Court filing
Information — United States v. Tracy D. Wade (Dkt. 296, S.D. Fla. No. 0:23-cr-60173)
Filed December 16, 2025 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 | 2025-12-16 |
U.S. District Court for the Southern District of Florida · No. 0:23-cr-60173-KMW · Doc. 296 · 2025-12-16 · Docket on CourtListener
Full text
Letter Requesting Travel Exception for Business Operations Tracy D. Wade Sr. Owner & Funeral Director Wade Funeral Home Hallandale Beach, Florida The Honorable Donald Graham 400 N.Miami Avenue Miami, fl. 33128 Re: Request for Modification of Probation Conditions - Business Operations Exceptions Dear Judge Graham: I am writing respectfully to request modifications to certain standard probation conditions currently in effect. As the owner and licensed funeral director of Wade Funeral Home, a professional funeral service establishment serving famili'es i°hroughout Miami-Dade and ~ Broward counties, I am occasionally required to travel outside the prescribed jurisdiction and execute financial transactions to fulfill essential business obligations. Nature of Business Operations Wade Funeral Home has been serving South Florida families since 2010, providing comprehensive funeral, memorial, and cremation services with dignity and compassion. Our business operates 24 hours a day, seven days a week, as families depend on our immediate response during their most difficult times. As the sole proprietor of Wade Funeral Home, I am the authorized signatory for all business transactions, both existing and new. The operational requirements of running a funeral service establishment occasionally necessitate actions that may conflict with standard probation restrictions. Request for Travel Exception The nature of funeral service work occasionally necessitates travel beyond local jurisdictional boundaries for the following legitimate business purposes: Case 0:23-cr-60173-KMW Document 296 Entered on FLSD Docket 12/17/2025 Page 1 of 3 • Transportation of deceased individuals from out-of-county locations to our facility • Service to families whose loved ones passed away while traveling or residing temporarily outside our primary service area • Coordination with out-of-area cemeteries, crematories, and other funeral service providers • Attendance at professional conferences and continuing education required to maintain licensure I respectfully request permission to travel outside the current jurisdictional boundaries strictly for verified business purposes related to Wade Funeral Home operations. I am fully prepared to provide comprehensive documentation for any such travel, including but not limited to: • Advance written notice to my probation officer with travel dates, destinations, and purpose • Service contracts or family authorization forms • Transportation manifests and death certificates (as applicable) • Receipts, invoices, and business correspondence substantiating the business nature of travel • Contact information for all locations visited Request for Credit Restriction Modification I respectfully request removal of the condition prohibiting the opening of new lines of credit. As the sole proprietor of Wade Funeral Home, I am the required signatory for all business financial transactions, including: • Vendor accounts and trade credit necessary for purchasing caskets, urns, and funeral supplies • Equipment financing for vehicles, embalming equipment, and facility improvements • Business credit lines to manage cash flow during periods when families require payment plans • Service contracts with third-party providers such as florists, transportation services, and cemetery operators The funeral service industry requires established credit relationships to operate effectively. Families often need time to settle estates before payment can be made, necessitating business credit facilities to bridge these gaps while maintaining uninterrupted service to the community. I propose that any new business credit applications be reported to my probation officer in advance, with full documentation provided, to ensure transparency while allowing necessary business operations to continue. Case 0:23-cr-60173-KMW Document 296 Entered on FLSD Docket 12/17/2025 Page 2 of 3 Commitment to Compliance I understand the seriousness of probation conditions and remain fully committed to compliance with all terms. These requests are made solely to enable me to continue operating my business responsibly and serving families who depend on our services. I recognize that these exceptions, if granted, are privileges that require accountability and transparency. I am available to discuss this matter further at your convenience and welcome any conditions or reporting requirements the Court deems appropriate to ensure continued compliance. Thank you for your time and consideration of these requests. ~pectfu~J~~:, TrXadeSr. Owner & Funeral Director Wade Funeral Home Hallandale Beach, Florida Case 0:23-cr-60173-KMW Document 296 Entered on FLSD Docket 12/17/2025 Page 3 of 3
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