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U.S. v. Carolyn D. Wade
Case# 23-cr-60173 Williams/ Graham
Def. Amended Witness/Exhibit List
Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AMERICA,
Case No:23-CR-60173 Williams (Graham)
v.
CAROLYN D. WADE,
Defendant.
/
DEFENDANT CAROLYN D. WADE’S AMENDED WITNESS AND EXHIBIT LISTS
Defendant, CAROLYN D. WADE, files her Witness and Exhibit List with regard to
the upcoming Trial and may use some or all of the following witnesses and exhibits in
the trial in this matter.
Witnesses
1. All witnesses listed on the government’s witness list
2. Carolyn D. Wade, Defendant
3. Tracy Wade
4. Haydee Granados, aka Haydee Rivero
5. Edward Rivero/ Rivero Funeral Home
6. Tammy DeClerq, COO, SBA, B.S.D. Capital/Lendistry
7. Representative, Harvest Small Business Finance
8. Representative/ Records Custodial, U.S. Small Business Administration (PPP)
9. Records Custodian, Broward Sheriff Office (BSO)
10. Eric Wilson, Eric Wilson Mortuary
Exhibits
11. All exhibits listed on the government’s exhibit list
12. 2019 Tax Returns (including Schedule C)-Carolyn D. Wade
Case 0:23-cr-60173-KMW Document 55 Entered on FLSD Docket 05/02/2024 Page 1 of 3
U.S. v. Carolyn D. Wade
Case# 23-cr-60173 Williams/ Graham
Def. Amended Witness/Exhibit List
Page 2 of 3
13. SBA PPP Loan applications, Haydee Granados, aka Haydee Rivero
14. Email Compendium between Carolyn D. Wade, Tracy Wade and Haydee
Granados
15. Cancelled Check from Carolyn D. Wade for payment to Haydee Granados for
PPP Loan preparation, payable to third party upon direction
16. Cancelled Check payable to Jersey City Group for PPP Loan Application
17. Email from Tracy Wade to Haydee Granados forwarding requested bank
statements
18. Email from Tracy Wade to Haydee Granados forwarding Docusign login
credentials for access to account
Defendant, CAROLYN D. WADE, reserves the right to call additional witnesses on
this list, or refrain from calling witnesses on this list, and reserves the right to
introduce into evidence or utilize additional documents on this list, or refrain from
utilizing or introducing into evidence documents on this list as the circumstances
dictate.
CERTIFICATE OF SERVICE
I HEREBY certify that on May 1, 2024, I electronically filed the foregoing document
with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is
being served this day on all counsel of record vis a transmission of Notices of
Electronic Filing generated by CM/ECF or in some other authorized manner for those
counsel or parties who are not authorized to receive electronically Notices of
Electronic Filing.
Case 0:23-cr-60173-KMW Document 55 Entered on FLSD Docket 05/02/2024 Page 2 of 3
U.S. v. Carolyn D. Wade
Case# 23-cr-60173 Williams/ Graham
Def. Amended Witness/Exhibit List
Page 3 of 3
Respectfully submitted,
/s/ Johnny L. McCray, Jr.
Fla. Bar Number 342319
Attorney for Defendant
Law Office of Johnny L. McCray, Jr. , P.A.
400 East Atlantic Boulevard
Pompano Beach, FL 33060
(954) 781-3662
McCrayjlaw @gmail.com
cc: Carolyn D. Wade
Case 0:23-cr-60173-KMW Document 55 Entered on FLSD Docket 05/02/2024 Page 3 of 3