Pl aintiff's m otion to strike defendants' dism as charities,inc., ana gispert and adam s im handa's response brief in response to plaintiff's motion to compel responses to second

IN THE UNITED STATES DISTRICT COURT FOR

THE SOUTHERN DISTRICT OF FLORIDA

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

FILED by. D.C.

k

0CT () 3 2011

s'tEvEN M LARIMOREc ERK u b as'r cT.&

. o. of fL#. - MIXMI

TRAIAN BUJDUVEANU,

Plaintiff,

DISMAS CHARITIE Y lNC., ANA GISPERT,DEREK THOM AS and ADAM S LESHOTA

Defendants.

PL- AINTIFF'S M OTION TO STRIKE DEFENDANTS' DISMAS CHARITIES,INC.,

ANA GISPERT AND ADAM S IM HANDA'S RESPONSE BRIEF IN RESPONSE TO

PLAINTIFF'S MOTION TO COMPEL RESPONSES TO SECOND REOUEST FORPRODUCTION AND INTERROGATORIES

Plaintiff Traian Bujduveanu, Pro Se, hereinafter Movant submit this Motion toStrike Defendant's Dismas Charities, Inc., Ana Gispert, Derek Thomas and AdamsLashanda's Response Brief In Response To Second Request For production AndInterrogatories.

INTRODUCTION

0n August 05, 2011, Defendants seN ed the movant with First Request For

Production and First Set Of lnterrogatories. (EXHIBIT A)

W hen the M ovant copied som e of the questions from the documents mentioned

above and propounded the Defendats with the same questions, the issue becom e

a m atter of harassm ent of the alleged innocent Defendants, by the Movant. This

represent a clear example of the unorthodox tactics used by the Defendants.

lnnocent people do not use those kind of tactics.

0n September 28, 2011, Defendants tiled a Response In Brief To Plaintiffs

Motion To Compel Responses To Second Request For Production Of Docum entsand lnterrogatories.

1

Case 1:11-cv-20120-PAS Document 60 Entered on FLSD Docket 10/03/2011 Page 1 of 39

ARGUM ENTS

1. Defendants have no legal substance on their defense. A1l they have are

statem ents such as: ' Plaintiff does not understand'' ''Defendants did not do#

anything wrong'', ''this is irrelevant to this case'' ''it is intended for harassment''

In reality it is a 'fwish list'' of how the defendants would have liked this situation

to be, and not how it is. All they have is a number of fabricated documents, in

hurry, after the Movant filed a Lawsuit with the District Court.

2. 0n their Procedural Posture And Statement Of the case, paragraph 3,

Defendants stated: ...f'Due to Health issue, the Plaintiff was staying at his hom e

subject to terms and conditions of his halfway house release, which he agreed inwritinf'..a..''-rhese conditions included the Plaintiff's agreement not to drive withthe perm ission or consent of Dism as and not to possess contraband, including

cell phone.''

3. Defendants throughout this case, failed to state what would the punishment

be for the alleged minor violations. Further than that, Defendants have already

sanctioned the movant twice for the same violation, driving without

authorization, and punished him without any legal procedure. (Exhibit B)

4. Defendants have violated every other BOP regulation with respects toHalfway House Operations, Federal and State Laws.

5. 0n Paragraph 4, of the sam e page Defendants Stated:....''Dismas was required

to report Plaintiffs breach of his release to the federal Bureau of Prisons. The

Federal Bureau of Prisons then had the United States Marshall's Service return

the Plaintiff to the Federal Detention Center-Miami to serve out the last 68 daysof his federal prison sentence.''

6. Here the defendants have failed again to state clear the followings:

a) The date, result and decision of Dismas Charities Disciplinary commissionregarding the two alleged minor incidents.

b) If the two alleged incidents have occulted at the same time and in the sameplace.

c) A detailed description of how the search of the vehicle was accomplished.

d) The results of the investigation, decision and documents of the CommunitySanction Center, and or BOP, or USPO, served upon the Movant before he was

transported to FDC Miami.

e) What was the name and date of the B0P employee they have reported theviolation to, and he name of the B0P Person that has ordered the US Marshal to


remove the Movant from Dismas Charities to FDC Miami, because the document

presented is not com plete, nor does it have a signature of the person that has

issued the document. W as that a favor done by any Federal Employee to Dismas

Charities, because the whole affair was highly illegal ?

7. Defandants cannot and will not answer those questions because these events

never took place. Nor in a legal sense of the 1aw anyways. They have occurred in

the ''Dismas W ay''

8. 0ne other misleading statement repeated several times in the past by the

Defendants, is about US Marshalls investigation of the Movant. US Marshalls do

not conduct investigations such the alleged illegal possession of a cellulartelephone or unauthorized driving. Under the contract with the BOP, the US

Marshalls escort and transport prisoners from one facility another, and they

apprehend fugitives and return tem to justice or prison. Therefore the USMarshalls investigation of the movant does not exist.

9. A B0P Investigation does not exist. A US Marshall investigation does not exist.

A Community Sanction lnvestigation and a Decision to return the resident to FDC

Miami does not exist. No federal em ployee or agents want to be a part of this

case and they al1 keep the distance fro Dismas Charities in this case.

10. Defendants seems to go around the real issue of this case, in an attempt tocreate confusion, invoking reasons set by the Federal Bureau of Prisons when is

convenient, then stating that ''Dismas is not a part of the Federal Bureau of

prisons'' when is no longer convenient. Up to this moment, they have never cam e

with a straight forward statem ent such as: ''Movant was sent back to Federalprison because he drove a vehicle unauthorized'', or ''Movant was sent back to

Federal Prison because he possessed contraband items in his vehicle'', ...f' and the

punishment for this is Termination of the Program ''.

11. Defendants should be hold responsabile for Illegal Search and Seizure, thetorture of the m ovant during his stay at Dismas House, for Negligence and Gross

Negligence, for the discrim ination against him based on national origin, ethnic

group, religion, sex, and color, and the violation of a1l Movant's Civil Rights

guaranteed to him by the Constitution of The United States.

12. Defendants are calculated people, of a different class, with a ratherquestionable background which of course cannot be revealed because itrepresents an intent of harassment on the part of the Movant. This is not the first

time they engage in those kind of illegal acts and activities.

13. This case is not about a Vendeta of the Movant against the Defendats, or

money, as stated by the Defendants' Attorney. This case is about JUSTICE, and inorder for the Justice to be done, we first need to find the truth. Defendants do not


share the same opinion on this issue and they obstruct every attempt to discover

the truth.

14. If Lashonda Adams can sign under oath with a different nam e, then this Court

can imagine that she is capable of other things. (EXHIBIT C)

15. Defendants have m ade three lncident Reports, on three different dates, forthe same alleged incidents that have occurred in the same place and in the same

time. They were desperate. (EXIHIBIT D)

16. Everything was allowed inside the Dismas house, from using a cellular

telephone to smoking marijuana and take a11 kinds of drugs, but they had to pay.They had to pay the employees for protection. And who was controlling this

entire operation ? An investigation from the Justice Department could revealthat. A1l residents from that tim e and em ployees need to be questioned under

oath.

17. Derek Thomas is a very clever man. He would not do or take with his hand

anything that he could be held accountable for. Instead he had f'Front People''

that would do things for him, employees of Dism as Charities and residents.

18. Ana Gispert, Directot of Dismas Charities, was aware al1 the time of al1events, and she was the only person that was in charge to m ake a decision there.

She was just sitting behind the whole seen, having Derek Thomas, LshandaAdams and the rest of the team, running in the front. In fact it appears that she

does not like foreign people very much, having in fact a background of

discrimination against foreign people and religions. These people are not exactly

innocent as described by the Attorney for the Defendants.

LEGAL STANDARDS

The CCC Contractor, the provider of home Continement, shall develop a system for

handling violations of program rules, which meets the ttdue process'' criteria of W olf

v. M cDonald, and includes provisions for dealing with minor infractions of program

rules for prisoners in Home Confinement. (Dept. of Justice)

CONCLUSIONS

Defendants deliberately and calculated, failed to respond to the writtenDiscovery requests, and it looks as they are not willing to release all requested

docum ents and interrogatories necessary to put a case together, in a continuous

attempt to gain more time.


Defendants statements cannot be documented by any BOP, US Marshal, USPO,

Community Sanction Center, or any federal authority.

A halfway house should not be a place for torture and the employees should not

have to act in the nam e of state or federal government.

W HEREFORE, premises considered, the Movant respectfully request this court to

Strike Defendants Brief in Response to Plaintiff's Motion to Compel Responses to

Second Request for Production and Interrogatories.

Date: September 29, 201 1

Respectfully submitted, y

M p

/J m //t

TRAIAN BUJDUVEANU, PRO SE


CERTIFICATE OF SERVICE

I hereby certify that on or about SEPTEM BER 29, 20l 1 a true and correct copy of theforegoing document was served upon the following via the United States Postal

Service, First Class M ail:

Dismas Charities, Inc.,l41 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 ThomasDismas Charitiesrlnc.

141 N.W . 1 St. Avenue

Dania, FL 33004-2835

Lashanda AdamsDismas Charities,lnc.

l41 N.W . l St. Avenue

Dania ,FL 33004-2835

David S. Chaiet,Esquire

Attorney for Defendants

4000 Hollywood BoulevardSuite 265-South

Hollywood,Fla 33021

EXECUTED ON THIS 29th DAY OF SEPTEM BER, 20l 1

..< - , ?

/ / 6Dk kTRAIAN BUJDUVE NU, PRO SE

5601 W . BROW ARD BLVD.,

PLANTATION, FL 33317

6


EXHIBIT A


IN THE UNITED STATES DISTRICT COURT FORTHE SOUTHERN DISTRICT OF FLORIDA

CASENO.: II-ZOIZO-CIV-SEITZ/SIM ONTON

TRAIAN BUJDUVEANU,

Plainliff,

5/ S .

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

Defendants.

/

FIRST REOUEST FOR PRODUCTION

In accordmwe with the applicable Florida Rules of Civil Procedure, Defendant, DISM AS

CIIARITIES, m C. by and through undersigned counsel, requeAs the Plaintiff, TRAIAN

BUJDUVEANU, to produce for inspection and copying all documents listed on the attached

Schedule ''A'' pursuant to Rule 34 of the Federal Rules of Civil Procedure at the offices of

EISINGER, BROW N, LEW IS, FRANKEL & CHAIET, P.A., 4000 Hollywood Boulevard, Suite

265 South, Hollywood, FL 33021 within tltirtpfive (35) days from the date of service hereof

unless otherwiqe ordered by the Court. This reqttest is intended to cover a1l docllnaents in the

possession of the Plaintiff, TRAIAN BUJDUVEANU, or subject to his/her custody and control,

specifically including, but not limited to, documents of tbird persons in the possession, custody

and control of the Plaintiff


DEFINITIONS

As used in this request, the following definitions shall apply herein:

The term ''document'' is intended to be comprehensive alld to include, without

limitation, all original writings of any nature whatsoever, copies and draAs which, by reason of

notes, changes, initials, or identification marks are not identical to the original and a1l non-

identical original copies thereof In al1 cases where original and/or non-original copies aze not

available, ''documentl' also means identical copies of original documents artd copies of non-

identical copies.

The tenn ''document'' includes, but is not limited to, correspondence, memoranda,

contracts, leases, agreemenl, irtvoices, credit memoranda, cfedit files, records, data-sheets,

purchase orders, tabulations, reports, bills of lading, evaluations, work papers, summaries,

opinions, journals, statistical records, sales reports, Gnancial reports, checks, notes transcriptions,

telegrams, teletypes, telex messages, recording of telephone calls and other communications

(including, but not limited to, notes, notations, memoranda and other writings of or relating to

telephone conversations and conferences), mlnutes and notes of transcriptions of all meetings

and other com mlmications of any type, microfilm dictobels, tapes or other records, logs and any

other information which is stored or carried electronically, by means of computer equipment or

otllerwise, and which can be retrieved in printed or graphic form.

The term ''relating to'' includes refeaing to, embodying, in cormection witlq

con= enting on, responding to sharing, describing, concerning, analyzing, reflecting or

constituting.

Tenns in the plural include the singular and terms in the singular include the

pllzral.

2


''Person'' means any individual, natmal person, pa> ership, frm, association,

organization, corporation, business tmst or governmental or public, legal or business entity.

CERTIFICATE OF SERW CE

1 HEQEBY CERTIFY that a true copy of the foregoing has been furnished

by U.S. mail to: Traian Bujduvearm, Pro Se Plaintiff, 5601 W. Broward Blvd., PlanGtiona FL

33317; this '3y/ day of , 201 1.

EISINGER BROW N, LEM S, FM NKBL.v CHAIEY, P.A.Atlorney for Defendants4000 Hollywood Boulevard

Suite 265-SouthHollywood, F 33 1

Telephone: .#5 94-8000Facsimile: : ) 94-8015BY:

DAVID . IET, ESQUIREFlorida B o. 963798


SCHEDULE $;A''

''Statements'', within the meaning and definitions in Rule 1.280(b), Florida Rules

of Civil Procedm e, of the Defendmlts, the agents of the Defendants and employees, and

independent witnesses, as well of the Defendants, bearing on the knowledge of facts relevant

and material to the claim and defenses in the instant litigation, to be produced prior to any

depositions of any said persons.

A11 of the tangible things within the possession, custody, or control of the

Plaintiffs herein upon which the claimn and defenses herein are based, and specifically, but not

limited to, writings, drawings, graphs, charts, photographs, movies, slides, film, video tape,

phonograph records arld other reoording devices, instruments, equipment, real and personal

property, objects, goods and/or vehicles or operations which are the subjects of the claims and

defemses herein, so that same may be inspected, copied, tested, measured, surveyed, and

photographed, pursuant to Rule 1 .350, Florida Rules of Civil Procedure.

Al1 documents and items specifed in your Answers to Interrogatories as coming

withn Rule 33, Federal Rules of Civil Procedttre, exercising the option to produce records in lieu

of summazy based on said records alld reports.

All statements obtained by you, or yottr attorneys, of the Defendants, the agents,

servants and employees of Defendants, either recorded or written, at the time of or subsequent to

the subject accident or incident described in the Complaint.

Copies of any agreem ents entered into by you or on your behalf with any other

person, finu, or corporation whom you contend may have some liability expostlre for the subject

accident or incident.

4


6. The complete criminal file, Zcluding any plea agreements or dismissals,

following the Plaintifrs m'rest and release.

7. Any Nvritten communications between the Plaintiff and Defendant concerning

the accident or conditions that caused the dlmages alleged in the Complaint that is the subject

matter of this lawsuit.

S. Any and a11 documents showing or evidencing your dam ages alleged in the

Complaint.

9. Any a11 documents supporting your claim and damages for the alleged

deprivations of you First Amendment Rights.

Any a11 documents supporting your claim and damages for the alleged

deprivatiops of you Fourth Amendment Rights.

Any a11 documents supporting yotlr claim and damages for the alleged

deprivations of you Fifth Amendment Rights.

12. Any a11 documents supporting your claim and damages for the alleged

deprivations of you Eighth Amendment Itights.

13. Any al1 documents supporting your clnim and dnmages for the alleged

deprivations of you Fourteenth Amendment Righl.

Any all docllments supporting your claim and damages for false arrest and

imprisonment.

15. Any a1l documents supporting your claim and dmnages for assatllt and battery.

Any al1 documents supporting your claim and damages for malicious prosecution,

Any a11 documents supporting your claim and dnmages for abuse of process.1 7.


18. M y a11 doclzment.s supporting youz claim and damages foT negligence and gross

negligence.

6


IN THE UNITED STATES DISTRICT COURT FOR

THE SOUTHERN DISTRICT OF FLORIDA

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

TRM AN BUJDUVEANU,

Plaintiff,

VS.

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

DEREK THOMAS and ADAM S LESHOTA

Defendants.

NOTICE OF SERW CE OF G TERROGATOQIES

Defendant DISM AS CHARITIES, m C. , by and through it.s undersigned atlorney, and propounds

lnterrogatories to the Plaintiff, TRAIAN BUJDUVEANU, numbered 1 through 19, to be answered under

oath, in writing, within the time prescribed by law and in accordance with the Federal Rules of Civil

Procedure.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true copy of the foregoing has been furnished by U.S. mail

to; raian Bujduveanu, Pro Se Plaintiff, 5601 W. Broward Blvd., Plantation, FL 33317; this. . . day of :.q. 2(j1 1 .

EISINGER BROW N, LEW IS, FRANKEL

& CHAIV, P.A.Attomey for Defen ants -4000 Hollm ood Bo leva

Suite 265-Sou$Hollywood, F 330

Teleghone: 4) 4-8000Facslmile: 95 94-8015

BY:

DAVI S. AIET, ESQUIREFlorida BarNo. 963798


IN THE CIRCUIT COURT OF THE1 1th JUDICIAL CIRCUIT IN ANDFOR M IAMI-DADE COUNTY, FLORIDA

CASENO: 11-06751 CA 11

TRAIAN BUJDUVEU U

Plaintiff,

VS.

CONTN NTAL GROUP, INC.,TURNBERRY ISLE

CONDOM W IUM ASSOCIATION, IN C.and PAUL EPSTEIN

Defendants

/

FIRST SET OF INTERROGATORIES

Defendant DIS> S CIG RITY S, m C. by and throagh its tmdersigned counsel, hereby

serves the following First Set of lnterrogatories upon Plaintiff, TRAIAN BUJDUVEANU.

DEFINITIONS

As used in tbis request:

The term ''document'' is intended to be comprehensive and to include, without

limitation, al1 origlnal writings of any nature whatsoever, copies and drafts which, by reason of

notes, charlges, initials. or identification marks are not identical to the original and a11 non-

identical original copies thereof. ln a1l cases where original and/or non-original copies are not

available, ''document'' also means identir-ql copies of original docllments and copies of non-

identical copies.


The term ''doctunent'' includes, but is not limited tos correspondence, memoranda, credit

files, records, data-sheets, pmchase orders, tabulations, reports, bills of lading, evaluations, work

papers, summaries, opinions, joumals, statistical records, sales reports, financial reports, checks,

notes tzanscriptions, telegrnms, teletypes, telex messages, recording of telephone calls and other

communications (including, but not limited to, notes, noGtions, memoranda and other writing of

or relating to telephone conversations arld conferences), minutes and notes of transcriptions of al1

meetings and other communication of any type, microfilms, dictobels, tapes or other records,

logs and any other information which is stored or carried eleckonically by means of computer

equipment or otherwise, and which can be retrieved in printed or graphic form.

2. The term ''relating to'' includes refening to, embodying, in cormection with,

commenting on, responding to sharing, describing, concem ing, analyzing, reflecling or

constimting.

3. Terms in the plural include the singular and terms in the singular include the

plm-al.

''ldentity'' when used with reference to a natural person, means state:

(a) His 111 nnme and address, or if the present is not known, his last known

address'.

The full name and address of each of his employers, each corporation of

which he is an officer or director, and each business in which he is a principal;

(c) His present (or, if the present is not known, his lmst 14.:10w11) position, and

his position or position at the time of the act to which the interrogatory answer relates', and

(d) Such other information sufficient to enable Defendants to identify the

Pe1'SOn.

3


''Identify'' when used * 11,1 reference to any entity olher than a naiural person,

m eal'ls :

(a) State the full name of the entity, the type of entity (e.g., comoration,

partnership, dc.), the address of its principal place of business, its principal business activity, and

if it is a corporation, the jurisdiction under the laws of which it has been organized, and the date

of such organization;

(b) Identify each of the entities, officers, directors, shreholders, or other

principals; and

State whatever other information exists wbich concenu the existence oT

identity of the entity.

''ldentify'' when used with reference to a document or cmnmunicatiom means

state-

(a) Its nature (e.g., letter, telegrnm, memorandum, chart, reports, study), dates,

author, date and place of prepmation, and the rmme and address of each addressee, if there is an

addressee;

(b) The identity of each signer to the document or communication;

The title or heading of the document of commtmication;

(d) Its substance;

(e) lts present (or, if the present is not known, the last known) location atld

custodian',

(9 The identity of each person to whom a copy was sent and each date of its

receipt and each date of its transmittal or other disposition by or on bchalf of (i) any Plaintiff and

4


(ii) any other person (naming such other person), who at any time either received or transmitted

or othem ise disposed of such document or commtmication and each copy thereof; and

(g) The circumstnnces of each such receipt and each transmittal or other

disposition, including identitication of the person from whom received and the person to whom

transmitted.

Plaintiff may, in lieu of identifying any document attach a true copy of such

document or communication as an exhibit to its answer to these inquiries along with an explicit

reference to the inquiry to which each such attached docllment or communication relates.

8. ''ldentify'' when used with reference to any oral transaction or communication,

m eans:

(a) State its nature (e.g., telephone call, conversation in person, etcl);

(b) State the date artd place thereof;

State the identity and address of each person participating therein, or

present during, or witness to any part thereof; and

(d) Identify each document in which such transaction or communication was

recorded, described or referred to.

''ldentify'' when used with reference to a contract means:

(a) State the date and place it was made;

(b) State the name and address of each party thereof;

State in terms, including but not limited to, the performarme to be rendered

by each party;

(d) State whether the performance was rendered; and

State whether there has been any litigation with reference to said contract.


''Identify'' when used with references to a sutement or representation, means:

(a) St.ate the date and place it was made;

(b) State whether the statement or representation was oral or written;

(c) the statement or rcpresentation was oral, identify the oral

communication in which it was made; and

(d) If the statement or representation was in writing, identify the document in

whioh it was made; indicating the page and line on which the statement or representation was

made and the opening and closing words of the statement or representation.

1 1. ''Identify'' when used in any other context than hereinabove set forth, means:

(a) Describe the act, word, situation, event, etc. (and/or conduct, course of

action of any natw e whatsoever, including, without limitation, any failure to act, to engage in

any conduct, or to pursue any comse of action), to be identifed as fully as possible, and identify

each document or communication in which such act, word, situation, event, conduct or course of

action, etc., was recorded, described and referred to.

ln answering each inquiry, identify each document or commllnication or act (a)

related upon in the preparation of each answer; or (b) which forms a11 or part of the basis for that

answer; or (c) which corroborates the answers or, (d) the substance of which forms all or pat't of

the answer.


INTERROOATORJES TO PLAW TIFF

(Ifansweringfor anotherperson or en/fysanswer with respect to thatperson (p?- entity

unlen ofherwfJe stated)

1) W hat is the name and address of the person answering these interrogatories, and,if applicable, the yerson's oficial position or relationship with the party to whom theinterrogatories are dlrected?

2) List the nnmes, business addresses, dates of employment, and rates of payregarding all employers, including self-employment

, for whom you have worked in the past 10

years.

3) List a1l former names and when you were known by those nnmes. State a1laddresses where you have lived for the past 10 years

, the date you lived at each address, yourSocial Security Number, yottr date of birth, and, if you are or have ever been married

, the nameof your spouse or spouses.

4) Have you ever been convicted of a crime, other than any juvenile adjudication,which under the 1aw lmder which you were convicted wms ptmishable by death or imprisonment

in excess of one year, or that involved dishonesty or a false statement regardless of the

punishment? If so, state as to each conviction the specific crime and the date and place ofcolwiction.


5) W ere you suffering from physical infirmity, disability, or sickness at the time ofthe incident described in the complnint? If so, what was the nature of the infirmity

, disability, orsickness?

. 6) Did you consllme any alcoholic beverages or take any drtzgs or medicationswithin 12 hoars before the time of the incident described in the complaint? lf so

, sute the typeand amount of alcoholic beverages, drugs or medication wltich w'ere consllmed, and when andwhere you conslzm ed them.

7) Describe in detail how the incidentts) described in the complaint haypened,including a11 actions taken by you to prevent the incidentts). Please describe and explam whyyou did not see the alleged dangerous condition (the removed cover) before the accidentoccurred.

8) Were you chrged with any violation of 1aw (including any regulations orordinances) arising out of the incident descnbed in the Complaint? If so what was the nature ofthe charge; what plea or answer, if any, did you enter to the charge; what court or agency heardthe charge; was any written report prepared by anyone regarding this charge, and if so, what isthe name and address of the person or entity that prepared the reporq do you have a copy of thereport, and wms the testimony at any trial, hearing or other proceeding on the charge recorded inany manner, and, if so, what is the name and address of the person who recorded the testimony?

8


9) Describe each injury and element of damages that you are claiming in tMs caae,specifying the nature of the injury and damage.

10) List each item of expense or dnmage, other than loss of income or earningcapacity, that you claim to have incurred as a result of the incident described in the complaint,giving for each item the date incurred, the name and business address of the person or entity towhom each was paid or is owed, and the goods or services for which each was inclvred.

1 1) Do you contend that you have lost any income, benefhs, or enrning capacity in thepast or futtzre as a result of the incident described in the complaint? If so, state the nature of theincome, benefits, or eam ing capacity, and the amotmt and the method that you used in computingthe amount.

12) Has anything been paid or is anything payable from any third party for thednmages listed in your answers to these interrogatories? lf so, state the nmolmts paid or payable,the name and business address of the person or entity who paid or owes said nmotmts, and whichof those third parties have or claim a right of subrogation.

13) List the nnmes and business addresses of each physician who has treated orexnmined you, and each medical facility where you have received any treatment or examination

for the injtuies for which you seek damages in this case; and state as to each the date of treaa entor exnmination and the injury or condition for which you were examined or treated.

9


14) List the names and business addresses of al1 other physicians, medical facilities,or other health cm'e providers by whom or at which you have been exnmined or treated in thepast 10 years; and state as to each the dates of examination or treatment and the condition or

injury for which you were exnmined or treated.

15) List the nnmes and addresses of all persons who are believed or known by you,your agents, or yottr attorneys to have any knowledge concerning any of the issues in this

lawsuit', and specify the subject matter which the witness has knowledge.

16) Have you heard or do you know about any statement or remazk made by or onbehalf of any party to this lawsuit, other than yourself, concerning any issue in the lawsuit? lfso, state the nnme and the address of each person who made the statement or statements, the

nnme and address of each person who heard it, and the date, time, place and substance of eachstatem ent.

17) State the name and address of each person known to you, your agents, or yourattorneys, who has knowledge about, or possession, custody, or control of, any model, plat, map,

drawing, motion picture, videotape, or photograph pertaining to any fact or issue involved in this

controversy; and describe as to each what item such person has, the name and address of theperson who took or prepared it, and the date it was taken or prepared.

10


l 8) Do you intend to call arïy expert witnesses at tlle trial of this case? lf so, state asto each such witness the nnme and business address of the witness, the witness' qualifications as

an expert, the subject matter upon which the witness is expected to testify, the substance of thefacts and opinion to which the witness is expected to testify

, and a stmunary of the grotmds foreach opinion.

19) Please state if you have ever been a party, either plaintiff or defendant, in alawsuit other than the present matter, and, if so, state whether you were plaintiff or defendant, they

. nature of the actiom and the date and court in which suit was filed.


Affiant, Traian Bujduveanu

STATE OF FLORIDA )COLTNTY OF )

Traian Bujduvemm, being duly sworn, deposes and says that the attached Answers aretnze mAd correct to the best of his/her knowledge, information and belief.

NOTARY PUBLIC

tprint, Type or Stnmp CommissionedName of Notary Public)

Personally Kmown 0R Produced IdentificationTlrpe of ldentification Produced:

SW ORN TO AND SUBSCRIBED before me this day of , 2011.

M y commission expires:


EXHIBIT B


' ' Blsm as Charities, lnc.

Disci Iina Re ort

. .- - -- - - . .- .- - .-qesjdent-Name ' - R'e'gisteerxtlmbur--- FuUlEt - -'B/dUVCZIRU

, Traian 80655-004 Dania Beach

Rule # ate of Alleged Offense Status309

10/:3/2010 Pre-Release

' Description and Com m ents: ''-'

Mr. Bujduveanu was observed operating a motor vehicle on 10/13/2010. Mr. Bujduveanu isnot authorized to o erate a m otor vehicle without the a roval of the Director

.

#'

gkg y. p j,y rResident's Com m ents:

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.

s a t e .;. j o

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Reporting Stal Sig ' l Date

. J q.-- h I-- t to) -Presenting Staff Signature

. Datel LY ( 6-' - î Ui

l

lnvestigation -.

Resident's Com ments:

Number of DRs to date: 2 Number of DRs for this rule: O

Action Taken:'

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dciz07intRevised 04/01/04

Page 1 of 1


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# Z


Dismas Charities, Inc.

Disci lina Re ort

Fj. k u jjjsResident jame egister umber cBujduveanu, Traian 80655-004 Dania Beach

Rule # Date of Alleged Offense Status309 violation 10/18/10 Sentenced

Descri tion and Com ments:

Resident attempted to have an unauthorized visit in the resident parking Iot. Mr. Bujduveanu

was not given permission to have any items dppped off to him nor did he receive permission

to have a visit today. Resident is on restrictio'i for 3 weeks and cannot have visitation withinthose 3 weeks.

Resident's Com ments'.

Resident Signature Date

Repoding Staff Sig ture ' -. Date p ..a' - .. ' c .;. .7 ' -- - l r-z ' lé-/'

Presenting staff ign tu .$'''' Date

lo /' /0

Investi ation:


Number of DRs to date: 3 Number of DRs for this r'ule:

Action Taken:

60 days extra duty (Iight duty), no visitation until further discussion with Director, AssistantDi

rector and Counselor. No weekend movemnts until fudher notice.

Rgsidmnt Signature Date Staft Signature Date.

..... ,. ... .!;j ..L,qu -. . . .----.- - yg fc . r <

dci2O7int Page 1 of 1Revised 04/01/04


BP - 52 0 5 . 07 3 INCIDENT REPORT ( CCC ' S ) CDFRMAUG 9 9

U . S . DEPARTMENT OF JUST I CE F E D E K- A.=T B E AU O F P R I S O N S

1 . N:- a m e t,'a F- C C C :D 7 S Nl ! 7. Q C V' 7. D 'I* T T r' Q D % N - > -> V' Q r' = - '17 ' 'C - - n c 1 d e n t Q 1 D (3 r t. . .. .... . .u- .- . .. - .. - w , .*'= k m. b. -. . .u .r1 . a r (: .. 2. .. . - .

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Buj d uvean u , Traian 8 O ov 5 r'o - c o 4 10 / 1 3 / 1 O l : O o'am

6. Dqace of Tancident 7. Comoonent 8. Tvre of Offender

D i I 5 m a s c in. - a r i- t i e s , V'Q-P.C P r e *IJ v e 1 e a s e S e n t e n c e

9. ZnCidCR2'. POSSeSSYOR manufacturel Or introduct-ion Of a hazardous YOO1-. / Violatinq a ConC'itionof a communi-tv orogram. Code : lG8, 309

1 1 . D e s c r i o t i o n o f I n c i d e n t. ( D a t e : 1 0 / l 3 / 1 O T i m e : 1 : 0 0 o m s t a 1z* f b e c o m e a w a r e o f i n c i d e n t )

On L 0 / l o's / 1 O I ob s e rved o F- 6- en de r Bu j duve anu wa 1 ki ng t owards h 1- s 5rœ h -5 c l e ( b lue Ford Exo lorer t ruck )'c h- -e r e s i de n t o a rk i ncr 1 c t . h 'e t 'ne n go t i nt o t h-- e ve h 1 c l e and b a c ke d t h e ve'n i c 1 e i n t o a pa rk .l' ngG 17 a C2 e . T- a s k e d h i s c oun s e 1 o r i T- h e w a G a u t lo .o r i z e d t o d r i ve a n d G h e s t a t e d t ha Q h e '4a s no t: a n d t 'n a tP- t i s '*l i f e w a s a u t h0 r -5 z e d t o t r a n s x) o r t h i m . A r e -sr i e w o '5- h i s c- 1 7 e c c) r r o b o r a t e d t h a t h e w a s n o t

au t hor i z ed t o dr 1 nu-e . O F- f ender Buj duveanu h a.c- d r i ven t he vehi c 1 e u= rom h i s home t. o the f ac 6- 1- i ty . Q---i sccuns e 1 0v- went out s ide and brought c 6- F- ender B uj dumzeanu ins ide wh--ere we cues Q a.C oned h--i m about '4'nY h--ew a s d r -5 v i n = ,4 q- t hou t a u t b - o r i z a t i o n . S t a f 6- e xo 1 a 1 n e d t o H.- z -5 m t h a t i t w a s a g a i n s t t 1n- - e r'ta 1 e s =u c r 'n i m t c

oo e ra t e a veh 1 c 1 e w i t ln--ou t p e rm 1 s s i on and ,aœ s e a rc in e d 'n i s Tr eh-- i c 1 e . D u r 1 nc t 'n e s e a rc 'n s t af f 6- ound a n'anau tc 'nor i z ed c e 7 l oh one ( 'oq ack Nl Io =u c ro3.a -1 n o'F 'F end e r Bu ZJ duqzeanu ' s nam e ) and a b 1 ack Moicoro la c a rc) h o ne c hara e r . (7 ff end e r B ud < uv e anu i s t he re 6- o r e i n v i o 1 a t i on c =u c ode o'h o 9 : -q' i o 5 a t 5 ncz a c ond i t- i on o=u a

C Ommun i t7 y D roc ram and c od e 3 O 8 : D- o s s e s s i on manu F- ac t u r e , c r i n t rod uc t i on o f a 1n- -a z a rdou s t cc 7- .

1 - .1/. Signarure of rtinq Emolovee Date & Time 13 Nam .. - inted)L , --' /13/10 2:3opm Dere' homas Assistant Dz vtorx w J>l-- * -*

z. ,- 4 IRC 1. in 1: veiorz IVe re () >- Clve L E en e r y . - ' w u - u-'h' . 1' . . . .wx .m r x'

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'

. 1 U ' r QJ.. j p. .sz, uy7 . v ;xq Time zncident Report oeliver d' 1k.. ik''dlk...,e *3 '''''''lf' 'J *e

O eO'-I -'3 1

Record Copy - Central File Record; Copy DHO; Copv Inmate fter UDC Action; Copy Inmate WiLhin 24 H rs OfPart I Freparat ion( Th.L s Form May Be Rep â icated Via WP j &. place s EP - 2 0 5 . 0 V 3 Of PZLAR 9 4


EXHIBIT C


Windows t-ive Hotmail Print Message. h

' . g.

RE: Defendants true

01/10/2011 13:09

indentity

David Chaiet ([email protected])

Wed 9/21/11 10:06 AM

Traian Bujduveanu ([email protected])

Lashonda Adams

/

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

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

From: Traian Bujduveanu (mailto:orionav@msn,com)Sent: W ednesday, September 21, 2011 9:50 AM

To: David Chaiet

Subjeu : Defendants true indentity

Dear Mr. Chaiet,

Please be kind and reveal the true identity of the Defendants, and in paoicular that of one of the Defendants

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

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

Best Regards

Traian Bujduveanu


.,.

x%;#.t' . k, , s-l4

.#kz,zs.F

DIS S CH ARITV S, m C.

LASHANDA ADAM SCounselor

141 N.W . lst Avenue * Dania Beach, FL 33004(954) 920-6558 * Fax (954) 920-6566

ladams@dis> s.comwww.dismascharities.org


.. 6 '..N

. !L. i ' Jk

LASHANDA ADAM S

STATC olr Fl-om oh . . )coux'rv oF % '4..uu à )

Lashanda Adams, being

true and correct to the bestduly swom , deposes and say thatof his/her knowledge, information

the attached Answers are

and beli f.

!C'q .

. Xq .

; *

/ ï? / èt . j

NO jUM ublfc state of gjooda. k . oava cjjaje,

q, >'tr. vs uy commasjop ojngasaxr#o, w+ nxx

res ozyg.ygyjg

(Print, Type or Stamp CommissionedName of Notary Public)zr

Personally Known OR Produced ldentifkation

Type of Identilication Produced: )

f'pk //'- ctlllSWORN TO AND SUBSCRIBED before me this day of ,

M y comm ission expires'.

13


EXHIBIT D


Dism as Charities, Inc.

Disci lina Re ort

- - --.- . -- - .- - .-qssjdent-N am'e - 'A cgister-Nrlm bB'r- -- FBrihit - - -

Bujduveanu, Traian 80655-004 Dania Beach

Rule # Date of Alleged Offense Status3O9 10/13/2010 Pre-Release

Description and Com ments: r.x. #

Mr. Bujduveanu was observed operating a motor vehicle on 10/13/2010. Mr. Bujduveanu isnot authorized to o erate a motor vehicle without the ap roval of the Director.

#

'/ pjt z' : ,-Resident's Comm ents:

.'

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.z e j p j,y, s a t a

y y o yResident Signature e

/ k ' itVeo ,'z, ' I o - l rRepoding Staff Sig l Date

. ) %.-. h %- $ qoPresenting Stafï Signature Date

/ Cr- $ $ -- t Ui

'

Investigation-.

Resident's Comm ents:

Number of DRs to date: 2

Action Taken:

rtqzn ccr'-?- c4 ' p/c''.zt e,moa*'or' . a we..,t .J vx'r. q/w,-/ d' 1zs'. f-6) -? P'e'hh c'w,4,.. ,

A/ rn t..J v . ' p. z c rc --fhob ..'@ ; . o y. ss.' -.z'. c--yhm .-q ,. - r.

Number of DRs for this rule: 0

Resident signature Dale kgnature , DateZ>l r-'-.z

'

N . l c -r1-rD

- J/ 3 P* 4J 'X-s- t vs-/g.r-.$ &

dci207intRevised 04/01/04

Page 1 of 1


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' '


Dismas Charities, Inc.

Disci Iina Re ort

Resident ûame Register ùumber VciityBujduveanu, Traian 89.j5:-004 Dania BeachRule # ' ' Date of Alleged Offense N j Status309 violation ' 10/18/10 Sentenced

3 Description and comments: .'-e

Resident attempted to have an unauthorized visit in the resident parking Iot. Mr. Bujduveanuwas not given permission to have any items dropped of'f to him nor did he receive permissionto have a visit today. Resident is on restrictio'i for 3 weeks and cannot have visitation withinthose 3 weeks.


Resident Signature Date

Reporting Staff Sig ture - - .-x Date . .-s

, y.; . --- / D . fzj-/a

Presenting Staff ign tu .$''- Date/o /, /0

I nvesti ation :

Resident's Comm ents'.

Number of DRs to date: 3 Num ber of DRs for this rule:

Action Taken:

60 days extra duty (Iight duty), no visitation until further discussion with Director, AssistantDirector and Counselor. No weekend movemnts until further notice

.

Resident Signature Date 3ta% Signature Date'

c ,.,z' . . g w jp ... y. 4t,s ,, --- - / ,

dci2O7int Page 1 of 1Revised 04/01/04


89-5205.073 INCIDENT REPORT (CCC/S) CDFP/!AUG 99U .S. DEPARTMENT OF JUSTICE FEDERAL BUREAU OF PR-ISONS

1 . K. ï a. m e t.'.n '5- C C C :D T. S Nl I.I.S C =. .w' 7..R I T T. Q' S D Q N T W B. '7' D. m' F D a r t T - *.s n .''J 1 d e n 2 Q.' . e C) (:) r t>. z . - .. r. .... E.

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B uj d u v e a n u T ra 1 a n 8 O o'- 5 b- - c () 4 1 o / 1 -'a / 1 0 7- : Q bn 'arc

6 . D 1 ac e o 6 T nc 1 d e nt *1 Cocm one nt 'Ro . 'T- voe oF O F F ervd e r

D-ismas charities, iqp-c Pre Release Sentence

9. T-nciden=u: Possession manufacture, or introduction of a hazardous tool. / Violae-inc a condition

of- a community orogram . Code: 108, 3O9l 1 . D e s c r i p t i o n o f T- n c i d e n t ( D a t e : 1 () / 7- 3 / 1 0 T i m e : 1 : 0 0 o m s t a =u f b e c (D m e a * a r e o L- 1 n c i d e: n r- )

t'Dn l () / l an / 1 0 ob s e n-ed of f ende r Buj duveanu %4z 1 'K inqt h e r e s -5 de n t p a rk 1 ng 1 o t . hx f e t 'n e n g o t i n t o t b - e ve h i c 1 e

Goace. T- asked his counselor if he was authorized to'n i s '.l i f e ,4 a s a u t b .o r 1 z e d t o t r a n s p c r t h i lrt . .t- r ev i e %a o 12

a. u t hx - o r i z e d r. o dr i n,- e . O f f e n de r Bu j duv e a nu h. a d d r -5 v e n(2 oun s ..:a l 0'r wen t ou t s i de and brough t c -6 f ende r B u j duveanu'&. a s d r -5 v 1 n g w 5- t 'n o u t a u t h o r 1 z a t 1 o n . S t a f 6- e x'o 1 a 1 n e doc e r a t e a ve hi c 1 e 'a 1 e. b-ou t oe x'mi s s 1 on and w e s e a rc hed

u n a u t H- - o r i z e d c e 1 1 c' h c n e ( b 1 a c k Nl ! o t o r o 1 a i n o -.F f e n d e ro h o r : e c b - a r cw e r . O f f e n d e r B u d a u v e a n u i : t h e r e f o r e i n- J(7 ommun i ty rroc ram and cod e 3 f2 8 : Do s s e s s ion manuf ac t ure ,

t o w a r d s h i s v e h- - i c 1 e ( b l u e F o r d 7'- x o 1 o r e r t: r u c 1, - ) i nand bac ked t he veh i c 1 e i n t o a pa rk - .1 ng

' r 1 v e a nd s h e s t a t. e d t in a t 'n e w a s n c t a n c1 t h a tC1 - .-

hs s f i 7 e corroborated thar he was notc' h e v e h .1 c 1 e z- r o l'n h 1 s h o ra e t o t n' , e =u a c 1 l i t y . -77: .1 s

' ns i de wh ere we cue s 'c i cned h i m about why he2 -- .

-

t o h 1 m. t h a t C t w a s a g a. i n s t t h e r'u: 7 e s == o r h i rn t oh 1 s v e h -5 c l e . D u r -6 n a t 'n e s e a r c h s 'c a f f f o u n d a n

B u ZJ d uqz e a nu ' s n arm e ) a nd a b 1 a c 'K Mo t o r c) 1 a c a r' o 7 a *- 1 o n o z- c o d e om () 9 . M i o 1 a '- i n c a c o n d i t i (D n o 'Tu e.VQ

- u . u

cr introduction oF- a hazardous r-oc-7.

1 -l 73 . SiqnaLure of .' e rting Employee Date & Time 13 . Name & Title ( Pri nted)J -œ & .œ A'x

7 x,-''- 1.0./ 13/ 10 2 : 3 Opm Derek ...T.n' omas ASs i stant Di c' =N. yuw f . ..-.

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o aO''T .> 1

R.ec'ord Copy - Central File Record ; Copy - D31O ; Copy - rnm f ter IJDC Act ion ; Cop'.z - Inmate Wi-thi.n 2 4 Hours Of

Part I preparat ion( 'rà: i s Form May Be Rep l icat ed vi.a :./P ) av-' *


Technology

Pl aintiff's m otion to strike defendants' dism as charities,inc., ana gispert and adam s im handa's response brief in response to plaintiff's motion to compel responses to second