Consent MOTION to Modify Conditions of Release by Ahmed M Sary. (Reamy, Julie)… — USA v. Sary - Ahmed M Sary (Dkt. 55)

Summary

A Consent Motion for Modification of Release Conditions filed March 2, 2023, as Document 55 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. It states that Mr. Sary was released from detention on May 13, 2022, initially with home confinement enforced by electronic monitoring, and that on October 6, 2022, the Court modified the conditions to replace home confinement with a daily curfew between 8:00 p.m. and 6:00 a.m. The motion asks that the curfew be modified to the hours of 10:00 p.m. and 6:00 a.m. with continued electronic monitoring. It states that Pretrial Supervision Agent Desiree Akuchie has no objection and that Assistant U.S. Attorney Paul Riley advised the Government has no objection.

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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.  Mr. Sary 
was initially required to submit to home confinement enforced by electronic 
monitoring.  On October 6, 2022, the Court modified Mr. Sary’s conditions to 
replace the home confinement condition with a daily curfew between 8:00 p.m. 
and 6:00 a.m.   Mr. Sary has maintained compliance with all conditions of 
release since his release from detention in this case.  
2. Mr. Sary respectfully requests that his curfew be modified to the hours of 10:00 
p.m. and 6:00 a.m. with continued electronic monitoring.  
3. U.S. Pretrial Supervision Agent, Desiree Akuchie, has no objection to this 
request.  
4. 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 the 
attached order modifying his conditions of release as proposed above.  
 
Case 1:23-cr-00344-RDB     Document 55     Filed 03/02/23     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 2nd day of March 2023, 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 55     Filed 03/02/23     Page 2 of 2

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