Government's Motion for Leave to File Sur-Reply — United States v. Ryan E. Dales (Document 88)

Summary

The Government's motion for leave to file a sur-reply, filed 11/07/24 as Document 88 in United States of America v. Ryan E. Dales, Criminal No. GLR-23-026, U.S. District Court for the District of Maryland, under Local Rule 105.2. It responds to the defendant's reply (ECF No. 86) on the Motion for Reconsideration of the Denial of Defendant's Motion to Suppress (ECF No. 76). The motion lists the filings since October 16, 2024, including the supplement (ECF No. 77), a Motion to Withdraw Argument II (ECF No. 83), the Government's opposition (ECF No. 84) and a Request for Scheduling a Motions Hearing (ECF No. 87). It states that the reply raises new arguments for the first time, attaches the sur-reply as Exhibit 1, and asks the Court to deny ECF No. 76 without a hearing. Paul A. Riley signed it; the block also names Reema Sood.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Government's Motion for Leave to File Sur-Reply — United States v. Ryan E. Dales (Document 88).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-mdd-529188-88-0-9811c0832f/, SHA-256 bba45b81c1950fe632fa8ad20e9a2f8e1e8e198586784b7fac2b62800fd18582.

Full text

Case 1:23-cr-00026-GLR Document 88 Filed 11/07/24 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND

UNITED STATES OF AMERICA *
*
v. *
*
RYAN E. DALES, * CRIMINAL NO. GLR-23-026
*
Defendant. *
*
*******

GOVERNMENT’S MOTION FOR LEAVE TO FILE SUR-REPLY

The United States of America respectfully submits this Motion for Leave to File Sur-reply

in response to Defendant’s Reply to Government’s Opposition to Defendant’s Motion for

Reconsideration of Denial of Motion to Suppress (ECF No. 86), and pursuant to Local Rule 105.2,

hereby states:

1. On October 16, 2024, Defendant filed a Motion for Reconsideration of the Denial

of Defendant’s Motion to Suppress (ECF No. 76).

2. On October 21, 2024, after being alerted to an erroneous statement in his filing,

Defendant filed a Supplement to his Motion, correcting the misstatement (ECF No. 77).

3. On October 28, 2024, Defendant filed a Motion to Withdraw Argument II in

Defendant’s Motion for Reconsideration of Denial of Motion to Suppress (ECF No. 83).

4. On October 30, 2024, the Government filed its Opposition to Defendant’s Motion

to Reconsider (ECF No. 84).

5. On November 5, 2024, Defendant filed his Reply (ECF No. 86) and a Request for

Scheduling a Motions Hearing (ECF No. 87).

6. In Defendant’s Reply, he raises new arguments for the first time. (See Def.’s Reply

at 1–3). As such, the Government has not had a meaningful opportunity to respond. The

1
Case 1:23-cr-00026-GLR Document 88 Filed 11/07/24 Page 2 of 2

Government respectfully requests that this Court accept a brief Sur-reply for this purpose, and,

pending the granting of this Motion, the Government has attached the Sur-reply here as Exhibit 1.

WHEREFORE, the Government respectfully requests that the Court grant this Motion,

accept for filing the Sur-reply, and deny Defendant’s Motion for Reconsideration of the Denial of

Defendant’s Motion to Suppress (ECF No. 76) without a hearing.

Respectfully submitted,
EREK L. BARRON
United States Attorney

By: /s/
Paul A. Riley
Reema Sood
Assistant United States Attorneys
36 S. Charles Street, 4th Fl.
Baltimore, Maryland 21201

File and source

File: gov.uscourts.mdd.529188.88.0.pdf
Size: 117,341 bytes
SHA-256: bba45b81c1950fe632fa8ad20e9a2f8e1e8e198586784b7fac2b62800fd18582
Our copy: gov.uscourts.mdd.529188.88.0.pdf
Original: No public link identified.