Defendant Milica Sumakovic’s Motion to Modify Conditions of Bond — United States v. Milica Sumakovic, No. 20CR750 (Dkt. 122, N.D. Ill.)

Summary

Motion by defendant Milica Sumakovic, through attorney Richard M. Beuke, in United States v. Milica Sumakovic, No. 20CR750, in the Northern District of Illinois, asking the Court to modify bond conditions. The motion says Sumakovic is charged with wire fraud and money laundering and is out on an unsecured bond on condition of living with a third party custodian, and that home incarceration with electronic monitoring at the custodian apartment was recently added. It asks that Sumakovic instead be monitored electronically out of the Sumakovic apartment in Elmhurst, Illinois, and that the third party custodian condition be removed. According to the motion, AUSA Brian Hayes does not oppose the request and Pretrial Officer Matthew Bonestroo has no objection.

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Full text

                    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.    Home incarceration with electronic monitoring out of her third party custodian’s

         apartment has recently been assigned as a condition of her bond.

   4.    Based on the new stipulation of electronic monitoring, we would respectfully request

         that Ms. Sumakovic be monitored electronically out of her own apartment, located at

         183 N. Addison Avenue, Apartment 304, Elmhurst, Illinois 60126, and eliminate the

         element of the third party custodian.

   5.    This has been discussed with AUSA Brian Hayes, and who stated that the

         Government does not oppose this request.
    6.      Ms. Sumakovic’s Pretrial Officer, Matthew Bonestroo also has no objection to the

            proposed modifications.



         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 and she be allowed to return

to her apartment, where she will continue of home incarceration and be monitored electronically

out of there.

                                             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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