MOTION to Continue Pretrial Conference and Extension of Time to File Pretrial Motions with… — USA v. Torjagbo (Dkt. 35)

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In this Motion for Continuance of Pretrial Conference and Extension of Time to File Pretrial Motions, Document 35 filed 09/14/22 in Criminal Indictment No. 1:22-CR-171 in the Northern District of Georgia, defendant Carl Delano Torjagbo asks to continue the September 14, 2022 pretrial conference. He says the discovery is voluminous and he has not had sufficient time to review it. He says his initial concerns included an appeal of the detention order and claims over sized property, which remain pending. The motion says the government has no objection to more time for discovery review and has advised that a superseding indictment is being contemplated.

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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 September 14, 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 35     Filed 09/14/22     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 time to review
discovery. 
The government has advised counsel that a superseding indictment is being
contemplated. A continuance to allow time for that issue to be resolved would
promote judicial efficiency and economy.
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. 
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 35     Filed 09/14/22     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   14th    day of   September    , 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 35     Filed 09/14/22     Page 3 of 3

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