Case 1:11-cv-20120-PAS Document 89-1 Entered on FLSD Docket 12/27/2011 Page 1 of 3

David Chaiet

From:
Sent:
To:

Traian Bujduveanu [orionav@msn.com]

Wednesday, November 09, 2011 1:09 PM
David Chaiet

Subject:
Dear Mr. Chaiet,

RE: Deposition Friday.

I have severe Ascites and subsequently a lot of fluid in my body.

At this moment,the doctors are trying to take all the fluid out of my body,which is unconfortable and painful. Apart from several other medical conditions,I do have a left inguinal hernia which I need to operate. Do lot let outside looks of a person induce in error,as many people look shiny like a glove on the outside
I am sure that you would not very much enjoy if you see what we have inside of us. I will send you a medical note as requested.
Best Regards Traian Bujduveanu

From: Dchaiet(a)eisinqerlaw.com
To: orionavgimsn.com

Subject: RE: Deposition Friday. Date: Wed, 9 Nov 2011 16:51:24 +0000
I am sorry to hear that.

Jtieissue is as I really do not want to postpone this deposition further.

You appeared to be in good health last week at mediation.

I want to depose you and file a motion for summary judgment. I need your testimony for the motion. From: Traian Bujduveanu rmailto:orionav(S)msn.com1 Sent: Wednesday, November 09, 2011 11:39 AM
To: David Chaiet

Subject: RE: Deposition Friday.

Dear Mr. Chaiet, I m very sick.

Therefore I kindly ask you to postpone out deposition for this Friday and reschedule at a later date. I will be taken an operation very soon.
Best Regards Traian Bujduveanu

From: Dchaiet@eisinqerlaw.com
To: orionav(5)msn.com

Subject: Deposition Friday. Date: Wed, 9 Nov 2011 14:55:06 +0000

Case 1:11-cv-20120-PAS Document 89-1 Entered on FLSD Docket 12/27/2011 Page 2 of 3

David Chaiet

From:
Sent:
To:

Traian Bujduveanu [orionav@msn.com]

Thursday, November 10, 2011 12:50 PM
David Chaiet

Subject:
Dear Mr. Chaiet,

RE: Deposition tomorrow

I understand your concern. However I cannot advise you what to do in this case.

If you think that I am "well enough" as stated, then you should take whatever action you deem is necessary. As I have pointed out to you, I am very sick and I cannot attend your deposition which you have set for tomorrow. Also please be aware that! cannot locate my doctor and obtain the letter you have requested, on such a short notice.
You will need to cancel the DeposllloTTsel by yuu Tot Luiiiuhuw diid ^schedule.
Best Regards Traian Bujduveanu

"

'

From: Dchaiet@eisinqerlaw.com
To: orionav(3)msn.com

Subject: Deposition tomorrow Date: Thu, 10 Nov 2011 16:08:38 +0000

Sir

Absent a doctor's letter explaining why you cannot attend tomorrow's deposition which I will need to review, I intend to proceed forward.
We previously cancelled the deposition at your request.
You were well enough to attend mediation.

If you fail to appear tomorrow, I will obtain a certificate of non appearance and take any other appropriate action.
I need to hear back from you before 4pm as I have a court reporter and other people to update.
Thank you

David Chaiet Esquire

Eisinger, Brown, Lewis, Frankel & Chaiet, P.A.
Presidential Circle Suite 265-S

4000 Hollywood Boulevard Hollywood, Florida 33021 p: (954) 894-3043 f: (954) 894-8015
dchaiet@eisinqerlaw.com* www.eisinqerlaw.com
*Please note that our firm name has changed.

Confidentiality and Privacy Notice: The information contained in this communication, including information contained in any attachments, is confidential, may be subject to the attorney-client privilege, may constitute inside information, and is intended only for the use of the addressee. It is the property of Eisinger, Brown, Lewis, Frankel & Chaiet, P.A. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to receptionOieisinqerlaw.com, and destroy this communication and all copies thereof, including all attachments. Debt Collection Disclosure: Pursuant to the Fair Debt Collection Practices Act, you are advised that this Law Firm is a debt collector attempting to collect a debt, and any infomiation obtained
1

Case 1:11-cv-20120-PAS Document 89-1 Entered on FLSD Docket 12/27/2011 Page 3 of 3

David Chaiet

From:
Sent:
To: Subject:

Traian Bujduveanu [orionav@msn.com]

Sunday, December 04, 2011 10:24 PM
David Chaiet RE:

Dear Mr. Chaiet,

Thank you again for your email.

Please be kind and understand that I wish to be as helpful as possible.

However I cannot attend your deposition set by you, due to the inconvenience ofbeing very sick. We need to reschedule the deposition during atime that I will be in good health and I have a clear mind, as
stress can cause my mind to go completely blank, or even to misremember things which could damage your
use. "

Once agai<I believe the logic thing here will be to schedule the deposition after the Court^wTTTanSwer^n
pending motions, and also aftermy surgery.
Best Regards Traian Bujduveanu

From: Dchaiet@eisinqerlaw.com
To: orionav@msn.com

Subject: Date: Fri, 2 Dec 2011 19:29:41 +0000

Sir

I have not received confirmation back from you regarding your attendance at the deposition.
Accordingly, I assume that I will see you at the date, time and place of the deposition notice attached.
Have a good weekend.

I trust that I will see you Monday.

David Chaiet Esquire Eisinger, Brown, Lewis, Frankel & Chaiet, P.A.
Presidential Circle Suite 265-S

4000 Hollywood Boulevard Hollywood, Florida 33021 p: (954) 894-3043 f: (954) 894-8015
dchaiet@eisinoerlaw.com*
www.eisinqerlaw.com

*Pieasenote that ourfirm name has changed.

Confidentiality and Privacy Notice: The information contained in this communication, including information contained in any attachments, is confidential, may be subject to the attorney-client privilege, may constitute inside information, and is intended only for the use ofthe addressee. It isthe property ofEisinger, Brown, Lewis, Frankel &Chaiet, P.A. Unauthorized use, disclosure orcopying ofthis communication orany part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to
reception@eisinaerlaw.com. and destroythiscommunication and all copiesthereof, including all attachments. Debt Collection Disclosure: Pursuant to the Fair Debt Collection Practices Act, you are advised thatthis Law Firm isa debtcollector attempting to collect a debt, andanyinformation obtained may be used for that purpose. Tax Advice Disclosure: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that anywritten advice relating to Federal tax issues contained in this communication, including in anyattachments, was notintended nor written to be used, and cannot be used, by anyperson for the purpose of(1) avoiding taxpenalties thatmay be imposed under the Internal Revenue Code or(2)