Bond — No. 1:20-cr-00750 (Dkt. 110, N.D. Ill.)

Summary

Defendant Milica Sumakovic's motion to modify conditions of bond, filed November 11, 2022 as Document #110 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 on the stipulation that she reside with a third party custodian. It asks the court to lift that condition so she can return to her home in Elmhurst, where she is bound by a lease until June 2023, and states that her pretrial officer has no problem with the request and that the government had not responded.

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   Case: 1:20-cr-00750 Document #: 110 Filed: 11/11/22 Page 1 of 2 PageID #:514


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

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

  DEFENDANT MILICA SUMAKOVIC’S MOTION TO MODIFY CONDITIONS OF
                            BOND


     Now comes Defendant, MILICA SUMAKOVIC, by and through her attorney,
RICHARD M. BEUKE, and for her Motion to Modify 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 the stipulation that she

         resides with a third party custodian.

   3.    Ms. Sumakovic’s third party custodian has graciously opened his apartment to her,

         with a few unavoidable caveats.

   4.    Her third party custodian, Mr. Babba, lives in Chicago, very far north, making

         traveling to her home office and her attorney’s office very difficult.

   5.    Mr. Babba has a cat and cannot allow Ms. Sumakovic to bring her dog into his

         apartment, leaving her dog alone for the majority of the day/night.

   6.    Mr. Babba only has the ability to provide Ms. Sumakovic with a sofa to sleep on.

         While she is grateful to this Court for granting her bond, and to Mr. Babba for

         allowing her to stay in his apartment, she has no privacy and the conditions of this

         living arrangement are far from ideal.
    Case: 1:20-cr-00750 Document #: 110 Filed: 11/11/22 Page 2 of 2 PageID #:515




   7.       Ms. Sumakovic is bound by her lease to her apartment in Elmhurst until June 2023,

            where she has lived for almost two years.

   8.       Ms. Sumakovic will continue to be responsible for her $2,500 rent until that time.

   9.       Ms. Sumakovic respectfully requests that the condition of residing with her third

            party custodian be lifted so she can return to her home in Elmhurst.

   10.      Ms. Sumakovic’s pretrial officer does not have a problem with the removal of this

            condition, and her office relays that they have no position on this request.

   11.      A voicemail was left for the Government but at the time of filing our call has not been

            returned for their position.

   12.      Ms. Sumakovic will continue to appear at every court appearance and abide by all

            conditions set forth by this Honorable Court.

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

the stipulation of residing with a third party custodian be removed. .



                                              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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