Motion for Extension of Time to File Appeal (30) Days; re 66 Motion — USA v. Rendon (Dkt. 70, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:23-cr-20036-KMM · Doc. 70 · 2023-09-01 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
 
UNITED STATES, 
Plaintiff,  
 
v.  
           Case No. 1:23-cr-20036-KMM 
 
DANIELA RENDON,  
Defendant. 
_______________________________/ 
 
DEFENDANT’S MOTION FOR 30 DAY EXTENSION 
 TO FILE AN APPEAL 
 
COMES NOW the undersigned Attorney, on behalf of Daniela Rendon 
and pursuant to this Court’s order, Document No. 68, and respectfully submit 
the Defendant’s request for a 30-day extension in which to file and/or request an 
Appeal in her matter.    
1. 
On January 26, 2023, the Defendant was indicted charging her with 
violations of:               
Count: 1-7 Citation: 18:1343.F  WIRE FRAUD/18:1343.F Count: 10 
Citation: 18:1028A.F AGGRAVATED IDENTITY THEFT/18:1028A.F 
Count: 
8-9 
Citation: 
18:1957-4700.F 
MONEY 
LAUNDERING/18:1957-4700.F.  
2. 
On August 17, 2023, she was sentenced to 41 months as to Count 
Case 1:23-cr-20036-KMM   Document 70   Entered on FLSD Docket 09/01/2023   Page 1 of 4

One, followed by three (3) years of supervised release with special conditions, 
restitution in the amount of $198,990.00 and $100.00 special assessment. 
Defendant’s notice of right to appeal was given.   
3. 
The undersigned’s representation was complete upon sentencing, 
however, did file a motion for return of property on her behalf, DE 64 on August 
21, 2023.  
4. 
On August 28, 2023, Daniela Rendon filed a Pro Se Motion for 
Extension of Appeal, siting reasons of ineffective counsel due to the failure to 
correctly review discovery with her and that counsel failed to make objections 
to her PSR report as requested by Ms. Rendon.  In addition, she claims counsel 
did not disclose his arguments presented at sentencing with her.  
5. 
For the foregoing reasons, the Parties respectfully request the Court 
grant the Defendant’s Motion for a 30-day extension in which to Appeal the 
matter.    
Date:  September 1, 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 70   Entered on FLSD Docket 09/01/2023   Page 2 of 4

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 70   Entered on FLSD Docket 09/01/2023   Page 3 of 4

 
CERTIFICATE OF SERVICE 
 
On September 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.  
Tel: (407)-956-1180 
 
Fax: (407)-386-9550 
 
 
 
 
 
 
 
  
 
Case 1:23-cr-20036-KMM   Document 70   Entered on FLSD Docket 09/01/2023   Page 4 of 4

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