Information - 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. 42 · 2024-04-12 · Docket on CourtListener

Summary

Defendant Carolyn D. Wade's proposed jury instruction in United States of America v. Carolyn D. Wade, Case No. 0:23-cr-60173-KMW, in the U.S. District Court for the Southern District of Florida, filed April 12, 2024 as Document 42. The filing asks the court to instruct the jury on summaries and summary witnesses before deliberations. The proposed instruction states that summary testimony is no better than the books, records and documents on which it is based and is not independent evidence. It tells jurors to give a summary witness no greater consideration than the underlying evidence and to decide whether the charts or summaries correctly present that information and what weight to give them. The two-page filing is signed by defense counsel Johnny L. McCray, Jr. and includes a certificate of service.

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Full text

Page 1 of 2 
 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
UNITED STATES OF AMERICA, 
 
Case No:23-CR-60173 Williams (Graham) 
v. 
CAROLYN D. WADE, 
 
Defendant.  
 
 
 
 
 
/ 
 
DEFENDANT WADE’S PROPOSED JURY INSTRUCTION  
 
 
The Defendant, CAROLYN D. WADE, through counsel, respectfully requests   
that the Court give  the following instructions to the jury panel prior to their  
deliberations:  
 
Defendant’s Proposed Jury Instruction regarding 
Summaries and Summary Witnesses 
 
There has been testimony from summary witnesses at this trial and the Court 
permitted this testimony in order to make the other evidence more meaningful 
and to aid you in considering the evidence. Such testimony is no better than 
the books, records and other documents upon which the summary witness 
based his/her summary and is not independent evidence. Therefore, you are to 
give no greater consideration to a summary witness than you would give to the 
evidence upon which that testimony is based. 
 
It is for you to decide whether the charts or summary testimony offered by a 
summary witness correctly presented the information contained in the 
documents on which they were based, and what, if any, weight to give such 
evidence. 
   
 
 
 
 
 
 
 
 
 
Case 0:23-cr-60173-KMW   Document 42   Entered on FLSD Docket 04/12/2024   Page 1 of 2

Page 2 of 2 
 
 
USA v. Carolyn D. Wade 
Proposed Jury Instruction 
Case N0. 23-cr-60173 Williams/Graham 
 
 
                           CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on April 12, 2024, I electronically filed the 
foregoing document with the Clerk of the Court using CM/ECF. I also certify that the 
foregoing document is being served this day on all counsel of record via transmission 
of the Notices of Electronic Filing generated by CMF-ECF or in some other authorized 
manner for those Counsel or parties who are not authorized to receive electronically 
Notices of Electronic Filing. 
 
Respectfully submitted, 
/s/ Johnny L. McCray, Jr., Esq.__ 
Johnny L. McCray, Jr., Esquire  
Counsel for Defendant Wade 
Florida Bar No.342319  
400 E. Atlantic Boulevard 
Pompano Beach, Florida 33060 
(954) 954-781-3662 
mccrayjlaw@gmail.com 
 
cc: Carolyn D. Wade 
 
 
 
Case 0:23-cr-60173-KMW   Document 42   Entered on FLSD Docket 04/12/2024   Page 2 of 2

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