1. Case 1:11-cv-20120-PAS Document 35 Entered on FLSD Docket 05/25/2011 Page 1 of 5
IN THE UNITED STATES DISTRICT COURT FOR
THE 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.
_________________________________________/
DEFENDANTS DISMAS CHARTIES, INC., ANA GISPERT, DEREK THOMAS AND
ADAMS LESHOTA’S BRIEF IN RESPONSE TO PLAINTIFF’S MOTION TO STRIKE
DOCUMENT FROM THE DOCKET
Defendants Dismas Charities, Inc., Ana Gispert, Derek Thomas and Adams Lashanda,
incorrectly identified as Adams Leshota (collectively “Defendants”) by and through their
undersigned counsel, file their Brief in Response to Plaintiff Traian Bujduveanu’s (“Plaintiff”)
Motion to Strike Documents from the Docket and alleges as follows:
1. Pursuant to Order of the Court, the parties were required to submit a Joint
Scheduling Report on or before Friday May 20, 2011.
2. After substantial time, energy and effort by Defendants’ counsel, Defendants
presented a proposed Joint Scheduling Report that followed the format recommended by the
District Court. However, Plaintiff initially refused to accept this form. Plaintiff wanted to
submit a Joint Scheduling Report having a section that basically contained an almost complete
recitation of the Complaint.

2. Case 1:11-cv-20120-PAS Document 35 Entered on FLSD Docket 05/25/2011 Page 2 of 5
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
3. After numerous conversations and email communications, Plaintiff agreed to the
form of the Joint Scheduling Report. However, Plaintiff, despite numerous requests, failed to
sign and return the Joint Scheduling Report to Defendant’s counsel so that the Report could be
timely filed.
4. As the deadline to file the Report was approaching, in the abundance of caution,
Defendants’ counsel electronically filed the Joint Scheduling Report during the evening of May
19, 2011, without Plaintiff’s signature. (Docket number 29)
5. The following day the Plaintiff filed his own Joint Scheduling Report. (Docket
number 30)
6. Subsequently, the Plaintiff then signed and filed the Joint Scheduling Report
(Docket Number 31) originally agreed upon and filed by Defendants’ counsel on May 19, 2011.
7. While the Defendants do not agree with the commentary contained in the first
three paragraphs of Plaintiff’s Motion to Strike the Document from the Docket, Defendants
concur with the statements contained in paragraph 4 of Plaintiff’s Motion, specifically that
Defendants agree that Document 31, is the valid and correct Joint Scheduling Report, which is
identical to the one filed by Defendants on May 19, 2011.
8. Accordingly, Defendants do not oppose Plaintiff’s Motion to Strike Document 30,
which is the Joint Scheduling Report unilaterally filed by the Plaintiff.
2

3. Case 1:11-cv-20120-PAS Document 35 Entered on FLSD Docket 05/25/2011 Page 3 of 5
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
EISINGER, BROWN, LEWIS, FRANKEL,
& CHAIET, P.A.
Attorneys for Defendants
4000 Hollywood Boulevard
Suite 265-South
Hollywood, FL 33021
(954) 894-8000
(954) 894-8015 Fax
BY: /S/ David S. Chaiet____________
DAVID S. CHAIET, ESQUIRE
FBN: 963798
3

4. Case 1:11-cv-20120-PAS Document 35 Entered on FLSD Docket 05/25/2011 Page 4 of 5
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 25th day of May, 2011, I electronically filed the
foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing
document is being served this day on all counsel of record or pro se parties identified on the
attached Service List in the manner specified, either via transmission of Notices of Electronic
Filing generated by CM/ECF or in some other authorized manner for those counsel or parties
who are authorized to receive electronically Notices of Electronic Filing.
__/s/ David S. Chaiet_______________
DAVID S. CHAIET, ESQUIRE
Florida Bar No. 963798
4

5. Case 1:11-cv-20120-PAS Document 35 Entered on FLSD Docket 05/25/2011 Page 5 of 5
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
SERVICE LIST
Traian Bujduveanu v. Dismas Charities, Inc., et al.
Case No..: 11-20120-CIV-SEITZ/SIMONTON
United States District Court, Southern District of Florida
Traian Bujduveanu
Pro Se Plaintiff
5601 W. Broward Blvd.
Plantation, FL 33317
Tel: (954) 316-3828
Email: orionav@msn.com
5