Brief — United States v. Tracy D. Wade (Dkt. 108-1, S.D. Fla. No. 0:23-cr-60173)

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U.S. District Court for the Southern District of Florida · No. 0:23-cr-60173-KMW · Doc. 108-1 · 2024-07-24 · Docket on CourtListener

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 23-CR-60173 WILLIAMS (GRAHAM) 
UNITED STATES OF AMERICA, 
Miami, Florida 
Plaintiff,
May 17, 2024
vs.
 
TESTIMONY OF TRACY WADE 
CAROLYN D. WADE,
 
Defendant. 
Pages 1 to 131
____________________________________________________________
TRANSCRIPT (EXCERPT) OF TRIAL
HELD BEFORE THE HONORABLE DONALD L. GRAHAM
UNITED STATES DISTRICT JUDGE
LANCE W. STEINBEISSER, FCRR, RPR, FPR-C
Official Court Reporter
United States District Court
400 North Miami Avenue 
Miami, Florida 33128
305.523.5633
Proceedings recorded by mechanical stenography; transcript 
produced by computer-aided transcription. 
Case 0:23-cr-60173-KMW   Document 108-1   Entered on FLSD Docket 07/24/2024   Page 1 of 11

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Q.
Okay.  And was that the total for both loans or was -- 
what did that represent, that -- 
A.
That was only the first one.  I'm not -- I'm not familiar 
or remember what the total amount was. 
Q.
Okay.  And this was back in 2021? 
A.
Yes. 
Q.
Okay.  Now, your wife, did she have other employment? 
A.
Yes. 
Q.
Can you please tell the jury about that employment? 
A.
My wife owns 1 Step A-Head Hair Salon. 
Q.
Okay.  And how long has she run that business? 
A.
That business has been incorporated, if I'm correct -- I 
think she did it in 2015, if I'm correct. 
Q.
All right.  Does your wife hold any other licenses? 
A.
She's a licensed cosmetologist. 
Q.
Do you know for how long? 
A.
Before I met her. 
Q.
Okay.  And you met her -- I know you married, you said, 
around 2015? 
A.
Altogether, we've been together, I think -- you're trying 
to get me in trouble -- about 15 years. 
Q.
Okay.  So did there come a time when you actually 
approached Mrs. Wade about a PPP loan? 
A.
Yes. 
Q.
Prior to your having approached her, had she approached 
Case 0:23-cr-60173-KMW   Document 108-1   Entered on FLSD Docket 07/24/2024   Page 2 of 11

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you about her -- any interest in her applying for a loan? 
A.
She never heard of it before. 
Q.
And tell us what you told her.  
A.
I said, "Do you want to see if you qualify to get" -- and 
I explained it to her.  I said, "It was a PPP."  She said, 
"What is that?"  And I explained it to her.  And because of 
who I said was handling it and she know I trust him to handle 
things for me as far as the funeral business goes, she was 
like, "Okay."  She said, "But I don't think nothing is going 
to come of it because I don't really make that kind of money 
for them to give me anything."  
Q.
Okay.  And did there come a time when you represented to 
Mrs. Wade what, if any, documents she was going to need? 
A.
The same documents I gave. 
Q.
Now, did you just tell her that or did someone -- did 
someone mention it to you that she was going to need these 
documents also? 
A.
Yes.  Eduardo relayed to me, just the same as he did when 
I did it, "Hey, I need this document -- you already know the 
documents we need.  Get this, this, this, and that."
Q.
Tell us specifically what documents were asked for and 
what documents were given.  
A.
Her driver's license, her Social Security card, bank 
statements, and a voided check.  
Q.
Do you know if any requests were made for login 
Case 0:23-cr-60173-KMW   Document 108-1   Entered on FLSD Docket 07/24/2024   Page 3 of 11

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information? 
A.
Yes.  That was through me. 
Q.
Okay.  And tell the members of the jury what login 
information you told your wife was going to be needed.  
A.
Access to the Womply -- if I'm saying it correct -- the 
Womply entry -- wherever they do the applications at -- the 
same requests.  
She didn't ask initially because I told her I would 
handle everything for my wife because I thought I was familiar 
with it because they did the same thing for me.  But 
initially -- well, down the road she ended up getting her -- 
access to her Gmail account and -- 
Q.
Let me be clear on that.  She ended up giving access to 
her Gmail -- 
A.
I gave it to her.  I asked my wife because they kept 
calling me -- 
Q.
Yes.  They who? 
A.
Haydee Rivero and Eduardo Rivero.  And -- because they 
were, like, "You can trust me.  You can trust me.  You know, 
we're boys.  I'm not going to do nothing to you guys."  So we 
gave it to them. 
Q.
Okay.  And so you gave them access -- she gave them access 
to her Gmail account? 
A.
Yes. 
Q.
Okay.  What about DocuSign?  Did they give her access to 
Case 0:23-cr-60173-KMW   Document 108-1   Entered on FLSD Docket 07/24/2024   Page 4 of 11

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that? 
A.
They had access to everything. 
Q.
And they had requested that --
A.
Yes. 
Q.
-- as they had done with you? 
A.
Yes.  The very exact same thing they did with me. 
Q.
Now, were there times when follow-up information was 
requested by -- I'm sorry -- by either Haydee or Eduardo? 
A.
Once they got the initial information that they requested, 
no, not then. 
Q.
Now, who, if anyone, between you and your wife, was in 
touch with the Granados about Ms. Wade's application process? 
A.
Myself. 
Q.
And why was that? 
A.
Because she was employed.  So her hours were, I think, 
8:00 to 4:00, and she couldn't have her phone.  So it was 
impossible for them to have constant communication with her. 
Q.
Okay.  And phones are not allowed in the jail? 
A.
In the jail or the courtrooms. 
Q.
Okay.  And let's say if an individual who worked in the 
jail or the courtroom -- you worked for the sheriff's office; 
right? 
A.
Yes, sir. 
Q.
How many years? 
A.
25. 
Case 0:23-cr-60173-KMW   Document 108-1   Entered on FLSD Docket 07/24/2024   Page 5 of 11

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Q.
Okay.  And were those proceeds deposited into any 
accounts? 
A.
Yes. 
Q.
Okay.  Was it a joint account? 
A.
It was a joint account at USAA. 
Q.
In terms of work that was done to process this loan, were 
you more active -- who would you say was most active on this 
account, you or your wife? 
A.
I was. 
Q.
Tell us why.  
A.
She had -- she really didn't have a clue.  She just 
went -- gathered the information that I required to get from 
her what they requested, which was Eduardo and Haydee.  
Certain things that she had to do was -- like, the photo, I 
couldn't take the photo.  But once she did that, she really 
had no interaction in getting it done.  She was actually 
surprised when -- when the funding came through. 
Q.
Okay.  And did she ever reach out, to your knowledge, to 
Eduardo --
A.
Not at all. 
Q.
-- regarding this loan, especially? 
A.
No. 
MR. MCCRAY:  I beg the Court's indulgence.  
Judge, at this time I have no further questions. 
THE COURT:  Cross-examination. 
Case 0:23-cr-60173-KMW   Document 108-1   Entered on FLSD Docket 07/24/2024   Page 6 of 11

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Q.
Okay.  On May 13th -- I'm going to go back to slide four 
in Government Exhibit 1000.  
After that event happened on May 4th, the next thing 
that happens is an email is sent to ckidd1226@gmail.com.  
That's your wife's email; correct? 
A.
Yes. 
Q.
And it's an email from Womply reminding your wife, hey, 
the application's pending.  Let's get it moving.  Do you agree 
with that?  Do you remember that? 
A.
No, I don't remember it. 
Q.
But this is going to your wife's email; correct? 
A.
Where is that -- yes, I see it there. 
Q.
Okay.  And then that triggers various login attempts to 
the Paycheck Protection Program application, and we see here 
that on May 13th -- and we're now looking at slide six -- you 
are now accessing Wade Funeral Home; correct?  Excuse me.  
You're accessing the application from Wade Funeral Home.  
Forgive my question.  
A.
Yes. 
Q.
All right.  And, again, you're doing it from your 
Windows 10 desktop; correct? 
A.
I can't confirm if it's Windows 10 or not. 
Q.
But you're doing it from a computer at Wade Funeral Home?  
Yes? 
A.
Yes. 
Case 0:23-cr-60173-KMW   Document 108-1   Entered on FLSD Docket 07/24/2024   Page 7 of 11

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Q.
All right.  Then later that same day -- in fact, your 
access is at 82317 -- right? -- and 92117?  Yes?  Do you 
disagree? 
A.
Yes. 
Q.
Yes, you disagree or yes, you agree? 
A.
Yes, I see it on the document. 
Q.
Okay.  And I want to point something else out here.  Much 
has been said about an IP address 125.  I'm looking now, for 
the record, at slide five.  
And do you see that in the third row, IP address 125? 
A.
Yes. 
Q.
But below that, you see the IP address ending in .166.  
And it's again from a Windows computer.  If I can just scroll 
up, I'm going to show you .166. 
Do you disagree that the IP address ending in .166, 
according to slide three, is Internet service coming from Wade 
Funeral Home? 
A.
Yes. 
Q.
You agree with that? 
A.
Yes. 
Q.
Okay.  So going back to May 13th, we see at 8:23 AM on 
May 13th you logging in from .166.  Then at 8:34 we see one 
login from IP address 125.  Then at 9:21, back to you, .166.  
With me so far?  
A.
Yes. 
Case 0:23-cr-60173-KMW   Document 108-1   Entered on FLSD Docket 07/24/2024   Page 8 of 11

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A.
As DocuSign is, I was advised that it was a document ready 
to sign by a phone call.  I went in there and I click, click, 
click, click, click, because it goes to the next, to the next, 
to the next.  I didn't look at anything on it.  I didn't 
review it.  I didn't feel it was a need to review because all 
the information that we gave them was accurate. 
Q.
Well, first of all, I want to point something out here.  
What does it say there is the legal business name? 
A.
Carolyn Wade. 
Q.
Well, that's not the legal business name, is it? 
A.
No, it's not. 
Q.
But you're the one that initiated the application back on 
May 4, 2021, at Wade Funeral Home? 
A.
But the only time I saw this was the night before she was 
taken into custody.  That was my first time laying eyes on her 
name being a business. 
Q.
And then with regard to the claimed gross income, it's 
your -- by the way, you didn't see that number of gross 
income, $113,560? 
A.
No, sir, not until the night before. 
Q.
And you know that your wife's business 1 Step A-Head did 
not gross $113,560? 
A.
As soon as I saw it the night before, I immediately called 
Haydee Granados and asked her why did she input that number 
without authorization, and she said she was advised to put it 
Case 0:23-cr-60173-KMW   Document 108-1   Entered on FLSD Docket 07/24/2024   Page 9 of 11

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Q.
Do you know what this is on the last photo that I'm 
pointing at? 
A.
That should have been a Social Security card. 
Q.
What did you do with that? 
A.
I sent it to Haydee Granados. 
Q.
Now, did you ever send Haydee Granados any checks for 
Carolyn Wade, sole proprietorship? 
A.
No, not at all.  
MR. MCCRAY:  Judge, essentially we, being both 
parties, we have an unwritten agreement that these two 
documents -- 
THE COURT:  A stipulation?  
MR. MCCRAY:  It's not reduced to writing, Judge. 
THE COURT:  No, but you have a stipulation?  
MR. MCCRAY:  Yes.  I'm sorry.  We do. 
THE COURT:  Do you want to publish it orally?  
MR. MCCRAY:  Yes. 
THE COURT:  Any objection?  
MR. ZACCA:  Judge, with regard to Defense Exhibit 2, 
we do.  We have an objection. 
MR. SNIDER:  No, no.  We've agreed to this. 
MR. ZACCA:  Forgive me, Judge.  I didn't know -- 
that's fine, Judge. 
THE COURT:  Since it's not in writing, just confer 
and make sure that which you're going to publish.  Is that 
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what you agreed to?  
MR. MCCRAY:  We have.  They are Exhibits 1 and 2.  
Exhibit 1, Judge, is the Broward County Sheriff's Office 
staffing management document showing the dates that an 
individual worked, the number of hours, and basically the 
number of hours that an individual was supposed to work -- 
MR. ZACCA:  Objection.  Objection. 
THE COURT:  One moment.  See, here -- I thought we 
had an agreed upon -- all right.  So here's what we're going 
to do because we're not going to finish today, obviously.  So 
whatever it is you all agree to, reduce it to writing and you 
can publish it on Monday morning. 
MR. MCCRAY:  That's fine, Judge. 
BY MR. MCCRAY:
Q.
The documents, Mr. Wade, that you sent to Ms. Granados -- 
to her or through her husband to her, did you ever send her a 
Schedule C? 
A.
No, I did not. 
Q.
Did you ever see a Schedule C for Carolyn Wade that had on 
it $113,000 income? 
A.
No, I did not. 
Q.
Now, on cross you talked about the Broward Sheriff's 
Office reporting policy.  Did you report every year? 
A.
No.  I worked 25 years there and I think the prosecution 
only showed me about four. 
Case 0:23-cr-60173-KMW   Document 108-1   Entered on FLSD Docket 07/24/2024   Page 11 of
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