Information — United States v. Tracy and Carolyn Wade (Dkt. 298, 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. 298 · 2025-12-31 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO. 23-60173-CR-KMW(s) (GRAHAM) 
 
UNITED STATES OF AMERICA  
 
 
 
vs. 
 
 
 
 
 
 
 
 
TRACY D. WADE, 
 
Defendant. 
                                    / 
 
RESPONSE BY THE UNITED STATES TO DEFENDANT TACY WADE’S  
MOTION TO MODIFY CONDITIONS OF SUPERVISED RELEASE [DE 296] 
 
 
The United States of America, by and through its undersigned counsel, hereby responds to 
the motion to modify conditions of supervised release filed by Defendant Tracy Wade 
(“Defendant”) on December 17, 2025 (DE 296) (the “Motion”).     
 
On March 12, 2025, the Court sentenced Defendant to a 90-day term of imprisonment to 
be followed by a 3-year term of supervised release as to Counts 1, 2, 3, 4, 6, 7, and 10 of the 
Superseding Indictment for which Defendant was found guilty (DE 242).  Defendant surrendered 
for service of his sentence on August 27, 2025.  According to Bureau of Prisons website, 
Defendant was released from custody on November 3, 2025. 
 
The terms of supervised release set forth in the Judgment (DE 242) provide, among other 
things, that Defendant shall not: 1) knowingly leave the federal judicial district in which he is 
authorized to reside (i.e., the Southern District of Florida) without first getting permission from 
the court or the probation officer; and 2) apply for, solicit or incur any further debt, including but 
not limited to loans, lines of credit or credit card charges, either as a principal or cosigner, as an 
individual or through any corporate entity, without first obtaining permission from the United 
States Probation Officer. 
Case 0:23-cr-60173-KMW   Document 298   Entered on FLSD Docket 12/31/2025   Page 1 of 3

2 
 
 
In the Motion, Defendant seeks to modify the above conditions as follows: 
1. 
“Permission to travel outside of the current jurisdictional boundaries strictly for 
verified business purposes related to Wade Funeral Home operations.”  In 
connection with this request, Defendants states that he is “fully prepared to provide 
comprehensive documentation for any such travel, including, but not limited to: 
• Advance written notice to my probation officer with travel dates, 
destinations, and purpose 
• Service contracts or family authorization forms 
• Transportation manifests and death certifications (as applicable)  
• Receipts, invoices, and business correspondence substantiating the 
business nature of travel 
• Contact information for all locations visited.” 
2. 
“Removal of the condition prohibiting the opening of new lines of credit” for Wade 
Funeral Home.  In connection with this request, Defendant states: “I propose that 
any new business credit applications be reported to my probation officer in advance, 
with full documentation provided, to ensure transparency while allowing necessary 
business operations to continue.”  
On December 29, 2025, the undersigned Assistant United States Attorney conferred with 
U.S. Probation Officer Chekia Hill who is presently supervising Defendant.  Officer Hill advised 
that Probation does not object to Defendant’s requests based upon the reasons set forth in the 
Motion, the fact that Defendant has satisfied all financial obligations ordered in this case, and 
Defendant has otherwise complied with the terms of supervision. 
Case 0:23-cr-60173-KMW   Document 298   Entered on FLSD Docket 12/31/2025   Page 2 of 3

3 
 
 
Based on the facts and circumstances of this case, the basis for the modifications set forth 
in the Motion, and Probation’s position, the United States does not oppose Defendant’s request to 
modify the conditions of his supervised release as set forth in the Motion so long as Defendant 
provides advance notice to U.S. Probation for each request. 
   
Respectfully submitted, 
 
    
JASON A. REDING QUIÑONES 
  
UNITED STATES ATTORNEY 
 
By: /s/ David A. Snider  
 
 
 
 
 
 
 
 
 
David A. Snider 
Assistant United States Attorney 
Court ID No. A5502260 
99 N.E. 4th Street 
Miami, FL 33132 
Tel: (305) 961-9446 
Email: david.snider@usdoj.gov 
Case 0:23-cr-60173-KMW   Document 298   Entered on FLSD Docket 12/31/2025   Page 3 of 3

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