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Wyatt M. Bailey (020356) 

wbailey@meagher.com 

Alden A. Thomas (031900) 

athomas@meagher.com 

Thomas H. Crouch (020134) 

tcrouch.com@meagher.com 

MEAGHER & GEER, P.L.L.P. 

8800 N. Gainey Center Drive, Suite 261 

Scottsdale, Arizona 85258 

Telephone: (480) 607-9719 

Facsimile: (480) 607-9780 

tcrouch@meagher.com 

wbailey@meagher.com 

athomas@meagher.com 

Attorneys for Plaintiff Travelers Property 

Casualty Company of America 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

Travelers Property Casualty Company Of 

America, a corporation, 

Plaintiff, 

 vs. 

Village Voice Media Holdings, L.L.C., 

d/b/a Backpage.com; Backpage.com, 

L.L.C.; New Times Media, L.L.C., d/b/a 

Backpage.com, 

Defendants. 

No. 2:17-cv-03994-SPL 

PLAINTIFF TRAVELERS 

PROPERTY CASUALTY 

COMPANY OF AMERICA'S 

STATEMENT OF OWNERSHIP 

AND STATE OF CITIZENSHIP 

OF LLC DEFENDANTS 

Pursuant to this Court’s October 31, 2017 order, Plaintiff Travelers Property Casualty 

Company of America (“Travelers”) hereby provides the following list detailing the identity 

Case 2:17-cv-03994-SPL Document 9 Filed 11/07/17 Page 1 of 5
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and state of citizenship of each of the owners and members of the Defendants. Travelers 

notes that each of the defendants are privately held Delaware limited liability companies. 

Such citizenship operates to obscure, deliberately or unintentionally, the identity of upstream 

owners and members. Travelers has conducted extensive due diligence on the ownership and 

membership of each defendant entity, including general research, court filings in other cases 

and, more importantly, the January 10, 2017 Staff Report issued by the United States Senate 

Permanent Subcommittee on Investigations and its Appendix (totaling 839 pages) (entitled 

BACKPAGE COM'S KNOWING FACILITATION OF ONLINE SEX 

TRAFFICKING (the “Senate Backpage.com Report”)). That report concluded, at least with 

respect to Backpage.com, LLC (“Backpage”), that Backpage has attempted to obscure the 

identity of its members and owners through a number of domestic and foreign transactions. 

Notwithstanding the foregoing, Travelers states, upon good faith information and belief: 

(1) Village Voice Media Holdings, LLC 

Village Voice Media Holdings, LLC is a privately held Delaware limited liability 

company. According to the Senate Backpage.com Report, by 2012 the members of Village 

Voice Media Holdings, LLC had transferred all of their membership interests into Medalist 

Holdings, LLC, also a privately held Delaware limited liability company. Upon good faith 

information and belief, Village Voice Media Holdings, LLC n/k/a Medalist Holding, LLC’s 

members are: Michael Lacey, James Larkin, John Brunst, Scott Spear, Troy Larkin, and 

Ramon Larkin. Upon good faith information and belief, Lacey, James Larkin, Brunst, and 

Spear are citizens of the state of Arizona. Upon good faith information and belief, Troy 

Larkin is a citizen of the state of New York. Upon good faith information and belief, Ramon 

Larkin is a citizen of the state of Missouri. 

Therefore, for purposes of determining diversity jurisdiction under 28 U.S.C. § 1332, 

Village Voice Media Holdings, LLC n/k/a Medalist Holding, LLC is a citizen of the states of 

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Arizona, Missouri and New York, and no member of Defendant Village Voice Media 

Holdings, LLC n/k/a Medalist Holding, LLC is a citizen of the state of Connecticut. 

Conversely, documentation in the Appendix to the Senate Backpage Report 

(specifically App. 000433-000440) refers to the members of Village Voice Media Holdings, 

LLC transferring the entirety of their membership interests into Medalists Holdings, Inc., a 

privately held Delaware corporation. If true, for the purposes of determining diversity 

jurisdiction under 28 U.S.C. § 1332, Village Voice Media Holdings, LLC n/k/a Medalist 

Holding, Inc. is a citizen of the state of Delaware and it is not a citizen of the state of 

Connecticut. 

(2) Backpage.com L.L.C. 

Backpage.com, LLC is a privately held Delaware limited liability company. Upon 

good faith information and belief, its operations are split into domestic and international 

services that are owned by two members. Upon good faith information and belief, the 

member that owns Backpage’s domestic operations is Atlantische Bedrijven C.V., a Dutch 

limited liability partnership domiciled in Curacao. Upon good faith information and belief, 

the member that owns Backpage’s foreign operations is UGC Tech Group C.V., a Dutch 

limited liability partnership domiciled in Curacao. Upon good faith information and belief, 

and specifically according to information contained in the Senate Backpage.com Report, 

Atlantische Bedrijven C.V. and UGC Tech Group C.V. are owned and controlled by five 

Delaware-based parent companies: Amstel River Holdings, LLC, Lupine Holdings, LLC, 

Kickapoo River Investments, LLC, CF Holdings GP, and CF Acquisitions. Upon good faith 

information and belief, Amstel River Holdings, LLC Lupine Holdings, LLC, Kickapoo River 

Investments, LLC, CF Holdings GP, and CF Acquisitions are 100% owned by Carl Ferrer, a 

citizen of Texas. Therefore, for purposes of determining diversity jurisdiction under 28 

U.S.C. § 1332, Backpage.com, LLC is a citizen of the state of Texas. Moreover, no member 

of Defendant Backpage.com or its parent Members is a citizen of the state of Connecticut. 

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(3) New Times Media, LLC 

New Times Media, LLC is a privately held Delaware limited liability company. Upon 

good faith information and belief, it is a wholly owned subsidiary whose ultimate parent, 

according to the Senate Backpage Report, is Village Voice Media Holdings, LLC n/k/a 

Medalist Holding, LLC. Village Voice Media Holdings, LLC n/k/a Medalist Holding, LLC 

is a privately held Delaware limited liability company. Upon good faith information and 

belief, Village Voice Media Holdings, LLC n/k/a Medalist Holding, LLC’s members are: 

Michael Lacey, James Larkin, John Brunst, Scott Spear, Troy Larkin, and Ramon Larkin. 

Upon good faith information and belief, Lacey, James Larkin, Brunst, and Spear are citizens 

of the state of Arizona. Upon good faith information and belief, Troy Larkin is a citizen of 

the state of New York. Upon good faith information and belief, Ramon Larkin is a citizen of 

the state of Missouri. 

Therefore, for purposes of determining diversity jurisdiction under 28 U.S.C. § 1332, 

New Times Media, LLC is a citizen of the states of Arizona, Missouri and New York. 

Moreover, no member of Defendant New Times Media, LLC, or its parent Members, is a 

citizen of the state of Connecticut. 

Conversely, documentation in the Appendix to the Senate Backpage Report 

(specifically App. 000433-000440), refers to the members of Village Voice Media Holdings, 

LLC transferring the entirety of their membership interests into Medalist Holdings, Inc., a 

privately held Delaware corporation. If true, for the purposes of determining diversity 

jurisdiction under 28 U.S.C. § 1332, Village Voice Media Holdings, LLC n/k/a Medalist 

Holding, Inc. is a citizen of the state of Delaware, and is not a citizen of the state of 

Connecticut. 

 Upon good faith information and belief, no publicly held corporation owns any 

interest in Backpage.com, LLC, New Times Media, LLC, or Village Voice Media Holdings, 

LLC. 

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In conclusion, and upon good faith information and belief, Plaintiff is not a citizen of 

the same State as any Defendant or any of the Defendants’ respective owners or members for 

purposes of determining diversity jurisdiction under 28 U.S.C. § 1332. 

DATED this 7th day of November, 2017. 

MEAGHER & GEER, P.L.L.P. 

By: /s/Wyatt M. Bailey 

Wyatt M. Bailey 

Alden A. Thomas 

Thomas H. Crouch 

8800 N. Gainey Center Dr., Suite 261 

Scottsdale, Arizona 85258 

Attorneys for Plaintiff Travelers 

Property Casualty Company of 

America

CERTIFICATE OF SERVICE 

I hereby certify that on November 7, 2017, I electronically transmitted the attached 

documents to the court clerk’s office using the CM/ECF system for filing and thereby 

transmitted a notice of electronic filing to the following CM/ECF registrants: 

Clerk of Court 

United States District Court 

District of Arizona – Phoenix 

401 W. Washington Street, Suite 130 

Phoenix, Arizona 85007 

By: /s/Judy Mannino 

11838568.1 

Case 2:17-cv-03994-SPL Document 9 Filed 11/07/17 Page 5 of 5