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Lance W. Steinbeisser, Official Court Reporter
1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NOS. 23-CR-60173-KMW-1
23-CR-60173-KMW-2
UNITED STATES OF AMERICA,
Miami, Florida
Plaintiff,
October 22, 2024
vs.
9:32 AM - 11:06 AM
CAROLYN DENISE WADE and
TRACY D. WADE,
Defendant.
Pages 1 to 71
____________________________________________________________
TRANSCRIPT OF TRIAL (TESTIMONY OF TRACY WADE)
HELD BEFORE THE HONORABLE DONALD L. GRAHAM
UNITED STATES DISTRICT JUDGE
FOR THE GOVERNMENT:
DAVID A. SNIDER, AUSA
ADAM LOVE, AUSA
United States Attorney's Office
ON BEHALF OF THE DEFENDANTS:
JOHNNY L MCCRAY, JR., ESQ.
Law Office of Johnny L. McCray, Jr., P.A.
and
DARYL E. WILCOX, ESQ.
ALSO PRESENT: Carolyn Wade
Hendrith V.A. Smith, paralegal
LANCE W. STEINBEISSER, FCRR, RPR, FPR-C
Official Court Reporter
United States District Court
400 North Miami Avenue
Miami, Florida 33128
305.523.5633
Proceedings recorded by mechanical stenography; transcript
produced by computer-aided transcription.
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
4
First, I'm going to put two documents on your screen.
You're familiar with her PPP loan application?
A.
No, sir.
Q.
You're not.
A.
Not with the application itself.
Q.
I'm publishing for you Government Exhibits 117 and 116.
Do you see that on the left and right side of the screen?
A.
Yes, sir.
Q.
And you've seen these before; right?
A.
Yes, sir.
Q.
I'm going to enlarge the top half of 116. Do you see
that?
A.
Yes, sir.
Q.
And your wife doesn't have a business named Carolyn Wade;
right?
A.
Never.
Q.
Never has.
Never did business as Carolyn Wade; correct?
A.
No, sir.
Q.
And certainly she did not have $113,560 from a business
named Carolyn Wade in 2019; correct?
A.
No, sir.
Q.
And there was no establishment of a business Carolyn Wade
in 2011; right?
A.
No, sir.
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
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Q.
And she doesn't have a sole proprietorship named Carolyn
Wade; right?
A.
No, sir.
Q.
So all of this information is false. Do you agree with
that?
A.
Yes, sir.
Q.
And looking at Government Exhibit 117, you agree that this
is identically false; correct?
A.
Yes, sir.
Q.
And you would agree that these are two PPP loan
applications; correct?
A.
Yes, sir.
Q.
Now, Carolyn Wade did have a Schedule C in her individual
tax return for the year 2019 for a business called 1 Step
A-Head; correct?
A.
From what I saw in the trial, yes.
Q.
And that Schedule C represented -- I should say reported
to the IRS that the business 1 Step A-Head in 2019 made $6,800
in gross income; right?
A.
I don't know. You would have to show me.
Q.
Sure.
Publishing Government Exhibit 201, page 13. This is
the Schedule C for the business 1 Step A-Head and in line 7 it
shows $6,800 gross income for the year 2019; correct?
A.
Yes, sir.
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
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Q.
All right. No reason to dispute the accuracy of this. I
mean, this is your wife's tax return; correct?
A.
Correct.
Q.
And you never gave that tax return to -- that Schedule C
to Haydee Rivero; correct?
A.
I never saw --
Q.
It's a yes-or-no question.
Did you ever give it to Haydee Rivero?
A.
No, sir. I never saw it.
Q.
And I asked you yesterday, you never asked Perez
Accounting, your long-time trusted accountant, for assistance
with your PPP loan application and you said, "No"; correct?
A.
Never a need.
Q.
That's a "no," you never --
A.
That's a "no."
Q.
That's a "no."
And you never asked Perez Accounting for any
assistance with any PPP loan application for Carolyn Wade?
A.
No, sir.
Q.
Now, in 2021, this time frame we're talking about --
April, May, June, July, August -- Carolyn Wade also had
Verizon Wireless?
A.
I have Verizon Wireless. Carolyn Wade had Verizon
Wireless, and from 2012 to 2023 Haydee Granados also had
Verizon Wireless.
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
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Q.
I'm not sure how you know that. That also wasn't my
question --
A.
I hired a private investigator last night, and he pulled
the records.
Q.
So last night you hired a private investigator. That's
what you did?
A.
Yes, sir.
Q.
Okay. So your testimony to this jury is that when Haydee
Granados was here and she said that she had T-Mobile, she's
never had Verizon, that she's not telling the truth. Is that
what you're saying?
A.
The phone number associated about her Verizon account ends
in 5338, which is Eduardo Rivero's phone number.
Q.
I'm asking you, sir --
MR. MCCRAY: Judge --
BY MR. SNIDER:
Q.
-- did your wife have Verizon at the same time that you
did in 2021?
A.
Yes, sir.
Q.
And she was on your account. Yes?
A.
Yes.
Q.
And her phone ended in 6800?
A.
Yes, sir.
Q.
And you've seen from the records that in this time frame
she had a Samsung Note 20 Ultra 5G; correct?
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
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ending in 84?
A.
Yes, sir.
Q.
Now, you started Carolyn Wade's PPP loan application;
correct?
A.
Correct.
Q.
You were the one that put in her phone number and email
address, and you were the one that put in the business Carolyn
Wade?
A.
I'm not sure of that, sir.
Q.
Well, that's what the data shows; right?
A.
Not necessarily.
Q.
Not necessarily?
A.
No, sir.
Q.
Publishing for you Government Exhibit 1000. We're going
to look at slide 15. Do you see logins here on May 13, 2021?
A.
I'm looking at it, yes, sir.
Q.
And it shows logins from the Wade Funeral Home -- two of
them?
A.
I see the first login, the identifier saying
ckidd1226@gmail.com. And if you go all the way to the end, it
says the IP address ending in 34.
Q.
Correct.
And right below that, there's a login from the Wade
Funeral Home?
A.
And it says -- the one underneath is 166 and the one
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
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underneath is 125.
Q.
Yep.
There's multiple people logging into this; correct?
A.
Yes, sir.
Q.
And you're one of them?
A.
Yes, sir.
Q.
And your wife is one of them?
A.
Undeniably.
Q.
I'm sorry?
A.
Undeniably.
Q.
"Undeniably."
A.
Yes.
Q.
This is the same slide with a little more detail. You
said "undeniably," and that's because this is your wife's
phone; right? That's the phone that she had. I just showed
you from -- that's your wife's phone, that Note Ultra 5G?
A.
Yes. Yes, sir.
Q.
She logged in five times on May 13?
A.
Yes, sir.
Q.
Did you log into your wife's PPP loan account from the
Broward Sheriff's Office network?
A.
Can you repeat that question, please?
Q.
Did you ever log into your wife's PPP loan account while
using the Broward Sheriff's Office network?
A.
No, sir.
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
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Q.
So this login on page 30 from the Broward Sheriff's Office
IP, that's your wife logging in from work. Yes?
A.
Yes, sir.
Q.
And on slide 34 now, that's your wife logging into her PPP
loan application from home. Yes?
A.
Yes, sir.
Q.
And on slide 35, that's your wife logging into her PPP
loan application from Verizon's network. Yes?
A.
No, that just clearly shows someone with a Verizon account
logging into that.
Q.
Do you see where it says -- this is no different than the
slide we looked at before. Do you see how it says "user agent
SM-N986U?
A.
Yes, sir.
Q.
And that's the phone your wife was holding in her hands
when she identified her identity. That's what's shown in
Government 114.1?
A.
What this shows is a Verizon user signing into this
account.
Q.
Yeah, with a certain phone. And that phone belongs to
Carolyn Wade; correct?
A.
I don't -- I can't deny or agree with that.
Q.
Well, a moment ago you said undeniably that was her.
What's different about this slide?
MR. MCCRAY: Judge, objection.
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
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A.
They're somewhat similar, but I can't say that that's her
exact signature.
Q.
Let's talk about these checks.
You have never worked as an employee for your wife;
correct?
A.
No, sir.
Q.
You have never been involved in the hairstyling business;
correct?
A.
Repeat the question.
Q.
You have never been involved in the hairstyling business
for your wife?
A.
No, sir.
Q.
And she has never paid you a salary; correct?
A.
No, sir.
Q.
And yet, she wrote multiple checks to you with the word
"salary" in the memo; correct?
A.
Yes, she did.
Q.
And it's your testimony that that was to withdraw cash;
correct?
A.
Yes, it was. So, again, as I testified earlier, one of
the things that was explained for me when you get the proceeds
from the PPP loan, you need to be accountable for the proceeds
that -- how you spent the proceeds. There has to be
accountability. So what she's putting in the memo section --
it's not illegal to pay yourself salary when you have PPP
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
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proceeds.
Q.
I'm talking about the checks to you, sir, where she
wrote --
A.
She was not paying me.
Q.
She wasn't paying you?
A.
No, sir.
Q.
But she wrote "salary" to you, and you just testified
she's never --
A.
She wrote a check to me for cash.
Q.
Well, is that what it says, "cash" in the memo?
A.
Maybe it should have said "cash," but she wrote it and I
gave her cash.
Q.
And she wrote "salary." That was false. Yes?
A.
No, it was her salary.
Q.
I'm talking about the checks to you. Let's put it up so
there's no confusion here.
This is a check to you, sir, signed by Carolyn Wade
with the memo "salary." That's false. Yes?
A.
No, it is not.
Q.
Was it for salary or -- yes or no?
A.
What's factual on this check, it's written out to me, and
in the memo section it says "salary." Technically, that's all
it says. It doesn't say it's for me. It doesn't say it's for
her. It says "salary." You asked me for an explanation and I
just told you why it says "salary."
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
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A.
I am not sure where you're getting that from, so...
Q.
Did Wade Funeral Home ever have $3 million in annual
payroll?
MR. MCCRAY: Objection as to relevance.
THE COURT: May I see -- come sidebar.
(The following proceedings were held sidebar:)
THE COURT: What is the $3 million about?
MR. SNIDER: A PPP loan application that was
submitted on behalf of Wade Funeral Home that represents --
that had $3,368,990 in payroll.
THE COURT: Well, what's --
MR. SNIDER: I'm asking if he ever did.
THE COURT: Well, based on his answer, you probably
should ask him is he familiar with this document. You're
publishing the contents of this document. Show him the
document and ask him if he recognizes it. And if he says no,
you go to your next question.
MR. SNIDER: Well -- okay.
(The following proceedings were held in open court:)
MR. SNIDER: May I approach the witness, Your Honor?
THE COURT: Yes, sir.
BY MR. SNIDER:
Q.
Mr. Wade, I'm handing you what has been marked for
identification as Government Exhibit 167. Do you see that?
A.
Yes, I see this.
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
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Q.
My question for you is did Wade Funeral Home ever have
$3,368,909.56 in payroll?
MR. MCCRAY: Objection to the form. That's not the
question that was supposed to be asked from sidebar.
THE COURT: Ask the question -- show him the form.
MR. SNIDER: He has it.
THE COURT: Are you familiar with the exhibit?
THE WITNESS: No, sir. I've never seen this form.
Never seen this number ever in my life.
THE COURT: The next question, please.
BY MR. SNIDER:
Q.
I'm showing you what is marked for identification as
Government Exhibit 168. Have you ever seen that before?
A.
Never seen this form before. I'm not familiar with this.
Q.
Okay. Showing you what is identified as Government
Exhibit 169. Have you ever seen that before?
A.
I'm not familiar with this document. Who prepared this?
Q.
Showing you what is marked for identification as
Government Exhibit 170. Have you ever seen that before?
A.
I've never seen this document before. Is there other
documents attached to it?
Q.
I'll take that back.
A.
Okay.
Q.
Mr. Wade, do you know what your payroll was for Wade
Funeral Home in 2020?
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
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A.
Not offhand.
Q.
Can you give an approximation?
A.
No, I don't want to approximate, sir.
Q.
Did you ever have payroll of $3 million?
A.
I had laborers --
MR. WILCOX: Objection, Your Honor.
THE COURT: What's the objection? The basis?
MR. WILCOX: Relevancy.
THE COURT: Overruled.
BY MR. SNIDER:
Q.
Did Wade Funeral Home ever have payroll of $3 million?
A.
Payroll of $3 million?
Q.
Yes.
A.
I've never ever stated that, sir.
Q.
Listen to the question --
A.
The answer is no.
Q.
Did Wade Funeral Home ever have 45 employees?
A.
45? No.
Q.
Mr. Wade, who would know the EIN for Wade Funeral Home?
A.
Anybody that logs on Sunbiz, sir.
Q.
Oh, it's available on Sunbiz, the EIN?
A.
Yes, it is, sir.
Q.
Who would know your cell phone number?
A.
Everybody that I've ever dealt with in my life as far as
business goes, personal. Everybody knows my number.
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
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MR. WILCOX: And to go into this -- and we will say
stay away from it because it's prejudicial. It's a confusion
of the issues, Judge, under 403.
THE COURT: I don't think it's that confusing.
I'm going to allow a few questions.
Are we going to get through with this anytime today?
MR. SNIDER: Yes.
THE COURT: What time today?
MR. SNIDER: I don't know how long their redirect is.
THE COURT: No, don't worry about the redirect. I'm
asking you. What time are you finishing?
MR. SNIDER: I think I've got 15 minutes.
THE COURT: You're on the clock.
MR. SNIDER: Very well.
MR. MCCRAY: Judge, can we establish the two
questions?
THE COURT: I'm not going to go into that, Counsel.
(The following proceedings were held in open court:)
BY MR. SNIDER:
Q.
Mr. Wade, you applied for an EIDL loan, E-I-D-L, from the
SBA for Wade Funeral Home; correct?
A.
I did not know it to be called that. I know it to be an
SBA loan until you told me that's what it was.
Q.
So you applied for an SBA loan for Wade Funeral Home that
was not a PPP loan; correct?
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
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A.
I was unaware that was considered a PPP loan --
Q.
No, that was not. I'm talking about a different --
Did you apply for a loan from the SBA that you
believed was an SBA loan?
A.
Yes, sir.
Q.
And you did that in approximately 2020; correct?
A.
I'm not sure. If you have the document and you show me, I
can verify that's the year.
Q.
And in that application, you were asked by the SBA to put
in the gross revenue for Wade Funeral Home for the year
preceding 2020; correct?
A.
I assume, if that's a part of the application process.
Q.
Okay. And in that response, you put $465 million;
correct?
A.
What?
Q.
In your response to that question, what is the gross
revenue for the 12 months prior to January 31, 2020, you put
$465 million?
A.
Sir, my tax documents -- I've never even been shown to
make 500,000 to a million dollars.
Q.
Listen to the question. I'm not talking about your tax
documents.
In the application to the SBA for this other loan
that you just said you applied for, when you were asked to put
in the gross revenues for the 12-month period before
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Lance W. Steinbeisser, Official Court Reporter
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January 31, 2020, you entered $465 million?
A.
I don't recall that. Can you show me the document? Or
was that phone recorded?
MR. SNIDER: May I approach, Your Honor?
THE COURT: Yes, sir.
BY MR. SNIDER:
Q.
Sir, I'm handing you what has been marked for
identification as Government's 900. Okay? And on the left
side, each side is numbered. Go to line 15, please.
A.
Can you make this bigger? Because I'm having trouble
seeing it. Can you publish it and I will try to follow along.
Q.
Okay. Sure.
If you can't read it, I'll be happy to do that. I'm
just going to turn it on your screen.
A.
Okay. Do that, then.
Q.
Okay. No problem.
Can we please publish only for the witness and
defense counsel and the Government's table what's identified
as 900? Okay. It's not going to publish to the jury?
THE COURTROOM DEPUTY: No.
BY MR. SNIDER:
Q.
So, sir, I'm going to -- do you see 900 on your screen --
what's identified as Government 900?
A.
Okay.
Q.
Do you see line 15?
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
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A.
Okay. And for what year is this?
Q.
Do you see line 15?
A.
I can see it.
Q.
Does this refresh your recollection that in answer to the
question by the SBA for gross revenues for the 12-month period
prior to January 31, 2020, there was an entry of $465 million?
A.
Clearly that has to be a typo because I've never claimed
that.
Q.
Okay. So you're saying that's a typo?
A.
Sir, the accurate documents for this particular loan have
been submitted. This loan is current and there's no issues
with this loan.
Q.
Just answer the question.
Is this a typo? Is that what you're saying?
A.
Absolutely.
Q.
And below that you were asked how much the Wade Funeral
Home had in cost of goods sold, which are expenses; correct?
Cost of goods sold are expenses --
A.
Yes, sir.
Q.
-- for the same period, the year before January 31,
2020 --
A.
Okay.
Q.
-- and you entered 175 million?
A.
That's what it's saying here. But, sir, clearly, I have a
full-time job. I ran a full-time business. I am a full-time
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
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dad and a husband. The difference between a hundred thousand
and millions is zeroes. Clearly that's a typo.
Q.
So that's your testimony; this is a typo. 465 million in
revenue was a typo and 175 million was a typo?
A.
Yes, sir.
Q.
I'm going to publish for you Government Exhibit --
A.
If I had that kind of money, why would I need any loan?
Q.
906. Do you see 906 on your screen?
A.
Yes, sir.
Q.
Okay. Do you see line 14?
A.
Yes, sir.
Q.
And this is a separate application for an SBA loan with
different information than the one we just looked at; correct?
A.
The discrepancy is zeros.
Q.
And what does it say that you put in for when asked the
question gross revenues for the 12 months prior to the date of
the disaster?
A.
That's an inaccurate typing.
Q.
Does it say 350 million?
A.
Yes, it does.
Q.
And line 15 for the cost of goods sold, did you put in 250
million?
A.
The discrepancy is zeros, sir.
Q.
So it's two different sets of typos in two different
applications. Is that what you're saying?
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Lance W. Steinbeisser, Official Court Reporter
TRACY WADE - CROSS
55
A.
All my correct tax documents are supporting what we
initially put, and the phone conversations were recorded.
Q.
And you asked the SBA for the status of this loan;
correct?
A.
Absolutely.
Q.
And you called them multiple times asking for the status?
A.
It was phone-recorded conversations.
Q.
Okay. And you never --
A.
Nothing fraudulent was discussed or brought up. That loan
was funded. It was never put under investigation, and it is
current as of this day.
Q.
So you asked the SBA for the status of the loan where you
had represented that Wade Funeral Home had 465 million in
revenues and 350 million in expenses?
A.
Never. Never. Never. At some point in time -- you
clearly see that was corrected.
Q.
So just to summarize, Mr. Wade. You sought from the
SBA --
THE COURT: Are these questions you've already asked?
MR. SNIDER: I'm just summarizing what we --
THE COURT: No, don't summarize. Are these questions
that you've asked --
MR. SNIDER: No.
THE COURT: -- and have been answered?
MR. SNIDER: No.
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