Consent MOTION Temporary Release of Surrendered Passport by Ahmed M Sary — USA v. Ahmed Sary - Ahmed M Sary (Dkt. 46)

Summary

A Consent Motion for Temporary Release of Surrendered Passport, Document 46, stamped Filed 08/17/22, 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 notes that Sary surrendered his own and his family's passports on May 9, 2022 after release on May 13, 2022. She asks the Clerk's Office to release his adult son's passport for 24 hours so the son can show proof of citizenship to complete enrollment at Anne Arundel Community College. The Government is not opposed, and the certificate of service is dated the 17th day of August 2022.

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IN THE UNITED STATES DISTRICT COURT  
FOR THE DISTRICT OF MARYLAND 
 
UNITED STATES OF AMERICA  
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v. 
 
 
 
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Criminal No.:  22-mj-01286-JMC 
 
 
 
 
 
 
 
 
AHMED SARY 
 
 
 
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CONSENT MOTION FOR TEMPORARY RELEASE OF SURRENDERED 
PASSPORT 
 
 
The Defendant, Ahmed Sary, by and through counsel, Julie M. Reamy, respectfully 
moves for an order of this Court authorizing the United States District Court Clerk’s Office 
to temporarily release the surrendered passport of his son, Mahmoud Sary, and states the 
following in support of his request: 
1. Mr. Sary was released from detention with conditions in this case on May 13, 
2022.  See ECF No. 30. 
2. On May 9, 2022, Mr. Sary surrendered his U.S. Passport as well as those of his 
wife and children. See ECF Nos. 19-23.  One of the surrendered passports 
belongs to Mr. Sary’s adult child, Mahmoud Sary. 
3. Mahmoud Sary is attempting to enroll at Anne Arundel Community College.    
To complete his enrollment Mahmoud Sary must present his passport as proof 
of United States citizenship to the school’s administrative officials.     
4. Ahmed Sary respectfully requests that this Court permit the temporary release 
of Mahmoud Sary’s passport for 24 hours so that he may present it to Anne 
Arundel Community College officials and complete his enrollment. 
5. The Defendant, Ahmed Sary, respectfully requests that the Court issue an order 
authorizing the U.S. District Court Clerk’s Office to access Mahmoud Sary’s 
Case 1:22-mj-01286-JMC     Document 46     Filed 08/17/22     Page 1 of 2

surrendered passport and directing that office to release it to Mahmoud Sary for 
a period of 24 hours.   
6. Undersigned has discussed this request with Assistant U.S. Attorney, Paul 
Riley, who has advised that the Government is not opposed.   
WHEREFORE the Defendant prays that the Court grant his request and issue the 
attached proposed order.   
 
 
 
 
 
 
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 17th day of August 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 46     Filed 08/17/22     Page 2 of 2

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