Exhibit - United States v. Carolyn Denise Wade (Doc. 40, filed 2024-04-12)

Summary

Defendant Carolyn D. Wade's witness and exhibit lists in United States of America v. Carolyn D. Wade, Case No. 23-cr-60173, in the U.S. District Court for the Southern District of Florida, Doc. 40, filed with a certificate of service dated April 12, 2024. The witness list includes all witnesses on the government's witness list, Carolyn D. Wade, Tracy Wade, Haydee Granados, aka Haydee Rivero, and Tammy DeClerq, COO, SBA, B.S.D. CapitalLendistry. The exhibit list includes all exhibits listed on the government's exhibit list, 2019 tax returns (including Schedule C) of Carolyn D. Wade, and SBA PPP loan applications of Haydee Granados, aka Haydee Rivero. The defendant reserves the right to call additional witnesses.

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Page 1 of 2 
 
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 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. CapitalLendistry 
7. Representative, Harvest Small Business Finance  
8. Representative/ Records Custodial, U.S. Small Business Administration (PPP) 
9. Records Custodian, Broward Sheriff Office (BSO) 
 
Exhibits 
 
10. All exhibits listed on the government’s exhibit list 
11. 2019 Tax Returns (including Schedule C)-Carolyn D. Wade 
12.  SBA PPP Loan applications, Haydee Granados, aka Haydee Rivero 
 
Defendant, CAROLYN D. WADE, reserves the right to call additional witnesses on  
Case 0:23-cr-60173-KMW   Document 40   Entered on FLSD Docket 04/12/2024   Page 1 of 2

Page 2 of 2 
 
U.S. v. Carolyn D. Wade 
Case# 23-cr-60173 Williams/ Graham 
Def. Witness/Exhibit List 
 
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 April 12, 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.   
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
/S/ 
 
 
 
 
 
 
 
 
 
 
Johnny L. McCray, Jr., Esq. 
 
 
 
 
 
 
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  
 
 
 
 
 
 
 
 
 
 
mccrayjl@gmail.com 
 
cc: Carolyn D. Wade 
Case 0:23-cr-60173-KMW   Document 40   Entered on FLSD Docket 04/12/2024   Page 2 of 2

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