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GARY M. RESTAINO

United States Attorney

District of Arizona

KEVIN M. RAPP (Ariz. Bar No. 014249, 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 

DAN G. BOYLE (N.Y. Bar No. 5216825, daniel.boyle2@usdoj.gov) Special Assistant U.S. Attorney 

312 N. Spring Street, Suite 1400 

Los Angeles, CA 90012 

Telephone (213) 894-2426 

NICOLE M. ARGENTIERI

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

AUSTIN M. BERRY (Texas Bar No. 24062615, austin.berry2@usdoj.gov) 

U.S. Department of Justice 

Child Exploitation and Obscenity Section 

1301 New York Avenue, NW, 11th Floor 

Washington, D.C. 20005 

Telephone (202) 412-4136 

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-DJH 

UNITED STATES’ RESPONSE TO 

DEFENDANTS’ ORAL MOTION TO 

DISMISS

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SUMMARY OF ARGUMENT

Defendants seek dismissal based on a draft asset tracing document that consists of 

information the United States disclosed to Defendants over three years ago. The United 

States provided the same statements to Defendants in nearly verbatim form when it 

produced two civil seizure affidavits in 2018, and when it served a related civil forfeiture 

complaint in 2020. (See Exhibits 1-3, attached.) As shown in a line-by-line comparison

prepared by the United States (Exhibit 8, attached), these long-ago produced documents 

contain every material statement in the draft. Moreover, the draft was written by an agent 

who didn’t testify at the trial, and no witness had adopted or approved of the draft. The 

draft isn’t Jencks and doesn’t contain any Brady or Giglio information that had not already 

been produced. For these and other reasons, the United States complied with its disclosure 

and discovery obligations—and Defendants’ motion should be denied. 

FACTUAL BACKGROUND

I. Inspector Versoza Prepared the Draft Asset Tracing Document

Defendants’ motion is premised on an email the United States produced in an 

abundance of caution in anticipation of former Special Agent Quoc Thai’s testimony 

during the forfeiture phase of the trial. On October 18, 2023, after Thai’s trial testimony, 

he emailed asset forfeiture AUSA Dan Boyle. (Oct. 18, 2023, email attached as Exhibit 4.) 

The email discussed Thai’s availability to meet with AUSA Boyle, “I’m generally free 

after 1 and could make exceptions most days after 9AM.” (Ex. 4.) It also attached “the 

latest draft of the tracing document that [Postal Inspector Lyndon Versoza] and I put 

together years ago.” (Ex. 4.) The attached document is titled, “Backpage Investigation, 

Asset Tracing Master Document Draft.” (“Draft,” attached as Exhibit 5.) 

The relevant facts about the Draft include the following, which Inspector Lyndon 

Versoza and former SA Thai would testify to if so requested by the Court. 

The purpose of the Draft was to serve as a repository to support asset forfeiture

arising out of the Backpage investigation. Inspector Versoza prepared the Draft. Former 

SA Thai reviewed the Draft and made some formatting and line edit suggestions, but did 

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not actually draft any part of the document.

The Draft formed the basis for Inspector Versoza’s affidavits in support of several 

seizure warrants issued by the Central District of California in 2018. (See, e.g., Versoza 

Affidavit, filed 4/26/2018, Case No. 2:18-MJ-01000, Doc. 3-1, Bates No. DOJ-BP0004598397-524 (attached as Exhibit 1); Versoza Affidavit, filed 10/31/2018, Case No. 

2:18-MJ-2872, Doc. 3-1, Bates No. DOJ-BP-0004719085-327 (attached as Exhibit 3).)

Defendants have long had access to the civil seizure affidavits. The United States 

produced the first affidavit to Defendants in discovery on July 2, 2018. (7/2/2018 discovery 

letter, attached as Exhibit 6.) The United States produced the second affidavit to 

Defendants on November 30, 2018. (11/30/2018 discovery letter, attached as Exhibit 7.)

The Draft was also used as a basis for the United States’ Consolidated Master 

Verified Complaint for Forfeiture (“Civil Forfeiture Complaint”) in a civil forfeiture action 

in the Central District of California. (See First Amended Consolidated Master Verified 

Complaint for Forfeiture, filed June 1, 2020, Case No. CV-18-8420-RGK-PJW, Doc. 108, 

Central District California (attached as Exhibit 2).) Inspector Versoza verified the 

complaint, and the United States filed it on the Central District of California’s public docket 

on June 1, 2020. (See Ex. 2 at 1, 90.) All Defendants have been made aware of that action, 

and Lacey, Brunst, and Spear have even filed claims in it—and have routinely received

ECF service of the filings in that case. (See, e.g., Case No. CV-18-8420-RGK-PJW, Doc. 

57 (claim filed by Lacey), Doc. 59 (claim filed by Spear), Docs. 73 and 75 (notices of 

appearance filed by Gary S Lincenberg and Gopi K Panchapakesan on behalf of Claimant 

John Brunst); see also Exhibit 9 (attached) (ECF filing notification showing service of Doc. 

108 on counsel for Lacey, Brunst, and Spear).)

The Draft itself is not a final document. Inspector Versoza used it as the starting 

point for his seizure warrant affidavits, but he would then review the underlying 

transactions to ensure the information included in the affidavits was correct. (See, e.g., Ex. 

5 at 70 (“Tracing to be completed on Monday.”).) The information included in the Draft 

still needed to be completed and finalized, which Inspector Versoza did before certifying 

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the seizure warrant affidavits and the Civil Forfeiture Complaint. 

In addition to the fact that former SA Thai did not prepare the Draft, he also did not 

rely on it in preparing for his trial testimony in this case. Instead, Thai drafted his own 

document titled “Master Table,” which the United States produced to Defendants on 

February 11, 2020. (Feb. 11, 2020, email from A. Stone to defense counsel, attached as 

Exhibit 10.) That spreadsheet contained all the notes and citations to bank records that Thai 

used in both (a) preparing the summary exhibits, and (b) preparing for his trial testimony

regarding the money laundering counts. 

After Thai’s trial testimony, he began to prepare for his potential testimony related 

to asset forfeiture. Thai referenced the Draft in the email to AUSA Boyle because the

information relates to asset forfeiture. Accordingly, and in an abundance of caution, the 

United States produced the email.

II. The Civil Seizure Affidavits and the Civil Forfeiture Complaint Disclose 

Nearly Verbatim the Contents of the Draft

The language in the Draft was incorporated nearly verbatim into the civil seizure 

affidavits and the Civil Forfeiture Complaint discussed above. To show this, the United 

States has prepared Exhibit 8. Exhibit 8 reproduces each paragraph of the Draft and 

corresponding language found in the affidavits, the complaint, and other bank records—all 

of which were either produced to Defendants in this case in discovery, or publicly filed and 

served on Defendants in the Central District of California. Simply put, Exhibit 8 shows that 

all the information contained in the Draft was previously disclosed and known to 

Defendants.

The following excerpt of Exhibit 8 is illustrative—it shows, on a line-by-line basis, 

how paragraphs 32-36 of the Draft were reproduced in nearly identical form in Exhibit 1—

Inspector Versoza’s 4/26/2018 civil seizure affidavit, produced to Defendants in July 2018 

(see Ex. 6): 

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32. Fio Bank accounts ‘2226,‘2231, ‘2230 

are located in the Czech Republic, and 

held in the name of Gold Leaf SRO. 

All funds and securities in these 

accounts are held for Backpage.com by 

a third party, Gold Leaf SRO. 

According to FERRER and the Service 

Level Agreement ("SLA") between Ad 

Tech BV, a Backpage owned company 

and Gold Leaf SRO, the funds and/or 

securities in these accounts are the 

criminally derived proceeds of 

Backpage ads, including ads promoting 

prostitution. 

10(n). SUBJECT ACCOUNT 18D: Fio 

Bank, in the Czech Republic, account 

number CZ7020100000002001002226, is 

an account held in the name of Gold Leaf 

SRO. All funds and securities in this 

account are held for Backpage.com by a 

third party, Gold Leaf SRO. 

10(o). SUBJECT ACCOUNT 18E: Fio 

Bank, in the Czech Republic, account 

number CZ7620100000002101002231, is 

an account held in the name of Gold Leaf 

SRO. All funds and securities in this 

account are held for Backpage.com by a 

third party, Gold Leaf SRO. 

10(p). SUBJECT ACCOUNT 18F: Fio 

Bank, in the Czech Republic, account 

number CZ8520100000002501002230, is 

an account held in the name of Gold Leaf 

SRO. All funds and securities in this 

account are held for Backpage.com by a 

third party, Gold Leaf SRO. 

(Ex. 1 at ¶ 10.)

66(b). SUBJECT ACCOUNTS 18D, 18E, 

and 18F are accounts held by a third party, 

Gold Leaf SRO. According to Ferrer and

Service Level Agreements ("SLA") 

between Ad Tech BV, a Backpage owned 

company and Gold Leaf SRO, which I 

have reviewed, the funds and/or securities 

in these accounts are the criminally 

derived proceeds of Backpage ads, 

including ads promoting prostitution. 

(Ex. 1 at ¶ 66.)

33. The SLAs state that 99.5% of the net 

proceeds are to be paid to Ad Tech 

BV, which is owned by Backpage. 

According to FERRER, the 

arrangement between Gold Leaf, 

66(b). The SLAs state that 99.5% of the 

net proceeds are to be paid to Ad Tech 

BV, which is owned by Backpage.

According to Ferrer, the arrangement 

between Gold Leaf, SRO, and Backpage 

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SRO, and Backpage was put into 

place to evade what he called a 

"blockade by credit card companies." 

FERRER explained that beginning 

around 2015, U.S. credit card 

companies such as MasterCard and 

Visa refused to process credit card 

payments for Backpage due to the 

negative press surrounding sex 

trafficking and prostitution content on 

Backpage. 

was put into place to evade what he called 

a "blockade by credit card companies." 

Ferrer explained that beginning around 

2015, U.S. credit card companies such as 

MasterCard and Visa refused to process 

credit card payments for Backpage due to 

the negative press surrounding sex 

trafficking and prostitution content on 

Backpage.

(Ex 1 at ¶ 66.)

34. As one of the ways around this 

"blockade," Backpage Operators set 

up agreements with foreign persons 

and partners to "franchise" websites 

for the sole purpose of accepting 

credit card payments. 

66(b). As one of the ways around this 

"blockade," Backpage Operators set up 

agreements with foreign persons and 

partners to "franchise" websites for the 

sole purpose of accepting credit card 

payments.

(Ex 1 at ¶ 66.) 

35. According to FERRER, this use of 

foreign third-parties and foreign 

accounts allowed Backpage to 

continue to accept credit card 

payments for prostitution ads while 

concealing from the credit card 

companies that the payments were for 

Backpage ads. 

66(b). According to Ferrer, this use of 

foreign third parties and foreign accounts 

allowed Backpage to continue to accept 

credit card payments for prostitution ads 

while concealing from the credit card 

companies that the payments were for 

Backpage ads.

(Ex 1 at ¶ 66.)

36. FERRER said that Gold Leaf SRO 

existed for the sole purpose of 

funneling to Backpage accounts 

otherwise prohibited credit card 

payments for Backpage ads. 

FERRER explained that these 

accounts are owned by Backpage and 

are not co-mingled with other funds, 

and are therefore subject to seizure 

and forfeiture to the United States.

66(b). Ferrer said that Gold Leaf SRO 

existed for the sole purpose of funneling 

to Backpage accounts otherwise 

prohibited credit card payments for 

Backpage ads. Ferrer explained that these 

accounts are owned by Backpage and are 

not co-mingled with other funds, and are 

therefore subject to seizure and forfeiture 

to the United States. 

(Ex 1 at ¶ 66.)

(Ex. 8 at 19-21.)

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ARGUMENT

The United States has complied with its discovery obligations. The Draft wasn’t 

Jencks and didn’t contain any Brady or Giglio information that hadn’t already been 

produced. (See Exs. 1-3.) The Draft also wasn’t subject to Rule 16. The Draft only arguably 

became discoverable when former SA Thai attached it to an email discussing his potential 

testimony related to the forfeiture phase. But the Draft itself provided Defendants with no 

new material information—Defendants were aware of everything in the document because 

it either had been produced by the United States in discovery over five years ago, or was 

included in the First Amended Consolidated Master Verified Complaint for Forfeiture filed 

by the United States in June 2020, of which all Defendants are fully aware. Defendants 

Lacey, Brunst, and Spear, through attorneys who represent them in this criminal trial, then 

filed two motions to dismiss the civil forfeiture action. (CV-18-8420-RGK-PJW, Central 

District of California, Docs. 111 and 112; see Exhibit 11, attached.) 

Accordingly, even if the Court found that the Draft should have been disclosed 

sooner, Defendants suffered zero prejudice, because all of the information contained in the 

Draft had been disclosed years ago.

I. The Draft Isn’t Jencks

Defendants argued in their oral motion to dismiss that the Draft may be Jencks of 

former SA Thai and Carl Ferrer. Those arguments do not square with the evidence. 

The Jencks Act requires the United States “to produce any statement (as hereinafter 

defined) of the witness in the possession of the United States which relates to the subject 

matter as to which the witness has testified.” 18 U.S.C. § 3500(b). “The term ‘statement’ 

. . . means—a written statement made by said witness and signed or otherwise adopted or 

approved by him.” 18 U.S.C. § 3500(e)(1).1 

1 Rule 26.2 also discusses the obligation to disclose a witness’s statement, but expands the obligation to the defense. “After a witness other than the defendant has testified 

on direct examination, the court, on motion of a party who did not call the witness, must 

order an attorney for the government or the defendant and the defendant’s attorney to 

produce, for the examination and use of the moving party, any statement of the witness that 

is in their possession and that relates to the subject matter of the witness’s testimony.” Fed. 

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The Draft isn’t a “written statement made by” Carl Ferrer. The Draft was not “signed 

or otherwise adopted or approved” by him. 18 U.S.C. § 3500. Further, all statements 

attributed to Ferrer in the Draft were produced to Defendants in the Versoza affidavits. 

(Exs. 1 & 3.) 

The Draft also isn’t Jencks for Quoc Thai. As an initial matter, former SA Thai was 

not the author of the Draft, nor did he contribute substantively to the document, so the 

document isn’t a “written statement made by” him. Defendants may argue that because 

Thai reviewed the Draft and offered some line edits and formatting suggestions he “adopted 

or approved” it, but that point is dubious. United States v. Begaye, 236 F.R.D. 448, 451-

454 (D. Ariz. 2006) (testifying agent who read and relied on another agent’s written report 

was not Jencks for the testifying witness). Assuming arguendo that Thai did “adopt or 

approve” the document, the Draft still isn’t Jencks—for two reasons. 

First, the document is a draft and wasn’t intended as a final “statement.” In United 

States v. Kaiser, 660 F.2d 724, 731-32 (9th Cir. 1981), the Ninth Circuit held that when a 

draft was “neither intended as a final statement nor [] a contemporaneously written factual 

account of what a witness said” then it wasn’t “adopted or approved” by the agent and isn’t 

producible. The court found no violation of Jencks where an agent discarded his 

handwritten rough draft of an investigative report, explaining:

The Jencks Act requires, in part, that the Government produce written 

statements made by a witness and “signed or otherwise adopted or approved 

by him.” 18 U.S.C. s 3500(e)(1). The draft of the report here was not intended as a final report. Nor was the draft similar to witness interview notes which 

are intended only to be factual accounts of what a witness said. 

Id. at 731-32 (citing United States v. Harris, 543 F.2d 1247, 1252 (9th Cir. 1976). 

In United States v. Steele, 2020 WL 4726704, at *5 (W.D. Wash. Aug. 13, 2020), 

the district court similarly held that the United States need not produce drafts of a special 

agent’s affidavit in support of a criminal complaint. The United States, relying on Kaiser, 

argued that the agent’s “drafts are not producible because ‘under a plain reading of the 

R. Crim. P. 26.2(a). A “witness’s ‘statement’ means: a written statement that the witness 

makes and signs, otherwise adopts or approves.” Fed. R. Crim. P. 26.2(f)(1). 

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statute (or Rule 26.2), a draft statement that is not signed or otherwise adopted or approved 

is not a written statement for purposes of Jencks.’” Id. The court agreed, finding that 

because the draft affidavit wasn’t “substantially different from the final version” and the 

special agent never “intended to approve or adopt earlier drafts,” the draft affidavit wasn’t 

“producible Jencks material.” Id. So too, here: the statements in the Draft aren’t 

substantially different from the finalized civil seizure affidavits and Civil Forfeiture 

Complaint discussed above (Exs. 1-3), and no agent or witness ever intended to approve 

or adopt the Draft.

Second, the Draft didn’t relate to Thai’s trial testimony. The document, as evidenced 

by its use exclusively in supporting the seizure warrants and civil forfeiture complaint, did 

not relate to the money laundering counts that Thai testified about at trial. Indeed, Thai did 

not rely on the Draft to prep for trial, but instead drafted his own document titled “Master 

Table,” which the United States produced to Defendants on February 11, 2020. (Ex. 10.)

Finally, even if the Court finds that the Draft should have been produced earlier, 

Defendants have suffered no prejudice, because they have received all this information—

nearly verbatim—from other sources, including the seizure warrant affidavits and Civil 

Forfeiture Complaint. (Exs. 1-3, 8.) See, e.g., Rosenberg v. United States, 360 U.S. 367, 

371 (1959) (“[Where] the same information that would have been afforded had the 

document been given to defendant was already in the possession of the defense by way of 

the witness’ admissions while testifying, it would deny reason to entertain the belief that 

defendant could have been prejudiced by not having had opportunity to inspect the letter.”); 

United States v. Terragna, 390 F. App’x 631, 639 (9th Cir. 2010) (“Because the interview 

notes that defendants received included [the witness’s] substantially verbatim statements, 

defendants were not prejudiced by the Government’s failure to produce formal summaries 

of those statements.”).

In sum, there was no Jencks violation, let alone any conduct sufficient to warrant 

the extreme sanctions of dismissal or stricken testimony that Defendants seek here. 

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II. Brady and Giglio Do Not Apply 

In making their oral motion to dismiss, Defendants attempted to couch the Draft’s 

recent disclosure as a Brady or Giglio violation. (See generally Transcript of the November 

8, 2023 status conference.) Defendant Brunst’s counsel argued that Carl Ferrer’s cross 

examination would have been materially different if the Draft had been disclosed 

previously. This argument strains credulity. 

An allegation that the prosecution failed to disclose material evidence is governed 

by Brady v. Maryland, 373 U.S. 83, 87, (1963). Under Brady, “[t]he government violates 

its constitutional duty to disclose material exculpatory evidence where (1) the evidence in 

question is favorable to the accused in that it is exculpatory or impeachment evidence, (2) 

the government willfully or inadvertently suppresses this evidence, and (3) prejudice 

ensues from the suppression (i.e., the evidence is ‘material’).” Jones v. Ryan, 691 F.3d 

1093, 1102 (9th Cir. 2012) (citation and quotations omitted). When evidence isn’t 

suppressed, Brady and Giglio aren’t implicated. Id.

Here, no evidence was actually suppressed, so neither Brady nor Giglio applies. In 

the draft document, there are 23 paragraphs that attribute statements to Carl Ferrer. (Ex. 5 

at ¶¶ 30, 32, 33, 35-38, 40-43, 45-47, 50, 51, 53-56, 59, 60, 65.) Each of these paragraphs 

is included nearly verbatim in Inspector Versoza’s two seizure warrant affidavits. (Exs. 1 

& 3.) Every single statement attributed to Ferrer was part of these affidavits. (See Ex. 8 at 

18-34.) These Ferrer statements have been in Defendants’ possession since November 

2018. (Exs. 6 & 7.) If anything, the two affidavits provide more detailed information about 

Ferrer’s statements than the draft document. (See Ex. 8 at ¶¶ 30, 32, 37, 42, 50, 53-54, 59.) 

Because no statements by Ferrer were suppressed—and the contents of the Draft were 

previously disclosed to Defendants years ago—neither Brady nor Giglio applies. United 

States v. Marashi, 913 F.2d 724, 734 (9th Cir. 1990) (when the substance of the information 

has already been disclosed, then the non-disclosed information is “merely cumulative 

impeachment evidence and thus [] not Brady material”); United States v. Kennedy, 890 

F.2d 1056, 1061 (9th Cir. 1989) (“no Brady violation when the undisclosed evidence was 

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cumulative to evidence presented at trial”); see also United States v. Van Brandy, 726 F.2d 

548, 551 (9th Cir. 1984) (defendant must not only make a showing that the non-disclosed 

evidence is material and favorable to defendant, but also that it has not been included in 

any report provided to defendant). 

III. Rule 16 Does Not Apply, and Defendants Suffered Zero Prejudice

Defendant’s oral motion to dismiss did not invoke Rule 16. Nevertheless, the United 

States preemptively notes that there has been no Rule 16 violation. As an initial matter, this 

Draft falls under the protection of Rule 16(a)(2). That rule “does not authorize the 

discovery or inspection of reports, memoranda, or other internal government documents 

made by an attorney for the government or other government agent in connection with 

investigating or prosecuting the case.” Fed. R. Crim. P. 16(a)(2). See also United States v. 

Amlani, 111 F.3d 705, 713 (9th Cir. 1997) (“We agree with the district court that the 

government is not obligated under Rule 16(a)(2) to turn over internal government 

documents . . . . Rule 16(a)(2) clarifies that a defendant has an interest in the actual evidence 

in the government’s control, not the government’s records of that evidence.”).

Even if the protection of Rule 16(a)(2) didn’t apply, the Draft was not discoverable 

under Rule 16. In accordance with the rule, the United States must disclose certain 

categories of information if the defendant makes a request for such information. The only 

category the Draft could possibly implicate is “documents and objects.” Fed. R. Crim. P. 

16(a)(1)(e). That section reads in pertinent part, “Upon a defendant’s request, the 

government must permit the defendant to inspect and to copy or photograph books, papers, 

documents, data . . . if the item is within the government’s possession, custody, or control 

and: (i) the item is material to preparing the defense.” But the Draft wasn’t material to trial 

preparation regarding the money laundering counts, and former SA Thai did not rely on it 

in creating the summary exhibits or preparing for his testimony. 

Finally, even if the Draft could be deemed material, all the information contained in 

the Draft was previously produced and known to Defendants. (See Exs. 1-3, 8.) 

Accordingly, Defendants suffered no prejudice. See, e.g., United States v. Christensen, 624 

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F. App’x 466, 481-82 (9th Cir. 2015) (“any Rule 16 violation was harmless because the 

[fact] was common knowledge”); United States v. Gee, 695 F.2d 1165, 1168 (9th Cir. 1983) 

(finding that failure to provide transcript of a tape-recorded conversation pre-trial did not 

prejudice defendant’s rights at trial, when defendant had the tape recording). 

Simply put, the United States complied with its disclosure and discovery 

obligations, and Defendants face no prejudice. For these same reasons, Defendants’ 

alternative requests for relief should denied. In addition to seeking dismissal of the entire 

case, Defendants seek partial dismissal, striking Thai’s testimony, and/or an evidentiary 

hearing. None of these requests are warranted or needed, given the clear fact that 

Defendants already had the Draft’s information in their possession—as Exhibit 8 

demonstrates. Production of the Draft before trial would have failed to change the evidence 

presented at trial in any meaningful way, since Defendants were already armed with all the 

facts identified in the Draft.

In these circumstances, Defendants’ motion should be denied. 

CONCLUSION

For the foregoing reasons, Defendants’ oral motion to dismiss or for other relief

should be denied. 

Respectfully submitted this 13th day of November, 2023.

 GARY M. RESTAINO United States Attorney District of Arizona

 NICOLE M. ARGENTIERI

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

s/Andrew C. Stone 

KEVIN M. RAPP

MARGARET PERLMETER

PETER KOZINETS

ANDREW STONE

DANIEL BOYLE

 Assistant U.S. Attorneys 

 AUSTIN M. BERRY

Trial Attorney 

Case 2:18-cr-00422-DJH Document 1966 Filed 11/13/23 Page 12 of 13
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CERTIFICATE OF SERVICE

I hereby certify that on November 13, 2023, 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 CM/ECF registrants who have entered their appearance 

as counsel of record.

s/ Daniel Parke

Case 2:18-cr-00422-DJH Document 1966 Filed 11/13/23 Page 13 of 13