Motion - United States v. Tracy and Carolyn Wade

Record facts

U.S. District Court for the Southern District of Florida · No. 0:23-cr-60173-KMW · Doc. 15 · 2023-11-17 · Docket on CourtListener

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IN THE UNITED STATES DISTRICT COURT 
 
FOR THE SOUTHERN DISTRICT OF FLORIDA 
 
 
UNITED STATES OF AMERICA, ) 
 
 
 
 
 
 
) 
 
 
Plaintiff, 
 
 
) 
 
 
 
 
 
 
 
) 
v. 
 
 
 
 
 
) 
CASE NO. 23-cr-60173-KMW 
 
 
 
                              ) 
 
 
 
 
 
 
 
) 
 
CAAROLYN DENISE WADE,   
) 
 
 
 
 
 
 
) 
 
 
Defendant.  
 
) 
_______________________________) 
 
AGREED MOTION TO CONTINUE TRIAL AND CALENDAR CALL 
 
COMES NOW, the Defendant, CAROLYN DENISE WADE (“Wade”), by 
and through the undersigned attorney, and motions this Court to continue her 
presently scheduled calendar call and trial by ninety (90) days. In support thereof, 
Wade states as follows: 
1. 
Prior to filing the instant motion, the undersigned communicated with 
AUSA David Snider (the prosecutor assigned to the instant matter) who advised the 
government has no objection to granting the instant motion. The instant motion is 
Wade’s first motion for continuance of calendar call and trial. 
Case 0:23-cr-60173-KMW   Document 15   Entered on FLSD Docket 11/17/2023   Page 1 of 3

2. 
On October 19, 2023, Wade was arraigned. On November 3, 2023, the 
government disclosed its first discovery submission. Calendar call is presently set 
for December 12, 2023 and trial is set for December 18, 2023. 
3. 
The parties agree to a ninety (90) extension of time so that the Defense 
may complete discovery. Specifically, the undersigned is in the process of issuing 
multiple subpoenas to produce documents and records on third parties who the 
undersigned believes may possess exculpatory evidence that is material to Wade’s 
defense. 
4. 
Additionally, the undersigned attorney has been ordered to appear for 
jury duty in this district on December 4, 2023 and is therefore unavailable for trial. 
WHEREFORE, the Defendant and the undersigned attorney respectfully 
motion this Court continue the presently scheduled calendar call and trial by ninety 
(90) days. 
 
 
 
 
 
 
Respectfully Submitted, 
 
 
 
 
 
 
/s/ Brian Silber 
 
 
 
 
 
 
______________________________ 
 
 
 
 
 
 
Brian Silber, Esq. 
 
 
 
 
 
 
Counsel for Carolyn Denise Wade 
 
 
 
 
 
 
Florida Bar #:  0640646 
 
 
 
 
 
 
916 South Andrews Avenue 
 
 
 
 
 
 
Fort Lauderdale, FL 33316 
 
 
 
 
 
 
954-462-3636 (ofc) 
 
 
 
 
 
 
silberlaw@gmail.com 
 
 
 
 
 
 
briansilberlaw.com 
 
Case 0:23-cr-60173-KMW   Document 15   Entered on FLSD Docket 11/17/2023   Page 2 of 3

 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that a copy of this document was served on the 
following parties via CM/ECF on November 17, 2023. 
 
SERVICE LIST 
 
AUSA David Snider 
U.S. Attorney’s Office SDFL 
500 E. Broward Blvd, 7th Floor 
Ft. Lauderdale, FL 33394 
954-660-5696 
david.snider@usdoj.gov 
 
 
 
 
Case 0:23-cr-60173-KMW   Document 15   Entered on FLSD Docket 11/17/2023   Page 3 of 3

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