Court filing - United States v. Carolyn Denise Wade (Doc. 59, filed 2024-05-10)

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The United States' Proposed Voir Dire Questions in United States of America v. Carolyn Denise Wade, Case No. 23-60173-CR-WILLIAMS, in the U.S. District Court for the Southern District of Florida, Document 59, entered May 10, 2024. The United States requests that, in addition to the Court's standard questions, the Court ask the listed questions during voir dire of the jury panel, and that the parties be allowed to propose additional questions. The questions are grouped under General, Experience with Law Enforcement and Government Agencies, and Experience with Business, the SBA, and Pandemic Relief Funds, and include questions about the Internal Revenue Service and the Paycheck Protection Program. The final question refers to the offense charged, fraudulently obtaining a Paycheck Protection Program loan.

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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’ PROPOSED VOIR DIRE QUESTIONS 
 
Pursuant to Fed. R. Crim. P. 24(a), the United States respectfully requests that, in 
addition to the Court’s standard questions, the Court ask the following questions during voir 
dire of the jury panel. The United States further requests that the parties be allowed to propose 
additional voir dire questions as may become appropriate during the examination of potential 
jurors. 
 
GENERAL  
1. 
Your duty, as jurors, is to judge guilt or innocence based upon the evidence.  It is 
the duty of the judge to determine punishment if you vote guilty.  The law does not permit you to 
consider the issue of punishment because there are factors having nothing to do with this trial that 
will determine lenience or harshness.  However, some people believe that people should not be 
incarcerated for committing certain types of crimes.  Does anyone believe that regardless of the 
evidence, they might vote "Not Guilty" simply because a conviction may result in a prison 
sentence, even though you do not know whether it will or not?  
Case 0:23-cr-60173-KMW   Document 59   Entered on FLSD Docket 05/10/2024   Page 1 of 4

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2. 
Do any of you have any beliefs or convictions, whether moral, religious, 
philosophical, or otherwise, that would prevent you from being a fair and impartial juror in this 
case or that would make it difficult for you to reach a verdict based on the evidence and the law as 
it applies to the evidence?  
3. 
Have you or someone close to you been involved in a lawsuit or court proceeding?  
a) 
What type of case was it? 
b) 
Were you, or someone close to you, a party in the case, or a witness?  
c) 
 Is your impression that the proceeding was fair?  
d) 
What is your impression of how you or someone close to you was treated? 
EXPERIENCE WITH LAW ENFORCEMENT AND GOVERNMENT AGENCIES  
4. 
Have you, your spouse, or any of your close relatives or friends, ever had any 
dealings or involvement with the Federal Bureau of Investigations, Broward County Sheriff’s 
Office, the Department of Justice, or any other federal, state, or local law enforcement agency? 
a) 
If you have, were those dealings positive or negative?  
b) 
Do you believe that would affect your ability to be a fair and impartial juror 
to both sides in this case? 
5. 
Police officers, federal law enforcement agencies, and the criminal justice system 
are often the topic of current events and news stories, and these events can shape the way that 
individuals view the criminal justice system in both positive and negative ways.  Does anyone feel 
that any current events, or any other knowledge or personal views that you have about police 
officers, federal law enforcement agencies, or the criminal justice system, will lead you to favor 
or disfavor either the United States or the Defendant in sitting as a juror in this case? 
Case 0:23-cr-60173-KMW   Document 59   Entered on FLSD Docket 05/10/2024   Page 2 of 4

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6. 
Other than filing taxes, have you or someone close to you had any experience with 
the Internal Revenue Service (IRS)? 
a) 
What happened? 
b) 
What is your impression of how you or the person close to you was treated? 
EXPERIENCE WITH BUSINESS, THE SBA, AND PANDEMIC RELIEF FUNDS 
 
7. 
Do you or someone close to you own a business? 
a) 
What type of business is it? 
b) 
Does it have employees? 
c) 
How many? 
8. 
Have you or someone close to you applied for a Paycheck Protection Program (PPP) 
or an Economic Injury Disaster Loan (“EIDL”)? 
a) 
If so, were the loans received, and what were the amounts of the loans? 
b) 
What is your impression of the experience with the application and the loan? 
c) 
Do you have strong feelings, either positive or negative, about the way that 
the SBA and/or its participating lenders administered the PPP or EIDL?  If 
so, please explain.  
d) 
Do you have strong feelings, either positive or negative, in general about any 
government financial assistance program during the pandemic? If so, please 
explain.  
9. 
Have you or someone close to you applied for any other type of loan through the 
government, including through the Small Business Administration (SBA)? 
a) 
What type of loan was it? 
b) 
What is your impression of the experience with the application and the loan? 
Case 0:23-cr-60173-KMW   Document 59   Entered on FLSD Docket 05/10/2024   Page 3 of 4

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10. 
The Defendant is charged with fraudulently obtaining a Paycheck Protection 
Program loan.  Knowing the offense charged, does anybody here feel that they may be more likely 
to side with the government over the Defendant in deciding the Defendant’s guilt or innocence? 
Does anybody feel that they may be more likely to side with the Defendant over the government 
because of the offense charged? 
 
 
 
 
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 59   Entered on FLSD Docket 05/10/2024   Page 4 of 4

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