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Defendant’s Notice to Court Regarding Use of Expert Testimony at Sentencing Hearing — No. 2:22-cr-00993 (Dkt. 131, D.S.C.)

Summary

Defendant Jonathan Ramaci's notice to the court regarding use of expert testimony at his sentencing hearing, filed January 1, 2025 as Entry Number 131 in United States v. Ramaci, Criminal No. 2:22-cr-993-RMG, in the U.S. District Court for the District of South Carolina. The notice states that he does not intend to offer expert testimony at the hearing, referring to the text order entered December 16, 2024 (ECF # 128). It discloses that he has obtained an expert report on the government's tax loss calculations, which he will offer only as mitigation with his sentencing memorandum and motion for downward departure or variance.

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“Defendant’s Notice to Court Regarding Use of Expert Testimony at Sentencing Hearing — No. 2:22-cr-00993 (Dkt. 131, D.S.C.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/defendant-s-notice-to-court-regarding-use-of-expert-testimony-at-sente-7b00ce9077/, SHA-256 1c09ab25d5d56277876396374a559353f2b7504d2b1197b5fb1698e872d8f1ed.

Full text

   2:22-cr-00993-RMG            Date Filed 01/01/25      Entry Number 131         Page 1 of 2




                               UNITED STATES DISTRICT COURT
                                DISTRICT OF SOUTH CAROLINA

UNITED STATES OF AMERICA      )               Criminal No. 2:22-cr-993-RMG
                              )
v.                            )               DEFENDANT’S NOTICE TO COURT
                              )               REGARDING USE OF EXPERT TESTIMONY
JONATHAN RAMACI               )               AT SENTENCING HEARING
______________________________)

        Defendant Jonathan Ramaci (“Defendant”), by and through his undersigned attorneys,

hereby notifies the Court that Defendant does not intend to offer expert testimony during the

Defendant’s sentencing hearing.

        On December 16, 2024, the Court entered the following text order:

        TEXT ORDER as to Jonathan Ramaci: If Defendant intends to offer expert testimony
        during the Defendant's sentencing hearing, he must file a written expert report on or
        before 1/1/25. The Government may then file an expert report in response on or before
        1/10/25. If Defendant determines not to offer expert testimony at the sentencing hearing,
        he should provide the Court and the Government notice on or before 1/1/25. AND IT IS
        SO ORDERED. ECF # 128.

        In full disclosure to the Court and the Government, the Defendant has obtained an expert

report regarding the Government’s tax loss calculations and Defendant will solely offer the said

report as mitigation. Unless otherwise ordered by the Court, Defendant intends to provide the

Court and Government said expert report when he files his anticipated sentencing memorandum

and motion for downward departure and/or variance.

        Respectfully submitted,

/s/ Joseph P. Griffith, Jr. (Fed. ID. 2473)   Jerry N. Theos
Joe Griffith Law Firm, LLC                    Gordon E. Hay
946 Johnnie Dodds Blvd.                       11 State Street
Mt. Pleasant, SC 29464                        Charleston, SC 29401
(843) 225-5563                                (843) 577-7046
joe@joegriffith.com                           jerry@theoslawfirm.com
                                              gordon@theoslawfirm.com
Attorneys for Jonathan Ramaci
2:22-cr-00993-RMG   Date Filed 01/01/25   Entry Number 131   Page 2 of 2

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