Amended Motion to Modify Conditions of Release Pusuant — USA v. Rendon (Dkt. 54, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:23-cr-20036-KMM · Doc. 54 · 2023-07-18 · Docket on CourtListener

Full text

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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. 
_______________________________/ 
 
 
REVISED UNOPPOSED MOTION TO ALLOW RETURN OF 
PASSPORT- MODIFY CONDITIONS OF RELEASE 
(Pursuant to US Probation’s request) 
 
 
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 54   Entered on FLSD Docket 07/18/2023   Page 1 of 4

 
 
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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. 
6. 
The Court did issue Paperless Order 52, allowing the return 
of the Defendant’s Niece, Mannuela Heredia Rendon’s, passport. 
7. 
On July 18, 2023, Bernisa Mejiah of the Miami office of 
United States Probation forwarded an email advising the Clerk cannot 
mail the passport to the Defendant’s attorney who is based in Orlando, 
Florida, as well as advising the green card had been surrendered and 
the order would need to be modified to indicate the green card is to be 
returned as well.  
Case 1:23-cr-20036-KMM   Document 54   Entered on FLSD Docket 07/18/2023   Page 2 of 4

 
 
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8. 
We were instructed to request the green card and passport of 
Ms. Rendon’s niece be mailed directly to the United States Probation 
Office at 400 N. Miami Avenue, 9th Floor, Miami, FL 33125, c/o Bernisa 
M. Mejia or Juan Lora.  
 
For the foregoing reasons, the Defendant respectfully requests that 
the Court grant this Revised 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 18th  day of July 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 
 
Email: rmandell@fightforyou.org 
Email: aali@fighgtforyou.org  
kim@fightforyou.org 
 
 
 
 
 
 
 
 
 
CERTIFICATE OF SERVICE 
 
On July 18, 2023 via Conventional Filing, I filed the foregoing with the clerk 
Case 1:23-cr-20036-KMM   Document 54   Entered on FLSD Docket 07/18/2023   Page 3 of 4

 
 
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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 54   Entered on FLSD Docket 07/18/2023   Page 4 of 4

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