Motion — United States v. Tracy D. Wade (Dkt. 288, S.D. Fla. No. 0:23-cr-60173)

Record facts

U.S. District Court for the Southern District of Florida · No. 0:23-cr-60173-KMW · Doc. 288 · 2025-08-01 · Docket on CourtListener

Full text

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
UNITED STATES OF AMERICA 
 
 
Plaintiff 
 
 
 
 
 
CASE NO.: 23-CR-60173-2 
vs. 
 
TRACY D. WADE 
 
 
Defendant.  
 
___________________________/ 
 
 
RENEWED MOTION TO STAY JAIL SENTENCE PENDING APPEAL 
  
Introduction. 
Tracy D. Wade was found guilty at trial of multiple counts related to Paycheck 
Protection Program (PPP) loan fraud and sentenced to 90 days in jail followed by 
probation.  He was tried jointly with his wife Carolyn Wade, who was also convicted 
and was sentenced to probation.  He has not yet surrendered to begin serving the jail 
sentence and is scheduled to surrender on August 27, 2025.  The Court previously 
extended the surrender date so that Mr. Wade could have this appellate bond motion 
considered, which he very much appreciates.  He has filed an appeal which is 
pending in the Eleventh Circuit Court of Appeals, case 25-11132-D.  A briefing 
schedule was issued today and the Appellant’s brief on behalf of the Wades is due 
August 20, 2025 (a briefing schedule was previously issued but was rescinded 
because not all transcripts had been filed). 
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Undersigned counsel on behalf of Mr. Wade previously filed a Motion to Stay 
Jail Sentence Pending Appeal on April 9, 2025 (D.E. 247).  The Court denied the 
motion without prejudice to refile since it did not specify what appellate grounds 
would be raised and therefore that the appeal “is not for the purpose of delay and 
raises a substantial question of law or fact likely to result in” reversal, a new trial, or 
a reduced sentence.  18 U.S.C. § 3143.  Undersigned counsel had to order and read 
the trial and pretrial hearing transcripts in order to properly file that motion.  That 
has been accomplished, and this motion follows.  Undersigned counsel notes that the 
reason for the delay was that the court reporter did not promptly transcribe all 
hearings despite the transcripts having all been ordered initially, which required 
follow-up.  Now all transcripts have been provided.  The most recent one, of a 
lengthy pretrial motions hearing that occurred on September 26, 2024, was filed on 
July 11, 2025.  Again, Mr. Wade and undersigned counsel appreciate the Court using 
its discretion to allow him to remain out of custody to date so that this motion could 
be properly filed and considered. 
 
Background on Tracy Wade. 
  Tracy D. Wade is a 52-year old man.  He and his wife Carolyn have an 11-
year-old daughter.  The family resides together in South Florida.  Besides his 
immediate household of three, Mr. Wade had two adult children from a previous 
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marriage.  Mr. Wade is from and grew up in Miami, graduating from Carol City 
High School and Miami Dade College with an associates degree.  He is a veteran of 
the US Marine Corps.  He served the community as a Broward Sheriff’s Deputy, 
working in BSO’s detention facilities for 25 years, from 1997-2022.  After retiring 
from BSO, Mr. Wade became a police officer in Pembroke Park.  Given his law 
enforcement background, it is unsurprising that Mr. Wade has no criminal history 
whatsoever.  His only experience of a jail cell is working in the Broward jails as a 
detention deputy for a quarter-century. 
In addition to his law enforcement work, Mr. Wade has owned and operated 
a local small business, Wade Funeral Home located in Hallandale Beach, since 2011.  
This business provides his family’s income, particularly since his wife Carolyn is 
marginally employed as a waitress after her conviction in this case (Carolyn also 
worked as a detention deputy for BSO prior to her arrest and ultimate conviction in 
this case).  Mr. Wade also employs multiple community members as 1099 
employees/independent contractors at the funeral home.  Mr. Wade runs the funeral 
home that bears his name, and being unable to run it for 90 days would have a 
definite short-term negative effect on the business, and potentially cause the business 
to close altogether due to lack of revenue and the possible inability for the business 
to remain operational without Mr. Wade to run it. 
During the pendency of the case, since July 1, 2024, Mr. Wade has been out 
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of custody living in the community on bond/pretrial release and has had no issues 
whatsoever.  And, of course, prior to his arrest in this case he lived in this community 
his entire life, over 50 years, with no issues whatsoever.  After conviction and then 
after sentencing, he remained at liberty despite the Government’s arguments that he 
should be taken into custody, and has continued to comply with all terms and 
conditions of his release and show up for all court dates and other required 
appointments.  He hired counsel to represent him at sentencing and has hired 
undersigned counsel to represent him on appeal, demonstrating that he is dedicated 
to fighting his case through the proper channels and complying with all requirements 
of the court.  His family, including his 11-year-old daughter, his home, and his 
business are here.  Mr. Wade presents zero risk of flight from a 90-day jail sentence 
and no danger to the community. 
The Court has had ample opportunity to observe Tracy Wade extensively 
firsthand, as the court presided over his trial and sentencing, as well as a previous 
trial of his wife Carolyn where Mr. Wade was called as a witness.  He is certainly 
unhappy about his present situation and feels he and his wife have not been treated 
justly by the Government, and he stands up for what he believes to be right, but he 
is always appropriate in court, respectful to all parties, and has never disobeyed a 
court order.  His behavior and general demeanor inside and outside of court is that 
of the law enforcement officer he has been for his entire adult life. 
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Legal Argument. 
18 U.S.C. § 3143(b)(1) provides that a judge shall detain a person who has 
been convicted and sentenced to imprisonment and has filed an appeal, unless the 
judge finds: 
(A) by clear and convincing evidence that the person is not 
likely to flee or pose a danger to the safety of any other 
person or the community if released under section 3142(b) 
or (c) of this title; and (B) that the appeal is not for the 
purpose of delay and raises a substantial question of law 
or fact likely to result in—(i) reversal, (ii) an order for a 
new trial, (iii) a sentence that does not include a term of 
imprisonment, or (iv) a reduced sentence to a term of 
imprisonment less than the total of the time already served 
plus the expected duration of the appeal process. 
 
If these findings are made, then the Court “shall order the release of the 
person” pending disposition of the appeal.  The flight/danger determination of § 
3143(b)(1)(A) is easy.  As detailed above, Mr. Wade presents no risk of flight and 
no danger to the community.  He has established himself as a productive member of 
this community over his entire life, has no priors, and has worked in law enforcement 
throughout his adult life.  The validity of the issues to be raised on appeal pursuant 
to § 3143(b)(1)(B) requires further analysis.  Undersigned counsel is an appellate 
law specialist and is representing Mr. Wade on the appeal, which is pending in the 
Eleventh Circuit.  The Appellant’s Brief is due in 19 days.  It would be reasonable 
to assume we would have an appellate decision from the Eleventh Circuit within six 
months.  If that appellate decision is an affirmance, Mr. Wade will have to serve his 
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90-day jail sentence.  He simply asks that the Court allow him to remain at liberty 
in the community until the Eleventh Circuit has the opportunity to weigh in.  
Otherwise, he will certainly have to serve the entire jail sentence even if the 
conviction is ultimately overturned, since he is scheduled to surrender August 27th 
and even if he served all 90 days would be released no later than November 25, 2025.  
The appeal will not be resolved through a decision by then. 
The defense does not claim that the jail sentence imposed is unreasonable or 
illegal in any way, and there will be no issue as to the sentence itself raised on appeal, 
meaning that the appeal will not result in a reduction of the jail sentence 
independently of the conviction.  Therefore, the defense proceeds pursuant to 18 
U.S.C. § 3143(b)(1)(B)(i-ii), related to the potential for reversal or an order for a 
new trial on appeal, not subsections iii and iv which related to an appellate order of 
a reduced sentence. 
The appeal is clearly not taken for the purpose of delay.  This is a direct appeal, 
taken by right, of Mr. Wade’s first ever felony conviction.  Mr. Wade always 
maintained his innocence, and in fact as the Court is aware he was charged because 
he also asserted his wife’s innocence and testified at her first trial, which resulted in 
a hung jury.  He is not seeking to delay anything, he is seeking to reverse what he 
views as an injustice, a conviction for a crime he has always maintained he did not 
commit. 
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The appeal also raises substantial questions of law or fact likely to result in 
reversal or a new trial.  Specifically, although additional issues may be raised in the 
Eleventh Circuit after further work and review by counsel, undersigned counsel 
intends to raise at least the following appellate issues1 in the Eleventh Circuit: 
 
1.  Error in Permitting the Government to Introduce Evidence of Other 
Uncharged Loans And Then Argue to the Jury That Mr. Wade Was Guilty Due to 
Those Other Uncharged Loans. 
 
 The charged loan was a PPP loan for $20,833.  There was no dispute that an 
application was submitted in Mr. Wade’s name for this loan and it was disbursed.  
There was also no dispute that another person, Haydee Granados, was the one who 
initiated this loan application and created and uploaded a fake Schedule C document 
to make it seem like Mr. Wade qualified for this loan when he did not.  The 
government introduced evidence that Mr. Wade had logged into the online account 
of the loan provider and electronically signed documents, which he acknowledged 
when he testified but clarified that he did not place any of the fraudulent information 
in the loan documents, nor did he see it, and relied entirely on Ms. Granados, who 
 
1 What follows is a summary of the issues to be raised, not an appellate brief.  
Undersigned counsel expects to flesh out these arguments in the actual appeal, but 
writes now to advise the Court as to the issues to be raised and that they are 
substantial, non-frivolous, and reasonably likely to succeed, as 18 U.S.C. § 3143 
requires in order for this Court to stay the jail sentence. 
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told him she had experience procuring PPP loans and could get him one without 
telling him that he in fact did not qualify or that qualifying would involve falsifying 
documents.  Mr. Wade said he simply logged in and signed the documents 
electronically, without actually downloading or viewing them as he had given Ms. 
Granados the correct information and trusted that she had therefore used the correct 
information in the loan application. (10/21/24 pp. 42-45, 118-122).  Thus, Mr. 
Wade’s intent, knowledge, and credibility were central issues for the jury.  If he were 
telling the truth he was not guilty, if he was lying and in fact knew he was submitting 
false loan information to the government, he was guilty. 
The Government’s case was fundamentally about one relatively small loan 
applied for and issued at a time when the PPP program was brand new and nobody 
had any significant experience in it, the country was shut down over Covid pandemic 
and the government policy was to get money into the hands of (eligible) Americans 
as soon as possible to prevent a recession or worse, and where there was no doubt 
that the primary false document (the Schedule C) was created and uploaded by a 
cooperating government witness rather than Mr. Wade.  The Government was no 
doubt also cognizant that the same basic case had recently resulted in a hung jury as 
to Carolyn Wade.  Thus, to bolster their case, the Government aggressively sought 
to introduce evidence of other loans Mr. Wade had applied for which they viewed 
as incriminatory and evidence that he had intentionally defrauded the Government 
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with this charged PPP loan.  Specifically, the Government filed a Notice of Intention 
to Introduce Evidence of Other Crimes, Wrongs, Or Acts, Pursuant to Fed. R. Evid. 
404(b)(2), seeking to introduce evidence that Mr. Wade had applied for two 
Economic Injury Disaster Loan (EIDL) loans for his business, Wade Funeral Home, 
which grossly overstated both the revenue and expenses of the business by a factor 
of 100 (the actual revenue was about $350,000 per a 2019 tax return, whereas the 
revenue for the past 12 months stated on the application was $465,000,000). (D.E. 
135).  One of the EIDL loans was issued after the Government realized the 
revenue/expense information in the application was wrong and directed Mr. Wade 
to provide accurate information via his tax return, which he did.  The actual EIDL 
amount disbursed was accurately tied to the real financials of the business and was 
not alleged to have been improper in any way, and did not result in charges.  The 
second EIDL loan application, which also had incorrect financial information in the 
hundreds of millions, was denied as duplicative of the first one.  The government 
claimed these prior applications, even though not criminal, showed that it was not 
an accident when false information was submitted in Mr. Wade’s name as to the 
charged loan.  The charged PPP loan for the $20,833 was to Mr. Wade personally 
per the application, although he said he intended it to be for the funeral home and 
did not know Ms. Granados had applied for it using the business name as his name 
rather than that of the funeral home. 
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The Court addressed the Government’s 404(b) motion at a pretrial calendar 
call on 10/1/24, and stated after argument from the parties that it would wait to hear 
the evidence in the Government’s case in chief before deciding if this evidence 
regarding uncharged loans would be admissible (10/1/24 p. 22).   
After the jury was picked but before testimony, the parties discussed admitting 
exhibits and the government brought up documents for a $700,000 PPP loan for 
Wade Funeral Home that was not issued. (10/7/24 p. 113).  The government 
acknowledged this loan was not alleged in the indictment, and said it was referenced 
in the 404(b) motion but not as 404(b) evidence, rather as charged conduct (despite 
not being charged in the indictment). (10/7/24 p. 114).  The government was 
referencing D.E. 135 pp. 3-4, where in the “offenses charged in the superseding 
indictment” section of the 404(b) motion the Government discussed allegedly false 
statements in the “Wade Funeral Home PPP Application”, which, again, was not 
actually charged in the superseding indictment.  The Court quickly (and in the 
defense view correctly) disposed of this issue, stating “I would think this is the 
404(b), and it’s not referenced in the indictment.  And so for those reasons, at this 
time, I am sustaining the objections” to the $700,000 Wade Funeral Home PPP 
application. (10/7/24 p. 117).  The Government tried to get the Court to change its 
mind later that day, and the Court maintained its ruling—the $700,000 Wade Funeral 
Home PPP loan was not charged in the indictment so it was not substantive evidence, 
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and the Court would address 404(b) evidence after hearing the Government case in 
chief. (10/7/24 pp. 165-66). 
When government cooperating witness Haydee Granados, the person who 
admitted to initiating these loan applications and falsifying and submitting the 
Schedule Cs, testified, on cross examination the defense asked her about and 
introduced Defense Exhibit 8, which was an email from a Wade Funeral Home 
account to Ms. Granados with Tracy Wade’s driver’s license and social security 
card, as well as a voided check from Wade Funeral Home, attached. (10/15/24 pp. 
155-57).  Ms. Granados said this email was not for the PPP loan application she did 
but for a business loan Mr. Wade was applying for with someone else. (10/15/24 p. 
157).  The Government began their redirect of Ms. Granados by asking her about 
Defense Exhibit 8, and she again said it was “for a business loan Tracy Wade was 
applying for”. (10/16/24 p. 40).  The defense objected that this was getting into 
uncharged crimes and the parties went sidebar.  The Court said now the check was 
in evidence so the prosecutor could ask about it. (T. 10/16/24 pp. 41-42).  The 
Government said they wanted to ask Ms. Granados about whether she was aware of 
the separate PPP loan application for Wade Funeral Home (the loan referenced as 
the $700,000 PPP loan) which Ms. Granados did not process, and admit it through 
her. (T. 10/16/24 p. 42-46).  The Court said it would allow the Government to ask 
Ms. Granados what she knew about why the email in Defense Exhibit 8 was sent, 
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but not information about the actual application if she didn’t have personal 
knowledge of that. (10/16/24 pp. 45-46).  A proffer was held outside the presence of 
the jury where Ms. Granados said she received the check and forwarded it to her 
husband’s accountant, Odalys Concepcion (who did not testify) at her husband’s 
direction. (10/16/24 p. 47).  Ms. Granados testified in the proffer this was because 
Ms. Concepcion was going to apply for a business loan for Mr. Wade, but the Court 
correctly recognized that information was hearsay. (10/16/24 p. 49).  The 
government (still during the proffer) introduced for identification Government 
Exhibit 2002, which was an email from Ms. Concepcion to Ms. Granados with a 
“Loan Overview” from “Smartbiz” with no name or other identifying information 
on the document (there is an application number which was never linked to anything) 
that says a loan application for $701,873 has been completed.  When the Court asked 
Ms. Granados how she knew what this was she said she was told by her husband, 
and the Court told the prosecutor that was why its alleged significance was hearsay 
and inadmissible. (10/16/24 p. 51).  The Government later pointed out that the 
subject line in the email Ms. Concepcion sent Ms. Granados with the loan 
application was “wade funeral home”. (10/16/24 p. 53).  The Court said it would 
admit the email document but the parties would have to argue about its significance 
at closing. (10/16/24 p. 55).  The defense objected to the admission of the amount of 
the loan in the email, but the Court said the defense had opened the door. (10/16/24 
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p. 57).  Ms. Granados testified before the jury that she received this email from 
Odalys Concepcion, her husband’s accountant, that the subject line was “Wade 
Funeral Home”, and that it stated an estimated loan amount of $701,873. (10/16/24 
pp. 63-64).  Ms. Granados testified she did not do a PPP loan for the Wade Funeral 
Home business and did not know how to do business PPP loans. (10/16/24 pp. 65-
66). 
After Ms. Granados testified the Government again renewed its request to 
bring in evidence of the other allegedly fraudulent loans they believed Mr. Wade 
was involved in.  They wanted to introduce the application for the $700,000 Wade 
Funeral Home PPP loan. (10/16/24 p. 74).  The Court asked how that was relevant 
to this case and what was the evidence this application was false. (10/16/24 p. 74).  
The Government could not satisfactorily answer that question as they clearly did not 
have any evidence to support their position that they could show this loan 
application, for a loan which was not disbursed, was knowingly falsely submitted by 
Mr. Wade, and the Court excluded the evidence as irrelevant. (10/16/24 p. 76).  The 
Government said they reserved the right to use it in cross-examination if Mr. Wade 
testified, and the Court said that was a different issue. (10/16/24 p. 76).   
The Government ultimately rested without introducing any 404(b) evidence 
(other than Exhibit 2002 which referenced a $700,000 loan application without any 
details).  The defense called a couple witnesses who essentially said they were also 
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defrauded by Haydee Granados and she uploaded false documents to their PPP loan 
applications without their knowledge, which is what the Wades alleged Ms. 
Granados also did for them.  The defense then called Tracy Wade, who testified that 
he did not know the false loan documentation had been submitted by Ms. Granados 
and he trusted her and her husband, who he knew very well, to handle this properly.   
On cross-examination the prosecutor asked Mr. Wade if the charged PPP 
application was submitted for Wade Funeral Home and he said it wasn’t but should 
have been. (10/22/24 p. 33).  The prosecutor then asked if Mr. Wade had applied for 
a separate PPP loan for Wade Funeral Home and the defense objected and the parties 
went sidebar as this was getting into the heretofore excluded 404(b) evidence. 
(10/22/24 pp. 33-34).  The Court asked the defense why the government couldn’t 
ask if Mr. Wade had had other loans and the defense said it was not relevant. 
(10/22/24 p. 36).  The Court said this was different from the prior ruling excluding 
404(b) because “now he’s asking him about his knowledge of other PPP loans since 
the subject of the examination is PPP loans”. (10/22/24 p. 37). The Court analogized 
to a defendant’s prior convictions, which are not admissible in the Government case 
in chief but are admissible if the defendant testifies. (10/22/24 p. 37).  The Court was 
not clear on what loan the Government was actually asking about, and the 
Government clarified it was the same loan referenced in the email from Ms. 
Concepcion that the Government was allowed to ask Ms. Granados about. (10/22/24 
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pp. 38-39).  The Court overruled the defense objection and the Government was 
allowed to ask about the $700,000 Wade Funeral Home PPP loan. (10/22/24 p. 39). 
When the Government asked Mr. Wade, he said he was not aware of any PPP 
loan for Wade Funeral Home. (10/22/24 pp. 39-40).  If such a loan application was 
submitted for Wade Funeral Home, he didn’t have anything to do with it. (10/22/24 
p. 40).  The prosecutor then asked Mr. Wade if the funeral home ever had $3 million 
in payroll, and the defense objected to relevance. (10/22/24 p. 41).  At sidebar the 
Court said first the prosecutor should ask if Mr. Wade was familiar with the 
document he was referring to with this number, but when the prosecutor resumed 
questioning instead of doing that he asked again about the actual number, “My 
question for you is did Wade Funeral Home ever have $3,368,909.56 in payroll?” 
(10/22/24 p. 41).  Of course the defense objected again, the Court again directed the 
prosecutor to ask the predicate question, and when the prosecutor did Mr. Wade said 
he had never seen the loan application being asked about before in his life. (10/22/24 
p. 42).  The prosecutor showed him other loan applications which he also testified 
he had never seen and was not familiar with. (10/22/24 p. 42).  The prosecutor asked 
if the funeral home had ever had a payroll of $3 million, the defense objected to 
relevancy, the Court overruled the objection, and Mr. Wade testified in response to 
the prosecutor’s questions that the funeral home never had a payroll of $3 million or 
45 employees. (10/22/24 p. 43).  The prosecutor was clearly referencing, in front of 
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the jury, the uncharged loan documents it had asked Mr. Wade about that he had just 
testified he had never seen. (10/22/24 p. 43).  The prosecutor asked Mr. Wade about 
the email from Ms. Concepcion to Ms. Granados, and he read it and that the subject 
Ms. Concepcion wrote was “Wade Funeral Home” and the amount was $701,873, 
but never said anything about his personal knowledge of that document and in fact 
when Mr. Wade asked to see the document again the prosecutor declined to show it 
to him and said “we’re moving on, sir”. (10/22/24 p. 44). 
Then the prosecutor tried to ask Mr. Wade about the EIDL loans, which were 
what the Court had already excluded.  The defense immediately objected and the 
parties went sidebar. (10/22/24 p. 45).  The Court did not recall what loans were 
being talked about (to be fair, there were a lot of different loans being talked about), 
the defense explained these were the loans that had already been discussed and 
excluded with the applications stating hundreds of millions in revenue and expenses 
which were corrected pre-disbursement and then funded correctly based on the 
actual revenue and expenses and not charged. (10/22/24 pp. 45-46).  The prosecutor 
claimed “I’m not going into this for 404(b).  This is impeachment.” (10/24/24 p. 47).  
The prosecutor did not explain what testimony he believed this would impeach, nor 
had Mr. Wade testified to anything about any other loans including the EIDL loans.  
The prosecutor claimed this was relevant because “The heart of this case is false 
statements to the SBA.  This is an application saying that Wade Funeral Home had 
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$465 million in gross revenue.” (10/22/24 p. 48).  The defense explained that the 
dollar amounts on the application were corrected before the loan was issued in the 
correct amount. (10/22/24 p. 49).  The prosecutor said the original loan application 
went to Mr. Wade’s credibility.  The Court said “Now I’m getting into another trial.  
That’s what troubles me . . . am I ever going to finish this case?” (10/22/24 pp. 49-
50).  The defense said this was also prejudicial and confused the issues under Rule 
403. (10/22/24 p. 51).  The Court said it would allow a few questions. (10/22/24 p. 
51). 
Back before the jury, the prosecutor asked and Mr. Wade acknowledged that 
he applied for a SBA loan in approximately 2020. (10/22/24 p. 52).  The prosecutor 
asked if he put that the revenues for the business were $465 million and Mr. Wade 
said he never made that amount and that was a typo. (10/22/24 pp. 54-55).  The 
prosecutor asked about the expenses saying $175 million and Mr. Wade said that 
was also a typo. (10/22/24 pp. 54-55).  The prosecutor asked about another SBA 
application for the same loan which listed $350 million in revenue and $250 million 
in expenses and Mr. Wade said those were also typos. (10/22/24 pp. 55-56).  Mr. 
Wade said he spoke with the SBA multiple times on recorded conversations about 
this loan, he provided accurate tax documents, and the loan was funded and was 
currently being repaid properly. (10/22/24 p. 56).  The prosecutor then asked about 
all five loans again (the two charged PPP loans for Mr. Wade and Ms. Wade, the 
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two SBA loan applications, and the PPP loan application for Wade Funeral Home 
that Mr. Wade said he had never seen) again. (10/22/24 p. 58).  The “few questions” 
the Court allowed turned into 38 questions about these uncharged loans spanning 
eight transcript pages. 
In closing the Government explicitly argued the Wade Funeral Home PPP 
loan application and the SBA loan applications as 404(b) evidence of guilt in this 
case, saying in part “that’s four typos, two on one application and two on another.  
Do you believe that, or is that someone who’s trying to get as much as he possibly 
can from the SBA during the Covid pandemic?  It’s evidence of intent.  It’s evidence 
of lack of [mistake].  This is someone who knew what he was doing.” (10/22/24 p. 
94).   
On appeal, Mr. Wade will argue that the Court erred by allowing the 
Government to introduce evidence of the substance of these uncharged loan 
applications, some via Haydee Granados in the Government case in chief and much 
more via Mr. Wade on cross-examination.  The admission of this evidence was 
contradictory to the (correct) earlier ruling that it was inadmissible, and it greatly 
prejudiced Mr. Wade, which was the entire reason the Government sought to admit 
it.  It is not entirely clear, at least to undersigned counsel, on what basis the Court 
ultimately admitted this evidence, since it never explicitly modified its ruling that it 
did not come in under Rule 404.  The government argued it was impeachment but 
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never identified any actual testimony of Mr. Wade it allegedly impeached (and there 
was none as Mr. Wade had never testified about any other loans).  In closing, the 
Government explicitly used this as 404(b) evidence, which was plainly their 
intention all along, arguing these other uncharged loan applications were evidence 
of intent and lack of mistake, which are rationales for admission of 404(b) evidence. 
The Court’s initial ruling that this evidence was not admissible under 404(b) 
was correct.  A court abuses its discretion when it admits evidence of a prior bad act 
that does not satisfy the following criteria: 1) the evidence must be relevant to an 
issue other than character; 2) the evidence must be accompanied by sufficient proof 
that a jury could find that the defendant committed the extrinsic act; and 3) the 
probative value of the evidence must not be substantially outweighed by its undue 
prejudice.  United States v. Whatley, 719 F.3d 1206, 1217 (11th Cir. 2013).  At least 
prongs 2 and 3 were not satisfied here. 
There was no evidence whatsoever introduced at any time sufficient to link 
Mr. Wade to the $700,000 Wade Funeral Home PPP application.  He denied having 
ever seen the application, the government’s own witness Haydee Rivero said in 
proffer that she heard from her husband that another person, Odalys Concepcion, 
prepared it.  Emails about it were sent between Ms. Rivero and Ms. Concepcion.  
The government presented no proof whatsoever that Mr. Wade had anything to do 
with this application.  As to the EIDL loans with the multimillion dollar amounts, 
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the government also provided no proof sufficient to demonstrate that Mr. Wade 
committed any bad act.  He also denied seeing these applications, and when asked 
about the numbers the prosecutor said were on the applications (which were not 
admitted, so all we have is the prosecutor’s allegations) he said they must have been 
typos and that he provided his real tax returns and the loan was funded properly.  
The government provided no evidence to the contrary.  There was no evidence 
whatsoever as to how any incorrect figures got on the loan documents, or that Mr. 
Wade, as opposed to someone preparing the documents on his behalf, placed them 
there.  The government certainly knew how to present such evidence—they did it in 
the charged crime, providing IP addresses and device type logins that matched Mr. 
Wade as well as Docusign information showing Mr. Wade viewed and signed the 
applications.  One could reasonably assume that if such evidence existed as to the 
uncharged loans, which were undoubtedly applied for on internet platforms that 
preserved this information about the users logging in to the accounts, the 
Government would have obtained and presented it.  Whatever the actual reason they 
didn’t do so, the fact is they did not.  Absent such evidence being presented as to the 
uncharged loans, the Government simply did not meet its burden to introduce 
extrinsic prior bad acts evidence.  The question is whether the jury could “reasonably 
find the . . . fact [at issue] by a preponderance of the evidence”.  Huddleston v. United 
States, 485 U.S. 681, 690 (1988).  Here there was no evidence, let alone a 
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preponderance, to show that Mr. Wade applied for, participated in, or knew about 
any false information in these uncharged loan applications.  See United States v. 
Lockhart, CR422-115, 2023 U.S. Dist. LEXIS 127132, 2023 WL 4707136 (S.D. Ga. 
July 24, 2023) (“in the Court’s view, there is not sufficient proof to enable a jury to 
find by a preponderance of the evidence that Defendant committed the acts in 
question” which were an auto theft where the victim’s credit cards were stolen and 
the defendant tried to use the credit cards, as “this evidentiary leap is a bridge too 
far for the Court to conclude a sufficient basis exists for the jury to find that 
Defendant was the actor”).  At most here the Government had some proof (via what 
prosecutors said was in unintroduced loan applications, which they also did not seek 
to admit conditionally to allow appellate review of this issue) that somebody applied 
for loans in Tracy Wade’s name with inaccurate information.  Coupled with the fact 
that it was undisputed that other people including the Government’s cooperating 
witness Haydee Rivero were applying for loans for Tracy Wade or his businesses at 
the relevant timeframe, and Ms. Rivero was manufacturing and uploading false 
financial documents to multiple loan applications including the Wades’, this is 
plainly insufficient to demonstrate that Mr. Wade inputted the incorrect information 
or knew about it, which is the fact that would need to be proved by a preponderance 
by evidence introduced by the Government prior to potential admissibility. 
To the extent there was any probative value to the uncharged loan evidence, 
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it was far outweighed by the prejudicial effect that this had on Mr. Wade’s ability to 
get a fair trial on the charged crimes.  The prosecutor, vested in the natural authority 
of the Government in a United States courtroom, was accusing Mr. Wade of having 
knowingly lied on other loan applications based on undisclosed-to-the-jury 
information the prosecutor claimed to be privy to.  These uncharged crimes were far 
more serious than the charged $20,833 loan, as purportedly Mr. Wade was trying to 
defraud the Government out of hundreds of thousands of dollars on multiple 
occasions.  Mr. Wade had no real opportunity to defend himself against these 
allegations, as he had already been advised by the Court this evidence was 
inadmissible. 
This sort of extrinsic evidence is akin to the Government introducing evidence 
of uncharged armed robberies when a defendant is on trial for shoplifting.  When the 
alleged uncharged crimes are much worse than the charged crime, the prejudice is 
that much more severe.  See United States v. Williams, 205 F.3d 23, 34 (2nd Cir 2000) 
(“we find no undue prejudice under Rule 403; the evidence did not involve conduct 
more serious than the charged crime and the district court gave a proper limiting 
instruction”).  The prejudice is also greater here because the jury only heard the 
Government’s version of events rather than being able to independently evaluate the 
evidence, particularly what link there was between the alleged prior crimes and Mr. 
Wade.  The jury naturally would assume that if the Government was permitted to 
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ask Mr. Wade about these other crimes, and purportedly read from papers 
documenting them, that there was actual evidence he applied for or knew about the 
prior loans—but as far as the record actually discloses, there was no such evidence.  
Prejudice is also apparent from the use the Government made of the prior loans—
arguing in closing that Mr. Wade was guilty of this crime as the uncharged loans 
showed he was “someone who’s trying to get as much as he possibly can from the 
SBA during the Covid pandemic” and “is someone who knew what he was doing.” 
(10/22/24 p. 94).  That was precisely the disputed issue at trial.  The Government 
should have had to prove Mr. Wade’s knowledge by evidence related to the charged 
crimes, not prejudicial innuendo about uncharged crimes. 
If instead the Court admitted the uncharged loan evidence as impeachment, 
which logically would make sense as the Court had mostly denied its admission 
during the government case in chief (other than the emails purportedly about the 
$700,000 Wade Funeral Home PPP loan it allowed the Government to introduce and 
discuss during Haydee Rivero’s testimony), and the Government had explicitly said 
it would therefore reserve the right to use it as impeachment, this was also error.  “A 
witness’s credibility may be impeached by a prior inconsistent statement so long as 
‘the statements are indeed inconsistent.’”.  United States v. Frye, 243 Fed. Appx. 
575, 576 (11th Cir. 2007) (quoting United States v. Hale, 422 U.S. 171 (1975). “In 
order to introduce a prior inconsistent statement, ‘the court must be persuaded that 
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the statements are indeed inconsistent’”.  United States v. Simpkins, 240 Fed. Appx. 
334, 342 (11th Cir. 2007) (quoting Hale at 176). 
Here Mr. Wade never testified about any prior or uncharged loans.  He never 
said “I never before submitted false documents to the Government” or “I never 
before applied for a business or personal loan from the Government” or anything 
along those lines.  Therefore there was no prior statement inconsistent with the 
uncharged loan applications which would allow the Government to use them for 
impeachment, nor did the Government identify any, although they did make an 
unsupported argument that they were seeking to use the uncharged crime evidence 
as impeachment.  (10/24/24 p. 47).  The Court mentioned that a defendant’s prior 
convictions are not normally admissible but become admissible if he testifies 
(10/22/24 p. 37), but that is not relevant to the issue as these were not prior 
convictions, they were uncharged prior alleged bad acts.  Prior convictions are 
governed by Federal Rule of Evidence 609, which permits their use to impeach 
witness.  There is no similar rule of blanket admission for prior uncharged crimes or 
bad acts.   
Sometimes specific acts of conduct may be admissible on cross-examination 
if probative of the truthfulness or untruthfulness of a witness.  Fed. R. Evid. 608(b).  
The defense does not believe the threshold was met to even ask about the uncharged 
loans, since the Government did not have evidence that Mr. Wade was involved with 
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or knew about those loans, as discussed above.  Furthermore, another district court 
in this Circuit has denied the admission of very similar evidence under 608(b).  In 
Jenifer v Fleming, Ingram, & Floyd P.C., CV 106-139, 2008 U.S. Dist. LEXIS 
17740 (S.D. Ga. Mar. 7, 2008), the Court wrote: 
The law is well settled that under Fed. R. Evid. 608(b), a 
witness may not be impeached on a collateral matter with 
extrinsic evidence. United States v. Calle, 822 F.2d 1016, 
1021 (11th Cir. 1987); United States v. Herzberg, 558 F.2d 
1219, 1223-24 (5th Cir. 1977). Moreover, prior wrongful 
acts that do not result in criminal convictions are ordinarily 
collateral matters. Herzberg, 558 F.2d at 1223. Here, 
assuming without deciding that there was some wrongful 
act performed in association with Plaintiff's tax returns, 
there has been no showing that there has been a criminal 
conviction regarding such acts. Therefore, evidence or 
testimony on the impropriety or alleged intentional 
fabrication of Plaintiff's tax returns is not admissible. 
 
Furthermore, admission of evidence under 608(b) is subject to Rule 403 and 
“must still outweigh the danger of unfair prejudice, confusion of the issues, or 
misleading the jury.”  First Weber Group, Inc. v. Horsfall, 738 F.3d 767, 778 (7th 
Cir. 2013); Ad-Vantage Tel. Directory Consultants v. GTE Directories Corp., 37 
F.3d 1460, 1464 (11th Cir. 1994) (Rule 403 applies to evidence sought to be admitted 
under Rule 608(b)).  For the reasons already discussed, prejudice far outweighed 
probative value here. 
However, ultimately all of this is irrelevant because under rule 608(b) 
impeachment, “[i]f the witness denies the conduct, such acts may not be proved by 
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extrinsic evidence and the questioning party must take the witness’ answer.”  United 
States v. Garza, 172 Fed. Appx. 983, 989 (11th Cir. 2006).  Here when the prosecutor 
asked Mr. Wade about the uncharged loans he denied making them or knowing about 
them.  The only way that the prosecutor got into the details of the loan applications 
and the dollar amounts allegedly put in them and got that information before the jury 
was by reading from the documents after this denial of knowledge from Mr. Wade.  
The prosecutor did not take Mr. Wade’s answer and used extrinsic evidence, the 
actual loan documents, to impeach him.  This is explicitly prohibited when evidence 
is admitted under Rule 608(b) to impeach a witness’s general truthfulness, per the 
plain language of the rule.  See United States v. Carthen, 906 F.3d 1315, 1321 (11th 
Cir. 2018) (“Rule 608(b) provides that extrinsic evidence other than a criminal 
conviction is ‘not admissible to prove specific instances of a witness’s conduct in 
order to attack or support the witness’s character for truthfulness’.”).  Thus, the 
uncharged loan evidence could not possibly have been properly admitted under Rule 
608(b) as its procedures were not followed (nor did the prosecution move for 
admission on this basis).  As there is no remaining valid basis for admission, the 
admission of this evidence was error. 
The theory that the defense opened the door is also unavailing.  The defense 
asked Ms. Granados about an email that Mr. Wade sent Ms. Granados with his 
drivers license, social security card, and a void check.  Ms. Granados said she 
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forwarded this email to another woman who, according to hearsay from her husband, 
was working on a business PPP loan for Mr. Wade.  Ms. Granados did not claim she 
knew this from Mr. Wade or that Mr. Wade said anything to her about intending for 
her to forward the email for a business loan.  This question may have opened the 
door for the Government to ask Ms. Granados what she did with the email, but it did 
not open the door to substantive testimony about the contents of the Wade Funeral 
Home PPP loan, and certainly did not open the door to testimony about the separate 
multimillion dollar EIDL loans. 
The foregoing demonstrates that the erroneous admission of the uncharged 
loan evidence is a valid, non-frivolous legal issue on appeal.  It is likely to succeed 
because this inadmissible evidence was so prejudicial given its substance along with 
the subject matter of the case, and the Government explicitly relied on it as evidence 
of guilt in closing.  They had very little to rebut Mr. Wade’s defense that he did not 
have knowledge of the fraud their own witness Ms. Granados was undisputedly 
committing, and so they used this extrinsic, inadmissible evidence that Mr. Wade 
had supposedly attempted to defraud the Government on other loan applications, 
despite having no admissible evidence that he had anything to do with those other 
loan applications.  This Court should therefore find that the requirements of 18 
U.S.C. § 3143(b)(1)(B) have been met and allow Mr. Wade to remain at liberty while 
the Eleventh Circuit decides this issue. 
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2.   Error in Failing to Give a Standard Good Faith Jury Instruction As the 
Defense Requested.. 
 
Prior to trial, the Court advised the defense that if they ultimately wanted a 
good faith instruction there would need to be a factual basis for it, usually the 
testimony of the defendant. (10/7/24 p 7).  The prosecutor said that they did not 
believe the good faith defense was applicable to the false statement counts in any 
event, and the Court said it would deal with it later. (10/7/24 p. 8). 
After Mr. Wade did testify, and said as outlined above that he relied on Haylee 
Granados to accurately complete the charged PPP loan application, and when the 
parties were discussing the jury instructions, the Court said that it had not heard 
testimony that would raise the good-faith defense, and the defense said “it would be 
our position that based upon the trust that Mr. and Mrs. Wade had with the Riveros 
that we believe that there’s at least . . . Well, they trusted them.  They were long-
time friends, business—not partners but they did a lot of business together, and they 
made representations to them that they believed, that they relied on in good faith.” 
(10/21/24 pp. 196-97).  The Court said it did not think the good faith defense had 
been raised. (10/21/24 p. 197).  The Government again said it did not believe that 
good faith applied to the false statement counts because “[t]here’s no intent to 
defraud in the false statements and therefore the good-faith defense would not 
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apply”. (10/21/24 p. 197).  The Government did not object to a good faith instruction 
on the other counts.  The next day, the Court revisited the good faith defense issue 
and asked if the parties had any cases and said it was willing to listen if the defense 
had anything new. (10/22/24 p. 66).  The defense attorneys did not say anything and 
the Court said “All right.  Hearing no argument on that issue, we will remove the 
good-faith defense instruction.” (10/22/24 p. 67).  The Court read the jury 
instructions without a good faith instruction. (10/22/24 pp. 145-46) (portion of 
instructions where good faith appeared in written instructions, showing Court did 
not read it).  The written jury instructions filed after trial do include the good faith 
instruction, though undersigned counsel does not know if the jury received that 
version of the instructions as they deliberated. (D.E. 186 p. 18). 
Mr. Wade intends to argue on appeal that it was error to refuse to give the 
requested good faith jury instruction.  This is a standard jury instruction.  11th Circuit 
Pattern Jury Instructions S17.  Standard jury instructions, particularly as to defenses, 
are supposed to be given if there is any evidence to support them.  This is what the 
5h Circuit, which at the time was the federal appellate court covering Florida, said 
in United States v. Goss, 650 F.2d 1336, 1344 (5th Cir. 1981) (“We have often held 
that, if there is any evidentiary support whatsoever for a legal defense, and the trial 
court’s attention is specifically directed to that defense, the trial judge commits 
reversible error by refusing thus to charge the jury. . . . On the record presented we 
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cannot say that there was no evidentiary basis upon which the defendants could rest 
a good faith defense.”).  The Goss Court reversed for failure to give the good faith 
instruction.  Goss has not been overruled, although the Eleventh Circuit in United 
States v. Andreatta, 737 Fed. Appx. 925, 932 (11th Cir. 2018) noted that cases since 
Goss have not used the “any evidence” standard and look to whether the good-faith 
instruction was duplicative of other instructions given in determining if error was 
harmless.  Therefore the failure to give the instruction has been found harmless error 
if the substance was covered by other instructions, as occurred in Andreatta 
(although “the government conceded at oral argument it should not have objected to 
the good-faith instruction, and the District Court ‘would have been wiser’ to give the 
requested instruction”, Andreatta at 932). 
Here the defense position is that the other instructions on intent, which 
included definitions of specific intent to defraud, knowledge, and willfulness, did 
not adequately cover what the good faith instruction did and under the specific facts 
of this case the failure to give the instruction was reversible error.  Admittedly, in 
Andreatta the Eleventh Circuit relied on the same other intent instructions to say that 
not giving the good faith instruction was not reversible error, but the facts in 
Andreatta were not the same as this case.  In Andreatta the good faith claim was that 
the defendant relied on her boss saying she could use other corporate employees 
corporate credit cards for personal expenses in exchange for having sex with the 
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boss.  The boss testified and denied this happened.  Andreatta at 926-28.  Here the 
good faith claim is that Mr. Wade relied on a person (Haydee Granados) who held 
herself out as an expert in PPP loans, and completed at least 18 other PPP loans for 
other people besides the Wades, and who testified and acknowledged that she was 
the one who uploaded the fraudulent documents for the PPP loan.  This seems to be 
substantially more evidence of legitimate good faith than existed in Andreatta. 
The good faith instruction would have told the jury that “an honestly held 
opinion or honestly formed belief cannot be fraudulent intent”, even if that belief is 
mistaken, and that “evidence of a mistake in judgment, an error in management, or 
carelessness can’t establish fraudulent intent”. (D.E. 186 p. 18).  This is far more 
defense-friendly (in addition to being legally accurate) language than that 
“knowingly” means “voluntarily and intentionally and not because of mistake of by 
accident” or that “willfully” means voluntarily and purposely, with intent to disobey 
the law. (D.E. 186 p. 20).  The good faith language excuses honest opinions and 
beliefs, not just mistakes, and the “faith” language directly applies to the facts of this 
case where Mr. Wade put his faith in a purported expert in the subject matter. 
Even if the government was correct that the good faith defense did not apply 
to the false statements counts, it did apply to the other specific intent/willfulness 
counts.  It is therefore still the case that, if the Eleventh Circuit agrees with the 
defense, the result would be a reversal and an order for a new trial, at least on some 
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counts.  Thus the requirements of 18 U.S.C. § 3143(b)(1)(B) are satisfied and this 
Court should stay the jail sentence and permit Mr. Wade to remain at liberty pending 
the disposition of his appeal by the Eleventh Circuit. 
 
Conclusion. 
For the foregoing reasons, Mr. Wade respectfully requests that the Court grant 
him permission to remain at liberty pending the disposition of his pending appeal.  
The requirements of 18 U.S.C. § 3143 are satisfied.  Mr. Wade is not any risk of 
flight or danger to the community, and he has legitimate, non-frivolous appellate 
issues.  The defense does not expect or ask the Court to change or disagree with its 
own rulings, but because there is a reasonable likelihood of success on appeal and 
other judges could disagree with those rulings, and the appeal is clearly not being 
brought for purposes of delay or frivolity, this Court should grant this motion.  If the 
appeal is unsuccessful, Mr. Wade will have to surrender to serve the 90-day jail 
sentence.  But if it is successful, he will never be able to get that time away from his 
wife, daughter, business, and community back.  The facts, as well as the equities, 
therefore weigh in favor of granting this motion. 
 
 
  
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Respectfully submitted, 
 
 
 
 
 
 
 
 
 
 
 
 
 
s/ Daniel Tibbitt______ 
 
 
 
 
 
 
 
 
DANIEL J. TIBBITT, P.A. 
 
 
 
 
 
 
 
 
FL Bar No. 816361 
 
 
 
 
 
 
 
 
1175 NE 125th Street 
 
 
 
 
 
 
 
 
Suite 404 
 
 
 
 
 
 
 
 
North Miami, FL 33161 
 
 
 
 
 
 
 
 
(305) 384-6160  
 
 
 
 
 
 
 
 
dan@tibbittlaw.com 
 
 
 
CERTIFICATE OF SERVICE 
 
I hereby certify that on this 1st day of August, 2025, I electronically filed the 
foregoing with the Clerk of Court for the Southern District of Florida using the 
CM/ECF system, and served a copy on counsel for the government, Assistant United 
States Attorney David Snider, as well as all persons registered for electronic service 
through the CM/ECF system. 
 
s/ Daniel Tibbitt______ 
 
 
 
 
 
 
 
 
Daniel Tibbitt 
 
 
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