Consent MOTION to Modify Conditions of Release by Ahmed M Sary. (Reamy, Julie)… — USA v. Sary - Ahmed M Sary (Dkt. 57)

Summary

A two-page Consent Motion for Modification of Release Conditions in United States of America v. Ahmed Sary, Case 1:23-cr-00344-RDB (also captioned Criminal No. 22-mj-01286-JMC), in the U.S. District Court for the District of Maryland, filed July 24, 2023 as Document 57 by counsel Julie M. Reamy. The motion states that Sary was released from detention on May 13, 2022 under home confinement with electronic monitoring, which in October of 2022 was replaced with a curfew and continued electronic monitoring. Sary requests removal of the curfew and placement on electronic monitoring through a stand-alone device that allows the Pretrial Services Office to monitor movement and set digital boundaries such as airports and state lines. It notes that U.S. Pretrial Supervision Agent Desiree Akuchie and Assistant U.S. Attorney Paul Riley have advised that they have no objection to the request.

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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 was initially required to submit to home 
confinement enforced by electronic monitoring.  In October of 2022, the home 
confinement condition was replaced with a curfew with continued 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 that would 
remove the curfew and place him on electronic monitoring through a stand- 
alone device.  This technology will allow the Pretrial Services Office to monitor 
Mr. Sary’s movement and set digital boundaries such as airports and state lines 
that he may not cross without alerting his supervision agent.  Mr. Sary’s 
supervision agent has recommended this condition in place of the curfew and 
current residence-based monitoring due to his longstanding compliance with all 
release conditions.   
Case 1:23-cr-00344-RDB     Document 57     Filed 07/24/23     Page 1 of 2

4. U.S. Pretrial Supervision Agent Desiree Akuchie 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.  
 
 
 
 
 
 
 
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 24th day of July 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 57     Filed 07/24/23     Page 2 of 2

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