Case 1:08-cr-20612-PAS
Document 143
Entered on FLSD Docket 01/26/2009
Page 1 of 3
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-20612-CR-SEITZ Magistrate Judge John J. O’Suliivan
UNITED STATES OF AMERICA vs. TRAIAN BUJDUVEANU, Defendant. ________________________________/
GOVERNMENT’S RESPONSE TO DEFENDANT TRAIAN BUJDUVEANU’S MOTION FOR EXTENSION OF TIME TO FILE EXPERT WITNESS DISCLOSURES AND RENEWED MOTION FOR EXTENSION OF TIME TO FILE EXPERT WITNESS DISCLOSURES The United States of America, through undersigned counsel, files this Response to Defendant Bujduveanu’s Motion for Extension of Time to File Expert Witness Disclosures, filed December 19, 2008 (D.E. 134), and Renewed Motion for Extension of Time to File Expert Witness Disclosures, filed January 20, 2009 (D.E. 140), and states: Defendant Bujduveanu requests an additional 30 days from the date of the Government's Disclosure of Expert Witnesses within which to disclose the Defendant's Expert Witness information, as well as an extension of the deadline for filing any motions to dismiss the Indictment. The United States has no objection to the requested extensions, and, therefore, the United States does not oppose the Defendant's Motions. Accordingly, based on Defendant's Requests, the Government respectfully recommends that this Court grant Defendant's Motions to the extent that the Defendant would have up to February 16, 2009, (30 days from the filing of the United States' Supplemental Notice of Expert Witnesses (D.E.
Case 1:08-cr-20612-PAS
Document 143
Entered on FLSD Docket 01/26/2009
Page 2 of 3
139)), within which to file Expert Witness Disclosures, and up to March 2, 2009, to file any Motion to Dismiss.
Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY
By:
/S/ Melissa Damian MELISSA DAMIAN ASSISTANT UNITED STATES ATTORNEY Fla. Bar No. 0068063 99 N.E. 4th Street, Suite 600 Miami, Florida 33132 Telephone: (305) 961-9018 Facsimile: (305) 536-4675
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Case 1:08-cr-20612-PAS
Document 143
Entered on FLSD Docket 01/26/2009
Page 3 of 3
CERTIFICATE OF SERVICE I hereby certify that on January 26, 2009, I electronically filed the foregoing with the Clerk of the Court by using the CM/ECF system which will send a notice of electronic filing to Michael Cohen, counsel for Defendant Traian Bujduveanu.
Melissa Damian Assistant United States Attorney
/S/ Melissa Damian Melissa Damian Assistant United States Attorney
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