Agreed Motion to Continue Trial and Calendar Call — USA v. Rendon (Dkt. 24, S.D. Fla.)

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U.S. District Court for the Southern District of Florida · No. 1:23-cr-20036-KMM · Doc. 24 · 2023-03-06 · 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. 
_______________________________/ 
 
AGREED MOTION FOR CONTINUE 
 
COMES NOW the undersigned Attorney, with agreement of United 
States Attorney, Jonathan Bailyn, and respectfully submit their agreed motion 
for continuance in the above styled cause, and as grounds thereof states:  
1. 
On January 26, 2023, the Defendant was indicted charging her 
with violations of : 
Count: 1-7 Citation: 18:1343.F  WIRE FRAUD/18:1343.F Count: 10 Citation: 
18:1028A.F AGGRAVATED IDENTITY THEFT/18:1028A.F Count: 8-9 
Citation: 18:1957-4700.F MONEY LAUNDERING/18:1957-4700.F.  
2. 
When Indictment in this case was filed on January 27, 2023.    
3. 
The Defendant’s counsel was retained on February 9, 2023. 
4. 
The fraud scheme in Counts 1-7 is alleged to have occurred over a 
two-year period, but at this time is unverified. As to the time frame for the 
other charges and counts, the time frame is yet to be determined.  
Case 1:23-cr-20036-KMM   Document 24   Entered on FLSD Docket 03/06/2023   Page 1 of 4

5. 
This is a complex case with multiple counts that include not only 
wire fraud but aggravated identity theft and money laundering, with more than 
usual media attention and scrutiny, because of the Defendant’s higher than 
average media profile as a social media influencer.  
6. 
The parties herein agree that there remain voluminous amounts of 
discovery to be reviewed and examined and resolution to be evaluated.     Both 
parties wish to give this case the time and attention required, in order to 
thoroughly and properly litigate it.   The current schedule with Calendar Call set 
on March 23, 2023, and Trial term to begin on March 27, 2023, rushes litigation 
in this case hinders the investigation and discovery processes for the parties 
involved.  
7. 
The Defendant is filing her waiver of speedy through the end of the 
year with this motion for continuance.  
8. 
For the foregoing reasons, the Parties respectfully request the Court 
grant their Motion to continue, and to reschedule the currently scheduled 
Hearing toward the end of the 2023.  
Date:  March 3, 2023 
                                                                        Respectfully Submitted, 
 
 
/s/ Robert Mandell  
ROBERT I. MANDELL, ESQ. 
FBN: 15484 
/s/ Asad Ali 
Case 1:23-cr-20036-KMM   Document 24   Entered on FLSD Docket 03/06/2023   Page 2 of 4

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 24   Entered on FLSD Docket 03/06/2023   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 24   Entered on FLSD Docket 03/06/2023   Page 4 of 4

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