MOTION to Continue Pretrial Conference and Extension of Time to File Pretrial Motions with… — USA v. Torjagbo (Dkt. 32)

Summary

Document 32, filed 08/25/22 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 seeks a continuance of the August 29, 2022 pretrial conference and a 14-day extension of time to file pretrial motions. The motion says the discovery is voluminous, that he has not had enough time to review it, and that his initial concerns, including an appeal of the detention order and claims over sized property, remain pending. It states that the government has no objection to an additional two 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 29, 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.
Mr. Torjagbo’s initial concerns included an appeal of the detention order and
claims over sized property.  Those issues remain pending.  Mr. Torjagbo and counsel
Case 1:22-cr-00171-MLB-RDC     Document 32     Filed 08/25/22     Page 1 of 3

still must focus on their thorough review of the discovery and any potential pre-trial
motions. 
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 two weeks to
complete their review.
Wherefore, the defendant, Carl Delano Torjagbo, requests that he be granted
a continuance of the pretrial conference and an extension of time in which to file
pretrial motions for 14 days. 
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 32     Filed 08/25/22     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   25th       day of    August      , 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 32     Filed 08/25/22     Page 3 of 3

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