Consent Motion for Protective Order by USA as to Ahmed M Sary — USA v. Sary (Dkt. 37, D. Md. No. 1:22-mj-01286)

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U.S. District Court for the District of Maryland · No. 1:23-cr-00344-RDB · Doc. 37 · 2022-06-09 · Docket on CourtListener

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IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MARYLAND 
 
UNITED STATES OF AMERICA 
* 
* 
v. 
* 
* 
CRIMINAL NO.   22-MJ-01286-JMC 
AHMED SARY 
    
 Defendant 
* 
* 
 
CONSENT MOTION FOR ENTRY OF A PROTECTIVE ORDER  
GOVERNING DISCLOSURE OF PERSONAL IDENTITY, FINANCIAL, CONTACT, 
GRAND JURY, TAX, COURT, AND INVESTIGATIVE INFORMATION 
 
 Pursuant to Rule 16(d) of the Federal Rules of Criminal Procedure, the United States 
hereby moves for entry by this Court of a protective order that will ensure the confidentiality of 
Protected Identity, Financial, Contact, Grand Jury, Tax, Court, and Investigative Information 
(collectively, “Protected Information”), which is or may be included within the evidence in this 
case. 
Entry of a protective order restricting the use, dissemination, and disposition of documents 
containing Protected Information is essential to permit the United States to provide extensive 
discovery to the Defendant while protecting the Protected Information of potential victims and 
other individuals in this case.   
The United States and the Defendant have conferred regarding a draft protective order 
proposed by the United States (the “Proposed Protective Order”) and have reached an agreement 
with respect to the provisions contained therein.  
 
 
 
 
Case 1:23-cr-00344-RDB     Document 37     Filed 06/09/22     Page 1 of 2

2 
A copy of the Proposed Protective Order is submitted herewith. 
 
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
Erek L. Barron  
 
 
 
 
 
 
United States Attorney 
 
 
 
 
 
 
 
By: 
________/s/________________ 
 
 
 
 
 
 
Paul A. Riley 
 
 
 
 
 
 
Abigail E. Ticse 
 
 
 
 
 
 
Assistant United States Attorneys 
 
 
 
 
 
 
36 South Charles St., 4th Floor 
 
 
 
 
 
 
Baltimore, Maryland 21201 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case 1:23-cr-00344-RDB     Document 37     Filed 06/09/22     Page 2 of 2

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