Court filing
Court filing — United States v. Tracy D. Wade (Doc. 161)
Filed September 25, 2024 in United States v. Tracy D. Wade; one of 133 filings from this case.
Record facts
| Court | U.S. District Court for the Southern District of Florida |
|---|---|
| Filed | 2024-09-25 |
U.S. District Court for the Southern District of Florida · No. 0:23-cr-60173-KMW · Doc. 161 · 2024-09-25 · 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’ 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 161 Entered on FLSD Docket 09/25/2024 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 161 Entered on FLSD Docket 09/25/2024 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 161 Entered on FLSD Docket 09/25/2024 Page 3 of 4
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10.
The Defendants are charged with conspiring to obtain Paycheck Protection
Program loans based on false and fraudulent information, obtaining Paycheck Protection Program
loans based on false and fraudulent information, and conspiring to make false statements to the
SBA, and making false statements to the SBA, in connection with Paycheck Protection Program
loans. 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 161 Entered on FLSD Docket 09/25/2024 Page 4 of 4File and source
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