Unopposed Motion to Modify Conditions of Release (Amended as to Curfew Hours) — USA v. Rendon (Dkt. 45, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:23-cr-20036-KMM · Doc. 45 · 2023-05-02 · 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 MODIFY 
 CONDITIONS OF RELEASE 
(AS TO CURFEW HOURS) 
 
COMES NOW the Defendant, Daniela Rendon, by and through 
the undersigned Counsel, and submits her unopposed motion to modify 
the conditions of her release prior to Sentencing, and as grounds 
therefore alleges as follows: 
1. 
The Defendant just entered into a plea agreement in this case and 
anticipates being sentenced in the Court’s due time.  
2. 
The Defendant has several personal and business items that require 
her  attention prior to  sentencing and is thereroe requesting the following 
modification to the  conditions of her release: 
3. 
The Defendant’s curfew shall be between the hours of 10:00 
Case 1:23-cr-20036-KMM   Document 45   Entered on FLSD Docket 05/02/2023   Page 1 of 3

 
 
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p.m to 6:00 a.m.; electronic monitoring shall remain in effect. 
4. 
The Defendant shall be permitted to travel from her home 
district in Miami-Dade County, Florida to Orlando, Florida, on for legal 
visits to her attorney’s office. 
5. 
The Defendant’s counsel did ask her Probation Officer, Juan 
Lora, for Probation’s position and he has stated that he had no objections 
on the curfew, or her travel to the Middle District of Florida for 
ATTORNEY VISITS ONLY.  
6. 
On May 1, 2023, the undersigned conferred with Assistant 
United States Attorney, Jonathan Bailyn, who advised that he has no 
objection to the mentioned conditions of the Defendant’s release. 
 
For the foregoing reasons, the Defendant respectfully requests that 
the Court grant this Motion to modify the above-mentioned conditions of 
the Defendant’s release.  
DATED this 2ND  day of May, 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.  
Case 1:23-cr-20036-KMM   Document 45   Entered on FLSD Docket 05/02/2023   Page 2 of 3

 
 
3 
189 S. Orange Ave. Suite 810 
Orlando, FL 32801 
Tel: (407)-956-1180 
 
Email: rmandell@fightforyou.org 
Email: aali@fighgtforyou.org  
kim@fightforyou.org 
 
 
 
 
 
 
 
 
 
CERTIFICATE OF SERVICE 
 
On May 1, 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 
 
Email: rmandell@fightforyou.org 
Email: aali@fighgtforyou.org  
kim@fightforyou.org 
 
 
 
 
 
 
  
 
 
Case 1:23-cr-20036-KMM   Document 45   Entered on FLSD Docket 05/02/2023   Page 3 of 3

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