Amended Motion to Travel Unopposed by the Government and Probation, by Daniela Rendon — USA v. Rendon (Dkt. 28, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:23-cr-20036-KMM · Doc. 28 · 2023-03-06 · Docket on CourtListener

Full text

1 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
 
UNITED STATES, 
Plaintiff,  
 
v.  
           Case No. 1:23-cr-20036-KMM 
 
DANIELA RENDON,  
Defendant. 
_______________________________/ 
 
 
AMENDED UNOPPOSED MOTION TO PERMIT TRAVEL 
 
COMES NOW the Defendant, Daniela Rendon, by and through the 
undersigned Counsel, and submits her unopposed motion to permit travel for a 
limited purpose and timeframe, and as grounds therefore alleges as follows: 
1. 
The Defendant requests to be permitted to travel to see her Attorney, 
Robert I. Mandell, Esq., for an in-office legal visit. 
2. 
The Defendant requests to be permitted to travel from her home 
district in Miami-Dade County, Florida to Orlando, Florida, on March 8, 2023. 
3. 
The Defendant will travel from Orlando, Florida and return back to Miami-
Dade, Florida, on March 9, 2023, she anticipates a possible overnight visit in Orlando 
depending on traffic conditions.  
4. 
On March 6, 2023, the undersigned conferred with Assistant United States 
Attorney, Jonathan Bailyn, who advised that he has no objection to permitting the 
Defendant to travel on these dates for said purposes. 
Case 1:23-cr-20036-KMM   Document 28   Entered on FLSD Docket 03/06/2023   Page 1 of 3

 
 
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5. 
On March 6, 2023, the undersigned’s office spoke with Senior United State’s 
Probation Officer, Juan F. Lora, who is the Defendant’s Probation Officer, who stated 
he has no Objections to Ms. Rendon traveling to the United States Middel District of 
Florida, specifically Orlando, for legal visits with her attorney, Robert I. Mandell.   
 
For the foregoing reasons, the Defendant respectfully requests that the Court 
grant this Motion to permit travel on the specific dates listed.  
 
DATED this 6th day of March, 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 
erodriguez@fightforyou.org  
 
 
 
 
 
 
 
 
 
 
 
Case 1:23-cr-20036-KMM   Document 28   Entered on FLSD Docket 03/06/2023   Page 2 of 3

 
 
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CERTIFICATE OF SERVICE 
 
On March 6, 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 28   Entered on FLSD Docket 03/06/2023   Page 3 of 3

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