Supplement to Motion for Reconsideration — United States v. Dales (District of Maryland, Document 77)

Summary

A supplement to a motion for reconsideration filed October 21, 2024, by defendant Ryan Dales in Case 1:23-cr-00026-GLR, U.S. District Court for the District of Maryland (Document 77). It corrects a statement in the motion, ECF 76, that discovery gave no source for the affiant's allegation that an IP address "resolved" to the VOA. The supplement states that the Government pointed to a single page at page 31,305 of the discovery, attached as Exhibit 1, from Verizon that identifies the Volunteers of America as being related to the IP address. It argues that this source was not included in the search warrant affidavit, which it says remains insufficient under the Aguilar/Spinelli line of cases. The signature block names Richard Bardos of Schulman, Hershfield & Gilden, P.A.

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  Case 1:23-cr-00026-GLR           Document 77        Filed 10/21/24      Page 1 of 2



                      UNITED STATES DISTRICT COURT
                      FOR THE DISTRICT OF MARYLAND


UNITED STATES OF AMERICA                      *

       V.                                     *                Cr. No. GLR-23-026

RYAN DALES                                    *

               Defendant                      *

For: RYAN DALES                               *

            SUPPLEMENT TO MOTION FOR RECONSIDERATION

       Defendant, Ryan Dales, submits this supplement to his motion for

reconsideration to supplement the record and correct an incorrect statement in that

motions and states     ;

       In his motion, ECF 76, the motion states “Discovery in this case, by

undersigned counsel’[s] careful review, does not provide any source for the affiant’s

allegation that the IP address “resolved” to the VOA..” ECF 76, p.7, n.7. After

receiving the defendant’s motion, the Government contacted defense counsel to point

out that the statement in the motion is incorrect. In fact, at page 31,305 of the

discovery there is a single page, attached hereto as Exhibit 1, from Verizon that

identifies the Volunteers of America as being related to IP address. Defense counsel

had not found that document among the over 38,000 pages of discovery.

       In any event, that reference and the source of the IP address “resolving” to the

VOA was not included in the search warrant affidavit and that affidavit remains

insufficient under the Aguilar/Spinelli line of cases as cited in the motion for

reconsideration. Further, this Verizon document does not give any indication of

whether a computer at VOA or a cell phone was used to connect to the internet when

the COVID loan applications were filed.
  Case 1:23-cr-00026-GLR         Document 77       Filed 10/21/24     Page 2 of 2




                                  Respectfully submitted,

                                     _______/s/__________________
                                     Richard Bardos
                                     Schulman, Hershfield & Gilden, P.A.
                                     1 East Pratt Street, 9th Floor
                                     Baltimore, Maryland 21202
                                     (410) 332 0850


                          CERTIFICATE OF SERVICE

    I HEREBY CERTIFY that on this 21st of October, 2024, a copy of the
foregoing was served electronically by ECF to: Office of the United States Attorney,
36 South Charles Street, Fourth Floor, Baltimore, Maryland 21201 and all defense
counsel.

                              _____/s/______________________
                              Richard Bardos


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