Consent Motion for Temporary Release of Passport of Mohamed Sary by Ahmed M Sary — USA v. Sary (Dkt. 86, 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. 86 · 2024-08-13 · 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.:  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, 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 minor and adult children. See ECF Nos. 19-23.  One of the surrendered 
passports belongs to Mr. Sary’s adult child, Mohamed Sary. 
3. Mohamed Sary wishes to visit his mother in Egypt between approximately 
August 15, 2024, and September 15, 2024.  Mohamed Sary is not the son of 
Ahmed Sary’s current wife, Izabela Sary, who resides in the United States.  
4. Ahmed Sary respectfully requests that this Court permit the temporary release 
of Mohamed Sary’s passport so that he may travel to visit his mother.  
Mohamed Sary intends to return to the United States on or before September 
15, 2024, and would return the passport to the Court no later than September 
18, 2024.  
Case 1:23-cr-00344-RDB     Document 86     Filed 08/13/24     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 Mohamed Sary’s 
surrendered passport and directing that office to release it to Mohamed 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 13th day of August 2024, 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 86     Filed 08/13/24     Page 2 of 2

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