Consent MOTION to Modify Conditions of Release by Ahmed M Sary. (Reamy, Julie)… — USA v. Sary - Ahmed M Sary (Dkt. 53)

Summary

A Consent Motion for Modification of Release Conditions, Document 53, filed 10/06/22 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, states that he was released from detention on May 13, 2022 subject to home confinement enforced by electronic monitoring and has maintained compliance with all conditions. He asks to modify the release conditions from 24-hour home confinement to a curfew between the hours of 8:00 p.m. and 6:00 a.m. with continued electronic monitoring, and states that the U.S. Pretrial Supervision Agent and Assistant U.S. Attorney Paul Riley have no objection. It is signed /s/ Julie M. Reamy, with a certificate of service dated the 6th day of October 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 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 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 is requesting a modification of his release conditions from 24-hour 
home confinement to a curfew between the hours of 8:00 p.m. and 6:00 a.m. 
with continued electronic monitoring.   
4. U.S. Pretrial Supervision Agent, Celine Ferguson, has advised undersigned that 
she has no objection to this request.  
5. Assistant U.S. Attorney, Paul Riley, has advised that the Government has no 
objection to this request.   
WHEREFORE the Defendant prays that the Court grant his request and issue an 
modifying his conditions of release as proposed above.  
 
Case 1:23-cr-00344-RDB     Document 53     Filed 10/06/22     Page 1 of 2

 
 
 
 
 
 
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 October 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 53     Filed 10/06/22     Page 2 of 2

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