Case 1:08-cr-20612-PAS
Document 164
Entered on FLSD Docket 02/18/2009
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No: 08-20612-CR-SEITZ/O’SULLIVAN
UNITED STATES OF AMERICA ) ) Plaintiff, ) vs. ) ) TRAIAN BUJDUVEANU, ) And ) ORION AVIATION CORP. ) ) Defendant. ) ____________________________ ) EXPERT WITNESS DISCLOSURE COMES NOW the defendant, TRAIAN BUJDUVEANU and ORION AVIATION CORPORATION, by and through Undersigned Counsel, respectfully files its Expert Witness Disclosure. At the present time the Defendant reasonably expects to offer the expert testimony of William L. Clements in the fields of the International Trading in Arms Regulations, the United States Munitions List, and the Office of Foreign Assets Control regulations. William L. Clements will provide testimony concerning the scope and breadth of the International Trading in Arms Regulations. He will testify that the International Trading in Arms Regulations is ambiguous, the United States Munitions List does not enumerate specific military parts, rather, it only says items designed for a military application are subject to the International Trading in Arms Regulations. Mr. Clements will testify as to the types of actions
Case 1:08-cr-20612-PAS
Document 164
Entered on FLSD Docket 02/18/2009
Page 2 of 3
that companies take to ensure their compliance with International Trading in Arms Regulations. Mr. Clements will further testify that the manufacturer is an indispensable party to a State Department decision that a particular item is on the United States Munitions List, because only the manufacturer knows what the item was originally designed for. He will testify that there can be purely commercial parts included in military aircraft, so the fact that an item is going into a military item is suggestive, but not dispositive of the question as to whether the part is a defense article listed on the United States Munitions List. William L. Clements' curriculum vitae is attached as Exhibit A. Additional expert witnesses will be divulged in the near future. The defense is diligently in the process of interviewing expert witnesses regarding military aircraft parts and the manufacturing of aircraft parts. The names of those experts will be promptly disclosed once they are identified.
Respectfully submitted, s/ *Michael B. Cohen, Esq.* _________________________ Michael B. Cohen, Esq. Florida Bar No: 210196
Case 1:08-cr-20612-PAS
Document 164
Entered on FLSD Docket 02/18/2009
Page 3 of 3
CERTIFICATE OF SERVICE IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing was furnished via CMECF this February 18, 2009 to all applicable parties.
Respectfully submitted, s/ *Michael B. Cohen, Esq.* _________________________ Michael B. Cohen, Esq. Florida Bar No: 210196 6400 North Andrews Ave Ste 460 Fort Lauderdale, Florida 33309 Ph (954) 928-0059 Fax (954) 928-0829