Court filing
RESPONSE as to Carl Delano Torjagbo filed by Carl Delano Torjagbo re: 253 MOTION for… — USA v. Torjagbo (Dkt. 257)
Record facts
| Court | U.S. District Court for the Northern District of Georgia |
|---|---|
| Filed | 2026-01-21 |
U.S. District Court for the Northern District of Georgia · No. 1:22-cr-00171-MLB-RDC · Doc. 257 · 2026-01-21 · Docket on CourtListener
Summary
A defense response contesting the government's motion for a preliminary order of forfeiture (Doc. 253) in United States v. Carl Delano Torjagbo, No. 1:22-cr-00171-MLB-RDC, in the U.S. District Court for the Northern District of Georgia, filed January 21, 2026 as Doc. 257. The response states that the defendant proceeded to trial on July 21, 2025, that the jury returned guilty verdicts on July 25, 2025, and that sentencing is scheduled for January 27, 2026. It argues the government has not established the nexus required by Federal Rule of Criminal Procedure 32.2 for three listed vehicles, three listed real properties and a forfeiture money judgment of $6,366,240.76. It asks the court to conduct an evidentiary hearing. The six-page filing is signed by defense counsel Sandra Michaels and includes a certificate of service.
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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,: : Plaintiff, : : v. : CASE NO. : 1:22-cr-00171-MLB-RDC-1 : CARL DELANO TORJAGBO, : a/k/a KARL LUCIOUS DELANO,: : Defendant. : ___________________________________ DEFENSE RESPONSE CONTESTING THE GOVERNMENT’S MOTION FOR PRELIMINARY ORDER OF FORFEITURE COMES NOW CARL DELANO TORJAGBO, a/k/a KARL LUCIUS DELANO, by and through undersigned counsel and files this Response Contesting the Government’s Motion for Preliminary Order of Forfeiture (Doc. 253) and shows as follows: Case 1:22-cr-00171-MLB-RDC Document 257 Filed 01/21/26 Page 1 of 6 2 1. Mr. Delano plead not guilty to the ten-count third Superseding Indictment. (Doc. 198). Mr. Delano proceeded to trial on July 21, 2025. (Doc. 218). On July 25, 2025 the jury returned a verdict of guilty on all counts. (Doc. 226). Sentencing is currently scheduled for January 27, 2026. Mr. Delano maintains his innocence of the charges and objects, pursuant to Federal Rule of Criminal Procedure Rule 32.2 (b) to the forfeiture of his property, real property and request for a forfeiture money judgment. 2. Mr. Delano asserts the vehicles listed in the Government’s Motion, to wit: the 2022 BMW M850xi; the 2021 Land Rover Range Rover Lelar Sports Utility Vehicle; and the 2014 Lamborghini Aventador; are not subject to criminal forfeiture because the Government has not established the requisite nexus Case 1:22-cr-00171-MLB-RDC Document 257 Filed 01/21/26 Page 2 of 6 3 between the subject vehicle property and the alleged offense as required under Federal Rule of Criminal Procedure 32.2 (a). 3. Mr. Delano asserts the real property listed in the Government’s Motion, to wit: 5114 Greythorne Lane, Marietta, Cobb County, Georgia 30068, and all buildings and appurtenances thereto; 101 Holt Drive, Acworth, Cherokee County, Georgia 30101, and all buildings and appurtenances thereto; and Tract Fiber Drive, Cartersville, Bartow County, Georgia 30120, and all buildings and appurtenances thereto; are not subject to criminal forfeiture because the Government has not established the requisite nexus between the subject real property and the alleged offense as required under Federal Rule of Criminal Procedure 32.2 (a). Case 1:22-cr-00171-MLB-RDC Document 257 Filed 01/21/26 Page 3 of 6 4 4. Mr. Delano further objects to the Government’s request for a preliminary order of forfeiture a forfeiture money judgement in the amount of $6,366,240.76 and asserts the evidence at trial did not show the requisite nexus between the subject funds and the alleged offense as required under Federal Rule of Criminal Procedure 32.2 (a). 5. Pursuant to Federal Rule of Criminal Procedure 32.2 (b), Mr. Delano respectfully requests this matter be set down for an evidentiary hearing to determine whether the Government has met its burden under Federal Rule of Criminal Procedure 32.2. Case 1:22-cr-00171-MLB-RDC Document 257 Filed 01/21/26 Page 4 of 6 5 WHEREFORE, for the above and foregoing reasons, Mr. Delano objects to and contests the Government’s request for a preliminary order of forfeiture and respectfully requests this Court conduct an evidentiary hearing on this matter. This 21st day of January, 2026. Respectfully submitted, s/Sandra Michaels SANDRA MICHAELS Attorney for Carl Delano Torjagbo Georgia Bar No. 504014 965 Virginia Ave, N.E. Atlanta, Georgia 30306 (404) 312-5781 SLMichaelsLaw@gmail.com Case 1:22-cr-00171-MLB-RDC Document 257 Filed 01/21/26 Page 5 of 6 6 CERTIFICATE OF SERVICE Undersigned counsel has served the forgoing Defense Response Contesting the Government’s Motion for Preliminary Order of Forfeiture today by filing it using the Court’s CM/ECF system, which automatically notifies the parties and counsel of record. This 21st day of January, 2026. s/Sandra Michaels SANDRA MICHAELS Attorney for Carl Delano Torjagbo Georgia Bar No. 504014 965 Virginia Ave, N.E. Atlanta, Georgia 30306 (404) 312-5781 SLMichaelsLaw@gmail.com Case 1:22-cr-00171-MLB-RDC Document 257 Filed 01/21/26 Page 6 of 6
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