Agreed Motion to Expand Conditions of Bond for Defendant Milica Sumakovic — No. 1:20-cr-00750 (Dkt. 215, N.D. Ill.)

Summary

An agreed motion to expand the conditions of bond for defendant Milica Sumakovic, filed February 5, 2024 as Document #215 in United States v. Sumakovic, No. 20CR750, in the U.S. District Court for the Northern District of Illinois. The motion states that she is charged with wire fraud and money laundering and is out on an unsecured bond with a curfew, and that one condition bars communication with co-defendants. It asks to remove co-defendant Marko Nikolic, who was sentenced on January 24, 2024, from her no contact list so she can speak with him by telephone and video calls, and states that the government and pretrial services do not object.

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  Case: 1:20-cr-00750 Document #: 215 Filed: 02/05/24 Page 1 of 2 PageID #:1147


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

UNITED STATES OF AMERICA,                      )
                                               )
                    Plaintiff,                 )
                                               )      No. 20CR750
            v.                                 )
                                               )
MILICA SUMAKOVIC,                              )
                                               )
                    Defendant.                 )

            AGREED MOTION TO EXPAND CONDITIONS OF BOND
                 FOR DEFENDANT MILICA SUMAKOVIC


       Now comes Defendant, MILICA SUMAKOVIC, by and through her attorney,
RICHARD M. BEUKE, and for her Agreed Motion to Expand Conditions of bond, states as
follows:

   1.    Ms. Sumakovic has been charged with wire fraud and money laundering, charges

         that are pending in this Court.

   2.    Ms. Sumakovic is currently out on an unsecured bond with a curfew stipulation.

   3.    One condition of her bond is that she not communicate with her co-defendants.

   4.    Ms. Sumakovic’s fiancé, Marko Nikolic, is a co-defendant in this case and Mr.

         Nikolic was sentenced on January 24, 2024.

   5.    Ms. Sumakovic is requesting permission to speak to her fiancé, Marko Nikolic, on

         phone calls and video calls.

   6.    The Government has no objection to Ms. Sumakovic and Mr. Nikolic

         communicating on the telephone and on video calls.

   7.    Pretrial does not have an objection with removing Marko Nikolic from Ms.

         Sumakovic’s no contact list.
   Case: 1:20-cr-00750 Document #: 215 Filed: 02/05/24 Page 2 of 2 PageID #:1148


          WHEREFORE, it is requested that the conditions of the Defendant’s be

expanded for the purpose of removing Marko Nikolic from Ms. Sumakovic’s no contact list

and she be allowed to speak to Marko Nikolic via telephone calls and video calls.



                                          Respectfully Submitted,


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



RICHARD M. BEUKE
ATTORNEY AT LAW
801 N. CASS AVENUE, SUITE 200
WESTMONT, ILLINOIS 60559
(312) 427-3050 phone
(312) 427-1215 fax


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