Court filing - United States v. Carolyn Denise Wade (Doc. 31, filed 2024-04-01)

Summary

The United States' Notice of Intent to Seek Admission of Self-Authenticating Records, Doc. 31, entered April 1, 2024 in United States v. Carolyn Denise Wade, Case No. 23-60173-CR-WILLIAMS, in the U.S. District Court for the Southern District of Florida. The notice is filed under Federal Rules of Evidence 902(11) and 902(13) and says the United States intends to introduce certified records at trial. A table lists entities and records, including Paycheck Protection Program loan records of B.S.D. Capital Inc. DBA Lendistry, Harvest Small Business and Oto Analytics, Inc. DBA Womply, Internal Revenue Service tax records, and records of AT&T, Verizon, Google and the Broward Sheriff's Office. The notice says copies were provided to the defendant's counsel in discovery.

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Record facts

Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO. 23-60173-CR-WILLIAMS 
 
UNITED STATES OF AMERICA  
 
 
 
 
 
 
vs. 
 
 
 
 
  
   
 
 
CAROLYN DENISE WADE, 
 
            
 
Defendant. 
________________________________________/ 
 
UNITED STATES’ NOTICE OF INTENT TO SEEK 
ADMISSION OF SELF-AUTHENTICATING RECORDS 
 
The United States of America, by and through its undersigned counsel, hereby files this 
notice, pursuant to Rules 902(11) and 902(13) of the Federal Rules of Evidence, of the United 
States’ intent to introduce into evidence at trial the following records as self-authenticating 
certified domestic records of a regularly conducted activity and/or certified records generated by 
an electronic process or system: 
No. 
Entity 
Description of Records  
1.  
B.S.D. Capital Inc. DBA Lendistry 
Paycheck Protection Program loan records. 
2.  
Harvest Small Business 
Paycheck Protection Program loan records. 
3.  
Oto Analytics, Inc. DBA Womply 
Paycheck Protection Program loan records. 
4.  
U.S. Small Business Administration  
Paycheck Protection Program loan records 
5.  
Internal Revenue Service 
Federal tax records, including tax returns. 
6.  
USAA Federal Savings Bank 
Bank records. 
7.  
Florida Department of Revenue 
Florida revenue records. 
8.  
AT&T 
Internet service provider records. 
9.  
Verizon 
Cell phone records. 
10.  
Google 
Account subscriber records 
11.  
Broward Sheriff’s Office 
BSO policy and human resource records 
 
 
 
 
Case 0:23-cr-60173-KMW   Document 31   Entered on FLSD Docket 04/01/2024   Page 1 of 2

2 
 
Copies of these records were provided to Defendant’s counsel of record in discovery prior 
to this filing.  The United States reserves its right to supplement this Notice to Defendant as 
necessary.    
Respectfully submitted, 
 
    
MARKENZY LAPOINTE 
  
UNITED STATES ATTORNEY 
 
By: /s/ David A. Snider  
 
 
 
 
 
 
 
 
 
David A. Snider 
Assistant United States Attorney 
Court ID No. A5502260 
500 E. Broward Blvd 
Fort Lauderdale, FL  33394 
Tel: (954) 660-5696 
Fax: (954) 356-7336 
Email: david.snider@usdoj.gov 
 
 
 
 
Case 0:23-cr-60173-KMW   Document 31   Entered on FLSD Docket 04/01/2024   Page 2 of 2

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