Popescu & Associates Law Firm

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Popescu & Asociates CLUJ BAR ASSOCIATION | ADRIAN & BOGDANA POPESCU LAW OFFICES


Contents

Popescu & Associates

02. . . . . . . . . . . . . . . . . . . . . About Us 03. . . . . . . . . . . . . . . . . . . . . Our Team 06. . . . . . . . . . . . . . . . . . . . . Areas Of Practice 10. . . . . . . . . . . . . . . . . . . . . Clients

Popescu & Associates



About us

Popescu & Associates

About Us In a legal environment full of too many players pretending to be “everything to everyone”, we decided to be straightforward. We benefit from a strong professional basis. This allows us to go upstream in helping our clients to avoid any possible mistake that might drive them into a conflict. And if this is to happen, well, we are ready and able to bring them to the best resolution. We believe that an effective legal representation begins with understanding our clients’ businesses and the environment in which they operate. We deliver result-oriented counsel to our clients at all stages of their actions, offering professional services at the highest standards. Our premise is that our company’s success depends on the success of each case. There are no major or minor clients, no major or minor cases. There is only confidence in success, given by the competence and commitment of our people. The outcomes are appraised as positive if obtained in a minimum of time and with minimum financial costs on behalf of the client. The favorable settlement of a legal issue is not the final end, but reaching it within the shortest time possible and with the lowest costs. Each case is unique. Therefore the legal solutions we offer are adapted to each client. Only thus we may be confident that the best outcomes are always achieved. The relation we develop with our clients is a partnership founded on mutual knowledge, trust and honesty, wherefrom both parties may only gain. We aim for excellence in everything we do. A fervent focus on client service constitutes the basis of our success. We strive at every level to develop beneficial relationships with our clients, built on trust and mutual respect. We take pride in the fact that clients who hire us once, hire us again. Moreover, sometimes after wining cases, our opponents, acknowledging the quality of our work, have chosen us to represent them in legal matters other than those in which we first met in the court. Our success is measured by the results we achieve on behalf of our clients, and we commit ourselves, without reservation, to the overriding objective of client satisfaction.

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Our Team

Popescu & Associates

Our Team

Our team offers the combination of legal insight, outstanding professional competence, courtroom experience and practical business sense needed in order to help our clients prevail in their most complex cases. Our Law Office is the legal office prepared to answer one’s highest requirements, for it combines the experience of the founding lawyer with the dynamism and determination of a young team, into a unified and powerful body. The law office was founded in 1998, when the leading partners, Adrian Popescu and Bogdana Popescu, became attorneys. Now, our team is made of five young motivated lawyers, and we cooperate with public notaries, experts and certified translators. Although we are not a large team, we proudly and confidently consider ourselves as prepared to find fast, efficient, dynamic, and non-expensive solutions to the clients’ legal issues. We offer legal advice based on a monthly subscription, and also on an hourly basis. Certainly, fees shall be discussed, negotiated and agreed upon with each and every client, depending on their personalized legal needs. Popescu & Associates

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Our Team

Popescu & Associates

Adrian Liviu Popescu Education:

Faculty of Law, Babes-Bolyai University, Cluj-Napoca Member of the Cluj Bar Association since 1998 Bankruptcy & Insolvency Practitioner since 2009 Member of UNPIR since 2010

Areas of Practice: Real Estate, Corporate & Commercial, Insolvency Insurance, Litigation Expertise:

Adrian Popescu’s expertise is mainly focused on real estate issues. He also advises on general corporate and commercial matters and has extensive experience in mergers and acquisitions field. Adrian Popescu advises clients on real estate matters, being experienced in handling large residential, office and commercial projects in all development phases. Adrian’s practice also focuses on corporate and commercial matters, advising major domestic corporations on a wide range of general and specific corporate and commercial issues. Adrian Popescu assists and represents clients in court in a wide range of legal areas, such as civil, commercial, administrative disputes, enforcement proceedings, bankruptcy and reorganization proceedings. He has also conducted, as co-coordinator, numerous joint-ventures.

Languages:

Romanian and English

Contact: Tel.no.: +40729555787 E-mail: avpopescu@yahoo.com

Bogdana Fluvia Popescu Education:

Faculty of Law, Babes-Bolyai University, Cluj-Napoca Member of the Cluj Bar Association since 1998 Bankruptcy & Insolvency Practitioner since 2009 Member of UNPIR since 2010

Areas of Practice: Litigation regarding commercial law, civil law, insolvency, judicial enforcements Languages:

Romanian and French

Contact: Tel.no.: +40728555787 E-mail: avpopescu@yahoo.com Popescu & Associates

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Our Team

Popescu & Associates

Daiana Ramona Sicoe Education:

Faculty of Law, Babes-Bolyai University, Cluj-Napoca Member of the Cluj Bar Association since 2006

Areas of Practice: Corporate & Commercial, Real Estate, Litigation Expertise:

Litigation regarding commercial law, civil law, administrative litigation department, insolvency, judicial enforcements

Languages:

Romanian and English.

Contact: Tel.no.: +40730707828 E-mail: av_daianasicoe@yahoo.com

Ioana Orbean Education:

Faculty of Law, Babes-Bolyai University, Cluj-Napoca Member of the Cluj Bar Association since 2006

Areas of Practice: Corporate & Commercial, Real Estate, Litigation Expertise:

Litigation regarding commercial law, civil law, administrative litigation department, insolvency, judicial enforcements

Languages:

Romanian and English.

Contact: Tel.no.: +40743550110 E-mail: ioanaorbean@yahoo.com

Roxana Maria Ioaniciu Education:

Faculty of Law, Babes-Bolyai University, Cluj-Napoca Master in Criminal Law Member of the Cluj Bar Association since 2010

Areas of Practice: Corporate & Commercial, Real Estate, Criminal Law, Litigation Expertise:

Litigation regarding commercial law, civil law, criminal law, judicial enforcements

Languages:

Romanian and English

Contact: Tel.no.: +40753509351 E-mail: roxiioaniciu@yahoo.com Popescu & Associates

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Areas of Practice

Popescu & Associates

Areas of Practice

We are widely known on the legal advice market and we have reached and kept a good reputation, not only by means of our professional results but also through our promptitude, flexible working time, dynamics and seriousness. In a nutshell, we can provide legal assistance (legal advice and representation) in the following areas: Commercial Law, Commercial Transactions, Contracts, Civil Law, Insolvency, Labour Litigations, Family Law, Real Estate, Criminal Law.

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Areas of Practice

Popescu & Associates

Corporate:

• Legal advice and assistance in incorporation of: companies; non-profit organisations (associations, foundations etc.). • Legal advice and assistance in the organisation and operation of companies and organisations: drafting the internal regulations; assistance in the meetings of statutory bodies; • procedures for amending the articles of incorporation; maintenance of the relation with the public institutions/ authorities involved. • Legal advice and assistance in the changes of the companies and organisations activities: • share capital increase/ decrease; mergers, spin-offs, changes; due diligence for acquiring an undertaking or an undertaking’s assets. • Advice on any corporate law issues; • Agreements of the undertakings concerning the management and operation of companies.

Real Estate:

• Drafting legal opinions, due diligence reports and memorials on real estate legal status • Drafting sale-purchase pre-agreements, agreements, lease agreements, mortgage agreements and assistance before the notary public in signing and authenticating all types of agreements • Assistance in the negotiations with the sellers and/ or purchasers • Checking the real estate technical and legal regime with the competent public authorities • Drafting and negotiating the Works Contracts • Negotiating the agreements having as object financing • Drafting and negotiating the lease agreements and the general terms of the Lease Agreements (Lease Pre-agreements - Head of terms) • Participation in signing the lease agreements • Negotiating and drafting the agreements having as object development of residential complexes • Fulfilment of all the land book related formalities concerning existent/ inexistent encumbrances over the real estate • Checking the fiscal regime of the real estate with the Local Taxes and Charges Department.

Industry, Reorganization, Insolvency: • Legal services tailored to the needs of the relevant companies: - legal assistance in contract negotiation - representation during disputes - legal assistance in conflict mediation - claim recovery - legal assistance and advice on company reorganization and dissolution.

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Areas of Practice

Popescu & Associates

Litigation and Judicial enforcements: Debt collection, judicial enforcements and judicial liquidations • Legal consultancy in respect of debt collection methods; debt analysis, assessing chances for collection, assessing collection costs. • Legal assistance and representation before courts in common law actions or in special actions for debt collection in various areas of law (banking, telecommunications, privatization, infrastructure). • Drafting all deeds and documents required by the procedures of actions in court, participation in conducting judiciary and extra-judiciary appraisements necessary for debt collection. • Negotiations and transactions within debt collection procedures, representing clients in direct conciliation procedures. • Developing projects for the recovery of large debts. • Legal assistance and representation in all judicial enforcement procedures, legal assistance in selecting court enforcement officers, representation with a view to performing the formalities necessary before court enforcement offices, negotiating fees, participation, together with the court enforcement officer, in judicial enforcements of movable and immovable property. • Legal assistance and representation in challenges to judicial enforcement, validation of garnishment and in any legal action in connection with judicial enforcement. • Legal assistance and representation in the insolvency procedure, both to creditors and to debtors, drawing up the necessary deeds, initiating the procedures to entail responsibility for the company’s insolvency, representing the client in the creditors’ meeting or committee, presenting pertinent legal opinions, as well as elaborating optimal debt collection strategies within such procedure. Legal assistance in dispute settlement: • Legal consultancy in respect of strategies to approach possible or existing disputes, assessment of success/risks, providing the client with assistance in decisions to bring an action to court, assessing costs, selecting procedures for taking legal action. • Mediation, negotiation and assistance in concluding settlements. • Legal assistance in the pre-litigation stage, assessing evidence, legal assistance in proof ensuring procedures, conducting judiciary appraisements. • Ensuring legal services in direct conciliations or in adjudications. • Legal appraisal of lawsuits of a legal entity. • Representation before law courts of all levels and before internal and international arbitral tribunals, in all areas of law. • Legal assistance and representation in conducting judiciary appraisements and or other evidence. • Drafting all the deeds and documents which the dispute presupposes. • Developing strategies to avoid the most frequent disputes in the client’s activity. Popescu & Associates

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Clients

Popescu & Associates

Some of the most important clients of our law office are: • • • • • • • • • • • • • • • • • • • • •

S.C. I&C TRANSILVANIA CONSTRUCTII S.R.L. S.C. TRANSILVANIA IMPACT IMPORT EXPORT S.R.L. S.C. ANCANDRA TRANS S.R.L. SC SCANIA CREDIT ROMANIA IFN S.A. S.C. LE FOLLIE IMPORT EXPORT S.R.L. S.C. NERVIA CENTER S.R.L. NERVIA CONSULTORES S.C. MBS GROUP S.R.L. S.C. DACHIM S.R.L. S.C.A&A IMPORT EXPORT S.A. S.C. ABIALEX S.R.L. S.C. AMBAS INVEST S.R.L. S.C. CASA RATIU DE NAGYLAK S.R.L. S.C. FAD ARANJAMENT SI DESIGN FLORAL S.R.L. S.C. ACSA S.A. S.C. TUDOR CONSTRUCT S.R.L. SC ALUMINIU DISTRIBUTION SYSTEM SRL RATIU FAMILY FOUNDATION The municipality of TURDA The municipality of SAVADISLA The municipality of MIHAI VITEAZU.

We have also been involved in the largest claims of land/buildings/shares in the area, having as clients two former US ambassadors, former Hungarian patriciate, important businessmen.

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Team biographies / Adrian Liviu Popescu

Popescu & Associates

I am the leader and coordinator of the Law Firm, organizing and supervising all the activities and contracts that are prepared by my colleagues. It is an activity that requires a high degree of sociability, an attorney requires communication skills, networking, teamwork, perseverance, creativity, adaptability, and relevant organizational, management, Computer knowledge (Word, Excel, Internet), flair for management and marketing. Since 2004 I have been offering consultancy services in the investment field (real estate, commercial, industrial) for foreign and Romanian investors. Past and present activity involves team work. Personal information Name Address Telephone Fax E-mail Nationality Date of birth Gender Occupational field Work Experience 2006 - Present

Adrian Liviu Popescu No. 31, Nicolae Iorga Str., Turda ,Romania +40 (0)729 555 787 +40 (0)264 311 842 / +40 (0)364 815 675 avpopescu@yahoo.com • avadrianpopescu@gmail.com Romanian 20th January, 1975 Male Lawyer

Lawyer at Popescu & Associates Law Office No. 24, Republicii Str., Turda ,Romania tel.no.: +40 (0)729 555 787

Main activities and responsibilities

Assisting and representing clients in court in a wide range of legal areas, such as civil, commercial, administrative disputes, enforcement proceedings,bankrupcy; providing legal advice in specialized fields to numerous customers, individuals, companies and state institutions.; writing legal documents, contracts

Type of business

Real Estate,Commercial Law, Commercial Transactions, Contracts, Civil Law, Insolvency, Litigation

Education and training 1997-1998 1993-1997 Level in national or international classification

Master’s in European Bussines Law ( LL.M ) Babes-Bolyai University , Faculty of Law, Cluj-Napoca , Romania Bachelor’s of Law ( LL.A ) Babes-Bolyai University , Faculty of Law, Cluj-Napoca , Romania Level 5 (ISCED)

Personal skills and competences Languages

Romanian - Native English - Common European Framework of Reference for Languages Understanding Listening C2

Reading

Speaking

Writing

Spoken interaction Spoken production

Proficient Proficient C2 C1 user user

Proficient user

C1

Proficient user

B2

Independent user

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Team biographies / Adrian Liviu Popescu

Popescu & Associates

Personal skills and competences Organisational skills and competence Computer skills and competences Other skills and competences Driving licence Additional information

Working in a law firm requires organization, coordination and communication within the working group, and structuring and selecting information held. Computer knowledge ( Word, Excel, Internet ) Ability to find solutions, by judgment, analysis and synthesis self-confidence, flexibility, creativity, dynamism, adaptability, communication skills. B category I have received a solid academic training and experience in the legal profession in the last 15 years in a law firm in which today operate five lawyers (two of them are also liquidators) and two people on the secretariat. I believe I can manage a fruitful partnership in which we can add value to our expertise in the field of real estate, civil, commercial, administrative and labor law and in the insolvency procedure. During this period I have solved independently or in collaboration with other team mates, approximately 2.000 cases of court (litigations), providing legal representation for clients before courts of law, tribunals and courts of appeal.

Team biographies / Bogdana Fluvia Popescu

Being a lawyer means having a profession that requires a high degree of sociability, communication skills, networking, teamwork, perseverance, creativity, adaptability, and relevant organizational skills, management, Computer knowledge (Word, Excel, Internet), flair for management and marketing.

Personal information Name Address Telephone Fax E-mail Nationality Date of birth Gender Occupational field

Bogdana Livia Popescu No. 31, Nicolae Iorga Str., Turda ,Romania +40 (0)729 555 787 +40 (0)264 311 842 / +40 (0)364 815 675 avpopescu@yahoo.com Romanian 16th June, 1975 Female Lawyer

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Team biographies / Bogdana Fluvia Popescu Popescu & Associates Work Experience 2006 - Present

Lawyer at Popescu & Associates Law Office No. 24, Republicii Str., Turda ,Romania tel.no.: +40 (0)729 555 787

Main activities and responsibilities

Assisting and representing clients in court in a wide range of legal areas, such as civil, commercial, administrative disputes, enforcement proceedings,bankrupcy; providing legal advice in specialized fields to numerous customers, individuals, companies and state institutions.; writing legal documents, contracts

Type of business

Commercial Law, Commercial Transactions, Contracts, Civil Law, Insolvency, Real Estate, Litigation

Education and training 1997-1998 1993-1997 Level in national or international classification

Master’s in European Bussines Law ( LL.M ) Babes-Bolyai University , Faculty of Law, Cluj-Napoca , Romania Bachelor’s of Law ( LL.A ) Babes-Bolyai University , Faculty of Law, Cluj-Napoca , Romania Level 5 (ISCED)

Personal skills and competences Languages

Romanian - Native Understanding Listening

English

C1

Reading

Speaking

Writing

Spoken interaction Spoken production

Proficient Proficient C1 C1 user user

Proficient user

C1

Proficient user

B2

Independent user

Common European Framework of Reference for Languages

Personal skills and competences Organisational skills and competence Computer skills and competences Other skills and competences Driving licence Additional information

Working in a law firm requires organization, coordination and communication within the working group, and structuring and selecting information held. Computer knowledge ( Word, Excel, Internet ) Ability to find solutions, by judgment, analysis and synthesis self-confidence, flexibility, creativity, dynamism, adaptability, communication skills. B category I have received a solid academic training and experience in the legal profession in the last 15 years in a law firm in which today operate five lawyers (two of them are also liquidators) and two people on the secretariat. I believe I can manage a fruitful partnership in which we can add value to our expertise in the field of real estate, civil, commercial, administrative and labor law and in the insolvency procedure. During this period I have solved independently or in collaboration with other team mates, approximately 2.000 cases of court (litigations), providing legal representation for clients before courts of law, tribunals and courts of appeal.

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Team biographies / Daiana Ramona Sicoe

Popescu & Associates

My current job requires a high degree of sociability, an attorney should have exceptional communication skills, networking, teamwork, perseverance, creativity, adaptability, and relevant organizational skills, management, IT skills (Word, Excel, Internet), flair for management and marketing

Personal information Name Address Telephone Fax E-mail Nationality Date of birth Gender Occupational field Work Experience 2006 - Present

Daiana Ramona Sicoe No.9, Observatorului Str., Cluj-Napoca, Romania +40 (0)730 707 828 / +40 (0)745 311 359 +40 (0)264 311 842 / +40 (0)364 815 675 av_daianasicoe@yahoo.com Romanian 1st June, 1983 Female Lawyer

Lawyer at Popescu & Associates Law Office No. 24, Republicii Str., Turda ,Romania tel.no.: +40 (0)729 555 787

Main activities and responsibilities

Assisting and representing clients in court in a wide range of legal areas, such as civil, commercial, administrative disputes, enforcement proceedings,bankrupcy; providing legal advice in specialized fields to numerous customers, individuals, companies and state institutions.; writing legal documents, contracts

Type of business

Real Estate,Commercial Law, Commercial Transactions, Contracts, Civil Law, Insolvency, Litigation

Education and training 2002-2006 2002-2005

Level in national or international classification

Bachelor’s of Law ( LL.B ) Babes-Bolyai University , Faculty of Law, Cluj-Napoca , Romania Bachelor’s in Economics and Business Administration ( BA. ) Babes-Bolyai University, Faculty of Economics and Business Administration Cluj-Napoca, Romania Level 5 (ISCED)

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Team biographies / Daiana Ramona Sicoe

Popescu & Associates

Personal skills and competences Languages

Romanian - Native Understanding Listening

English French

Reading

Speaking

Writing

Spoken interaction Spoken production

Independent Independent Independent Independent B1 B1 B1 B1 B1 user user user user Basic Basic Basic Basic A2 A2 A2 A2 A2 user user user user

Independent user Basic user

Common European Framework of Reference for Languages

Organisational skills and competence Computer skills and competences Other skills and competences Driving licence Additional information

Working in a law firm requires organization, coordination and communication within the working group, and structuring and selecting information held. Computer knowledge ( Word, Excel, Internet ) Ability to find solutions, by judgment, analysis and synthesis self-confidence, flexibility, creativity, dynamism, adaptability, communication skills. B category I have acquired a solid academic training and experience in the legal profession throughout the last five years within the law firm in which today operate five lawyers (two of them are also liquidators) and two people on the secretariat. I believe I am ready for a fruitful partnership that will add value to my experience in the field of civil, commercial, administrative and labor law and in the insolvency procedure. During this period I have solved independently or in collaboration with other team mates, approximately 800- 900 cases of court, providing legal representation for clients before courts, tribunals and courts of appeal.

Team biographies / Ioana Orbean

Popescu & Associates

Collaborating with others to reach a common goal, coordinating and sharing information and knowledge, cultivating relationships with colleagues, staff, clients, experts and others, attending and participating in team events, meetings and conferences.

Personal information Name Address Telephone Fax E-mail Nationality Date of birth Gender

Ioana Orbean No. 43, Stefan cel Mare Street, Turda, Cluj, Romania +40 (0)743 550 110 +40 (0)264 311 842 ioanaorbean@gmail.com Romanian 22th June, 1982 Female Popescu & Associates

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Team biographies / Ioana Orbean Occupational field Work Experience 2007 - Present

Main activities and responsibilities

Lawyer

Lawyer at Popescu & Associates Law Office / No. 24, Republicii Str., Turda ,Romania tel.no.: +40 (0)729 555 787 • • • •

Type of business

Popescu & Associates

Drew up and negotiated transactions and contracts involving leases, purchases, sales, real estate and other matters. Examined legal data to determine advisability of defending lawsuits. Rendered legal advice on protection of property Assisting and representing clients in court in a wide range of legal areas, such as civil, commercial, administrative disputes, enforcement proceedings

Commercial Law, Commercial Transactions, Contracts, Civil Law, Insolvency, Real Estate, Litigation

Education and training 2005-2006 2001-2005 Level in national or international classification

Master’s in Civil Law Institutions ( LL.M ) Babes-Bolyai University , Faculty of Law, Cluj-Napoca , Romania Bachelor’s of Law ( LL.A ) Babes-Bolyai University , Faculty of Law, Cluj-Napoca , Romania Level 5 (ISCED)

Personal skills and competences Languages

Romanian - Native Understanding Listening

English French

Reading

Speaking

Writing

Spoken interaction Spoken production

Proficient Proficient Independent Independent C1 C1 B2 B2 B2 user user user user

Independent user

Independent Independent Independent Independent B2 B1 B1 B1 user user user user

Independent user

B2

Common European Framework of Reference for Languages

Personal skills and competences Organisational skills and competence Computer skills and competences Driving licence Additional information

Working in a law firm requires organization, coordination and communication within the working group, and structuring and selecting information held. Computer knowledge ( Word, PowerPoint, Internet ) A, B category In the client focused legal industry, serving the client honestly, capably and responsibly is crucial to success. For the last five years in the law firm in which today operate five lawyers (two of them are also liquidators) and two people on the secretariat, these traits have constantly been seen in all of us. Based on these skills, driven by curiosity, I constantly work to improve my law practice. Most of my work is now focused on private clients whom I assist in law cases before courts, tribunals and courts of appeal. Popescu & Associates

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Team biographies / Roxana Maria Ioaniciu

Popescu & Associates

Personal information Name Address Telephone Fax E-mail Nationality Date of birth Gender Occupational field Work Experience 2010 - Present

Roxana Maria Ioaniciu No.136, Gheorghe Baritiu Street, Turda, Cluj, Romania +40 (0)753 50 93 51 +40 (0)264 311 842 / +40 (0)364 815 675 roxiioaniciu@yahoo.com Romanian 9th September, 1986 Female Lawyer

Lawyer at Popescu & Associates Law Office No. 24, Republicii Str., Turda ,Romania Tel.no.: +40 (0)729 555 787

Main activities and responsibilities

Assisting and representing clients in court in a wide range of legal areas, such as civil, commercial, administrative disputes, enforcement proceedings,bankrupcy; providing legal advice in specialized fields to numerous customers, individuals, companies and state institutions.; writing legal documents, contracts

Type of business

Real Estate,Commercial Law, Commercial Transactions, Contracts, Civil Law, Insolvency, Litigation

Education and training 2009-2011 2004-2009 Level in national or international classification

Master’s in Criminology and Criminal Law ( LL.M ) Dimitrie Cantemir University, Cluj-Napoca, Romania Bachelor’s of Law ( LL.A ) Babes-Bolyai University , Faculty of Law, Cluj-Napoca , Romania Level 5 (ISCED)

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Team biographies / Roxana Maria Ioaniciu

Popescu & Associates

Personal skills and competences Languages

Romanian - Native Understanding Listening

Reading

Speaking

Writing

Spoken interaction Spoken production

English

B2

Independent Independent Independent Independent B2 B2 B2 B2 user user user user

Independent user

French

B2

Independent Independent Independent Independent B2 B1 B1 B1 user user user user

Independent user

Common European Framework of Reference for Languages

Personal skills and competences Social skills and competences

Creativity, adaptability, sociability, perseverance, organizational and communication skills, computer knowledge (Word, Excel, Internet).

Organisational skills and competence

Working in a law firm requires organization, coordination and communication within the working group, and structuring and selecting information held.

Computer skills and competences Driving licence Additional information

Computer knowledge ( Word, Excell, Internet ) B category Although I am the newest in the firm, I soon understood how things work in practice so, now I have my own clients whom I advise and represent in court under the supervision of Mr. ADRIAN LIVIU POPESCU, attorney-at-law. All this was possible in such short time due to my solid theoretical knowledge acquired in college and faculty. I am a social person so it was easy for me to become part of Adrian and Bogdana Popescu’ s team. I work hard, I am a fast learner, I like challenges and competition, I pay attention to details. All this can be easily seen in my drafts and in court.

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