Memorandum

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:22-cr-00171-MLB-RDC · Doc. 197-2 · 2025-07-06 · Docket on CourtListener

Summary

Document 197-2, filed July 6, 2025 in United States v. Torjagbo, No. 1:22-cr-00171-MLB-RDC, in the U.S. District Court for the Northern District of Georgia, is a four-page set of memorandum pages describing enforcement priorities of the Justice Department's Civil Division. The pages cover ending antisemitism, protecting women and children, ending sanctuary jurisdictions, and prioritizing denaturalization under 8 U.S.C. § 1451(a). They cite executive orders including Executive Order 14,188 and memoranda from Attorney General Bondi. The denaturalization part lists ten priority categories, one of which is financial fraud against the United States, including Paycheck Protection Program loan fraud. The pages state that the categories guide but do not limit which cases the Civil Division pursues.

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Case 1:22-cr-00171-MLB-RDC     Document 197-2     Filed 07/06/25     Page 1 of 4

 
 
 
 
 
 
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2. Ending Antisemitism  
On January 29, 2025, President Trump issued Executive Order 14,188, Additional Measures to 
Combat Anti-Semitism, 90 Fed. Reg. 8847 (Feb. 3, 2025), which established the “policy of the 
United States to combat anti-Semitism vigorously, using all available and appropriate legal tools, 
to prosecute, remove, or otherwise hold accountable the perpetrators of unlawful anti-Semitic 
harassment and violence,” id. § 2, and encouraged the “Attorney General … to employ 
appropriate civil-rights enforcement authorities … to combat anti-Semitism,” id. § 3(c).  The 
Executive Order also reaffirmed Executive Order 13,899, Combating Anti-Semitism, 84 Fed. 
Reg. 68779 (Dec. 16, 2019). 
The Attorney General has established Joint Task Force October 7 (“JTF 10-7”) and directed 
components to “prioritize seeking justice for victims of the October 7, 2023 terrorist attack in 
Israel” as well as “combatting antisemitic acts of terrorism and civil rights violations in the 
homeland.”  Memorandum from Attorney General, Establishment of Joint Task Force October 7, 
at 1 (Feb. 5, 2025).  To assist these enforcement efforts, the Civil Division will prioritize 
investigations and enforcement actions against entities that make claims for federal funds but 
knowingly violate federal civil rights laws by participating in or allowing antisemitism.   
3. Protecting Women and Children 
The President has issued several Executive Orders protecting women and children.  On January 
20, the President issued Executive Order 14,168, Defending Women from Gender Ideology 
Extremism and Restoring Biological Truth to the Federal Government, 90 Fed. Reg. 8615 (Jan. 
30, 2025), which established the “policy of the United States to recognize two sexes, male and 
female.” Id. § 2.  On February 3, President Trump issued Executive Order 14,187, Protecting 
Children from Chemical and Surgical Mutilation, 90 Fed. Reg. 8771 (Feb. 3, 2025), which 
directed the Attorney General to, among other things, “prioritize investigations and take 
appropriate action to end deception of consumers, fraud, and violations of the Food, Drug, and 
Cosmetic Act by any entity that may be misleading the public about long-term side effects of 
chemical and surgical mutilation.” Id. § 8(c). 
Following these directives, Attorney General Bondi directed the Civil Division to “act decisively 
to protect our children and hold accountable those who mutilate them under the guise of care” 
and “to undertake appropriate investigations of any violations of the Food, Drug, and Cosmetic 
Act by manufacturers and distributors engaged in misbranding by making false claims about the 
on- or off-label use of puberty blockers, sex hormones, or any other drug used to facilitate a 
child’s so-called ‘gender transition.’” Memorandum from Attorney General, Preventing the 
Mutilation of American Children, at 3-4 (April 22, 2025).  The Attorney General also directed 
the Civil Division “to pursue investigations under the False Claims Act of false claims submitted 
to federal health care programs for any non-covered services related to radical gender 
experimentation.” Id. at 4.   
The Civil Division will use all available resources to prioritize investigations of doctors, 
hospitals, pharmaceutical companies, and other appropriate entities consistent with these 
directives.  These efforts will include, but will not be limited to, possible violations of the Food, 
Case 1:22-cr-00171-MLB-RDC     Document 197-2     Filed 07/06/25     Page 2 of 4

 
 
 
 
 
 
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Drug, and Cosmetic Act and other laws by (1) pharmaceutical companies that manufacture drugs 
used in connection with so-called gender transition and (2) dealers such as online pharmacies 
suspected of illegally selling such drugs.  31 U.S.C. § 301 et seq.  In addition, the Civil Division 
will aggressively pursue claims under the False Claims Act against health care providers that bill 
the federal government for impermissible services.  This includes, for example, providers that 
attempt to evade state bans on gender dysphoria treatments by knowingly submitting claims to 
Medicaid with false diagnosis codes. 
4. Ending Sanctuary Jurisdictions 
On President Trump’s first day in office, he issued multiple directives to secure the southern 
border.  See Proclamation 10,886, Declaring a National Emergency at the Southern Border of 
the United States, 90 Fed. Reg. 8327 (Jan. 20, 2025); Executive Order 14,159, Protecting the 
American People Against Invasion, 90 Fed. Reg. 8443 (Jan. 20, 2025).  To ensure that States and 
local governments promote the enforcement of our nation’s immigration laws, he also issued 
Executive Order 14,287, Protecting American Communities from Criminal Aliens, 90 Fed. Reg. 
18761 (April 28, 2025).  This built on the President’s previous Executive Order 13,768, 
Enhancing Public Safety in the Interior of the United States, 82 Fed. Reg. 8799 (January 25, 
2017).  Moreover, Attorney General Bondi has directed the Civil Division to “identify state and 
local laws, policies, and practices that facilitate violations of federal immigration laws or impede 
lawful federal immigration operations” and “take legal action to challenge such laws, policies, or 
practices,” where appropriate.  Memorandum from Attorney General, Sanctuary Jurisdiction 
Directive, at 3 (Feb. 5, 2025).  Consistent with this directive, the Civil Division shall prioritize 
affirmative litigation to invalidate any State or local laws preempted by Federal law.   
5. Prioritizing Denaturalization 
The Department of Justice may institute civil proceedings to revoke a person’s United States 
citizenship if an individual either “illegally procured” naturalization or procured naturalization 
by “concealment of a material fact or by willful misrepresentation.”  8 U.S.C. § 1451(a).  The 
benefits of civil denaturalization include the government’s ability to revoke the citizenship of 
individuals who engaged in the commission of war crimes, extrajudicial killings, or other serious 
human rights abuses; to remove naturalized criminals, gang members, or, indeed, any individuals 
convicted of crimes who pose an ongoing threat to the United States; and to prevent convicted 
terrorists from returning to U.S. soil or traveling internationally on a U.S. passport.  At a 
fundamental level, it also supports the overall integrity of the naturalization program by ensuring 
that those who unlawfully procured citizenship, including those who obtained it through fraud or 
concealment of material information, do not maintain the benefits of the unlawful procurement. 
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The Civil Division shall prioritize and maximally pursue denaturalization proceedings in all 
cases permitted by law and supported by the evidence.  To promote the pursuit of all viable 
denaturalization cases available under 8 U.S.C. § 1451 and maintain the integrity of the 
naturalization system while simultaneously ensuring an appropriate allocation of resources, the 
Civil Division has established the following categories of priorities for denaturalization cases: 
1. Cases against individuals who pose a potential danger to national security, including 
those with a nexus to terrorism, espionage, or the unlawful export from the United States 
of sensitive goods, technology, or information raising national security concerns; 
 
2. Cases against individuals who engaged in torture, war crimes, or other human rights 
violations; 
 
3. Cases against individuals who further or furthered the unlawful enterprise of criminal 
gangs, transnational criminal organizations, and drug cartels; 
 
4. Cases against individuals who committed felonies that were not disclosed during the 
naturalization process; 
 
5. Cases against individuals who committed human trafficking, sex offenses, or violent 
crimes; 
 
6. Cases against individuals who engaged in various forms of financial fraud against the 
United States (including Paycheck Protection Program (“PPP”) loan fraud and 
Medicaid/Medicare fraud); 
 
7. Cases against individuals who engaged in fraud against private individuals, funds, or 
corporations; 
 
8. Cases against individuals who acquired naturalization through government corruption, 
fraud, or material misrepresentations, not otherwise addressed by another priority 
category; 
 
9. Cases referred by a United States Attorney’s Office or in connection with pending 
criminal charges, if those charges do not fit within one of the other priorities; and 
 
10. Any other cases referred to the Civil Division that the Division determines to be 
sufficiently important to pursue. 
These categories are intended to guide the Civil Division in prioritizing which cases to pursue; 
however, these categories do not limit the Civil Division from pursuing any particular case, nor 
are they listed in a particular order of importance.  Further, the Civil Division retains the 
discretion to pursue cases outside of these categories as it determines appropriate. The 
assignment of denaturalization cases may be made across sections or units based on experience, 
subject-matter expertise, and the overall needs of the Civil Division.  
Case 1:22-cr-00171-MLB-RDC     Document 197-2     Filed 07/06/25     Page 4 of 4

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