Court filing

Supplement to Defendant’s Pre-Sentence Memorandum and Objections — United States v. Sumakovic (Dkt. 209, N.D. Ill.)

Summary

Filed January 23, 2024 in Case No. 1:20-cr-00750, this supplement withdraws one claim from Marko Nikolic's sentencing memorandum: that Nikolic's cooperation led to approximately $1,000,000 the government was able to seize or recover. Defense counsel writes that, after further conversations with agents and the government, the figure was mistaken, while maintaining that the cooperation was substantial. The defense asks to strike that language from the memorandum.

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Filed January 23, 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	2024-01-23

Cite this document

“Supplement to Defendant’s Pre-Sentence Memorandum and Objections — United States v. Sumakovic (Dkt. 209, N.D. Ill.).” U.S. District Court for the Northern District of Illinois, No. 1:20-cr-00750, Doc. 209, filed 2024-01-23. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/us-v-milica-sumakovic/2024-01-23-supplement-to-defendant-s-pre-sentence-memorandum-and-object-dkt-209/, SHA-256 c9666612e3d7f19c121876588b0e13c61c61ec718ff6464fb9838e3751f37faf.

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Full text

Case: 1:20-cr-00750 Document #: 209 Filed: 01/23/24 Page 1 of 2 PageID #:1130

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

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

SUPPLEMENT TO DEFENDANT’S
PRE-SENTENCE MEMORANDUM AND OBJECTIONS

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

Michael Krejci, respectfully submits this Supplement to its Sentencing Memorandum

In its previously filed Sentencing Memorandum, Defendant provided that the

Defendant’s assistance and cooperation led to approximately $1,000,000 in funds that the

Government was been able to seize/recover. Following the filing of Defendant’s Pre-Sentence

Memorandum and Objections, Defense Counsel has had additional conversation with agents and

the Government as to the Defendant’s cooperation. Although Defendant’s cooperation was

substantial, Defense Counsel was mistaken in providing this $1,000,000 figure based on its

additional conversations. Defendant seeks to strike this language from its memorandum.

Respectfully submitted,

Case: 1:20-cr-00750 Document #: 209 Filed: 01/23/24 Page 2 of 2 PageID #:1131

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

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