Consent Motion Temporary Release of Passport by Ahmed M Sary — USA v. Sary (Dkt. 59, D. Md. No. 1:22-mj-01286)

Record facts

U.S. District Court for the District of Maryland · No. 1:23-cr-00344-RDB · Doc. 59 · 2023-09-26 · Docket on CourtListener

Full text

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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* 
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CONSENT MOTION FOR TEMPORARY RELEASE OF 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 temporarily release the surrendered passport of his son, Mohamed Sary, and states the 
following in support of his request: 
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 children. See ECF Nos. 19-23.  One of the surrendered passports 
belongs to Mr. Sary’s adult child, Mohamed Sary. 
3. Mohamed Sary is attempting to enroll at Liberty University.    To complete his 
enrollment Mahmoud Sary must present his passport as proof of United States 
citizenship to the school’s administrative officials.     
4. Ahmed Sary respectfully requests that this Court permit the temporary release 
of Mahmoud Sary’s passport for 24 hours (or until the next business day if 
released on a Friday) so that he may present it to school officials and complete 
his enrollment. 
Case 1:23-cr-00344-RDB     Document 59     Filed 09/26/23     Page 1 of 2

5. The Defendant, Ahmed Sary, respectfully requests that the Court issue an order 
authorizing the U.S. District Court Clerk’s Office to access Mohamed Sary’s 
surrendered passport and directing that office to release it to Mohamed Sary for 
a period of 24 hours.   
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 26th day of September 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 59     Filed 09/26/23     Page 2 of 2

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