Court filing

Indictment - United States v. Tracy and Carolyn Wade

Record facts

Court	U.S. District Court for the Southern District of Florida
Filed	2024-03-08

U.S. District Court for the Southern District of Florida · No. 0:23-cr-60173-KMW · Doc. 26 · 2024-03-08 · Docket on CourtListener

Summary

Carolyn Denise Wade's Unopposed Motion for Continuance in United States v. Carolyn Wade, No. 0:23-cr-60173-KMW, in the U.S. District Court for the Southern District of Florida, entered on the docket March 8, 2024 as Doc. 26. The motion states that Ms. Wade is charged by Indictment with one count of wire bank fraud in connection with a PPP loan application under 18 U.S.C. Section 1343 and was arraigned on October 19, 2023. It lists a calendar call on April 2, 2024 and a jury trial set for April 8, 2024, and notes the February 21, 2024 order substituting counsel. Counsel states that discovery has not yet been received, cites conflicting trial commitments, and reports that Assistant U.S. Attorney David Snider has no objection. The motion asks the Court to continue the trial until at least mid-June, 2024, and is signed by Johnny L. McCray, Jr.

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Full text

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
UNITED STATES OF AMERICA,             Case No. 23-CR60173-KMW                             
 
Plaintiff, 
 
v. 
 
CAROLYN WADE, 
                   
Defendant. 
__________________________/                  
 
DEFENDANT’S UNOPPOSED MOTION FOR CONTINUANCE 
 
 
The Defendant, CAROLYN DENISE WADE (“Ms. Wade”), through  
counsel, respectfully moves to continue the calendar call and trial of this  
matter.  In support thereof, Ms. Wade states the following: 
1. Ms. Wade is charged by Indictment with one count of wire  
bank fraud in connection with a PPP loan application, in violation of  
18 U.S.C. Section 1343.  
2. Ms. was arraigned on October 19, 2023.  
3. This matter is currently scheduled for a calendar call on April 2,  
2024, at 11:00 a.m.  
4. A jury trial is also scheduled to commence on April 8, 2024, at 9:00  
a.m. 
5. On February 21, 2024, this Honorable Court entered an Order of  
Substitution of Counsel granting leave for the undersigned to represent  
Case 0:23-cr-60173-KMW   Document 26   Entered on FLSD Docket 03/08/2024   Page 1 of 3

Page 2 of 3 
 
the interest of Ms. Wade. 
6. The undersigned counsel commenced a federal jury trial on  
February 29, 2024 before the Honorable Judge James Cohn, which ended  
March 5, 2024. AUSA David Snider was the assigned prosecutor in that  
case. 
7. The undersigned has not yet received discovery; however, the  
government has represented to the undersigned that they are in the  
process of providing discovery to the. 
8.  Once the discovery is received, the undersigned will need  
additional time to sort through and review. 
9. The undersigned counsel has had longstanding plans to be out of the  
country from March 19, 2024 through March 31, 2024, and has purchased  
non-refundable airline tickets and hotel accommodations, etc. 
10. 
The undersigned will require additional time to prepare for  
trial once discovery is received. 
11. 
The undersigned has contacted the assigned Assistant United  
States Attorney David Snider, who advises he has no objection to  
continuing the calendar call and trial in this matter. 
12. 
On Monday, May 6, 2024, the undersigned is scheduled to  
commence jury selection in Broward County in State of Florida v. Jaslyn  
Smith, Case No. 21-10420 CF 10A (Judge Ernest Kollra), a special set  
three co-defendant first degree murder trial. The expected length of the  
trial is 5-6 weeks. The current trial date was special set in November,  
Case 0:23-cr-60173-KMW   Document 26   Entered on FLSD Docket 03/08/2024   Page 2 of 3

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2023. 
WHEREFORE, the Defendant, CAROLYN DENISE WADE,  
respectfully requests this Honorable Court continue the trial of this  
matter until at least mid-June, 2024. 
By: s/Johnny L. McCray, J. Esq.    
 
 
 
 
 
 
 
                 
 CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on March 8, 2024, I electronically filed 
the foregoing motion/document with the Clerk of the Court 
using CM/ECF. I also certify that the foregoing 
motion/document is being serving on all counsel of record via 
transmission of Notices of Electronic Filing generated by 
CM/ECF or in some other authorized manner for those counsel 
or parties who are not authorized to receive electronic Notices 
of Electronic Filing, on this 8th day of March, 2024. /s/ Johnny L. 
McCray, Jr. 
Johnny L. McCray, Jr., Esquire  
Florida Bar No. 342319 
Law Office of Johnny L. McCray, Jr., P.A. 
400 East Atlantic Boulevard  
Pompano Beach, Florida 33060 
Tel: (954) 781-3662 
Fax: (954) 786-2289                                                     
 
mccrayjlaw@gmail.com 
cc: Client 
Case 0:23-cr-60173-KMW   Document 26   Entered on FLSD Docket 03/08/2024   Page 3 of 3

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