Indictment - 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. 303 · 2026-04-07 · Docket on CourtListener

Summary

The government's response to Carolyn Denise Wade's motion for early termination of probation (DE 300) in United States v. Carolyn Denise Wade, No. 0:23-cr-60173-KMW, in the U.S. District Court for the Southern District of Florida, entered on the docket April 7, 2026 as Doc. 303. The United States states that it does not oppose the motion. It recounts the June 27, 2024 Superseding Indictment charging counts under 18 U.S.C. § 1349, 18 U.S.C. § 1343, 18 U.S.C. § 371 and 15 U.S.C. § 645(a), the jury's guilty verdict after an October 2024 trial, and the March 12, 2025 sentence of 3 years' probation with $41,666 in restitution and a $600 special assessment. Citing Section 3564(c), it reports that the supervising probation officer found no non-compliance and supports the motion. The two-page response is signed by Assistant U.S. Attorney David A. Snider.

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Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO. 23-60173-CR-KMW(s) (GRAHAM) 
 
UNITED STATES OF AMERICA 
 
vs. 
 
CAROLYN DENISE WADE, 
 
Defendant. 
 
 / 
 
RESPONSE BY THE UNITED STATES TO  
DEFENDANT’S MOTION FOR EARLY TERMINATION OF PROBATION 
 
 
The United States of America hereby responds to the motion for early termination of 
probation as to Defendant Carolyn Denise Wade (“Defendant”) filed on March 18, 2026 (DE 300) 
(the “Motion”).1  For the reasons set forth below, the United States does not oppose the Motion. 
Procedural History  
On June 27, 2024, a grand jury returned a Superseding Indictment (DE 188) charging 
Defendant with conspiracy to commit wire fraud (18 U.S.C. § 1349), wire fraud (18 U.S.C. 
§ 1343), conspiracy to make false statements to the Small Business Administration (SBA) (18 
U.S.C. § 371) and false statements to the SBA (15 U.S.C. § 645(a)).  The charges arose from 
Defendant fraudulently obtaining a loan through the SBA’s Paycheck Protection Program.  
Defendant proceeded to trial in October 2024, and a jury returned a verdict finding her guilty on 
all counts with which she was charged (DE 183).  On March 12, 2025, the Court sentenced 
Defendant to a term of 3 years’ probation and imposed criminal monetary penalties consisting of 
restitution in the amount of $41,666 and a $600 special assessment (DE 241).2 
 
1 The Court directed the government and the Probation Office to respond to the Motion by April 7, 2026 (DE 302). 
 
2 Defendant’s term of probation included home detention for 90 days, among other special conditions.  
Case 0:23-cr-60173-KMW   Document 303   Entered on FLSD Docket 04/07/2026   Page 1 of 2

2 
 
Applicable Statute 
 
Title 18, United States Code, Section 3564(c) provides as follows: 
The court, after considering the factors set forth in section 3553(a) to the extent that 
they are applicable, may, pursuant to the provisions of the Federal Rules of 
Criminal Procedure relating to the modification of probation, terminate a term of 
probation previously ordered and discharge the defendant at any time in the case of 
a misdemeanor or an infraction or at any time after the expiration of one year of 
probation in the case of a felony, if it is satisfied that such action is warranted by 
the conduct of the defendant and the interest of justice. 
 
Factors Supporting Early Termination of Probation 
Undersigned counsel has conferred with United States Probation Officer Caitlin Mayo, 
who is presently supervising Defendant.  Officer Mayo advised the government that Defendant 
has had no instances of non-compliance during her term of probation and is presently assessed to 
be low risk.  She further advised that Defendant has satisfied all her financial obligations in this 
case.  Furthermore, Officer Mayo advised that she is familiar with the Motion and supports it.  The 
government agrees with Probation’s assessment. 
Conclusion 
The United States does not oppose early termination of probation as to Defendant Carolyn 
Denise Wade, pursuant to Title 18, United States Code, Section 3564(c). 
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 303   Entered on FLSD Docket 04/07/2026   Page 2 of 2

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