Indictment — United States v. Tracy and Carolyn Wade (Dkt. 88, S.D. Fla. No. 0:23-cr-60173)

Record facts

U.S. District Court for the Southern District of Florida · No. 0:23-cr-60173-KMW · Doc. 88 · 2024-06-27 · Docket on CourtListener

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 23-60173-CR-W lLLlAM S(s)
18 U.S.C. j 1349
18 U.S.C. j 1343
18 U.S.C. j 371
15 U.S.C. j 645(a)
18 U.S.C. j 981(a)(1)(C)
FILED BY 
D.C.
JUN 2 7 222j
ANGELA E. NOBLE
CLERK U S. DISI C'E
s. (). o: Ftk. - Irc LAun.
UM TED STATES OF AM ERICA
VS.
CAROLYN DENISE W ADE and
TM CY D. W ADE,
D efendants.
SUPERSEDING INDICTG
NT
The Grand Jury charges that:
GENERAL ALLEGATIONS
At alI times relevant to this Superseding lndictment:
The Small Business Administration
The United States Small Business Administration (;$SBA'') was an executive
branch agency of the United States governm ent that provided support to entrepreneurs and small
businesses. The m ission of the SBA was to maintain and strengthen the nation's economy by
enabling the establishment and viability of small businesses and by assisting in the economic
recovery of communities after disasters.
As part of this effort, the SBA enabled and provided loans through banks, credit
unions, and other lenders. These loans had government-backed guarantees.
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The Paycheck Protection Program
The Coronavirus Aid, Relief, and Economic Security CtCARES''I Act was a federal
law enacted in or around M arch 2020, designed to provide emergency financial assistance to the
millions of Americans who were suffering from the econom ic effects caused by the COVlD-19
pandem ic. One source Of relief that the CARES Act provided was the Paycheck Protection
Program ((PPP''), which authorized forgivable loans to small businesses for job retention and
certain other expenses.
4. 
The SBA promulgated regulations concerning eligibility for a PPP loan. To obtain
a PPP loan, a qualifying business was required to submit a PPP loan application, which was signed
by an authorized representative of the business. The PPP loan application required the business
(through its authorized representative) to acknowledge the program rules and make certain
affirmative certifications to be eligible to obtain the PPP loan, including that the business was in
operation on February l 5, 2020, and either had employees for whom it paid salaries and payroll
taxes or paid independent contractors. Payments to independent contractors are typically reported
to the lntemal Revenue Service ((tlRS'') on a çsForm 1099-MlSC.'' ln the PPP loan application
(SBA Fonn 2483), the small business (through its authorized representative) was required to state,
amcmg other things, its: (a) average monthly payroll expenses; and (b) number of employees.
These figures were used to calculate the amount of money the small business was eligible to
receive under the PPP.
In addition, a business applying for a PPP loan was required to provide
docum entation showing its payroll expenscs. This payroll inform ation was matcrial to the
application because, pursuant to statutoly requirements and implementing regulaticms, the amount
of the loan that typically could be approved was a function of the applicant's historical payroll
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costs, consisting of compensation to its employees whose principal place of residence was the
United States, subject to certain exclusions.
6. 
lndividuals who operated a business under a Sûsole proprietorship'' business
structure were eligible for a PPP loan. To qualify for such a PPP loan, individuals had to report
and document their income and expenses from the sole proprietorship. Sole proprietorships
typically report their income and expenses yearly to the lRS on a :TOI'I'IA 1 040, Schedule C.'' As
with other PPP loans, this infonnation and supporting documentation was used to calculate the
amount of money the individual was entitled to receive under the PPP. The m aximum PPP loan
amount for a sole proprietor with no employees was $20,833.
PPP loan applications were processed by participating lenders and third-party loan
processors. If a PPP loan application was approved, the participating lender funded the PPP loan
using its own monies, including by electronic transfer through the Automated Clearing House
system . W hile it was the participating lender that issued the PPP loan, the loan was 100%
guaranteed by the SBA. Data from the application, including information about the borrower, the
total amount of the loan, and the listed number of employees, was transmitted by the lender to the
SBA in the course of processing the loan.
After the lender funded the PPP loan to the borrower, the lender submitted
disbursement details into the SBA E-Tran system, with servers located in Sterling, VA. The SBA'S
Denver Finance Center, located in Denver, Colorado, created payment files and authorized
paym ents of the PPP processing fee to the lender through the Financial M anagem ent System to
the Treasury. The primary server for the Financial M anagement System was in Sterling, VA. The
PPP processing fee varied dcpcnding on the amount of the loan. Once created, the payment tiles
were then transmitted via wire to the U.S. Treasury disbursing office in Kansas City, M issouri,
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which, in turn, sent instructions for payment of funds to the Federal Reserve Bank Automated
Clearing House processing site in East Rutherford, New Jersey.
9. 
The proceeds of a PPP loan could be used only for certain specified items, such as
payroll costs, costs related to the continuation of group health care benefits, or m ortgage interest
payments for the business. The proceeds of a PPP loan were not permitted to be used by the
borrowers to purchase consumer goods, automobiles, personal residences, clothing, orjewelry, to
pay the borrower's personal federal incom e taxes, or to fund the borrower's ordinary day-to-day
living expenses unrelated to the specified authorized expenses.
10. 
The PPP allowed the interest and principal on the PPP loan to be entirely forgiven
if the borrower utilized 60% of the loan in the 24 weeks post-disbursem ent toward payroll costs
and utilized the remaining 40% on qualified expense items (e.g., mortgage, rent, and utilities).
11. 
Applying for PPP loan forgiveness was a separate process that required additional
affirmations that the applicant satisfied the eligibility for PPP loan forgiveness. W hatever portion
of the PPP loan was not forgiven was serviced as a loan.
The Defendants. Co-conspirator. and Relevant Entities
Defendant CAROLYN DENISE W ADE was a resident of Broward County,
Florida, and a Deputy Sherriff with the Broward Sheriff's Office.
13. 
Defendant TR ACY D. W ADE was a resident of Broward County, Florida, and a
Deputy Sheriff with the Broward Sheriff's Office.
14. 
Co-conspirator Haydee Rivero, formerly known as Haydee Granados, was a
resident of Broward County, Florida.
Lender 1 was a participating lender in the PPP, and was located in California.
4
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Loan Processor 1 was a third-party loan processor that processed PPP loan
applications for Lender 1, among other participating PPP lenders, and was located in California.
COUNT 1
Conspiracy to Com mit W ire Fraud
(18 U.S.C. j 1349)
The General Allegations section of this Superseding lndictm ent is re-alleged and
incorporated by reference as though fully set forth herein.
From in or around M ay 202 1, through in or around August 2021, the exact dates
being unknown to the Grand Jury, in Broward County, in the Southern District of Florida, and
elsewhere, the defendants,
CAROLYN DENISE W ADE and
TRACY D. W ADE,
did willfully, that is, with the intent to further the objects of the conspiracy, and knowingly
combine, conspire, confederate and agree with each other, and with Haydee Rivero, fIVa Haydee
Granados, and others known and unknown to the Grand Jury, to knowingly and with intent to
defraud devise and intend to devise a scheme and artifice to defraud, and to obtain money and
property by means of materially false and fraudulent pretenses, representations, and promises,
knowing that the pretenses, representations, and promises were false and fraudulent when made,
and, for the purpose of executing the scheme and artifice, knowingly transm it and cause to be
transmitted, by m eans of wire communications in interstate commerce, certain writings, signs,
signals, pictures, and sounds, in violation of Title l 8, United States Code, Section 1343.
5
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PURPOSE OF THE CONSPIRACY
19. 
It was the purpose of the conspiracy for the defendants and their co-conspirators to
unlawfully enrich themselves by, among other things: (a) making false statements to obtain PPP
loans and forgiveness of such PPP loans from the SBA and its lenders; (b) submitting and causing
the submission of PPP loan applications that contained false and fraudulcnt information; (c)
causing the disbursement of false and fraudulent PPP loans; and (d) submitting and causing the
submission of PPP loan forgiveness applications that contained false and fraudulent information.
M AN NER AND M EA NS O F TH E C ON SPIR ACY
The mylmer and means by which the defendants and their co-conspirators sought to
accomplish the purpose of the conspiracy included, among other things, the following:
Haydee Rivero, f/k/a Haydee Granados, prepared and created false and fictitious
IRS Schedule C forms for inclusion with, and in support of, PPP loan applications for CAROLYN
DENISE W ADE and TR ACY D. W ADE.
CAROLYN DENISE W ADE and TM CY D. W ADE supplied login credentials,
including one-time, short-lived passcodes to Haydee Rivero, f/k/a Haydee Granados, for Rivero to
log in to Loan Processor 1's website and electronically access PPP loan applications for
CAROLYN DENISE W ADE and TRACY D. W ADE.
22. 
Haydee Rivero, f/k/a Haydee Granados, ' inputted and transmitted through the
internet, via Loan Processor l 's website, materially false infonnation for PPP loan applications for
CAROLYN DENISE W ADE and TM CY D. W ADE.
6
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Haydee Rivero, f/k/a Haydee Granados, uploaded and transm itted through the
internet, via Loan Processor 1 's website, materially false and fictitious 1RS Schedule C forms for
inclusion with, and in support of, PPP loan applications for CAROLYN DENISE W ADE and
TM CY D. W ADE.
24. 
CAROLYN DENISE W ADE and TRACY D. W ADE submitted and caused the
submission of PPP loan applications that contained materially false information, including false
and fictitious tax documents.
25. 
CAROLYN DENISE W ADE and TRACY D. W ADE caused the SBA and
Lender 1 to approve and disburse PPP loan proceeds to themselves based upon materially false
inform ation, including false and fictitious IRS Schedule C form s supplied by Haydee Rivero, f/k/a
Haydee Granados.
CAROLYN DENISE W ADE and TRACY D. W ADE paid Haydee Rivero, îlkla
Haydee Granados, and caused her to receive payment, for supplying materially false information,
including false and fictitious 1RS Schedule C forms, in connection with their PPP loan
applications.
27. 
CAROLYN DENSE W ADE and TIRACY D. W ADE used fraudulently obtained
PPP loan proceeds for their personal use, including by writing checks payable to them selves,
directly and indirectly, for purported EGsalary'' and EEpayroll.''
28. 
CAROLYN DENISE W ADE and TM CY D. W ADE subm itled and caused the
subm ission of materially false and fraudulent informaticm to the SBA to attempt to cause and cause
the forgiveness of fraudulently obtained PPP loans.
All in violation of Title l 8, United States Code, Section 1349.
7
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COUNTS 2-3
W ire Fraud
(18 U.S.C. j 1343)
29. 
The General Allegations section of this Superscding lndictment is re-alleged and
incorporated by reference as though fully set forth herein.
30. 
From in or around M ay 2021 , through in or around August 2021, the exact dates
being unknown to the Grand Jury, in Broward Countys in the Southern District of Florida, and
elsewhere, the defendants,
CAROLYN DENISE W ADE and
TM CY D. W ADE,
did knowingly, and with the intent to defraud, devise, and intend to devise, a scheme and artifice
to defraud, and to obtain money and property by means of materially false and fraudulent
pretenses, representations, and promises, knowing that the pretenses, representations, and
promises were false and fraudulent when made, and, for the purpose of executing the scheme and
artifice, did knowingly transmit and cause to be transm itted, by m eans of wire communication in
interstate commerce, certain writings, signs, signals, pictures, and sounds, in violation of Title l 8,
United States Code, Section 1343.
PURPO SE OF THE SCHEM E AND ARTIFICE
31. 
lt was the purpose of the scheme and artifice for the defendants to unlawfully enrich
themselves by, among other things: (a) making false statements to obtain PPP loans and
forgiveness of such PPP loans from the SBA and its lenders; (b) submitting and causing the
submission of PPP loan applications that contained false and fraudulent information; (c) causing
the disbursement of false and fraudulent PPP loans; and (d) submitting and causing the submission
of PPP loan forgiveness applications that contained false and fraudulent inform ation.
8
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THE SCHEM E AND ARTIFICE
32. 
Paragraphs 20 through 28 of the M anner and M eans section of Count l of this
Superseding lndictment are re-alleged and incorporated by reference as though fully set forth
herein as a description of the scheme and artifice.
USE OF W IRES
33. 
On or about the dates and for the defendants specified as to each count below, for
the purpose of executing the aforesaid scheme and artifice to defraud, and to obtain money and
property by means of m aterially false and fraudulent pretenses, representations, and promises,
knowing that the pretenses, representations, and promises were false and fraudulent when made,
did knowingly transm it and cause to be transmitted in interstate commerce, by means of wire
communication, certain writings, signs, signals, pictures, and sounds, as described below:
COUNT 
DEFENDANT 
APPROM M ATE DESCRIPTION OF W IRE
DA TE
1 
TRACY D. W ADE 
June 3, 2021 
Disbursement of SBA loan
number 6261949003 from
Lender l in the approximate
amount of $20,833 by
Automated Clearing House
(ACH) transfer to USAA
Classic Checking account
number endin in 7309.
2 
CAROLYN DENISE 
June 7, 2021 
Disbursement of SBA loan
W ADE 
number 6697269001 from
Lender l in the approximate
and 
amount of $20,833 by
Automated Clearing House
TRACY D. W ADE 
(ACH) transfer to USAA
Classic Checking account
number endin in 3926.
ln violation of Title 18, United States Code, Section 1343.
9
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COUNT 4
Conspiracy to M ake False Statements to the SBA
(18 U.S.C. j 371)
34. 
The General Allegations section of this Superseding lndictm cnt is re-alleged and
incorporated by reference as though fully set forth herein.
35. 
From in or around M ay 2021 , through in or around August 2021, the exact dates
being unknown to the Grand Jury, in Broward County, in the Southern District of Florida, and
elsewhere, the defendants,
CAROLYN DENISE W ADE and
TM
CY D . W AD E,
did willfully, that is, with the intent to further the objects of the conspiracy, and knowingly
combine, conspire, confederate and agree with each other, and with Haydee Rivero, flkla Haydee
Granados, and others known and unknown to the Grand July, to comm it certain offenses against
the United States, that is, to m ake any statement knowing it to be false for the purpose of obtaining
for herself or for any applicant any loan, or extension thereof by renewal, deferment of action, or
for the purpose of influencing in any way the action of the Small Business Adm inistration, or for
the purpose of obtaining money, property, or anything of value, under Title 15, United States Code,
Chapter 14A, in violation of Title 15, United States Code, Section 645(a).
PURPOSE OF THE CONSPIRACY
36. 
lt was the purpose of the conspiracy for the defendants and their co-conspirators to
unlawfully enrich themselves by, among other things: (a) making false sltements to obtain PPP
loans and forgiveness of such PPP loans from the SBA and its lenders; (b) submitting and causing
the submission of PPP loan applications that contained false and fraudulent information; (c)
causing the disbursement of false and fraudulent PPP loans; and (d) submitting and causing the
submission of PPP loan forgiveness applications that contained false and fraudulent information.
10
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M ANNER AND M EANS OF THF, CONSPIM CY
37. 
Paragraphs 20 through 28 of the M anner and M eans section of Count 1 of this
Superseding lndictment are re-alleged and incorporated by reference as though fully set forth
herein as the manner and means by which the defendants and their co-conspirators sought to
accomplish the purpose of the conspiracy.
OVERT ACTS
ln furtherance of the conspiracy and to achieve the purpose thereotl at least one of
the co-conspirators committed and caused to be committed, in the Southern District of Florida, at
least one of the following overt acts, among others:
39. 
On or about M ay 6, 2021, Haydee Rivero, f/k/a Haydee Granados, uploaded and
transm itted through the internet, via Loan Processor 1 's website, a false and fictitious 1RS
Schedule C form for inclusion with, and in support of, a PPP loan application for TRACY D.
W ADE .
On or about M ay 13, 202 l , Haydee Rivero, f/k/a Haydee Granados, uploaded and
transm itted through the internet, via Loan Processor 1's website, a false and tictitious lRS
Schedule C fonn for inclusion with, and in support of, a PPP loan application for CAROLYN
DENISE W ADE.
41. 
On or about M ay l8, 2021, CAROLYN DENISE W ADE electronically initialed
and signed an SBA Form 2483-C Paycheck Protection Program Borrower Application Form for
Schedule C Filers Using Gross lncome, which falsely stated, am ong other things, that the Business
Legal Name was çlcarolyn W ade'' and that the Total Amount of Gross Income (from lRS Form
1040, Schedule C, Line 7) was Eûl 13,560.00.''
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Or about M ay 19, 2021, TIRACY D. W ADE electronically initialed and signed an
SBA Form 2483-C Paycheck Protection Program Borrower Application Form for Schedule C
Filers Using Gross Income, which falsely stated, among otherthings, that the Business Legal Name
was td-l-racy W ade'' and that the Total Amount of Gross lncome (from lRS Form 1040, Schedule
C, Line 7) was $$1 12,430.00.'5
Or about M ay 27, 2021, TRACY D. W ADE electrtmically initialed and signed an
SBA Form 2483-C Paycheck Protection Program Borrower Application Form for Schedule C
Filers Using Gross lncome, which falsely sàted, among otherthings, thatthe Business Legal Nam e
was Ei-l-racy W ade'' and that the Total Amount of Gross lncome (from lRS Form 1040, Schedule
C, Line 7) was ((1 12,430.00.'5
On or about M ay 28, 2021, CAROLYN DENISE W ADE electronically initialed
and signed an SBA Form 2483-C Paycheck Protection Program Borrower Application Form for
Schedule C Filers Using Gross lncome, which falsely stated, among other things, that the Business
Legal Name was ûûcarolyn W ade'' and that the Total Amount of Gross lncome (from IRS Form
1040, Schedule C, Line 7) was E:l 13,560.00.'5
On or about August 7, 2021, CAROLYN DENISE W ADE electronically initialed
and signed an SBA PPP Loan Forgiveness Application Form 35085, which falsely stated, among
other things, that the Business Legal Name was tûcarolyn W ade,'' that the Employees at Tim e of
Loan Application was Cç3,'' that the Employees at Time of Forgiveness Application was 6$3,'' and
that the Amount of Loan Spent on Payroll Costs was :6$20,833.00.''
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46. 
On or about August 7, 2021, TIRACY D. W ADE electronically initialed and signed
an SBA PPP Loan Forgiveness Application Form 35085, which falsely stated, among other things,
that the Business Legal Name was ti-rracy W ade,'' that the Employees at Time of Loan Application
was Gûl0,'' that the Employees at Time of Forgiveness Application was 4:10,'' and that the Amount
of Loan Spent on Payroll Costs was 1:$20,833.00,''
All in violation of Title 1 8, United States Code, Section 371.
COUNT 5
False Statem ent to the SBA
(15 U.S.C. j 645(a))
The General Allegations section of this Superseding lndictment is re-alleged and
incorporated by reference as though fully set forth herein.
48. 
On or about M ay l 8, 2021, in Broward County, in the Southern District of Florida,
and elsewhere, the defendant,
CA R O LY N DE NISE W A DE ,
did knowingly make a false statement to the Small Business Administration for the purpose of
obtaining money and intluencing in any way the Small Business Administration, that is, an SBA
Form 2483-C Paycheck Protection Program Borrower Application Form for Schedule C Filers
Using Gross lncome, which false statement included, among other things, that the Business Legal
Name was ttcarolyn W ade'' and that the Total Amount of Gross Income (from 1RS Form 1040,
Schedule C, Line 7) was (;l 13,560.00,'' in violation of Title 15, United States Code, Section 645(a),
and Title 18, United States Code, Section 2.
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COUNT 6
False Statem ent to the SBA
(15 U.S.C. j 645(a))
49. 
The General Allegations section of this Superseding lndictment is re-alleged and
incorporated by reference as though fully set forth herein.
50. 
On or about M ay l9, 2021, in Broward County, in the Southern District of Florida,
and elsewhere, the defendant,
TR ACY D. W ADE,
did knowingly make a false statement to the Small Business Administration for the purpose of
obtaining money and influencing in any way the Small Business Adm inistration, that is, an SBA
Form 2483-C Paycheck Protection Program Borrower Application Form for Schedule C Filers
Using Gross lncome, which false statement included, among other things, that the Business Legal
Name was Eirfracy Wade'' and that the Total Amount of Gross lncome (from 1RS Form 1040,
Schedule C, Line 7) was $;1 12,430.00,'' in violation of Title l5, United States Code, Section 645(a)
and, Title 18, United States Code, Section 2.
CO UNT 7
False Statem ent to the SBA
(15 U.S.C. j 645(a))
The General Allegations section of this Superseding lndictment is re-alleged and
incorporated by reference as though fully set forth herein.
52. 
On or about M ay 27, 2021, in Broward County, in the Southern District of Florida,
and elsewhere, the defendant,
TR ACY D. W ADE,
did knowingly make a false statement to the Small Business Administration for the purpose of
obtaining money and influencing in any way the Small Business Administration, that is, an SBA
!
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Form 2483-C Paycheck Protection Program Borrower Application Form for Schedule C Filers
Using Gross lncome, which false statement included, among other things, that the Business Legal
Name was Eû-fracy Wade'' and that the Total Amount of Gross lncome (from 1RS Form 1040,
Schedule C, Line 7) was ûC1 12,430.00,'' in violation of Title 15, United States Code, Section 6454$
and, Title 18, United States Code, Section 2.
CO UNT 8
False Statem ent to the SBA
(15 U.S.C. j 645(a))
53. 
The General Allegations section of this Superseding lndictment is rc-alleged and
incorporated by reference as though fully set forth herein.
54. 
On or about M ay 28, 2021, in Broward County, in the Southern District of Florida,
and elsewhere, the defendant,
CARO LYN DENISE W ADE,
did knowingly m ake a false statement to the Small Business Adm inistration for the purpose of
obtaining m oney and influencing in any way the Small Business Administration, that is, an SBA
Form 2483-C Paycheck Protection Program Borrower Application Form for Schedule C Filers
Using Gross lncome, which false statem ent included, among other things, that the Business Legal
Name was tûcarolyn W ade'' and that the Total Amount of Gross lncome (from IRS Form 1040,
Schedule C, Line 7) was ûC1 13,560.00,'' in violation of Title l 5, United States Code, Section 645(a,)
and, Title 18, United States Code, Section 2.
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COUNT 9
False Statem ent to the SBA
(15 U.S.C. j 645(a))
55. 
The General Allegations section of this Superseding lndictment is re-alleged and
incorporated by reference as though fully set forth herein.
56. 
On Or about August 7, 2021, in Broward County, in the Southern District of Florida,
and elsewhere, the defendant,
CAR OLYN DENISE W ADE,
did knowingly make a false statement to the Sm all Business Adm inistration for the purpose of
obtaining money and intluencing in any way the Small Business Administration, that is, an SBA
PPP Loan Forgiveness Application Form 35085, which false statement included, among other
things, that the Business Legal Name was tEcarolyn W ade,'' that the Employees at Time of Loan
Application was tC3,'' that the Employees at Time of Forgiveness Application was ;ç3,'' and that the
Amount of Loan Spent on Payroll Costs was 11$20,833.00,'' in violation of Title 15, United States
Code, Section 645(a) and, Title 18, United States Code, Section 2.
COUNT 10
False Statement to the SBA
(15 U.S.C. j 645(a))
57. 
The General Allegations section of this Superseding lndictment is re-alleged and
incorporated by reference as though fully set forth herein.
58. 
On or about August 7, 2021 , in Broward County, in the Southern District of Florida,
and elsewhere, the defendant,
TM
CY D. W ADE,
did knowingly make a false statement to the Small Business Administration for the purpose of
obtaining money and influencing in any way the Small Business Administration, that is, an SBA
16
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PPP Loan Forgiveness Application Fonn 35085, which false statement included, among others
things, that the Business Legal Name was Ed-rracy W ade,'' that the Employees at Time of Loan
Application was Cd10 '' that the Employees at Time of Forgiveness Application was C$10,'' and that
the Amount of Loan Spent on Payroll Costs was (6$20,833.00,'5 in violation of Title l 5, United
States Code, Section 645/) and, Title 18, United States Code, Section 2.
FORFEITURE AIaLEGATIONS
The allegations of this Superseding lndictment are hereby re-alleged and by this
reference fully incorporated herein for the purpose of alleging forfeiture to the United States of
America of certain property in which the defendants, CAROLYN DENISE W ADE and TRACY
D. W ADE, have an interest.
2. 
Upon conviction of a violation of, or a conspiracy to violate, Title l8, United States
Codc, Section 1343, as alleged in this Superseding lndictment, the defendant shall forfeit to the
United States any property, real or personal, which constitutes or is derived from proceeds
traceable to such offense, pursuant to Title 1 8, United States Code, Section 98 1(a)(l)(C).
All pursuant to Title 1 8, United States Code, Section 981(a)(1)(C) and the procedures set
forth in Title 2l, United States Code, Section 853, as incorporated by Title 28, United States Code,
Section 2461(c).
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Case 0:23-cr-60173-KMW   Document 88   Entered on FLSD Docket 06/28/2024   Page 17 of 22

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AM ERICA
CASE No.: 23-60173-CR-KMW (s)
CERTIFICATE OF TRIAL ATTORNEY
CAROLYN DENISE W ADE and
TRACY D. W ADE,
/
Defendants.
Court Division (select one)
D M iami 
n Key W est 
L FTP
S FTL 
D W PB
I do hereby certify that:
1 . 
l have carefully considered the allegations of the indictment, the number of defendants, the number of probable
witnesses and the legal complexities of the lndictment/lnformation attached hereto.
I am aware that the information supplied on this statement will be relied upon by the Judges of this Court in setting
their calendars and scheduling criminal trials under the mandate of the Speedy Trial Act, Title 28 U.S.C. j3l 61 .
superseding Case Inform ation:
New Defendantts) (Yes or No) Yes
Number of New Defendants 1
Total number of new counts 10
Interpreter: (Yes or No) No
List language and/or dialect:
6 days for the parties to tly.
This case will take
Please check appropriate category and type of offense listed below :
(Check only one) 
(Check only one)
I n 0 to 5 days 
n Petty
11 ? 6 to 10 days 
D Minor
1II D 11 to 20 days 
D Misdemeanor
lv D 21 to 60 days 
Z Felony
r
v 
61 days and over
Has this case been previously filed in this District Court? (Yes or No) No
lf yes, Judge 
Case No.
Has a complaint been sled in this matter? (Yes or No) No
lf yes, M agistrate Case No.
Does this case relate to a previously filed matter in this District Court? (Y'es or No) No
lf yes, Judge 
Case N o.
9. Defendantts) in federal custody as of N/A
l 0. Defendantts) in state custody as of N/A
l 1 . Rule 20 from the 
District of
12. ls this a potential death penalty case? (Yes or No) No
13. Does this case originate from a matter pending in the Northern Region of the U.S. Attorney's Office
prior to August 8, 2014 (Mag. Judge Shaniek M aynard? (Yes or No) No
14. Does this case originate from a matter pending in the Central Region of the U.S. Attonzey's Oftke prior
to October 3, 2019 (M ag. Judge Jared Strauss? (Yes or No) No
matter involve the 
of or consultation with 
Sanchez
Did this 
participation 
M agistrate Judge Eduardo 1.
during his tenure at the U.S. Attorney's Office, which concluded on January 22, 20232 No
l6. Did this m atter involve the participation of or çonsultation w ith now M agistrate Judge M arta Fulgueira
Elfenbein during her tentlre at the U.S. Attorney's Office, which co cluded on M arch 5, 2024? NO
B : 
$ 
'e'
x -
y .
( 
DAVI A. SNl
Assist nt United States Attorney
Court ID N o.
A 5502260
Case 0:23-cr-60173-KMW   Document 88   Entered on FLSD Docket 06/28/2024   Page 18 of 22

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PEN ALTY SH EET
Defendant's Nam e; 
CAROLYN DENISE W ADE
Case No: 23-60l73-CR-KM W (s1
Count #: 1
Conspiracy to Commit W ire Fraud
Title 18. United States Code, Section 1349
* M ax. Term of lm prisonm ent: 20 Years
* M ax. Supervised R elease: 3 years
* M ax. Fine: $250,000
Count #: 3
W ire Fraud
Title 1 8. United States Code. Section 1343
* M ax. Term of lmprisonment: 20 Years
* M ax. Supervised Release: 3 years
* M ax. Fine: $250,000
Count #: 4
Conspiracy to M ake False Statements to SBA
Title l 8. United States Codes Section 371
* M ax. Term of Im prisonment: 5 Years
* M ax. Supervised Release: 3 years
* M ax. Fine: $250,000
Revised 5/16/2022
Case 0:23-cr-60173-KMW   Document 88   Entered on FLSD Docket 06/28/2024   Page 19 of 22

Counts #: 5, 8, 9
False Statem ent to SBA
1
Title l 5- United States Codes Section 6454a)
* M ax. Term  of lm prisonm ent: 2 Years
* M ax. Supervised R elease: 1 year
* M ax. Fine: $5,000 
- 
- -
WRefers only to possible term of incarceration, supervised release and fines. It does not include restitution,
special assessments, parole terms, or forfeitures that may be applicable.
Revised 5/16/2022
Case 0:23-cr-60173-KMW   Document 88   Entered on FLSD Docket 06/28/2024   Page 20 of 22

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Name: 
TRACY D. W ADE
Case No: 23-60173-CR-KM W (s)
C ount #: 1
Conspiracy to Commit W ire Fraud
Title 18. United States Code, Section 1349
* M ax. Term of lmprisonm ent: 20 Years
* M ax. Supervised Release: 3 years
* M ax. Fine: $250,000
Count #: 2, 3
W ire Fraud
Title 18. United States Code. Section 1343
* M ax. Term of lm prisonment: 20 Years
* M ax. Supervised Release: 3 years
* M ax. Fine: $250,000
Count #: 4
Conspiracv to M ake False Statements to SBA
Title 18. United States Code, Section 371
* M ax. Term of Imprisonment: 5 Years
* M ax. Supervised Release: 3 years
* M ax. Fine: $250,000
Revised 5/16/2022
Case 0:23-cr-60173-KMW   Document 88   Entered on FLSD Docket 06/28/2024   Page 21 of 22

Counts #: 6, 7, 10
False Statement to SBA
Title 15s United States Code. Section 645(:0
* M ax. Term of Im prisonm ent: 2 Years
* M ax. Supervised Release: 1 year
* M ax. Fine: $5,000
WRefers only to possible term of incarceration, supervised release and fines. lt does not include restitution,
special assessments, parole terms, or forfeitures that may be applicable.
Revised 5/16/2022
Case 0:23-cr-60173-KMW   Document 88   Entered on FLSD Docket 06/28/2024   Page 22 of 22

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