Motion Return of Surrendered U.S. Passports by Ahmed M Sary — USA v. Sary (Dkt. 101, 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. 101 · 2024-12-24 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT  
FOR THE DISTRICT OF MARYLAND 
NORTHERN DIVISION 
 
UNITED STATES OF AMERICA  
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*     Criminal No. RDB 23-344 
v. 
 
 
 
 
 
 
 
 
 
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AHMED SARY 
 
 
 
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Defendant 
 
 
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MOTION FOR RETURN OF PASSPORTS 
 
 
Defendant, Ahmed Sary, by and through counsel, Julie M. Reamy, Esquire, hereby 
moves for return of his and his wife and children’s U.S. Passports, which were previously 
surrendered to the Court as a condition of pretrial release.   
1.  On April 29, 2022, Mr. Sary had an initial appearance on a complaint charging him 
with a violation of 18 U.S.C. §§ 1343, 1349, and 1956.  He was placed on pretrial 
release with conditions on May 9, 2022.  
2.  Pursuant to those conditions, the passports of Mr. Sary, his wife and children were 
surrendered to the Clerk of the U.S. District Court for the District of Maryland on 
May 9, 2022. 
3. Mr. Sary entered a guilty plea on October 18, 2024, and was sentenced to a term of 
imprisonment on June 25, 2024.  Mr. Sary is currently in the custody of the Bureau of 
Prisons.  
4. The surrender of passports condition applied only to pretrial release.  
5. The passports of Mr. Sary’s two adult children (ending 4458 and 4459) were 
previously released.  
Case 1:23-cr-00344-RDB     Document 101     Filed 12/24/24     Page 1 of 2

6. Now that Mr. Sary has been sentenced, he respectfully requests the release of all the 
passports that remain in the custody of the Clerk’s Office. (See ECF Nos. 19 - 23; 
passport surrender receipts).  
7. Mr. Sary requests that his passport, his wife, Izabela Sary’s, passport, and those of their 
minor children be released to Izabela Sary.   
8. WHEREFORE, Mr. Sary respectfully requests that the Court pass an order authorizing 
the release of the surrendered passports by the Clerk of the Court. 
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
__________/s/_____________________ 
 
 
 
 
 
 
Julie M. Reamy 
 
 
 
 
 
 
 
Federal Bar No.: 28232 
 
 
 
 
 
 
 
JULIE M. REAMY | Attorney At Law, LLC 
 
 
 
 
 
 
 
One Olympic Place, Suite 900 
 
 
 
 
 
 
 
Towson, Maryland 21204 
 
 
 
 
 
 
 
Ofc: (410) 605-0000 
 
 
 
 
 
 
 
Email: juliereamy@gmail.com 
 
CERTIFICATE OF SERVICE 
 
 
I HEREBY CERTIFY that on this 24th day of December 2024, the foregoing was 
electronically filed via the Court’s CM/ECF filing system and served upon the counsel for the 
Government.  
 
 
 
 
 
 
 
 
_________/s/____________________ 
 
 
 
 
 
 
 
Julie M. Reamy 
 
 
Case 1:23-cr-00344-RDB     Document 101     Filed 12/24/24     Page 2 of 2

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