UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.11-20120-CIV-SEITZ/SIMONTON TRAIAN BUJDUVEANU Plaintiff, vs. DISMAS CHARITIES,INC.

,ANA GISPERT, DEREK THOMAS,LASHANDA ADAMS Defendants. _________________________________________/ PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS AND ELECTRONICALLY STORED INFORMATIONS TO DEFENDANTS DISMAS CHARITIES,INC.,ANA GISPERT,DERK THOMAS AND LASHANDA ADAMS.

Plaintiffs, Traian Bujduveanu, pursuant to Rule 34 of the Federal Rules of Civil Procedure, hereby request that Defendants Dismas Charities, Inc., Ana Gispert, Derek Thomas and Lashanda Adams produce the originals of documents described below within thirty (30) days of service of this notice to be at the address as set forth in the First Amended Complaint or at such other time and location as the parties may mutually agree. DEFINITIONS For purposes of this Request for Production of Documents, the following definitions shall apply unless otherwise specifically indicated: A. The word "document" shall mean any written or graphic matter or other means of preserving thought or expression, and all tangible things from which information can be processed or transcribed, including, but not limited to, correspondence, memoranda, notes, messages, letters, telegrams, teletyped messages, bulletins, diaries, chronological data, minutes, books, reports, charts, ledgers, invoices, worksheets, receipts, computer printouts, schedules, affidavits, contracts, transcripts, surveys, graphic representations of any kind, photographs, graphs, microfilm, video tapes, tape recordings, motion pictures or other film.

B. All documents produced shall be in both hard copy format and electronic media, to the extent the documents exist in electronic media. If the documents once existed in

electronic media but were deleted, Defendants shall produce mirror image copies of the electronic media from which the documents were deleted or shall produce the electronic media. C. "Mirror image copies" means true and exact copies of the electronic media including the portion of the electronic media from which material has been deleted. D. "All documents and electronic media relating to" means any and all documents or communications that constitute, comprise, contain, embody, reflect, identify, state, refer directly or indirectly to or are in any way relevant to the particular subject matter identified in the request. E. If any Request is deemed by Defendants to call for the production of documents covered by the attorney/client or work product privilege, and Defendants withhold said documents on the basis of one or both of the privileges, provide a description of the document and the grounds for withholding the document. F. If any documents responsive to these requests have been destroyed, describe said documents and the reasons for their destruction and state the date on which said documents were destroyed. If any such destroyed documents existed in electronic media, provide the electronic media from which the documents were destroyed. G. "Person" means any natural person; public or private corporation, whether organized for profit ; governmental entity ; partnership; association; cooperative; joint venture; sole proprietorship ; or other legal entity . With respect to a business entity, the term "person" includes any natural person acting formally or informally as an employee, officer, agent, attorney, or other representative of the business entity. H. "Policy" means each rule, procedure, or directive, formal or informal, and each common understanding or course of conduct that was recognized as such by Your present or former officers, directors, employees, agents, or other Persons acting or purporting to act on Your behalf, that was in effect at any time during the period covered by these requests and includes any changes of policy. I. The terms "and" and "or" shall be construed either disjunctively or conjunctively as necessary to bring within the scope of the discovery request all responses that might otherwise be construed outside of its scope. J. The use of the singular form of any word includes the plural and vice versa. In addition, the use of any tense of any verb includes all other tenses of the verb. K. "And" and "or" shall be construed disjunctively or conjunctively as necessary in order to bring within the scope of each request all documents which might otherwise be construed to be outside its scope.

L. The term "and/or" is to be read in both the conjunctive and disjunctive and shall serve as a request for information which would be responsive under a conjunctive reading in addition to all information which would be responsive under a disjunctive reading. M. "Each" includes both "each" and "every." N. The singular and masculine gender shall, respectively, include the plural and feminine gender, and vice versa. O. "You" and "your" shall mean yourself and all other persons acting or purporting to act on your behalf. P. "Relating to" and "relates to" mean, without limitation, relating to, concerning, constituting, mentioning, referring to, describing, summarizing, evidencing, listing, relevant to, demonstrating, tending to prove or disprove, or explain. R. "Communication" or "communications" includes, without limitation, in-person or telephone conversations, facsimiles, letters, electronic mail, telegrams, telexes, tapes or other sound recordings, or other means of transmitting information from one source to another. S. "Plaintiffs"- The term "Plaintiffs" refers to Traian Bujduveanu, as described in the Complaint. T. "Defendants" - The term "Defendants" in the context of this case refers to Dismas Charities,Inc.,Ana Gispert,Derek Thomas,lashanda Adams.

SCHEDULE OF DOCUMENTS

1. One copy of each of Dismas Charities,Inc., most current employee lists and organizational charts. 2. The complete contents of Plaintiff's personal file. 3. The complete contents of any other files maintained in Plaintiff's name by any of the Defendants. 4. Copies of any and all information indicating whether any of the

Defendants has been convicted of a crime.

5. Any and all documents, in Plaintiffs name, which are in the possession, custody or control of Defendants, their attorneys, investigators, agents, employees and other representatives. 6. Any and all medical, psychiatric or other health-related reports or writings which describe or evaluate Plaintiff's physical or mental condition or any treatment received by plaintiff at any time Plaintiff was at Dismas Charities,Inc., or in Home Confinement. 7. Any and all performance appraisals, evaluations, and reviews of Plaintiff by any Defendant. 8. Any and all writings containing any reference to Plaintiff's performance while at Dismas Charities,Inc. 9. Any and all records,correspondence,notes,communications, and other documents concerning or relating to Plaintiffs files obtained by Dismas Charities,Inc, Ana Gispert, Derek Thomas, Lashanda Adams, the contents of those files, the circumstances under which they obtained possession of those files, or any investigation of those circumstances. 10. Any and all records, correspondence, notes, communications, and other documents concerning or relating to any correspondence or communications with CCM Director Rodriguez, regarding the Plaintiffs files, their contents, the circumstances under which Dismas Charities,Inc,Ana Gispert,Derek Thomas,and Lashanda Adams obtained possession of those files, or any investigation of those circumstances. 11. Any and all records, correspondence, notes, communications, and other documents concerning or relating to any correspondence or communications with U.S. Marshal regarding the Plaintiffs files, their contents, the circumstances under which Dismas Charities,Inc,Ana Gispert,Derek Thomas,and Lashanda Adams obtained possession of those files, or any investigation of those circumstances. 12. Any and all records, correspondence, notes, communications, and other documents concerning or relating to any correspondence or communications with any officer, employee or agent of the Federal or State Government, regarding the Plaintiffs files, their contents, the circumstances under which Dismas Charities,Inc.,Ana Gispert,Derek Thomas,and Lashanda Adams obtained possession of those files, or any investigation of those circumstances. 13. Any and all records, correspondence, notes, communications, and other documents concerning or relating to any correspondence or communications with USPO Steven Aasterud, regarding Plaintiff or containing the name of the Plaintiff, and the circumstances under which Dismas Charities,Inc.,Ana Gispert, Derek Thomas, and Lashanda Adams obtained possession of those files, or any investigation of those circumstances. 4

14. Any and all records, correspondence, notes, communications and other documents concerning or relating to any correspondence or communications with any person or persons, or agents of USPO regarding Plaintiff,or containing the name of the Plaintiff, and the circumstances under which Dismas Charities,Inc., Ana Gispert, Derek Thomas, and Lashanda Adams obtained possession of those files, or any investigation of those circumstances. 15. Any and all records, correspondence, notes, communications, and other documents concerning or relating to any communications with any officer, agent or employee of the Federal Corection Center in Miami, regarding the Plaintiffs files, their contents, the circumstances under which Dismas Charities,Inc., Ana Gispert, Derek Thomas, and Lashanda Adams obtained possession of those files, or any investigation of those circumstances. 16. Any and all records, correspondence, notes, communications, and other documents concerning or relating to any correspondence or communications with any officer, employee or agent of the United States Department Of Justice, Federal Bureau Of Prisons, regarding the Plaintiffs files, their contents, the circumstances under which Dismas Charities, Inc., Ana Gispert, Derek Thomas, and Lashanda Adams obtained possession of those files, or any investigation of those circumstances. 17. Copies of any and all surveillance reports, videotapes, audiotapes,

photographs, of any of the parties in this lawsuit. 18. Copies of any and all information from any computer information center, and/or computer communication center, concerning the plaintiff(s) named. 19. Any and all documents, including any written reports, which state the substance of facts and opinions to which any expert is expected to testify at trial, or which contain a summary of the grounds for any such opinion held. 20. Any and all exhibits proposed to be offered into evidence at the time of trial. 21. Any and all demonstrative or visual aids proposed for use at trial, including any proposed or planned for use to clarify, illustrate, or assist in explaining the testimony of any witnesses. 22. A copy of all statements from witnesses to the incident mentioned in the complaint. 23. A copy of each photograph, diagram, map, chart or drawing which will be introduced at trial. 5

24. A copy of the declarations page for any insurance agreement between defendants or any third party and any person carrying on an insurance business which may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or reimburse defendants for payments made to satisfy said judgment, showing policy limits, which was available to the defendants on the date of the incident described in plaintiff's complaint, including primary policy, secondary policy, blanket policy, umbrella policy, homeowner's policy, professional liability policy, or any other type of insurance policy.

________________________________ TRAIAN BUJDUVEANU, PRO SE

Date: July 25, 2011

CERTIFICATE OF SERVICE I hereby certify that on or about JULY 25, 2011 a true and correct copy of the foregoing document was served upon the following via the United States Postal Service, First Class Mail:

Dismas Charities, Inc., 141 N.W. 1 St. Avenue Dania, FL 33004-2835 Ana Gispert Dismas Charities,Inc. 141 N.W. 1 St. Avenue Dania, FL 33004-2835 Derek Thomas Dismas Charities,Inc. 141 N.W. 1 St. Avenue Dania, FL 33004-2835 Lashanda Adams Dismas Charities,Inc. 141 N.W. 1 St. Avenue Dania ,FL 33004-2835 David S. Chaiet,Esquire Attorney for Defendants 4000 Hollywood Boulevard Suite 265-South Hollywood,FL 33021

EXECUTED ON THIS 25rd DAY OF JULY, 2011 ___________________________________ TRAIAN BUJDUVEANU, PRO SE 5601 W. BROWARD BLVD., PLANTATION, FL 33317