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

Summary

A Consent Motion for Temporary Modification of Release Conditions filed July 22, 2022, as Document 41 in Case 1:23-cr-00344-RDB in the U.S. District Court for the District of Maryland, by defendant Ahmed Sary through counsel Julie M. Reamy. The motion states that Mr. Sary was released from detention on May 13, 2022, is required to submit to home confinement enforced by electronic monitoring, and has maintained compliance with all conditions of release. It asks for an order so that Mr. Sary may 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. It states that the pretrial supervision agent has no objection and that Assistant U.S. Attorney Paul Riley advised the Government is not opposed.

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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 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 1:23-cr-00344-RDB     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 1:23-cr-00344-RDB     Document 41     Filed 07/22/22     Page 2 of 2

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