Response to Motion by USA as to Daniela Rendon — USA v. Rendon (Dkt. 87, S.D. Fla.)

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U.S. District Court for the Southern District of Florida · No. 1:23-cr-20036-KMM · Doc. 87 · 2023-10-26 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO: 23-CR-20036-KMM 
 
 
UNITED STATES, 
 
 
v. 
 
DANIEL RENDON, 
 
 
Defendant. 
___________________________/ 
 
 
UNITED STATES’ RESPONSE TO THE DEFENDANT’S  
PRO SE MOTION TO RETURN PROPERTY 
 
The United States does not oppose the Defendant Daniela Rendon’s pro se Motion for 
Return of Property (the “Motion”) [ECF No. 85].  However, the “specific aircraft documents” 
which the Defendant refers to in the Motion are not the property of the Defendant or her mother.  
The aircraft documents are the property of Eliasib Reyes, the Defendant’s fiancé, who surrendered 
his flight certificate and aircraft registration as a condition of the Defendant’s bond [ECF No. 11].  
After co-signing the Defendant’s bond, however, Mr. Reyes was indicted, pled guilty, and was 
sentenced to seven months’ imprisonment on September 11, 2023, for wire fraud.  See United 
States v. Reyes, Case No. 23-cr-20166-ALTONAGA (S.D. Fla. Sept. 11, 2023).  The undersigned 
has conferred with Mr. Reyes’ counsel in United States v. Reyes, Frank Gaviria, who is willing to 
take custody of Mr. Reyes’ aircraft documents, as he has taken custody of Mr. Gaviria’s passport, 
see Reyes, Case No. 23-CR-20166-ALTONAGA (S.D. Fla. Oct. 7, 2023) (granting motion to 
return Mr. Reyes’ passport to the custody of Mr. Gaviria).  The Government therefore does not 
object to Mr. Reyes’ aircraft documents being returned to: 
Frank J. Gaviria, Esq. 
Frank J. Gaviria, P.A. 
Case 1:23-cr-20036-KMM   Document 87   Entered on FLSD Docket 10/26/2023   Page 1 of 2

  
-2- 
14 N.E. 1st Avenue, Suite # 301 
Miami, FL 33132 
Telephone: (305)379-4441 
Email: thefloridalawyer@yahoo.com  
Respectfully submitted,        
     
 
 
 
 
 
 
MARKENZY LAPOINTE 
 
 
 
 
 
 
 
 
 
UNITED STATES ATTORNEY 
 
 
 
 
 
 
BY:  
/s/ Jonathan Bailyn 
 
 
 
 
 
 
 
 
 
Jonathan R. Bailyn, AUSA 
Court ID No. A5502602 
500 South Australian Ave, 4th Floor 
West Palm Beach, Florida 33401 
Phone: (561) 209-1050 
jonathan.bailyn@usdoj.gov 
 
Case 1:23-cr-20036-KMM   Document 87   Entered on FLSD Docket 10/26/2023   Page 2 of 2

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