Pro Se Motion to Compel Ruling on Compassionate Release — United States v. Ahmed Sary

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Case 1:23-cr-00344-RDB Document112- Filed 07/22/25 Page1iof4

UNITED STATES DISTRICT COURT —— FILED

—— LOGeen WO ENTERED

RECEIVg
DISTRICT OF MARYLAND °
JUL 29 2025
BALTIMORE DIVISION arpa,
— ALTIMORE
_ M LAND
DEPuTy
AHMED M. SARY, )
Petitioner,
)
v. Criminal Case Number: 1:23-cr-00344-RDB-|
)
. )
UNITED STATE : E .
S OF AMERICA, ) Honorable Judge Richard D. Bennett

Respondent. )
)

PRO SE MOTION TO COMPEL RULING ON PENDING COMPASSIONATE
RELEASE MOTION [98]

NOW COMES the Defendant, AHMED M. SARY, appearing pro se, and respectfully
moves this Honorable Court to issue a ruling on his pending motion for compassionate

release pursuant to 18 U.S.C. § 3582(c)(1)(A). In support, Defendant states the following:

1. Onor about November 13, 2024, Defendant submitted a sealed motion for compassionate

release, which was docketed as ECF No. 98.

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Case 1:23-cr-00344-RDB Document112 Filed 07/22/25 Page 2of4

Case No. 1:23-cr-00344-RDB-1

The Court acknowledged receipt via letter dated November 14, 2024 (ECF No, 99), and

the Federal Public Defender declined appointment on December 10, 2024 (ECF No, 100),

Since that time, Defendant has submitted several follow-up filings and status updates to
mm . . ‘ ‘ o at ai ©) s Wyd<
the Court, including sealed submissions on March 6, 2025 (ECF No. 108), April 2, 2025

(ECF No. 109), and June 9, 2025 (ECF No, 110).

These filings informed the Court of ongoing family hardship, particularly that
Defendant's wite has had multiple surgeries scheduled and then cancelled due to lack of

available support, causing medical and emotional strain on the family,

Despite these urgent developments, the Court has not ruled on the compassionate release

motion——now pending for over eight months.

Compassionate release under § 3582(¢)(1)(A) was designed by Congress to offer a timely
remedy when “extraordinary and compelling reasons” exist, Delay risks rendering any

relief moot.

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Case 1:23-cr-00344-RDB Document112_ Filed 07/22/25 Page 3of4

Case No.: 1:23-cr-00344-RDB-1

WHEREFORE, Defendant respectfully requests that this Honorable Court:
a) Issue a ruling on his pending compassionate release motion (ECF No. 98); or

b) In the alternative, set a schedule for resolution or require the government to respond;

and

c) Grant such other relief as the Court deems just and proper.

Respectfully Submitted,

hel

Nine Sary

Pro Se I efendant

Register Number 98545-509
Schuylkill FCI

P.O. Box 759

Minersville, PA 17954

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Case No.: 1:23-cr-00344-RDB-1

VERIFICATION

Pursuant to 28 U.S. C. 1746, I declare and verify, under the penalty of perjury under the laws
of the United States of America, that I have read the foregoing and that it is true and correct to
the best of my ability, knowledge & belief.

Dated this 16" day of July 2025.

Signed,

Ahmed M.Aary

CERTIFICATE OF SERVICE

I, hereby certify that I have caused to be served to the U.S. District Clerk (Baltimore), a
- copy of the foregoing document via U.S. pre-paid & first class postage through the United States

Postal Service via the prison mailbox.

Dated this 17" day of July 2025.

Signed,

Meals

Ahmed Wary

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