1. Case 1:08-cr-20612-PAS Document 41 Entered on FLSD Docket 07/23/2008 Page 1 of 6
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-20612-CR-SEITZ
UNITED STATES OF AMERICA
v.
HASSAN SAIED KESHARI,
TRAIAN BUJDUVEANU,
KESH AIR INTERNATIONAL CORP.,
and
ORION AVIATION CORP.,
Defendants.
______________________________
GOVERNMENT’S RESPONSE TO
THE STANDING DISCOVERY ORDER
The United States hereby files this response to the Standing Discovery Order. This response
also complies with Local Rule 88.10 and Federal Rule of Criminal Procedure 16, and is numbered
to correspond with Local Rule 88.10.
A. 1. Compact discs containing the contents of email communications by the defendants
are enclosed as follows: 2 CDs containing copies of emails obtained from Google
for the keshair@gmail.com email account used by Defendant Keshari and 1 CD
containing copies of emails obtained from Microsoft Networks for the
orionav@msn.com email account used by Defendant Bujduveanu.
In addition, the Government has the following computer data images from
computers seized from the defendants:
Kesh Air Computers:
EPIC PC (S/N 70020321116) 2 Images from 2 Hard Drives (total approx 20Gb);
160 Gb Image of My Book External USH Hard Drive (s/n WCANM8026861);
80 Gb Image of Dell (s/n C7VXR41);
250 GB Image of Gateway GT5436E (S/N XLG7311001239);
1GB Image of Toshiba HESP100DS Notebook (S/N EIO25881305)
Keshari Laptop Computer:
1 Image 80GB Apple MacBook (S/N 4H706TNDWGL)
Orion Aviation/Bujduveanu Computers:

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2 Images 160Gb and 200GB from HP Pavilion (S/N MXK419085H);
2 Images 250GB each from HP Media Center (S/N CNX7030RYH);
1 Image 120GB from HP Pavilion TX1000 (CNF7103DF9) *
1 Image 120GB from HP Pavilion dv6000 (S/N CNF7012SQN) *
1 Image 250GB from HP PAvilion TX1000 (S/N CNF7516782)
1 Image 120GB from HP Pavilion dv2000 (S/N 2CE70809RJ)
1 Image 320GB from HP Media Center m7640n (S/N MXX6490NyN)
1 Image 160GB from HP Pavilion (S/N MXK41907MJ)
2 Images 160GB and 200GB from HP Pavilion (S/N MXK419085H)
If you would like a copy of any or all of the above-listed images, please provide
appropriate storage media to the undersigned Assistant United States Attorney.
These storage media will be used for copying and then returned forthwith.
Although the government is unaware of any other written statements made by the
defendants, attached, you will find copies of any written consents and/or rights
waivers by the defendants.
2. That portion of the written record containing the substance of any oral statements made
by the defendants before or after arrest in response to interrogation by any person then
known to the defendants to be a government agent is attached and includes one report
of the post-arrest interview of Defendant Keshari and one report of the post-arrest
interview of Defendant Bujduveanu.
3. No defendant testified before the Grand Jury.
4. The NCIC records of the defendants are attached.
5. Books, papers, documents, photographs, tangible objects, buildings or places
which the government intends to use as evidence at trial to prove its case in chief,
or were obtained or belonging to the defendants may be inspected at a mutually
convenient time at the Office of the United States Attorney, 99 Northeast 4th
Street, Miami, Florida. Please call AUSA Melissa Damian at (305) 961-9018 to set
up a date and time that is convenient to both parties.
In addition, approximately 9 boxes of documents were seized during the search of
the business Kesh Air International, and approximately 7 boxes of documents were
seized during the search of Orion Aviation. Copies of those documents can be
obtained by ordering copies from Expedia Copy (954) 384-2112. (Please ask for
Jackie.)
6. There were no physical or mental examinations or scientific tests or experiments
made in connection with this case.
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B. DEMAND FOR RECIPROCAL DISCOVERY: The United States requests the
disclosure and production of materials enumerated as items 1, 2 and 3 of Section
B of the Standing Discovery Order. This request is also made pursuant to Rule
16(b) of the Federal Rules of Criminal Procedure.
C. The government will disclose any information or material which may be favorable
on the issues of guilt or punishment within the scope of Brady v. Maryland, 373
U.S. 83 (1963), and United States v. Agurs, 427 U.S. 97 (1976).
D. The government will disclose any payments, promises of immunity, leniency,
preferential treatment, or other inducements made to prospective government
witnesses, within the scope of Giglio v. United States, 405 U.S. 150 (1972), or
Napue v. Illinois, 360 U.S. 264 (1959).
E. The government will disclose any prior convictions of any alleged co-conspirator,
accomplice or informant who will testify for the government at trial.
F. Defendants were not identified in a lineup, show up, photo spread or similar
identification proceedings.
G. The government has advised its agents and officers involved in this case to
preserve all rough notes.
H. The government will timely advise the defendants of its intent, if any, to introduce
during its case in chief proof of evidence pursuant to F.R.E. 404(b). You are
hereby on notice that all evidence made available to you for inspection, as well as
all statements disclosed herein or in any future discovery letter, may be offered in
the trial of this cause, under F.R.E. 404(b) or otherwise (including the inextricably-
intertwined doctrine).
I. The defendant is not an aggrieved person, as defined in Title 18, United States
Code, Section 2510(11), of any electronic surveillance.
J. The government has ordered transcribed the Grand Jury testimony of all witnesses
who will testify for the government at the trial of this cause.
K. No contraband is involved in this indictment.
L. The government does not know of any automobile, vessel, or aircraft allegedly
used in the commission of this offense that is in the government's possession.
M. The government is not aware of any latent fingerprints or palm prints which have
been identified by a government expert as those of the defendants.
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N. To date, the government has not received a request for disclosure of the subject-
matter of expert testimony that the government reasonably expects to offer at trial.
However, at this time, the government reasonably expects to offer, at trial, among
others, the expert testimony of experts in the fields of aircraft parts, including
expertise regarding the types of aircraft parts at issue in this case, as well as an
expert in the field of the United States Munitions list and the qualification of the
items at issue in this case for coverage under the list, and an expert regarding the
Office of Foreign Assets Control’s Embargo of the Republic of Iran and regarding
the Iranian military and its use of the aircraft parts at issue in this case.
O. The government will make every possible effort in good faith to stipulate to all
facts or points of law the truth and existence of which is not contested and the early
resolution of which will expedite trial. These stipulations will be discussed at the
discovery conference.
P. At the discovery conference scheduled in Section A.5, above, the government will
seek written stipulations to agreed facts in this case, to be signed by the defendant
and defense counsel.
The government is aware of its continuing duty to disclose such newly discovered additional
information required by the Standing Discovery Order, Rule 16(c) of the Federal Rules of Criminal
Procedure, Brady, Giglio, Napue, and the obligation to assure a fair trial.
The attachments to this response number D0001-D0017. Please contact the undersigned
Assistant United States Attorney if any pages are missing.
Respectfully submitted,
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
By: S/ Melissa Damian
Melissa Damian
Assistant United States Attorney
Florida Bar No. 0068063
99 Northeast 4th Street
Miami, Florida 33132-2111
Tel: (305) 961-9018
Fax: (305) 536-4675
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CERTIFICATE OF SERVICE
I hereby certify that on July 23, 2008, I electronically filed the foregoing with the Clerk of the Court
by using the CM/ECF system which will send a notice of electronic filing to David O. Markus, counsel for
Defendant Hassan Saied Keshari, and to Mark Eiglarsh, counsel for Defendant Bujduveanu.
I hereby further certify that on July 23, 2008, physical copies of the foregoing, including additional
attachments and enclosures, were delivered to David O. Markus via Federal Express and to Mark Eiglarsh
via hand-delivery.
S/ Melissa Damian
Melissa Damian
Assistant United States Attorney
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