MOTION to Modify Conditions of Release /Permission to Reside at… — USA v. Denton - Cindi Ellis Denton (Dkt. 54)

Summary

In United States of America v. Cindi Ellis Denton, CASE NO. 21-60171-CR-SMITH, the defendant moves for permission to reside at a new or changed address. The motion recounts that the Court set a $26,000.00 personal surety bond on April 7, 2021 and that on October 8, 2021, the Court sentenced Ms. Denton to six months imprisonment with a self-surrender on January 10, 2022. It states that standard condition No. 3 bars a change of address without approval and that she has changed her residence and gave the new address to her probation officers. The motion is signed by Manuel Gonzalez, Jr., Esq. and dated the 9th day of December, 2021.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA  
 
UNITED STATES OF AMERICA, 
 
Plaintiff, 
 
v. 
 
 
 
 
 
CASE NO. 21-60171-CR-SMITH   
 
CINDI ELLIS DENTON,    
 
Defendant. 
______________________________/ 
 
                                 DEFENDANT'S MOTION FOR PERMISSION  
TO RESIDE AT NEW/CHANGED ADDRESS 
 
      The Defendant, CINDI ELLIS DENTON, by and through her undersigned counsel, 
respectfully requests this Honorable Court enter an Order granting her permission to reside 
at her new/changed address.  As grounds therefore, it is respectfully submitted: 
1.   On April 7, 2021, the Court set a $26,000.00 personal surety bond continuing the 
bond that had been set in California. [ECF No. 8] On October 8, 2021, this Court 
sentenced Ms. Denton to six months imprisonment with a self-surrender before 2 p.m. on 
January 10, 2022. [ECF No. 53] 
   2.      One of the standard conditions of bond (i.e., No. 3) is that the Defendant may 
not change her present address without prior notification and approval from the U.S. 
Probation Officer or the Court. On or about last Thursday, December 2nd, Ms. Denton was 
evicted and/or told to leave the residence as the owner was in the process of selling the 
residence. As a result, Ms. Denton has changed her residence.  
        3.       The Defendant is seeking permission to remain at the new residence and is 
requesting a Court Order. Ms. Denton’s new address has been provided to Adriana Corona, 
her U.S. Probation/Pretrial Services Officer in California, and Nelson Valenzuela, her U.S.  
 
Case 0:21-cr-60171-RS   Document 54   Entered on FLSD Docket 12/09/2021   Page 1 of 2

 
 
 
 
Probation Officer in the S.D. of Florida. The undersigned has provided the new address, by 
email to Lindsey Friedman Lazopoulos, Assistant United States Attorney, who is on 
Maternity Leave.  
 
         WHEREFORE, the Defendant, CINDI ELLIS DENTON, respectfully requests 
that this Honorable Court enter an Order permitting her to remain at her new/changed her  
address for the reasons stated above. 
 
 
 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that a true and correct copy of the foregoing was 
electronically filed with the Clerk of Court using CM/ECF, this 9th day of  December,  
2021.   
Respectfully submitted, 
 
MANUEL GONZALEZ, JR., ESQ. 
121 Alhambra Plaza, Suite 1500    
Coral Gables, Florida 33134  
(305) 444-1400  
(305) 938-5009  (Fax) 
Mannylaw7@yahoo.com (e-mail) 
 
 
BY: s/Manuel Gonzalez, Jr._________ 
       MANUEL GONZALEZ, JR., ESQ. 
                                                                                    FLORIDA BAR NO. 397997 
 
 
 
 
 
 
 
 
-2- 
 
 
 
 
 
 
 
Case 0:21-cr-60171-RS   Document 54   Entered on FLSD Docket 12/09/2021   Page 2 of 2

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