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Home Court filings United States v. Carl Delano Torjagbo — N.D. Ga., No. 1:22-cr-171-MLB Unopposed MOTION for Extension of Time to File Pretrial Motions and to Continue Pretria…

Court filing

Unopposed MOTION for Extension of Time to File Pretrial Motions and to Continue Pretrial… — USA v. Torjagbo (Dkt. 18)

Record facts

CourtU.S. District Court for the Northern District of Georgia
Filed2022-05-25

U.S. District Court for the Northern District of Georgia · No. 1:22-cr-00171-MLB-RDC · Doc. 18 · 2022-05-25 · Docket on CourtListener

Summary

An unopposed defense motion filed May 25, 2022 as Doc. 18 in United States v. Carl Delano Torjagbo, No. 1:22-cr-00171-MLB-RDC, in the U.S. District Court for the Northern District of Georgia. The defendant asks for sixty (60) additional days to file pretrial motions and for the pretrial conference scheduled for May 26, 2022 to be continued. The motion states that the seven-count indictment charges bank fraud under 18 U.S.C. §§ 1344 and 2 and money laundering counts under 18 U.S.C. §§ 1957 and 2 and section 1956(a)(1)(B)(i), and that the discovery produced so far is voluminous. It reports that government counsel does not object and argues the delay is excludable under the Speedy Trial Act, 18 U.S.C. § 3161. The four-page filing is signed by counsel from the Federal Defender Program, Inc. and includes a certificate of service.

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Full text

1 
 
IN THE UNITED STATES DISTRICT COURT 
 
FOR THE NORTHERN DISTRICT OF GEORGIA 
 
 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA 
) 
    
) 
 
 
vs. 
 
 
    
) 
CRIMINAL ACTION 
)    NO. 1:22-CR-171-MLB-RDC 
CARL DELANO TORJAGBO  
) 
 
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE PRETRIAL 
MOTIONS AND TO CONTINUE PRETRIAL CONFERENCE 
 
COMES NOW the Defendant, CARL DELANO TORJAGBO, by and through 
his undersigned counsel, and moves the Court for sixty (60) additional days to file 
pre-trial motions.  Mr. Torjagbo also requests that the pretrial conference, which is 
scheduled for May 26, 2022, be continued.  In support of this motion, Mr. Torjagbo 
states the following.  
Mr. Torjagbo is charged in a seven-count indictment.  Count One charges 
bank fraud in violation of 18 U.S.C. §§ 1344 and 2.  Counts Two through Four charge 
Concealment Money Laundering in violation of 18 U.S.C. 1956(a)(1)(B)(i) and 2.  
Count Five through Seven charge transactional money laundering in violation of 18 
U.S.C. §§ 1957 and 2.  
Mr. Torjagbo made his initial appearance and was arraigned on May 12, 2022.  
Thus, his pretrial motions are due to be filed by May 26, 2022.  The discovery 
Case 1:22-cr-00171-MLB-RDC     Document 18     Filed 05/25/22     Page 1 of 4

 
 
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materials produced thus far by the Government are voluminous.  Undersigned 
counsel has not yet been able to complete a review of the discovery materials, consult 
with Mr. Torjagbo, and prepare pretrial motions.  Given the volume and nature of 
the discovery materials and the press of undersigned counsel’s responsibilities on 
other matters, Mr. Torjagbo requests an extension of sixty (60) days to complete a 
review of the discovery materials and to file pretrial motions.  Mr. Torjagbo further 
requests that the pretrial conference be continued until a date after the extended 
pretrial motions filing deadline. 
Undersigned counsel has spoken with counsel for the Government, Russell 
Phillips, regarding this motion for an extension of time to file pretrial motions.  Mr.  
Phillips has informed undersigned that he does not object to this motion. 
Undersigned counsel posits that the time associated with this requested 
extension of time and continuance is excludable under the provisions of the Speedy 
Trial Act, 18 U.S.C. § 3161.  Subsections 3161(h)(7)(A) and (h)(7)(B)(iv) authorize 
exclusion of delay based upon a finding that the ends of justice outweigh the best 
interests of the public and the defendant in a speedy trial, such as where the delay 
provides reasonable time necessary for effective preparation by counsel, taking into 
account the exercise of due diligence. See 18 U.S.C. §§ 3161(h)(7)(A) & (h)(7)(B)(iv). 
WHEREFORE, Mr. Torjagbo respectfully requests that this motion be granted. 
Case 1:22-cr-00171-MLB-RDC     Document 18     Filed 05/25/22     Page 2 of 4

 
 
3 
 
Dated: This 25th day of May, 2022. 
 
 
 
 
 
Respectfully submitted, 
 
 
s/ Kendal D. Silas                      
 
KENDAL D. SILAS 
State Bar of Georgia No. 645959 
Attorney for  
CARL DELANO TORJAGBO  
 
Federal Defender Program, Inc. 
Suite 1500, Centennial Tower 
101 Marietta Street, N.W. 
Atlanta, GA 30303; 404/688-7530 
Case 1:22-cr-00171-MLB-RDC     Document 18     Filed 05/25/22     Page 3 of 4

 
 
CERTIFICATE OF SERVICE 
 
I hereby certify that the foregoing Motion for Extension of Time to File Pretrial 
Motions and to Continue Pretrial Conference was electronically filed this day with the 
Clerk of Court using the CM/ECF system, which will automatically send email 
notification of such filing to the following: 
 
Russell Phillips, Esq. 
 
Assistant United States Attorney 
Northern District of Georgia 
Federal Courthouse, Ste. 600  
75 Ted Turner Drive, S.W. 
Atlanta, GA 30303 
 
Dated: This 25th day of May, 2022. 
 
 
s/ Kendal D. Silas                            
 
KENDAL D. SILAS, Esq. 
Attorney for  
CARL DELANO TORJAGBO 
 
Case 1:22-cr-00171-MLB-RDC     Document 18     Filed 05/25/22     Page 4 of 4

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