Unopposed MOTION for Return of Property/PostTrial , Return of Children's Passports and Green… — USA v. RENDON (Dkt. 64)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:23-cr-20036-KMM · Doc. 64 · 2023-08-21 · 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/REVISED AND UNOPPOSED MOTION TO ALLOW  
RETURN OF CHILDRENS PASSPORTS AND GREEN CARDS 
 
 
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 children and neice’s passports and 
green cards and as grounds therefore alleges as follows: 
1. 
The Defendant has entered into a plea agreement in this case and 
and was Sentenced on August 17, 2023.  
2. 
The Defendant and her family and children, including her niece, 
Mannuela Heredia Rendon, had agreed to surrender of their passports as a 
condition of the Defendant’s release prior to sentencing.  
3. 
In a prior motion the Defendant’s niece’s passport was 
Case 1:23-cr-20036-KMM   Document 64   Entered on FLSD Docket 08/21/2023   Page 1 of 4

 
 
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requested to be turned, the Defendant’s counsel was only notified after 
the initial passport was attempted to be picked up that her, (their) green 
cards needed to be requested to be returned as well.  The Court issued 
an order for the return of the neice’s passport and left the amended 
asking for the greencard as well, unanswered.  
4. 
Now that the Defendant has been sentenced and is in 
custody, her counsel is requesting the return of all of the childrens 
passports and greencards, their names and dates of birth are: 
5. 
On August 21, 2023, the undersigned conferred with 
Assistant United States Attorney, Jonathan Bailyn, who advised that 
he has no objection to return of the children’s passports and green cards. 
6. 
The children’s natural grandmother, Gilda Isabel Andrade 
Sarmiento is granted by the Defendant, full custodial care and authority 
of the children while she is incarcerated and would ask the Court to have 
pretrial services, (or whatever agency retaines them at this time), to 
release the passports and greencards directly to Gilda Isabel Andrade 
Case 1:23-cr-20036-KMM   Document 64   Entered on FLSD Docket 08/21/2023   Page 2 of 4

 
 
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Sarmiento.   
 
For the foregoing reasons, the Defendant respectfully requests that 
the Court grant this Amended/Revised Motion for release of Children’s 
passports and green cards to the childrens natural grandmother, Gilda 
Isabel Andrade Sarmiento. 
  
DATED this 21st  day of August, 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 
Email: aali@fighgtforyou.org  
kim@fightforyou.org 
 
 
 
 
 
 
 
 
CERTIFICATE OF SERVICE 
 
On August 21, 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. 
Case 1:23-cr-20036-KMM   Document 64   Entered on FLSD Docket 08/21/2023   Page 3 of 4

 
 
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FBN: 15484 
/s/ Asad Ali 
ASAD ALI, ESQ. 
CO-COUNSEL 
FBN: 111887 
Mandell Law, P.A.  
Tel: (407)-956-1180 
 
 
 
 
 
 
 
  
 
 
Case 1:23-cr-20036-KMM   Document 64   Entered on FLSD Docket 08/21/2023   Page 4 of 4

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