Joint shedilling report
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Transcript of Joint shedilling report
IN THE UNITED STATES DISTRICT COURT FOR
THE SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
TRAIAN BUJDUVEANU,
Plaintiff,
vs.
DISMAS CHARITIES, INC., ANA GISPERT,DEREK THOMAS and ADAMS LESHOTA
Defendants.
JOINT SCHEDULING REPORT
The Plaintiff, Traian Bujduveanu and Defendants Dismas Charities, Ana Gispert, Derek
Thomas and Adams Lashanda, by and through undersigned counsel, and pursuant to the Court's
"Order Requiring Joint Scheduling Report", hereby submit this Joint Scheduling Report.
A. STATEMENT OF THE FACTS AND OF THE CASE
Plaintiff Traian Bujduveanu, a former Federal Inmate, has filed a Complaint against
Residential Reentry Center (RRC)/Half Way House, Dismas, and three of its employees, Gispert,
Thomas and Lashanda.
PLAINTIFF'S SUMMARY OF CONTENTION & RELIEF SOUGHT
This is an individual action brought by Plaintiff Traian Bujduveanu, a former federal
inmate, against (i) Dismas Charities, Inc., owner and operator of Dismas Charities Halfway
House in Dania Beach, Florida, at which Plaintiff was sent by the Federal Bureau Of Prisons,
after he was released from Federal Custody to Community Custody;(ii) individual Defendants
Ana Gispert, Director of Dismas Charity Halfway House in Dania Beach, Florida, Derek
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 1 of 22
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
Thomas, Assistant Director of Dismas Charities halfway house in Dania Beach, Florida, and
Lashanda Adams, Counsel of Dismas Charities halfway House in Dania Beach, Florida. ("An
inmate must be assigned COMMUNITY custody status, prior to transfer to a CCC")
(PS5100.08)
Plaintiffs claims against Dismas Charities, Inc. and the Defendants, allege violations of
Illegal Search and Seizure, False Arrest, Unlawful Imprisonment, Violation of Constitutional
Rights, Unlawful Discrimination of Race, National Origin, Ethnic Groups and Ancestry, Reverse
Discrimination under the color of state and federal law, Discriminatory Harassment, Intentional
Infliction of Mental Distress, Deliberate Indifference, Negligence and Gross Negligence, by
failing to ascertain the medical condition of the Movant complaints of feeling ill.
Plaintiff sues Defendants Ana Gispert, Derek Thomas and Lashanda Adams both in their
personal capacity and their official capacity as employees of Dismas Charities, Inc. for violation
of Plaintiff s :
a. First Amendment of the United States Constitution, for Freedom of Speech and retaliation;
b. Fourth Amendment of the United States Constitution, defining the right to be free from
unlawful seizure of his property or person;
c. Fifth Amendment of the United States Constitution, defining the rights to due process.
d. Eight Amendment of the United States Constitution, defining the right to be free from cruel
and unusual punishment.
d. Fourteen Amendment of the United States Constitution rights to
procedural due process pursuant to 42 U.S.C. 1983 ("Due Process")
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 2 of 22
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
e. Violation of state laws of the State Of Florida, to include False arrest and imprisonment,
Assault and battery; Malicious Prosecution, Abuse of process, Negligence, and Gross
Negligence.
f. Unlawful discrimination of race, national origin, ethnic groups and ancestry under the color of
state and federal law.
g. Infliction of Mental Distress,
h. Deliberate Indifference.
i. Negligence and Gross Negligence by failing to ascertain the medical condition of the Plaintiff
complaints of feeling ill.
Plaintiff brings this action for general, compensatory, and punitive damages,
prejudgment interest, costs and Court fees, and other appropriate and just relief resulting from
Defendants' unlawful conduct.
DEFENDANTS' SUMMARY
Defendants contend that Plaintiff, Traian Bujduveanu, was transferred from Federal
Correctional Institute Coleman Low to Dismas Charities, Inc.'s Dania Facility on July 28, 2010.
Dismas' Dania facility is a Residential Re-Entry Center for federal inmates, such as Plaintiff, to
serve out a remaining percentage of their sentence before release. Plaintiff was serving a 35
month sentence for conspiracy to violate the International Emergency Economic/Power Act, the
Iranian Transactions Regulations, and the Arm/Export Control Act. Plaintiff was scheduled for
release from Dismas on January 3, 2011.
On or about September 28, 2010, Plaintiff was transferred to home detention. He
remained on home detention until October 15, 2010, at which time he was returned to the Dania
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 3 of 22
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
facility for violating a condition of his home detention and the possession, manufacture, or
introduction of a hazardous tool. The underlying incident occurred on October 13, 2010, where
Plaintiff was discovered driving an automobile without proper authorization. The vehicle was
located at the Dania facility and was subsequently searched after Plaintiff was observed by staff
and then admitted that he had been operating the vehicle without authorization. A
mobile/cellular telephone was found inside the vehicle, which Plaintiff acknowledged.
A Disciplinary Report by Dismas staff was then prepared and signed by the Plaintiff on
October 15, 2010. In addition, an Incident Repot was also prepared by Dismas on October 20,
2010, and forwarded to the Bureau of Prisons. Also on this day, Dismas advised the Bureau of
Prisons that Plaintiff was terminated from the residential re-entry center due to the accumulation
of the Incident Report, three prior Disciplinary Reports, and general noncompliance with
program rules and regulations. He was, therefore, taken into custody by the U.S. Marshall
Service and transported to the Federal Detention Center in Miami, where he remained until his
release 81 days later.
Plaintiff originally filed with this Court a Motion for Return of Property against Dismas
and Ana Gispert, the Director of the Dania facility on January 12, 2011. The Motion was
preceded by a certified letter from Dismas to Plaintiff dated January 5, 2011, advising him that
his belongings were being held at the facility awaiting someone to pick them up. As of current
day, the items remain at Dismas.
On March 28, 2011, Plaintiff filed a Complaint against Dismas, Ana Gispert, Derek
Thomas and LaShanda Adams (improperly named as Adams Lashota) seeking $3.1 million
dollars in compensatory damages and $500,000 in punitive damages for a total of $3.6 million
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 4 of 22
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
dollars against the Defendants. The Complaint contains 50 paragraphs of "factual allegations"
filed by a laundry list of four alleged Federal Theories of Recovery and six alleged state law
theories of recovery. The Defendants filed a Motionto Dismiss the Complaint which is pending.
No counterclaims are expected.
B. UNCONTESTED AND STIPULATED FACTS
None.
C. LIST OF LEGAL ELEMENTS AND DEFENSES ASSERTED
The Plaintiffs list of the legal elements for each claim is as follows:
a. First Amendment of the United States Constitution, defining the right to freedom of
expression;
b. Fourth Amendment of the United States Constitution, defining the right to be free from
unlawful seizure of his property or person;
c. Fifth Amendment of the United States Constitution, defining the rights to due process.
d. Eight Amendment of the United States Constitution, defining the right to be free from cruel
and unusual punishment.
d. Fourteen Amendment of the United States Constitution rights to procedural due process
pursuant to 42 U.S.C. 1983 ("Due Process")
e. Violation of state laws of the State Of Florida to include False arrest and imprisonment,
Assault and battery; Malicious Prosecution, Abuse of process, Negligence, and Gross
Negligence.
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 5 of 22
CASE NO.: 11 -20120-CIV-SEITZ/SIMONTON
f. Unlawful discrimination of race, national origin, ethnic groups and ancestry under the color of
state and federal law.
g. Infliction of Mental Distress,
h. Deliberate Indifference.
i. Negligence and Gross Negligence by failing to ascertain the medical condition of the Plaintiff
complaints of feeling ill.
j. Plaintiff brings this action for general, compensatory, and punitive damages; pre-judgment
interest, costs and Court fees; and other appropriate and just relief resulting from Defendants'
unlawful conduct.
Defendants have asserted the following defenses:
The Defendant has not raised defenses at this time. Instead, the Defendants filed a
Motion to Dismiss the Complaint. In the Motion to Dismiss, the Defendants alleged that the
Complaint fails to allege the specific facts and allegations necessary for any cause of action.
Instead the Complaint simply names a cause of action (i.e. abuse of process) without stating the
legal and factual elements for the cause of action. The Complaint fails to delineate which
Defendant is being sued for which specific cause of action. The Complaint also fails to allege
any cause of action against certain Defendants. Even if the factual allegations in the Complaint
are accepted as true, the Complaint fails to properly plead causes of action. The Complaint also
fails to allege any violations of Federal or State law by any Defendant. Without any proper and
sustainable Federal or State cause of action, this lawsuit should be dismissed.
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 6 of 22
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
D. WHETHER DISCOVERY SHOULD BE CONDUCTED IN PHASES OR
LIMITED TO CERTAIN ISSUES
The Parties do not believe that discovery should be conducted in phases or limited to
certain issues.
E. A DETAILED SCHEDULE OF DISCOVERY FOR EACH PARTY
Plaintiff and Defendants have attached their discovery schedules to this Report.
F. PROPOSED DATES AND DEADLINES
See attached Schedule on the form provided by the Court.
G. ESTIMATED LENGTH OF TRIAL
This case will be tried by a jury and is estimated to last 4-7 days.
H. LIST OF PENDING MOTIONS
Defendants filed a Motion to Dismiss which is not ripe as the Plaintiff has not presently
filed a response brief and Defendants have not filed a reply brief. The Motion to Dismiss was
filed on May 4, 2011. There are no other matters presently set before this court other than Joint
Scheduling Report and Motion to DismissAnd Incorporated Memorandum of Law in Support by
Dismas Charities, Inc. However, Plaintiff intends to file Motion to Strike Motion to Dismiss and
Incorporated Memorandum of Law in Support of the defendants.
I. UNIQUE LEGAL OR FACTUAL ASPECT REQUIRING
SPECIAL CONSIDERATION
Unknown at this time pending the determination of the Motion to Dismiss. The Plaintiff
is pro se.
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 7 of 22
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
J. STATEMENT OF NEED OR AGREEMENT TO REFER MATTERS TO
MAGISTRATE JUDGE
The Parties agree that the Magistrate can hear all non-dispositive motions. The Parties
agree that the District Court Judge should try this matter and rule on dispositive motions and pre
trial motions. The Parties agree that the District Court Judge shall be the one to try this matter in
front of a jury.
K. LIKELIHOOD OF SETTLEMENT
In light of the demands of the Plaintiff and settlement conversations to date, settlement is
unlikely. The Parties are willing to discuss settlement.
L. ANY LOCAL RULE 16.1B MATTERS
Unknown at this time pending determination of the Motion to Dismiss.
The parties certify that their Rule 26 disclosures will be made at the time of the
preparation of this Report.
The parties certify that their Rule 26 disclosures have been made at the time of the
preparation of this Report.
DATED: DATED:
TRAIAN BUJDUVEANU, PRO SEPro Se Plaintiff
5601 W. Broward Blvd.
Plantation, FL 33317(954)316-3828orionav(S),msn.com
TRAIAN BUJDUVEANU, PRO SE
,: V WDAVID S. CHAIET, ESQUIREAttorneys for DefendantsEisinger, Brown, Lewis, Frankel& Chaiet, P.A.4000 Hollywood BoulevardSuite 265-South
Holly\(954)dchaiettoetsingftfiavy.com
DAVID 57CHAIET, ESQUIREFla. Bar No. 963798
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 8 of 22
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 19th day of May, 2011, I electronically filed theforegoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoingdocument is being served this day on all counsel of record or pro se parties identified on theattached Service List in the manner specified, either via transmission of Notices of ElectronicFiling generated by CM/ECF or in some other authorized manner for those counsel or partieswho are authorized to receive electronically Notices of Electronic Filing.
Isi David S. Chaiet
DAVID S. CHAIET, ESQUIREFlorida Bar No. 963798
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 9 of 22
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
SERVICE LIST
Traian Bujduveanu v. Dismas Charities, Inc., et al.Case No..: 11-20120-CIV-SEITZ/SIMONTON
United States District Court, Southern District of Florida
Traian BujduveanuPro Se Plaintiff
5601 W. Broward Blvd.
Plantation, FL 33317
Tel: (954) 316-3828Email: [email protected]
10
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 10 of 22
Case 1:11-cv-20120-PAS Document 11 Entered on FLSD Docket 02/03/2011 Page 5 of 7
Case Management Deadline Worksheet
ft tJ.AU.5-V 5 .2QII Joinder of parties and amendment of pleadings.S/»0+Anh^3a2£JI Parties shall furnish opposing counsel with awritten list containing the names and addresses of ail fact witnesses intended to beOCPVaXMCJU^i wiied ^ tr.a| ^ Qn)y ^ w.messes ljsted shaU ^ permjtted tQ testjfy ^^ good cause IS shown ^ ^g 1S no prejudice to
opposing party. The parties are under acontinuing obligation to supplement discovery responses within ten (10) days ofreceipt orother notice of new or revised information.
/VtfthA-31 20ll Plaintiffmust furnish expert witness listto the Defendant, alongwith the summaries/reports required by Local Rule 16 l.K, and onlyUUUVUC^i-^mi AMe ^^ w.inesses sha|| be permiued tQ testjfy wjthin ^ fourteen day perjod thereat, Piaint.ff shall make .ts expertsavailable fordeposition by Defendant.
l)tfr/*W if\20li Defendant must furnish expert witness list to the Plaintiffalong with the summaries/reports required by Local Rule 16. l.K. and onlyW(USZaflfr_M>A*ii ^ ^^ w^cnes ^ ^ ^.^ ^^.^ wjthin ^ ^^ dfly perjod Pearler, Defendan, shall make its expertsavailable for deposition by Plaintiff.
X)ce.embcr llo,ZULi A"discovery must be completed.
Tw^l,- [u 2QJI All dispositive pretrial motions and memoranda of law must be filed. Aminimum of fifteen (15) weeks is required for the CourtVCLCOOOec JJA, fc*J. ^^ dispositive motions prior to filing of the joint pretrial stipulation. If no dispositive motions will be filed, clearly note
this fact in the Joint Scheduling Report.
A04jQLS±J& ^1 Mediation must be completed. (The parties should select the earliest date to maximize resolution of the case in amanner thatpromotes client and judicial economy.)
Jan ii/im 1U 20l2 (a) Joint pretrial stipulation must be filed pursuant to Local Rule 16.1 ,E. The pretrial stipulation shall include Plaintiffs non-b.nding^^ breakdown of damages with corresponding amounts; the witness lists shall be pared down to those witnesses the parties actually
intend to call at trial; and the exhibit lists shall identify the witness introducing each exhibit. The parties shall meet at least one(1) month prior to the deadline for filing the pretrial stipulation to confer on the preparation ofthat stipulation. The Courtwill not accept unilateral pretrial stipulations, and will strike, sua sponte, any such submissions; and
(b) Joint proposed jury instructions (for jury cases) or conclusions of law (non-jury cases) outlining (1) the legal elements ofPlaintiffs claims, including damages, and (2) the legal elements of the defenses raised; and
(c) Joint Summary ofRespective Motions in Limine must be filed. The Summary shall contain acover page providing thestyle ofthe case and an index ofthe motions in limine. The Summary shall also include for each evidentiary issue: (0 aone (1) pagemotion identifying the evidence sought to be precluded at trial and citing legal authority supporting exclusion; and (//) aone (I) pageresponse to the motion providing astatement of the purpose for which the challenged evidence would be offered and citing legalauthority in support ofadmission ofthe challenged evidence. The parties shall work together to prepare the Summary. Prior tosubmission ofthe Summary, the parties are encouraged to resolve evidentiary issues through stipulation.
tiALIAULli 2MI Final proposed jury instructions or findings of fact and conclusions of law must be submitted. (A courtesy copy shall be hand-JU -u-") "+ delivered l0 Chambers on 3.5 diskette, WordPerfect format), each party's list indicating each witness who will testify at trial, aone
sentence synopsis of the testimony, and in consultation with opposing counsel, indicate the amount oftime needed for direct andcross examination.
finrl\ ,iHil Pretrial conference. Usually 50 minutes are allotted for pretrial conference unless the parties or the Court, sua sponte. indicate agreater time is needed.
<WL^ >MZ Trial Date.llnk/UulA Date ofany other deadline the parties adopt as part oftheir case management plan, including Daubert or Markman hearing. In cases
the parties anticipate aMarkman hearing, counsel must provide dates for the exchange ofproposed disputed claim terms, and duedates for Plaintiffs brief and Defendant's brief.
[Attachment A]
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 11 of 22
Case 1:11 -cv-20120-PAS Document 11 Entered on FLSD Docket 02/03/2011 Page 6 of 7
TRAIAN BUJDUVEANU,
Plaintiff,
v.
UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDA
CASE NO. 11-20120-CIV-SEITZ/O'SULLIVAN
ANA GINSPERT and DISMASCHARITIES, INC.,
Defendant.
ELECTION TOJURISDICTION BY AUNITED STATESMAniRTB ATF JUDGE FOR FINAL DISPOSITION OF MOTIONS
In accordance with the provisions of 28 U.S.C. 636(c), the undersigned parties to the above-captioned civil
matter hereby jointly and voluntarily elect to have aUnited States Magistrate Judge decide the following motions and
issue a final order orjudgment with respect thereto:
1. Motions for Costs
2. Motions for Attorney's Fees
3. Motions for Sanctions
4. Motions to Dismiss
5. Motions for Summary Judgment
6. Other (specify)
Yes
Yes
Yes
Yes
Yes
*
(Date) (Signature-Plaintiffs Counsel)
(Date)
(Date)
(Date)
(Signatuir>*hrhTtTTfs Cdunsel)
(Signature-Defendant's Counsel)
(Signature-Defendant's Counsel)
[Attachment B]
No
No
No
No
No
<A>^°v*
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 12 of 22
Case 1:11-cv-20120-PAS Document 11 Entered on FLSD Docket 02/03/2011 Page 7 of 7
UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDA
CASE NO. 11-20120-CIV-SEITZ/O'SULLIVAN
TRAIANBUJDUVEANU,
Plaintiff,
v.
ANA GINSPERT and DISMASCHARITIES, INC.,
Defendant.
ELECTION TO JURISDICTION BY Atttmitfxi STATES MAGISTRATE JUDGE FOR TRIAL
Inaccordance with the provisionsof28 U.S.C. 636(c), the undersigned parties to the above-captioned
civil matter hereby jointly and voluntarily elect to have aUnited States Magistrate Judge conduct any and allfurther proceedings in the case, including TRIAL, and entry of final judgment with respect thereto.
(5^) (Signature-Plaintiffs Counsel)
(5^) (Signature-Plaintiffs Counsel)
(Date) (Signature-Defendant'st>
(5^) (Signature-Defendant's Counsel) iVs^-
\<*^*^
[Attachment C]
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 13 of 22
IN THE UNITED STATES DISTRICT COURT FORTHE SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
TRAIAN BUJDUVEANU,
Plaintiff,
vs.
DISMAS CHARITIES, INC., ANA GISPERT,DEREK THOMAS and ADAMS LESHOTA
Defendants.
DEFENDANTS DISMAS CHARTIES, INC., ANA GISPERT, DEREK THOMAS ANDADAMS LESHOTA'S DISCOVERY SCHEDULE
Defendants Dismas Charities, Inc., Ana Gispert, Derek Thomas and Adams Lashanda,
incorrectly identified as Adams Leshota (collectively "Defendants") pursuant to the Federal
Rules of Civil Procedure and the Southern District of Florida Local Rules, hereby file their
discovery schedule as follows:
Written Discovery:
Defendant Dismas propounded initial interrogatories and requests for production upon the
Plaintiff on April 28, 2011. Additional written discovery may be needed following the Court's
ruling on Defendant's motion to dismiss. Defendants hope to complete written discovery on or
before September 15, 2011, which will include requests for production, requests for admissions
and interrogatories.
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 14 of 22
11-20120-CIV-SEITZ/SIMONTON
Depositions:
Defendants intend to set the Plaintiff for depositions sometime in August 2011. Defendants
anticipate defending the depositions of Dismas, Gispert,Thomas and Lashanda. Defendants may
need to depose representatives of the United States Marshall's Service and Federal Bureau of
Prisons, along with the Plaintiffs wife and son. These depositions will likely be set in
September or October 2011.
Expert Discovery:
At this time expert discovery is not anticipated unless the Plaintiff presents a claim for physical
or mental injury. If so, then Defendants will need to retain an expert in the appropriate medical
specialty.
Respectfully submitted,
EISINGER, BROWN, LEWIS, FRANKEL,& CHAIET, PA.Attorneys for Defendants4000 Hollywood BoulevardSuite 265-South
Hollywood, FL 33021(954) 894-8000(954) 894-8015 Fax
BY: /S/ David S. Chaiet
DAVID S. CHAIET, ESQUIREFBN: 963798
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 15 of 22
11-20120-CIV-SEITZ/SIMONTON
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 19th day of May, 2011, I electronically filed theforegoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoingdocument is being served this day on all counsel of record or pro se parties identified on theattached Service List in the manner specified, either via transmission of Notices of ElectronicFiling generated by CM/ECF or in some other authorized manner for those counsel or partieswho are authorized to receive electronically Notices of Electronic Filing.
Isi David S. Chaiet
DAVID S. CHAIET, ESQUIREFlorida Bar No. 963798
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 16 of 22
11-20120-CIV-SEITZ/SIMONTON
SERVICE LIST
Traian Bujduveanu v. Dismas Charities, Inc., et al.Case No..: 11-20120-CIV-SEITZ/SIMONTON
United States District Court, Southern District of Florida
Traian BujduveanuPro Se Plaintiff
5601 W. Broward Blvd.
Plantation, FL 33317
Tel: (954) 316-3828Email: orionav(a),msn.com
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 17 of 22
IN THE UNITED STATES DISTRICT COURT FOR
THE SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
TRAIAN BUJDUVEANU,
Plaintiff,
vs.
DISMAS CHARITIES, INC., ANA GISPERT,DEREK THOMAS and ADAMS LESHOTA
Defendants.
DEFENDANTS DISMAS CHARTIES, INC., ANA GISPERT, DEREK THOMAS ANDADAMS LESHOTA'S DISCLOSURES PURSUANT TO RULE 26
OF THE FEDERAL RULES OF CIVIL PROCEDURE
AND CERTIFICATE OF INTERESTED PERSONS
Defendants Dismas Charities, Inc., Ana Gispert, Derek Thomas and Adams Lashanda,
incorrectly identified as Adams Leshota (collectively "Defendants") pursuant to the Federal
Rules of Civil Procedure and the Southern District of Florida Local Rules, hereby makes their
initial disclosures:
Traian Bujduveanu5601 W. Broward Blvd.
Plantation, FL 33317
PWMK at Dismas Charities, Inc.141 N.W. 1st AvenueDania Beach, FL 33004
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 18 of 22
Ana GispertDismas Charities, Inc.141 N.W. 1stAvenueDania Beach, FL 33004
Derek Thomas
Dismas Charities, Inc.141 N.W. 1stAvenueDania Beach, FL 33004
Adams Lashanda
Dismas Charities, Inc.141 N.W. 1stAvenueDania Beach, FL 33004
PWMK at the United States Marshalls Service
Federal Courthouse Square400 N. Miami Avenue, 6th FloorMiami, FL 33128
PWMK Federal Bureau of Prisons-Miami Detention Center
33 Northeast 4th Street
Miami, Florida 33101-9118
Wife and Children of
Traian Bujduveanu5601 W. Broward Blvd.
Plantation, FL 33317
11-20120-CIV-SEITZ/SIMONTON
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 19 of 22
11-20120-CIV-SEITZ/SIMONTON
1. Defendants hereby discloses the following documents which may support their defenses as
follows:
1. Dismas file on Mr. Bujduveanu.
2. United States Marshall's file on Mr. Bujduveanu.
3. United States Federal Bureau of Prison file on Mr. Bujduveanu.
4. Manuals and handbooks of Dismas for residents and other released inmates.
2. No other disclosures are required to be made by the Defendants pursuant to Rule 26 at this
time.
Respectfully submitted,
EISINGER, BROWN, LEWIS, FRANKEL,& CHAIET, PA.Attorneys for Defendants4000 Hollywood BoulevardSuite 265-South
Hollywood, FL 33021(954) 894-8000(954) 894-8015 Fax
BY: /S/ David S. ChaietDAVID S. CHAIET, ESQUIREFBN: 963798
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 20 of 22
11-20120-CIV-SEITZ/SIMONTON
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 19th day of May, 2011, I electronically filed theforegoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoingdocument is being served this day on all counsel of record or pro se parties identified on theattached Service List in the manner specified, either via transmission of Notices of ElectronicFiling generated by CM/ECF or in some other authorized manner for those counsel or partieswho are authorized to receive electronically Notices of Electronic Filing.
Isl David S. Chaiet
DAVID S. CHAIET, ESQUIREFlorida Bar No. 963798
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 21 of 22
11-20120-CIV-SEITZ/SIMONTON
SERVICE LIST
Traian Bujduveanu v. Dismas Charities, Inc., et al.Case No..: 11-20120-CIV-SEITZ/SIMONTON
United States District Court, Southern District of Florida
Traian BujduveanuPro Se Plaintiff
5601 W. Broward Blvd.
Plantation, FL 33317
Tel: (954) 316-3828Email: [email protected]
Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 22 of 22