Court filing - United States v. Tracy and Carolyn Wade (Doc. 33, filed 2024-04-01)

Summary

The government's witness list in United States of America v. Carolyn Denise Wade, No. 0:23-cr-60173-KMW, in the U.S. District Court for the Southern District of Florida, Doc. 33, entered April 1, 2024. It lists proposed trial witnesses, including Arlene Embrey of the U.S. Small Business Administration, Paycheck Protection Program; Renee McClain of the Internal Revenue Service; Joanna Hely of the Broward Sheriff's Office; and Kelly DiPietrantonio, Special Agent, Federal Bureau of Investigation. It also lists companies with witnesses to be designated, including USAA Federal Savings Bank, AT&T, Verizon and Google. The United States requests leave to add witnesses based on their availability, whether or not defendant will testify, and whether the Government will present a rebuttal case.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO.  23-60173-CR-WILLIAMS 
 
 
UNITED STATES OF AMERICA  
 
 
 
 
 
 
 
vs. 
 
 
 
 
 
 
 
 
 
 
 
 
 
CAROLYN DENISE WADE,  
 
 
 
 
 
 
 
 
 
Defendant. 
 
 
____________________________________/ 
 
GOVERNMENT’S WITNESS LIST 
 
The United States of America, by and through its undersigned counsel, hereby files its list 
of proposed witnesses for trial. 
1. Arlene Embrey, U.S. Small Business Administration, Paycheck Protection Program 
2. B.S.D. Capital Inc. DBA Lendistry (witness to be designated) 
3. Harvest Small Business Finance, LLC (witness to be designated)  
4. Oto Analytics, Inc. DBA Womply (witness to be designated)  
5. Rob Walley, Innova Solutions 
6. Renee McClain, Internal Revenue Service 
 
7. USAA Federal Savings Bank (witness to be designated) 
8. Joanna Hely, Broward Sheriff’s Office 
9. AT&T (witness to be designated)  
 
10. Verizon (witness to be designated)  
11. Google (witness to be designated) 
12. Kelly DiPietrantonio, Special Agent, Federal Bureau of Investigation 
 
Case 0:23-cr-60173-KMW   Document 33   Entered on FLSD Docket 04/01/2024   Page 1 of 2

2 
 
The United States requests leave to add witnesses based on their availability, whether or 
not defendant will testify, and whether the Government will present a rebuttal case.   
 
 
 
 
 
 
Respectfully submitted, 
 
 
MARKENZY LAPOINTE 
  
UNITED STATES ATTORNEY 
 
By: /s/ David A. Snider  
 
 
 
 
 
 
 
 
 
David A. Snider 
Assistant United States Attorney 
Court ID No. A5502260 
500 E. Broward Blvd 
Fort Lauderdale, FL  33394 
Tel: (954) 660-5696 
Fax: (954) 356-7336 
Email: david.snider@usdoj.gov 
Case 0:23-cr-60173-KMW   Document 33   Entered on FLSD Docket 04/01/2024   Page 2 of 2

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