Indictment — United States v. Maja Nikolic and Marko Nikolic, Northern District of Illinois (Document 47)

Summary

An indictment in United States v. Maja Nikolic and Marko Nikolic, No. 20 CR 750, in the U.S. District Court for the Northern District of Illinois, Eastern Division, filed January 19, 2021 as Document 47. The grand jury alleges that from around March 2020 through September 2020 the defendants submitted false EIDL applications for Food by Orange LLC, Agrovet Solutions LLC, Farm & Village Market, LLC and PI Infinitive LLC, companies it describes as fictitious, after reincorporating previously dissolved companies in their own and other individuals' names. It states that the defendants misappropriated at least hundreds of thousands of dollars. Count Three charges wire fraud under Title 18, United States Code, Section 1343 over an electronic funds transfer of approximately $149,900 for Agrovet Solutions LLC. The forfeiture allegation cites Title 18, United States Code, Section 981(a)(1)(C).

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“Indictment — United States v. Maja Nikolic and Marko Nikolic, Northern District of Illinois (Document 47).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-1-20-cr-00750-dkt-47-n-d-ill-bf546c31c8/, SHA-256 87a6bc606c04be34d68065978c00229584e64153c8d82a4a36211ed4c7c55b48.

Full text

Case: 1:20-cr-00750 Document #: 47 Filed: 01/19/21 Page 1 of 8 PageID #:296

FIL ED MP
9/2021
1/1
N UNITED STATES DISTRICT COURT
THOMA.SDG . BRUTO C O U RT NORTHERN DISTRICT OF ILLINOIS
IS T R IC T
CLERK, U.S
EASTERN DIVISION

UNITED STATES OF AMERICA
No. 20 CR 750
v.
Violations: fitle 18, United States
MAJA NIKOLIC and Code, Sections 1343 and L349
MARKO NIKOLIC Judge Ronald A. Guzman
Magistrate Judge Susan E. Cox
COUNT ONE

The SPECIAL NOVEMBER 2OLg GRAND JURY charges:

1. At times material to this Indictment:

a. Defendant MAJA MKOLIC was a resident of Brookfield, Illinois

and a legal permanent resident of the United States.

b. Defendant MARKO NIKOLIC was a resident of Opa Locka,

Florida and La Grange, Illinois, and a legal permanent resident of the United States.

Defendant MARKO NIKOLIC was a member and registered agent of Food by Orange
:

LLC and Agrovet Solutions LLC, both of which were Florida companies.

c. Individual A was the registered agent of Farm & Village Market,

LLC, a Florida company.

d. Individual B was the registered agent of PI Infinitive LLC, a

Florida company.

e. The U.S. Small Business Administration ('SBA") was a United

States government agency that provided support to small businesses.
Case: 1:20-cr-00750 Document #: 47 Filed: 01/19/21 Page 2 of 8 PageID #:297

The Coronavirus Aid, Relief, and Economic Security ("CARES")

Act was a federal law enacted in or around March 2020 and designed to provide

emergency financial assistance to the millions of Americans who were suffering the
(

economic effects caused by the COVID-19 pandemic

g. One source of relief provided by the CARES Act was the

expansion of the Economic Injury Disaster Loan ('EIDU') program, which provided

loan assistance (including advances of up to $10,000) for businesses with, among

other things, 500 or fewer employees and other eligible entities foi loans up to

$150,000. The EIDL program was designed to provide economic relief to small

businesses that were experiencing a temporary loss of revenue.

h. EIDL loan proceeds were permitted to be used to pay an array of

working capital and normal operating expenses, such as continuation of health care

benefits, rent, utilities,.and fi.xed debt payments.

i. In order to obtain funds through the EIDL program, small
businesses applied through the SBA via an 6nline portal and application. As part of

the EIDL application process, the SBA required applicants to submit truthful
information concerning the business, including the gross revenues for the business

prior .to January 31, 2O2Ot, the cost of goods sold, and the number of employees.

Applicants were required. to electronically certifti that the information provided was

true and accurate, and were warned that any false statement or misrepresentation

to the SBA may result in sanctions, including criminal penalties.

2
Case: 1:20-cr-00750 Document #: 47 Filed: 01/19/21 Page 3 of 8 PageID #:298

j. The SBA issued EIDL funds to the small business applicants

directly from the United States Treasury.

2. Beginning in or around March 2020, and continuing through in or

around September 2020, in the NortJrern District of Illinois, Eastern Division, and

elsewhere,

MAJA NIKOLIC and MARKO NIKOLIC,

defendants herein, and others known and unknown to the grand jrry, knowingly

devised, intended to devise, and. participated. in a scheme to defraud and to obtain

money from the Small Business Administration by means of materially false and

fraudulent pretenses, representations, and promises, which scheme is further

described below.

3. It was part of the scheme that defendants MAJA MKOLIC, MARKO
NIKOLIC and others submitted, attempted to submit, and caused to be submitted",

applications for loans under the EIDL program, knowing that the applications

contained false statements and misrepresentations related to the loan applicants.

4. It was further part of the scheme that defendants MAJA NIKOLIC and

MARCO NIKOLIC knowingly solicited and caused to be solicited from individuals,

including Indiyidual C and Individual D, personal identifuine information such as

addresses, phone numbers, birthdates, and social security numbers.

5. It was further part of the scheme that defendants MAJA MKOLIC and

MARCO NIKOLIC used and caused to be used their own and other ind.ividuals'

personal identifiring information to reincorporate previously dissolved companies in
Case: 1:20-cr-00750 Document #: 47 Filed: 01/19/21 Page 4 of 8 PageID #:299

their own names and the trames of other individuals, including Individual C and

Individual D.

6. It was further part of the scheme that defendant MARKO NIKOLIC
reincorporated Food by Orange LLC and Agrovet Solutions LLC in his name, and

with defendant MAJA NIKOLIC's knowledge, submitted and caused to be submitted

applications for EIDL funds on behalf of these companies, knowing that the

applications falsely represented that the companies conducted business and had

employees, when, as d.efend.ants MARKO NIKOLIC and MAJA NIKOLIC knew, Food

by Orange LLC and Agrovet Solutions LLC were fi.ctitious, conducted no business,

had no employees, and did not suffer economic injury due to the COVID-l9 pandemic.

7. It was further part of the scheme that defendant MAJA MKOLIC, with

defend"ant MARKO NIKOLIC's knowledge and assistance, reincorporated Farm &

Village Market, LLC in the name of Individ,ual C and created" incorporation

documents for the purpose of applying for EIDL funds on behalf of the company,

knowing that Farm & Village Market, LLC was a fictitious company and not eligible

to receive funds from the EIDL program.

8. It was further part of the scheme that defendant MAJA MKOLIC
reincorporated PI Infinitive LLC in the name of Individual D and created

incorporation documents for the purpose of applying for EIDL funds on behalf of the

Company, knowing that PI Infi.nitive LLC was a fictitious company and not eligible to

receive funds from the EIDL program.

4
Case: 1:20-cr-00750 Document #: 47 Filed: 01/19/21 Page 5 of 8 PageID #:300

9. It was further part of the scheme that defendants MAJA NIKOLIC and

MARKO NIKOLIC knowingly caused the SBA to disburse EIDL funds into bank

accounts controlled by defendants MAJA NIKOLIC and MARKO NIKOLIC so that

they could use the funds for their personal benefi.t.

10. It was further part of the scheme that defendants MAJA NIKOLIC and
MARKO MKOLIC misrepresented, concealed, lod hid, and caused to be

misrepresented, concealed, and hidden, the existence, purpose, and acts done in

furtherance of the scheme.

11. As a result of the scheme, defendants MAJA NIKOLIC and MARKO
NIKOLIC fraudulently misappropriated at least hundreds of thousands of dollars

from the SBA's EIDL program.

12. On or about August 3i^,z}zo,at Oak Brook, in the Northern District of
Illinois, Eastern Division, and elsewhere,

MAJA MKOLIC,

defend.ant herein, for the purpoSe of attempting to execute the above-d.escribed

scheme, knowingly transmitted and caused. to be transmitted by means of wire

communicatibn in interstate commerce, certain writings, signs, and signals, namely,

an email from furiafreight@grnail.com to xxxx@**ro,.com, containing articles of
incorporation and a federal employer identification number for Farm & Village

Market, LLC;

In violation of Title l-8, United States Code, Section 1349.

5
Case: 1:20-cr-00750 Document #: 47 Filed: 01/19/21 Page 6 of 8 PageID #:301

COUNT TWO
THE SPECIAL NOVEMBER 2019 GRAND JURY further charges:

1. Paragraphs 1 through 11 ofCount One are incorporated here.

2. On or about June 28,202(-,at Oak Brook, in the Northern District of

Illinois, Eastern Division, and elsewhere,

MARKO NIKOLIC,

defendant herein, for the purpose of executing the above-described scheme,

knowingly caused to be transmitted by means of wire communication in interstate

commerce, certain writings, signs, and signals, namely, an electronic funds transfer

in the amount of approximately $L49,900 from the SmaII Business Administration to

an account ending in 9036 at Bank A, which funds represented the proceeds of an

Economic Injury Disaster Loan to Food, by Orange LLC;

In violation of Title 18, United States Code, Section 1343.

6
Case: 1:20-cr-00750 Document #: 47 Filed: 01/19/21 Page 7 of 8 PageID #:302

COUNT THREE

THE SPECIAL NOVEMBER 2019 GRAND JURY further charges:

1-. Paragraphs 1- through 11 of Count One are incorporated. here.

2. On or about JuIy 28, 2020, at Oak Brook, in the Northern District of

Illinois, Eastern Division, and elsewhere,

MARKO MKOLIC,

defendant herein, for the purpose of executing the above-described scheme,

knowingly caused. to be transmitted by means of wire communication in interstate

commerce, certain writings, signs, and signals, namely, an electronic fund.s transfer

in the amount of approximately $149,900 from the Small Business Administration to

an account ending in 0043 at Bank B, which funds represented the proieeds of an

Economic Injury Disaster Loan to Agrovet Solutions LLC;

In violation of Title 18, United States Code, Section 1343.

7
Case: 1:20-cr-00750 Document #: 47 Filed: 01/19/21 Page 8 of 8 PageID #:303

FORFEITURE ALLEGATION
The SPECIAL NOVEMBER 2OIIGRAND JURY turther alleges:

1. Upon conviction of the offenses in violation of Title 18, United. States

Cod.e, Sections 1343 and L34g,as set forth in this Ind.ictment,

defendants heiein, shall forfeit to the United States of America, any propeity which

constitutes and. is derived. foom proceeds traceable to the offenses, as provided in Title

18, United States Code, Section 981(a)(1)(C).

2. If any of the property described,above, as a result of any act or omission

by a defendant: cannot be located upon the exercise of due diligence, has been
transferred. or sold to, or deposited with, a third party, has been placed beyond the

jurisdiction of the Court; has been substantially diminished. in value; or has been

commingled with other property which cannot be divided without difficulty, the

United States of America shall be entitled to forfeiture of substitute property, as

provided in Title 21, United States Code, Section S53(p).

A TRUE BILL:

FOREPERSON

UNITED STATES ATTORNEY

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