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Home Court filings United States v. Carolyn and Tracy Wade — U.S. District Court, S.D. Fla. Exhibit - United States v. Carolyn Denise Wade (Doc. 196-1, filed 2024-10-30)

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Exhibit - United States v. Carolyn Denise Wade (Doc. 196-1, filed 2024-10-30)

Summary

A trial stipulation regarding communications transmitted by wire in interstate commerce, Doc. 196-1 in United States of America v. Carolyn Denise Wade and Tracy D. Wade, Case No. 23-60173-CR-KMW(s) (GRAHAM), in the U.S. District Court for the Southern District of Florida, dated September 23, 2024. The United States and the Defendants stipulate that, as alleged in Count 2 of the Superseding Indictment, a disbursement of approximately $20,833 by ACH transfer to a USAA Federal Savings Bank account was a communication transmitted by wire in interstate commerce on or about June 3, 2021. They stipulate the same as to a second disbursement of approximately $20,833 on or about June 7, 2021, alleged in Count 3. They further stipulate that these facts are deemed proven beyond a reasonable doubt.

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Record facts

CourtU.S. District Court for the Southern District of Florida
Filed2024-10-30

Cite this document

“Exhibit - United States v. Carolyn Denise Wade.” U.S. District Court for the Southern District of Florida, No. 0:23-cr-60173-KMW, Doc. 196-1, filed 2024-10-30. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-wade-flsd-654267/2024-10-30-exhibit-doc-196-1/, SHA-256 110ba28a7179a903fa10f8738eaa3ea66c07f5e032ebf80cb381ac85296f91f5.

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Case 0:23-cr-60173-KMW Document 196-1 Entered on FLSD Docket 10/30/2024 Page 1 of 2

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO. 23-60173-CR-KMW(s) (GRAHAM)
UNITED STATES OF AMERICA
vs.

CAROLYN DENISE WADE and
TRACY D. WADE,

Defendants.

/

TRIAL STIPULATION REGARDING
COMMUNICATIONS TRANSMITTED BY WIRE IN INTERSTATE COMMERCE

The United States of America and Defendants Carolyn Denise Wade and Tracy D. Wade
(“Defendants”), through their respective undersigned counsel, hereby stipulate and agree to the
following facts:

As alleged in Count 2 of the Superseding Indictment, the disbursement of SBA loan
number 6261949003 (hereinafter, “PPP Loan 1”) from Harvest Small Business Finance, LLC,
identified in the Superseding Indictment as Lender 1 (hereinafter, “Lender 1”), in the approximate
amount of $20,833, by Automated Clearing House (ACH) transfer to USAA Federal Savings Bank
(“USAA Bank”) account number ending in 7309, was a communication transmitted by wire in
interstate commerce on or about June 3, 2021. Among other things, the funds for PPP Loan |
originated from Lender 1’s bank, which was a bank located in the State of California, and the funds
were transmitted electronically via ACH transfer to a classic checking account ending in 7309 at
USAA Bank, which was a bank located in the State of Texas.

As alleged in Count 3 of the Superseding Indictment, the disbursement of SBA loan

number 6697269001 (hereinafter, “PPP Loan 2”) from Lender | in the approximate amount of
Case 0:23-cr-60173-KMW Document 196-1 Entered on FLSD Docket 10/30/2024 Page 2 of 2

$20,833, by ACH transfer to USAA Bank account number ending in 3926, was a communication

transmitted by wire in interstate commerce on or about June 7, 2021. Among other things, the

funds for PPP Loan 2 originated from Lender 1’s bank, which was a bank located in the State of

California, and the funds were transmitted electronically via ACH transfer to a classic checking

account ending in 3926 at USAA Bank, which was a bank located in the State of Texas.

The United States and Defendants further stipulate and agree that the United States would

prove the above-stated facts beyond a reasonable doubt with evidence admissible at trial under the

Federal Rules of Evidence, including, but not limited to, testimony and records from Lender 1, and

that these facts are deemed proven beyond a reasonable doubt.

DATED: September 23, 2024

MARKENZY LAPOINTE

UNITED STATES ATTORNEY

Digitally signed by DAVID

DAVID SNIDER pate:202609.23 082732
By: -04'00'
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

LA ef

“ Li MeCray, i it
= 42319
L J oftics Of Johnny L. Mc \ A ara gee

400 East Atlantic Boulevard
Pompano Beach, Florida 33060
Tel: (954) 781-3662

Fax: (754) 307-2857

Email: mecrayjlaw@gmail.com

Daryl E. Wilcox, Esq.
Florida Bar No. 838845
5201 S.W. 18th Street
Plantation, Florida 33317
Tel: (954) 303-1457
darylewilcox06@gmail.com

Attorneys for Carolyn Denise Wade and
Tracy D. Wade

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