Motion for Extension of Time to Surrender by Ahmed M Sary — USA v. Sary (Dkt. 89, 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. 89 · 2024-09-18 · 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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MOTION FOR EXTENSION OF TIME FOR VOLUNTARY SURRENDER 
 
 
Defendant, Ahmed Sary, by and through counsel, Julie M. Reamy, hereby moves for an 
extension of time for his voluntary surrender to the Bureau of Prisons.  Mr. Sary asserts the 
following in support of his request. 
1. On October 18, 2023, Mr. Sary entered a guilty plea to one count of conspiracy to 
commit wire fraud in violation of 18 U.S.C. §§ 1349 and 1343.  
2. On June 25, 2024, Mr. Sary was sentenced to 84 months of imprisonment to be 
followed by 12 months of home detention and 3 years of supervised release.  The Court 
set a voluntary surrender date of September 25, 2024, pending designation and 
surrender instructions by the Bureau of Prisons.   
3. Mr. Sary has not yet received his designation and reporting instructions from the 
Bureau of Prisons.  
4. Mr. Sary’s residence suffered a catastrophic fire in January 2024, which led to the 
displacement of Mr. Sary and his family, which includes his wife and five children.  
Three of Mr. Sary’s children are under 11 years old.   There are remaining structural, 
electrical, and plumbing repairs, among other things, that must be completed before the 
house will pass inspection and Mr. Sary’s family can return to the home.   
Case 1:23-cr-00344-RDB     Document 89     Filed 09/18/24     Page 1 of 2

5. Mr. Sary seeks an extension of his voluntary surrender date to December 27, 2024, to 
allow additional time for the necessary repairs to be completed and to move his family 
back into the home before he begins his sentence.   
6. Assistant United States Attorney Paul Riley consents to an extension of 45 days, but 
objects to any further extension at this time.  
WHEREFORE, Mr. Sary respectfully requests that this Court grant his motion and pass an 
order extending his voluntary surrender date to December 27, 2024.   
 
 
 
 
 
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 18th day of September 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 89     Filed 09/18/24     Page 2 of 2

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