Plaintiff's Motion to Continue on Emergency Basis — USA v. Rendon (Dkt. 15, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:23-cr-20036-KMM · Doc. 15 · 2023-02-09 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
 
UNITED STATES, 
Plaintiff,  
 
v.  
           Case No. 1:23-cr-20036-KMM 
 
DANIELA RENDON,  
Defendant. 
_______________________________/ 
 
 
DEFENDANT’S EMERGENCY MOTION TO CONTINUE 
 
COMES NOW the Defendant, Daniela Rendon, by and through the 
undersigned Attorney, and submits this unopposed motion to continue the 
sentencing currently scheduled for February 9, 2023. A memorandum of law is 
not required to be filed with this motion pursuant to S. D. Fla. L. Rule 7.1 (a) (1) 
(G). In support of this motion Defendant states as follows: 
1. 
On January 26, 2023, the Defendant was indicted charging her 
with violations  of : 
Count: 1-7 Citation: 18:1343.F Offense Level: 4 WIRE FRAUD/18:1343.F 
Count: 10 Citation: 18:1028A.F Offense Level: 4 AGGRAVATED 
IDENTITY THEFT/18:1028A.F Count: 8-9 Citation: 18:1957-4700.F Offense 
Level: 4 MONEY LAUNDERING/18:1957-4700.F. 
2. 
Through the evening of February 8th and into the morning of 
Case 1:23-cr-20036-KMM   Document 15   Entered on FLSD Docket 02/09/2023   Page 1 of 4

February 9th, 2023, the undersigned counsel was retained to represent this 
Defendant and has not had adequate time to contact parties involved and to make 
arrangements to be present.  
 
3. 
Newly retained counsel is located in Orlando and is unable appear in 
person for the Hearing on Determination of Counsel by 10:00 a.m. and 
respectfully requests a continuance in this matter.          
 
4. 
For the foregoing reasons, the Defendant respectfully requests that 
the Court grant this Motion to continue Hearing on Determination of Counsel 
currently scheduled for February 9, 2023. 
Date:  February 9, 2023 
 
Respectfully Submitted, 
 
 
/s/ Robert Mandell  
ROBERT I. MANDELL, ESQ. 
FBN: 15484 
/s/ Asad Ali 
ASAD ALI, ESQ. 
CO-COUNSEL 
FBN: 111887 
Mandell Law, P.A.  
189 S. Orange Ave. Suite 810 
Orlando, FL 32801 
Tel: (407)-956-1180 
 
Fax: (407)-386-9550 
 
Email: rmandell@fightforyou.org 
Email: aali@fighgtforyou.org  
kim@fightforyou.org 
Case 1:23-cr-20036-KMM   Document 15   Entered on FLSD Docket 02/09/2023   Page 2 of 4

erodriguez@fightforyou.org  
Case 1:23-cr-20036-KMM   Document 15   Entered on FLSD Docket 02/09/2023   Page 3 of 4

 
CERTIFICATE OF SERVICE 
 
On February 9, 2023 via Conventional Filing, I filed the foregoing with the clerk 
of the court which will send notice to:  US Attorney’s Office, Southern District of 
Florida, 99 NE 4th Street, Miami, FL 33132. 
 
/s/ Robert Mandell  
ROBERT I. MANDELL, ESQ. 
FBN: 15484 
/s/ Asad Ali 
ASAD ALI, ESQ. 
CO-COUNSEL 
FBN: 111887 
Mandell Law, P.A.  
189 S. Orange Ave. Suite 810 
Orlando, FL 32801 
Tel: (407)-956-1180 
 
Fax: (407)-386-9550 
 
Email: rmandell@fightforyou.org 
Email: aali@fighgtforyou.org  
kim@fightforyou.org 
erodriguez@fightforyou.org  
 
 
 
 
 
 
  
 
Case 1:23-cr-20036-KMM   Document 15   Entered on FLSD Docket 02/09/2023   Page 4 of 4

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