Motion to Modify Restitution Payment Schedule — United States v. Jonathan E. Ramaci (Entry Number 194)

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A three-page Motion to Modify Restitution Payment Schedule pursuant to 18 U.S.C. §§ 3664(k) and 3572(d)(3), filed April 28, 2026 as Entry Number 194 in United States of America v. Jonathan E. Ramaci, Case No. 2:22-cr-00993-RMG-1, in the U.S. District Court for the District of South Carolina. Ramaci, proceeding pro se, states that he was sentenced on February 7, 2025 and ordered to pay restitution of $1,547,862.88 at $500 per month, and asserts a material and involuntary change in economic circumstances, including unemployment and court-imposed travel restrictions. He asks the Court to reduce payments to $50 per month, set a nominal amount until employment is secured, or temporarily suspend payments.

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2:22-cr-00993-RMG Date Filed 04/28/26 Entry Number 194 Page 1 of 3

UNITED STATES DISTRICT COURT

District of South Carolina

United States of America
v.

Jonathan E. Ramaci,
Defendant.

Case No. 2:22-cr-00993-RMG-1

MOTION TO MODIFY RESTITUTION PAYMENT SCHEDULE

PURSUANT TO 18 U.S.C. §§ 3664(k) AND 3572(d)(3)

COMES NOW the Defendant, Jonathan E. Ramaci, proceeding pro se, and respectfully moves
this Honorable Court to modify the restitution payment schedule based on a material and
involuntary change in economic circumstances. In support, Defendant states:

I. INTRODUCTION

This Motion is brought due to a substantial, unforeseen, and continuing decline in
Defendant’s financial condition, rendering compliance with the current restitution schedule
impracticable. The current payment obligation no longer reflects Defendant’s actual ability to
pay and risks becoming punitive rather than compensatory, contrary to the purpose of federal
restitution law.

Il, MATERIAL CHANGE IN ECONOMIC CIRCUMSTANCES

1. Defendant, Jonathan E, Ramaci, was sentenced on February 7, 2025 and ordered to pay
restitution in the amount of $1,547,862.88 with scheduled payments of $500 per month.
2. Since sentencing, Defendant has experienced a significant and material change in
economic circumstances, including:
o Ongoing unemployment despite diligent, good-faith efforts to secure
employment;
o Substantial reduction in income and financial resources;
o Inability to meet both basic living expenses and restitution obligations.
2:22-cr-00993-RMG Date Filed 04/28/26 Entry Number 194 Page 2 of 3

3. Defendant is constrained by court-imposed travel restrictions, which:
o Prevent acceptance of viable employment opportunities outside a limited area;
o Significantly restrict Defendant’s earning capacity;
o Directly contribute to Defendant’s continued unemployment.
4, These circumstances constitute a material, non-speculative, and ongoing change that
was not reasonably anticipated at the time of sentencing.

Il. LEGAL AUTHORITY

A. Statutory Authority for Modification

6. Under 18 U.S.C. § 3664(k), the Court may adjust a restitution payment schedule upon
notice of a material change in the defendant’s economic circumstances affecting the
ability to pay.

7. Additionally, 18 U.S.C. § 3572(d)(3) authorizes modification of payment schedules when
a defendant’s financial condition materially changes.

B. Restitution Must Reflect Ability to Pay

8. Restitution is intended to be compensatory rather than punitive, and payment
schedules must be grounded in a defendant’s actual financial capacity.

9. Courts have recognized that unrealistic payment obligations undermine compliance and
frustrate the purpose of restitution.

C. Constitutional Considerations

10. The Supreme Court has held that a defendant cannot be penalized solely due to inability
to pay. Bearden v. Georgia, 461 U.S. 660 (1983).
11, Defendant’s circumstances demonstrate:

¢ No willful refusal to pay;
e A genuine inability to comply;
¢ Good-faith efforts to obtain employment.

12. Maintaining the current payment schedule under these conditions risk violating
fundamental fairness principles.
2:22-cr-00993-RMG Date Filed 04/28/26 Entry Number 194 Page 3 of 3

D. Impact of Court-Imposed Restrictions

13. Defendant’s travel restrictions materially impair earning capacity, limiting access to
employment opportunities.

14. A payment schedule based on income Defendant is effectively prevented from earning
is inequitable and contrary to statutory intent.

E. Interests of Justice
15. Modification of the payment schedule will:
e Promote compliance;
e Encourage lawful employment;

¢ Increase the likelihood of eventual restitution recovery.

16. A realistic payment structure better serves both the victim’s long-term interests and
the Court’s enforcement objectives.

IV. REQUEST FOR RELIEF
WHEREFORE, Defendant Jonathan E, Ramaci respectfully requests that this Court:

1. Modify the restitution payment schedule to reflect Defendant’s current financial
condition;
2. Order one or more of the following:
o Reduce payments to $50 per month;
o Inthe alternative, set a nominal payment amount until employment is secured;
o Temporarily suspend restitution payments if deemed appropriate;
3. Grant such other relief as the Court deems just and proper.

V. DECLARATION

I, Jonathan E. Ramaci, declare under penalty of perjury that the foregoing is true and correct.

Date: Lhekit. 25, 20262

Respectfully submitted, 5 ; 4 :

Jonathan E. Ramaci


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