Consent MOTION to Modify Conditions of Release Temporarily by Ahmed M Sary.… — USA v. Sary - Ahmed M Sary (Dkt. 51)

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A Consent Motion to Temporarily Modify Conditions of Release, Document 51 filed 09/22/22 in Case 1:23-cr-00344-RDB, captioned United States of America v. Ahmed Sary, Criminal No. 22-mj-01286-JMC, in the United States District Court for the District of Maryland, Northern Division. The motion states that Mr. Sary was released from detention on May 13, 2022 subject to home confinement enforced by electronic monitoring, and has maintained compliance. It asks to attend a birthday celebration for a minor daughter on Sunday, September 25, 2022 between 12:00 p.m. and 7:00 p.m. at a movie theater and restaurant in a mall complex. The pretrial supervision agent and the Assistant United States Attorney do not object, and the motion is dated the 22nd day of September 2022.

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IN THE UNITED STATES DISTRICT COURT  
FOR THE DISTRICT OF MARYLAND 
NORTHERN DIVISION 
 
UNITED STATES OF AMERICA  
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v. 
 
 
 
 
*  Criminal No.:  22-mj-01286-JMC 
 
AHMED SARY 
 
 
 
* 
 
 
 
 
 
 
 
Defendant 
 
 
* 
 
* 
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CONSENT MOTION TO TEMPORARIILY MODIFY CONDITIONS OF RELEASE 
 
The Defendant, Ahmed Sary, by undersigned counsel, hereby files this Motion to 
Temporarily Modify Conditions of Release, and states the following in support thereof: 
1. 
Mr. Sary was released from detention on May 13, 2022.  As a condition of release, 
Mr. Sary is required to submit to home confinement enforced by electronic 
monitoring.  
2. 
Mr. Sary has maintained compliance with all conditions of his release to date.  
3. 
Mr. Sary would like to attend a birthday celebration for his minor daughter on Sunday, 
September 25, 2022, outside of his residence.  Specifically, Mr. Sary and his wife 
would like to take their daughter to a movie at Cinemark Egyptian 24 and dinner at 
the Olive Garden, each of which are located within the Arundel Mills Mall complex, 
between 12:00 p.m. and 7:00 p.m.  The exact address of each establishment has been 
provided to Mr. Sary’s pretrial supervision agent.  
4. 
A similar request relating to Mr. Sary’s other minor daughter was granted in July of 
2022.  Mr. Sary maintained complete compliance with all release conditions while on 
leave from his residence pursuant to that request.  
5. 
U.S. Pretrial Supervision Agent, Celine Ferguson, has no objection to this request. 
Case 1:23-cr-00344-RDB     Document 51     Filed 09/22/22     Page 1 of 2

6. 
Assistant United States Attorney, Paul Riley, has advised undersigned that the 
Government does not object to this request. 
7. 
WHEREFORE, the Defendant respectfully requests that this Court grant his request 
and temporarily modify the conditions of his release.   
Respectfully submitted, 
 
 
 
 
 
______________/s/__________________ 
 
 
 
 
 
Julie M. Reamy 
 
 
 
 
 
JULIE M. REAMY | Attorney At Law, LLC 
 
 
 
 
 
210 Allegheny Avenue, Suite 100 
 
 
 
 
 
Towson, Maryland 21204 
 
 
 
 
 
Telephone: (410) 605-0000 
 
 
 
 
 
Fax: (410) 697-4006 
 
 
 
 
 
Email: juliereamy@gmail.com 
 
 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on this 22nd day of September 2022, a PDF version of this Motion 
was filed electronically via ECF with the Clerk of the United States District Court for the 
District of Maryland and thereby served upon Assistant U.S. Attorney, Paul Riley.  A copy of 
this motion was also emailed to U.S. Pre-trial Agent, Celine Ferguson. 
 
 
 
 
 
 
 
 
 
 
 
 
____________/s/____________________ 
 
 
 
 
 
Julie M. Reamy 
 
 
 
 
 
 
 
 
Attorney for Ahmed Sary 
 
 
 
 
 
 
 
Case 1:23-cr-00344-RDB     Document 51     Filed 09/22/22     Page 2 of 2

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