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Case 1:08-cr-20612-PAS

Document 126

Entered on FLSD Docket 12/03/2008

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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 ) ) Defendant. ) ____________________________ ) UNOPPOSED MOTION FOR MEDICAL TREATMENT COMES NOW, the defendant, TRAIAN BUJDUVEANU, by and through undersigned counsel respectfully requests this Honorable Court convene a hearing and conduct an inquiry about the necessity of the defendant’s receipt of certain medications that he is not presently receiving at the Federal Detention Center in Miami. As grounds therefore, your undersigned would state the following: 1.

Traian Bujduveanu suffers from Hepatitis C, sclerosis of the liver, diabetes

and ascytes. 2.

Mr. Bujduveanu is in urgent need of certain medications to treat these

conditions which can become life threatening. 3.

These medications include pegasys, interferon, and ribovirin.

4.

Undersigned Counsel has been informed by Mr. Bujduveanu that he is not

receiving these medications at the Federal Detention Center.


Case 1:08-cr-20612-PAS

5.

Document 126

Entered on FLSD Docket 12/03/2008

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Your Undersigned therefore, respectfully moves for this court to convene

a hearing to inquire into the failure of the Federal Detention Center to properly treat Mr. Bujduveanu for his conditions. 6.

Your Undersigned has spoken to Assistant United States Attorney, Melissa

Damian, who has no objection to this motion. WHEREFORE, based on the foregoing, Undersigned Counsel requests leave of court to file this motion out of time since he was recently retained by the defendant.

Respectfully submitted, s/ *Michael B. Cohen, Esq.* _________________________ Michael B. Cohen, Esq. Florida Bar No: 210196

CERTIFICATE OF SERVICE IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing was furnished via CMECF this December _____, 2008 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


doc 126