Consent MOTION to Modify Conditions of Release Temporarily by Ahmed M Sary — USA v. Ahmed Sary - Ahmed M Sary (Dkt. 41)

Summary

A Consent Motion for Temporary Modification of Release Conditions, Document 41, stamped Filed 07/22/22, in United States v. Ahmed Sary, Criminal No. 22-mj-01286-JMC, in the United States District Court for the District of Maryland. Defense counsel Julie M. Reamy states that Sary was released on May 13, 2022 on home confinement with electronic monitoring and has complied with all conditions. She asks to let him attend his minor daughter's birthday celebration at a restaurant on Sunday, July 24, 2022 between 2:00 p.m. and 6:00 p.m. Pretrial Services has no objection and the Government is not opposed. The certificate of service is dated the 21st day of July 2022.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Record facts

Full text

IN THE UNITED STATES DISTRICT COURT  
FOR THE DISTRICT OF MARYLAND 
 
UNITED STATES OF AMERICA  
* 
 
 
 
v. 
 
 
 
* 
Criminal No.:  22-mj-01286-JMC 
 
 
 
 
 
 
 
 
AHMED SARY 
 
 
 
* 
 
* 
*  
*  
*  
*  
*  
*  
*  
*  
*  
*  
*  
 
CONSENT MOTION FOR TEMPORARY MODIFICATION OF RELEASE 
CONDITIONS 
 
 
The Defendant, Ahmed Sary, by and through counsel, Julie M. Reamy, respectfully 
moves for an order of this Court authorizing a temporary modification of his release 
conditions and states the following in support of his motion.  
1. Mr. Sary was released from detention in this case on May 13, 2022.  As a 
condition of his release, Mr. Sary is required to submit to home confinement 
enforced by electronic monitoring.   
2. Mr. Sary has maintained compliance with all conditions of release since his 
release from detention in this case.  
3. Mr. Sary wishes to attend a birthday celebration for his minor daughter at an 
area restaurant on Sunday, July 24, 2022, between 2:00 p.m. and 6:00 p.m.  The 
address of the restaurant has been provided to Mr. Sary’s assigned pretrial 
supervision agent and Assistant United States Attorney, Paul Riley.  
4. U.S. Pretrial Supervision Agent, Celine Ferguson, has advised undersigned that 
she has no objection to this request.  
5. Undersigned has also discussed this request with Assistant U.S. Attorney, Paul 
Riley, who has advised that the Government is not opposed.   
Case 1:22-mj-01286-JMC     Document 41     Filed 07/22/22     Page 1 of 2

WHEREFORE the Defendant prays that the Court grant his request and issue an 
order temporarily modifying his conditions of release so that he may attend his 
daughter’s birthday celebration on July 24, 2022.   
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
/s/ Julie M. Reamy 
 
 
 
 
 
 
Julie M. Reamy 
 
 
 
 
 
 
Federal Bar No. 28232 
 
 
 
 
 
 
JULIE M. REAMY | Attorney At Law, LLC 
 
 
 
 
 
 
210 Allegheny Avenue, Suite 100 
 
 
 
 
 
 
Baltimore, Maryland 21204 
 
 
 
 
 
 
Ofc: (410) 605-0000 
 
 
 
 
 
 
Fax: (410) 697-4006 
 
 
 
 
 
 
Email: juliereamy@gmail.com 
 
 
 
 
 
 
 
 
CERTIFICATE OF SERVICE 
 
 
I HEREBY CERTIFY that on this 21st day of July 2022, this document was filed 
with the Clerk of U.S. District Court and a copy served upon, Assistant United States 
Attorney, Paul Riley. 
 
 
 
 
 
 
 
 
 
 
/s/ Julie M. Reamy 
 
 
 
 
 
 
Julie M. Reamy 
 
 
Case 1:22-mj-01286-JMC     Document 41     Filed 07/22/22     Page 2 of 2

File and source

File

gov.uscourts.mdd.511816.41.0.pdf

Size

93,990 bytes

SHA-256

f5151668993537e0989aeb996f98812c5d2f583ec086c3ea7540fd629cc9f2b8

Our copy

gov.uscourts.mdd.511816.41.0.pdf

Original

PACER (login required)