Plaintiff's m otio n to supplem en t m otion to com pel second reouest for production of docum ents....

IN THE UNITED STATES DISTRICT COURT FORTHE SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1 1-20l20-ClV-SElTZ/S1M ONTON

FILED b D.C.

10 Y 11 i3 l11u. 2 j

STEVEN M I-ARtMOR: 1CLERK u b Dls-r cT. '.s. o. of Ck/i - MlkMI

TRAIAN BUJDUVEANU,

Plaintiff,

DISMAS CHARITIE :S IN V. ANA GISPERT,DEREK THOMAS and ADAM S LESHOTA

Defendants.

PLAINTIFF'S M OTION TO SUPPLEM ENT M OTION TO COM PEL

SECOND REOUEST FOR PRODUCTION OF DOCUMENTS. FIRST AN-DSECOND SET OF INTERROGATORIES

Plaintiff Traian Bujduveanu, Pro Se, hereinafter Movant, moves to supplementSecond M otion To Compel to include additional documents as follows:

1. BACKGROUND

1 . On September 17, 20l 1, After the M ovant has filed two M otions to Compel the

Production of Documents and Responses to the lnterrogatories, M ovant received an

envelope from the Defendants, which contained copies of some of the requested

documents in this case, some of them being copied more than once, to create the

impressions of massive amount of documents.On September l9, 20l 1, M ovant advised the Attorney representing the Defendants, of

the receipt of the documents and the fact that it represents incomplete answers. (SeeExibit A)

2. Defendants do not have to conceal important documents of this case if there isopenness and transparency on their part, and they feel they did not do anything

wrong, as stated before by their attorney. On the contrary, the M ovant believes that

there is a lot to hide in this case, and for good reasons. The people and the courts will

find the trtzth.

3. W hen requested to reveal a chart of a11 Dismas Charities employees at Daniafacility, the defendants vehemently denied. Not all Dismas Charities employees share

the same opinion, thus they can represent a great danger to the Defendants.

4. ldentities of the tllree Dismas Charities employees, two man and a women, that

have visited the M ovant at M iami FDC visiting area, and presented him with one page

fabricated Violation, Greatest Offense Code 108, was not revealed because in time

this false document was elaborated and today has several pages.

Case 1:11-cv-20120-PAS Document 61 Entered on FLSD Docket 10/04/2011 of 21

Of course a Polygraph test can shed light into this matter. lf the Defendants are

capable of concealing evidence, then they are capable of many other things.

5. Until today the M ovant does not exactly know the real identity of Lashanda

Adams. ls her name Lashanda Adam s, Leshota Adams, or Lashonda Adam s ?.

Attorney for the Defendants answered Lashonda Adams, and advise to look at thesignature on the responses to the interrogatories. However, even there, she signed

Lashanda Adams. (Exhibit B)

6. M ovant also asked the Defendants attorney to provide full names of the

defendants, including middle names. He never received an answer. (Exhibit C)

7. W ithout any information M ovant is not able to conduct an investigation and he

cannot put a case together.

8. ln a few interrogatories questions that they have answered, Defendants provided

and continues to provide only vague and misleading statements, in a calculated

attempt to mislead everyone. M ajority of the questions were not answered and only afew documents, which are convenient to the Defendants.. The Defendants have

signaled from the beginning, they do not intend to provide any documents to anyone.

Either they have a 1ot of courage or they have some very powerful people behind theirbacks.

9. Defendats have caused the M ovant halnn and humiliation by not allowing him toattend Church Services on Sunday, at a Greek-orthodox church on Sundays, located

16 minutes from the Dismas Charities halfway house, thus violating the M ovant's

First Amendment Rights. (Exhibit D)

l0. This is an example of a misleading statement by the Defendants: lnten-ogatories

Question No:l

Describe in details why Plaintiff, while at Dismas House, was never allowed to atlend

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 services even when he was on Home Confinement.

Response: t*-l-he Plaintiff was never denied the opportunity to attend religious services

that met Federal Bureau of prisons Guidelines.''

1 l . The M ovant would like to point put to this court and the defendants, that there are

no such guidelines set by the Federal Bureau of Prisons for the Halfway Houses, andftlrther than that M ovant would like to point out the fact hat United States

Government remains neutral when it comes to religion practices or distances. This is

explained in the Free Exercise Clause ofthe First Amendment.

l 2. The Bill of Rights guarantees that the govermnent can never deprive people in the

U.S. of certain f'undamental rights including the right to freedom of religion and to

free speech and the due process of law.

2


1 3. Interrogatorries Question No: 9

State whether or not the premises were equipped with video surveillance camera and,

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

surveillance camera and weather there are still tapes from the dates of the occurrenceand the week both before and after the occurrence.

Response: tt-fhe premises have surveillance cameras. The cameras are monitored bystaff. The tapes from the time of the alleged occurrences do not exisf'.

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

use any tapes. Instead data collected from the surveillance cameras is stored on a

computer hard drive in a digital format which acts as a Digital Video Recorder. TheOperating System as well as Remote Viewing software enables the user to monitor

the security system via computer, over the internet.

l 5. Data has been erased from the computer hard drive due to the fact that it

represented damaging evidence against Dismas Charities. Federal Bureau Of PrisonsRegulations requires that all data be archived and kept for 30 years.

l6. Second Set of Interrogatories Question No. 3

Describe in details the lim itations of Dismas Charities disciplinary discretions and thelimitations of sanctions they can apply on residents. Provide details of any serioussanctions required approvals, as required under the contract with the government.

Response: ttln response to this question, the Plaintiff is directed to the Resident

Handbook, which is available for inspection at Defendants' counsel's office.''

l7. First Set Of Interrogatories Question No.4

Etldentify each employee, agent ancl/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, ldentify his or herjob title and job functionbeing performed by that individual at the time of these incidents

, and the summary ofwhat knowledge the witness has ,and articulate their expected testimony.

''

Answer: ççAna Gispert, Adams Lashanda and Derek Thom as have information aboutthe Plaintiff s actions and noncompliance with nlles he agreed to abide by''

There several people aware of these events an in particular this outside private

contractor that was working inside the building, and complaining a1l the time about

intoxicated fumes in the building, generated by the smoke of synthetic marijuana, in a

way that a normal person could not breed. Such people will never be revealed ofcourse. However the defendants, employees and former residents


could be brought in the coul't, by consent or by force to testify and tell the truth and

nothing but the truth.M ovant strongly believes that if this Court desire to find the truth in this case, there

are tools and mean available. After all, the purpose of justice is to find the truth.

18. First Set Of lnterrogatories Question No.14

tlldentify a11 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, before the arrest and removal, in the emergency room at Broward Hospital.

Due to pain and liver discom fort of liver and abdomen.''

Answer: tfon 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

treatm ent.

Defendants were all fully aware of the Movant's medical conditions. (EXHIBIT E )

19. Paying the employees of Dismas Charities for favors and protection was a daily

activity at Dismas Charities in Dania. Former residents can be interviewed by the

legal authorities if the government desires to find the truth. If they have difficulties,

than the M ovant can point to quiet a few of them. lt would take an independent

investigation, to tind out that Dismas Charities runs a vicious cornlpted not for profit

corporation, hiding behind a wall of religion and God.

20. This is not the first time that such events have occurred at Dismas Charities,

although Defendants denied having any knowledge.

ttln Atlanta, Georgia, fonner Dismas Charities employee Terrence Clay received a

sentence of one year and one day in prison and a $1 ,000 fine for soliciting and takingbribes. Clay was employed by Dismas. a non-profit organization, at a halfway house

for federal prisoners. At least twice in 2007, Clay solicited and received $ 1,000 froma prisoner in exchange for certain favors.''

21 . M ovant cannot conduct any background investigation on any of the Defendants

because they categorically refuse to provide any infonnation. There is a lot into theDefendants background that needs to be revealed to this Court in order to better

understand who these people are in reality.

22. The matter of the fact here is that Defendants conspired to, and caused M ovant

incarceration when they knew in fact it was not legal.

23. Defendants have falsely imprisoned the M ovant by returning him to federal prison

on a charge that even if trtze, was not punishable by re-incarceration.

The possession of a cellular telephone, is not a violation serious enough to removeM ovant from the program. Beside, the M ovant never had a cellular telephone in his


possession, he never used one while at Dismas House, and the Defendants never

found one in his possession during the routine body search.

24. Dismas Charities does not have the legal authority to revoke a prisoner'sCommunity Custody, and there are no documents with respect to the Plaintiff's

Community Custody Revocation, issued by any legal authority.

25. The request shall be made through the Bureau of Community Sanctions per

Administrative Rule 5120-12-08, Rettzrn to the lnstitution for Administrative

Reasons.

26. The M ovant never attended a Disciplinary Hearing, in front of a Disciplinary

Committee while at Dismas House, for ret'urn or revocation of home confinement and

Community Custody and rettlrn to a federal prison in accordance with division (F) ofsection 2967.26 of the Revised Code.

27. Dismas Charities is nmning a Democracy set by the owners and employees to

benefit their private agenda. They do not respect any laws or rules and they go by

their own rules, speaking many times in the name of the state or federal government.

28. The M ovant was not sent to federal prison because he drove from home toDismas Charities on his reporting day. The M ovant was send to federal prison on a

false charge, Greatest Violation Code 108, stating that a cellular telephone was found

on the glove compartment of the vehicle that he drove to Dismas Charities, and it

could be used as a hazardous weapon, intended to do harms to others.

29. The vehicle was parked, and an illegal search was conducted without M ovant's

lcnowledge. The telephone was all the time in the glove compartment, for emergency

purposes, due to M ovant's mother medical conditions, which in blind andhandicapped. M ovant was not even aware of the existence of the phone in the glove

compartment of the vehicle that day, or he would leave the phone home.

30. A cellular telephone must be in the possession of the resident, and used on the

premises of the Building of a halfway house, without permission, in order to be

considered an offense. Even in that case, the possession of a telephone represents aminor offense, and a resident should not be sent to Federal Prison under the charges

of possession of a weapon.

31 . Unauthorized use or possession of telephone (including cellular phones andaccessories) without permission is listed ad a Low- Low/M oderate Offense Code,and the sanctions are listed below:

Low

a) Loss of privileges for 2 days (Phone, visits, passes, vehicle, smoking,television, recreation, outings, late nights)b) Change of quartersc) Removal from program/group activities for 2 daysd) Confiscate Contrabande) Extra Duty Hours


Monetary Restitution/community Service hours

Low/M oderate

a) Loss of privileges for 7 days (Phone, visits, passes, vehicle, smoking, television,recreation, outings, late nights)b) Change of quartersc) Removal from program/group activities for 7 days d)d) Contiscate Contrabande) Extra Duty Hours or additional household chores9 Cognitive-Behavioral lntervention (i.e. Thinking Reports)g) Monetary Restitmion/community Service hours

lI. LEGAL STANDARDS AND ARTICLES.

The CCC Contractor, theprovider ofhome Conhnement, shall develop a systemforhandling violations ofprogram rules, which meets the ''dueprocess '' criteria of l'IS///-v. McDonalti and includes provisionsfor dealing with minor inkactions ofprogramrlllesforprisoners in Home Confnement. (Dept. oflustice)

The Free Exercise Clause of the First Amendment gives you tlze right to worship or

not as you choose. The government can't penalize you because of your religious

beliefs.

The rights to Freedom of Religion and the free exercise thereof means:

a) The Freedom of Religion is an inalienable right.

b) The First Amendment provides for the Freedom of Religion for allAmericans.

c) The Free Exercise Clause provides that government will neither control norprohibit the free exercise of one's religion.

The government will remain neutral.

Title Vll's prohibition against religious discrimination may overlap with Title Vll'sprohibitions against discrimination based on national origin, race, and color. W here a

given religion is strongly associated - or perceived to be associated - with a certain

national origin, the same facts may state a claim of both religious and national origin

discrim ination. All four bases might be implicated where, for example, co-workerstarget a dark-skinned M uslim employee from Saudi Arabia for harassment because of

his religion, national origin, race, and/or color.

The attorney-client privilege is not intended to permit ttan attorney to conduct his

client's business affairs in secret.'' In re Grand Jury Subpoenas (Hirsch), 803 F.2d493, 496 (9th Cir. 1986). As the Second Circuit, in refusing to extend the privilegebeyond the protection of confidential legal communications, stated: ççlt seem s evident

to us that a broad privilege against the disclosure of the identity of clients and of fee


information might easily become an immunity for corrupt or criminal acts. gcitationomittedj.

Such a shield would create unnecessary but considerable temptations to use lawyersas conduits of information or of commodities necessary to criminal schemes or as

launderers of money. The bar and the system of justice will suffer little if a1linvolved are aware that assured safety from disclosure does not exist.''

Articles

The business of operating state or federal community re-entry programs for prisoners

has fast becomc one of the most prosting businesses in the country. The recent audit

(linked below) and news reports on Dismas Charities outline the mega -millions ofdollars each year Dismas earns in the community corrections industry.

ln fact, in 2009, Dismas Charities reported a total of $38,924,654 in revenues fromtheir combined federal and state contracts, donations, public contributions, grants and

membership fee's. Out of that, $27,376.067 came from the Federal Bureau of Prisonsand $2,539,050 came from prisoner's subsistence payments.Dismas's M ission Statement claims that they. . . ttprovide quality, cost-effective

,

community-based supervision, treatment services, and program s to individuals within

the criminal justice system and assist them in becoming positive, productive membersof their community.'' ln reality, their programs sound great on paper and in sales

pitches to the public.

In fact, just in 2009, Dismas official Bob Yates told citizens in Martinsburg WV, thatif allowed to open a pre-release facility in their neighborhood, that location would

only house ''low-risk offenders.'' W hich is the same mistnlth given to Tyler M ountain

residents in 2001.

Bottom line...lt appears on the surface that, Dismas Executives and Board members

may be to busy enjoying life on the taxpayer's dollars, instead of operatingcommunity based corrections facilities. It also appears some local level employees

and residents are enjoying themselves too.tW est Virginia News 20l 1)

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 lçstall tactics'' in

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

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

7


W HEREFORE, premises considered, the M ovant respectfully requests the Court 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 Plaintiff justly may be entitled.

Date: September 28, 201 l

Respectfully submitt d,M t r

/ &/ // ptrm pzt

TRAIAN BUJDUVEANU, PRO SE


*

CERTIFICATE OF SERVICE

1 hereby certify that on or about SEPTEM BER 28, 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, lnc.,

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

Ana GispertDismas Charities,lnc.

141 N.W . 1 St. Avenue

Dania, FL 33004-2835

Derek ThomasDismas Charities,lnc.

141 N.W . l St. Avenue

Dania, FL 33004-2835

Lashanda Adams

Dismas Charities,lnc.

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

David S. Chaiet,Esquire

Attorney for Defendants

4000 Hollywood Boulevard

Suite 265-South

Hollywood,FL 3302 l

EXECUTED ON THIS 28th DAY OF SEPTEM BER, 201 l

r ' f/r&/A# /,- Jr*TRAIAN BUJDUV AN ,U PRO SE

5601 W . BROW ARD BLVD.,

PLANTATION, FL 33317


#

EXHIBIT A


Windows Live Hotmail Print Message

(No Subject)

28/09/2011 17:05

Traian Bujduveanu ([email protected])

Mon 9/19/11 12:18 PM

David Chaiet ([email protected])

Dear Mr. Chaiet,

I have received an envelope from you on September 17, 2011, for which I kindly thank you.

The envelope contain some of the documents requested, which are copied,some more than one time.

However copies of important documents are missing. Also many of the requested interrogatories are notanswered.These are some of the documents and things that I need in order to put a case together:

1. Complete copies of the first two shots issued by Derek Thomas to me, Before the Greatest Violation Offense

shot 108. (that includes the shot that I have allegedly refused to sign)2. I would Iike the defendants to answer the questions regarding jobs held in the past 10 years.3. Answer if they have been arrested before and if they have any criminal record.

4. Answer if they have ever been involved in lawsuit before and in what capacity.

Mr. Chaiet, you have asked me these questions in your request and I did not have any objedions.W hen I asked the Defendants the same questions, the subject becomed immediately an issue of harassment.Apparently Mr. Chaiet, there are many things that the Defendants did not tell you.Mr. Chaiet, please be kind and understand that 1 need these information and more, in order to put a casetogether, and that the time for discovery is running short.If you and the Defendants continue at this rate, I have no choice but ti file a Motion For Summary Judgment.

Best Regards

Traian Bujduveanu


EXHIBIT B



RE: Defendants true indentity

2 8 / 09 / 2 0 1 1 1 7 : 0 1


Wed 9/21/11 10:37 AM

David Chaiet ([email protected])

I understand Mr. Chaiet. I was the one ''who got her name wrong'', and for the Iast 9 (nine) month her real

name and identity could not be reveal.

With aIl due resped Mr.chaiet, the interrogatories (question 1) reveal an objedion to that question, and nother real name, and you use her name, in the same interrogatories, as Lashanda Adams.Her signature Mr. Chaiet, reveals something other that her real identity.Mr. Chaiet, it took me nine moth to find out her alleged true name. Just make sure Mr. Chaiet that they aretelling you the truth.

Best Regards

Traian Bujduveanu

From: [email protected]: [email protected]: RE: Defendants true indentityDate: Wed, 21 Sep 2011 14:06:37 +0000

Lashonda Adams

It was ''revealed'' in her interrogatory responses and her signature Iine.

You were the one who got her nam e wrong. No one is concealing their identity.

From: Traian Bujduveanu [email protected])Sent: Wednesday, September 21, 2011 9:50 AM

To: David Chaiet

Subjeu: Defendants true indentity

Dear Mr. Chaiet,

Please be kind and reveal the true identit'y of the Defendants, and in particular that of one of the Defendants

that goes by the following names: Leshota Adams, Lashonda Adams and Lashanda Adams.

I very much dislike to be rude, but I need the real identities of the defendants.


EXHIBIT C



Defendants Identities

28/09/ 2011 17:01


Fri 9/23/11 4:52 PMDavid Chaiet ([email protected])

Dear Mr. Chaiet,

Please be kind and provide full name of each Defendant, including the middle name, if any.

Best Regards

Traian Bujduveanu


EXHIBIT D


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Traian BujduveanuAcnoN Rsotlss'rs ACTION REQUEST DETAILS

cAsE NoTEs Staff Adams, Lashonda

ctlExr INgo Client Bujduveanu, TraianCUIENT STAY INFo Number 3235

coNAwc'rs Requested7/29/2010 12:24 PMCLIENT n sKs Date

DISCHARGE status completed

DRM NG INFO j would Iike to attend Church Sevices

,every Sunday moming, at theEMPLOYMENT Reason Romanian Orthodox Church located on ST .Road 441 and PembrookeE

MRLOYMENT scHeouue Pines.

FtxEo MovEMEN'rs Previous You are only allowed to travel within 5ve miles of the facility forH

oMe coNF. Responses religious services.

Adams, Lashonda 7/29/2010 4:23:00 PMMOVEMENT REQUESTSResponseOFFENSES

OPEN MovEMeNTs

PAYMENTS

PROGRAMS

RK UIRED CHECKSSave Reset Cancel ReassignSTATUS HISTORY

StlsslsTENcE

SUMMARY

hup://dnnia-se>erTreshstG esidentschedules/ActioG equests/AcioO equestDeGils.asp... 9/7/201 1


Dismas Charities - FreshstartPage 1 of 1

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Traian BujduveanuM OVEMENT REQIJEST DETAILS

AcnoN REQUESTS ff Adams, LashondaStaCASE NOTES

Client Bttduveanu, TraianCLIENT INFO

Requested Date 8/4/201 0CLIENT STAY INFO

Requested For Date 8/8/2010CONTACTS

Locations GeneralCulEsT TASKS suxeu civ state ZipName Streetl

DISCHARGE yijlmore cj Izu 33::4Holy Cross 6232 HollywooDRlvlsG INFO church Street

EMPLOYMEKTRequested Out Time 9:00 AM

EMPLOYMENT SCHEDULEDuration 4 Hourls) 0 Minutels)F

lxEo MOVEMERTS

HOME CONF. Mode Of Transpoded by Family/FriendMOVEMENT REQUESTS W anspoftation VO

OFFENSE: Mode Of Transpoded by Family/FriendTransportation FromOPEN MOVEMENTS b

outd Church SeNices. Distance: 7.3 mi-al would like to attenPAYMENT: Reason 5 mins1

PROGM MSStatus DeniedR

EQUIRED CHECKS ith kn five milesing. Can yotl GI-Y afld 5ne a Chtlrch WGood evenSrAzus HISTORY oenial Reason j

je facility,of tSUBSISTEKCESUMMARY C8r1COl


Dism as Chadties - Freshstart Page l of l

MOVEMENT REQUEST DETAILS

Staff Adams, Lashonda

Client Bujduveanu, TraianRequested Date 10/6/2010

Requested For 1 0/10/2010Date

Locations GeneralName streatl Streetz City State Zip

Rom anian Orthodox Church 6232 Fillmore Street Hollywood FL 33024

Requested Out 10:00 AMTi

m e

Duration 3 Hourts) 0 Minutets)

Mode Of Transpoded by Family/FriendT

ranspodaticn To

Mode OfTranspodation Transpodsd by Family/FriendFrom

This is a request for ''Church Attendance'' Church is Iccated at 9.5 Mi and should take aboutReason 16 Minutes by car. There are ONLY two Odhodox churches in South Florida,and both are

located about 16 minutes away from my home.

Status DeniedDenial Reason You need to find a place of worhship within 5 miles of your home.

Cancel 1


#

EXHIBIT E


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Carlos E. Rodriguez, CMFederal Bureau of Prisons

40l North M iami AvenkleM iami. Florida 33 l 28

RE: Em ploym ent W aiver

Bujduveanu, Traian80655-004

Dear M r. Rodriguez,

Mr. Bujduveanu is a fifty. six year oId who arrived at Dismas Charities on 07-28-1 0. He isschedtlled to be released on 0 1 -03- l 1 . Mr. Bujduveantl has several clnronic medical conditions forwlnicll he is taken several medications. Nlr. Bujduveanu stlffers from Chronic Hepatitis C.Hypertension. Cirrlnosis of Liver, Diabetes Mellittls Type 2- Hyperlipidemia. and

Tllrombocy-topenia. At this timea I am reqtlesting that his employment reqtlirement be waived.

Thank you in advance and if you need any ftlrther information, piease feel free to contact me at

(954) 920-6558.

Sincerely.

'

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'

Lashonda Adams

Counselor

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Dere ' Thomas '

Assistal irector

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Plaintiff's m otio n to supplem en t m otion to com pel second reouest for production of docum ents....

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Transcript of Plaintiff's m otio n to supplem en t m otion to com pel second reouest for production of docum ents....