Court filing

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

Summary

A Consent Motion for Temporary Release of Surrendered Passport, Document 59 filed 09/26/23 in Case 1:23-cr-00344-RDB, captioned Criminal No. 22-mj-01286-JMC, United States v. Ahmed Sary, in the United States District Court for the District of Maryland. Defendant Ahmed Sary, through counsel Julie M. Reamy, asks for an order authorizing the Clerk's Office to temporarily release the surrendered passport of his adult child, Mohamed Sary, for 24 hours so that it can be presented to school officials as proof of United States citizenship to complete enrollment at Liberty University. The motion recalls that the passports were surrendered on May 9, 2022 (ECF Nos. 19-23) and that the defendant was released on May 13, 2022. It states that Assistant U.S. Attorney Paul Riley advised the Government is not opposed, and is dated the 26th day of September 2023.

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Filed September 26, 2023 in USA v. Sary; one of 192 filings from this case.

Record facts

Court	U.S. District Court for the District of Maryland
Filed	2023-09-26

Cite this document

“Consent Motion Temporary Release of Passport by Ahmed M Sary — USA v. Sary (Dkt. 59, D. Md. No. 1:22-mj-01286).” U.S. District Court for the District of Maryland, No. 1:23-cr-00344-RDB, Doc. 59, filed 2023-09-26. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-ahmed-sary-mdd-545200/2023-09-26-gov-uscourts-mdd-545200-59-0-doc-59/, SHA-256 31dfcd4fd00d920e7390ac19846e46f84b7fa0c00ed08ace48df30d2f1d6be8d.

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Full text

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND

UNITED STATES OF AMERICA
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Criminal No.: 22-mj-01286-JMC

AHMED SARY

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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.