Motion for Return of Bond — United States v. Jonathan Ramaci, No. 2:22-cr-00993-RMG (Dkt. 159, D.S.C.)
Summary
Motion filed February 17, 2025, in United States v. Jonathan Ramaci, Case Number 2:22-cr-00993-RMG, in the District of South Carolina, Charleston Division, asking the Court to return the surety bond or cash security posted for the defendant. The motion says that on or about December 16, 2022, Haverly Ramaci, the spouse of the defendant, deposited a cash security of $5,000.00 for the bond. It says the Court entered a final judgment on February 7, 2025, sentencing Jonathan Ramaci to a term of incarceration in the Bureau of Prisons, and that Jonathan Ramaci has fully complied with the bond conditions and will remain compliant until reporting. It asks that the security be returned to Haverly Ramaci once Jonathan Ramaci reports to serve the sentence. Counsel are Jerry N. Theos and E. Gordon Hay, VI, of Theos Law Firm, LLC, and Joseph P. Griffith, Jr.
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Full text
2:22-cr-00993-RMG Date Filed 02/17/25 Entry Number 159 Page 1 of 2
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 RETURN OF BOND
)
JONATHAN RAMACI, )
)
Defendant.
The Defendant, by and through his undersigned counsel, hereby moves this Honorable
Court for an Order returning the surety bond and/or cash security in the above referenced case.
On or about December 16, 2022, the Defendant’s spouse, Mrs. Haverly Ramaci, deposited
a cash security in the amount of $5,000.00 as security for Defendant’s bond. The Court entered a
final judgment on February 7, 2025, sentencing Defendant to a term of incarceration in the Bureau
of Prisons. To date, the Defendant has fully complied with the conditions of his bond. He will
remain on bond and compliant with the conditions of his bond until such time he reports to the
Bureau of Prisons.
Based on the foregoing, the Defendant respectfully moves the Court to enter an Order
returning the above referenced surety bond and/or cash security to Mrs. Haverly Ramaci upon the
Defendant reporting to serve his sentence in the Bureau of Prisons.
By: 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
&
2:22-cr-00993-RMG Date Filed 02/17/25 Entry Number 159 Page 2 of 2
/s/ Joseph P. Griffith, Jr.
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
February 17, 2025
Charleston, SC
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