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ELIZABETH A. STRANGE

First Assistant United States Attorney District of Arizona

KEVIN M. RAPP (Ariz. Bar No. 14249, kevin.rapp@usdoj.gov)

MARGARET PERLMETER (Ariz. Bar No. 024805, margaret.perlmeter@usdoj.gov)

PETER S. KOZINETS (Ariz. Bar No. 019856, peter.kozinets@usdoj.gov) 

ANDREW C. STONE (Ariz. Bar No. 026543, andrew.stone@usdoj.gov)

Assistant U.S. Attorneys

40 N. Central Avenue, Suite 1800

Phoenix, Arizona 85004-4408

Telephone (602) 514-7500

JOHN J. KUCERA (Cal. Bar No. 274184,john.kucera@usdoj.gov) 

Special Assistant U.S. Attorney

312 N. Spring Street, Suite 1200

Los Angeles, CA 90012

Telephone (213) 894-3391

JOHN P. CRONAN

Acting Assistant Attorney General

Criminal Division, U.S. Department of Justice

REGINALD E. JONES (Miss. Bar No. 102806, reginald.jones4@usdoj.gov)

Senior Trial Attorney, U.S. Department of Justice

Child Exploitation and Obscenity Section 

950 Pennsylvania Ave N.W., Room 2116

Washington, D.C. 20530

Telephone (202) 616-2807 

Attorneys for Plaintiff

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

United States of America,

Plaintiff, 

v. 

Michael Lacey, et al.,

Defendants.

CR-18-422-PHX-SPL (BSB) 

UNITED STATES’ MOTION TO 

TRANSFER CASES

On March 28, 2018, the grand jury returned an indictment against seven defendants 

in United States v. Lacey, et al. That case was assigned to Judge Logan and given the case 

number CR 18-422-PHX-SPL. Subsequently, two related cases—both arising from the 

same underlying events and transactions—were opened and assigned to Judge Humetewa. 

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Those two related cases are United States v. Ferrer (CR 18-464-PHX-DJH) and United 

States v. Backpage.com, LLC et al. (CR 18-465-PHX-DJH).

Pursuant to Arizona Local Rule of Civil Procedure 42.1 and Arizona Local Rule of 

Criminal Procedure 5.2, the United States respectfully moves to transfer the more recentlyopened cases (Case Nos. CR 18-464-PHX-DJM and CR 18-465-PHX-DJM) from Judge 

Humetewa to Judge Logan, who is the assigned judge in the older case (Case No. CR 18-

422-PHX-SPL). Such a transfer is appropriate because all of these matters arise from 

substantially the same transaction or event, because all of these matters may call for 

determination of substantially the same questions of law, and because assignment to a 

different district judge would otherwise entail substantial duplication of labor. See LR Civ. 

P. 42.1(a) (“When two or more cases are pending before different Judges, a party in any of 

those cases may file a motion to transfer the case or cases to a single Judge on the ground 

that the cases . . . arise from substantially the same transaction or event; . . . call for 

determination of substantially the same questions of law; or . . . for any other reason would 

entail substantial duplication of labor if heard by different Judges.”); LR Crim. P. 5.2 

(“With regard to transfer of related cases assigned to different Judges to a single judge, . . 

. see Rule 42.1, Local Rules of Civil Procedure.”).1

Undersigned counsel can avow that counsel for Mr. Ferrer (in CR 18-464-PHXDJM) and counsel for the corporate entities (in CR 18-465-PHX-DJM) have no objection 

to this request.

 

1 This motion is being filed in the docket of CR 18-422-PHX-SPL (BSB), as opposed 

to the dockets of the more recently-filed cases, because this approach is required by LR 

Civ. P. 42.1(b): “A motion to transfer under subparagraph (a) . . . must identify all the 

cases that are the subject of the motion by case name and case number. The movant 

. . . must file the motion in the case with the lowest case number in which the movant is a 

party. The ECF System . . . will electronically file the motion in each affected case 

identified in the motion.”

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Excludable delay under 18 U.S.C. § 3161(h) may occur as a result of this motion or 

an order based thereon.

Respectfully submitted this 24th day of May, 2018.

ELIZABETH A. STRANGE

First Assistant United States Attorney District of Arizona

/s Kevin Rapp

KEVIN M. RAPP

MARGARET PERLMETER

PETER S. KOZINETS

ANDREW C. STONE

Assistant U.S. Attorneys

JOHN J. KUCERA

Special Assistant U.S. Attorney

JOHN P. CRONAN

Acting Assistant Attorney General Criminal Division, U.S. Department of Justice

REGINALD E. JONES

Senior Trial Attorney

U.S. Department of Justice, Criminal Division

Child Exploitation and Obscenity Section

Certificate of Service: I hereby certify that on this date, I electronically transmitted the 

attached document to the Clerk’s Office using the CM/ECF system for filing and 

transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Anne 

Chapman, Erin McCampbell, Gregory Zamora, James Grant, Larry Debus, Lawrence 

Kazan, Lee Stein, Paul Cambria, Robert Corn-Revere, Ronald London, Janey Henze Cook, 

John Littrell, Kenneth Miller, Thomas Bienart, Jr., Bruce Feder, Michael Kimerer, Rhonda 

Neff, KC Maxwell, David Wakukawa, Michael Piccarreta, Stephen Weiss, Nanci Clarence, 

Jonathan Baum, David Botsford. 

s/Zachry Stoebe

U.S. Attorney’s Office

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