MOTION to Continue Pretrial Conference and Extension of Time to File Pretrial Motions with… — USA v. Torjagbo (Dkt. 29)

Summary

Document 29, filed 07/29/22 in Criminal Indictment No. 1:22-CR-171, in the United States District Court for the Northern District of Georgia, Atlanta Division, is a Motion for Continuance of Pretrial Conference and Extension of Time to File Pretrial Motions by defendant Carl Delano Torjagbo. Through counsel, he asks for an extension of time to file pretrial motions through August 23, 2022 and for the August 2, 2022 pretrial conference to be reset. The motion says the discovery is voluminous, that the defendant has not had sufficient time to review it or discuss it with counsel, and that counsel needs additional time. It states that counsel discussed the request with the government, which has no objection to an additional three weeks.

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA,
   :
   :
   :    CRIMINAL INDICTMENT 
v.
   :
NO. 1:22-CR-171
   :
                  
CARL DELANO TORJAGBO,    
   :
Defendant.     
   :
MOTION FOR CONTINUANCE OF PRETRIAL CONFERENCE AND
EXTENSION OF TIME TO FILE PRETRIAL MOTIONS
Now comes the defendant, Carl Delano Torjagbo, by and through his
undersigned counsel, who moves the court for an extension of time in which to file
pretrial motions and for a continuance of the August 2, 2022 pretrial conference.  In
support thereof, the defendant shows the court the following:
1.
The discovery in this case is voluminous.  The defendant has not had sufficient
time to review the discovery or an opportunity to discuss its importance with his
counsel.
2.
Undersigned counsel also requires additional time to review the material and
advise the client.
Case 1:22-cr-00171-MLB-RDC     Document 29     Filed 07/29/22     Page 1 of 3

3.
Counsel has discussed the need for additional time with the government.  There
is no objection on its part to allowing the defendant an additional three weeks their
review.
Wherefore, the defendant, Carl Delano Torjagbo, requests that he be granted
an extension of time in which to file pretrial motions up and through August 23, 2022
and for the pretrial conference to be reset.
Respectfully submitted,
 /s/ Jay L. Strongwater        
Jay L. Strongwater
Georgia Bar No. 688750
 /s/ Emily B. Strongwater  
Emily B. Strongwater
Georgia Bar No. 572648
1360 Peachtree Street
Suite 910
Atlanta, Georgia  30309
(404) 872-1700
Counsel for Defendant 
Case 1:22-cr-00171-MLB-RDC     Document 29     Filed 07/29/22     Page 2 of 3

CERTIFICATE OF SERVICE
I hereby certify that I have on this day served a true and correct copy of the
within and foregoing pleading upon counsel for the government by electronically
posting through the District Court’s ECF Filing System, addressed as follows:
John Russell Phillips, Esq.
Assistant United States Attorney
russell.phillips@usdoj.gov
This   29th      day of     July      , 2022.
 /s/ Jay L. Strongwater 
Jay L. Strongwater
Georgia Bar No. 688750
1360 Peachtree Street
Suite 910
Atlanta, Georgia  30309
(404) 872-1700
Counsel for Defendant  
Case 1:22-cr-00171-MLB-RDC     Document 29     Filed 07/29/22     Page 3 of 3

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