Motion for Order Authorizing Travel Outside of Charleston County — United States v. Jonathan Ramaci, No. 2:22-cr-00993-RMG (Dkt. 70, D.S.C.)

Summary

Jonathan Ramaci, charged on December 7, 2022 with three counts of wire fraud, asked the court in this motion of December 11, 2023 for leave to travel outside Charleston County, South Carolina (Case No. 2:22-cr-00993-RMG, D.S.C.). The motion says Ramaci was released on a $100,000.00 secured bond after a December 15, 2022 hearing before Magistrate Judge Molly Cherry, has complied with all conditions, and complied with an October 18, 2023 order allowing business travel to Italy. It seeks permission for a December 13, 2023 family day trip to Brookgreen Gardens, a December 18, 2023 drive to a Summerville hospital to pick up the defendant's wife after surgery, and a December 22, 2023 to January 2, 2024 holiday visit to in-laws in Daisytown, Pennsylvania. Probation Officer Graham did not oppose; AUSA Amy Bower did not respond before filing. Jerry N. Theos signed it.

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Full text

IN THE DISTRICT COURT OF THE UNITED STATES
DISTRICT OF SOUTH CAROLINA
CHARLESTON DIVISION

UNITED STATES OF AMERICA, )
) CASE NUMBER: 2:22-cr-00993-RMG
Plaintiff, )
v. ) MOTION FOR ORDER AUTHORIZING
) TRAVEL OUTSIDE OF CHARLESTON
JONATHAN RAMACI, ) COUNTY
)
Defendant. )

PLEASE TAKE NOTICE that the Defendant, by and through undersigned counsel,

hereby respectfully moves this Court for an Order allowing Defendant to travel outside of

Charleston County, South Carolina to the following locations on the below referenced dates, for

the reasons set forth herein.

BACKGROUND

On December 7, 2022, Defendant was charged in the instant Indictment with three counts

of Wire Fraud, in violation of 18 U.S.C. § 1343. ECF No. 3. On December 15, 2022, a bond

hearing was held before United States Magistrate Judge Molly Cherry, at which time Defendant

was released on a $100,000.00 secured bond. ECF No. 25. Thereafter, the Court entered an

Order setting Defendant’s conditions of release, which, in relevant part, restricted Defendant’s

ability to travel outside of Charleston County. 1 See ECF No. 26. To date, Defendant has

complied with all conditions of his bond and has appeared at all required court proceedings.

1
On October 18, 2023, the Court entered an Order Temporarily Modifying Defendant’s
Conditions of Release in order to the allow him to travel to Italy for business purposes. See ECF
Nos. 64, 67. Defendant complied with all of the terms and conditions of the Court’s Order and
promptly reported back to Probation upon his return to the country.
1
ARGUMENT

Defendant respectfully requests an Order from the Court enabling him to travel outside of

Charleston County to the below referenced locations on the following dates for family, medical,

and holiday travel, as outlined below.

LOCATION PURPOSE DATE(S)
Brookgreen Gardens, Defendant plans to drive to Brookgreen Gardens December 13,
1931 Brookgreen Dr, with his family on a day trip to see the Christmas 2023
Murrells Inlet, SC 29576 display. (Day-Trip)

Roper St. Francis Defendant plans to drive to Roper St. Francis December 18,
Berkeley Hospital, Medical Center in Summerville to pick up his wife 2023
100 Callen Blvd. after her surgery.
Summerville, SC 29486

Daisytown, Washington Defendant plans to drive to Daisytown, December 22,
County, Pennsylvania Pennsylvania, which is located outside of 2023- January
Pittsburg, to visit his in-laws for the holidays. 2, 2024

Defendant respectfully submits that his travel requests are appropriately limited in scope

and purpose. Moreover, Defendant does not present a flight risk. He has appeared at all required

court proceedings and has maintained contact with undersigned counsel and Probation

throughout this case, including during his international business trip to Italy. Moreover,

Defendant will certainly comply with any additional conditions that the Court or Probation

deems necessary and proper.

Defendant contacted Probation Officer Graham regarding the above referenced travel

requests. Officer Graham indicated that he did not oppose Defendant’s travel requests but

informed him that he would need to obtain Court approval. Undersigned counsel also attempted

to consult with AUSA Amy Bower regarding this motion but did not receive a response prior to

filing.
2
CONCLUSION

WHEREFORE, Defendant respectfully requests the Court enter an Order allowing him to

travel outside of Charleston County on December 13, 2023, December 18, 2023, and December

22, 2023 through January 2, 2024 for family, medical, and holiday related travel as outlined

herein.

. Respectfully submitted,

s /Jerry N. Theos
Jerry N. Theos, Esq. (Fed. I.D. 4055)
E. Gordon Hay, VI, Esq., (Fed.ID 13490)
Theos Law Firm, LLC
11 State Street
Charleston, SC 29401
jerry@theoslaw.com
gordon@theoslaw.com
(843) 577-7046

&
Joseph P. Griffith, Esquire (Fed I.D. 2473)
Joe Griffith Law Firm, LLC
946 Johnnie Dodds Blvd.
Mt. Pleasant, S.C. 29464
843.225.5563 (tel)
joegriffithjr@hotmail.com
ATTORNEYS FOR DEFENDANT
December 11, 2023
Charleston, SC

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