Consent MOTION Access to Surrendered Passport by Ahmed M Sary. (Reamy, Julie)… — USA v. Sary - Ahmed M Sary (Dkt. 39)

Summary

A Consent Motion for Access to Surrendered Passport, Document 39, filed 07/06/22 under Case 1:23-cr-00344-RDB in United States of America v. Ahmed Sary, Criminal No. 22-mj-01286-JMC, in the United States District Court for the District of Maryland. The Defendant, through counsel Julie M. Reamy, asks the Court to authorize the Clerk's Office to access a passport surrendered on May 9, 2022 and to provide photocopies of its front page and back page, citing an employment application with a submission deadline of July 6, 2022. The motion states that the defendant was released with conditions on May 13, 2022 (ECF No. 30) and that Assistant U.S. Attorney Paul Riley advised that the Government is not opposed. It is signed /s/ Julie M. Reamy, with a certificate of service dated the 6th day of July 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 ACCESS TO 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 access the surrendered passport of his son, Mohamed Sary, and to provide photocopies 
of said passport to the Defendant. 
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 three children. See ECF Nos. 19-23.  One of the surrendered passports 
belongs to Mr. Sary’s adult child, Mohamed Sary. 
3. Mohamed Sary wishes to apply for employment in Baltimore, which requires 
that he show proof of his United States citizenship.  The only way in which 
Mohamed Sary can satisfy that requirement is to attach a copy of his passport 
to the employment application.   If Mohamed Sary is offered the position in the 
future, he will have to produce the original passport to the potential employer 
for inspection.  While Mr. Sary is not requesting physical possession of the 
passport at this time, he may request a temporary return of the passport to 
present to the potential employer if an offer of employment is extended to him 
in the future.   
Case 1:23-cr-00344-RDB     Document 39     Filed 07/06/22     Page 1 of 2

4. The application submission deadline is July 6, 2022. 
5. The Defendant, Ahmed Sary, respectfully requests that the Court issue an order 
authorizing the U.S. District Court Clerk’s Office to access Mohamed Sary’s 
surrendered passport and directing that office to photocopy 1) the front page 
bearing Mohamed Sary’s photograph and personal identifying information 2) 
the back page bearing the passport’s bar code and PPN, and 3) provide the 
photocopies to the Defendant, Mohamed Sary, or undersigned counsel. 
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 6th 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 1:23-cr-00344-RDB     Document 39     Filed 07/06/22     Page 2 of 2

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