Unopposed Motion for Continuance of Sentencing Hearing — United States v. Tracy D. Wade (Dkt. 231, S.D. Fla. No. 0:23-cr-60173)

Summary

This is an unopposed motion for continuance of the sentencing hearing in the Southern District of Florida criminal case against Tracy and Carolyn Wade (Doc. 231). It states that sentencing is scheduled for January 23, 2025, and that counsel was recently retained for sentencing purposes only and needs time to review the PSI as well as the other evidence. It states that counsel is unavailable March 20-28, 2025, that the Government has been consulted and has no objections, and that counsel requests a 30-day continuance. The motion shows /s/ Larry R. Handfield, Esq.

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U.S. District Court 
Southern District of Florida   
CRIMINAL DOCKET FOR CASE#: 1:23-CR-60173 
THE UNITED STATES,                                                   
 
 
Plaintiff,                                                           
vs. 
 
 
 
 
 
 
         
TRACY and CAROLYN WADE  
 
Defendant. 
________________________/ 
 
UNOPPOSED MOTION FOR CONTINUANCE OF SENTENCING HEARING 
 
COMES NOW the Defendant TRACY and CAROLYN WADE by and through her undersigned 
counsel hereby file Defendant’s Motion for Continuance and states as follows: 
1. The above-styled case is scheduled for a Sentencing Hearing on January 23, 2025.   
2. Counsel for the defendant has been recently retained for sentencing purposes only and 
counsel needs time to review the PSI as well as the other evidence in the case for purposes of 
the sentencing hearing. 
3. Counsel for the defendant is unavailable March 20-28, 2025 
4. The Government has been consulted and has no objections. 
5. Undersigned Counsel is requesting a 30-day continuance 
6. This motion is hereby filed in good faith. 
WHEREFORE, the defendant, TRACY and CAROLYN WADE, respectfully moves this 
Honorable Court to grant her motion. 
 
 
 
 
 
electronically with the Clerk of Court via CM/ECF. I also certify the attached notice was 
served electronically this day on all counsel of record via Notice of Electronic Filing generated by 
CM/DCF.
/S/Larry R. Handfield, Esq. 
By: /s/Larry R. Handfield, Esq. 
Florida Bar No: 330590 
LARRY R. HANDFIELD, ESQ.,  
4770 Biscayne Boulevard Ste. 1250 
Miami, Florida 33137 
Tel: (305) 576-1011 
Fax: (305) 576-2304 
 
 
 
 
 
 
 
Case 0:23-cr-60173-KMW   Document 231   Entered on FLSD Docket 01/21/2025   Page 1 of 3

 
 
 
                                                          CERTIFICATE OF SERVICE 
I, HEREBY CERTIFY that a true and correct copy of the foregoing was served by CM/ECF 
to: USA David Snider, U.S. Attorney’s Office, 500 E. Broward Blvd., Suite 7th floor Fort 
Lauderdale, FL 33394on this 21st  day of January 2025. 
 
 
 
 
 
Respectfully submitted, 
 
 /Larry R. Handfield, Esq./__ 
LARRY R. HANDFIELD, ESQ. 
Florida Bar No.  330590 
4770 Biscayne Boulevard 
Suite 1250 
Miami, Florida 33137 
(305) 576-1011 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
U.S. District Court 
Southern District of Florida   
CRIMINAL DOCKET FOR CASE#: 1:23-CR-60173-KMW-1 
Case 0:23-cr-60173-KMW   Document 231   Entered on FLSD Docket 01/21/2025   Page 2 of 3

 
 
THE UNITED STATES,                                                   
 
 
Plaintiff,                                                           
vs. 
 
 
 
 
 
 
         
TRACY and CAROLYN WADE,  
 
Defendant. 
________________________/ 
 
ORDER ON UNOPPOSED MOTION FOR CONTINUANCE OF SENTENCING 
HEARING 
 
THIS CAUSE having come on to be heard upon Defendant's Motion to Continue the 
Sentencing Hearing, and the Court having heard argument of counsel or being otherwise fully 
advised in the premises, it is hereby: 
ORDERED AND ADJUDGED that: 
1. Defendant’s Motion for Continuance is hereby, _________________. 
2. The Sentencing Hearing in the above-styled case is re-scheduled for _____, day of 
________________ 2025 at __________ a.m. /p.m. 
DONE AND ORDERED in Open Court in Dade County, Florida on this ______ day of 
January 2025.  
 
 
 
_____________________________ 
Judge Kathleen M. Williams 
United States District Court Judge 
Southern District of Florida  
 
cc: 
Larry R. Handfield, Esq. 
            David Snider, AUSA 
Case 0:23-cr-60173-KMW   Document 231   Entered on FLSD Docket 01/21/2025   Page 3 of 3

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