Consent MOTION to Modify Conditions of Release by Ahmed M Sary — USA v. Ahmed Sary - Ahmed M Sary (Dkt. 55)

Summary

A Consent Motion for Modification of Release Conditions, Document 55, stamped Filed 03/02/23, 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, which was replaced on October 6, 2022 by a daily curfew between 8:00 p.m. and 6:00 a.m., and that he has complied with all conditions. She asks to change the curfew to 10:00 p.m. to 6:00 a.m. with continued electronic monitoring. Pretrial Services and the Government have no objection, and the certificate of service is dated the 2nd day of March 2023.

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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 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 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.  Mr. Sary 
was initially required to submit to home confinement enforced by electronic 
monitoring.  On October 6, 2022, the Court modified Mr. Sary’s conditions to 
replace the home confinement condition with a daily curfew between 8:00 p.m. 
and 6:00 a.m.   Mr. Sary has maintained compliance with all conditions of 
release since his release from detention in this case.  
2. Mr. Sary respectfully requests that his curfew be modified to the hours of 10:00 
p.m. and 6:00 a.m. with continued electronic monitoring.  
3. U.S. Pretrial Supervision Agent, Desiree Akuchie, has no objection to this 
request.  
4. Assistant U.S. Attorney, Paul Riley, has advised that the Government has no 
objection to this request.   
WHEREFORE the Defendant prays that the Court grant his request and issue the 
attached order modifying his conditions of release as proposed above.  
 
Case 1:22-mj-01286-JMC     Document 55     Filed 03/02/23     Page 1 of 2

 
 
 
 
 
 
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 2nd day of March 2023, 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 55     Filed 03/02/23     Page 2 of 2

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