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Motion to Issue Corrected Bench Warrants — No. 1:20-cr-00750 (Dkt. 133, N.D. Ill.)

Summary

A Motion to Issue Corrected Bench Warrants, Document 133 filed January 17, 2023 in the Northern District of Illinois (Case 1:20-cr-00750, No. 20 CR 750), United States v. Maja Nikolic, et al., before Judge Guzman, signed by Assistant U.S. Attorney Brian Hayes for U.S. Attorney John R. Lausch, Jr. The government asks the court to quash existing arrest or bench warrants for four fugitive defendants, Maja Nikolic, Nebojsa Simeunovic, Mijajlo Stanisic and Dorde Todorovic, and to issue corrected warrants on form ILND 442 identifying the superseding indictment returned October 19, 2022. It explains that the earlier warrants do not accurately reflect the pending charges, which now include additional wire fraud counts and money laundering. It adds that discrepancies could cause difficulties in detaining and extraditing a defendant apprehended abroad.

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“Motion to Issue Corrected Bench Warrants — No. 1:20-cr-00750 (Dkt. 133, N.D. Ill.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/motion-to-issue-corrected-bench-warrants-no-1-20-cr-00750-dkt-133-n-d-9a6993f4a6/, SHA-256 c0adf02c25083659aacb26cf6c58cb2a4ced4cc2ef55519172b25cbfefb008f0.

Full text

   Case: 1:20-cr-00750 Document #: 133 Filed: 01/17/23 Page 1 of 3 PageID #:556




                         UNITED STATES DISTRICT COURT
                         NORTHERN DISTRICT OF ILLINOIS
                              EASTERN DIVISION

 UNITED STATES OF AMERICA,                 )
                                           )    No. 20 CR 750
                    v.                     )
                                           )    Judge Guzman
 MAJA NIKOLIC, et al.                      )

           MOTION TO ISSUE CORRECTED BENCH WARRANTS

      The United States of America, by its attorney, John R. Lausch, Jr., United

States Attorney for the Northern District of Illinois, moves this court for issuance of

corrected bench warrants as to four fugitive defendants: (1) Maja Nikolic, (2) Nebojsa

Simeunovic, (3) Mijajlo Stanisic, and (4) Dorde Todorovic. In support of its motion,

the government states:

      1.     Defendants Maja Nikolic and Marko Nikolic were first charged in this

case, each with one count of wire fraud, on October 23, 2020.

      2.     Maja and Marko Nikolic were indicted on January 19, 2021. In the

indictment, Marko Nikolic was charged with two counts of wire fraud, and Maja

Nikolic was charged with one count of wire fraud.

      3.     A superseding indictment was returned on October 19, 2022. In

addition to the Nikolics, five additional defendants were charged in the superseding

indictment. Additional counts of wire fraud, as well as domestic and international

concealment money laundering charges, were also added to the case.

      4.     Existing arrest and bench warrants issued in this case do not

completely and accurately reflect the pending charges as to the fugitive defendants.



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   Case: 1:20-cr-00750 Document #: 133 Filed: 01/17/23 Page 2 of 3 PageID #:557




In the event that one or more of the fugitive defendants is apprehended abroad,

discrepancies between the superseding indictment and the active arrest warrant

may lead to difficulties in detaining and extraditing such individuals.

      5.     To correct these discrepancies, the government requests that the Court

quash the existing arrest and/or bench warrants for defendants Maja Nikolic,

Nebojsa Simeunovic, Mijajlo Stanisic, and Dorde Todorovic, and issue in their place

corrected bench warrants (ILND 442). Each corrected bench warrant should identify

the charging instrument as a Superseding Indictment by selecting the appropriate

box on ILND 442. The offenses for each defendant should be briefly described as

follows:




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   Case: 1:20-cr-00750 Document #: 133 Filed: 01/17/23 Page 3 of 3 PageID #:558




      WHEREFORE, the United States moves this court to issue corrected bench

warrants as described herein.




                                     Respectfully submitted,

                                     JOHN R. LAUSCH, Jr.
                                     United States Attorney

                                 By: s/ Brian Hayes
                                     Brian Hayes
                                     Assistant United States Attorney
                                     219 S. Dearborn Street, 5th Floor
                                     Chicago, Illinois 60604
                                     Brian.Hayes@usdoj.gov




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