Unopposed Motion for Leave to Appear Telephonically at Motion — USA v. Rendon (Dkt. 73, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:23-cr-20036-KMM · Doc. 73 · 2023-09-06 · 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. 
_______________________________/ 
UNOPPOSED MOTION TO APPEAR TELEPHONICALLY 
COMES NOW the undersigned counsel, on behalf of Daniela Rendon, for 
the purposes of her Motion for 30 Day Extension to File and Appeal and 
for Appointment of Counsel to file an Appeal, and as grounds therefore alleges 
as follows: 
1.
The undersigned’s representation ended upon the conclusion of the Sentencing
Hearing on August 17, 2023. 
2.
The Defendant made additional requests to former counsel which was
to provide power of attorneys for her and family members in addition request the 
additional passports and greencards of family memberws be returned.   
3.
The Defendant filed her pro se motion for Extension of time on August
29, 2023. 
Case 1:23-cr-20036-KMM   Document 73   Entered on FLSD Docket 09/06/2023   Page 1 of 4

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ordered the undersigned’s office to file the motion on her behalf or adopt her 
motion.  
5.
   The Court set the matter for hearing on September 7, 2023, for  
10:00 a.m., and then updated the time to 11:30 a.m. as of September 5, 2023. 
6.
The undersigned’s office did not anticipate or make allowances on his
or the firms calendar for an additional hearing in this case and consequentially his 
and his associates calendar is full of hearings on cases in central florida.  
7.
Due to the above stated reasons, the undersigned must respectfully
request the Court to allow him to appear Telephonically. 
8.
On September 5, 2023, the undersigned’s office reached out to Assistant United
States Attorney,  Jonathan Bailyn, who states he has no objection to this motion.
For the foregoing reasons, the Defendant respectfully requests that the Court 
allow his appearance telephonically for the hearing scheduled September 7, 2023 at 
11:30 a.m.   
DATED this 6th day of September, 2023. 
Respectfully submitted, 
4.
On September 1, 2023, the court struck the Defendant’s motion and
Case 1:23-cr-20036-KMM   Document 73   Entered on FLSD Docket 09/06/2023   Page 2 of 4

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Mandell Law, P.A.  
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 
CERTIFICATE OF SERVICE 
On September 6, 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 
Case 1:23-cr-20036-KMM   Document 73   Entered on FLSD Docket 09/06/2023   Page 3 of 4

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/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 
Fax: (407)-386-9550 
Email: rmandell@fightforyou.org 
Email: aali@fighgtforyou.org  
kim@fightforyou.org 
Case 1:23-cr-20036-KMM   Document 73   Entered on FLSD Docket 09/06/2023   Page 4 of 4

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