Consent MOTION Access to Surrendered Passport by Ahmed M Sary. (Reamy, Julie)… — USA v. Sary - Ahmed M Sary (Dkt. 43)

Summary

A Consent Motion for Access to Surrendered Passport filed August 2, 2022 as Document 43 in United States of America v. Ahmed Sary, Criminal No. 22-mj-01286-JMC (Case 1:23-cr-00344-RDB), District of Maryland. Filed by defense counsel Julie M. Reamy (Federal Bar No. 28232), it states that Ahmed Sary surrendered his U.S. passport and those of his wife and three children on May 9, 2022 (ECF Nos. 19-23) and was released on May 13, 2022 (ECF No. 30), and notes a prior motion granted for his son Mohamed Sary. Ahmed Sary asks the court to authorize the Clerk’s Office to photocopy the front and back pages of the surrendered passport of his adult child Mahmoud Sary (Mamoud Sary) as proof of United States citizenship. Assistant U.S. Attorney Paul Riley advised that 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 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, Mahmoud 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, Mahmoud Sary. 
3. Mamoud Sary wishes to transfer from Salisbury University to Anne Arundel 
Community College to be closer to his family.  In order to enroll and register 
for classes, he will be required to show proof of his United States citizenship, 
which will necessitate a copy of his passport.     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 enrollment officials, if requested.  
4. The Defendant, Ahmed Sary, respectfully requests that the Court issue an order 
authorizing the U.S. District Court Clerk’s Office to access Mamoud Sary’s 
surrendered passport and directing that office to photocopy 1) the front page 
Case 1:23-cr-00344-RDB     Document 43     Filed 08/02/22     Page 1 of 2

bearing Mamoud 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, Mamoud Sary, or undersigned counsel. 
5. For clarification, a similar motion was previously filed and granted regarding 
Mr. Sary’s other son, Mohamed Sary, who needed access to his passport for 
employment purposes.  
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 2nd 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 1:23-cr-00344-RDB     Document 43     Filed 08/02/22     Page 2 of 2

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