Response to Motion by USA as to Daniela Rendon — USA v. Rendon (Dkt. 100, S.D. Fla.)

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United States' Response to the Defendant Daniela Rendon's Pro Se Motion to Reduce Sentence, Document 100, entered 07/01/2024 in Case No. 23-CR-20036-MOORE, United States v. Rendon, U.S. District Court for the Southern District of Florida, two pages. The United States states that the defendant filed a pro se Motion to Reduce Sentence Under 18 U.S.C. § 3582 [ECF No. 99], and that defense counsel conferred with the Government and filed an unopposed motion seeking the maximum allowable reduction under Amendment 821 to the United States Sentencing Guidelines [ECF No. 97]. Because the defendant is represented by counsel, the Government argues the pro se motion should be stricken. Alternatively, the United States does not object to considering it as supplemental briefing. It is signed /s/ Jonathan Bailyn, AUSA.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO: 23-CR-20036-MOORE 
 
 
UNITED STATES, 
 
 
v. 
 
DANIELA RENDON, 
 
 
Defendant. 
___________________________/ 
 
 
UNITED STATES’ RESPONSE TO THE DEFENDANT DANIELA RENDON’S PRO SE 
MOTION TO REDUCE SENTENCE 
The Defendant Daniela Rendon has filed a pro se Motion to Reduce Sentence Under 18 
U.S.C. § 3582 [ECF No. 99].  The Defendant is represented by Defense Counsel.  Defense Counsel 
conferred with the Government and filed an unopposed motion to reduce the Defendant’s sentence, 
seeking the maximum allowable reduction under Amendment 821 to the United States Sentencing 
Guidelines.  ECF No. 97.  Because the Defendant is represented by counsel, the Defendant’s pro 
se Motion should be stricken.  See United States v. Singh, Case No. 23-cr-20483-RKA, ECF No. 
76 (S.D. Fla. Apr. 8, 2024) (“In our Circuit . . . we routinely strike pro se filings by litigants who 
are represented by counsel) (citing Whitman v. Clerk of Court, 768 Fed. App’x 228, 231 (11th Cir. 
2010)).  Alternatively, the United States does not object to considering the Defendant’s Motion as 
supplemental briefing. 
Respectfully submitted,        
     
 
 
 
 
 
 
MARKENZY LAPOINTE 
 
 
 
 
 
 
 
 
 
UNITED STATES ATTORNEY 
 
 
 
 
 
 
BY:  
/s/ Jonathan Bailyn 
 
 
 
 
 
 
 
 
 
Jonathan R. Bailyn, AUSA 
Case 1:23-cr-20036-KMM   Document 100   Entered on FLSD Docket 07/01/2024   Page 1 of 2

  
-2- 
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 100   Entered on FLSD Docket 07/01/2024   Page 2 of 2

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