Defendant Carolyn D. Wade's Amended Witness and Exhibit Lists — United States v. Wade (Dkt. 55, S.D. Fla.)

Summary

Defendant Carolyn D. Wade's amended witness and exhibit lists for her trial in United States v. Carolyn D. Wade, Case No. 23-CR-60173, Southern District of Florida, entered on the docket 05/02/2024 as Document 55. Her witnesses include Tracy Wade, Haydee Granados, also known as Haydee Rivero, a B.S.D. Capital/Lendistry officer, a Harvest Small Business Finance representative and an SBA records custodian. Her exhibits include her 2019 tax returns, SBA PPP loan applications of Haydee Granados, emails among the Wades and Granados, and cancelled checks, including one paying Granados for PPP loan preparation. The list was filed by defense attorney Johnny L. McCray, Jr.

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U.S. v. Carolyn D. Wade 
Case# 23-cr-60173 Williams/ Graham 
Def. Amended Witness/Exhibit List 
 
 
Page 1 of 3 
 
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 CAROLYN D. WADE’S AMENDED WITNESS AND EXHIBIT LISTS 
 
 
Defendant, CAROLYN D. WADE, files her Witness and Exhibit List with regard to 
the upcoming Trial and may use some or all of the following witnesses and exhibits in 
the trial in this matter. 
Witnesses 
1. All witnesses listed on the government’s witness list 
2. Carolyn D. Wade, Defendant 
3. Tracy Wade 
4. Haydee Granados, aka Haydee Rivero 
5. Edward Rivero/ Rivero Funeral Home  
6. Tammy DeClerq, COO, SBA, B.S.D. Capital/Lendistry 
7. Representative, Harvest Small Business Finance  
8. Representative/ Records Custodial, U.S. Small Business Administration (PPP) 
9. Records Custodian, Broward Sheriff Office (BSO) 
10. Eric Wilson, Eric Wilson Mortuary  
 
Exhibits 
 
11. All exhibits listed on the government’s exhibit list 
12. 2019 Tax Returns (including Schedule C)-Carolyn D. Wade 
Case 0:23-cr-60173-KMW   Document 55   Entered on FLSD Docket 05/02/2024   Page 1 of 3

U.S. v. Carolyn D. Wade 
Case# 23-cr-60173 Williams/ Graham 
Def. Amended Witness/Exhibit List 
 
 
Page 2 of 3 
 
13.  SBA PPP Loan applications, Haydee Granados, aka Haydee Rivero 
14. Email Compendium between Carolyn D. Wade, Tracy Wade and Haydee 
Granados 
15. Cancelled Check from Carolyn D. Wade for payment to Haydee Granados for 
PPP Loan preparation, payable to third party upon direction 
16. Cancelled Check payable to Jersey City Group for PPP Loan Application 
17. Email from Tracy Wade to Haydee Granados forwarding requested bank 
statements 
18. Email from Tracy Wade to Haydee Granados forwarding Docusign login 
credentials for access to account  
 
Defendant, CAROLYN D. WADE, reserves the right to call additional witnesses on  
this list, or refrain from calling witnesses on this list, and reserves the right to 
introduce into evidence or utilize additional documents on this list, or refrain from 
utilizing or introducing into evidence documents on this list as the circumstances 
dictate. 
CERTIFICATE OF SERVICE 
I HEREBY certify that on May 1, 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 vis a 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 electronically Notices of 
Electronic Filing.   
 
 
 
Case 0:23-cr-60173-KMW   Document 55   Entered on FLSD Docket 05/02/2024   Page 2 of 3

U.S. v. Carolyn D. Wade 
Case# 23-cr-60173 Williams/ Graham 
Def. Amended Witness/Exhibit List 
 
 
Page 3 of 3 
 
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
/s/ Johnny L. McCray, Jr. 
 
 
 
 
 
 
Fla. Bar Number 342319 
 
 
 
 
 
 
Attorney for Defendant 
 
 
 
 
 
 
Law Office of Johnny L. McCray, Jr. , P.A. 
 
 
 
 
 
 
400 East Atlantic Boulevard 
 
 
 
 
 
 
Pompano Beach, FL 33060 
 
 
 
 
 
 
(954) 781-3662  
 
 
 
 
 
 
 
 
 
 
McCrayjlaw @gmail.com 
 
cc: Carolyn D. Wade 
Case 0:23-cr-60173-KMW   Document 55   Entered on FLSD Docket 05/02/2024   Page 3 of 3

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