Court filing

Consent MOTION Temporary Release of Passport by Ahmed M Sary — USA v. Sary - Ahmed M Sary (Dkt. 71)

Record facts

Court	U.S. District Court for the District of Maryland
Filed	2024-04-16

U.S. District Court for the District of Maryland · No. 1:23-cr-00344-RDB · Doc. 71 · 2024-04-16 · Docket on CourtListener

Summary

A consent motion for temporary release of a surrendered passport, filed April 16, 2024 as Doc. 71 by Defendant Ahmed Sary in United States v. Ahmed Sary, No. 1:23-cr-00344-RDB, in the U.S. District Court for the District of Maryland. The motion states that Mr. Sary was released from detention with conditions on May 13, 2022 and that passports were surrendered on May 9, 2022. It asks the Court to authorize the Clerk's Office to temporarily release one surrendered passport belonging to a family member for travel, with the passport to be returned to the Court no later than June 3, 2024. The motion states that the government is not opposed, and it is signed by defense counsel Julie M. Reamy with a certificate of service.

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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.: RDB 23-0344

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 adult son, Mahmoud 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 minor and adult children. See ECF Nos. 19-23. One of the surrendered
passports belongs to Mr. Sary’s adult child, Mahmoud Sary.
3. Mahmoud Sary wishes to visit his mother in Egypt between approximately
April 27, 2024, and May 31, 2024. Mahmoud Sary is not the son of Ahmed
Sary’s current wife, Izabela Sary.
4. Ahmed Sary respectfully requests that this Court permit the temporary release
of Mahmoud Sary’s passport so that he may travel to visit his mother.
Mahmoud Sary intends to return to the United States on or before May 31, 2024,
and would return the passport to the Court no later than June 3, 2024.
Case 1:23-cr-00344-RDB Document 71 Filed 04/16/24 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 Mahmoud Sary’s
surrendered passport and directing that office to release it to Mahmoud Sary.
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 110

Baltimore, Maryland 21204

Ofc: (410) 605-0000

Fax: (410) 697-4006

Email: juliereamy@gmail.com

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 16th day of April 2024, this document was filed
with the Clerk of U.S. District Court and a copy served upon, Assistant United States
Attorney, Paul Riley.