joint sheduling report

8/6/2019 Joint Sheduling Report

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IN THE UNITED STATES DISTRICT COURT FORTHE SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 11-20120-CIV-SEITZ/SIMONTON

TRAIAN BUJDUVEANU,Plaintiff,

vs.

DISMAS CHARITIES, INC., ANA GISPERT,DEREK THOMAS and ADAMS LESHOTA

Defendants.

JO INT SCHEDUL ING REPORT

The Plaintiff, Traian Bujduveanu and Defendants Dismas Charities, Ana Gispert, DerekThomas and Adams Lashanda, by and through undersigned counsel, and pursuant to the Court's"Order Requiring Joint Scheduling Report", hereby submit this Joint Scheduling Report.

A . STATEMENT OF THE F AC TS A ND OF THE C ASE

Plaintiff Traian Bujduveanu, a former Federal Inmate, has filed a Complaint againstResidential Reentry Center (RRC)/HalfWay House, Dismas, and three of its employees, Gispert,Thomas and Lashanda .

PLAINTIFF'S SUMMARY OF CONTENT ION & RELIEF SOUGHTThis is an individual action brought by Plaintiff Traian Bujduveanu, a former federal

inmate, against (i) Dismas Charities, Inc., owner and operator of Dismas Charities HalfwayHouse in Dania Beach, Florida, at which Plaintiff was sent by the Federal Bureau Of Prisons,after he was released from Federal Custody to Community Custody;(ii) individual DefendantsAna Gispert, Director of Dismas Charity Halfway House in Dania Beach, Florida, Derek

Case 1:11-cv-20120-PAS Document 29 Entered on FLSD Docket 05/19/2011 Page 1 of 22


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Thomas, Assistant Director of Dismas Charities halfway house in Dania Beach, Florida, andLashanda Adams, Counsel of Dismas Charities halfway House in Dania Beach, Florida. ("An

inmate must be assigned COMMUNITY custody status, prior to transfer to a CCC")(PS5100.08)

Plaintiffs claims against Dismas Charities, Inc. and the Defendants, allege violations ofIllegal Search and Seizure, False Arrest, Unlawful Imprisonment, Violation of ConstitutionalRights, Unlawful Discrimination ofRace, National Origin, Ethnic Groups and Ancestry, ReverseDiscrimination under the color of state and federal law, Discriminatory Harassment, IntentionalInfliction of Mental Distress, Deliberate Indifference, Negligence and Gross Negligence, byfailing to ascertain the medical condition of the Movant complaints of feeling ill.

Plaintiff sues Defendants Ana Gispert, Derek Thomas and Lashanda Adams both in theirpersonal capacity and their official capacity as employees ofDismas Charities, Inc. for violationof Plaintiff s :a. First Amendment of the United States Constitution, for Freedom of Speech and retaliation;b. Fourth Amendment of the United States Constitution, defining the right to be free fromunlawful seizure of his property or person;c. Fifth Amendment of the United States Constitution, defining the rights to due process.d. Eight Amendment of the United States Constitution, defining the right to be free from crueland unusual punishment.d. Fourteen Amendment of the United States Constitution rights toprocedural due process pursuant to 42 U.S.C. 1983 ("Due Process")



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e. Violation of state laws of the State Of Florida, to include False arrest and imprisonment,Assault and battery; Malicious Prosecution, Abuse of process, Negligence, and Gross

Negligence.f. Unlawful discrimination of race, national origin, ethnic groups and ancestry under the color ofstate and f ede ra l l aw .

g. Infliction ofMental Distress,h. Deliberate Indifference.

i. Negligence and Gross Negligence by failing to ascertain the medical condition of the Plaintiffcomplaints of feeling ill.

Plaintiff brings this action for general, compensatory, and punitive damages,prejudgment interest, costs and Court fees, and other appropriate and just relief resulting fromDefendants ' un lawfu l conduct .

DEFENDANTS ' SUMMARY

Defendants contend that Plaintiff, Traian Bujduveanu, was transferred from FederalCorrectional Institute Coleman Low to Dismas Charities, Inc.'s Dania Facility on July 28, 2010.Dismas' Dania facility is a Residential Re-Entry Center for federal inmates, such as Plaintiff, toserve out a remaining percentage of their sentence before release. Plaintiff was serving a 35month sentence for conspiracy to violate the International Emergency Economic/Power Act, theIranian Transactions Regulations, and the Arm/Export Control Act. Plaintiff was scheduled forrelease from Dismas on January 3, 2011.

On or about September 28, 2010, Plaintiff was transferred to home detention. Heremained on home detention until October 15, 2010, at which time he was returned to the Dania



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facility for violating a condition of his home detention and the possession, manufacture, orintroduction of a hazardous tool. The underlying incident occurred on October 13, 2010, where

Plaintiff was discovered driving an automobile without proper authorization. The vehicle waslocated at the Dania facility and was subsequently searched after Plaintiff was observed by staffand then admitted that he had been operating the vehicle without authorization. Amobile/cellular telephone was found inside the vehicle, which Plaintiff acknowledged.

A Disciplinary Report by Dismas staff was then prepared and signed by the Plaintiff onOctober 15, 2010. In addition, an Incident Repot was also prepared by Dismas on October 20,2010, and forwarded to the Bureau of Prisons. Also on this day, Dismas advised the Bureau ofPrisons that Plaintiffwas terminated from the residential re-entry center due to the accumulationof the Incident Report, three prior Disciplinary Reports, and general noncompliance withprogram rules and regulations. He was, therefore, taken into custody by the U.S. MarshallService and transported to the Federal Detention Center in Miami, where he remained until hisrelease 81 days later.

Plaintiff originally filed with this Court a Motion for Return of Property against Dismasand Ana Gispert, the Director of the Dania facility on January 12, 2011. The Motion waspreceded by a certified letter from Dismas to Plaintiff dated January 5, 2011, advising him thathis belongings were being held at the facility awaiting someone to pick them up. As of currentday, the items remain at Dismas.

On March 28, 2011, Plaintiff filed a Complaint against Dismas, Ana Gispert, DerekThomas and LaShanda Adams (improperly named as Adams Lashota) seeking $3.1 milliondollars in compensatory damages and $500,000 in punitive damages for a total of $3.6 million



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CASE NO.: 11-20120-CIV-SEITZ/SIMONTONdollars against the Defendants. The Complaint contains 50 paragraphs of "factual allegations"filed by a laundry list of four alleged Federal Theories of Recovery and six alleged state lawtheories of recovery. The Defendants filed a Motionto Dismiss theComplaint which is pending.No counterclaims are expected.

B. UNCONTE ST ED AND S TI PU LA TED FACT S

None .

C. L IST OF L EGAL ELEMENT S AND DEFENSE S ASSERTED

The Plainti ffs list of the legal elements for each claim is as follows:a. First Amendment of the United States Constitution, defining the right to freedom ofexpression;b. Fourth Amendment of the United States Constitution, defining the right to be free fromunlawful seizure of his property or person;c. Fifth Amendment of the United States Constitution, defining the rights to due process.d. Eight Amendment of the United States Constitution, defining the right to be free from crueland unusual punishment.d. Fourteen Amendment of the United States Constitution rights to procedural due processpursuant to 42 U.S.C. 1983 ("Due Process")e. Violation of state laws of the State Of Florida to include False arrest and imprisonment,Assault and battery; Malicious Prosecution, Abuse of process, Negligence, and GrossNegligence.



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CASE NO.: 11 -20120-CIV-SEITZ/SIMONTONf. Unlawful discrimination of race, national origin, ethnic groups and ancestry under the color ofstate and f eder al l aw .

g. Infliction ofMental Distress,h. Deliberate Indifference.

i. Negligence and Gross Negligence by failing to ascertain the medical condition of the Plaintiffcomplaints of feeling ill.j. Plaintiff brings this action for general, compensatory, and punitive damages; pre-judgmentinterest, costs and Court fees; and other appropriate and just relief resulting from Defendants'unlawful conduct .

Defendants have asserted the following defenses:The Defendant has no t raised defenses at this time. Instead, the Defendants filed a

Motion to Dismiss the Complaint. In the Motion to Dismiss, the Defendants alleged that theComplaint fails to allege the specific facts and allegations necessary for any cause of action.Instead the Complaint simply names a cause of action (i.e. abuse of process) without stating thelegal and factual elements for the cause of action. The Complaint fails to delineate whichDefendant is being sued for which specific cause of action. The Complaint also fails to allegeany cause of action against certain Defendants. Even if the factual allegations in the Complaintare accepted as true, the Complaint fails to properly plead causes of action. The Complaint alsofails to allege any violations of Federal or State law by any Defendant. Without any proper andsustainable Federal or State cause of action, this lawsuit should be dismissed.



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D. WHETHER DISCOVERY SHOULD BE CONDUCTED IN PHASES ORL IM I TED TO CE R TA IN ISSUES

The Parties do not believe that discovery should be conducted in phases or limited tocer ta in i ssues.

E. A DETAILED S CHEDUL E OF DISCOVERY FO R EACH PART Y

Plaintiff and Defendants have attached their discovery schedules to this Report.F. PROPOSED DA TE S A ND DEADL INES

See attached Schedule on the form provided by the Court .G. E S TIMA TED L ENGTH OF TR IAL

This case will be tried by a jury and is estimated to last 4-7 days.H. LIST OF PENDING MOTIONS

Defendants filed a Motion to Dismiss which is not ripe as the Plaintiff has not presentlyfiled a response brief and Defendants have not filed a reply brief. The Motion to Dismiss wasfiled on May 4, 2011. There are no other matters presently set before this court other than JointScheduling ReportandMotionto DismissAnd Incorporated Memorandum of Lawin Support byDismas Charities, Inc. However, Plaintiff intends to file Motion to Strike Motion to Dismiss andIncorporated Memorandum ofLaw in Support of the defendants.

I. UNIQUE LEGAL OR FACTUAL ASPECT REQUIR INGSPEC IAL CONS IDERAT ION

Unknown at this time pending the determination of the Motion to Dismiss. The Plaintiffis pro se.



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CASE NO.: 11-20120-CIV-SEITZ/SIMONTONJ. STATEMENT OF NEED OR AGREEMENT TO R EF ER MATTERS TO

MAGI STRATE JUDGE

The Parties agree that the Magistrate can hear all non-dispositive motions. The Partiesagree that the District Court Judge should try this matter and rule on dispositive motions and pretrial motions. The Parties agree that the District Court Judge shall be the one to try this matter infront of a jury.

K . L IKEL IHOOD OF SET T LEMENT

In light of the demands of the Plaintiff and settlement conversations to date, settlement isunlikely. The Parties are willing to discuss settlement.

L . AN Y LOCAL RULE 16.1B MATTERS

Unknown at this time pending determination of the Motion to Dismiss.The parties certify that their Rule 26 disclosures will be made at the time of the

preparation of this Report.The parties certify that their Rule 26 disclosures have been made at the time of the

preparation of this Report.DATED: DATED:

TRAIAN BUJDUVEANU, PRO SEPro Se Plaintiff5601 W. Broward Blvd.Plantation, FL 33317(954)316-3828orionav(S),msn.com

TRAIAN BUJDUVEANU, PRO SE

,: V WDAVID S. CHAIET, ESQUIREAttorneys for DefendantsEisinger, Brown, Lewis, Frankel& Chaiet, P.A.4000 Hollywood BoulevardSuite 265-SouthHolly\(954)dchaiettoetsingftfiavy.comDAVID 57CHAIET, ESQUIREFla. Bar N o. 963798



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CASE NO.: 11-20120-CIV-SEITZ/SIMONTONCERT IF ICATE OF SERVICE

I HEREBY CERTIFY that on the 19th day of May, 2011, I electronically filed theforegoing documentwith the Clerk of the Court using CM/ECF. I also certify that the foregoingdocument is being served this day on all counsel of record or pro se parties identified on theattached Service List in the manner specified, either via transmission of Notices of ElectronicFiling generated by CM/ECF or in some other authorized manner for those counsel or partieswho are authorized to receive electronically Notices of Electronic Filing.

Isi David S. ChaietDAVID S. CHAIET, ESQUIREFlorida Bar No . 963798



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SERV ICE L IST

Traian Bujduveanu v. Dismas Charities, Inc., et al.Case No..: 11-20120-CIV-SEITZ/S IMONTONUnited States District Court , Southern District of Florida

Traian BujduveanuP ro S e Plaintiff5601 W. Broward Blvd.Plantation, FL 33317Tel: (954) 316-3828Email: [email protected]

10



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Case 1:11-cv-20120-PAS Document 11 Entered on FLSD Docket 02/03/2011 Page 5 of 7Case Management Deadline Worksheet

ft tJ.AU.5-V 5 .2QII Joinder of parties and amendment of pleadings.S/0+Anh^3a2JI Parties shall furnish opposing counsel with awritten list containing the names and addresses of ail fact witnesses intended to beOCPVaXMC JU^i wiied ^ tr.a| ^ Qn)y ^ w.messes ljsted shaU ^ permjtted tQ testjfy^^ good cause IS shown ^ ^g 1S no prejudice to

opposing party. The parties are under acontinuing obligation to supplement discovery responses within ten (10) days ofreceipt orothernotice of new or revised information.

/VtfthA-31 20ll Plaintiffmust furnish expertwitness listto theDefendant, alongwith the summaries/reports required by Local Rule 16 l.K, and onlyUUUVUC^i-^mi AMe ^ ^ w.inesses sha || be permiued tQ testjfy wjthin ^ fourteen day perjod thereat, Piaint.ff shall make .ts expertsavailable fordeposition by Defendant.

l)tfr/*W if\20li Defendantmust furnish expert witness list tothe Plaintiffalong with the summaries/reports required by Local Rule 16. l.K. and onlyW(USZaflfr_M>A*ii ^ ^ ^ w^cnes ^ ^ ^ . ^ ^^.^ wjthin ^ ^^ dfly perjod Pearler, Defendan, shall make its expertsavailable for deposition by Plaintiff.

X)ce.embcr llo,ZULi A"discovery must be completed.Tw^l,- [u 2QJI All dispositive pretrial motions and memoranda of law must be filed. Aminimum of fifteen (15) weeks is required for the CourtVCLCOOOec JJA, fc*J. ^^ dispositive motions prior to fil ing of the joint pretrial stipulation. If no dispositive motions will be filed, clearly note

this fact in the Joint Scheduling Report.

A04jQLSJ& ^1 Mediation must be completed. (The parties should select the earliest date to maximize resolution of the case in amanner thatpromotes client and judicial economy.)Jan ii/im 1U 20l2 (a) Joint pretrial stipulation must be filed pursuant to Local Rule 16.1 ,E. The pretrial stipulation shall include Plaintiffs non-b.nding^ ^ breakdown ofdamages with corresponding amounts; the witness lists shall be pared down to those witnesses the parties actuallyintend to call at trial; and the exhibit lists shall identify the witness introducing each exhibit. The parties shallmeet at least one(1) month prior to the deadline for filing the pretrial stipulation to confer on the preparation of that stipulation. The Courtwill not accept unilateral pretrial stipulations, and will strike, sua sponte, any such submissions; and

(b) Joint proposed jury instructions (for jury cases) or conclusions of law (non-jury cases) outlining (1) the legal elements ofPlaintiffs claims, including damages, and (2) the legal elements of the defenses raised; and(c) Joint Summary ofRespective Motions in Limine must be filed. The Summary shall contain acover page providing thestyle ofthe case and an indexofthe motions in limine. The Summary shall also include for each evidentiary issue: (0 aone (1) pagemotion identifying the evidence sought to be precluded at trial and citing legal authority supporting exclusion; and (//) aone (I) pageresponse to the motion providing astatement of the purpose for which the challenged evidence would be offered and citing legalauthority in support ofadmission ofthe challenged evidence. The parties shall work together to prepare the Summary. Prior tosubmission ofthe Summary, the parties are encouraged to resolve evidentiary issues through stipulation.

t i ALIAUL l i 2MI Final proposed jury instructions or findings of fact and conclusions of law must be submitted. (A courtesy copy shall be hand-JU -u-") "+ delivered l0 Chambers on 3.5 diskette, WordPerfectformat), each party's list indicatingeach witness whowill testify at trial, aonesentence synopsis of the testimony, and in consultation with opposing counsel, indicate the amount oftime needed for direct andcross examination.

finrl\ ,iHil Pretrial conference. Usually 50 minutes are allotted for pretrial conference unless the parties or the Court, sua sponte. indicate agreater time isneeded.

MZ Trial Date.llnk/UulA Dateofany other deadline the parties adopt as partoftheir case management plan, including Daubert or Markman hearing. In casesthe parties anticipate aMarkman hearing, counsel must provide dates for the exchange ofproposed disputed claim terms, and due

dates for Plaintiffs brief and Defendant's brief.

[Attachment A]



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Case 1:11 -cv-20120-PAS Document 11 Entered on FLSD Docket 02/03/2011 Page 6 of 7


v .

UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDACASE NO. 11-20120-CIV-SEITZ/O'SULLIVAN

ANA GINSPERT and DISMASCHARITIES, INC.,

Defendant.

ELECTION TOJURISDICTION BY AUNITED STATESMAniRTB ATF JUDGE FOR FINAL DISPOSITION OF MOTIONSIn accordance with the provisions of 28 U.S.C. 636(c), the undersigned parties to the above-captioned civil

matter hereby jointly and voluntarily elect to have aUnited StatesMagistrate Judge decide the followingmotions andissue a final order orjudgment with respect thereto:

1. Motions for Costs2. Motions for Attorney's Fees3. Motions for Sanctions4. Motions to Dismiss5. Motions for Summary Judgment6. Other (specify)

Yes

Yes

Yes

Yes

Yes

*

(Date) (Signature-PlaintiffsCounsel)

(Date)

(Date)

(Date)

(Signatuir>*hrhTtTTf s Cdunsel)

(Signature-Defendant's Counsel)

(Signature-Defendant's Counsel)[Attachment B]

No

No

No

No

No

^v *



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Case 1:11-cv-20120-PAS Document 11 Entered on FLSD Docket 02/03/2011 Page 7 of 7UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDA

CASE NO. 11-20120-CIV-SEITZ/O'SULLIVAN

TRAIANBUJDUVEANU,Plaintiff,

v .

ANA GINSPERT andDISMASCHARITIES, INC.,

Defendant.

ELECTION TO JURISDICTION BY Atttmitfxi STATES MAGISTRATE JUDGE FORTRIALInaccordance withthe provisionsof28 U.S.C. 636(c), the undersigned parties to the above-captioned

civil matter hereby jointly and voluntarily elect to have aUnited States Magistrate Judge conduct any and allfurther proceedings in the case, including TRIAL, and entry of final judgment with respect thereto.

(5^) (Signature-Plaintiffs Counsel)(5^) (Signature-Plaintiffs Counsel)

(Date) (Signature-Defendant's t>(5^) (Signature-Defendant's Counsel) iVs^-

\


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CASE NO.: 11-20120-CIV-SEITZ/SIMONTONTRAIAN BUJDUVEANU,

Plaintiff,vs.


Defendants.

DEFENDANTS DISMAS CHARTIES, INC., ANA GISPERT, DEREK THOMAS ANDADAMS LE SHOTA ' S D I SCOVERY SCHEDULE

Defendants Dismas Charities, Inc., Ana Gispert, Derek Thomas and Adams Lashanda,incorrectly identified as Adams Leshota (collectively "Defendants") pursuant to the FederalRules of Civil Procedure and the Southern Distr ict of Florida Local Rules, hereby file theirdiscovery schedule as follows:Written Discovery:

Defendant Dismas propounded initial interrogatories and requests for production upon thePlaintiff on April 28, 2011. Additional written discovery may be needed following the Court 'sruling on Defendant's motion to dismiss. Defendants hope to complete written discovery on orbefore September 15, 2011, which will include requests for production, requests for admissionsand interrogatories.



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11-20120-CIV-SEITZ/SIMONTONDepositions:

Defendants intend to set the Plaintiff for depositions sometime in August 2011. Defendantsanticipate defending the depositions ofDismas, Gispert,Thomas and Lashanda. Defendants mayneed to depose representatives of the United States Marshall's Service and Federal Bureau ofPrisons, along with the Plaintiffs wife and son. These depositions will likely be set inSeptember or October 2011.Expert Discovery:

At this time expert discovery is not anticipated unless the Plaintiff presents a claim for physicalor mental injury. If so, then Defendants will need to retain an expert in the appropriate medicalspecialty.

Respectfully submitted,EISINGER, BROWN, LEWIS, FRANKEL,& CHAIET, PA.Attorneys for Defendants4000 Hollywood BoulevardSuite 265-SouthHollywood, FL 33021(954) 894-8000(954) 894-8015 FaxBY: / S / Davi d S. Chaiet

DAVID S. CHAIET, ESQUIREFBN : 9 63 79 8



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11-20120-CIV-SEITZ/SIMONTON

CERT IF ICATE OF SERVICE

I HEREBY CERTIFY that on the 19th day of May, 2011, I electronically filed theforegoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoingdocument is being served this day on all counsel of record or pro se parties identified on theattached Service List in the manner specified, either via transmission of Notices of ElectronicFiling generated by CM/ECF or in some other authorized manner for those counsel or partieswho are authorized to receive electronically Notices of Electronic Filing.

Isi David S. ChaietDAVID S. CHAIET, ESQUIREFlorida Bar No . 963798



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SERV ICE L IST

Traian Bujduveanu v. Dismas Charities, Inc., et al.Case No..: 11-20120-CIV-SEITZ/SIMONTON

United States District Court, Southern District of Florida

Traian BujduveanuP ro S e P la in ti ff5601 W. Broward Blvd.Plantation, FL 33317Tel: (954) 316-3828Email: orionav(a),msn.com



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vs.


Defendants.

DEFENDANTS DISMAS CHARTIES, INC., ANA GISPERT, DEREK THOMAS ANDADAMS LE SHOTA ' S D I SCLOSURE S PUR SUANT TO RULE 26

OF THE FEDERAL RULES OF CIVIL PROCEDUREAND CERT IF ICATE OF INTERESTED PERSONS

Defendants Dismas Charities, Inc., Ana Gispert, Derek Thomas and Adams Lashanda,incorrectly identified as Adams Leshota (collectively "Defendants") pursuant to the FederalRules of Civil Procedure and the Southern District of Florida Local Rules, hereby makes theirini tia l disclosures:

Traian Bujduveanu5601 W. Broward Blvd.Plantation, FL 33317PWMK at Dismas Charities, Inc.141 N.W. 1stAvenueDania Beach, FL 33004



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Ana GispertDismas Charities, Inc.141 N.W. 1stAvenueDania Beach, FL 33004

Derek ThomasDismas Charities, Inc.141 N.W. 1stAvenueDania Beach, FL 33004Adams LashandaDismas Charities, Inc.141 N.W. 1stAvenueDania Beach, FL 33004PWMK a t th e United S ta tes Marsha ll s Serv iceFederal Courthouse Square400 N. Miami Avenue, 6th FloorMiami, FL 33128PWMK Federal Bureau o f Pr isons-Miami Detent ion Center33 Northeast 4th StreetMiami, Florida 33101-9118Wife and Children o fTraian Bujduveanu5601 W. Broward Blvd.Plantation, FL 33317




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1. Defendants hereby discloses the following documents which may support their defenses asfollows:

1. Dismas file on Mr. Bujduveanu.2. United States Marshall's file on Mr. Bujduveanu.3. United States Federal Bureau of Prison file on Mr. Bujduveanu.4. Manuals and handbooks o f Dismas for residents and other re leased inmates.

2. No other disclosures are required to be made by the Defendants pursuant to Rule 26 at thist ime.

Respectfully submitted,EISINGER, BROWN, LEWIS, FRANKEL,& CHAIET, PA.Attorneys for Defendants4000 Hollywood BoulevardSuite 265-SouthHollywood, FL 33021(954) 894-8000(954) 894-8015 FaxBY: /S/ David S. Chaiet

DAVID S. CHAIET, ESQUIREFBN: 963798



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CERT IF ICATE OF SERVICE

I HEREBY CERTIFY that on the 19th day of May, 2011, I electronically filed theforegoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoingdocument is being served this day on all counsel of record or pro se parties identified on theattached Service List in the manner specified, either via transmission of Notices of ElectronicFiling generated by CM/ECF or in some other authorized manner for those counsel or partieswho are authorized to receive electronically Notices ofElectronic Filing.

Is l David S. ChaietDAVID S. CHAIET, ESQUIREFlorida Bar No . 9 63 79 8



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SERV ICE L IST

Traian Bujduveanu v. Dismas Charities, Inc., et al.Case No..: 11-20120-CIV-SEITZ/S IMONTON

United States District Court, Southern District of Florida

Traian BujduveanuP ro Se Plaint i ff5601 W. Broward Blvd.Plantation, FL 33317Tel: (954) 316-3828Email: [email protected]


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