Unopposed Motion to Modify Conditions of Release -Allow the Return — USA v. Rendon (Dkt. 50, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:23-cr-20036-KMM · Doc. 50 · 2023-07-12 · 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. 
_______________________________/ 
 
 
UNOPPOSED MOTION TO ALLOW RETURN OF PASSPORT- 
MODIFY CONDITIONS OF RELEASE 
 
 
COMES NOW the Defendant, Daniela Rendon, by and through 
the undersigned Counsel, and submits her unopposed motion to allow 
for the return of the Defendant’s neice’s passport to allow the niece to 
travel to Columbia for a summer visit with her mother, who resides in 
Columbia; a modification of one of the conditions of her release prior to 
Sentencing, and as grounds therefore alleges as follows: 
1. 
The Defendant has entered into a plea agreement in this case and 
anticipates being sentenced on August 10, 2023 at 2:00 p.m.  
2. 
The Defendant and her family, including her niece, Mannuela 
Heredia Rendon, had agreed to surrender of their passports as a condition of the 
Case 1:23-cr-20036-KMM   Document 50   Entered on FLSD Docket 07/12/2023   Page 1 of 3

 
 
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Defendant’s release prior to sentencing: 
3. 
The Defendant’s niece according to regular visitation with 
her parents, was to visit with her mother during the summer vacation 
months and needs her passport returned in order to return to Columbia 
to have her regular visitation with her mother. 
4. 
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 return of the niece’s passport.   
5. 
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, and allow the niece, Mannuela Heredia Rendon 
to have her passport returned.  
DATED this 12th  day of July, 2023.  
  
 
 
 
 
 
Respectfully submitted,  
 
 
 
 
 
 
 
 
 
 
/s/ Robert Mandell  
ROBERT I. MANDELL, ESQ. 
FBN: 15484 
/s/ Asad Ali 
ASAD ALI, ESQ. 
CO-COUNSEL 
Case 1:23-cr-20036-KMM   Document 50   Entered on FLSD Docket 07/12/2023   Page 2 of 3

 
 
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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 
 
 
 
 
 
 
 
 
 
CERTIFICATE OF SERVICE 
 
On July 12, 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 50   Entered on FLSD Docket 07/12/2023   Page 3 of 3

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