Proposed Voir Dire Questions as to Carl Delano Torjagbo — USA v. Torjagbo (Dkt. 185, N.D. Ga. No. 1:22-cr-00171)

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:22-cr-00171-MLB-RDC · Doc. 185 · 2025-05-20 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA
)
 
)
v.
)
                                 
)    Case No. 1:22-cr-00171-MLB-RDC
)
 Second Superseding
CARL DELANO TORJAGBO,
)
 a/k/a Karl Lucius Delano.
)
____________________________
)
DEFENDANT’S PROPOSED VOIR DIRE
COMES NOW the Defendant, CARL DELANO TORJAGBO, a/k/a Karl
Lucius Delano, by and through counsel, and files the following proposed voir dire
as directed by the Court:
[To be asked by Defense counsel].
1) Does anyone here do business with or know of the businesses Kremkov
Industries or Flying Jack Freight & Logistics?
2) Who here has received a PPP Loan, or has a family member or close
personal friend who has received a PPP Loan?
3) Who applied but was turned down for a PPP Loan?
4) Among those who received a PPP Loan, who had their loan forgiven?
5) Among those who received a PPP Loan, who had to pay it back?
Case 1:22-cr-00171-MLB-RDC     Document 185     Filed 05/20/25     Page 1 of 6

6) Who has worked for or currently works for a bank or savings and loan?
7) Who here banks with or has a relationship with JP Morgan Chase Bank?
8)  Who here has owned or run their own business?
[Follow up -] 
a. If so, do or did you rent or own your office space?
b. How many employees?
c. Did you do the hiring and firing?
9) Among the business owners, who has had private investors in their
company?
10) Who has prepared and filed their own taxes?
11) Who has had their taxes prepared by someone else to file?
12) Has anyone here ever been audited by the IRS or Treasury Department?
13) Who has had problems or issues with the IRS or a state department of
revenue, or a state tax agency?
            
(a)  [Follow up - please explain.]    
14)   Who here is familiar with the country of Ghana or has a close friend or
family member from Ghana?
                           [Follow up ?  How ? Who ?]
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15) You will learn in this case that Mr. Delano Torjagbo is from Ghana but
is now a naturalized U.S. Citizen. Is there anybody who cannot fairly judge his
case because of his national origin?  
16) Is there anyone here who has knowledge or information about the
operation of gold mines?
17) Who here thinks Mr. Delano Torjagbo is probably guilty just because he
has been charged with a crime?
18) Who here has legally changed their name, or has a close friend of family
member who changed their name? 
19)  Is anyone here employed by a law enforcement agency, related to or
closely acquainted with any employee of  —  a state, county or a federal law
enforcement agency such as IRS, the FBI or a local police, sheriff’s department? 
20) Has anyone here worked as a volunteer, intern or employee for any law
enforcement agency, prosecutor's office or probation office on the local, state, or
federal level?
21)  Has anyone here ever worked for any prison, jail or correctional 
institution?
22)  Anyone here ever work as an EMT or  paramedic?
23) Has anyone here ever had to testify as a witness or victim in court?
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24) For those who have served in the military, have any of you ever
participated in a court martial?
25)  Does anyone think a federal agent or police officer is more believable
than a regular defense witness?   
I
26)  Who here has a bumper sticker on their car?
[Follow up - If so, what does it say ?] 
27) Mr. Delano Torjagbo is charged with PPP loan fraud, aggravated
identity theft, wire fraud upon the IRS, and two types of money laundering. Is
there anybody here who, due to the nature of the charges, cannot fairly judge the
case based solely upon the evidence presented and the law as instructed by the
Court? 
28)  Is there anybody here, who just sitting here looking at Mr. Delano
Torjagbo, has already made up their mind and formed an opinion about his case ?   
WHEREBY, Carl Torjagbo requests that his counsel be allowed to ask the
above questions of the prospective jurors, and that counsel be allowed to 
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ask reasonable follow-up questions in response to those answers given.
Dated:  This 20th day of May, 2025.
Respectfully submitted,
 
s/ L. Burton Finlayson 
L. BURTON FINLAYSON
Attorney for CARL DELANO TORJAGBO 
Georgia Bar Number: 261460
LAW OFFICE OF
L. BURTON FINLAYSON, LLC 
685 Linwood Avenue, NE, Suite 200A
Atlanta, Georgia 30306
(404) 872-0560
lbfcourts@aol.com
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CERTIFICATE OF SERVICE
This is to certify that I have this day electronically filed the Defendant’s
Proposed Voir Dire with the Clerk of Court using the CM/ECF system which will
automatically send email notifications of such filing upon all counsel of record
including the following:
 
      Ms. Kelly Connors, and
                              Mr. Nick Evert 
     Assistant United States Attorneys
     600 U.S. Courthouse
     75 Ted Turner Drive, S. W.
     Atlanta, Georgia  30303
DATED:  This 20th day of May, 2025.
 s/ L. Burton Finlayson 
L. BURTON FINLAYSON
ATTORNEY FOR CARL DELANO TORJAGBO   
State Bar Number: 261460   
  
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