GOVERNMENT’S RESPONSE TO DEFENDANT TRAIAN BUJDUVEANU’S EMERGENCY MOTION FOR FURLOUGH

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Case 1:08-cr-20612-PAS

Document 107

Entered on FLSD Docket 11/03/2008

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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 EMERGENCY MOTION FOR FURLOUGH The United States of America, through undersigned counsel, files this Response to Defendant Bujduveanu’s Emergency Motion for Furlough, filed October 30, 2008 (D.E.105). For the reasons that follow, this Court should deny the defendant's Motion. Defendant Bujduveanu, who is presently being held at the Federal Detention Center in pretrial detention, has filed an Emergency Motion seeking permission from the Court for a brief furlough to visit his ailing mother. Authority to grant furloughs to federal inmates is solely within the jurisdiction of the Director of the United States Bureau of Prisons. 18 U.S.C. § 3622. The United States Courts are, therefore, not the appropriate venue for such a request. The defendant should direct his request to the United States Bureau of Prisons.


Case 1:08-cr-20612-PAS

Document 107

Entered on FLSD Docket 11/03/2008

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Conclusion For the foregoing reasons, the United States respectfully requests that this Court deny Defendant Bujduveanu’s Emergency Motion for Furlough.

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 107

Entered on FLSD Docket 11/03/2008

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CERTIFICATE OF SERVICE I hereby certify that on November 3, 2008, 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 Mark Eiglarsh, counsel for Defendant Traian Bujduveanu.

Melissa Damian Assistant United States Attorney

S/ Melissa Damian Melissa Damian Assistant United States Attorney

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