The defendant is disclosing an expert witness, William L. Clements, to testify in their case. Clements will testify about the ambiguity of International Trading in Arms Regulations and the scope of the United States Munitions List. Specifically, he will state that the regulations do not enumerate specific military parts and that manufacturer input is needed to determine if a part is for military use. Clements will also testify that some commercial parts may be included in military aircraft, so the use alone does not determine regulatory status. The defense is seeking additional expert witnesses on military aircraft parts and manufacturing.

1. Case 1:08-cr-20612-PAS Document 164 Entered on FLSD Docket 02/18/2009 Page 1 of 3
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

2. 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

3. 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