Court filing — United States v. Tracy D. Wade (Doc. 148)

Record facts

U.S. District Court for the Southern District of Florida · No. 0:23-cr-60173-KMW · Doc. 148 · 2024-09-05 · Docket on CourtListener

Full text

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. 
________________________________________/ 
 
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. 
Economic Injury Disaster 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 and tax records. 
8.  
AT&T 
Internet service provider records. 
9.  
Verizon 
Cell phone account records. 
10.  
Google 
Account subscriber records. 
11.  
Broward Sheriff’s Office (BSO) 
BSO policy and human resource records. 
12.  
DocuSign 
Electronic signature records. 
13.  
Leader Bank 
Paycheck Protection Program loan records. 
14.  
Persona 
Identity verification records. 
15.  
SmartBiz 
Paycheck Protection Program loan records. 
 
Case 0:23-cr-60173-KMW   Document 148   Entered on FLSD Docket 09/05/2024   Page 1 of 2

2 
 
Copies of these records were provided to Defendants’ counsel of record in discovery prior 
to this filing.1  The United States reserves its right to supplement this Notice to Defendants 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 
 
 
 
 
 
1 The government is awaiting receipt of the certified copies of the IRS records produced in discovery on July 25, 2024 
pertaining to Defendant Tracy Wade (Bates numbers 23-60173-CR_006249 through 23-60173-CR_006361).     
Case 0:23-cr-60173-KMW   Document 148   Entered on FLSD Docket 09/05/2024   Page 2 of 2

File and source

File

gov.uscourts.flsd.670191.148.0.pdf

Size

132,359 bytes

SHA-256

f4b27bae5b87bec40361c77aa1e06a04f02b803877c6adca5313349392ff5a95

Our copy

gov.uscourts.flsd.670191.148.0.pdf

Original

PACER (login required)