Joint Motion to Continue Status Hearing — No. 1:20-cr-00750 (Dkt. 85, N.D. Ill.)

Summary

Joint motion filed August 15, 2022 in the Northern District of Illinois, case 1:20-cr-00750, Dkt. 85, by the government and counsel for Marko Nikolic, asking the court to move the August 16, 2022 status hearing back 30 days to the week of September 19, 2022. It says the indictment charges two counts of wire fraud, that Marko Nikolic pleaded not guilty and that co-defendant Maja Nikolic has an outstanding warrant and remains a fugitive. The parties report continuing plea negotiations and discovery, and Nikolic agrees to exclude the time under the Speedy Trial Act.

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    Case: 1:20-cr-00750 Document #: 85 Filed: 08/15/22 Page 1 of 2 PageID #:397




                       UNITED STATES DISTRICT COURT
                       NORTHERN DISTRICT OF ILLINOIS
                            EASTERN DIVISION

 UNITED STATES OF AMERICA,
                                                  No. 20 CR 750
       v.
                                                  Honorable Ronald A. Guzman
 MAJA NIKOLIC and
 MARKO NIKOLIC


             JOINT MOTION TO CONTINUE STATUS HEARING

      The UNITED STATES OF AMERICA, by its attorney JOHN R. LAUSCH, JR.,

United States Attorney for the Northern District of Illinois, and attorneys MICHAEL

GILLESPIE and MICHAEL KREJCI, on behalf of defendant Marko Nikolic, jointly

file this motion to continue the August 16, 2022 status hearing, and state as follows:

      1.     The indictment in this case charges defendant with two counts of wire

fraud, in violation of Title 18, United States Code, Section 1343. Dkt. 47. Defendant

Marko Nikolic was arraigned and entered a plea of not guilty. Dkt. 59. The co-

defendant Maja Nikolic has an outstanding warrant and remains a fugitive.

      2.     The government has provided defendant Marko Nikolic and counsel

discovery materials and continues to produce discovery as materials become

available.

      3.     The counsel for defendant Marko Nikolic and the government continue

to diligently discuss and negotiate resolution of the matter against defendant Marko

Nikolic. Additionally, the government has made significant progress in its continued

investigation.
    Case: 1:20-cr-00750 Document #: 85 Filed: 08/15/22 Page 2 of 2 PageID #:398




      4.     For these reasons, the government and counsel for defendant Marko

Nikolic respectfully request that the August 16, 2022 status hearing be reset by 30

days to a date during the week of September 19, 2022.

      5.     Defendant Marko Nikolic does not object to the exclusion of time under

the Speedy Trial Act through the next hearing date, under Title 18, United States

Code, Section 3161(h)(7)(A), for continuing plea negotiations, review of discovery and

continuity of counsel.



Respectfully submitted,


/s/ Michael Gillespie                         /s/ Malgorzata Tracz Kozaka
MICHAEL GILLESPIE                             MALGORZATA TRACZ KOZAKA
MICHAEL D. KREJCI                             KAVITHA BABU
Counsel for defendant Marko Nikolic           Assistant U.S. Attorneys
                                              219 S. Dearborn St., Suite 500
                                              Chicago, IL 60604
                                              (312) 353-5300




Dated: August 15, 2022




                                          2


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