Court filing

Defendant’s Pre-Sentence Memorandum and Objections — United States v. Sumakovic (Dkt. 203, N.D. Ill.)

Summary

Marko Nikolic, through attorneys Michael P. Gillespie and Michael Krejci, filed this sentencing memorandum on January 10, 2024 in Case No. 1:20-cr-00750 in the Northern District of Illinois. Nikolic pleaded guilty on May 22, 2023 before Judge Nancy Maldonado to Counts Eight and Thirty-Two of the superseding indictment, wire fraud and money laundering. The memorandum seeks a two-point zero-point offender reduction under the 2023 guidelines and argues the offense caused no substantial financial hardship to individual victims, since it was aimed at a federal aid program; the agreed loss is at least $17,700,000 but not more than $25,000,000. It also credits Nikolic's cooperation with about $1,000,000 the government seized or recovered.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Filed January 10, 2024 in Milica Sumakovic; one of 6 filings from this case.

Record facts

Court	U.S. District Court for the Northern District of Illinois
Filed	2024-01-10

Cite this document

“Defendant’s Pre-Sentence Memorandum and Objections — United States v. Sumakovic (Dkt. 203, N.D. Ill.).” U.S. District Court for the Northern District of Illinois, No. 1:20-cr-00750, Doc. 203, filed 2024-01-10. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/us-v-milica-sumakovic/2024-01-10-defendant-s-pre-sentence-memorandum-and-objections-dkt-203/, SHA-256 b135ad1055f8dc604d80ed8855b9e36436bdf52e08f98bfb3df10c7b39afd2f7.

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Full text

Case: 1:20-cr-00750 Document #: 203 Filed: 01/10/24 Page 1 of 16 PageID #:1029

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

UNITED STATES OF AMERICA )
)
)
)
v. )
) Case No. 1:20CR00750-2
) Hon. Judge Nancy Maldonado
)
MARKO NIKOLIC )
)

DEFENDANT’S PRE-SENTENCE MEMORANDUM AND OBJECTIONS

Defendant Marko Nikolic, by and through his attorneys, Michael P. Gillespie and

Michael Krejci, respectfully submits this Sentencing Memorandum in order to provide

information to assist the Court in fashioning a sentence “sufficient but not greater than

necessary” to achieve the statutory punishment as required by 18 U.S.C. §3553(a). Defendant

states as follows:

OVERVIEW OF SENTENCING REPORT

Mr. Nikolic is charged in violation of 18 U.S.C. § 1343 (Wire Fraud) and 18 U.S.C. §

1956(a)(2)(B)(i) (Money Laundering).

On May 22nd, 2023, Mr. Nikolic appeared before the Honorable Judge Nancy Maldonado

and entered a plea of guilty to Counts Eight and Thirty-Two of the superseding indictment.

GUIDELINES

Mr. Nikolic agrees with the calculated offense levels, special offense characteristics, and

adjustments for acceptance of responsibility as provided in the Presentence Report (“PSR”).

Mr. Nikolic additionally provides he is a zero-point offender is additionally eligible for a

two-point reduction under §4C1.1 as he has no prior convictions and no criminal history points.

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As noted by this Honorable Court as of November 1, 2023, the 2023 Sentencing Guidelines

are in effect. As noted by the Court, the amendments include a new guideline under §4C1.1 that

provides a decrease of two offense levels for "Zero-Point Offenders," that is, offenders with no

criminal history, as long as certain requirements are met. As provided in the Court’s docket

entry, this Honorable Court expects Defendant's and the Government's forthcoming sentencing

memoranda to opine on the impact of the amendments (including the amendment in §4C1.1 or

any other potentially relevant amendments) on the guidelines calculations in the PSR, if any.

§4C1.1 defines “zero-point offenders” as those offenders with no criminal history points,

including (1) offenders with no prior convictions; (2) offenders who have prior convictions that

are not counted because those convictions were not within the time limits set forth in subsection

(d) and (e) of §4A1.2 (Definitions and Instructions for Computing Criminal History); and (3)

offenders who have prior convictions that are not used in computing the CHC for reasons other

than their “staleness” (e.g., sentences resulting from foreign or tribal court convictions, minor

misdemeanor convictions, or infractions). Offenders must meet the following criteria under

§4C1.1:

1. the Defendant has not received any criminal history points;

2. the Defendant has not received an adjustment for terrorism (covered by § 3A1.4);

3. the Defendant did not use violence or credible threats of violence in connection with the

offense;

4. the offense did not result in death or serious bodily injury;

5. the offense of conviction is not a sex offense;

6. the defendant did not personally cause substantial financial hardship (to be determined

independently of the application of § 2B1.1(b)(c));

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7. the Defendant did not possess, receive, purchase, transport, transfer, sell, or otherwise

dispose of a firearm or other dangerous weapon (or induce another participant to do so) in

connection with the offense;

8. the offense of conviction is not an offense involving individual rights (covered by §

2H1.1);

9. the Defendant did not receive an adjustment under § 3A1.1 (hate crime motivation or

vulnerable victim) or § 3A1.5 (serious human rights offense); and,

10. the Defendant did not receive an adjustment under § 3B1.1 (aggravating role) and was

not engaged in a continuing criminal enterprise.

Mr. Nikolic has not received any criminal history points, has not received an adjustment for

terrorism, did not use violence or threats of credible violence, the offense did not result in death

or serious bodily injury, the instant matter is not a sex offense, Mr. Nikolic did not possess

firearms in the commission of this offense, the instant offense is not one involving individual

rights, Mr. Nikolic did not receive an adjustment under § 3A1.1 or § 3A1.5, and Mr. Nikolic did

not receive an adjustment under § 3B1.1 and was not engaged in a criminal enterprise.

Mr. Nikolic does note that although the plea agreement applied a leadership enhancement

regarding the wire fraud offense under § 3B1.1(b) because Mr. Nikolic was a manager and

supervisor and the criminal activity involved 5 or more participants and was otherwise extensive.

However as noted in the Presentence Investigation Report, pursuant §1B1.5(c) and §2S1.1,

Application Note 2(C), because the money laundering offense level is determined by referencing

another guideline, that is §2B1.1, the adjustments are determined in respect to the money

laundering offense. Because Mr. Nikolic was not a leader in the money laundering offense, the

adjustment for an aggravating role under §3B1.1 is not applied.

Case: 1:20-cr-00750 Document #: 203 Filed: 01/10/24 Page 4 of 16 PageID #:1032

The remaining determination for this Honorable Court to determine if Mr. Nikolic is if the

instant offense resulted in a substantial financial hardship, a determination that must be made

independently from the application of § 2B1.1(b)(c). Courts have generally applied a subjective

standard to the determination of whether a victim has suffered “substantial financial hardship.”1

The Seventh Circuit has provided the most extensive discussion of the enhancement thus

far.2 In United States v. Minhas, the court held that the fact that the hardship must be

“substantial” introduces a relativity requirement as “the same dollar harm to one victim may

result in a substantial financial hardship, while for another it may be only a minor hiccup.”3

As part of the plea agreement, the parties have agreed the loss amount in the instant

matter is at least $17,700,000 but not more than $25,000,000.

Mr. Nikolic wholeheartedly accepts responsibility for this immense financial crime, and

is profoundly remorseful for his role within it. Given the nature of the offense, the criminal act

preyed upon a federal government aid package intending to provide emergency financial

assistance to millions of Americans who were suffering from the economic effects of the

COVID-19 pandemic. The scheme itself ran counter to the intention behind the aid, but

ultimately impacted the United States Government, and as a result, the American taxpayer.

While the amount of funds involved in the instant matter is unquestionably significant, there is

not a substantial financial hardship to any particular victim given the size and scope of the

federal government and the number of American taxpayers.

1
See e.g., United States v. Poulson, 871 F.3d 261, 268 (3d Cir. 2017) (“We agree with the observation by our
sister circuits that the determination of ‘substantial financial hardship’ is subject to the usual—and
significant—degree of discretion afforded a district court during sentencing…[and] [t]hat discretion is crucial
as §2B1.1’s increased emphasis on individual harm means that ‘substantial financial hardship’ is measured on
a sliding scale that is also fairly subjective.”).
2
See generally United States v. Minhas, 850 F.3d 873 (7th Cir. 2017).
3
Id. at 877–78

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Additionally, Mr. Nikolic respectfully asks this Honorable Court to note that Mr.

Nikolic’s co-defendant Branko Aleksic was granted this adjustment under §4C1.1 upon

agreement of the parties on November 2nd, 2023.

Again, in no way does Mr. Nikolic attempt to downplay the immensity of this crime. Mr.

Nikolic makes this point simply to support that this Honorable Court determine he is a Zero

Point Offender under §4C1.1 given that he has zero criminal history points and no prior criminal

convictions.

THE DEFENDANT’S CRIMINAL HISTORY

Mr. Nikolic agrees with his criminal history, criminal history computation and criminal

history score as provided in the PSR.

SENTENCING OPTIONS

Custody

Statutory Provisions:

Mr. Nikolic agrees to the statutory provisions outlined in the PSR.

Guideline Provisions:

Mr. Nikolic provides that his total offense level should be 28 with a criminal history

category of I due to the fact Mr. Nikolic is a zero-point offender is additionally eligible for a

two-point reduction under §4C1.1 as he has no prior convictions. As a result, Mr. Nikolic

provides that the guideline imprisonment range should be 78 to 97 months.

Supervised Release

Mr. Nikolic agrees to the supervised release provisions as outlined by the PSR.

Supervised Release Conditions

Mr. Nikolic agrees to the terms outlined by Probation Officer Jessica S. Cook.

Case: 1:20-cr-00750 Document #: 203 Filed: 01/10/24 Page 6 of 16 PageID #:1034

Probation

Mr. Nikolic agrees he is eligible for not less than one not more than five years’ probation

because the offense is a Class C Felony. 18 U.S.C. § 3561(c)(1).

Fines

Mr. Nikolic agrees to the fine provisions and assessments as outlined by the PSR.

Restitution

Mr. Nikolic agrees to the restitution calculations in the PSR.

As discussed in further detail below, Mr. Nikolic has diligently worked towards paying as

much of his restitution amount as possible prior to sentencing. As of sentencing, Mr. Nikolic has

paid approximately $800,000 towards his restitution amount with $160,000 in a BMO Harris

account that will be forfeited to the Government. This is in addition to the approximately

$1,000,000 the Government has been able to seize/recover through the Defendant’s cooperation.

INTRODUCTION

Marko Nikolic is truly sorry for what he has done and how he has disappointed those that

he loves. He is profoundly humbled and deeply ashamed of himself: that his actions have not

only affected his community and his life, but also the lives of his closest loved ones. There is no

denying the seriousness of Mr. Nikolic’s transgressions, and he does not intend on doing so – he

was clearly wrong. Instead, he offers himself to the mercy of this Court, to take into

consideration not only those actions that brought him before this Court, but to take into

consideration the full value of a man’s life when fashioning a reasonable sentence.

Taking together the nature and circumstances of the instant offense, his personal history

Case: 1:20-cr-00750 Document #: 203 Filed: 01/10/24 Page 7 of 16 PageID #:1035

and characteristics, Mr. Nikolic respectfully asks this Honorable Court for leniency when

imposing a sentence, one that is sufficient, but not greater than necessary, to comply with the

purposes of sentencing.

FACTORS TO CONSIDER FOR SENTENCING

Defendant submits this memorandum in order to assist the Court in fashioning the most

appropriate sentence by addressing each of the available sentencing options under the provisions

of 18 U.S.C. §3553(a), as now constitutionally required by the Supreme Court in light of United

States v. Booker, 543 U.S. 220, 125 S.Ct. 738, 160 L.Ed.2d 621 (2005). This memorandum will

supplement the Presentence Report (“PSR”) and submit reasons why this Court should consider

and grant a sentence that is below or “in variance” with the advisory Guideline level based on

various factors in mitigation.

The purpose of sentencing as reflected in 18 U.S.C 3553 is not to be punitive but rather to

be just based on the offense and offender. Under 18 U.S.C. §3553(a)(2) the Court shall impose a

sentence sufficient, but not greater necessary to reflect the purposes of sentencing, including, the

need for just punishment, the need for deterrence, protection of the public, and the rehabilitation

of the defendant. §3553 also orders courts to consider the history and characteristics of the

defendant as well as the nature and circumstances of the offense.

Nature of Offense

Marko Nikolic accepts full responsibility for his actions and provides to this Honorable

Court he did commit the offense as charged and he makes no excuses for his actions whatsoever.

It should be noted that this conspiracy was the original product of his sister Maya and

Nebojsa Simeunovic. They began in January of 2020 by submitting false applications for loans

from the Small Business Administration under the Economic Injury Disaster Loan (EIDL)

Case: 1:20-cr-00750 Document #: 203 Filed: 01/10/24 Page 8 of 16 PageID #:1036

Program and receive Government funding. It was in the summer of 2020 that Nebojsa and Maya

asked him to assist in preparing and submitting false loan applications.

As to allegations of attempted flight in the Government’s Version of the Offense, Mr.

Nikolic respectfully provides that he was in the process of moving to Florida, not fleeing the

country. Mr. Nikolic not only planned to move to Florida, but already had accommodations in

place at the time of his arrest.4

The Government’s Version of the Offense also details that Mr. Nikolic bought numerous

material goods including a Lamborghini Urus, which along with other assets, has since been

liquidated and applied towards his restitution amount.

Following his sentencing, Marko Nikolic will become a convicted felon for the first time

in his life. As noted in his Presentence Investigation Report, he will likely be amenable to arrest

for violations of the Immigration and Nationality Act upon his judgement entered in the instant

matter.

Cooperation and Restitution

Since the time of his arrest, Mr. Nikolic has reflected on the greed and poor decisions that

have brought him before this Honorable Court, and he has diligently worked towards righting the

wrongs that he has committed.

Mr. Nikolic has provided substantial assistance to authorities doing everything and

anything asked of him by the Government. Mr. Nikolic’s assistance includes testifying before the

Grand Jury, assisting the Government to seize/claim over $1,000,000 stemming from the instant

offense, and numerous proffer sessions even resulting in the indictment of his own fiancé as a

co-defendant.

4
This was verified by the parties after providing the Government with the specific location of his apartment and the
contacts of his landlord.

Case: 1:20-cr-00750 Document #: 203 Filed: 01/10/24 Page 9 of 16 PageID #:1037

In addition to his assistance in cooperating with the Government, Mr. Nikolic has

prioritized his restitution amount of $3,446,030. At the time of sentencing Mr. Nikolic will have

paid approximately $800,000 of his restitution amount with another $160,000 to be forfeited to

the Government from a BMO Harris account ultimately resulting in close to $1,000,000 of his

restitution paid at sentencing.

History and Characteristics

The PSR accurately explains the personal background of Marko Nikolic and so that will

not be repeated in full here (PSR ¶55-88). Mr. Nikolic was born in Belgrade, Serbia where he

experienced a happy childhood and did well in school until approximately 2002. Growing up,

Mr. Nikolic was subjected to corporal punishment, which he felt was “normal,” Around 2002,

Mr. Nikolic’s parents moved at which time there were marital issues within the home. Mr.

Nikolic’s parents would fight amidst fights centered around issues such as faithfulness, stealing,

and money. His parents divorced when he was 15 years old, and he began to move between

homes. After the divorce, there were times his father could not financially support, and his

mother would “kick him out” because she was living with another man who did not care for Mr.

Nikolic. After his parents’ divorce, Mr. Nikolic began drinking alcohol and got into a motorcycle

accident while consuming alcohol.

At the time of his parents’ divorce, Mr. Nikolic was enrolled in a high school program to

become a dental hygienist, but shortly thereafter, abandoned those plans. Mr. Nikolic

subsequently applied for a student visa in college and came to the United States the summers of

2009 and 2010, with an extended visa after the summer of 2010, living in the Florida Keys

during those times.

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Mr. Nikolic graduated in 2013 from the University of Singidunum in Belgrade, Serbia

with a degree in marketing and logistics.

In 2014, after following his bachelor’s degree, he returned to the United States where he

has remained, but for one trip to Serbia in 2017.

Since obtaining his commercial driver’s license in 2015, Mr. Nikolic has been a hard-

working individual, diligently gaining experience in the logistics and trucking field. He worked

his way up through the industry and developed his own successful business as an independent

contractor, owning his own semitrucks, and working in dispatch. His conduct in this case that

brings him before this Honorable Court ultimately will cost him his career, a career he put

everything into, a reality Mr. Nikolic acknowledges, and accepts responsibility for entirely.

Mr. Nikolic is engaged to Milica Sumakovic whom he has known since high school. As

ordered by this Honorable Court, he has since had no contact with Ms. Sumakovic, but hopes to

one day get married at the conclusion of his sentence.

Following his arrest for the instant offense, Mr. Nikolic’s parents were upset and

ashamed and did not speak to him for approximately 18 months subsequent to his arrest. When

interviewed by United States Probation, Mr. Nikolic’s friend, Milka Mladenovic, advised she

believes he has become a better person as a result of his indictment. Ms. Mladenovic provides

that he appears to appreciate his family, friends, and freedom more and that he is more focused

on his future and having a “normal life” to include getting married and having children.

During his time in custody, Mr. Nikolic has dedicated himself to using his time

productively in order to best help himself upon his release from his sentence for the instant

matter. Mr. Nikolic has completed a number of certificates and programs, including but not

limited to: participating in the Beyond Prison Series, successfully completing T.O.P.U.C.U.

Case: 1:20-cr-00750 Document #: 203 Filed: 01/10/24 Page 11 of 16 PageID #:1039

(“The Only Person U Cheat Is U”), Personal Finance and Small Business Ownership Course,

Understanding Unconscious Bias, Choosing and Using the Best Solution, Building Your

Presentation, Become a Great Listener, Self-Improvement for Lifelong Success, Generating and

Evaluating Alternatives, Interacting with Customers, Establishing Self-Confidence for Life,

Ensuring Successful Presentation Delivery, Difficult People, Cultivating Relationships with

Your Peers, Communicating with Confidence, Get Organized, Making and Carrying Out Tough

Decisions, Reaching Sound Conclusions, Receiving Feedback, Uncovering and Utilizing Your

Talents and Skills, The Essentials for Anger Management, The Art of Staying Focused, and the

Peace Education Program. (See Exhibit Certificates).

Defendant’s Controlled Substance Use

The court should consider Marko Nikolic’s history of controlled substance use with

regard to alcohol, marijuana, pills, and cough syrup. Sentencing courts have the authority to and

have imposed below-guideline sentences on the basis of an individual’s drug addiction. See, e.g.,

United States v. Richardson, No. 03cr474, 2008 U.S. Dist. LEXIS 92059, *1-2 (N.D. Ill. Nov.

13, 2008) (“Taking into account the Defendant’s age, her drug addiction, and the lack of violent

behavior despite the presence of guns, the Court imposed a sentence substantially below the

guideline range . . .”).

During his Presentence Investigation Interview, Mr. Nikolic detailed that he first began

to consume alcohol while in high school, at parties. He drinks at most daily and at least two to

three days per week. Mr. Nikolic acknowledged that he loves to drink alcohol and that it has

caused problems in his life including being ticketed for drinking in Serbia as well as a vehicle

accident in which he crashed his motorcycle.

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Mr. Nikolic was first introduced to cocaine by his uncle at the age of approximately 15

and his use at that time was severe to the point that he suffered from “facial strokes” as a result.

At the time of his arrest, Mr. Nikolic used cocaine approximately twice a month at parties. Mr.

Nikolic previously used mushrooms twice in 2013. At the time of his arrest, Mr. Nikolic took

unprescribed Adderall two to three times a week. Mr. Nikolic first tried marijuana in his 20s and

used it every four to five months prior to his arrest. Mr. Nikolic asks the court to take his

previous substance use into consideration when determining a sentence.

Character Letters

Tatjana Nikolic and Miroslav Nikolic are Marko Nikolic’s parents. Tatjana and

Miroslav state in pertinent part:

“Marko has always been [a] good and great child. Beloved in society, good pupil
and a good student. He always liked to read a lot, travel, learn languages, play
sports, and go fishing.
…
When he came to America, he had big plans for his future and began to realize them
slowly. He founded his own company and had a good and successful start. He ran
his company well, was a good boss to his employees, and everything was working
great until corona virus came. Then, everything went downhill, and what happened
in him then, to make wrong steps and decisions in his life, only he knows.

When he was arrested, we didn’t hear from each other for almost two years, except
when his grandfather died. We know how deeply it hurt him. Since January of this
year, we hear each other regularly.

We talked a lot about everything, especially how deeply and how much he regrets
everything he did wrong. He is aware that this huge mistake led to the fact that we
neither heard nor saw each other for Christmas, New Years, birthdays, and
unfortunately, not even for the funerals of our loved ones.

He read a lot, The Bible helped him to understand and accept his time in prison. A
lot of time[s] he said that prison put him back on track. As parents, we love our
child without limits, but we never approve of his mistakes. We are sincerely and
deeply sure that he sincerely regrets and that he will never repeat his mistakes again
and that he will try to fix everything he can.”

(Letter attaches as Exhibit A.)

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Goran Macura grew up in the same neighborhood as Marko Nikolic in Serbia. Mr.

Macura states in pertinent part:

“Marko struck me as an intelligent, well-educated person and someone who was
dedicated to work[ing] hard towards the bright feature and accomplishment of his
dreams. When with friends, Marko was always generous and kind to everyone. He
was always willing to help everyone, and everyone could always rely on him.”
…
Marko is intelligent and mature, and I am sure that he is well aware of his mistake.
By knowing his character, I know that he feels deep regret and that he suffers
because of the pain that this has caused to his family. I am confident that he will
take this as a lesson and that he will never allow himself to make such poor
judgment again or to engage in any illegal activities. Marko deserves a second
chance in life, and I know that he will not take it for granted.”

(Letter attaches as Exhibit B.)

Milka Mladenovic is close friends with Marko Nikolic. Ms. Mladenovic states in

pertinent part:

“I met Marko when I moved to Chicago, and he helped me during a tough time. He
not only helped me find more work when I really needed it but also supported and
guided me. Marko has always been generous and selfless.

There are countless examples that shows Marko’s compassion and willingness to
go above and beyond for others.
…
That time when I haven’t spoke to my father, Marko helped fix things between me
and him. He understood how important family is and made an effort to bring us
closer by helping us communicate and overcome our issues.
…
Marko goes beyond being kind in personal relationships. When he started his
trucking company, he helped a hardworking friend who was struggling financially
by secretly giving extra benefits on work, that he never practiced before. All that
without even mentioning to him till today.
…
Despite everything I know and everything he admitted, beside all mistakes he made,
his core is good. He would never hurt or harm anyone. He was always
understand[ing], compassionate and sensitive to people around him.”

(Letter attaches as Exhibit C.)

Milica Sumakovic is Marko Nikolic’s fiancé. Ms. Sumakovic states in pertinent part:

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“He drove [a] truck for years, I remember that there were times that he didn’t come
home for weeks because he was driving [a] truck all the time spending sometimes
even holidays separated from me and his family. He would sleep [at] truck stops
every single night for weeks.

Before driving truck[s], Marko was [a] busboy in [a] restaurant and he would work
double shifts in that restaurant spending countless nights and days in there cleaning
tables just so we can have [a] better life.
…
I fell in love with the attention that he always gave me. He always thought about
me if I was hungry or I need anything, he was always there for me. When I had
[the] hardest time in my life, losing people that I love, Marko was always next to
me giving me his unconditional love and support.

Whenever I wasn’t feeling well, he would make me tea, make me dinner and bring
medications. We have a little dog named Charlie, that I got from Marko as a
birthday surprise 7 years ago. Marko loves him very much, he always took care of
him, making sure he is never hungry, always happy, and he also liked to sleep with
him.

I left my family back in 2014 as the only child to my parents to live life here with
Marko. He is [the] love of my life and I miss him very much. After his arrest back
in October 2020, I talked to him every day for hours until October 2022 when I was
indicted. Unfortunately, I am not able to talk to him or see him because of the wrong
decisions that we both made in the past.

[The] past three years were very difficult for both of us, but I know that this is [a]
big life lesson for us. And I know that we both learned a lot from our mistakes and
that we will be better people and our love is going to be stronger after everything
that we both have been through.”

(Letter attaches as Exhibit D.)

Aaron Regans details how Mr. Nikolic went out of his way to help Mr. Regans begin his

own trucking business (Exhibit E); Milos Nikolic provides he has always known Marko Nikolic

as a great friend (Exhibit F); Sevic Ivan believes from their time as friends that Mr. Nikolic will

never repeat such a mistake (Exhibit G); Uros Barjaktarevic awaits the day in which Mr.

Nikolic will be the best man at his wedding and knows him to be deeply sorry (Exhibit H); the

Videnovic family have known him to always be hardworking and conscientious (Exhibit I); the

Milisavljevic family details how Mr. Nikolic would always check in with their family and how

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they believe he will never repeat his mistake (Exhibit J); the Stefanov family provides Mr.

Nikolic is a beloved nephew and cousin who was always there to help others (Exhibit K), and

Damjan Cvetkovic, a monk from the Bukovo monastery, details Mr. Nikolic as someone who

has always helped his family and will learn from this mistake.

CONCLUSION

Marko Nikolic knows he has made a horrible mistake and has expressed remorse for his

actions. He understands these actions were unlawful and accepts responsibility for this conduct.

WHEREFORE, for the reasons stated above, Mr. Nikolic respectfully asks this Court for

leniency.

Respectfully submitted,

MICHAEL P. GILLESPIE
Counsel for Marko Nikolic
Law Offices of Gillespie & Gillespie
1550 N. Northwest Hwy.
Suite 203
Park Ridge, IL 60068
Tel. (224) 361-3111
michael@gillespieandgillespielaw.com

Michael D. Krejci
Counsel for Marko Nikolic
Michael D. Krejci & Associates
1770 Park Street
Suite 205
Naperville, IL 60563
(630)388-0600
Email: krejcilaw@gmail.com

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CERTIFICATE OF SERVICE

I hereby certify I electronically filed the foregoing with the Clerk of the Court for the
United States, Northern District of Illinois and said filing complies with Fed.R.Crim.P.49,
Fed.R.Civ.P.5, LR 5.5, and the General Order on Electronic Case Filing (ECF) pursuant to the
district court’s system as to ECF filers.

MICHAEL P. GILLESPIE
Counsel for Marko Nikolic
Law Offices of Gillespie & Gillespie
1550 N. Northwest Hwy.
Suite 203
Park Ridge, IL 60068
Tel. (224)-361-111
michael@gillespieandgillespielaw.com