Defendant’s Reply Motion to Reconsider Sentence — United States v. Sumakovic (Dkt. 229, N.D. Ill.)

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Defendant Milica Sumakovic's reply in support of her motion to reconsider sentence in United States v. Milica Sumakovic, Case No. 20-CR-750-6, in the U.S. District Court for the Northern District of Illinois, filed June 28, 2024 as Document #: 229. It recites that she filed the motion on May 24, 2024 (Doc. 226) and the government responded on June 12, 2024 (Doc. 228). It states that after surrendering she was taken to FCI Aliceville, a low security institution, while the court had envisioned FPC Alderson, a minimum security camp, and asks the court to reconsider her sentence in light of her time in pretrial home incarceration.

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Case: 1:20-cr-00750 Document #: 229 Filed: 06/28/24 Page 1 of 2 PageID #:1284




                      IN THE UNITED STATES DISTRICT COURT
                     FOR THE NORTHERN DISTRICT OF ILLINOIS

UNITED STATES OF AMERICA,                            )
               Plaintiff,                            )
                                                     )       Case No. 20-CR-750-6
       v.                                            )
                                                     )       Judge Nancy Maldonado
MILICA SUMAKOVIC,                                    )
              Defendant.                             )

            DEFENDANT’S REPLY MOTION TO RECONSIDER SENTENCE

       NOW COMES, the Defendant, MILICA SUMAKOVIC, by and through her attorney,

RICHARD M. BEUKE, and in support of Defendant’s Motion to Reconsider Sentence, Ms.

Sumakovic states the following:

       1.      On May 24, 2024, Ms. Sumakovic filed a motion entitled Defendant’s Motion to

Reconsider Sentence. (Doc. 226).

       2.      On June 12, 2024, the Government filed its Response to that Motion. (Doc. 228).

       3.      Since that date, Ms. Sumakovic has surrendered to the custody of the United States

Bureau of Prisons. Upon surrender, Ms. Sumakovic was taken to Federal Correctional Institute

(FCI) Aliceville in the Northern District of Alabama. That FCI is a low security federal institution

with an adjacent minimum security satellite camp.         However, upon sentencing, the Court

envisioned Ms. Sumakovic being taken to FPC Alderson, which is a minimum security federal

prison camp. (Doc. 223).

       4.      When the sentence a Defendant receives does not reflect the intent of the sentencing

court, “[s]uch a correction is clearly within the power of the court.” United States v. Lawrenson,

196 F. Supp. 838, 840 (D. Md. 1961), aff’d, 298 F.2d 880 (4th Cir. 1962), citing United States v.

Leather, 271 F.2d 80 (7th Cir. 1959).




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   Case: 1:20-cr-00750 Document #: 229 Filed: 06/28/24 Page 2 of 2 PageID #:1285




       5.      Ms. Sumakoivc humbly requests that this Court reconsider her sentence, taking into

account the amount of time Ms. Sumakovic spent in pretrial home incarceration and the fact that

she has been taken to a federal prison facility with greater restrictions and less resources than the

facility in which the Court intended her to be housed.

       WHEREFORE, for all the reasons stated in Defendant’s Motion to Reconsider Sentence

and all of the reasons stated above, Milica Sumakovic respectfully asks this Court to reconsider

her sentence to account for her pretrial custody and her assignment to a facility other than a

minimum security federal prison camp.

                                      Respectfully submitted,

                                      /s/ Richard M. Beuke
                                      Richard M. Beuke
                                      Attorney for the Defendant, Milica Sumakovic

RICHARD M. BEUKE
801 N. Cass Avenue, Suite 200
Westmont, Illinois 60559
(312) 427-3050 – phone
(312) 427-1215 – fax




                                 CERTIFICATE OF SERVICE

        I, Nicole Terrazas, hereby certify that Defendant’s Reply Motion to Reconsider Sentence
was served on June 28, 2024, in accordance with Federal Rule of Criminal Procedure 49, Federal
Rule of Civil Procedure 5, and Local Rule 5-1 pursuant to the District Court’s system for ECF
filers.

                                      /s/ Nicole Terrazas
                                      Nicole Terrazas
                                      801 N. Cass Avenue, Suite 200
                                      Westmont, Illinois 60559
                                      (312) 427-3050 – phone
                                      (312) 427-1215 – fax

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