1. Case 1:08-cr-20612-PAS Document 134 Entered on FLSD Docket 12/19/2008 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 )
)
Defendant. )
____________________________ )
MOTION FOR EXTENSION OF TIME TO FILE EXPERT WITNESS
DISCLOSURES
COMES NOW the defendant, TRAIAN BUJDUVEANU and ORION AVIATION
CORPORATION, by and through Undersigned Counsel, respectfully requests this Honorable
Court extend the time that the Defendant must file his expert witness disclosures and as
grounds therefore, your Undersigned would state the following:
1. The Defendant is charged in a multi count indictment in Count 1 with
Conspiracy to Violate the Iran Embargo IEEPA and AECA Acts. In addition the Defendant is
charged with the violations of the Iran Embargo Act in Counts 2-7 of the indictment and
violations of the Arms Export Control Act in Counts 8and 9 in the indictment. In addition the
Defendant is charged with making a false statement in violation of Title 18 United States
Code section 1001 in Count 10 of the indictment.
2. Pertinent to this motion is the fact that Counts 1 through 9 requires expert
testimony to support the allegations upon which those counts are based. The Court previously

2. Case 1:08-cr-20612-PAS Document 134 Entered on FLSD Docket 12/19/2008 Page 2 of 3
entered an Order requiring the Government to disclose its expert witnesses in this case on or
before December 17, 2008.
3. On December 17, 2008 the Government did comply and filed a Notice of
Filing Expert Witness Disclosure; however, the notice is incomplete and additional experts
will be disclosed by the Government pursuant to the notice referred to herein.
4. In view of this fact the Defendant is not in a position to hire all the experts it
needs and make its disclosure by the due date this Court has entered previously as January 20,
2009. In view of this fact the defense requests an additional 30 days beyond the time the
Government makes its disclosures to file its expert witness disclosures.
5. The defense also moves for an extension of time of the February 2, 2009 due
date to file its motion to dismiss in this case since the defense cannot do so until it has
reviewed all of the information in the Government's expert disclosures as well as to our expert
disclosures.
6. Your Undersigned has attempted to contact Assistant United States Attorney
Melissa Damian regarding her position to this motion but was unable to reach her.
WHEREFORE, based on the foregoing your Undersigned moves for an extension of
both the February 2, 2009 due date for which the defense must file its expert witness
disclosure and the present due date for the filing of its motions to dismiss.
Respectfully submitted,
s/ *Michael B. Cohen, Esq.*
_________________________

3. Case 1:08-cr-20612-PAS Document 134 Entered on FLSD Docket 12/19/2008 Page 3 of 3
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 November 23, 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