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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…

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Unopposed MOTION for Extension of Time to File Pretrial Motions and to Continue Pretrial… — USA v. Torjagbo (Dkt. 75)

Record facts

CourtU.S. District Court for the Northern District of Georgia
Filed2023-12-08

U.S. District Court for the Northern District of Georgia · No. 1:22-cr-00171-MLB-RDC · Doc. 75 · 2023-12-08 · Docket on CourtListener

Summary

An unopposed motion for a 30-day extension of time to file pretrial motions and to continue the pretrial conference, filed December 8, 2023 as Document 75 in United States of America v. Carl Delano Torjagbo, No. 1:22-CR-171-MLB-RDC, in the U.S. District Court for the Northern District of Georgia. The motion states that pretrial motions are due December 8, 2023 and that the pretrial conference is scheduled for December 12, 2023. It states that the defendant is charged in a seven-count indictment charging bank fraud under 18 U.S.C. §§ 1344 and 2 and counts of concealment and transactional money laundering. It says counsel needs more time to review voluminous discovery, conduct legal research and consult with the defendant, and that counsel for the Government does not oppose. It cites the Speedy Trial Act, 18 U.S.C. § 3161, as making the delay excludable.

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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 thirty (30) additional days to file 
pretrial motions.  Mr. Torjagbo also requests that the pretrial conference, which is 
scheduled for December 12, 2023, be continued.  In support of this motion, Mr. 
Torjagbo states the following.  
Mr. Torjagbo is charged in a seven-count indictment. (Doc. 1).  Count One 
charges bank fraud in violation of 18 U.S.C. §§ 1344 and 2. (Doc. 1).  Counts Two 
through Four charge concealment money laundering in violation of 18 U.S.C. 
1956(a)(1)(B)(i) and 2. (Doc. 1).  Counts Five through Seven charge transactional 
money laundering in violation of 18 U.S.C. §§ 1957 and 2. (Doc. 1). 
Mr. Torjagbo made his initial appearance and was arraigned on May 12, 2022. 
(Doc. 9).  The Federal Defender Program was appointed to represent Mr. Torjagbo. 
Case 1:22-cr-00171-MLB-RDC     Document 75     Filed 12/08/23     Page 1 of 4

 
 
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(Doc. 9).  However, Mr. Torjagbo retained private counsel prior to the filing of 
pretrial motions. (Docs. 23, 24).  On October 2, 2023, Mr. Torjagbo filed a motion 
to dismiss private counsel and replace with court-appointed counsel. (Doc. 65).  On 
October 17, the District Court granted Mr. Torjagbo’s motion, and on October 19, the 
Federal Defender Program was re-appointed to represent Mr. Torjagbo. (Docs. 68, 
70).  Pretrial motions are currently due to be filed by December 8, 2023, and a 
pretrial conference is scheduled for December 12.   
Undersigned counsel needs additional time to review the discovery materials 
produced thus far by the Government, which are voluminous.  Undersigned counsel 
also needs the additional time to conduct necessary legal research, consult with Mr. 
Torjagbo, and prepare the appropriate pretrial motions on Mr. Torjagbo’s behalf.   
Undersigned counsel has communicated with counsel for the Government, 
Russell Phillips, regarding this motion.  Mr. Phillips has informed undersigned 
counsel that he does not oppose 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.  Subsection 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 
Case 1:22-cr-00171-MLB-RDC     Document 75     Filed 12/08/23     Page 2 of 4

 
 
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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. 
Dated: This 8th day of December, 2023. 
 
 
 
 
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 75     Filed 12/08/23     Page 3 of 4

 
 
CERTIFICATE OF SERVICE 
 
I hereby certify that the foregoing Unopposed 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 8th day of December, 2023. 
 
 
s/ Kendal D. Silas                            
 
KENDAL D. SILAS, Esq. 
Attorney for CARL DELANO TORJAGBO 
Case 1:22-cr-00171-MLB-RDC     Document 75     Filed 12/08/23     Page 4 of 4

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