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 AND LASHANDA ADAMS Defendants ________________________________________/ MOTION FOR LEAVE TO EXTEND TIME TO REPOND TO DEFENDANTS SUPPLEMENTAL MOTION FOR SUMMARY JUDGMENT AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT COMES NOW TRAIAN BUJDUVEAN, Plaintiff, Pro-Se, and Moves this Honorable Court, pursuant to Fed. Civ. P 26(a)(2)(B) for leave to extend the deadline to file a response to the Defendants Supplemental Motion For Summary Judgment And Incorporated Memorandum Of Law In Support Of Motion For Summary Judgment., from April 30, 32012 to June 30, 2012 or as soon thereafter. Good cause exist for extending the deadline to file the response, as set forth with greater particularity below: 1. Mother of Plaintiff passed away. (Exhibit A) 2. Plaintiff had to undergo surgery. (Exhibit B) 3. Plaintiff has been very ill for the past few weeks and needs time to recuperate. 4. Plaintiff cannot file a response without a clear mind. WHEREFORE, pursuant to Fed. Civ. P 26(a)(2)(B), Plaintiff request that the Court enter an Order to grant the Plaintiff leave to file this response to June 30,2912, or as soon thereafter. Respectfully submitted, this 29 th day of April, 2012. __________________________________________ TRAIAN BUJDUVEANU, Pro-Se 5601 W. Broward Blvd. Plantation, FL 33317