each rule, procedure, or directive, formal or informal, and each

common understanding or course of conduct that was recognized as such by Yourpresent or former officers, directors, employees, agents, or other Persons acting or

purporting to act on Your behalf, that was in effect at any time during the period

covered by these requests and includes any changes of policy.

1. The terms ''and'' and ''or'' shall be construed either disjunctively or conjunctively asnecessary to bring within the scope of the discovery request all responses that mightotherwise be construed outside of its scope.

J. The use of the singular form of any word includes the plural and vice versa. In

addition, the use of any tense of any verb includes all other tenses of the verb.

K. ''And'' and ''or'' shall be construed disjunctively or conjunctively as necessary inorder to bring within the scope of each request all documents which might otherwise

be construed to be outside its scope.


The term ''and/or'' is to be read in both the conjunctive and disjunctive and shallserve as a request for information which would be responsive under a conjunctivereading in addition to all information which would be responsive under a disjunctivereading.

M ''Each'' includes both ''each'' and ''every.''

N. The singular and masculine gender shall, respectively, include the plural and

feminine gender, and vice versa.

0. ''You'' and ''your'' shall mean yourself and all other persons acting or purporting

to act on your behalf.

P. ''Relating to'' and ''relates to'' mean, without limitation, relating to, concerning,

constituting, mentioning, referring to, describing, summarizing, evidencing, listing,

relevant to, demonstrating, tending to prove or disprove, or explain.

R. ''Communication'' or ''communications'' includes, without limitation, in-personor telephone conversations, facsimiles, letters, electronic mail, telegrams, telexes,

tapes or other sound recordings, or other means of transmitting information from one

source to another.

S. ''Plaintiffs''- The tenn ''Plaintiffs'' refers to Traian Bujduveanu, as described inthe Complaint.

T. ''Defendants'' - The tenn ''Defendants'' in the context of this case refers to DismasCharities,lnc.,Ana GispertDerek Thomas,lashanda Adams.

SCHEDULE OFDOCUM ENTS

1 . Any and al1 records, correspondence, notes, communications and other documents

signed by Carlos Rodriguez, Director CCM , or any Decision M aking party orindividual from CCM M iami,regarding the fact that Plaintiff s Community Custody

should be terminated, and requirement for removal by, US M arshal Agents, from

Dismas Charities and transported to FDC M iami. Provide copiy of the Ret'urn to theinstitm ion Order.

2. Any and all records, correspondence, notes, communications and other documentssigned by USPO Steven Aasterud or any Decision M aking party or individual from

USPO, regarding the fact that Plaintiff ts Community Custody should be terminated,

and requirement for removal, by US M arshal Agents, from Dismas Charities and

transported to FDC M iami. Provide copy of the Ret'unz to the lnstitutin Order.


3. Any and a1l record, correspondence, notes, communication, between DismasCharities and US M arshal Office, containing the name of the M ovant, and the consent

to remove M ovant from Dismas Charities and transport him to FDC M iami, and copy

of Ret'urn to the Institution Order. Please provide PRISONER RECEPTION

documents signed by the US M arshall, and Prisoner Release Documents to the US

Marshall, signed by Dismas Charities staff.

4. Copy of ttconditions Of Home Consnment'' BP-460 signed by Plaintiff and

Dismas Staff

5. Copy of Transfer Order to document the official transfer to home continement and

the Authorized Unescorted Commitment and Transfer Card, 8P-385

6. Copy of Dismas Charities' Etcondition and Terms of Home Continement''çtviolation of Rules of Home Confinement'' and tûDismas Charities Disciplinary

Procedings''

7. Any and a11 tçstatements'' conceming the subject matter of this action within themeaning of Rule 26.02 of the Rules of Civil Procedure.

8. Any and all documents that support, tend to support, prove, or tend to prove any of

the allegations, facts, defenses, denials, or other matters asserted in the Answer or

other response to the Complaint in this lawsuit.

9. Any and all documents that refute,

Plaintiff's Complaint in this lawsuit.

or tend to refute, any claims asserted in

l0. Any and all docum ents read, reviewed, consulted, examined, used, or relied uponin preparing your Responses to Plaintiff's Request for Production of Documents - Set

1.

l 1 . Copy of all Plaintiff requests to attend religious service at the Orthodox church,

located 16 minutes away from Dismas Charities house. (GPS Time -oistance)

l2. Copy of W ritten Item ized lnventory of all Plaintiff's Personal Propertyconfiscated, from the Plaintiff , by Dismas Chariies staff. Also provide copies of al1

receipts for all lnmate Property, including money and other valuables signed and held

by Dismas Charities staff, and copies of all receipts for the lnmate Property's Return,

signed by the Plaintiff.

4


Date: August 30, 201 1

..M c ?zzz/o v//

TRAIAN BUJDUV ANU, PRO SE



l hereby certify that on August 30, 201 1 a true and correct copy of the foregoingdocument was served upon the following via the United States Postal Service

, FirstClass M ail:

Dismas Charities, lnc.,

l41 N.W . 1 St. AvenueDania, FL 33004-2835

Ana Gispert



Dania, FL 33004-2835



Dania, FL 33004-2835

Lashanda Adams



Dania ,FL 33004-2835

David S. Chaiet,EsquireAttomey for Defendants

4000 Hollywood Boulevard

Suite 265-South

Hollywood,Fla 33021

EXECUTED ON THIS 30 DAY OF AUGUST, 20l l

.,-'e

r /

/ // # zz / < ##TRAIAN BUJDUVE , PRo sE




EXHIBIT C




CASE NO.: 11-20120-C1V-SElTZ/S1M ONTON

TM IAN BUJDUVEANU,

Plaintiff,

VS.

DISM AS CHARITIE ,S IN ,C. ANA GISPERT,

DEREK THOM AS and ADAM S LESHOTA

Defendants./

NOTICE OF FILING ANSW ERS TO PLAINTIFF'S FIRST SET OF

INTERROGATORIES PROPOU-NDED TO DISM AS CHARITIES. INC.

Defendant, Dismas Charities, lnc., by and through its tmdersigned cotmsel, tsles its

Answers to Plaintiff s First Set of Interrogatories plzrsuant to the Federal Rules of Civil

Procedure.

CERTIFTCATE OF SERVICE

Y- day of September, 201 1 the foregoing doclzment1 HEREBY CERTIFY that on theis being served this day on a1l cotmsel of record or pro se parties identified on the attached

Service List via United States Regular M '

DAVID S. ET, ESQUIREFlorida Bar No. 963798


SERVICE LIST

Traian Bujduveanu v. Dismas Charities, Inc-, et aI.Case No..: II-ZOIZO-CIV-SEITZ/SIM ONTON

United States District Court, Southern District of Florida

Traian BujduveanuPro Se Plaintiff5601 W . Broward Blvd.

Plantation, FL 33317

Tel: (954) 316-3828Email: [email protected]

2


ANSW ERS

Dism as Charities, Inc. was form ed in 1964 in the Comm onwealth of Kentucky. The Plaintiff is

directed to www.dismas.com for additional information about Dismas Charities, Inc. The nnm es

of any officers and directors, partners and owners is not reasonably calculated to lead to the

discovery of admissible evidence and is intended solely to harass these individuals.

Objection. The term çtpremises liability claims'' is overbroad, vague and not responsibly

calculated to lead to the discovery of admissible evidence. Subject to and without waiving the

foregoing objections, Dismms is not aware of any claims similar to those set forth in the

Plaintiffs vague and confusing Complaint.

The Plaintiffwas afforded al1 reasonable and necessary medical care and referrals requested.

The premises have surveillance cnmeras. The cameras are monitored by staff. The tapes from

the time of the alleged occurrences do not exist.

Objection, this question is overbroad in scope and is not relevant as training is not an issue in this

lawsuit. Subject to and without waiving the foregoing objections, a11 Dismas employees are

trained and receive a handbook.

No.

The Plaintiff violated rules he acknowledged receiving.

6.

The Plaintiff drove without the

8.

9.

permission of Dism as and improperly possessed a cell phone.

No.

Objection.

improperly seeks fnancial information and is not reasonably calculated to lead to the discovery

of admissible evidence.

The salaries of employees and directors are not relevant or adm issible. This request

3


10. Objection. TMs request is not reasonably calculated to lead to discovery of admissible evidence

and seeks irrelevant information. Subject to and without waiving the foregoing objections, none

that Dismas is aware of.

Objection. This request concerning political contributions of Dismas and its employees is not

relevant or reasonably calculated to lead to the discovery of admissible evidence. This request

improperly seeks financial information about Dismas and is harassing.

Objection. This request for information about any other lawsuit involving Dismas is overbroad

and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and

without waiving the foregoing objections, none Dismas Dania Beach is aware of.

4


V z 'X ! .-

. .

DISMAS CIIARIYIES,INC.: www-o w''u? FC.kz.. . 4

STATE OF FLORI )ltCOUNTY OF swDismas Charities,lnc., being

are true and correct to the bestduly swom, deposes

of his/her knowledge,

and say that the attached Answersinformation and belief

it%. . , l

1

/lf t. y

Nw ys xojas yjjyy

yjss oy yggj

vy y* Davè cj

j (jaX Q V A4 RQ j

y

s p y tsmmysyjoyy ssgygtya .og a+ sxpay gyyggyg yy

.4

(Print Type or Slnmp o ' edNnme of No Public)

Personally Known OR Produced Identification

Type of Identiication Produced: .

.,-.-7 t h,!

day of J C' j ,2011swon To Axo susscmBso before me thisM y com mission expires:

9




CASE NO.: II-ZOIZO-CIV-SEITZ/SIM ONTON

TRAIAN BUJDUVEANU,

Plaintiff,

VS.

Dlsm s CHARJTIE ,s I'N ,c. ANA GISPERT,

DEREK Tl-lom s and Aoo s LESHOTA

Defendants.

NOTICE OF FILING ANSW ERS TO- PLM NTIFF'S SECOND SET OF

INTERRO GATORIES PRO PO UN- DE-D T-O DISM AS CHARITIES. INC.

Defendant, Dismas Charities, Inc., by and tllrough its undersigned counsel, files its

Answers to Plaintiffs Second Set of Interrogatoriès pursuant to the Federal Rules of Civil

Procedtzre.

CERTIFICA OF SERVICE

I HEREBY CERTIFY that on the day of Septem ber,is being served this day on al1 cotmsel

: f ecord or pro se partiesService List via United States Regular M a 1.

DAVID S. A T, ESQUIREFlorida Bar No.963798

20l 1 the foregoing docllm ent

identified on the attached


SERVICE LIST

Traian Bujduveanu v. Dismas Charities, Inc., et aI.Case No..: II-ZOIZO-CIV-SEITZ/SIM ONTON


Traian BujduveanuPro Se Plaintiff5601 W . Brow ard Blvd.


Te1: (954) 316-3828Email: [email protected]


ANSW ERS

1. The Plaintiff was never denied the opportunity to attend religious services that m et Federal

Btlreau of Prison Guidelines.

No receipts are issued for confscation of contraband. The Plaintiff was provided an inventory

receipt fornn for other itenls. This docum ent was produced in response to Plaintiff s second

request for production of docum ents.

In response to this question, the Plaintiff is directed to the Resident Handbook, which is available

for inspection at Defendants' counsel's office.


t '$ !, .1' ,,? W

DISM A RITIES INC. ' z. ., . k -e-C.

STATE OF FLO A )V/'u . .

jCOUNW OF

Dismas Cblm'tiesylnc., being duly sworn, deposes and say that the attached Anmwers

are true and correct to the best ofe er u owledge, information and belief.

*.

: 7. $., p th. . I?N.

'q'

,x !jç. j j. ï

NO #* Rotgry pvyy ,* $ Lovk ch ;e Yte of Flo

rjNaY < w 7 u * ts w y xmmysyyos yyyyyyyo. ryk sxpjx cugyyy yy

(Print Type or Stamp ' 'Name of No Public)

Personally Known OR Produced IdentilcaéonType of Identiscation Produced:

jêx /SWORN TO M D SUBSCRmED before me this -1 day of J 2Jkz''N ,2011

My commitsion expires:

10




CASE NO.: II-ZOIZO-CIV-SEITZ/SIVONTON

TRM AN BUJDUVEANU,

Plaintiff,

VS.

DlsM A s CHARITIE ,s IN ,c. ANA GISPERT,

DEREK Tldom s and Aoo S LESHOTA

Defendants.

/

NOTICE OF FILING ANSW KRS TO PLAINTIFF'S FIRST SET OFINTERROGATORIES PROPOVNDED TO ANA GISPERT

Defendant, Ana Gispert by and through undersigned counsel, files M swers to PlaintiT s

First Set of lnterrogatories pm suant to the Federal Rules of Civil Procedure.


lday of september, 2O1 1I HEREBY CERTIFY that on theis being served tllis day on a11 co of record or pro se partiesService List via United States Regular ail.

DAVID . IET, ESQUIREFlorida Bar N o. 963798

the foregoing docum entidentified on the attached


SERVICE LIST



Traian BujduveanuPro Se Plaintiff

5601 W . Broward Blvd.




ANSW ERS

Objection; this request seeks personal and confidential information on persons being sued in their

employment capacity, is not reasonably calculated to lead to the discovery of admissible

evidence and is intended for harassment purposes only. Subject to and without waiving the

W 1St Avenue Dania, FL 33004. As l nm being sued inforegoing objections, Ana Gispert, 141 N ,

my professional capacity, my home address, social seclzrity ntzmber, date of birth and marital

status are not relevant and contidential. Due to my line of work in the corrections area, I do not

want to provide personal information for security reasons.

Objection, this request seeks personal and confidential infonnation on persons being sued in their

em ploym ent capacity, is not reasonably calculated to lead to the discovery of admissible


foregoing objections, none.

Objection, this request seeks personal and confidential information on persons being sued in their


evidence and is imended for harassment purposes only. Subject to and without waiving the

foregoing objections, none professionally. -

4. Ana Gispert, Adnms Lashanda and Derek Thom as have information about the Plaintifrs actions ,?/

and noncom pliance with rules he agreed to abide by.

The matter was investigated by Dismas Charities, lnc., the United States M arshalls Service and

the Federal Btlreau of Prisons. Any reports, if any, are in possession of the respective entity.

Dism as has m ade available any reports for inspection at its cotmsel's office.

The Plaintiffw% interviewed and also failed to accept a copy of his incident report.

3


None.

8. Incident report written by Derek Thomas on October 13, 2010..z. *'

9. The prem ises have surveillance cam eras. The cameras are m onitored by staff. The tapes from t


10. Dismas has limited medical records of the Plaintiff which are available for inspection at its

counsel's office.

No.

Yes. However, I could not control the violations of rules by the Plaintiff.

l 3. The Plaintiff was afforded a11 reasonable and necessary m edical care requested by him, including ?

)

'

-r--- visits to the hospital and home confinement. d

14. j On October 13, 2010, the Plaintiff violated the rules of Dismas. On October 19, 2010, Derek )f Thomas was made aware that the Plaintiff was transported to the hospital but was not aware of 1

/

q$ the medical condition that required treatment. . .

.

- - - - - - - - - - - - - - - - - - 2- - -.J

12.

The Plaintiff fails to tmderstand that he was not permitted to drive by Dism as as an agreed

condition of his halfway house release. W hile the Plaintiff provided domlments, including,

instzrance inform ation, this does not change the fact that he was not permitted to drive without

perm ission of Dism as as per the agreem ent he signed as part of his halfway house release.

See response to question 9.

Unknown at this tim e. N o experts have been presently retained.

18. Unknown at this tim e.


j 'k 'lz/ J J

ANA GISPERT

STATE OF FLORIDA )cotm'l'Y OF 'h t-w )

N.

Ana Gsw rt, being duly sworm deposes and say that the attached M swers are trueand correct to the best of lkis/her knowledge

, information and belief.

i

!

N ''t P'kN z.c jjc stax of norjda

*

. c oavid cjjaje tl c. . g My commjssjon ooqaszxYo, wo% oxx

fss cwzpgcjq

(Print Type or Sflmp CommissionedNnme of No Public)

Personally Known '( OR Produced ldentitkaéonType of Identifkation-produced:

Nk

.!.t aollSWORN TO ANll SUBSCRIBED before me this day of ,

My comm iqsion expires:

8



CA SE NO.: II-ZOIZO-CIV-SEITZ/SIM ONTON

TRAIAN BUJDUVEAN U,

Plaintiff,

VS.

DlsM A s CHA RJTIE ,s l'N ,c. ANA GISPERT,

DEREK THOMAS and ADAM S LESHOTA

Defendants.

NOTICE OF FILING M SW ERS TO- PLAINTIFF'S SECOND SET O FINTERROGATORIES PROPOUNDED TO ANA GISPERT

Defendant, Ana Gispert, by and through undersigned counsel, files these Answers to

Plaintifcs Second Set of lntenogatories ptzrsuant to the Federal Rules of Civil Procedure.

CERTIFICATE OF SERVICE/

I HEQEBY CERTIFY that on the day of September, 201 1 the foregoing

is being served this day on a1l counse o record or pro se parties identified on the

Service List via United States Regular '

DAVID . C IET, ESQUIREFlorida Bar No. 963798

documentattached


SERVICE LIST

Traian Bujduveanu v. Dismas Charities, Inc., et al.Case No..: II-ZOIZO-CIV-SEITZ/SIM ONTON

United States District Courq Southern District of Florida


5601 W . Broward Blvd.Plantation, FL 33317



ANSW ERS

The Plaintiff was rlever denied the opportunity to attend religious services that m et Federal


2. No receipts are issued for consscation of contraband. t The Plaintiff was provided an inventoryI

-

receipt form for other items. This document was produced in response to Plaintiffs second


ln response to this question, the Plaintiff is directed to the Resident Handbook, which is available



) /'N :/ l , î

'

'' 4 .'' V. .-- . t ...-

ANA GISPERT

STATE OF FLO DA )j), w . . )COUNTY OF

Ana Gspert, being duly sworn, deposes and say that the attached Answers are true

and correct to the best of his/her knowledge, information and belief.

G

i

'

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' / t/ jl !

J -

NOT Y PUBLIC.* '%A'iy'

x'Y >o Noury public state of rlorida -p A.Q D

avid Chaiet v;*l c. . < My commission 0D985396 .;* Ex ir / 4

. . @

'

*

'

( , nedName of Notary Public)

Personally Known OR Produced Identifk ation

Type of ldentifkation Produced:.--x

/b - c > . ,

zgrK, , z () 1 JSW ORN TO AND SUBSCRIBED before me this day of

M y comm ission expires:


IN THE UNIR'ED STATES DISTRICT COURT FORTHE SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1 IQOIZO-CIV-SEITZ/SIMONTON

TRM AN BUJDUVEANU,

Plaintiff,

VS.

DlsM As CHARITIE & IN ,c. ANA GISPERT,DEREK Tldom s and ADAM S LESHOTA

Defendants.

/

NOTICE O F FILING ANSW ERS TO-PLM NTIFF'S FIRST SET OF

INTERROGATORIES PROPOUNDED TO DEREK THOM AS

Defendant, Derek Thomas, by and tluough tmdersigned counsel, files Answers to

Plaintiff s First Set of Interrogatories plzrsuant to the Federal Rules of Civil Procedtlre.


I HEREBY CERTIFY that on the day of September, 201 1 the foregoing document

is being served this day on all counsel record or pro se parties identitied on the attached

Service List via United States Regular M .

DAVID S. H IET, ESQUIREFlorida Bar No. 963798


SERVICE LIST

Traian Bujduveanu v. Dismas Charities, Inc-, et al.Case No..: II-ZOIZO-CIV-SEITZ/SIM ONTON





2


ANSW ERS



evidence and is intended for harassment pum oses only. Subject to and without waiving the

h 141 NW 1St Avenue Dnnia FL 33004. As l am being suedforegoing objections, Derek T omas, , ,

in my professional capacity, my home address, social security nllmber, date of birth and marital

status are not relevant and con/dential. Due to my line of work in the corrections area, l do not

want to provide personal information for security reasons.

Objection, this request seeks personal and contidential information on persons being sued in their

employment capacity, is not reasonably calculated to

evidence and is intended for harassment purposes only.


2.

lead to the discovery of admissible

Subject to and without waiving the



evidence and is intended for harassment purposes orlly. Subject to and without waiving the

foregoing objections, none professionally.

Ana Gispert, Adam s Lashanda and Derek Thom as have infonnation about the Plaintiff s adions

and noncompliance with rules he agreed to abide by.

4.

The matler was investigated by Dism as Charities, lnc., the United States M arshalls Service and

the Federal Bureau of Prisons. Any reports, if any, are in possession of the respective entity.

Dismas has made available any reports for inspection at its counsel's offiee.

The Plaintiff was interviewed and also failed to accept a copy of his incident report.

6.


7.

8.

9.

N one.

Incident report written by Derek Thomas on October 13s 2010.

The prem ises have surveillance cameras.


The cnmeras are m onitored by staff. The tapes from

l 0. Dismas has limited medical records of the Plaintiff which are available for inspection at its

counsel's office.

11. No.

12. Yes. However, 1 could not control the violations of rules by the Plaintiff.

The Plaintiff was afforded a1l reasonable and necessary medical care requested by him, including

visits to the hospital and hom e confinem ent.

14. On October 13, 2010, the Plaintiff violated the rules of Dismas. On October 19, 2010, Derek

Thomas was made aware that the Plaintiff was transported to the hospital but was not aware of

the medical condition that required treatment.

The Plaintiff fails to understand that he was not permitted to drive by Dism as as an agreed

condition of his halfway house release. W hile the Plaintiff provided documents, including,

instlrance information, this does not change the fact that he was not permitted to drive without

perm ission of Dism as as per the agreem ent he signed as part of his halfway house release.

16. See response to question 9.

17. Unknown at tltis time. No experts have been presently retained.

Unknown at this tim e.

4


't-.r.

. j!: . .?-/,. ...yxyss..ss......- jjjjjjjjjjvjvj yaz y,, ...............DEREK THO S .

V.J

STATE OF FLO A )cotm'fY OF kk )

swom , deposes and say that the attached Answers aretrue and correct to the best of his/her u owledge

, information and belief.

't!

t l

t.t 1

1 '' j/ ,N v

olX *1

w y, yogry susjo ,sya of rjorjys1. ch v J U*vid Chxet

s y w commjasss yogooyyo, s. gxpas oo

(Print, Type 'ssionNnme of Notary Public)

Personally Known OR Produced Identiik ation

Type of Identilcation Produced:

Derek n omas, being duly

f.. i

SW ORN TO Ar SUBSCRIRED before me thistl day of 1 X' X ,2011

M y commission expires:




CASE N O.: II-ZOIZO-CIV-SEITZ/SIM ONTON

TM IAN BUJDW EANU,

Plaintiff,

VS.

DlsMAs CHARITIE & IN ,C. ANA GISPERT,DEREK THOM A S and ADAM S LESHOTA

Defendants.

NOTICE OF FILING ANSW FRS-TO PLAINTIFF'S SECOND SET OF

INTERROGATORIES PROPOVNDED TO DEREK THOM AS

Defendant, Derek Thomas, by and through undersigned cotmsel, files these Answers to

Plaintiffs Second Set of lnterrogatories pttrsuant to the Federal Rules of Civil Procedure.


I HEREBY CERTIFY that on the day of September, 201 1

is being served this day on a11 cotmsel of record or pro se parties

Service List via United States Regular 'l.

DAVID S. IET, ESQUIREFlorida Bar No. 963798

the foregoing docllm ent



SERVICE LIST

Traian Bujduveanu v. Dismas Charities, Inc., et al.Case No..: II-ZOIZO-CIV-SEITZ/SIM ONTON


Traian BujduveanuPro Se Plaintiff5601 W . Broward Blvd.Plantation, FL 33317


2


ANSW ERS

The Plaintiff was never denied the opportunity to attend religious services that met Federal


No receipts are issued for confiscation of contraband. The Plaintiff was provided an inventory

receipt form for other items. This document was produced in response to Plaintiff s second





A - - x

*' . .N .

DEREV TN

i

STATE OF FLO DA )q-a )COUNTY OF

Derek Thomas, being duly swom, deposes and say that the attached Answers are

true and correct to the best of llis/her knowledge, infonnation and belief.

ft,.-'dk.

'

;/.N #

. y , -tl'

kj tî ) j''$ '' t /

@ ' *' lf$

ss- % .'o .e xotary pusjc sj

at, of soraa t.t j > oavjd cjjajet .@

yc. . . g uy commjssion oogasax j0) #v* Expjres os)2n;o;4 a.

Print Type or ' '' ned( ,Nnme of Notary Public)

Personally Known OR Produced IdentificationType of Identiscation roduced:

*$ y-

j) r , ' aollSWORN TO AND SUBSCRIBED before me this day of . ,

M y com mission expires:

12


':


CASE NO .2 II-ZOIZO-CIV-SEITZ/SIM ONTON

TRAIAN BUJDUVEANU,

Plaintiff,

VS.

DISM AS CHARITIES INC. ANA GISPERT,

DEREK THOMAS aQ ADAVS LESHOTA

Defendants./

NOTICE OF FILING ANSW ERS TO PLAINTIFF'S FIRST SET OFINTERROGATORIES PROPOVNDED TP LASHANDA ADAM S

Defendant, Lashanda Adams, by and through tmdersigned counsel, files Answers to

Plaintiff s First Set of lnterrogatories ptlrsuant to the Federal Rules of Civil Procedtlre.


I HEREBY CERTIFY that on the day of Septem ber, 201 1 the foregoingis being served this day on all counsel record or pro se parties identified on the

Service List via Urïited States Regular a' .

$

DAVID S IET, ESQUIREFlorida Bar No. 963798

docllment

attached


SERVICE LIST




5601 W . Broward Blvd.




I

ANSW ERS




d L handa 141 NW 1St Avenue, Dania, FL 33004. As l am beingforegoing objections, A nms as ,

sued in my professional capacity, my home address, social sectlrity number, date of birth and

m mital status are not relevant and confidential. Due to my line of work in the corrections area, I

do not want to provide personal information for security reasons.


em ployment capacity, is not reasonably calculated to lead to the discovery of adm issible

Subject to and without waiving theevidence and is intended for harmssment purposes only.



employm ent capacity,is not reasonably calculated to lead to the discovery of adm issible


foregoing objections, none professionally.

Ana Gisperq Adnms Lashanda and Derek Thomas have information about the Plaintifps actions

and noncom pliance with rules he agreed to abide by.

The m atter was investigated by Dism as Charities, lnc., the United States M arshalls Service and

the Federal Bureau of Prisons. Any reports, if any,

5.

are in possession of the respective entity.

Dismas has made available any reports for inspection at its counsel's oftke.

The Plaintiff was interviewed and also failed to accept a copy of his incident report.

3


N one.

lncident report written by Derek Thom as on October 13, 2010.

The premises have surveillance csmeras. The cam eras are m onitored by staff. The tapes from9.

the tim e of the alleged occtr ences do not exist.

Dismas has limited medical records of the Plaintiff wltich are available for inspection at its

counsel's oftke.

1 1. N o.

l2. Yes. However, 1 could not control the violations of rules by the Plaintiff.

The Plaintiff was afforded al1 reasonable and necessary medical care requested by him, including

visits to the hospital and hom e confinem ent.

14. On October 13, 2010, the Plaintiff violated the rules of Dism as. On October 19, 2010, Derek

Thomas was m ade aw are that the Plaintiff was transported to the hospital but was not aware of

the medical condition that required treatment.

The Plaintiff fails to tmderstand that he was not permitted to drive by Dism as as an agreed

condition of his halfway house release. W hile the Plaintiff provided docllments, including,

instlrance inform ation, this does not change the fact that he was not permitted to drive without

pennission of Dism as as per the agreem ent he signed as part of his halfway house release.

16. See response to question 9.

17. Unknown at this time. No experts have been presently retained.

18. Unknown at this tim e.

4


#. Z

J

LASHANDA ADAM S

STATE OF FLORIDA )CoUNW OF r û

Lashanda Adsms. being duly swom, deposes and say Gat the attached Answers are

tnze and correct to tlze best of his/her knowledge, information and belief.

Et .

I' jl! t

I l

; . e t/N K P .,., s.o. o .. fy Puoic sf.

' ,,e

. tpavje cjjajet -te of poryyalG Q w v jj ,l z y commjsgjop o

jyjgjyytyx j( .o, fk Epjrss ooggyg2014 <

rint Type or Stamp o ' ' bd(P ,Nnme of No Public)

Personally Known OR Produced ldentiikation

Type of Idento cation D oduced:*

î kjk. .201 ISW ORN TO Ar SUBSCRIRED before me this day of

My commission expires:

11



CASE NO.: 11-20120-ClV-SE1TZ/SlM ONTON

TRAIAN BUJDW EAN U,

Plaintiff,

DlsM As CHARJTIES m c. AXA GISPERT,

DEREK Tl-lom s =J AoiMs LESHOTA

Defendants.

/

NOTICE OF FILING ANSW ERS TO PLAINTIFF'S SECOND SET OFINTERROGATORIES PROPQVNDED TO LASHANDA ADAM S

Defendant, Lashanda Adams, by and through undersigned counsel, files these Answers to

Plaintiff's Second Set of lnterrogatories pursuant to the Federal Rules of Civil Procedlzre.

CERTIFICATX OF SERW CE

Uday of September, 201 1I HEREBY CERTIFY that on theis being served this day on all counsel of record or pro se parties

Service List via United States Regular M ail

DAVID S. C IET, ESQUIREFlorida Bar No. 963798

the foregoing document



SERV-ICE LIST

Traian Bujduveanu v. Dismas Charities, Inc., et al.Case No..: II-ZOIZO-CIV-SEITZ/SIM O NTON






ANSW ERS

opportunity to attend religious services that met FederalThe Plaintiff was never denied the

Bureau of Prison Guidelines.

No receipts are issued for confiscation of contraband. The Plaintiff was provided an inventory

receipt fonn for other items. This doctlment was produced in response to Plaintiff s second


2.




kr/'h'jj,jsllljjjjjjrs,,,,,.gjjjgjj

yj,kjy

't,jk

yy .t

ASHANDA ADA M S

STATE OF FLORI )% k )COUNTY OFY N

Lashanda Adam s, being

true and correct to the bestduly sworn, deposes and say that

of his/her knowledge,the attx hed M swers are

information and beli f.

%'

h j-t j. ,i t

NO 4U4 ublic state of ptotjqa. w . oavid cs

ajej< Ftru z uy commasjon ooggsax#< Exxres osjg:uojq* R

(Print, Type or Stnmp CommissionedName of Notary Public)z'

Personally Known OR Produced IdentificationType of Identifkation Produced:

f'', t ,co1ISW ORN TO AN D SUBSCRIBED before me this day of

M y comm ission expires:

13



CASE NO.: 1 IQOIZO-CIV-SEITZ/SIM ONTON

TM IAN BUJDW EANU,

Plaintiff,

VS.

DlsM As CHARITIE ,s IN ,c. AXA GISPERT,DEREK THOM AS and Aow s LESHOTA

Defendants.

/

DEFENDANTS DISM AS CHARTIES- J NC..AN- A GISPERT. DEREK THOM AS AND

ADAM S LESHOTA'S RESPQNSE TO PLAINTIFF'S SECOND REOUEST FOR

PRODUCTION

Defendants Dismas Charities, lnc., Ana Gispert, Derek Thomas and Adnms Lashanda,

incorrectly identified as Adnms Leshota (tttaeshota''), (collectively trefendants'') by and through

their tmdersigned counsel and file their Responses to the Second Requests for Production of

Traian Bujduveanu Csplaintiff'') as follows:

1 . See attached document.

2.

3.

N one.

See response to request number one above.

4. Dism as is willing to produce the requested docum ents at its attorneys' office at a

mum ally convenient date and time or will produce the doclzm ent requested upon pre-paym ent of

reasonable copying costs.

N one.


4

Dism as is willing to produce the requested docum ents at its attorneys' office at a

mutually convenient date and time or will produce the doclzment requested upon pre-paym ent of

reasonable copying costs.

N one.

8. Objection, this request is overbroad and confusing as no answer has been filed to

the Complaint. n e Defendants filed a M otion to Dismiss which is still pending. Subject to and

whhout waiving the foregoing objections, see documents that the Defendants have agreed to

produce in response to Plaintifps First Request for Production of Docllm ents.

9. Objection, this request is overbroad and confusing as no answer has been filed to

the Complaint. The Defendants tiled a M otion to Dismiss which is still pending. Subject to and

without waiving the foregoing objections, see docllments that the Defendants have agreed to

produce in response to Plaintiffs First Request for Production of Docllments, including the

acknowledgement forms signed by the Plaintiff.

10. Objection, this request is overbroad and confusing as it seeks docllments relied

upon in prepming a response to a request for production. Subject to and without waiving the

foregoing objections, see documents that the Defendants have agreed to produce in response to

Plaintifrs First Request for Production of Docum ents,

N one.

See attached docllm ents.

2


CERTIFICAT-E OF SERVICE

Y day of September, 201 1 the foregoing documentI HEREBY CERTIFY that on theis being served tllis day on al1 counsel of record or pr se ies identified on the attached

Service List via United SGtes Regular M ail.

/s/ David S. Chaiet

DAVID S. CHAIET, ESQUIFlorida Bar No. 963798

3


SERVICE LIST

Traian Bujduveanu v. Dismas Charities, Inc., et aI.Case No..: 11-20120-ClV-SElTZ/SlM ONTON



5601 W . Broward Blvd.Plantation, FL 33317


4


#

EXH IBIT D


From: [email protected]

To: [email protected]: Re: Defendants responses to The Second Request For Production Of Documents andFirst and Second Set Of InterrogatoriesDate: Sat, 10 Sep 2011 20:48:16 +0000

I am waiting for the judge to rule on the motion to dismiss.

On Sep 10, 2011, at 3:50 PM, ''Traian Bujduveanu'' <[email protected]> wrote:

Dear Mr. Chaiet,Thank you again for your email.You ate right about that. 1 do not undereand the ''legal process'' the way others do

.This is why we should Iet a judge decide.

Best Regards

Traian Bujduveanu

From: [email protected]: [email protected]: Re: Defendants responses to The Second Request For Produdion Of Documents andFirst and Second Set Of InterrogatoriesDate: Sat, 10 Sep 2011 11:03:49 +0000

I have no idea what you mean. The responsive document are available for your review. 1

attached the responslve documents to your second request. W e answered aII harassing andi

rrelevant interrogatorie . If you do not understand the Iegal proc- q or respon- K it is not my jobto educate you as you are not my client.

On Sep 9, 2011, at 8:50 PM, ''Traian Bujduveanu'' <[email protected]> wrote:

Dear Mr. Chaiet,

i have received the Defendants responses today, and I do not know how to interpret them

.Are these Stall Tadics em ployed by the Defendants or Obstrudion of Justice ?

Mr. Chaiet, 1 cannot make a case if the defendant refuse to pa/icipate in the Discovel process.Let me remind you Mr. Chaiet, that if we continue this way

, they leave me no alternative but to5Ie a Motion For Summary Judgment.

Best Regards

Traian Bujduveanu


/

EXH IBIT E


5E8-28-2212 TUE 21:32 Fhe

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UNTTED STATES GOVERNN ENTm e m o r z n d o m

Commmlijy C/avtlt'/l/zixv Qmce40l North M iami J venue

M JœP/.. Flonida 3-UZJ-JdJP305-536-5718

F= .- 305436-4024

Date:

Reply toAtm oc

Subjed:

To :

lnfo'.

ITlle àbéke-riférèrtced inmate is a C C-c-prolam Failcre. .please assump pujtpdy cf him soon as

! ' ' 'e

possible, and tranmort him to FDC M ipmi. Florida.1

Ootober 19, 201 0l

(Carlos E. RodrigueA ColMmunil Corredions M anager

lBujduveanu, Traian R4g. No. 80655-004*** cCC Prograrn Failule *#*

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U.S. M arshals Service - Fon Lauderdales Florida!

BOP - FDC V ami. FL (JSM & CMC)

Nhe subj- ig cuaently mssired to Disp' 1e4 House Ct',Ca Dania, Florida. PltamKe confact tht CCC1.Director, Ana Gisptn, at (954) 920-6358 for aséiMance in tssurning custody of this inmate.

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Note to MIM (ISMI - This is a;CCC Program failure for security reasons, 1% bas a

release d.ate of 01 .03. l 1 via GCT. His release date is not subject to

change. !f

'

!n ank you for your assistance with this matter. lfyog havc any questions. please ccntact me ati

305-536-51 t:.


Technology

Motion to compel second request for production of documents,first and second set of interrogatories