Court filing
Proposed Voir Dire Questions as to Carl Delano Torjagbo by USA — USA v. Torjagbo (Dkt. 173, N.D. Ga. No. 1:22-cr-00171)
Filed February 25, 2025 in USA v. Torjagbo; one of 189 filings from this case.
Record facts
| Court | U.S. District Court for the Northern District of Georgia |
|---|---|
| Filed | 2025-02-25 |
U.S. District Court for the Northern District of Georgia · No. 1:22-cr-00171-MLB-RDC · Doc. 173 · 2025-02-25 · Docket on CourtListener
Full text
Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION UNITED STATES OF AMERICA v. CARL TORJAGBO CRIMINAL ACTION NUMBER 1:22-CR-171-MLB-RDC PROPOSED VOIR DIRE QUESTIONS Pursuant to this Court’s Order Setting Trial [Doc. 138], the United States hereby submits its proposed voir dire questions, to be asked in addition to the Court’s Qualifying Questions and Background Questions. The United States respectfully requests leave to supplement its proposed questions, should it become necessary. Case 1:22-cr-00171-MLB-RDC Document 173 Filed 02/25/25 Page 1 of 8 Page 2 of 8 Respectfully submitted, UNITED STATES OF AMERICA /s/ Kelly K. Connors Assistant United States Attorney Georgia Bar No. 504787 Kelly.Connors@usdoj.gov /s/ Nicholas Evert Assistant United States Attorney Georgia Bar No. 693062 Nicholas.Evert@usdoj.gov 600 U.S. Courthouse 75 Ted Turner Drive, SW Atlanta, GA 30303 (404) 581-6000 Case 1:22-cr-00171-MLB-RDC Document 173 Filed 02/25/25 Page 2 of 8 Page 3 of 8 A. Case-Related Conflicts 1. Please look around the room at the other members of the panel. Were you acquainted with any other member of the panel before reporting for jury service? 2. This case involves allegations that, in early 2021, Carl Torjagbo obtained a fraudulent loan from a federally insured financial institution and that he filed two fraudulent 2020 federal tax returns. Do you have any personal knowledge of the facts in this case, or about Carl Torjagbo, that has not come from what you learned in court today? Please explain. 3. The Indictment charges Defendant Torjagbo with, among other offenses, bank fraud, and alleges that the victim of the bank fraud was J.P. Morgan Chase Bank. Have you, any member of your immediate family, or a close friend ever worked for J.P. Morgan Chase Bank? • Who? • What position and where? • What were the job duties? • Would this prior work experience prevent you from fairly evaluating the testimony of witnesses employed by a bank? 4. Aside from J.P. Morgan Chase Bank, have you, any member of your immediate family, or a close friend ever worked for a bank or a company that issued loans? • Who? • What position and where? • What were the job duties? • Did you have any involvement in the loan application or Case 1:22-cr-00171-MLB-RDC Document 173 Filed 02/25/25 Page 3 of 8 Page 4 of 8 approval process? • What types of loans? e.g. automobile, mortgage, business, personal, etc. • Would this prior work experience prevent you from fairly evaluating the testimony of witnesses from a bank or lending company? 5. Has any member of the panel or any member of your immediate family had an unpleasant or negative experience with a bank or company that issues loans? • Would this experience prevent you from being a fair and impartial juror? • Would this experience prevent you from fairly evaluating the testimony of witnesses who work for a bank or lending company? 6. In response to the COVID-19 pandemic, certain federal programs were created to counteract the economic hardships faced by many businesses and individuals. These programs provided financial relief to businesses and individuals through government funding. One of these programs was the Paycheck Protection Program (PPP). • Does any member of the jury panel have a negative opinion of the Paycheck Protection Program, or any other government- funded economic relief program, that would prevent you from being a fair and impartial juror? 7. Have you or has anyone in your immediate family ever worked for the Small Business Administration? Case 1:22-cr-00171-MLB-RDC Document 173 Filed 02/25/25 Page 4 of 8 Page 5 of 8 8. Does any member of the jury panel have any opinions about the Small Business Administration, the Internal Revenue Service, the Federal Bureau of Investigation, or any other federal, state, or local law enforcement agency that would affect your ability to render a fair and impartial verdict in this case? 9. Would any member of the jury panel have difficulty fairly evaluating the testimony of law enforcement witnesses or other witnesses employed by government agencies? 10. In this case, you will hear from at least one IRS employee. Has any member of the panel had any experience that would affect your ability to evaluate an IRS witness’s testimony in a fair and impartial manner? 11. Have you ever had an unpleasant experience with any government agency or government employee, which might make it difficult for you to serve as a fair and impartial juror in this case? 12. Have you, any member of your immediate family, or a close friend ever been involved in a lawsuit or any kind of litigation with the United States government? 13. Has any member of the jury panel formed a negative opinion about prosecutors, police, or federal investigators? 14. This case is being prosecuted by the United States Attorney’s Office for the Northern District of Georgia, which is part of the United States Department of Justice. Do you have any feelings or opinions about the United States Attorney’s Office or the United States Department of Justice that might make it difficult for you to serve as a fair and impartial juror in this case? 15. At the close of the case, the Court will instruct you on the law that you must follow in reaching your verdict. If the Court’s instructions conflict with your personal convictions or beliefs, would you be unable to follow the Court’s instructions? Case 1:22-cr-00171-MLB-RDC Document 173 Filed 02/25/25 Page 5 of 8 Page 6 of 8 B. General Questions 16. Do you or does any member of your immediate family own or operate a business? • How long have you owned the business? • How many employees do you have? 17. The Indictment alleges that Defendant Torjagbo obtained a PPP loan in the name of Kremkov Industries, LLC. Have you ever heard of Kremkov Industries, LLC? 18. Has any member of the jury panel applied for a PPP loan or had a family member or close friend apply for a PPP loan? • Did anyone assist you with the application, such as an attorney or accountant? • Was the PPP loan approved and funded? • If not, is there anything about the fact that the loan was not funded that would prevent you from being a fair and impartial juror? • Did you apply for loan forgiveness? • Is there anything about the PPP loan application process or loan forgiveness process that would impact your ability to be a fair and impartial juror in this case? 19. If any member of the panel or an immediate family member was employed by a company that received a PPP loan, is there anything about that circumstance that would prevent you from being a fair and impartial juror? 20. Aside from student loans, has any member of the panel applied for any other type of government-funded loan or had a family member or close Case 1:22-cr-00171-MLB-RDC Document 173 Filed 02/25/25 Page 6 of 8 Page 7 of 8 friend apply for one? This would include loans through the Small Business Administration. • Is there anything about the loan application process that would prevent you from being a fair and impartial juror? 21. As part of your duties at work, have you ever had any responsibility related to employees’ payroll, such as calculating payroll, issuing payroll checks or direct deposits, and enrolling new employees in payroll systems? Please explain. 22. As part of your duties at work, have you ever had any responsibility related to employees’ tax withholdings, such as federal income taxes and Social Security taxes, that are deducted from paychecks? Please explain. 23. Have you or any member of your immediate family ever received a salary or wages from a mining company? 24. Have you or any member of your immediate family ever worked for a trucking or logistics company? 25. Aside from a change due to marriage or divorce, has any member of the jury panel or a close family member changed his or her name? 26. Have you, any of your relatives, or your close friends ever had any of your assets seized by the government? Please explain. • Was there anything about that experience that would prevent you from being a fair and impartial juror? 27. The Indictment in this case alleges that Carl Torjagbo used another individual’s identity without that person’s permission. • If your personal identity information has ever been used without your permission, is there anything about that experience that would prevent you from being a fair and impartial juror? Case 1:22-cr-00171-MLB-RDC Document 173 Filed 02/25/25 Page 7 of 8 Page 8 of 8 28. Have you ever worked as an accountant or auditor? 29. Have you ever worked as a tax preparer, or as part of your duties at work, have you had any responsibility related to preparing tax returns? 30. Do you have any paralegal training? 31. Have you ever attended law school? 32. Have you or any member of your immediate family ever worked for a law firm or other organization that defended people who were charged with committing crimes? 33. Have you ever belonged to or donated money to any of the following organizations: the ACLU, Prison Outreach, the Innocence Project, or the Fully Informed Jury Association? 34. If you tend to feel sympathy for someone who is charged with committing a crime, do you believe that those feelings might make it difficult for you to serve as a fair and impartial juror in this case? 35. Do you have any beliefs or views that you have not yet mentioned that would prevent you from being fair to both the government and Defendant Torjagbo? 36. Is there any other reason that you prefer not to sit on this jury? Case 1:22-cr-00171-MLB-RDC Document 173 Filed 02/25/25 Page 8 of 8
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