Exhibit N

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 1 of 120
United States District Court

___________CENTRAL_ ___ DISTRICT OF CALIFORNIA_______ ________

TO: United States Postal Service (USPIS) and any Authorized Officer of the United States, Affidavit(s) having been made before 

me by POSTAL INSPECTOR LYNDON A. VERSOZA who has reason to believe that in the District of Arizona there is now certain 

property which is subject to forfeiture to the United States, namely (describe the property to be seized)

Any and all funds held in Republic Bank of Arizona Accounts: #11101889, #11402592; #11101938; 

#11002912 and #11402500

which is (state one or more bases for seizure under United States Code)

subject to seizure and forfeiture under 18 U.S.C. § 981 (a)(1)(A) and (C)

 

concerning a violation of Title 18 United States Code, Sections 1952, 1956, and 1957. 

I am satisfied that the affidavit(s) and any recorded testimony establish probable cause to believe that the property so described is subject 

to seizure and that grounds exist for the issuance of this seizure warrant.

Republic Bank of Arizona is ordered to deliver said funds immediately and forthwith upon presentation of this warrant to the law 

enforcement agent serving the warrant, in the form of a cashier's check made payable to the United States Marshals Service. 

YOU ARE HEREBY COMMANDED to seize within 14 days the property specified, serving this warrant and making the seizure in the 

daytime - 6:00 A.M. to 10:00 P.M., leaving a copy of this warrant and receipt for the property seized, and prepare a written inventory 

of the property seized and promptly return this warrant to the undersigned judicial officer as required by law. 

 

In the Matter of the Seizure of

(Address or Brief description of property or premises to be seized)

Any and all funds held in Republic Bank of 

Arizona Accounts: #11101889, #11402592; 

#11101938; #11002912 and #11402500 

 

AMENDED SEIZURE WARRANT

CASE NUMBER: 2:18-MJ-00722 

 3/28/18 6:30 p.m.

Date and Time Issued

Hon. PATRICK J. WALSH, U.S. Magistrate Judge

Name and Title of Judicial Officer 

Los Angeles, California

City and State

Signature of Judicial Officer 

JOHN J. KUCERA/smb

Case 2:18-mj-00722-DUTY *SEALED* Document 2-1 *SEALED* Filed 03/28/18 Page 1 of 2 

 Page ID #:162

Case 2:18-mj-00722-DUTY *SEALED* Document 4 *SEALED* Filed 03/28/18 Page 1 of 2 

 Page ID #:172

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 2 of 120
RETURN

DATE WARRANT RECEIVED DATE AND TIME WARRANT EXECUTED COPY OF WARRANT AND RECEIPT FOR ITEMS LEFT 

WITH

INVENTORY MADE IN THE PRESENCE OF

INVENTORY OF PROPERTY SEIZED PURSUANT TO THE WARRANT

CERTIFICATION

I declare under penalty of perjury that I am an officer who executed this warrant and that this inventory is correct and will be

returned through a filing with the Clerk’s Office.

Date: 

 Executing Officer’s Signature

 

 Printed Name and Title

 

Case 2:18-mj-00722-DUTY *SEALED* Document 2-1 *SEALED* Filed 03/28/18 Page 2 of 2 

 Page ID #:163

Case 2:18-mj-00722-DUTY *SEALED* Document 4 *SEALED* Filed 03/28/18 Page 2 of 2 

 Page ID #:173

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 3 of 120
Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 1 of

 117 Page ID #:174

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 4 of 120
AFFIDAVIT IN SUPPORT OF SEIZURE WARRANT

I, Lyndon A. Versoza, being duly sworn, hereby depose and state 

as follows: 

I. TRAINING AND EXPERIENCE

1. I am a United States Postal Inspector employed by the 

United States Postal Inspection Service (“USPIS”), Los Angeles 

Division, in Los Angeles, California, where I have served since 

June 2005. Currently, I am responsible for investigating 

criminal violations of money laundering and structuring laws,

such as when United States Postal Service (“USPS”) Money Orders 

or the United States Mail are used as a means to launder or 

structure funds. During my career as a Postal Inspector, I have 

participated in or investigated financial violations including

money laundering, darknet investigations, digital currency 

investigations, structuring, bank, wire and mail fraud, and 

identity theft. In addition, I have received both formal and 

informal training from USPIS and other agencies regarding money 

laundering and financial crimes. For approximately five years 

prior to investigating money laundering, I was assigned to 

investigate child exploitation and sex trafficking. In that

assignment, I worked both independently and in a task force 

where I led and participated in investigations related to crimes 

involving the exploitation of children and sex trafficking.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 2 of 117 

 Page ID #:46

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 2 of

 117 Page ID #:175

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 5 of 120
-2-

2. Prior to my service as a U.S. Postal Inspector, I

attended the University of Southern California in Los Angeles, 

where, in 2001, I received a bachelor’s degree. While in

college, I was the website administrator for a non-profit media 

company in Los Angeles where, among other things, I learned 

about domain names, domain name servers, and remote hosting.

Following college, from 2002 to 2005, I served as a law 

enforcement officer with the U.S. Immigration and Naturalization 

Service, which later became U.S. Customs and Border Protection.

There, among other things, I worked on cases involving human 

smuggling and international sex trafficking.

3. I am familiar with the facts and circumstances 

described herein. This affidavit is based upon my personal 

involvement in this investigation, my training and experience, 

and information obtained from various law enforcement personnel 

and witnesses, including information that has been reported to 

me either directly or indirectly. This affidavit does not 

purport to set forth my complete knowledge or understanding of 

the facts related to this investigation. Unless specifically 

indicated otherwise, all conversations and statements described 

in this affidavit are related in substance and part only. All 

figures, times, and calculations set forth herein are 

approximate.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 3 of 117 

 Page ID #:47

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 3 of

 117 Page ID #:176

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 6 of 120
-3-

II. SUMMARY AND PURPOSE OF AFFIDAVIT

4. This affidavit is made in support of applications for

warrants to seize all funds held in certain SUBJECT ACCOUNTS and 

certain SUBJECT DOMAINS, all owned or controlled by 

“Backpage.com” (referred to herein as “Backpage”), associated 

entities, and the owners and operators of each.

A. Background

5. This case is being investigated by the USPIS, the 

Federal Bureau of Investigation (“FBI”) and the Internal Revenue 

Service-Criminal Investigation (“IRS-CI”), with assistance from 

the Los Angeles Joint Regional Intelligence Center.

6. The focus of the investigation has been on violations 

by Backpage, its associated entities, and the owners and 

operators of each of Title 18, United States Code, Sections 

1952(a)(3)(A) and (b)(i)(1) (Interstate and Foreign Travel in 

Aid of Racketeering Enterprise); and Title 18 U.S.C. §§ 1956 and 

1957, (Money Laundering).

7. From speaking with other agents in this investigation, 

and reviewing emails, internal documents, and other records

related to this investigation, I know the following:

a. Backpage.com, LLC, incorporated in Delaware in 

2004, is an internet-based company that allows customers to post 

on-line classified advertisements. These advertisements include

sections dedicated to a variety of matters, including adult,

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 4 of 117 

 Page ID #:48

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 4 of

 117 Page ID #:177

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 7 of 120
-4-

automotive, community, dating, jobs, local places, musicians, 

rentals and services. Backpage receives between 75 million to 

100 million unique internet visitors per month.

b. Backpage realizes profits in the tens of millions 

of dollars per year from adult advertisement. Historically,

adult ads, where Backpage advertisers post sex trafficking ads,

constitute less than ten percent of all advertisements posted on 

the website. However, the adult ads generate over 90 percent of

Backpage’s revenue. In short, Backpage derives almost all its

revenue and profits from adult service ads, including 

advertising for sex trafficking.1

c. In or about 2004, operators Michael Lacey 

(“Lacey”), James Larkin (“Larkin”), and Carl Ferrer (“Ferrer”) 

created Backpage. There were also two minority owners; John

Brunst (“Brunst”), who owned 5.67 percent; and Scott Spear 

1 According to Backpage accounting records, for the period May 1 

to May 31, 2014, over 90% of Backpage’s revenues derived from 

what they characterized as “adult entertainment.” Backpage’s

internal documents suggest that this 90% figure has been 

consistent since its 2004 inception.

For example, between October 6, 2014, and May 31, 2015, 

Backpage grossed almost $105 million from advertising “adult 

entertainment.” During this same period, Backpage grossed only 

$1.6 million from all other advertisements combined. Assuming

that Backpage has accurately estimated that 90% of its revenues 

are generated from “adult” and “escort” ads, Backpage has 

generated as much as $500 million in prostitution-related

revenue since 2004.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 5 of 117 

 Page ID #:49

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 5 of

 117 Page ID #:178

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 8 of 120
-5-

(“Spear”), who owned 4.09 percent. From 2004 until 2015, Lacey 

and Larkin oversaw the website’s policies and strategic 

direction. In 2015, Lacy and Larkin purportedly sold all or 

substantially all of their interests in Backpage to Ferrer.2

However Lacey and Larkin retained significant control over the 

website, and both Lacey and Larkin continue to receive tens of 

millions of dollars of annual distributions of Backpage revenue.

d. While not an original owner, Ferrer was one of 

the original officers of Backpage, having initially served as

Backpage’s vice-president, and later as CEO. Ferrer is also the 

CEO of several Backpage related entities in the Netherlands,

including “Website Technologies,” “Amstel River Holdings,” and

“Ad Tech BV.”

e. Michael Thomas Gage (“Gage”) has no formal 

position at Backpage, but is the President, Chief Executive 

Officer, Treasurer, and Secretary of another Backpage controlled 

entity, “Posting Solutions,” a wholly owned subsidiary of 

Backpage that receives payments from Backpage advertisers.

According to his social media profile, Gage is also the Chief 

2 From my review of financial records related to Ferrer’s 2015 

agreement to purchase Backpage, it appears that, through a 

series of loans from other Backpage Operators to be repaid by 

Ferrer, Ferrer agreed to purchase Backpage for approximately 

$400 million.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 6 of 117 

 Page ID #:50

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 6 of

 117 Page ID #:179

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 9 of 120
-6-

Financial Officer of Website Technologies. Based on emails he 

has sent and wire transfer information, Gage appears to control 

much of the international and domestic financial transactions of 

Backpage and its related entities.

f. Daniel Hyer (“Hyer”) at one time was the Sales 

and Marketing Director of Backpage. He remains an account 

signatory for Backpage controlled entities, including Website

Technologies.

8. Throughout this affidavit, the individuals identified

in paragraphs 7(c) through (f), along with others not named in 

this affidavit, are collectively referred to as the “Backpage 

Operators.”

9. Based on a review of publicly available materials 

obtained in the course of the investigation, and my review of 

the Backpage website, I have learned the following:

a. The majority of the paid advertisements on the 

Backpage website relate to prostitution activities in violation 

of 18 U.S.C. §§ 1591 and 1252.

b. As further described below, Backpage itself, as 

well as its operators, who are in control of the SUBJECT 

ACCOUNTS and SUBJECT DOMAINS (as those terms are defined below),

is in the business of promoting the trafficking of children and 

adults for sex. Sex trafficking of adults is a violation of 18 

U.S.C. § 1952, and sex trafficking of children is a violation of 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 7 of 117 

 Page ID #:51

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 7 of

 117 Page ID #:180

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 10 of 120
-7-

18 U.S.C. 1591, each of which statutes is a Specified Unlawful 

activity (“SUA”) within the meaning of federal law. (see 18

U.S.C. § 1956(c)(7)(vii)).

c. The SUBJECT ACCOUNTS (all of which are located in 

the United States) have received wire transfers from places 

outside of the United States or have received funds traceable to 

wire transfers from places outside of the United States, which

funds Backpage would then use to promote sex trafficking, in 

violation of 18 U.S.C. § 1956(a)(2)(A) (International Money 

Laundering). Some of the SUBJECT ACCOUNTS have received 

transfers or deposits in excess of $10,000 traceable to the SUA, 

in violation of 18 U.S.C. § 1957 (Money Laundering Spending 

Statute).

d. The SUBJECT DOMAINS are registered by “ASCIO 

TECHNOLOGIES INC” DBA “NETNAMES,” a domain registrar that 

manages the reservation of internet domain names for Backpage.

A domain registrar serves to ensure that a registered domain 

name, like each of the SUBJECT DOMAINS, is not double sold.

Additionally, a domain registration will allow the owner of the 

domain to direct internet traffic to a company’s webserver. The 

SUBJECT DOMAINS have been acquired and maintained with funds 

traceable to the money laundering scheme described herein,

specifically with funds from SUBJECT ACCOUNT 1, and the SUBJECT 

DOMAINS are the mechanism Backpage uses to promote the

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 8 of 117 

 Page ID #:52

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 8 of

 117 Page ID #:181

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 11 of 120
-8-

prostitution and sex trafficking activity described below.

10. From my review of publically available materials and 

bank statements obtained in the course of this investigation, I 

have learned the following:

a. Verizon Digital Media Services in Los Angeles, 

California (“Verizon”) provides various media solutions for

internet related activities, including web acceleration, 

commerce acceleration, cloud security and video 

streaming. Based on my training and experience, I know that 

these type of services would be necessary for a high-volume

website like Backpage to operate efficiently and handle internet 

traffic without delay for the end user.

b. Beginning when the account was opened in February 

2017, and continuing until at least December 2017, SUBJECT 

ACCOUNT 1 has directed $570,530 dollars to Verizon to pay for 

Backpage related expenses. 

B. SUBJECT ACCOUNTS

11. This affidavit is offered in support of applications

for warrants to seize all funds held in the following U.S. bank 

accounts (hereinafter referred to collectively as the “SUBJECT

ACCOUNTS”):

a. SUBJECT ACCOUNT 1: Prosperity Bank account number 

216887188, is a business bank account held in the name of

“Posting Solutions LLC.” Gage is identified in the records of 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 9 of 117 

 Page ID #:53

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 9 of

 117 Page ID #:182

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 12 of 120
-9-

the account as the President, Chief Executive Officer, 

Treasurer, and Secretary of Posting Solutions LLC, and is the

sole signatory on SUBJECT ACCOUNT 1. As further described 

below, SUBJECT ACCOUNT 1 is one of Backpage’s main operating 

accounts, used to receive funds from customers paying for 

Backpage advertising, including advertising to promote sex 

trafficking.

b. SUBJECT ACCOUNT 2A: Compass Bank Account number 

6738453873 is a business bank account held in the name of

“Cereus Properties LLC.” Spear is the sole signatory on the 

account.

c. SUBJECT ACCOUNT 2B: Compass Bank Account number 

6745023825 is held in the name of Brunst.

d. SUBJECT ACCOUNT 3A: National Bank of Arizona

Account number 45000178 is a checking account held in the name 

of Spear.

e. SUBJECT ACCOUNT 3B: National Bank of Arizona

Account number 45000151 is a checking account held in the name 

of Spear.

f. SUBJECT ACCOUNT 3C: National Bank of Arizona

Account number 46003645 is a checking account held in the name 

of Spear.

g. SUBJECT ACCOUNT 4: Live Oak Bank Account Number 

75600050642523 is a checking account held in the name of Spear.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 10 of 117

 Page ID #:54

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 10 of

 117 Page ID #:183

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 13 of 120
- 10 -

h. SUBJECT ACCOUNT 5A: Ascensus Broker Dealer 

Services Account Number 367726943-01 is an account held in the 

name of Natasha Spear, Spear’s adult daughter.

i. SUBJECT ACCOUNT 5B: Ascensus Broker Dealer 

Services account Number 549755280-01 is an account held in the 

name of Natasha Spear.

j. SUBJECT ACCOUNT 6: First Federal Savings & Loan 

of San Rafael account number 51103620 is an account held in the 

name of Lacey.

k. SUBJECT ACCOUNT 7A: Republic Bank of Arizona

account number 11101889 is an account held in the name of 

Larkin.

l. SUBJECT ACCOUNT 7B: Republic Bank of Arizona

account number 11402592 is an account held in the name of 

Larkin.

m. SUBJECT ACCOUNT 7C: Republic Bank of Arizona

account number 11002912 is an account held in the name of 

Ferrer.

n. SUBJECT ACCOUNT 7D: Republic Bank of Arizona

account number 11402500 is an account held in the name of 

Ferrer.

o. SUBJECT ACCOUNT 7E: Republic Bank of Arizona

account number 11101938 is an account held in the name of 

Larkin.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 11 of 117

 Page ID #:55

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 11 of

 117 Page ID #:184

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 14 of 120
- 11 -

p. SUBJECT ACCOUNT 8A: Bank of America Account 

number 0000483072278225 is a checking account held in the name 

of Troy Larkin, James Larkin’s adult son.

q. SUBJECT ACCOUNT 8B: Bank of America Account 

number 0000005091387054 is an account held in the name of Ramon 

Larkin, James Larkin’s adult son.

r. SUBJECT ACCOUNT 8C: Bank of America Account 

number 0000001294879342 is a checking account held in the name 

of Hyer.

s. SUBJECT ACCOUNT 8D: Bank of America Account 

number 0000488039130071 is a savings account held in the name of 

Hyer.

t. SUBJECT ACCOUNT 9: San Francisco Fire Credit 

Union Account Number 75600050642523 is held in the name of 

Lacey.

u. SUBJECT ACCOUNT 10: Ally Bank Account Number 

2153056292 is an account held in the name of Spear.

v. SUBJECT ACCOUNT 11: Branch Banking and Trust Bank

account number 1440001710218 is an account held in the name of

Gage.

w. SUBJECT ACCOUNT 12A: Green Bank Account number 

3094832 is an account held in the name of Ferrer.

x. SUBJECT ACCOUNT 12B: Green Bank Account number 

5501194293 is an account held in the name of Ferrer.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 12 of 117

 Page ID #:56

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 12 of

 117 Page ID #:185

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 15 of 120
- 12 -

y. SUBJECT ACCOUNT 13: Plains Capital Bank account 

number 5501801098 is an Interest on Lawyers Trust Account 

(“IOLTA”) held in the name of Phillip Linder, identifying April

Ferrer (who is or was Carl Ferrer’s spouse) as the sole

beneficiary.

C. SUBJECT DOMAINS

12. This affidavit also supports an application for a 

warrant to seize the following domain names managed by “Ascio

Technologies,” incorporated in Delaware, the domain registrar 

for the SUBJECT DOMAINS, (hereinafter, collectively referred to 

as “SUBJECT DOMAINS”):

a. atlantabackpage.com

b. backpage.be

c. backpage.com

d. backpage.com.br

e. backpage.cz

f. backpage.dk

g. backpage.ee

h. backpage.es

i. backpage.fi

j. backpage.fr

k. backpage.gr

l. backpage.hu

m. backpage.ie

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 13 of 117

 Page ID #:57

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 13 of

 117 Page ID #:186

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 16 of 120
- 13 -

n. backpage.it

o. backpage.lt

p. backpage.mx

q. backpage.net

r. backpage.no

s. backpage.pl

t. backpage.pt

u. backpage.ro

v. backpage.si

w. backpage.sk

x. backpage.us

y. backpage-insider.com

z. bestofbackpage.com

aa. bestofbigcity.com

bb. bigcity.com

cc. chicagobackpage.com

dd. denverbackpage.com

ee. newyorkbackpage.com

ff. phoenixbackpage.com

gg. sandiegobackpage.com

hh. seattlebackpage.com

ii. tampabackpage.com

III. APPLICABLE LAW

13. There is probable cause to believe that the SUBJECT 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 14 of 117

 Page ID #:58

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 14 of

 117 Page ID #:187

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 17 of 120
- 14 -

ACCOUNTS and SUBJECT DOMAINS are subject to seizure and 

forfeiture by the United States under the following provisions:

a. 18 U.S.C. § 981(a)(1)(A), because those SUBJECT

ACCOUNTS and SUBJECT DOMAINS are involved in, and traceable to, 

one or more transactions or attempted transactions in violation 

of 18 U.S.C. § 1956(h) (Conspiracy to Launder Money), 18 U.S.C. 

§ 1956(a)(2) (International Money Laundering for Promotion), and 

18 U.S.C. § 1957 (Financial Transactions Involving Illicit 

Proceeds). Pursuant to 18 U.S.C. § 981(a)(1)(A), any property 

involved in a transaction, or attempted transaction, in

violation of 18 U.S.C. §§ 1956 or 1957, or any property 

traceable to such property, is subject to forfeiture to the 

United States; and

b. 18 U.S.C. § 981(a)(1)(C), because those SUBJECT

ACCOUNTS and SUBJECT DOMAINS constitute and are derived from 

proceeds traceable to one or more violations of 18 U.S.C. § 

1956(h), 18 U.S.C. § 1956(a)(2), and 18 U.S.C. § 1957. 

14. Title 18 U.S.C. § 1956 prohibits, among other things,

financial transactions involving the proceeds of SUAs --

committed or attempted (1) with the intent to promote further 

predicate offenses; (2) with the intent to evade taxation; (3) 

knowing the transaction is designed to conceal the source, 

location, ownership or control of the proceeds; or (4) knowing 

the transaction is designed to avoid anti-laundering financial 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 15 of 117

 Page ID #:59

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 15 of

 117 Page ID #:188

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 18 of 120
- 15 -

reporting requirements. 18 U.S.C. § 1956(h) prohibits two or 

more parties agreeing to accomplish the unlawful purpose of 

money laundering.

15. Title 18 U.S.C. § 1957 prohibits a party from 

knowingly engaging in a monetary transaction in excess of 

$10,000 with property that is criminally derived from some SUA.

16. Title 18 U.S.C. § 1956(a)(2) (International Money 

Laundering for Promotion) makes it a crime to transport, 

transmit, or transfer, or attempt to transport, transmit, or 

transfer, monetary instruments or funds (including funds that 

are not criminal proceeds) from the United States to or through 

a place outside the United States, or to the United States from 

or through a place outside the United States, with the intent to 

promote some SUA, as that term is defined in 18 U.S.C. § 

1956(c)(7).

17. The “Travel Act,” 18 U.S.C. § 1952(a), an SUA, 

prohibits, in part, the use of the mail or any facility in 

interstate or foreign commerce with the intent to otherwise 

promote, manage, establish, carry on, or facilitate the 

promotion, management, establishment, or carrying on of any 

unlawful activity, by any person who thereafter performs or 

attempts to perform an act to promote, manage, establish, carry 

on, or facilitate the promotion, management, establishment and 

carrying on of such unlawful activity. “Unlawful Activity,” as 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 16 of 117

 Page ID #:60

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 16 of

 117 Page ID #:189

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 19 of 120
- 16 -

defined in 18 U.S.C. § 1952(b), includes prostitution offenses 

in violation of the laws of the state in which such acts are 

committed or in violation of the laws of the United States.

Prostitution is illegal in the State of California. (See, e.g.,

Cal. Penal Code § 647(b).)

18. Sex trafficking of juveniles or any person by means of

force, fraud or coercion, is a violation of 18 U.S.C. § 1591, an 

SUA.

IV. DIGITAL CURRENCY/BITCOIN

19. Digital currency (also known as crypto-currency) is 

generally defined as an electronic-sourced unit of value that 

can be used as a substitute for fiat currency (i.e., currency 

created and regulated by a sovereign government). It exists

entirely on the Internet and is not stored in any physical form.

It is not issued by any government, bank, or company, but is

instead generated and controlled through computer software

operating on a decentralized peer-to-peer network. Digital 

currency is not illegal in the United States and may be used for 

legitimate financial transactions. However, it is often used to

conduct illegal transactions, such as the sale of controlled

substance, or as in this investigation, to purchase ads to 

promote prostitution.

20. Bitcoin is a type of digital currency accepted by 

Backpage. Bitcoin payments are recorded on a public ledger that 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 17 of 117

 Page ID #:61

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 17 of

 117 Page ID #:190

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 20 of 120
- 17 -

is maintained by peer-to-peer verification, and is thus not 

maintained by a single administrator or entity. Individuals can 

acquire Bitcoins either by “mining” them or purchasing Bitcoins

from other individuals. An individual can “mine” Bitcoins by 

allowing his/her computing power to verify and record the 

Bitcoin payments into a public ledger. Individuals are rewarded 

for this by being given newly created Bitcoins. Bitcoins can be 

bought and sold in fractions.

21. Backpage also accepts other digital currencies, 

including Litecoin, Bitcoin Cash, and Ether. Sometimes called 

“alt-coins,” because they are alternatives to Bitcoins, these 

digital currencies were created after Bitcoin to address 

perceived weaknesses or problems with Bitcoin technology. Based

on my review of Backpage transactions, the majority of 

Backpage’s digital currency transactions are in Bitcoin.

22. An individual can send and receive Bitcoins through 

peer-to-peer digital transactions or by using a third-party

broker. Such transactions can be done on any type of computer, 

including laptop computers and smart phones.

23. Digital currency is generally stored in digital 

“wallets,” which essentially store the access codes that allows 

individuals to conduct digital currency transactions on the 

public ledger. To access digital currency on the public ledger, 

an individual must use a public address (or “public key”) and a 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 18 of 117

 Page ID #:62

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 18 of

 117 Page ID #:191

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 21 of 120
- 18 -

private address (or “private key”). The public address can be 

analogized to a bank account number, while the private key is 

like a password used to access an online account.

24. Even though the public addresses of those engaging in 

Bitcoin transactions are recorded on the public ledger, the true 

identities of the individuals or entities behind the public 

addresses are not. If, however, an individual or entity is 

linked to a public address, it would be possible to determine 

what transactions were conducted by that individual or entity.

For these reasons, digital currency transactions are described

as “pseudonymous,” meaning they are partially anonymous.

V. STATEMENT OF PROBABLE CAUSE

A. Buying a Backpage Ad

25. In February 2018, I visited Backpage.com and, posing

as an advertising purchaser, engaged in the regular process of 

posting an ad in the Backpage “Dating” section, which is one of 

the places on Backpage.com where prostitution ads are commonly

found. Through this process, I learned the following:

a. A person looking to post an advertisement on 

Backpage (an “advertiser”) must first create an account. Once 

an account is created, the advertiser clicks on a link called 

“Post an ad,” which will then toggle certain categories

regarding where the ad should be posted (e.g., “Los Angeles,” 

“Riverside,” etc.) and under what category the ad should appear 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 19 of 117

 Page ID #:63

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 19 of

 117 Page ID #:192

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 22 of 120
- 19 -

(e.g., “Dating,” “Adult,” etc.). The advertiser also has the 

option to post pictures and videos. In the adult sections, 

opting to post in more than one geographical area, or opting to 

post more frequently occurring ads will increase the 

advertisement price. Currently, Backpage.com charges $5 per ad

posted in the adult sections. In some of the non-adult and nondating sections I checked, there was no charge at all to post an 

ad.

b. Once an advertiser selects the desired options,

he or she is required to enter a phone number, a link to a 

social media page (such as Facebook), and an email address. The

Backpage website claims to verify the advertiser’s phone number 

before he or she can continue on to actually purchasing an ad.

c. In order to pay for Backpage ads, an advertiser

must first buy “credits.” Backpage offers several ways for an 

advertiser to acquire credits:

i. A Backpage advertiser may mail gift cards, 

checks, and money orders to “Posting Solutions” at a P.O. Box in

Dallas, Texas (as further described below, this P.O. Box is

associated with Posting Solutions and SUBJECT ACCOUNT 1).3

3 I have reviewed the cash purchase of USPS money orders 

subsequently directed to this P.O. Box. Between September 2014 

and June 2016, several millions of dollars in money orders were

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 20 of 117

 Page ID #:64

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 20 of

 117 Page ID #:193

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 23 of 120
- 20 -

ii. Backpage directly accepts credit card 

payment through a third-party credit card payment processor.

iii. Backpage also accepts several types of 

digital currency (specifically, Backpage accepts Bitcoin,

Bitcoin Cash, Litecoin, and Ethereum). If the advertiser

selects this option, Backpage provides a digital currency wallet 

address where the advertiser can send the electronic transfer of 

the digital currency.

iv. Backpage also accepts cash, but only through

third party payment processors. Based on information gathered 

during this investigation, I believe that once the third-party

payment processor receives cash, it converts the cash into 

digital currency and then electronically transfers that digital

currency to a Backpage digital currency wallet.

26. Digital Currency is processed through the subject 

accounts in the following way:

a. When Backpage receives digital currency, it will

aggregate the digital currency and then transfer it to a thirdpurchased in what appears to have been structured transactions 

(i.e., transactions carried out in a manner intended to avoid 

certain reporting requirements that USPS maintains for money 

order purchases greater than $3000). Based on my review, 

hundreds of these money orders include email addresses with

words consistent with prostitution, such as “sex” or “sexy.”

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 21 of 117

 Page ID #:65

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 21 of

 117 Page ID #:194

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 24 of 120
- 21 -

party exchanger like GoCoin.4

b. In exchange for the digital currency, the exchanger

transfers U.S. dollars from its foreign bank accounts into

Backpage operating accounts, such as SUBJECT ACCOUNT 1. The

exchanger, if it so elects, may then sell its Bitcoin on various 

Bitcoin markets.

27. I reviewed records obtained from GoCoin. From this

review, I estimate that between 5 to 10 percent of the ads posted 

on Backpage.com are ads within the Central District of California 

(including Los Angeles and Orange Counties). For example, between

January 10 and February 3, 2016, approximately 500,000 ads were 

posted on Backpage.com and paid for with Bitcoin, for which 

Backpage received over $3,840,000 in revenue. Of these 

approximately 500,000 ads, approximately 28,400 were posted only

in LosAngeles.Backpage.com, Ventura.Backpage.com, 

SanLuisObispo.Backpage.com, OrangeCounty.Backpage.com, and 

SanGabrielValley.Backpage.com. These specific ads generated

approximately $184,479 in revenue.

4 GoCoin is a digital currency exchanger that converts Bitcoin,

Litecoin and another digital currency into fiat currency, like 

the U.S. Dollar or the Euro. GoCoin is owned by Manx 

Broadcasting Corporation, based in the Isle of Man. GoCoin has 

offices in Singapore and Santa Monica, California and appears to 

hold bank accounts in several countries outside the United 

States.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 22 of 117

 Page ID #:66

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 22 of

 117 Page ID #:195

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 25 of 120
- 22 -

B. Backpage Promotion of Prostitution and Sex Trafficking

28. I have reviewed several Backpage ads that were used to 

sell minors for sex and forcibly traffic adult women for sex. I 

have also reviewed the criminal records of certain of the pimps 

and sex traffickers, most of whom were convicted after having used 

Backpage to advertise their victims. From this review, I learned 

the following:

a. Between 2014 and 2015, a pimp sold S.F., a minor

girl, for sex. The pimp advertised S.F. on Backpage’s “Escort”

section in the Los Angeles area of California and in Arizona. The

ad contained phrases such as “New In Town” and “Sexy Dark Asain 

Bombshell with a Nice & Tight {Booty}.” The ad selling S.F. on 

Backpage included multiple pictures showing her legs, stomach,

shoulders and buttocks. Later, the pimp was arrested and 

convicted on state sex trafficking charges, and sentenced to 196 

years imprisonment.

b. Between 2014 and 2015, the same pimp sold A.C., a 

minor girl, for sex. In November 2014, at the age of 17, A.C. was 

first sold for sex through a Backpage ad using phrases such as 

“NEW IN TOWN,” “sexy sweet,” and “sweet like honey but super hot 

like fire.” The Backpage ad selling A.C. included pictures of her 

showing her legs, stomach, shoulder, and buttocks, and posed her

in sexually provocative positions.

c. Between November 2015 and December 2015, in a 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 23 of 117

 Page ID #:67

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 23 of

 117 Page ID #:196

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 26 of 120
- 23 -

different incident, a pimp drove two women and four minor girls

(T.S., S.L., K.O., and R.W.) from Columbus, Ohio to a hotel in St. 

Charles, Missouri. The next day, the pimp told the girls to post 

ads on Backpage.com. Some of the girls took calls and engaged in

paid sex acts with Backpage customers who responded to the ads.

The ads the girls posted included pictures of themsitting on the 

bed showing their buttocks. Another image I saw was of a naked 

girl’s body pressed against a mirror. Other pictures appeared

more mundane, such as images of girls posing clothed in front of a 

mirror. However, these ads used phrases like “I’m sweet as a 

treat maybe even sweeter” and “not a lot need to be said. my pic 

are 100% real.” In 2017, this pimp was convicted on sex 

trafficking charges and a federal court sentenced him to 300 

months in prison.

d. In or around 2010, in Washington, J.S., a minor 

girl, was sold for sex through the use of Backpage ads. J.S.’s 

pimp drafted the ads that were placed a Backpage that contained

words and phrases such as, “W’E’L’L_W’O’R’T’H_I’T***^***150HR” and 

“IT WONT TAKE LONG AT ALL.” The ads also included pictures of 

J.S. in provocative positions showing her breasts and buttocks.

On March 29, 2011, the pimp who sold J.S. for sex was sentenced to 

over 26 years imprisonment on charges related to sex trafficking.

e. Between in or around 2011 and 2016, a female 

victim, D.O., who was between the ages of 14 and 19 during those 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 24 of 117

 Page ID #:68

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 24 of

 117 Page ID #:197

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 27 of 120
- 24 -

years, was sold for sex through Backpage ads. D.O.’s female pimp 

instructed D.O. that Backpage was the safest place to advertise 

because Backpage did not require age verification. D.O.’s 

Backpage ads included words and phrases that were indicative of 

prostitution, such as “roses” (money) and “back door” (anal sex).

Some of the customers who responded to D.O.’s Backpage ads forced 

D.O. to perform sexual acts at gunpoint, choked her to the point 

of having seizures, and gang-raped her.5

29. I have reviewed documents and reports from multiple 

state and government agencies and authorities regarding Backpage’s 

promotion of sex trafficking and prostitution. From these 

reports, and from my review of internal Backpage correspondence 

following Backpage management receiving these reports, I am aware 

5 Using these examples, I also reviewed financial transactions 

for some of these ads. Using email addresses and other 

identifiers associated with the Backpage ads, I reviewed GoCoin 

records for some of these transactions. From these records, I 

found bitcoin payments associated with the email addresses used 

to post the ads, which transactions were processed by GoCoin.

For example, in the case involving victims S.F. and A.C. 

(described in paragraphs 28(a) and (b)) prosecuted in Arizona, 

the bitcoin payments for these ads were made in November and 

October 2015. In the case involving T.S., S.L., K.O., and R.W. 

(described in paragraph 28(c)) prosecuted in Missouri, the 

bitcoin payments were made in October and November 2015. As 

described in paragraph 48 of this affidavit, between December 

2015 and June 2016, over 130 wires from Slovakia from GoCoin, 

totaling over $16.8 million was sent to a Website Technologies 

account at Branch Bank & Trust Company account number 

1440001712008. Between December 2015 and October 2016, 32 wires 

totaling $48 million were sent from the BBT Account to a Cereus 

Properties Account 9361116211 at Arizona Bank and Trust, which 

made its way into SUBJECT ACCOUNTS 3A, 3B, and 3C.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 25 of 117

 Page ID #:69

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 25 of

 117 Page ID #:198

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 28 of 120
- 25 -

that all levels of Backpage management are aware of Backpage’s

role in promoting criminal activity. For example:

a. On September 21, 2010, a group of state attorneys 

general wrote a letter to Backpage observing that “ads for 

prostitution—including ads trafficking children—are rampant on the 

site,” and arguing that “[b]ecause Backpage cannot, or will not, 

adequately screen these ads, it should stop accepting them 

altogether.” The state AGs acknowledged that this step would 

cause Backpage to, ”lose the considerable revenue generated by the 

adult services ads,” but stated that “no amount of money can 

justify the scourge of illegal prostitution, and the misery of the 

women and children who will continue to be victimized in the 

marketplace provided by backpage.”

b. Following this letter, on September 25, 2010, 

Ferrer wrote an email explaining that Backpage was unwilling to 

delete ads that included terms indicative of prostitution because 

doing so would “piss[] off a lot of users who will migrate 

elsewhere” and force Backpage to refund those customers’ fees.

c. In January 2017, the U.S. Senate Subcommittee on 

Permanent Investigations (“Subcommittee”) conducted a lengthy 

investigation into sex trafficking and Backpage. I have reviewed 

the Subcommittee’s 50-page report entitled “Backpage.com’s Knowing 

Facilitation of Online Sex Trafficking.” This report concluded, 

among other things, that virtually all of Backpage’s “adult” ads 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 26 of 117

 Page ID #:70

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 26 of

 117 Page ID #:199

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 29 of 120
- 26 -

are actually solicitations for illegal prostitution services and 

that “Backpage has maintained a practice of altering ads before 

publication by deleting words, phrases, and images indicative of 

criminality, including child sex trafficking . . . . Those 

practices served to sanitize the content of innumerable 

advertisements for illegal transactions—even as Backpage 

represented to the public and the courts that it merely hosted 

content others had created.” In response to the Subcommittee’s 

report, Backpage purported to shut down the “adult” section of its 

website. However, based on my review of several thousands of 

Backpage ads, I believe that the prostitution ads simply migrated 

to other sections of the website, where they remain to this day.

d. On August 5, 2011, Backpage received a letter from 

the mayor of Seattle. This letter warned, “Seattle Police have 

identified an alarming number of juvenile prostitutes advertised 

on Backpage.com since January 2010,” and explained that Backpage 

was dissimilar from other companies whose products and services 

are “occasionally or incidentally” utilized by criminals because 

“[y]our company is in the business of selling sex ads” and “your 

services are a direct vehicle for prostitution.” The letter also 

recommended that Backpage require in-person age verification for 

all of the “escorts” depicted in its ads. Based on knowledge 

gained through this investigation, I do not believe that Backpage 

has ever instituted an in-person age verification.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 27 of 117

 Page ID #:71

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 27 of

 117 Page ID #:200

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 30 of 120
- 27 -

30. I have reviewed internal documents, emails, and

correspondence among Backpage employees and management. From 

those emails I have learned that Backpage has instituted policies 

and procedures designed to maintain its promotion of sex 

trafficking and prostitution, but which “sanitize” some of the 

language Backpage customers use to advertise in order to make the 

advertising of sex trafficking less overt. From my review of 

Backpage documents, I know that Backpage refers to this practice 

as “moderation.” For example:

a. In April 2008, Ferrer wrote an email explaining 

that, although he was “under pressure to clean up phoenix’s adult 

content,” he was unwilling to delete prostitution ads because 

doing so “would put us in a very uncompetitive position with 

craig[slist]”6 and result in “lost pageviews and revenue.” Thus, 

Ferrer instructed Backpage’s technical staff to edit the wording 

of such ads by removing particular terms that were indicative of 

prostitution, and then allow the remainder of the ad to be 

featured on Backpage’s website.

b. On October 8, 2010, a Backpage manager sent an 

email threatening to fire any Backpage employee who acknowledged, 

in writing, that a customer was advertising prostitution:

6 Craigslist is a competing internet based advertising company 

that features classified ads.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 28 of 117

 Page ID #:72

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 28 of

 117 Page ID #:201

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 31 of 120
- 28 -

“Leaving notes on our site that imply that we’re aware of 

prostitution, or in any position to define it, is enough to lose 

your job over. . . . This isn’t open for discussion. If you don’t

agree with what I’m saying completely, you need to find another 

job.”

c. On October 16, 2010, the same Backpage manager 

again sent an email to a large group of Backpage employees that 

contained two attachments providing guidance on how to “moderate” 

ads. The first was a PowerPoint presentation that displayed a 

series of 38 nude and partially-nude photographs, some of which 

depicted graphic sex acts. Next to each picture was an 

instruction as to whether it should be approved or disapproved by 

a Backpage moderator. These instructions included “Approve. Nude 

rear shots are okay as long the model is not exposing her anus or 

genitalia.” and “Approve. Rear shot okay. Transparent wet 

panties okay.” The second was an Excel spreadsheet identifying 50 

terms (all of which were indicative of prostitution) that should 

be “stripped” from ads before publication. The Backpage manager

concluded the email by stating, “[I]t’s the language in ads that’s 

really killing us with the Attorneys General. Images are almost 

an afterthought to them.”

d. On October 16, 2010, the same Backpage manager sent

a separate internal email explaining, “I’d like to still avoid 

Deleting ads when possible,” that “we’re still allowing phrases 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 29 of 117

 Page ID #:73

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 29 of

 117 Page ID #:202

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 32 of 120
- 29 -

with nuance,” and that “[i]n the case of lesser violations, 

editing should be sufficient.”

e. On October 25, 2010, Ferrer sent an email 

acknowledging that the “[i]llegal content removed” through 

Backpage’s moderation processes was “usually money for sex act.”

This email also explained that, after the “sex act pics are 

removed,” the “ad text may stay.”

f. On October 27, 2010, a different Backpage manager

sent an internal email stating that Backpage was “editing 70 to 

80%” of the ads it received from customers. 

g. On June 7, 2011, Ferrer received an inquiry from a 

law enforcement official about a particular ad that included the 

term “amber alert.” In response, Ferrer acknowledged this might 

be “some kind of bizarre new code word for an under aged person.”

Ferrer then forwarded this exchange to a Backpage manager and

instructed that the term “amber alert” be added to Backpage’s 

“strip out” list. I believe that this email indicates that

Backpage did not require all future ads involving this particular 

coded term for the prostitution of a child to be blocked from 

Backpage, but merely required that such ads be edited before 

publication.

h. On August 31, 2011, Backpage managers exchanged

emails in which they discussed a list of 100 “solid sex for money 

terms.” Later emails indicate that this list of terms would 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 30 of 117

 Page ID #:74

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 30 of

 117 Page ID #:203

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 33 of 120
- 30 -

change but, in general, the list prohibited use of certain terms 

that Backpage management and employees too closely identified with 

the obvious promotion of sex trafficking and prostitution.

i. Based on knowledge gained during this investigation

and my training and experience, I believe that this manager 

acknowledged that a large proportion of the ads originally 

submitted by Backpage’s customers contained text and pictures that 

were indicative of sex trafficking. Nevertheless, Backpage would

still publish those ads after editing them to appear less obvious 

in promoting illegal activity. Using the words the Backpage 

manager used in the email described in paragraph 30(d) above, I

believe that Backpage sex trafficking ads have adapted to 

Backpage’s moderation policy by using “phrases with nuance” when 

promoting sex trafficking. Also, based on knowledge gained during 

this investigation, and my training and experience, I believe 

that, following the implementation of “moderation,” Backpage’s

list of prohibited terms needed to change and evolve to adjust to 

the reality of Backpage advertisers’ use of new code words to

promote prostitution. That is, once a coded word or phrase not 

previously associated with sex-for-money would become too familiar 

and associated with certain sex trafficking activities in the 

Backpage community of advertisers, Backpage’s “moderation” policy 

would need to adapt by adding such words or phrases to the 

“blocked” list or risk being too obvious in its promotion.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 31 of 117

 Page ID #:75

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 31 of

 117 Page ID #:204

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 34 of 120
- 31 -

31. Based on my review of several thousand Backpage ads and

internal Backpage documents and correspondence, I believe that 

Backpage’s policy of “moderation” only caused ads explicitly 

promoting sex trafficking to become more coded and implicit in the 

ads’ purpose. I have reviewed several thousand Backpage ads 

posted in the various “adult” categories of Backpage (including 

“massage,” “dating,” “escort” and others). From this review, I 

learned the following:

a. Well over half of the Backpage classified ads in

these categories use terms and phrases that, in my training and 

experience, I believe to be consistent with sex trafficking and 

prostitution. These terms and phrases include, “roses” (money, 

e.g., “150 roses/half hour”), “in-call” (where the customer goes 

to the prostitute’s location), “outcall” (where the prostitute 

goes to the customer’s location), “GFE” (girlfriend experience), 

and “PSE” (porn star experience). 

b. Other Backpage ads use language that can be mostly

free of coded language, but that include sexually provocative 

pictures. In my training and experience, the sexually suggestive 

images included in these ads are typical of ads for prostitution.

For example, one such ad posted in Backpage’s Los Angeles dating 

section depicted images of a woman on a bed with her buttocks 

presented in a sexual manner; another included a picture of a 

woman’s cleavage; others included pictures of women posing in 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 32 of 117

 Page ID #:76

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 32 of

 117 Page ID #:205

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 35 of 120
- 32 -

sexual positions wearing lingerie and pictures of a woman bending

over revealing her naked buttocks.

c. Based on knowledge gained through this 

investigation, and my training and experience, I believe that 

Backpage’s policy of moderation has had its intended effect.

Moderation has caused and allowed otherwise neutral or innocuous 

terms to be understood within the Backpage community as coded 

language for sex trafficking and prostitution. Because of this 

evolving use of coded terms, a reader of such ads who is familiar 

with the particular vocabulary used in Backpage “adult” ads may 

readily identify coded terms and images indicating an ad for 

prostitution, while an uninitiated reader may not understand these 

terms at all, or at least not as being associated with sex-formoney.

32. Notwithstanding many Backpage advertisements’ use of 

seemingly innocuous language in promoting prostitution, based on 

my conversations with law enforcement officers around the country 

and from my review of law enforcement officers’ statements and 

reports regarding Backpage, I believe that the majority of 

Backpage ads that appear in the traditionally “adult” categories 

(such as “escort,” “massage,” or “body rubs”) are actually 

advertisements promoting sex trafficking or prostitution. For

example, in August 2015, the Detective-Sergeant in charge of the 

Seattle Police Department’s Vice/High Risk Victims Unit and Human 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 33 of 117

 Page ID #:77

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 33 of

 117 Page ID #:206

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 36 of 120
- 33 -

Trafficking Task Force made a sworn statement that provided, in

pertinent part,

Since 2014, the Seattle Police Department has made arrests 

that include hundreds of related charges, such as charges 

for patronizing a prostitute/sexual exploitation, hundreds 

of charges for prostitution, dozens of charges [of]

Promoting Prostitution, up to 100 charges for Commercial 

Sexual Abuse against a Minor and have investigated dozens 

of rape reports involving victims who are prostitutes and 

one murder of a prostitute. As a result of hundreds of 

investigations, the Seattle Police Department Vice/High 

Risk Victims Unit has found that Backpage.com has become 

the primary web site in Seattle/Washington State for those 

looking to solicit a prostitute, post prostitution ads or 

traffic prostitutes and minors.

Vice/High Risk Victims Unit Detectives also make use of 

this site to respond to ads posted under the ‘escorts’ and 

‘body rubs’ categories posing as male customers and 

successfully arrest females and males who charge 

undercover operatives money in exchange for sex. To date, 

no Detective within the Seattle Police Department’s

Vice/High Risk Victims Unit has ever found a legitimate

‘escort’, (person who charges simply for companionship 

with no offer of sex) or ‘masseuse’, (person offering 

legitimate and licensed massage therapy rather than sex) 

while responding to ads placed in these categories on

Backpage.com.

As stated previously, every time the Seattle Police 

Department Vice/High Risk Victims Unit has responded to an 

ad in the adult section of Backpage.com, we have found 

that the ad was a posting for illegal activity. The 

Seattle Police Department Vice/High Risk Victims Unit has

not once found that the individual posting or responding 

to one of our decoy ads in the adult section of 

Backpage.com was in fact seeking any type of innocent, 

legal activity. In my professional experience, the adult 

section of Backpage.com not only contains ads for illegal 

activity, including prostitution, solicitation and 

trafficking, but it is a primary source for such ads and 

is well known for that purpose in the sex trafficking 

industry in the city of Seattle and State of Washington.

Additionally, in August 2015, the Sergeant Detective who is

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 34 of 117

 Page ID #:78

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 34 of

 117 Page ID #:207

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 37 of 120
- 34 -

Commander of the Human Trafficking Unit (“HTU”) for the Boston, 

Massachusetts Police Department made a sworn statement that

provided, in pertinent part, 

Since 2009, the [HTU] has made numerous arrests that 

include enticement of a minor into prostitution, sex 

trafficking of a minor, sex trafficking of an adult, 

forcible rape . . . and sex for a fee for soliciting a 

prostitute.

As a result of investigations, the HTU has found that 

Backpage.com is the go-to Web site in Boston for those 

looking to solicit a prostitute, post prostitution ads, 

and recruit and traffic young women and minors. The 

detectives have been able to identify numerous would-be

exploiters by setting up decoy ads and responding to ads 

on the site. The have arrested pimps, traffickers and 

buyers who facilitate prostitution and fuel the harmful 

and violent sex trade. Backpage.com is the number one 

site that detectives go to in order to look for underage 

girls who are on the run and are being commercially

sexually exploited by pimps.

Since 2010, the HTU has arrested over 100 buyers of sex of 

both adults and minors through Backpage.com ads 

exclusively in hotel stings.

Since 2013, 12 individuals have been charged in federal 

court for sex trafficking of both minors and adults. In 

all these aforementioned cases, Backpage.com played a 

pivotal role in facilitating these crimes.

Detectives of the HTU often get tips about illegal 

activity concerning ads posted on the escort, adult and 

massage sections of Backpage.com. In almost every case 

detectives have found that in fact there was illegal 

activity which resulted in fines, arrests, or further 

investigations of sex trafficking.

Therefore, in my professional experience as a law 

enforcement officer for over thirty years, the adult 

section of Backpage.com not only contains ads for illegal 

activity, including prostitution, solicitation and 

trafficking, but it is also the primary source for such 

ads and well known for that purpose in the sex trafficking

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 35 of 117

 Page ID #:79

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 35 of

 117 Page ID #:208

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 38 of 120
- 35 -

industry in Boston, Massachusetts. Backpage.com’s adult 

section provides a vehicle and anonymity for its users who 

exploit and traffic young women and girls. . . . It is my 

humble opinion that the adult section of Backpage.com 

serves no legitimate service and nearly all the cases we 

find associated with it involve pimp controlled 

prostitution.

33. Almost all “adult”-type Backpage ads list phone numbers 

or emails for a potential customer to use to make contact with the 

advertiser. I have compared a sample of phone numbers and emails 

found within Backpage ads with phone numbers and emails that 

frequently are included in the memo section of some of the checks 

that Backpage advertisers use to pay Backpage for those ads. From 

my review, I have found that very often the same number and/or 

email appears in multiple Backpage ads as the contact information 

to make an appointment. For example:

a. A $25 USPS Money Order purchased on June 15, 2017, 

in Duarte, California, made payable to “Posting Solutions PO BOX

802426, Dallas, TX,” and thereafter deposited into SUBJECT ACCOUNT

1, included writing on the money order listing a phone number and 

the words “Dulce Latina.” From a search of Backpage ads, I found 

almost 800 advertisements listing the same phone number found on

the $25 USPS Money Order.

b. A $20 USPS Money Order purchased in Sacramento, 

California, and later deposited into SUBJECT ACCOUNT 1, included 

writing listing a phone number and the words “love my lips.” From

a search of Backpage ads, I found almost 1300 advertisements

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 36 of 117

 Page ID #:80

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 36 of

 117 Page ID #:209

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 39 of 120
- 36 -

listing the same phone number found on the $20 USPS Money Order.

c. A $150 Wells Fargo Bank Money Order, purchased in 

Arizona, and made payable to “Posting Solutions,” included an

email and the words, “red hot stuff”. From an internet search of 

the email address listed on this $150 money order, I found 

advertisements on several female escort websites that directed 

customers to contact an Arizona phone number ending in 2397. I 

then searched Backpage.com for this phone number and found 

approximately 760 ads that included this same phone number. My 

review of these Backpage ads revealed images indicative of 

prostitution. For example, one such ad posted on Backpage’s 

“massage” section included sexual images such as a woman lying on 

a bed wearing lingerie and a woman laying naked on her stomach.

One of the ads describes, “Pampering provider | Body Rub Massage | 

Body Shampoo | Body Scrub | 4 hands | Walk ins or appointment.”

From my training and experience, I know that legal massage 

advertisements do not typically depict sexual images. This 

advertisement depicted sexual images and included terms like “4 

hands,” which I know to be coded language describing a massage 

given to a customer by two women. Such advertisements are often 

indicative of prostitution.

34. Despite the fact that several thousand Backpage ads 

shared the exact same phone number or email address to contact the 

advertiser, these same ads included sexually suggestive images of 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 37 of 117

 Page ID #:81

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 37 of

 117 Page ID #:210

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 40 of 120
- 37 -

hundreds of different women. Based on my training and experience, 

multiple different women do not share the same email address or 

phone number when posting ads for dating. Rather, in my training 

and experience, such ads are consistent with ads posted by pimps 

or prostitution agencies that are using the same phone number or 

email to advertise several different women (or girls) to 

prospective prostitution clients.

35. On March 28, 2018, a grand jury returned a 93 count 

indictment charging certain Backpage Operators with criminal 

violations of 18 U.S.C. § 371 (Conspiracy), § 1952 (Travel Act—

Facilitation of Prostitution), § 1956 (Money Laundering), § 1957 

(Financial Transactions Involving Illicit Proceeds), and including

Forfeiture Allegations pursuant to 18 U.S.C. §§ 981 and 982 

(seeking criminal forfeiture of, among other assets, the SUBJECT 

ACCOUNTS and the SUBJECT DOMAIN NAMES). A copy of that indictment 

is attached hereto (as Exhibit A) and incorporated herein as 

though fully set forth.

C. THE SUBJECT ACCOUNTS

1. SUBJECT ACCOUNT 1

i. Foreign Transfers Into SUBJECT ACCOUNT 1

36. While Backpage accepts payments for ads from thirdparties, for the purpose of this affidavit, I will focus on 

advertising payments made via the Posting Solutions’ P.O. BOX

using cash, money orders, or digital currency.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 38 of 117

 Page ID #:82

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 38 of

 117 Page ID #:211

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 41 of 120
- 38 -

37. From my review of Posting Solutions’ application for the 

USPS Dallas, Texas P.O. BOX, I learned that it was registered to 

“Website Technologies, LLC/Backpage.com.” Also listed on the P.O.

BOX Application were the names of several Backpage Operators,

including Ferrer.

38. I have reviewed bank records for SUBJECT ACCOUNT 1.

Based on my review, I know the following:

a. On February 15, 2017, Posting Solutions LLC, 

located at 13601 Preston Rd., Ste. 801E, Dallas, Texas 75240,

opened Prosperity Bank account number 216887188 (SUBJECT ACCOUNT 

1, which lists Gage as the sole signatory on the account).

b. Gage is the President, Chief Executive Officer,

Treasurer and Secretary of Posting Solutions LLC.

39. Based on my knowledge of this investigation, having

spoken to law enforcement personnel, and my review of the 

financial records, when an advertiser purchases an ad for 

prostitution using digital currency, the payments to Backpage (and 

certain subsequent expenditures) then proceed in the following 

manner:

a. A “poster” of a prostitution ad on backpage.com

would pick a payment method, for example, through Bitcoin payments

as previously described above.

b. The poster would already have Bitcoin or Backpage 

would direct the poster to a third-party exchanger in order to buy 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 39 of 117

 Page ID #:83

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 39 of

 117 Page ID #:212

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 42 of 120
- 39 -

Bitcoin.

c. Backpage would then provide the poster with a 

wallet address to send the specific amount of Bitcoin.

d. The poster would receive credit to then post ads on 

Backpage.

e. In batches, generally valued in hundreds of 

thousands of dollars, Backpage would sell the Bitcoin to a third 

party exchanger, frequently “GoCoin,” in order to convert the 

Bitcoin into U.S. or foreign currency, which GoCoin generally 

holds in foreign bank accounts.

f. GoCoin would wire funds from these foreign accounts 

to either 1) Backpage controlled foreign accounts, or 2) Backpage 

controlled domestic operating accounts.

g. Backpage operators would hold these receiving 

accounts in the names of entities controlled by Backpage, such as 

Ad Tech BV, Posting Solutions (SUBJECT ACCOUNT 1 is held in the 

name of Posting Solutions), Website Technologies, or Cereus

Properties (SUBJECT ACCOUNT 2A is held in the name of Cereus 

Properties).

h. These funds that originated from foreign 

transactions would be used to pay for services, like Verizon in 

Los Angeles, or would be transferred to Backpage Operators’ 

accounts and accounts held in their family members’ names.

40. I have reviewed records of wire transfers from countries 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 40 of 117

 Page ID #:84

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 40 of

 117 Page ID #:213

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 43 of 120
- 40 -

outside the United States deposited into the SUBJECT ACCOUNT 1.

Just for the period of August 1 through September 1, 2017, SUBJECT 

ACCOUNT 1 received over $2.7 million in wire transfers from

outside the United States. For example:

a. On or about August 16, 2017, a company called 

“Binary Trading SG PTE LTD” (“Binary Trading”) wired $535,500 from

an account in Singapore into SUBJECT ACCOUNT 1. Based on my 

review of records related to this transaction, Binary Trading is a 

name used by GoCoin.7

b. On or about August 17, 2017, Binary Trading wired 

another $528,500 from a Singapore account into SUBJECT ACCOUNT 1.

c. On or about August 30, 2017, a company named

“TRILIX PTE LTD,” listing the same Singapore address as Binary 

Trading and GoCoin, in four wires ranging from $385,450 to 

$492,250, sent approximately $1,717,750 from a Singapore account 

into SUBJECT ACCOUNT 1. Memo lines from these wires list “GC” or

“GC FOR INTERNET SERVICES.” I understand “GC” to mean GoCoin.

ii. SUBJECT ACCOUNT 1 Payments for Backpage Operations

41. I have reviewed outgoing payments from SUBJECT ACCOUNT 1

and found that substantial percentages of these payments are for

the operation of Backpage.com. For example, between July and

7 Further, according to GoCoin’s website, GoCoin maintains

offices at the Singapore address listed on the $535,500 wire

from “Binary Trading.”

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 41 of 117

 Page ID #:85

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 41 of

 117 Page ID #:214

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 44 of 120
- 41 -

October, 2017, SUBJECT ACCOUNT 1 wired over $1.1 million to pay 

for the following:

a. Between July and October 2017, SUBJECT ACCOUNT 1

wired $570,530 to Verizon Digital Media Services in Los Angeles.

b. On August 4, 2017, SUBJECT ACCOUNT 1 wired $4,137 

to “Netnames,” also known as ASCIO, to pay for the registration

renewal of all the SUBJECT DOMAINS, including Backpage.com.

c. In August 2017, SUBJECT ACCOUNT 1 sent numerous 

automated clearinghouse payments to “Netchex Tax Prep Clients” 

totaling over $437,000. From a review of their website, I learned 

Netchex is a human resources company that provides payroll and 

other such services to Backpage.

d. Within a one-week period beginning on August 2, 

2017, SUBJECT ACCOUNT 1 wired approximately $77,800 to S&W Payroll 

Services. An online search of S&W Payroll indicated that S&W 

Payroll is owned by Netchex. As stated above, Netchex is a human

resource service, and S&W Payroll appears to be Netchex’s payroll

division.

e. On August 11, 2017, SUBJECT ACCOUNT 1 wired 

$5,319.79 to the Telesign Corporation, located in Marina del Ray, 

California. According to their website, Telesign is a 

communications platform that delivers security for websites.

f. On August 18, 2017, SUBJECT ACCOUNT 1 wired $1,497 

and $6,984, respectively, to two separate data backup companies

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 42 of 117

 Page ID #:86

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 42 of

 117 Page ID #:215

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 45 of 120
- 42 -

for Backpage’s on-line data backup.

42. Based on my review of bank records for SUBJECT ACCOUNT 1 

throughout the existence of the account, these types of 

transactions and expenditures were typical. 

2. SUBJECT ACCOUNT 2A

i. Transfers From SUBJECT ACCOUNT 1

43. From my review of bank documents, I have learned that 

SUBJECT ACCOUNT 2A is a Compass Bank business bank account owned 

by “Cereus Properties LLC,” identifying Spear as the sole 

signatory. My review revealed that this account was funded with 

transfers from SUBJECT ACCOUNT 1. On average, during each month

of 2017, SUBJECT ACCOUNT 1 transferred several hundred thousand 

dollars into SUBJECT ACCOUNT 2A. For example:

a. On July 25, 2017, SUBJECT ACCOUNT 1 sent two wire 

transfers totaling about $566,562.47 to SUBJECT ACCOUNT 2A.

b. On August 8, 2017, SUBJECT ACCOUNT 1 sent a wire 

totaling $62,198.51 to SUBJECT ACCOUNT 2A.

c. On August 31, 2017, SUBJECT ACCOUNT 1 sent a wire 

transfer totaling $487,491.45 to SUBJECT ACCOUNT 2A.

d. On September 15, 2017, SUBJECT ACCOUNT 1 sent a wire 

transfer totaling $91,672.67 to SUBJECT ACCOUNT 2A.

e. On October 2, 2017, SUBJECT ACCOUNT 1 sent a wire 

transfer totaling $471,766 to SUBJECT ACCOUNT 2A.

ii. Foreign Transfers into SUBJECT ACCOUNT 2A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 43 of 117

 Page ID #:87

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 43 of

 117 Page ID #:216

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 46 of 120
- 43 -

44. I have reviewed financial records from a foreign bank

in the Netherlands (the “Foreign Account”). I have also 

reviewed emails related to this account. From my review of 

these records, I learned the following: 

a. The Foreign Account was opened in March 2015 and 

is held in the name of Ad Tech BV, a Netherlands based company,

and identifies Ferrer as the CEO and Gage as the CFO.

b. From March 2015 through November 2017, Foreign

Account A received millions of dollars from Binary Trading SG 

PTE, Limited, the same company GoCoin used to wire funds into

SUBJECT ACCOUNT 1. In an April 4, 2017, email to employees of 

the bank that maintains the Foreign Account, Gage explained,

Binary Capital is our trading partner, they hold money in 

trust for Go Coin [sic]. Rather than incurring 3 sets of 

wire fees which make our transactions unprofitable, they 

act as our agent and disburse payments directly from our

trust account to our merchant.

c. During this same period, Foreign Account A wire

transferred several million dollars into SUBJECT ACCOUNT 2A.

For example, an April 25, 2017, an email from Gage to 

individuals at the bank holding the Foreign Account directed the 

bank to wire “USD $2,337,048” to SUBJECT ACCOUNT 2A.

Thereafter, I reviewed a wire record and confirmed that on April 

25, 2017, the Foreign Account wired $2,337,048 into SUBJECT 

ACCOUNT 2A, as Gage directed in his email. In reviewing the 

records, I found the following additional wires sent to SUBJECT 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 44 of 117

 Page ID #:88

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 44 of

 117 Page ID #:217

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 47 of 120
- 44 -

ACCOUNT 2A:

i. In December 2016, the Foreign Account wired

approximately $1 million dollars to SUBJECT ACCOUNT 2A.

ii. On February 28, 2017, the Foreign Account 

wired $2,324,390 into SUBJECT ACCOUNT 2A.

iii. On March 30, 2017, the Foreign Account A 

wired $2,247,858 into SUBJECT ACCOUNT 2A.

iv. On May 31, 2017, the Foreign Account wired

$2,335,076 to SUBJECT ACCOUNT 2A.

v. On June 28, 2017, the Foreign Account A 

wired $2,324,390 to SUBJECT ACCOUNT 2A.

vi. July 27, 2017, the Foreign Account A wired

$10,928 to SUBJECT ACCOUNT 2A.

iii. SUBJECT ACCOUNT 2A Payments for Backpage Operations

45. I then reviewed SUBJECT ACCOUNT 2A records for 

payments to promote Backpage operations. From March through

December 2017, SUBJECT ACCOUNT 2A paid over $9,000 to “Cox

Communications,” an internet services company that provides 

voice-over-internet phone and cable services. I believe that 

Backpage uses Cox Communications to facilitate its internet 

presence and promote its sale of prostitution advertising.

3. SUBJECT ACCOUNT 2B

46. I reviewed records SUBJECT ACCOUNT 2A and SUBJECT 

ACCOUNT 2B. On February 2, 2018, SUBJECT ACCOUNT 2A wired

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 45 of 117

 Page ID #:89

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 45 of

 117 Page ID #:218

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 48 of 120
- 45 -

transferred $135,956.59 into SUBJECT ACCOUNT 2B. I am aware of 

no other funding sources for SUBJECT ACCOUNT 2B.

4. SUBJECT ACCOUNTS 3A, 3B, 3C

47. I have reviewed records for SUBJECT ACCOUNT 3A as well 

as the following accounts: Branch Banking & Trust account 

number 1440001712008, belonging to Website Technologies (as

detailed above, a Backpage controlled entity), held in Arizona

(“BBT Account”); Arizona Bank & Trust account number 9361116211 

belonging to Cereus Properties, held in Arizona (“AZBT

Account”). From this review, I learned the following:

a. Between December 14, 2015, and January 15, 2016,

in approximately 26 wires, a GoCoin account in Slovakia 

transferred over $2.5 million to the BBT Account in the United 

States.

b. On January 15, 2016, the BBT account wired 

$189,571 to Verizon in Los Angeles, California, in payment for 

Backpage internet services.

c. Between January 21, 2016, and August 31, 2016, in

approximately 27 wires, the BBT Account transferred

approximately $48 million to the AZBT Account. 

d. Between March 1, 2016, and July 1, 2016, the AZBT 

Account wired $892,426 into SUBJECT ACCOUNT 3A.

48. According to records for SUBJECT ACCOUNTS 3A, 3B, and 

3C:

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 46 of 117

 Page ID #:90

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 46 of

 117 Page ID #:219

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 49 of 120
- 46 -

a. On September 14, 2017, SUBJECT ACCOUNT 2A wired

$50,162.05 into SUBJECT ACCOUNT 3A.

b. On October 12, 2017, SUBJECT ACCOUNT 3A wired

approximately $21,500 into SUBJECT ACCOUNT 3B.

c. On January 5, 2018, SUBJECT ACCOUNT 3A wired

approximately $600,000 into SUBJECT ACCOUNT 3C.

5. SUBJECT ACCOUNT 4

49. From my review of the records for SUBJECT ACCOUNT 4

(belonging to Spear), I learned that on or about March 16, 2016, 

SUBJECT ACCOUNT 3A transferred $250,000 into SUBJECT ACCOUNT 4 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 47 of 117

 Page ID #:91

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 47 of

 117 Page ID #:220

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 50 of 120
- 47 -

as an opening deposit. On March 20, 2018, Live Oak Bank 

confirmed that these funds have remained in SUBJECT ACCOUNT 4 

since the account was opened.

6. SUBJECT ACCOUNT 5A and 5B

50. I have reviewed financial records related to SUBJECT 

ACCOUNTS 5A and 5B, held in the name of Natasha Spear, Scott

Spear’s adult daughter. From this review, I learned the

following:

a. On February 23, 2017, SUBJECT ACCOUNT 3A wired

approximately $50,000 into SUBJECT ACCOUNT 5A.

b. On the February 23, 2017, SUBJECT ACCOUNT 3A 

wired $50,000 into SUBJECT ACCOUNT 5B.

7. SUBJECT ACCOUNT 6

51. From my review of financial records related to SUJBECT

ACCOUNTS 2A, 2B and 6, I learned the following:

a. On October 2, 2017, SUBJECT ACCOUNT 2A wired

approximately $297,795 into SUBJECT ACCOUNT 6.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 48 of 117

 Page ID #:92

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 48 of

 117 Page ID #:221

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 51 of 120
- 48 -

8. SUBJECT ACCOUNTS 7A through 7E

52. From my review of financial records of SUBJECT

ACCOUNTS 2A and 2B, 7A through 7D, and 12A, I learned the

following:

a. On July 6, 2017, SUBJECT ACCOUNT 2A wired

$971,651.51 into SUBJECT ACCOUNT 7A.

b. On July 28, 2017, SUBJECT ACCOUNT 7A wired

$400,000 into SUBJECT ACCOUNT 7B.

53. From my review of financial records of SUBJECT

ACCOUNTS 1 and 7C, and those concerning the Veritex Bank account 

ending in -1462, held in the name of Posting Solutions (“Account

-1462”),8 I learned the following:

a. On January 13, 2017 and January 20, 2017, a GoCoin 

account in Singapore wired a total of approximately $1,318,800 

into Account -1462.

b. In February 2017, Account -1462 wired a total of 

$5,395 to Verizon, in Los Angeles.

c. On August 8, 2017, SUBJECT ACCOUNT 1 wired $62,000 

into SUBJECT ACCOUNT 12A. 

8 Veritex Bank is a U.S. bank located in Dallas, Texas. Posting 

Solutions opened Veritex Bank account -1462 on or about January 

5, 2017.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 49 of 117

 Page ID #:93

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 49 of

 117 Page ID #:222

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 52 of 120
- 49 -

d. On November 3, 2017, SUBJECT ACCOUNT 12A wired

$100,000 to SUBJECT ACCOUNT 7D.

9. SUBJECT ACCOUNTS 8A, 8B, 8C, and 8D

54. From my review of the records for SUBJECT ACCOUNTS 2A

and 2B, 8A, and 8B, I learned the following:

a. On February 2, 2018, SUBJECT ACCOUNT 2A wired

$28,337 into SUBJECT ACCOUNT 8A.

b. Also on February 2, 2018, SUBJECT ACCOUNT 2A

wired $28,337 into SUBJECT ACCOUNT 8B.

55. From my review of SUBJECT ACCOUNTS 1, 8C, and 8D, I 

learned the following:

a. On August 2 and August 8, 2017, SUBJECT ACCOUNT 1 

wired $33,700 and $44,000, respectively, to S&W Payroll, a

company Backpage uses to pay its employees.

b. Between August 11, 2017, and December 1, 2017, 

S&W Payroll wired a total of $207,125.81 into SUBJECT ACCOUNT 

8C.

c. Between November 3, 2017, and December 8, 2017, 

SUBJECT ACCOUNT 8C wired $57,500 into SUBJECT ACCOUNT 8D.

10. SUBJECT ACCOUNT 9

56. From my review of the records for SUBJECT ACCOUNTS 2A

2B, and 9, I learned that on February 2, 2018, SUBJECT ACCOUNT 

2A wired $734,603.70 into SUBJECT ACCOUNT 9.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 50 of 117

 Page ID #:94

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 50 of

 117 Page ID #:223

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 53 of 120
- 50 -

11. SUBJECT ACCOUNT 10

57. From my review of records for SUBJECT ACCOUNTS 2A and

10, I learned that on February 2, 2018, SUBJECT ACCOUNT 2A wired

$94,154.89 into SUBJECT ACCOUNT 10.

12. SUBJECT ACCOUNT 11

58. From my review of SUBJECT ACCOUNTS 1, 8C, 8D, and 11, 

as well as Account -1462 (as described above, a Posting

Solutions’ Veritex Bank account), I learned the following:

a. On January 4, 2017, GoCoin’s Singapore account

wired $489,500 into Account -1462, and on January 20, 2017, 

GoCoin’s Singapore account directed two additional wires, for 

$358,150 and $470,150, respectively, into Account -1462 (for a 

total of $1,317,800 wired from GoCoin’s Singapore account into 

Account -1462).

b. On January 24, 2017, Account -1462 wired

approximately $1.3 million into S&W Payroll. 

59. On January 27, 2017, an S&W Payroll account wired a

total of $9,913.53 into SUBJECT ACCOUNT 11.

13. SUBJECT ACCOUNTS 12A and 12B

60. From my review of financial records for SUBJECT

ACCOUNTS 1, 12A, and 12B, I learned the following:

a. On August 8, 2017, SUBJECT ACCOUNT 1 wired

$62,000 into SUBJECT ACCOUNT 12A.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 51 of 117

 Page ID #:95

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 51 of

 117 Page ID #:224

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 54 of 120
- 51 -

61. On December 8, 2017, SUBJECT ACCOUNT 12A wired $20,000

into SUBJECT ACCOUNT 12B.

14. SUBJECT ACCOUNT 13

62. From my review of financial records for SUBJECT

ACCOUNTS 1, 12A, and 13, I learned the following:

a. In January 2017, SUBJECT ACCOUNT 1 wired $62,000 

into SUBJECT ACCOUNT 12A. 

b. On August 16, 2017, SUBJECT ACCOUNT 12A wired 

$20,000 into SUBJECT ACCOUNT 13.

15. SUBJECT DOMAINS

63. From my review of records from Ascio Technologies

(“ASCIO”), the domain registrar for the SUBJECT DOMAINS, I 

learned the following:

a. ASCIO is a domain registrar that manages the 

reservation of internet domain names for Backpage, and ASCIO is

the registrar for over 300 domain names registered by Ferrer and 

Backpage.com, LLC.

b. On or about August 4, 2017, SUBJECT ACCOUNT 1 

wired $4,147 to ASCIO/WMB Inc. as payment for the renewal of the 

SUBJECT DOMAINS. From my training and experience and review of 

online sources, I know that, in general, to reach a website on 

the Internet, a person types an address into a web browser or 

computer. That address is usually in the form of a name or a 

number and has to be unique so computers can locate the 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 52 of 117

 Page ID #:96

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 52 of

 117 Page ID #:225

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 55 of 120
- 52 -

website. The Internet Corporation for Assigned Names and 

Numbers or “ICANN,” coordinates these unique identifiers across 

the world with registrars. Domain renewal fees are paid 

annually and are in part used to maintain this service. This

allows visitors to be pointed to Backpage controlled servers 

when they point their web browser to addresses such as 

www.backpage.com.

c. In order to maintain an on-line presence, 

companies like Backpage must renew their domains yearly,

generally for a fee. Without this payment, the domain could be 

resold to others and Backpage customers would not be able to 

find the Backpage servers when the customer types the domain 

name in their web browser. 

64. Of the over 300 domain names registered by 

Backpage.com LLC and/or Ferrer, all of which I reviewed, I

believe the 35 SUBJECT DOMAINS are specifically used to promote 

and advertise prostitution for the following reasons:

a. I visited each of the SUBJECT DOMAINS and found 

that, with the exception of “Backpage-insider.com”, the SUBJECT 

DOMAINS that begin with the word “Backpage” automatically

redirected my internet browser to Backpage.com. These

particular SUBJECT DOMAINS act and appear exactly as

Backpage.com.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 53 of 117

 Page ID #:97

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 53 of

 117 Page ID #:226

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 56 of 120
- 53 -

b. I visited Backpage.com and navigated to the Los 

Angeles/Dating/Women for Men section. I clicked on the first ad 

listed (Post ID 142685832). This ad contained approximately one

dozen pictures of women posing sexually, many on a bed wearing 

lingerie. Super-imposed over a few of the images was the text: 

“JENNY HERE TODAY – FBSM – BETTER THAN NURU.” An open source 

search for “FBSM” indicated that FBSM is code language for “Full 

Body Massage.” An open source search for “NURU” produced the 

following description:

NURU is a Japanese erotic massage technique in which one 

or more masseuses would rub their body against the

client’s body after both parties are nude. 

c. Based on this review, I believe this to be an 

advertisement in promotion of prostitution. From my further 

review, I observed thousands of other ads that posted similar 

content consistent with advertising prostitution.

65. I also attempted to visit Backpage-Insider.com,

bestofbackpage.com, bestofbigcity.com, but these domains did not 

have a landing page and were unavailable.

66. On March 22, 2018, I visited bigcity.com and, similar 

to Backpage.com, I found sexual content and additional

advertisements promoting prostitution. On the initial landing 

page for bigcity.com, there was a disclaimer noting that the 

website included sexual content.

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 54 of 117

 Page ID #:98

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 54 of

 117 Page ID #:227

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 57 of 120
- 54 -

67. I also attempted to visit chicagobackpage.com, 

denverbackpage.com, newyorkbackpage.com, phoenixbackpage.com, 

sandiegobackpage.com, seattlebackpage.com, and

tampabackpage.com. Each of these domains automatically directed

me to a landing page with links to other websites with sexual

content, including Backpage.com.

68. Based on the above, there is probable cause to believe 

that funds wire transferred into the SUBJECT ACCOUNTS have been 

used to support and maintain each of the SUBJECT DOMAINS that

promote prostitution. Therefore, each of the SUBJECT DOMAINS is

subject to seizure and forfeiture pursuant to 18 U.S.C. § 

981(a)(1)(A), because those SUBJECT DOMAINS are involved in, and 

traceable to, one or more transactions or attempted transactions 

in violation of 18 U.S.C. §§ 1956(a)(2)(A) and 1956(h) 

(International Money Laundering for Promotion and Money 

Laundering Conspiracy, respectively), and 18 U.S.C. § 1957 

(Financial Transactions Involving Illicit Proceeds). 

VI. CONCLUSION

69. For the reasons stated above, there is probable cause

to believe that the SUBJECT ACCOUNTS and SUBJECT DOMAINS are 

subject to seizure and forfeiture by the United States under the 

following provisions:

a. 18 U.S.C. § 981(a)(1)(A), because each of the

SUBJECT ACCOUNTS and SUBJECT DOMAINS are involved in, and 

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 55 of 117

 Page ID #:99

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 55 of

 117 Page ID #:228

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 58 of 120
Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 56 of

 117 Page ID #:229

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 59 of 120
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

United States of America,

Plaintiff, 

v.

1. Michael Lacey

Counts 1-70, 81, 83-84, 86, 88-92

2. James Larkin

Counts 1-68, 80, 87

3. Scott Spear

Counts 1-68, 71-78, 85, 93

4. John “Jed” Brunst

Counts 52-70, 78-84, 86-93

5. Dan Hyer

Counts 1-68

6. Andrew Padilla

Counts 1-51

7. Joye Vaught

Counts 1-51

Defendants. 

INDICTMENT

VIO: 18 U.S.C. § 371 

(Conspiracy) 

Count 1 

18 U.S.C. § 1952(a)(3)(A) 

(Travel Act—Facilitate Prostitution) 

Counts 2-51 

18 U.S.C. § 1956(h) 

(Conspiracy to Commit Money Laundering) Count 52 

18 U.S.C. § 1956(a)(1)(B)(i) 

(Concealment Money Laundering)

Counts 53-62 

18 U.S.C. § 1956(a)(2)(A) 

(International Promotional Money Laundering) Counts 63-68 

18 U.S.C. § 1957(a) 

(Transactional Money Laundering) 

Counts 69-93 

18 U.S.C. §§ 981, 982 

 21 U.S.C. § 853, 28 U.S.C. § 2461 

(Forfeiture Allegations) 

THE GRAND JURY CHARGES:

A. Introduction

1. The website www.backpage.com (“Backpage”) is notorious for being the

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 57 of 117

 Page ID #:101

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 57 of

 117 Page ID #:230

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 60 of 120
- 2 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

internet’s leading source of prostitution advertisements. Backpage derives the 

overwhelming majority of its revenue from such ads. These practices have enabled 

Backpage to earn over $500 million in prostitution-related revenue since its inception. 

 2. Backpage was created in 2004 by defendant MICHAEL LACEY 

(“LACEY”), defendant JAMES LARKIN (“LARKIN”), and a third individual, C.F. From 

2004-15, LACEY and LARKIN oversaw the website’s policies and strategic direction. 

Additionally, LACEY and LARKIN have retained significant control over the website (and 

have continued receiving tens of millions of dollars of Backpage-related distributions) 

since purportedly selling their interests in Backpage in 2015. 

3. Defendant SCOTT SPEAR served as the Executive Vice President of one of 

Backpage’s parent companies and held, at times, an ownership interest in Backpage of 

approximately 4%. 

4. Defendant JOHN “JED” BRUNST (“BRUNST”) served as the Chief 

Financial Officer of Backpage and several of Backpage’s parent companies and held, at 

times, an ownership interest in Backpage of approximately 6%. 

5. Defendant DAN HYER (“HYER”) joined Backpage’s marketing department 

in or around 2006 and served as Backpage’s Sales and Marketing Director. 

6. Defendant ANDREW PADILLA (“PADILLA”) served as Backpage’s 

Operations Manager. 

7. Defendant JOYE VAUGHT (“VAUGHT”) served as Backpage’s assistant 

Operations Manager. 

8. The defendants identified above are referred to at times in this indictment as 

the “BACKPAGE DEFENDANTS.” 

 9. As explained in detail below, the BACKPAGE DEFENDANTS have utilized 

a variety of strategies to make it appear that the prostitution ads appearing on Backpage 

are actually ads for “escort” services, “adult” companionship, dating, or other lawful 

activities. For example, Backpage purports to bar customers from offering illegal services 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 58 of 117

 Page ID #:102

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 58 of

 117 Page ID #:231

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 61 of 120
- 3 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

and has periodically used computerized filters and human “moderators” to edit the wording 

of (or block) ads that explicitly offer sexual services in return for money. 

 10. These strategies are a fiction designed to conceal the true nature of 

Backpage’s ads and customers. Indeed, the BACKPAGE DEFENDANTS have 

admitted—in internal company documents and during private meetings—that they know 

the overwhelming majority of the website’s ads involve prostitution. In one internal 

document, LACEY actually bragged about the company’s contributions to the prostitution 

industry: “Backpage is part of the solution. Eliminating adult advertising will in no way 

eliminate or even reduce the incidence of prostitution in this country. . . . For the very first 

time, the oldest profession in the world has transparency, record keeping and safeguards.” 

11. Notwithstanding these private admissions, the BACKPAGE 

DEFENDANTS have taken pains to mislead the public, regulators, and law enforcement

officials concerning the supposed sincerity of Backpage’s efforts to prevent the publication 

of prostitution-related ads. For example, after reviewing LACEY’s written description of 

Backpage’s contributions to the prostitution industry and editing practices, LARKIN 

instructed C.F. to prevent “any of the information in this being made public.” PADILLA, 

who helped supervise Backpage’s moderators, threatened to fire any employee who 

acknowledged in writing that the “escorts” depicted in the website’s ads were actually 

prostitutes: “Leaving notes . . . implying that we’re aware of prostitution . . . is enough to 

lose your job over.” And in one internal document, Backpage’s media strategy was 

described simply as “Do not acknowledge the prostitution.” 

 12. Many of the ads published on Backpage depicted children who were victims 

of sex trafficking. Once again, although Backpage has sought to create the perception that 

it diligently attempts to prevent the publication of such ads, the reality is that Backpage has 

allowed such ads to be published while declining—for financial reasons—to take necessary 

steps to address the problem. For example, for several years, Backpage’s official policy, 

when presented with an ad featuring the prostitution of a child, was to delete the particular 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 59 of 117

 Page ID #:103

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 59 of

 117 Page ID #:232

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 62 of 120
- 4 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

words in the ad denoting the child’s age and then publish a revised version of the ad. Such 

editing, of course, did nothing to change the fact the ad featured the prostitution of a child—

it only created a veneer of deniability and helped Backpage’s customers (i.e., pimps 

trafficking children) evade detection. 

 13. Backpage has also contributed to the proliferation of ads featuring the

prostitution of children in other ways. For example, an anti-sex trafficking organization 

once suggested that Backpage provide an automatic warning message whenever a customer 

searched for particular terms indicative of the prostitution of a child. In response, C.F. 

acknowledged the proposal was a good one but declined to adopt it because Backpage 

would not derive any public-relations benefit from doing so: “This is a good idea but it is 

not visible to AGs [state attorneys general] so it has little PR value. It is a low priority.”

Backpage has also claimed it does everything in its power to alert the National Center for 

Missing and Exploited Children (“NCMEC”) whenever it becomes aware that a child is 

being advertised on its website. However, the BACKPAGE DEFENDANTS implemented 

policies to artificially limit such referrals. In one email, PADILLA instructed VAUGHT 

that “if we don’t want to blow past 500 [referrals to NMCEC] this month, we shouldn’t be 

doing more than 16 per day.” In another training document, moderators were instructed 

not to send emergency alerts to NCMEC in response to complaints filed by the 

grandparents and other extended family members of children being advertised on the 

website: “Neice [sic], nephew, grandchild, cousin, etc. doesn’t count.” 

14. Virtually every dollar flowing into Backpage’s coffers represents the 

proceeds of illegal activity. In fact, by 2015, the major credit card companies stopped 

processing payments for Backpage and some banks closed Backpage’s accounts out of 

concern they were being used for illegal purposes. In response, the BACKPAGE 

DEFENDANTS have pursued an array of money laundering strategies. These strategies 

have included (a) instructing customers to send checks and money orders to particular Post 

Office box, depositing those payments in bank accounts held in the name of entities with 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 60 of 117

 Page ID #:104

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 60 of

 117 Page ID #:233

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 63 of 120
- 5 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

no apparent connection to Backpage, and then giving customers a corresponding “credit” 

on Backpage to purchase new ads, (b) wiring the proceeds of Backpage’s business to bank 

accounts held in foreign countries and then redistributing the funds to certain BACKPAGE 

DEFENDANTS (as compensation) or redepositing the funds in bank accounts held in the 

United States (to conceal the nature of those funds and promote Backpage’s ongoing 

operations), and (c) converting customer payments, and the proceeds of Backpage’s 

business, into and out of cryptocurrency. 

15. The BACKPAGE DEFENDANTS have also engaged in other financial 

transactions designed to conceal their misconduct and evade seizure by law enforcement. 

For example, in November 2016, LACEY asked employees of an Arizona-based bank for 

advice on how to move his assets “offshore” to protect them from seizure by the 

government. Soon afterward, $16.5 million in Backpage-derived cash was wired from 

LACEY’s bank accounts in the United States to an overseas bank account in Hungary. 

16. For all of these reasons, the BACKPAGE DEFENDANTS are charged in this 

indictment with the crimes of facilitating prostitution (18 U.S.C. § 1952), concealment,

transactional, and international promotional money laundering (18 U.S.C. §§ 1956 and 

1957), and/or conspiracy to commit these offenses (18 U.S.C § 371 and 1956). 

B. Backpage’s Origins, Ownership, and Control 

 17. LACEY and LARKIN are the founders of the Phoenix New Times, an 

alternative newspaper based in Arizona. Over time, LACEY and LARKIN acquired 

several other alternative newspapers, which they came to operate through an entity called 

Village Voice Media Holdings (“VVMH”). Additionally, SPEAR served as VVMH’s 

Executive Vice President and BRUNST served as VVMH’s Chief Financial Officer. 

 18. The publications within the VVMH newspaper chain routinely featured 

illegal prostitution ads. In fact, more than 30 years ago, a federal court affirmed the 

conviction of the operator of a prostitution business (which masqueraded as a massage 

parlor) for publishing ads in the classified section of the Village Voice. See United States

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 61 of 117

 Page ID #:105

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 61 of

 117 Page ID #:234

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 64 of 120
- 6 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

v. Sigalow, 812 F.2d 783 (2d Cir. 1987). The conviction was for violating 18 U.S.C. 

§ 1952, one of the same crimes charged in this indictment. 

 19. By 2000, the rise of the internet—and, in particular, the website 

www.craigslist.com (“Craigslist”), which offered free classified ads—began to 

significantly disrupt VVMH’s business model, which depended on classified advertising 

revenue for survival. 

 20. LACEY and LARKIN, with assistance from C.F., sought to address this 

threat by creating Backpage. Their decision to create Backpage was later described in an 

internal company document as follows: “In 2004, in response to the Craigslist threat that 

was decimating daily newspapers, VVM launched its own online classified site, 

Backpage.com, named after the back page of VVM’s print publication.” 

 21. During its first few years of operation, Backpage accounted for only a 

fraction of VVMH’s overall revenue. In January 2006, for example, VVMH estimated that 

Backpage supplied only 1% of its overall advertising revenue but also noted that Backpage 

had “tremendous upside potential.” 

 22. This prediction proved prophetic. By 2008, Backpage was generating over 

$5 million in annual profit. This annual profit figure increased to over $10 million in 2009.

 23. In 2010, Craiglist chose to shut down its “adult” section due to the prevalence 

of ads for prostitution and other illegal services. The BACKPAGE DEFENDANTS,

sensing an opportunity, made an aggressive push for Backpage to capture Craiglist’s share 

of this market. In one internal document, LARKIN commented: “Craigslist has folded . . 

. . It is possible that this will mean a deluge of adult content ads for backpage.com . . . . 

We have with the Village Voice probably the longest run of adult content advertising in 

the US and it is, like it or not, in our DNA.” 

 24. This push was successful. In internal documents, Backpage stated that it 

experienced “explosive growth” by “capitalizing on displaced Craigslist ad volume.”

Backpage’s annual profits grew to over $26 million in 2010, over $52 million in 2011, and 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 62 of 117

 Page ID #:106

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 62 of

 117 Page ID #:235

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 65 of 120
- 7 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

over $78 million in 2012. 

25. These figures dwarfed the profits that VVMH’s print publications were 

generating. In fact, Backpage became so profitable that the BACKPAGE DEFENDANTS 

decided to get rid of VVMH’s publishing business so they could focus on Backpage’s

further development and expansion. Accordingly, in or around November 2012, the

BACKPAGE DEFENDANTS spun off VVMH’s print publications and began utilizing 

several new corporate entities, including Medalist Holdings, Inc. (“Medalist”), Dartmoor 

Holdings LLC (“Dartmoor”), and Camarillo Holdings, LLC (“Camarillo”), to serve as

Backpage’s parent companies. 

26. Following these transactions, LACEY held an ownership interest in Medalist 

(and, therefore, in Backpage) of approximately 45%, LARKIN held an ownership interest 

of approximately 43%, BRUNST held an ownership interest of approximately 6%, and 

SPEAR held an ownership interest of approximately 4%. 

 27. Backpage’s annual profits continued to skyrocket during and after these 

changes. They grew to over $112 million in 2013 and over $134 million in 2014. 

 28. In or around April 2015, LACEY, LARKIN, SPEAR, and BRUNST 

purported to sell their ownership interests in Backpage and several related entities for 

around $600 million to various Dutch entities. These Dutch entities included Atlantische 

Bedrijven, C.V., which agreed to purchase Backpage’s U.S. operations for around $526 

million, and UGC Tech Group C.V., which agreed to purchase Backpage’s overseas 

operations for around $77 million. 

 29. In fact, these Dutch entities were controlled by C.F., who borrowed most of 

the $600 million from entities controlled by the sellers to finance the purchase. Due to this 

financial arrangement, LACEY, LARKIN, SPEAR, and BRUNST retained a significant 

financial interest in Backpage after the transactions were completed. 

 30. Additionally, LACEY, LARKIN, SPEAR, and BRUNST retained significant 

operational control over Backpage following these transactions. For example, the April 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 63 of 117

 Page ID #:107

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 63 of

 117 Page ID #:236

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 66 of 120
- 8 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

2015 loan agreement required C.F. to sign a six-year employment agreement, required C.F. 

to provide the lenders with full access to Backpage’s books and records, required C.F. to

provide the lenders with an annual listing of all of C.F.’s personal assets, and prohibited 

C.F. from opening any new bank accounts on Backpage’s behalf without the lenders’ 

consent. 

C. Backpage’s Knowledge And Facilitation Of Prostitution Ads 

 31. By 2008, if not earlier, the BACKPAGE DEFENDANTS were aware that 

the overwhelming majority of the website’s “adult” ads involved prostitution.

Nevertheless, the BACKPAGE DEFENDANTS made a financial decision to continue 

displaying those ads. 

32. The BACKPAGE DEFENDANTS also sought to sanitize the ads by editing

them—that is, by removing terms and pictures that were particularly indicative of 

prostitution and then publishing a revised version of the ad. This process was sometimes 

referred to as “moderation.” 

 33. For example, in April 2008, C.F. wrote an email explaining that, although he 

was “under pressure to clean up phoenix’s adult content,” he was unwilling to delete 

prostitution ads because doing so “would put us in a very uncompetitive position with 

craig[slist]” and result in “lost pageviews and revenue.” Thus, he instructed Backpage’s 

technical staff to edit the wording of such ads, by removing particular terms that were 

indicative of prostitution, and then allow the remainder of the ad to be featured on

Backpage’s website.

 34. On February 26, 2009, C.F. received an email from the classified-ads

manager of a newspaper within the VVMH chain asking why Backpage’s terms of service 

purported to prevent customers from “suggest[ing] an exchange of sexual favors for 

money” in light of the fact that “[c]learly everyone on the entire backpage network breaks 

the rules.” In response, C.F. didn’t dispute the author’s characterization and explained that 

Backpage had simply added the terms of service at the behest of “our attorney in SF” in an 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 64 of 117

 Page ID #:108

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 64 of

 117 Page ID #:237

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 67 of 120
- 9 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

attempt to avoid liability in civil lawsuits. 

 35. On May 25, 2009, SPEAR received an email summarizing a plan to begin 

“remov[ing] sex act pics and coded terms” from Backpage ads. Later that day, C.F.

forwarded this email to HYER with the explanatory note that “We do not intend to be a 

craig[slist] here, just get out the most egregious stuff.” 

 36. On March 8, 2010, C.F. testified in federal court (the United States District 

Court for the Southern District of Florida) in the criminal trial of a pimp who had used 

Backpage to post prostitution ads. During his testimony, C.F. acknowledged the defendant 

had used the email address “Youngpimpin86” when posting the ads. C.F. also 

acknowledged that the ads described one so-called escort as “five-foot-three, with a small 

waist and amazing ass you'll have to see to believe. XL, XL, XL, Lollipop” and described 

a different so-called escort as “discrete, sincere and extremely naughty. I am the type of 

girl who absolutely adores a man who understands the many desires of a young beautiful 

woman and how to accommodate a variety of fantasies.” This episode provided notice to 

Backpage that it was implausible to pretend such ads were merely offering lawful escort 

services. 

 37. On September 1, 2010, PADILLA sent an email to HYER and C.F. stating 

that customers who engaged in “extreme and repeat” violations of Backpage’s posting rules 

would have their ads deleted and be banned from the website. However, PADILLA also 

stated the bans would only be temporary and that “we’ll do everything we can to affect 

only the worst apples.” 

 38. On September 1, 2010, SPEAR received an email acknowledging that 

Backpage’s moderators were being instructed to “Remove any sex act pics in escorts [ads]” 

and “Remove any illegal text in escorts [ads] to include any code words for sex act for 

money.” 

 39. On September 21, 2010, a group of state attorneys general wrote a letter to 

Backpage. This letter observed that “ads for prostitution—including ads trafficking 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 65 of 117

 Page ID #:109

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 65 of

 117 Page ID #:238

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 68 of 120
- 10 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

children—are rampant on the site” and argued that “[b]ecause Backpage cannot, or will 

not, adequately screen these ads, it should stop accepting them altogether.” The letter 

acknowledged that this step would cause Backpage to ”lose the considerable revenue 

generated by the adult services ads” but stated that “no amount of money can justify the 

scourge of illegal prostitution, and the misery of the women and children who will continue 

to be victimized, in the marketplace provided by backpage.” 

 40. On September 25, 2010, C.F. wrote an email explaining that Backpage was 

unwilling to delete ads that included terms indicative of prostitution because doing so 

would “piss[] off a lot of users who will migrate elsewhere” and force Backpage to refund 

those customers’ fees. Thus, C.F. announced that Backpage would “go back to having our 

moderators remove bad content in a post . . . .” 

 41. On September 30, 2010, C.F. testified in federal court (the United States 

District Court for the District of Minnesota) in the criminal trial of a pimp who had used 

Backpage to post prostitution ads. During his testimony, C.F. acknowledged that

Backpage’s servers are located in Arizona and that the ads posted by the Minnesota-based 

defendant had therefore “traveled across state lines.” 

 42. On October 8, 2010, PADILLA sent an email (on which VAUGHT was cc’d) 

threatening to fire any Backpage employee who acknowledged, in writing, that a customer 

was a prostitute: “Leaving notes on our site that imply that we’re aware of prostitution, or 

in any position to define it, is enough to lose your job over. . . . This isn’t open for 

discussion. If you don’t agree with what I'm saying completely, you need to find another 

job.” 

 43. On October 16, 2010, PADILLA sent an email to a large group of Backpage 

employees (including HYER and VAUGHT). The email had two attachments that 

provided guidance on how to “moderate” ads. The first was a Powerpoint presentation that 

displayed a series of 38 nude and partially-nude photographs, some of which depicted 

graphic sex acts. Next to each picture was an instruction as to whether it should be 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 66 of 117

 Page ID #:110

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 66 of

 117 Page ID #:239

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 69 of 120
- 11 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

approved or disapproved by a Backpage moderator. These instructions included “Approve. 

Nude rear shots are okay as long the model is not exposing her anus or genitalia.” and 

“Approve. Rear shot okay. Transparent wet panties okay.” The second was an Excel 

spreadsheet identifying 50 terms (all of which were indicative of prostitution) that should 

be “stripped” from ads before publication. PADILLA concluded the email by stating:

“[I]t’s the language in ads that’s really killing us with the Attorneys General. Images are 

almost an afterthought to them.” 

 44. On October 16, 2010, PADILLA sent a separate internal email (which also 

included HYER and VAUGHT as recipients). In this email, PADILLA explained that “I’d 

like to still avoid Deleting ads when possible,” that “we’re still allowing phrases with 

nuance,” and that “[i]n the case of lesser violations, editing should be sufficient.” 

 45. On October 25, 2010, C.F. sent an email to SPEAR, HYER, and PADILLA 

acknowledging that the “[i]llegal content removed” through Backpage’s moderation 

processes was “usually money for sex act.” This email also explained that, after the “sex 

act pics are removed,” the “ad text may stay.”

 46. On October 26, 2010, HYER and PADILLA received an email explaining: 

“We will not remove ads with vaginas or penis showing, just the images unless they are a 

frequent offender. We will not remove ads with rates under an hour, just the text with the 

minimum rates. Users need time to react to this change.” 

 47. On October 27, 2010, PADILLA sent an email to the head of a group of 

contractors from India who had been hired to moderate Backpage’s adult ads. In this email, 

PADILLA criticized the contractors for deleting too many ads, stated that this approach 

was bad for business, and instructed the contractors to simply edit the ads to remove the 

more-obvious language: “As long as your crew is editing and not removing the ad entirely, 

we shouldn’t upset too many users. Your crew has permission to edit out text violations 

and images and then approve the ad.” 

 48. On October 27, 2010, HYER sent an internal email stating that Backpage 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 67 of 117

 Page ID #:111

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 67 of

 117 Page ID #:240

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 70 of 120
- 12 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

was “editing 70 to 80%” of the ads it received from customers. In other words, HYER 

acknowledged that a large proportion of the ads originally submitted by Backpage’s 

customers contained text and pictures that were indicative of prostitution and that 

Backpage was still choosing to publish those ads after editing them. 

 49. On November 4, 2010, C.F. sent an email to Backpage’s India-based 

moderators (on which PADILLA was cc’d) explaining that “[m]any of the ads need to have 

15 minute and 30 minute pricing removed” and that “I’m being evaluated by lawyers [i.e.,

state attorneys general] later this week so cleaning up old stuff is important.” 

 50. On November 17, 2010, HYER and PADILLA received an email 

acknowledging that the term Lolita is “code for under aged girl” but explaining that this 

term could simply be stripped out from ads (as opposed to refusing to publish the ad). The

email also explained that customers should be allowed to include their identification 

numbers from a notorious prostitution website, The Erotic Review: “[A]llow users to put 

in TER IDs (just no live links).” 

 51. On November 30, 2010, LARKIN, SPEAR, and other Backpage 

representatives participated in a conference call with representatives from NCMEC. 

During this call, the Backpage representatives were advised that a large portion of the ads 

on Backpage were blatant prostitution ads, that many of those ads featured children, and 

that the posting of such ads was illegal in every state. 

 52. In December 2010, HYER, PADILLA, and others exchanged a series of 

emails entitled “Deep cleaning strip out.” These emails identified a lengthy list of terms 

that were indicative of prostitution and discussed plans for removing the terms from the 

old ads in Backpage’s archives. During this exchange, C.F. stated that Backpage wasn’t 

willing to delete the old prostitution ads because “our users love” having access them,

“[s]o, best to do deep cleaning and not kill a valuable feature.” C.F. later encouraged 

Backpage’s staff to complete the project quickly to avoid scrutiny: “This task is urgent 

since CNN is runing [sic] a report soon.” 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 68 of 117

 Page ID #:112

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 68 of

 117 Page ID #:241

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 71 of 120
- 13 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 53. On January 13, 2011, HYER and PADILLA received an email summarizing 

instructions that had been provided to members of Backpage’s technical staff. It explained 

that the technical staff had been instructed “not to display the moderation log” in a 

particular section of Backpage’s database “since we pdf this page for subpoenas. I would 

rather not testify in court as to why my staff ‘approved’ . . . postings.” 

 54. In January 2011, LARKIN and LACEY met with a representative from 

NCMEC. During this meeting, LACEY asked which types of sex ads would be acceptable 

from NCMEC’s perspective. When the NCMEC representative declined to say that any 

such ads would be acceptable, LACEY made a statement to the effect of “adult prostitution 

is none of your business.” 

 55. On January 31, 2011, and February 1, 2011, C.F. engaged in an email 

exchange concerning whether to remove links to other prostitution websites (such as The

Erotic Review) from expired Backpage ads. C.F. stated that, although SPEAR and his 

“internet safety guy” were recommending that such ads be removed, he thought this would 

“be a stupid move” because it would hurt Backpage financially (by reducing the number 

of referrals from other sites). C.F. added that “this overly zealous focus on moderation at 

the expense of other development is a lot of bullshit . . . .” 

 56. On February 2, 2011, C.F. sent an email acknowledging that “[t]he strip out

affects almost every adult ad.” In other words, C.F. acknowledged that “almost every adult 

ad” on Backpage was a prostitution ad that had been edited to remove the most damning 

text and pictures. 

 57. On February 3, 2011, a Backpage customer who went by the name “Licks 

Alot” wrote an email to Backpage complaining that all of the pictures in one of her ads 

(entitled “Athletic SWF Guaranteed Low Mileage Boys!!!”) had been deleted. C.F. 

responded to “Licks Alot” by explaining that one of her photos had been removed because 

“[o]ur crazy internet safety experts do not want any genitalia showing up around the 

thong.” However, C.F. proceeded to apologize to “Licks Alot” over the removal of her 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 69 of 117

 Page ID #:113

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 69 of

 117 Page ID #:242

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 72 of 120
- 14 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

remaining photos, allowed her ad (which was obviously for prostitution) to remain on the 

website, and offered her a free upgrade. 

 58. On February 8, 2011, C.F. testified in federal court (the United States District 

Court for the Middle District of Florida) in the criminal trial of a pimp who had used 

Backpage to post prostitution ads. During his testimony, C.F. authenticated one of the ads 

the defendant had placed on Backpage, whose title was “Extra horny sexy newbie,” 

confirmed that Backpage had allowed this ad to be posted multiple times in various East 

Coast cities, and acknowledged that Backpage published “a lot” of similar ads. This 

episode provided further notice to Backpage that it was implausible to pretend such ads 

were merely offering lawful escort services. 

 59. On February 16, 2011, PADILLA sent an email to Backpage’s India-based 

moderators (on which VAUGHT was cc’d) explaining that Backpage was adopting a 

“more lenient policy” and that he was instructing his Phoenix-based employees to “go easy 

on some types of violations.” PADILLA acknowledged this approach would “likely” result 

in more “violations” but emphasized that “moderators should err on the side of the user.” 

 60. On February 16, 2011, PADILLA sent a separate email discussing whether 

several terms should remain on Backpage’s “filtered terms” list. During this discussion, 

PADILLA acknowledged—by placing quote marks around the term “companionship”—

that he didn’t actually believe the women being advertised on Backpage were providing 

lawful escort services: “[The term] implies some exchange of bodily fluids which kills our 

‘companionship’ argument, but i don’t think we’ve ever really gotten in trouble for it.” 

61. On February 22, 2011, PADILLA received an email requesting Backpage’s 

“list of banned, stripped out adult terms.” In response, PADILLA sent an Excel 

spreadsheet entitled “Phrase List 02211,” which PADILLA described as “the latest greatest 

version of the list.” The enclosed spreadsheet identified over 660 words or phrases that are 

indicative of prostitution, including an array of terms that are suggestive of child 

prostitution (e.g., “lolita,” “fresh,” “high school,” “tight,” “young”). The spreadsheet 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 70 of 117

 Page ID #:114

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 70 of

 117 Page ID #:243

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 73 of 120
- 15 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

explained that most such terms were simply to be “filtered” from the ads in which they 

appeared. 

 62. On February 23, 2011, PADILLA received an email concerning a particular 

ad that had recently been edited by Backpage’s India-based moderators. The ad was 

obviously for prostitution—its title was “new-new-new-put me in your favorite position” 

and the poster had attempted to include two photographs that violated Backpage’s posting 

rules. In response, the India-based moderators had deleted both of those photos, as well as 

a third photo that depicted the prostitute’s face, and then allowed the ad to be published. 

The email received by PADILLA did not criticize the moderators for allowing an obvious 

prostitution ad to be published after editing. To the contrary, it emphasized that the ad 

should remain on Backpage and criticized the moderators for removing the third photo,

threatening to fire them if they did it again: “2 out of 3 pics should have been removed. 

But [the] moderator deleted all three pics. This is plain wrong . . . . I would fire a moderator 

in Phoenix if they did this.” 

 63. In March 2011, LARKIN, LACEY, SPEAR, and other Backpage 

representatives met with representatives from NCMEC. During this meeting, the Backpage 

representatives were again advised that a large portion of the ads on Backpage were blatant 

prostitution ads. The Backpage representatives also were advised they could be criminally 

prosecuted under federal law for their conduct. 

 64. On April 5, 2011, PADILLA sent an email whose recipients included 

VAUGHT and the supervisor of Backpage’s Indian moderation team. The email was 

entitled “relaxed image standards” and included, as an attachment, a document that 

displayed a series of 30 nude and partially-nude photographs. Next to each picture was an 

instruction as to whether it should be approved or disapproved by a moderator. One picture 

showed a woman sitting on a bed, wearing only a bra and panties, with her legs spread 

open and her hand partially covering her crotch. The caption provided in part: “okay – 

but barely.” 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 71 of 117

 Page ID #:115

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 71 of

 117 Page ID #:244

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 74 of 120
- 16 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 65. Between April 2011 and March 2012, PADILLA, C.F., and others 

participated in an email exchange acknowledging that Backpage was deleting thousands of 

pictures from customer ads each week and seeking assistance in collecting all of the deleted 

pictures so they could be used for “entertainment” or to generate user “traffic for other 

projects.” The email explained that the deleted pictures could be made available to the 

public on a new website called “nakedpics.backpage.com” or “badpics.backpage.com.” 

 66. On April 19, 2011, LARKIN and SPEAR received an email seeking 

permission to terminate the contract of a third-party vendor that had been receiving $17,000 

per month to “remov[e] any nude pics” from the expired ads in Backpage’s database. 

LARKIN responded: “do it!” 

 67. On June 7, 2011, C.F. received an inquiry from a law enforcement official 

about a particular ad that included the term “amber alert.” In response, C.F. acknowledged 

this might be “some kind of bizarre new code word for an under aged person.” C.F. then 

forwarded this exchange to PADILLA and stated that he had instructed HYER to add 

“amber alert” to Backpage’s “strip out” list. In other words, HYER, PADILLA, and C.F. 

did not require all future ads involving this particular coded term for the prostitution of a 

child to be blocked from Backpage—they merely required such ads to be edited before 

publication. 

 68. On June 30, 2011, several Backpage representatives met with representatives 

from the office of the Washington State Attorney General. During this meeting, the 

Backpage representatives initially attempted to claim that no prostitution ads appeared on 

their website. In response, a representative from the Attorney General’s office stated: 

“You mean to tell me that if someone responded to an advertisement, the woman they 

called for services would be offering to go out for coffee?” A Backpage representative 

responded to this question by looking at C.F., laughing, and acknowledging that Backpage 

couldn’t “deny the undeniable.” 

 69. On July 27, 2011, C.F. sent an email to HYER and PADILLA, and a nearlyAttachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 72 of 117

 Page ID #:116

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 72 of

 117 Page ID #:245

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 75 of 120
- 17 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

identical email to LARKIN and LACEY, concerning the possibility of using ageverification software. In this email, C.F. acknowledged the software might be beneficial 

(“This might be our solution”) but recommended against its wholesale adoption because it 

would cost “79 to 99 cents per query” and would thus cut into Backpage’s profits. 

 70. On July 28, 2011, LACEY sent LARKIN a draft editorial entitled “BackPage 

understood.” In this document, LACEY bragged about Backpage’s contributions to the 

prostitution industry: “Backpage is part of the solution. Eliminating our adult advertising 

will in no way eliminate or even reduce the incidence of prostitution in this country. . . . 

For the very first time, the oldest profession in the world has transparency, record keeping 

and safeguards.” LACEY also acknowledged that Backpage used an automatic filter to 

remove particular phrases from ads that were indicative of prostitution but still published 

the ads after editing them. 

71. Soon afterward, LARKIN forwarded the editorial to C.F., with a cover note 

cautioning against some of LACEY’s statements “being made public” because “we need 

to stay away from the very idea of ‘editing’ the posts, as you know.” C.F., in turn, revised 

the editorial to take out the paragraph lauding Backpage’s contributions to the prostitution 

industry. 

72. On August 5, 2011, Backpage received a letter from the mayor of Seattle. 

This letter warned that “Seattle Police have identified an alarming number of juvenile

prostitutes advertised on Backpage.com since January 2010” and explained that Backpage 

was dissimilar from other companies whose products and services are “occasionally or 

incidentally” utilized by criminals because “[y]our company is in the business of selling 

sex ads” and “your services are a direct vehicle for prostitution.” The letter also 

recommended that Backpage require in-person age verification for all of the “escorts” 

depicted in its ads. Afterward, Backpage declined to adopt these recommendations. 

73. On August 15, 2011, PADILLA received an email containing an updated 

version of Backpage’s moderation guidelines. This six-page document provided the 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 73 of 117

 Page ID #:117

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 73 of

 117 Page ID #:246

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 76 of 120
- 18 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

following instructions concerning photographs: “Nude rear shots are okay as long the 

model is not exposing her anus or genitalia,” “Transparent wet panties okay should not be 

able to see personal private part,” and “cherry, Ice-cream keeping in mouth [is okay].” The 

document also explained that “Bikini, lingerie, g-string, thong, and hands covering nipples 

are all allowed,” “Hourly rates are OK,” and “Sessions are okay. E.g $50 session.” 

74. On August 31, 2011, Backpage received a letter from the National 

Association of Attorneys General. This letter characterized Backpage as “a hub” for 

human trafficking, identified “more than 50 instances, in 22 states over three years, of 

charges filed against those trafficking or attempting to traffic minors on Backpage.com,” 

and noted that “[n]early naked persons in provocative positions are pictured in nearly every 

adult services advertisement on Backpage.com and the site requires advertisements for 

escorts, and other similar ‘services,’ to include hourly rates. It does not require forensic 

training to understand that these advertisements are for prostitution.” 

75. On October 6, 2011, C.F. sent an email discussing various proposals for 

addressing “the under aged issue.” With respect to one particular proposal, C.F. 

acknowledged it was a good one but recommended against adopting it because Backpage 

would not derive any public-relations benefit from doing so: “This is a good idea but it is 

not visible to AG’s [state attorneys general] so it has little PR value. It is a low priority.” 

76. In the fall of 2011, Backpage sought the assistance of a public relations firm 

based in Washington, D.C. On October 12, 2011, C.F. received a written copy of the firm’s 

presentation. Later, some of the BACKPAGE DEFENDANTS attended a meeting at 

which the presentation was discussed in more detail. The presentation warned that 

Backpage’s business practices would inevitably result in legal trouble (“One day the 

proverbial is going to hit the fan”) and characterized Backpage’s “media strategy” as “Do 

not acknowledge the prostitution.” The presentation also noted that the “ads on the 

backpage.com site” generally fall into three categories, one of which is “Pimps and Men 

Looking for Kids.” 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 74 of 117

 Page ID #:118

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 74 of

 117 Page ID #:247

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 77 of 120
- 19 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

77. On October 21, 2011, LARKIN received an email discussing whether the 

Backpage website should include a warning message concerning the prostitution of 

children. This email contained the following joke: “Andrew [PADILLA] thinks it to[o] 

heavy handed and thinks our web site name will be entrapment.com (Hilarious).” 

78. On November 16, 2011, HYER and PADILLA received an email asking for 

“urgent” assistance in eliminating the word “teen” from the ads appearing on Backpage’s 

website: “Remove ads with teens or remove the text teen from . . . ads.” The following 

day, PADILLA wrote back with an update that he had found “76 pages of results” and that 

he had simply “edited” all of the ads posted within the last two months (i.e., allowed those 

ads to remain on the website after sanitizing them). 

79. Between around January and March 2012, many of Backpage’s moderators

(who were supervised in part by PADILLA and VAUGHT) underwent performance 

appraisals. These appraisals revealed that many of the moderators did “not report young 

looking escorts.” Nevertheless, these moderators were allowed to keep their jobs, and 

sometimes were given strong overall performance ratings. 

80. On February 16, 2012, PADILLA sent an email to VAUGHT stating that 

Backpage should limit the number of child-exploitation referrals it was making to 

NCMEC: “If we don’t want to blow past 500 this month, we shouldn’t be doing more than 

16 a day.” 

81. On February 23, 2012, C.F. was forwarded a legal notice claiming that 

several of Backpage’s ads included copyrighted content from two competing websites

called RubMaps.com and EroticMP.com. C.F. also received copies of the underlying ads 

from the competing websites, which clearly involved prostitution. In one of the ads, a 

customer stated that, in return for $45 and a $5 tip, he had received a “Blow Job . . . w/ 

condom” from a woman who “had nice breasts.” In a different ad, a customer stated that, 

in return for $60, he had oral and vaginal sex with a prostitute. And in a different ad, a 

customer stated: “Her bj was slow and erotic, and she was happy to go with whatever 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 75 of 117

 Page ID #:119

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 75 of

 117 Page ID #:248

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 78 of 120
- 20 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

position I wanted.” When C.F. forwarded these materials to Backpage’s staff, he was asked 

whether the corresponding ads appearing on Backpage’s website should be removed 

immediately. C.F. replied that they should be allowed to remain on Backpage for another 

few weeks without any modification. 

82. On March 15, 2012, HYER received an email concerning the ads with the 

copyrighted material. This email stated that the ads shouldn’t be deleted and that 

Backpage’s technical staff should merely “strip out” the names of the competing 

prostitution websites: “Copyright infringement issue. We need to strip out every 

appearance of rubmaps.com and eroticmp.com.” When a staff member sought more 

guidance, HYER interjected: “We don’t need to delete ads or users.” 

83. On April 7, 2012, PADILLA was informed that a woman had contacted 

Backpage to report that one of the “escorts” depicted on the site was only 17 years old. 

The woman provided the juvenile’s full name and birth year and further stated that the 

juvenile had been attempting to recruit the complaining party’s daughter (who was 15). In 

response, PADILLA instructed his staff to refuse to remove the ad because “she’s isn’t 

claiming her own daughter is in the ad.” 

84. On April 8, 2012, LACEY sent an email emphasizing that “jim [LARKIN] 

and I believe in legalized prostitution” and stating that Backpage’s efforts to prevent the 

prostitution of children on the site were “not perfect, by any means.” 

85. On April 25, 2012, a Backpage representative spoke at a meeting of the New 

York City Council’s Women’s Issues Committee. During this meeting, the representative 

stated it was better to have ads for sex work appear on Backpage than have them move to 

other places on the internet. The representative further stated: “I don’t deny that Backpage 

is part of the problem, but the problem is the internet.” 

86. On April 27, 2012, a woman wrote an email to Backpage’s support 

department stating that her underage daughter had been kidnapped, drugged, and was being 

advertised as a prostitute against her will. The email identified the specific phone number 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 76 of 117

 Page ID #:120

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 76 of

 117 Page ID #:249

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 79 of 120
- 21 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

associated with the ads (754-229-xxxx), stated that the ads appeared on a website called 

BackpagePics.com, and asked that the ads be removed immediately: “This is a drugged 

and held against her will child who had photos taken under threat and duress . . . . Please 

remove.” This email was forwarded to PADILLA by a subordinate, who asked “should 

we respond?” PADILLA replied by explaining that, because the website 

BackpagePics.com wasn’t owned by Backpage, there was no need to respond to the 

mother. 

87. On April 30, 2012 (three days later), the same woman wrote another email 

to Backpage’s support department. In this email, the woman stated that “I have contacted 

backpage on several occassions [sic] to remove these pictures which were posted against 

her will and while she was drugged and held captive. I have yet to receive a reply.” This

time, the woman provided a link to her daughter’s ad on Backpage (not 

BackpagePics.com), which included the same phone number (754-229-xxxx) that had been 

included in the other ad. 

88. On May 1, 2012 (the next day), the same woman wrote a third email to 

Backpage’s support department. In this email, the woman included a link to another ad on 

Backpage depicting her underage daughter and stated: “I also found a pix of my daughter 

within this url both girls are in protective custody.” Later that day, the woman received an 

email from Backpage’s support department stating: “The post is confirmed removed.” 

89. Some of these emails were forwarded to LACEY and LARKIN. In response, 

LARKIN applauded Backpage’s “good solid response” to the woman and remarked: “this 

whole rigamarole seems a little odd to me.” 

90. On May 10, 2012, the television news station CNN ran an expose on 

Backpage that emphasized “how young some of these girls look” and deemed the website 

“a hub for the sex trade.” 

91. On May 11, 2012, PADILLA sent an email to VAUGHT and other Backpage 

employees entitled “forbidden planet.” Enclosed with the email was an Excel spreadsheet 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 77 of 117

 Page ID #:121

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 77 of

 117 Page ID #:250

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 80 of 120
- 22 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

that identified over 600 words and phrases that are indicative of prostitution. The 

spreadsheet also specified, for each word and phrase, whether an ad containing the 

offending language should be banned or whether Backpage should simply “strip term from 

ad” and then publish it after the revision. 

92. On July 12, 2012, PADILLA sent an email (which was also shared with 

VAUGHT) to the head of Backpage’s Indian moderation team. In this email, PADILLA 

criticized the moderators for deleting too many ads and provided the following instruction: 

“I agree that ‘over cautiousness’ is as big of a problem as moderators that miss a lot of 

violations.” 

93. In or around November 2012, a researcher at Arizona State University 

published a study concluding that most of the ads on Backpage’s Phoenix page involved 

prostitution and that many of the ads depicted juvenile trafficking victims. On December 

19, 2012, LACEY was forwarded a copy of the study’s results. The researcher responsible 

for the study also met with a Backpage representative to propose various mechanisms for 

reducing or eliminating the prostitution of children on the website. Backpage declined to 

adopt these proposals. 

94. Between around September 2010 and October 2012, C.F. became aware that

a particular Backpage customer, P.R., was posting prostitution ads. Rather than bar this 

customer from posting future ads, C.F. repeatedly restored her posting privileges and gave 

her advice on how to conform to Backpage’s publication standards. The communications 

involving this woman’s ads included the following: 

• On September 26, 2010, C.F. received an email from a woman who was 

obviously posting prostitution ads on Backpage. The woman, whose email address 

included the phrase “provider4u,” wrote to complain that her escort ad (“50 Red Roses 

special – Dont Miss out !!!”) had been removed even though “[o]ther women have more 

explicit ads than me and they are up!” The woman continued: “I can not afford to have 

this ad removed. This is the only way I can get by and if its not on all the time I will not 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 78 of 117

 Page ID #:122

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 78 of

 117 Page ID #:251

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 81 of 120
- 23 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

be able to pay my bills . . . . My fiancé is in jail and he is not able to help me at this 

point.” In response, C.F. arranged for the woman to be allowed to continue posting ads. 

• On October 6, 2010, C.F. received another email from the same woman. In 

this email, she complained that her most recent ad had been removed because it included 

an explicit picture of her body. She provided a copy of the picture to C.F. and stated: “If 

the person [who removed the ad] is such a prude well maybe they should check out the 

other women’s ads in that [escorts] section.” On November 15, 2010, C.F. wrote back to 

the woman to encourage her to edit the ad so it could be re-posted: “Ok, please try editing 

the ad now.” After this exchange, the woman was permitted to resume posting ads on 

Backpage. 

• On June 6, 2011, C.F. received another email from the same woman. It 

stated: “I would really appreciate it if you would please take the block off my ad for editing 

. . . . I wont post any more objectionable pics, ok?” In response, C.F. arranged for the 

woman’s editing and posting privileged to be restored: “You should be able to edit 

now. Please let us know if you are still having any trouble.” After this exchange, the 

woman resumed posting ads on Backpage. 

• On July 14, 2012, C.F. received another email from the same woman. It 

stated: “would you please take the edit block off my ad. I need to change some info on it 

and update it. I promise i wont put no more nude pics in it, you have my word. . . . [M]y 

ad says: 50 red roses special – dont miss out.” After this exchange, the woman was allowed 

to continue posting ads on Backpage. 

 • On September 17, 2012, C.F. received another email from the same 

woman. This time, she complained that Backpage was editing her ads (whose title 

continued to feature the obvious prostitution term “50 Red roses special”) to remove the 

most explicit pictures. She stated: “I would like to know why my ad in the escort section 

of backpage keeps getting messed with. . . . [S]omeone keeps erasing the link to my pics 

on the ad. that is so wrong. I am being deprived of income that I sorely need . . . . There 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 79 of 117

 Page ID #:123

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 79 of

 117 Page ID #:252

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 82 of 120
- 24 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

are other woman posting pics on their ads that show more nudity . . . .” After this exchange, 

the woman was permitted to continue posting ads on Backpage. 

• On October 16, 2012, the woman wrote another email to Backpage. In this 

email, she again complained about how Backpage was editing her ads to remove the most 

explicit pictures. She stated: “It is very hard for me to make any income from this ad as 

they continually go into my ad and remove the link from the ad that goes to my 

pictures. They wont allow me to post my pics on the ad yet other women with other ads 

show more nudity than my pictures ever did.” 

• This email was forwarded to VAUGHT and to PADILLA, who asked 

another Backpage employee to “dig into this one a little.” On October 17, 2012, PADILLA 

received a follow-up email from his co-worker stating that the woman’s ad had been posted 

on September 27, was still on the Backpage website, and that the pictures the woman had 

originally attempted to include in the ad (which had been stripped by Backpage) were 

“topless shots.” 

• Following these exchanges, between October 2012 and November 2015, the 

same customer was allowed to post over a dozen new ads on Backpage, many of which 

utilized the same identifying information, coded prostitution terms, and contact phone 

number as before. 

95. On January 7, 2013, VAUGHT was informed by a moderator that Backpage 

wasn’t diligently pursuing reports of child exploitation: “We’ve supposedly been checking 

them, but some seem to be ignored. They get ‘marked as read’, but nothing gets done with 

them. It’s aggravating and irresponsible.” 

96. On June 6, 2013, Backpage received a letter from NCMEC recommending 

the adoption of several specific security measures to prevent the trafficking of children. 

The recommended security measures included (a) verifying the age and identity of users 

who submitted adult ads, (b) verifying the age and identity of individuals depicted in 

photographs within adult ads, (c) prohibiting the use of anonymous payment sources such 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 80 of 117

 Page ID #:124

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 80 of

 117 Page ID #:253

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 83 of 120
- 25 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

as prepaid credit cards, and (d) requiring users to utilize verified email addresses and 

telephone numbers. Afterward, Backpage declined to follow any of these 

recommendations. 

97. On August 30, 2013, LARKIN, SPEAR, BRUNST, HYER, and C.F. 

received an email notifying them that “Chase [Bank] was no longer accepting transactions 

from Backpage.com, due to their involvement in human trafficking.” In response, C.F. 

informed the group that he intended to begin “giv[ing] users free ads if they complain while 

we wait on directly transactions to another processor.” 

98. On September 11, 2013, a Backpage representative made a presentation to 

the Arizona Governor’s Task Force on Human Trafficking. Following this presentation 

(which took place in Phoenix), the representative was asked whether there would be any 

“cons” to requiring verifiable identification of all escorts being advertised on Backpage’s 

website. In response, the representative did not identify any financial or logistical hurdles 

to the adoption of such a requirement. Instead, the representative stated that such a 

requirement would simply cause Backpage to lose business to other prostitution websites 

like myRedBook.com or to overseas prostitution websites. During this meeting, members 

of the task force also provided the representative with evidence showing that Backpage’s 

moderation efforts were ineffective at preventing the publication of prostitution ads. 

99. On April 3, 2014, PADILLA and VAUGHT were forwarded an email that 

had been sent to Backpage by a credit card processing company in Canada. The email 

stated that “[w]e have multiple user accounts that are paying for your services for what I 

understand to be prostitution advertisements” and sought information about “how you are 

processing these transactions.” 

 100. On April 14, 2014, LARKIN and BRUNST received an email from C.F. 

discussing why Backpage had experienced “past high growth” and identifying various 

ideas for achieving “future growth.” This email stated that Backpage had been the 

beneficiary of “[m]igration of content from other . . . marketplaces to the internet” and 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 81 of 117

 Page ID #:125

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 81 of

 117 Page ID #:254

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 84 of 120
- 26 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

identified one particular marketplace as a key source of Backpage’s customers: “[N]et loss 

for brick and mortar marketplaces: Strip clubs, hotels, and gathering spots displaced by the 

internet.” In other words, the email acknowledged that the supposed “escorts” advertising 

on Backpage were actually prostitutes (lawful escorts did not congregate at strip clubs, 

hotels, and other brick-and-mortar “gathering spots” during the pre-internet age). This 

email also attributed Backpage’s success in part to its adoption of policies that allowed 

customers to post ads without leaving any meaningful identifying information—in a list of 

Backpage’s advantageous policies, it identified “Anonymous,” “Prepaid card friendly,” 

“User can post paid ads without a valid email address,” and “bitcoin.” 

 101. On April 24, 2014, VAUGHT sent an email to Backpage’s moderators (while 

cc’ing PADILLA). In this email, VAUGHT explained that if a moderator came across an 

ad containing a link to a “sex for money” website, the moderator should add the link to a 

list of banned terms but “don’t bother removing it from the current ad.” 

 102. On September 4, 2014, Backpage was served with a brief that had been filed 

by NCMEC in a lawsuit in Washington state court. In this brief, NCMEC criticized the 

sincerity of Backpage’s efforts to prevent child sex trafficking: “Backpage has repeatedly 

claimed in public statements and court filings that it is working to reduce child sex 

trafficking on its website. The unpleasant reality is that Backpage publicizes carefully 

selected operational processes as a subterfuge to avoid increased scrutiny, while providing

traffickers with easy access to an online venue to sell children for sex. In practice, 

Backpage’s stated interest in doing something meaningful to stop child sex trafficking ads 

on its site is apparently overridden by the enormous revenue it generates from its escort 

ads, including ads selling children for sex.” 

103. On March 17, 2015, a law enforcement officer with the California 

Department of Justice spoke with a Backpage representative concerning the prevalence of 

blatant prostitution ads on Backpage. In response, the representative did not dispute the

officer’s characterization and said the internet and prostitution were not going away. 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 82 of 117

 Page ID #:126

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 82 of

 117 Page ID #:255

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 85 of 120
- 27 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

104. On July 30, 2015, a document entitled “trainingJuly2015” was distributed to 

Backpage’s moderators. This training manual specifically told moderators that, if they saw 

a photograph depicting “a person [who] looks young/minor,” they should “approve dont 

delete the ad unless it has a banned term.” The training manual also identified, under the 

heading “THESE ARE ALL OKAY,” a long list of terms that are indicative of prostitution, 

such as “99% CUM BACK FOR MORE,” “car service,” and “lollipop special.” 

105. In or around August 2015, as part of a lawsuit in Illinois, Backpage was 

served with an affidavit from a detective employed by the Seattle Police Department. In 

this affidavit, the detective avowed that “[t]o date, no Detective within the Seattle Police 

Department’s Vice/High Risk Victims Unit has ever found a legitimate ‘escort’ (person 

who charges simply for companionship with no offer of sex) or ‘masseuse’ (person offering 

legitimate and licensed massage therapy rather than sex) while responding to ads placed in 

these categories on Backpage.com” and that “every time the Seattle Police Department’s 

Vice/High Risk Victims Unit has responded to an ad in the adult section of Backpage.com, 

we have found that the ad was a posting for illegal activity.” 

106. In or around August 2015, during the same lawsuit in Illinois, Backpage was 

served with a different affidavit from a detective employed by the Boston Police 

Department. In this affidavit, the detective avowed that “Backpage.com is the number one 

site in Boston for prostitution and sex trafficking,” that his unit had “[s]ince 2010 . . . 

arrested over 100 buyers of sex of both adults and minors through Backpage.com ads,” and 

that “nearly all the cases we find associated with it [Backpage] involve pimp controlled 

prostitution.” 

107. On October 7, 2015, PADILLA received an email from another Backpage 

employee (which was later forwarded to VAUGHT) disclosing that there were “massive 

numbers of live ads with banned terms and pictures out on the site.” 

 108. On December 9, 2015, Backpage received an email from a reporter stating

that “[o]f the 359 sex trafficking incidents Toronto Police have been involved in since 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 83 of 117

 Page ID #:127

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 83 of

 117 Page ID #:256

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 86 of 120
- 28 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

2013, every single girl that was rescued was advertised on Backpage.” The email also 

asked: “Why hasn’t Backpage closed down the adult escort ads portion of its site like 

Craigslist when it’s known that underage girls are being exploited via Backpage?” 

 109. In or around January 2016, Company A was retained to serve as a payment 

processor for some of Backpage’s websites. On April 29, 2016, Company A informed C.F. 

that it had conducted “a review of your website, and unfortunately we had to suspend your 

account . . . [because] advertising of illegal activities is strictly forbidden.” 

 110. Beginning in or around January 2016, Backpage’s moderators were 

instructed to stop removing ads that contained the phrase “GFE.” For example, on January 

28, 2016, VAUGHT was sent an email from a Backpage moderator explaining that “As far 

as I am aware we are no longer removing ads for GFE.” Similarly, on March 9, 2016, a 

Backpage moderator sent an email to his coworkers explaining that “Andrew [PADILLA] 

and I talked about the GFE thing, going forward we will not be removing ads for GFE” 

and clarifying “this includes even gfe with price.” And again, on March 25, 2016, an email 

was sent to Backpage’s moderation staff stating that “We are no longer removing ads for 

‘GFE’ or ‘PSE.’” 

111. In fact, the BACKPAGE DEFENDANTS repeatedly acknowledged that the 

term “GFE” (girlfriend experience) is a coded term for prostitution. For example: 

• On October 26, 2010, SPEAR, HYER, and PADILLA received an email 

from C.F. that explained: “No coded sex act for money: GFE, PSE, BBBJ, DATY, etc.” 

• On May 4, 2011, HYER sent an email to PADILLA and others identifying 

GFE as a “code word” that should be forbidden. 

• On August 31, 2011, PADILLA and C.F. exchanged emails in which they 

discussed a list of 100 “solid sex for money terms.” The list included “GFE = girlfriend 

experience.” 

• On November 2, 2011, PADILLA and VAUGHT received an email from a 

co-worker identifying GFE in a list of “sex phrases and coded terms” that are “not 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 84 of 117

 Page ID #:128

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 84 of

 117 Page ID #:257

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 87 of 120
- 29 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

allowed.” 

 112. HYER, PADILLA, and other BACKPAGE DEFENDANTS periodically 

received a “Google alert” when articles discussing Backpage appeared in the news. Many 

of the news articles identified in these alerts discuss instances in which prostitutes who had 

been advertised on Backpage were kidnapped, raped, or murdered. 

113. In January 2017, after conducting a lengthy investigation, the Senate 

Subcommittee on Permanent Investigations (“Subcommittee”) issued a 50-page report 

entitled “Backpage.com’s Knowing Facilitation of Online Sex Trafficking.” This report 

concluded, among other things, that virtually all of Backpage’s “adult” ads are actually 

solicitations for illegal prostitution services and that “Backpage has maintained a practice 

of altering ads before publication by deleting words, phrases, and images indicative of 

criminality, including child sex trafficking . . . . Those practices served to sanitize the 

content of innumerable advertisements for illegal transactions—even as Backpage 

represented to the public and the courts that it merely hosted content others had created.” 

 114. In response to the Subcommittee’s report, Backpage purported to shut down 

the “adult” section of its website. However, the prostitution ads simply migrated to other 

sections of the website, where they remain to this day. 

D. International Operations 

 115. In addition to facilitating prostitution through its U.S. website, Backpage has 

also facilitated prostitution through its websites in foreign countries. In this context,

Backpage often affirmatively creates the content of the illegal prostitution ads being 

published. 

 116. Around 2013 or 2014, Backpage hired a Philippines-based company 

(Company B) in an attempt to increase the profitability of Backpage’s international 

operations. Company B’s employees were instructed to (1) visit rival prostitution websites 

in other countries, (2) obtain the email addresses of prostitutes who were posting ads on 

those websites (often by falsely posing as prospective customers), (3) use the information 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 85 of 117

 Page ID #:129

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 85 of

 117 Page ID #:258

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 88 of 120
- 30 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

from the other website to create a competing prostitution ad on Backpage (a process 

referred to internally as “preboarding”), and then (4) transmit the new ad to the prostitute,

often using the previously-harvested email account information, in an attempt to persuade 

the prostitute to become a Backpage customer. Company B’s employees were paid 

bonuses based on the amount of ad revenue they generated for Backpage using these 

techniques. 

 117. Backpage’s executives were fully aware of the plan to use Company B to 

create prostitution ads outside the United States. For example, on or around November 6, 

2013, C.F. made a presentation to LARKIN, SPEAR, and BRUNST. Among other things, 

this presentation summarized Backpage’s plans for “International Planning and 

Expansion.” One of the plans was to use the Philippines as a “test” market and hire Filipino 

contractors to “contact by email leads, secure email address, add ad and email address in 

[computer system] and assign to American staff. American staff makes contact.” 

 118. On August 7, 2014, HYER sent an email stating that Company B was “an 

efficient and cost effective way for us to bring new users to backpage.” This email also 

contained the following summary of how Company B would operate: “Process after hiring 

company offering BPO services: 1. Backpage provides BPO with sites, categories & 

countries to target. Backpage also provides sample ‘scripts’ and examples of phone 

calls. 2. BPO contacts users via phone from sites backpage provided, obtains user email 

address & permission to preboard ad. 3. BPO preboards ad as public user. 4. After ad is 

preboarded, users receive verification link to verify the ad.” This email also stated that 

Backpage would offer a “bonus per verified authenticated ad.” 

119. On April 10, 2015, a “five-year business plan” was emailed to LARKIN, 

BRUNST, SPEAR, and C.F. One of the goals for 2015 was “Off shore marketing staff in 

the Philippines to grow to 166 and main task is international market content acquisition.”

This email also included a separate attachment stating that HYER should be considered for 

promotion because “his strengths are strong marketing and revenue growth skills” and he 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 86 of 117

 Page ID #:130

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 86 of

 117 Page ID #:259

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 89 of 120
- 31 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

had been “heavily involved in the user experience development” and that VAUGHT should 

be considered for a promotion because “[h]er strengths include six years of experience 

managing moderators.”

 120. On May 15, 2015, a Company B employee posing as a Backpage employee 

sent an email to an apparent prostitute. The subject line was “Offering Free Advertisement 

from Backpage.com” and the text of the email sought to persuade the prostitute to “upgrade 

your ad with sponsor placement or automatic repost.” In response, the prostitute wrote 

back that she had “managed to activate my ad and could buy credits as well. thanks for 

your help. I’m traveling today to [London] how can I change my location.” This email 

exchange was later forwarded by HYER to C.F. with a cover note stating: “[I]deal scenario

for [Company B] agent – user activates ad, user purchases credit.” 

 121. On December 14, 2015, C.F. was part of an email exchange concerning an 

ad that had an IP address associated with Company B. This email contained the following 

description of Company B’s process for creating and selling prostitution ads on Backpage: 

(1) “Staff found lead in assigned area.” (2) “Staff entered all relevant into [database] 

(phone/email/etc.)” (3) “Staff called lead to discuss creation of free ad” (4) Staff created 

free ad for lead (verification email sent). (5) Staff followed under with an email reminding 

lead of phone conversation and detailing verification of ad.” 

E. Select Victim Summaries 

 122. Between in or around 2009 and 2013, Victim 1 was sold for sex, through the 

use of Backpage ads, in Ohio, Indiana, and Georgia. Victim 1’s Backpage ads often 

included words and phrases that were indicative of prostitution, such as “roses” (money). 

On at least one occasion, Victim 1 contacted Backpage after a proposed ad had been 

rejected because it contained banned words and phrases. In response, a Backpage 

representative coached Victim 1 on how to re-write the ad using different words. Victim 

1’s trafficker took all of the money that was earned through her acts of prostitution. 

 123. Between in or around 2009 and 2011, Victim 2 was sold for sex, through the 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 87 of 117

 Page ID #:131

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 87 of

 117 Page ID #:260

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 90 of 120
- 32 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

use of Backpage ads, in Arizona, Georgia, North Carolina, Texas, New York, New Jersey, 

and Louisiana. Victim 2’s trafficker drafted her Backpage ads and Victim 2 initially did 

not know she was being offered on Backpage. The ads contained words and phrases to 

make customers believe Victim 2 was “barely legal” and also contained words and phrases

indicative of prostitution, such as “roses” (money). 

 124. Between in or around 2009 and 2012, Victim 3 was sold for sex, through the 

use of Backpage ads, in Colorado and North Dakota. Victim 3’s pimp instructed her to 

review existing prostitution ads on Backpage to learn how to draft her own ads. During a 

portion of this period, Victim 3 was required by her pimp to make week-long trips to North 

Dakota to work as a prostitute. During these trips, which would generate as much as $2,000 

in prostitution-derived revenue each day, Victim 3 was forced to leave her children at home 

in the care of her pimp. 

 125. In or around 2010, Victim 4 was sold for sex, through the use of Backpage 

ads, in Washington. During this period, Victim 4 was a juvenile (15 years old). Victim 

4’s pimp drafted the ads that were placed on Backpage. The wording of these ads was 

edited by Backpage before publication. The ads contained words and phrases such as 

“W’E’L’L_W’O’R’T’H_I’T***^***150HR” and “IT WONT TAKE LONG AT ALL”

and included pictures of Victim 4 in provocative positions showing her breasts and 

buttocks. 

 126. Between in or around 2011 and 2016, Victim 5 was sold for sex, through the 

use of Backpage ads, in Massachusetts and Rhode Island. During much of this period, 

Victim 5 was a juvenile (14-19 years old). Victim 5’s female pimp instructed Victim 5 

that Backpage was the safest place to advertise because it did not require age verification.

On one occasion, Backpage declined to accept a proposed ad that indicated Victim 5 was 

only 17 years old. In response, the ad was simply resubmitted with a new (false) age of 

19. On other occasions, Backpage removed provocative pictures of Victim 5 from ads and 

then allowed edited versions of the ads to be published. Victim 5’s Backpage ads included 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 88 of 117

 Page ID #:132

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 88 of

 117 Page ID #:261

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 91 of 120
- 33 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

words and phrases that were indicative of prostitution, such as “roses” (money) and “back 

door” (anal sex). Some of the customers who responded Victim 5’s Backpage ads forced 

Victim 5 to perform sexual acts at gun point, choked her to the point of having seizures, 

and gang-raped her. 

 127. In or around June 2012, Victim 6 was sold for sex, through the use of 

Backpage ads, in Arizona. Her traffickers utilized Backpage ads that did not offer a

specific person but instead generally offered a woman with a particular type of hair color

and build. On June 22, 2012, Victim 6 was dispatched to a customer who had responded 

to a Backpage ad featuring “Nadia,” who was described as a slender brunette woman. 

Upon her arrival at the location, Victim 6 was stabbed to death.

 128. Between in or around 2012 and 2015, Victim 7 was sold for sex, through the 

use of Backpage ads, in Washington and Oregon. Victim 7’s pimp drafted the ads that 

were placed on Backpage. The wording of these ads was edited by Backpage before 

publication. The ads contained provocative nude pictures of Victim 7.

 129. Between in or around 2013 and 2014, Victim 8 was sold for sex, through the 

use of Backpage ads, in Maine, Connecticut, and Massachusetts. During this period, 

Victim 8 was a juvenile (15 years old). Victim 8’s uncle, as well as his friends, placed the 

ads on Backpage, which included words and phrases that were indicative of prostitution, 

such as “roses” (money), “fetish friendly,” and 150 for 1/2 hour, 200 for full hour. 

Through these ads, Victim 8 was forced to do “in-calls” (where she was raped in hotels) as 

well as “out-calls” (where she was raped at other locations chosen by the men paying for 

her). 

 130. In or around 2013, Victim 9 was sold for sex, through the use of Backpage 

ads, in Florida. Victim 9’s pimp taught her how to use code words in her Backpage ads to 

indicate how much she was charging for certain sex acts. Victim 9 was brutally attacked 

by her trafficker, causing bruises and a fractured cheek bone. 

 131. Between in or around 2014 and 2015, Victim 10 was sold for sex, through 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 89 of 117

 Page ID #:133

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 89 of

 117 Page ID #:262

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 92 of 120
- 34 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

the use of Backpage ads, in California and Arizona. During some of this period, Victim 

10 was a juvenile (17 years old). An associate of Victim 10’s pimp took pictures of her 

and drafted the ads that were placed on Backpage. The Backpage ads contained words and 

phrases such as “NEW IN TOWN,” “sexy sweet,” and “sweet like honey but super hot like 

fire” and included pictures of Victim 10 in provocative positions showing her legs, 

stomach, shoulder, and buttocks. 

132. Between in or around 2014 and 2015, Victim 11 was sold for sex, through 

the use of Backpage ads, in Arizona, Colorado, Minnesota, Oregon, California, Montana, 

Nevada, New Mexico, and Utah. The Backpage ads contained words and phrases 

indicative of prostitution and included pictures of Victim 11 in provocative positions. On 

some occasions, Backpage would remove certain explicit photos from the ads but publish 

the remaining text and other photos. Victim 11’s trafficker gave her drugs, took her 

identification documents, sexually assaulted her with a firearm, and forced her to work fulltime as a prostitute. 

 133. In or around 2015, Victim 12 was sold for sex, through the use of Backpage 

ads, in California and Arizona. Victim 12 was first advertised on Backpage in San 

Bernardino, California, but moved to the Phoenix metro area because the Super Bowl was 

being held there. Victim 12’s advertisements on Backpage contained words and phrases 

such as “New In Town” and “Sexy Dark Asian Bombshell with a Nice & Tight {Booty}” 

and included pictures showing Victim 12’s legs, stomach, shoulders and buttocks. 

134. In or around 2015, Victim 13 was sold for sex, through the use of Backpage 

ads, in California. During this period, Victim 13 was a juvenile (15 years old). Victim 13 

and her trafficker both posted the Backpage ads, which falsely represented that Victim 13 

was 19 years old and showed pictures of her face and body. On at least one occasion, a 

Backpage representative contacted Victim 13 with instructions on how to fix an ad so it 

could be published. 

 135. In or around June 2015, Victim 14 was sold for sex, through the use of a

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 90 of 117

 Page ID #:134

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 90 of

 117 Page ID #:263

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 93 of 120
- 35 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Backpage ad, in Texas. This ad contained words and phrases such as “fun, young, exotic,” 

“Ready to be your fantasy girl,” “OUT CALLS ONLY,” and “NO BLACK MEN” and 

included pictures of Victim 14’s stomach, breasts, shoulders, and buttocks. On or around 

June 20, 2015, Victim 14 was murdered by a customer. Afterward, the customer attempted 

to destroy Victim 14’s corpse by lighting it on fire. Victim 14’s father later contacted 

Backpage to request that the ads showing his deceased daughter be removed. Backpage 

did not immediately comply with this request. 

 136. In or around June 2015, Victim 15 was sold for sex, through the use of 

Backpage ads, in Texas and Louisiana. These ads contained words and phrases such as 

“Thick Glass of Chocolate Milk Looking for a GoodTime!!!” and “sexy certified freak” 

and contained pictures showing Victim 15’s legs, shoulders and buttocks. On June 10, 

2015, Victim 15 was forced into a vehicle with her trafficker, who was attempting to take 

her to Texas against her will. In an attempt to escape, Victim 15 jumped out of the vehicle 

onto Interstate 10 and was killed after being hit by several vehicles at high speeds. 

 137. In or around July and August 2015, Victim 16 was sold for sex, through the 

use of Backpage ads, in Michigan. These ads contained words and phrases such as 

“OUTCALLS ONLY,” “Juicy Caramel Lady On Duty,” “Sexy, Erotic Caramel Dream,”

and “No Thugs, Pimps Or Weirdos” and contained pictures showing Victim 16’s breasts, 

legs, lips, buttocks, and face. On August 15, 2015, Victim 16 was murdered by a customer. 

Afterward, the customer dumped her corpse in a park. 

 138. Between in or around 2015 and 2016, Victim 17 was sold for sex, through 

the use of Backpage ads, in Arizona and California. Victim 17 averaged ten customers a 

day during this time and turned over all of her prostitution earnings (approximately $1,500 

per day) to her pimp. An associate of Victim 17’s pimp took pictures of her and drafted 

the ads that were placed on Backpage. The Backpage ads contained words and phrases 

such as “IN/CALLS ONLY,” “I’m here to make your wildest fantasies come true!” and 

“Sorry, but NO BLACK MEN” and included pictures of Victim 17’s buttocks and face. 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 91 of 117

 Page ID #:135

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 91 of

 117 Page ID #:264

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 94 of 120
- 36 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

F. Money Laundering Activities 

 139. Backpage’s customers have overwhelmingly used the proceeds of criminal

activity (i.e., money earned from pimping and prostitution) when purchasing ads on 

Backpage. In addition, because Backpage’s publication of such ads is an independent 

crime (e.g., violation of 18 U.S.C. § 1952), the fees it collects from customers posting 

prostitution ads—estimated at more than $500 million since 2004—constitute the proceeds 

of unlawful activity. 

 140. For these and other reasons, banks and financial institutions have repeatedly 

refused to do business with Backpage. In response, the BACKPAGE DEFENDANTS have 

pursued a variety of money laundering strategies. For example, on August 27, 2013, C.F. 

was forwarded an array of emails from Backpage customers who were complaining that 

their credit card companies had refused to process Backpage-related transactions. One 

customer wrote: “Have you resolved the issue of Chase Bank not honoring payment for 

you for ethical reasons?” C.F. forwarded these complaint emails to LARKIN, SPEAR, and 

BRUNST and proposed, as a “solution” to the problem, that Backpage reconfigure its 

website to fool credit card companies into believing the charges were being incurred on a 

different website. 

 141. During a November 2013 presentation by C.F. to LARKIN, SPEAR, and 

BRUNST, C.F. again discussed strategies for fooling credit card companies into believing 

that Backpage-associated charges were being incurred on different websites, including a

proposal to set up shell companies without any apparent connection to Backpage (“create 

new companies with new principals”) and use their bank accounts to accept payment. 

Another “solution” was to “allow users to fund an account thru several other sites” that 

“have no adult or images.” 

 142. On November 6, 2013, LARKIN, SPEAR, and BRUNST received an email 

entitled “Options for the future of Backpage.” This email discussed various strategies for 

creating new entities to process Backpage-related payments “without ever disclosing ties 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 92 of 117

 Page ID #:136

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 92 of

 117 Page ID #:265

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 95 of 120
- 37 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

to Backpage.” 

 143. On April 1, 2015, BRUNST and C.F. were informed that Mastercard was 

“snooping around” Backpage and might stop processing payments for Backpage. In 

response, C.F. offered several suggestions for setting up new payment channels that would 

conceal Backpage’s involvement. One such proposal was to begin routing Backpagerelated transactions through banks located in the country of Mauritius. In response, 

BRUNST stated: “Didnt we go down the Mauritius path once and the banks had the same 

issue with our content?” 

 144. Notwithstanding these strategies, the three major credit card companies 

stopped doing business with Backpage. On or about April 30, 2015, Backpage learned that 

American Express would no longer allow its cards to be used for any purchases in 

Backpage’s adult section. In or around July 2015, Backpage learned that Mastercard would 

no longer allow its cards to be used for Backpage-related transactions. When discussing 

this decision, MasterCard stated that it “has rules that prohibit our cards from being used 

for illegal activities.” Around the same time, Backpage learned that Visa would no longer 

allow its cards to be used for Backpage-related transactions. When discussing this 

decision, Visa stated that its “rules prohibit our network from being used for illegal 

activity.” 

 145. Similarly, some banks closed accounts that were held by Backpage (or 

Backpage-related entities) out of concern the accounts were being used for illegal purposes. 

For example, on April 2, 2014, BRUNST received a letter from U.S. Bank that was 

addressed to “Backpage.com.” The letter explained: “Dear Jed . . . please be advised that 

we have elected to close your Account with us.” 

 146. Backpage responded to these developments in several ways. One was to 

encourage customers to send checks and money orders to a Post Office box held in the 

name of a seemingly-unrelated entity called Posting Solutions LLC (“Posting Solutions”)

and give such customers a corresponding credit on Backpage. For example, on July 31, 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 93 of 117

 Page ID #:137

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 93 of

 117 Page ID #:266

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 96 of 120
- 38 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

2015, C.F. exchanged email correspondence with a representative from a payment 

processing company. In this email, C.F. identified himself as the CEO of Posting 

Solutions, described Backpage as a “brand” operated by Posting Solutions, and explained 

he was seeking to “find a way to position payments under another company.”

147. The following episode provides an example of how the Posting Solutions 

payment process worked. On October 16, 2015, Backpage received an email from a 

customer complaining about her inability to pay for ads using a credit card. In response, a 

Backpage representative explained—in an email exchange later forwarded to VAUGHT—

that “[i]f you would like to pay for upgrades or buy credits, we suggest posting with 

alternative payment methods such as Bitcoin. If you are in the United States, you can also 

pay by check or money order. Please make payable to ‘Posting Solutions.’ WE CAN 

ONLY ACCEPT CHECKS OR MONEY ORDERS MADE OUT TO ‘POSTING 

SOLUTIONS.’ Posting Solutions. Attn: Accounts. P.O. Box 192307. Dallas, TX 75219. 

Please send through the United States Postal Service. FedEx, UPS, or other mail delivery 

alternatives cannot deliver to a P.O. Box. When sending your payment please be sure to 

include your email address. Please do not make your payments out to backpage.com as we 

will no longer be able to accept them.” 

 148. Between around September 2015 and June 2016, over $7.1 million of checks 

and money orders sent by Backpage customers were deposited in bank accounts held by 

Posting Solutions. 

 149. Backpage also utilized a different entity, called Website Technologies, LLC 

(“Website Technologies”), to process Backpage-related funds and took steps to make it 

appear that Backpage and Website Technologies were independent entities. For example, 

on March 10, 2014, BRUNST, SPEAR, and others participated in an email exchange with 

the subject line “Website Technologies vs Backpage (Vendors, audits, risk assessments, 

email).” During this exchange, one person stated “[C.F.] and I were just discussing 

company names and the possibility of updating our email addresses to 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 94 of 117

 Page ID #:138

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 94 of

 117 Page ID #:267

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 97 of 120
- 39 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

websitetechnologies.com.” In response, BRUNST cautioned: “We need to think this thru 

or all the work to separate it from BP will be lost.” Similarly, on April 3, 2014, BRUNST 

sent an email to SPEAR and others explaining that “[b]y May 1 we will have to be out of 

US Bank. We will move all banking under Website Technologies at [a different bank, 

BMO Harris].” 

150. In many instances, Backpage-related money that was initially deposited into 

accounts held by Posting Solutions was later transmitted to accounts held by Website 

Technologies. For example: 

• On October 27, 2015, C.F. received an email entitled “Two packages coming 

your way! (Money Orders).” The email stated that two UPS packages filled with money 

orders were being sent—one containing $47,647.25 of money orders made out to Backpage 

and the other containing $52,251.48 of money orders made out to Posting Solutions. 

• Similarly, on November 16, 2015, C.F. received an email entitled “Three 

packages sent today $441,408.69.” The email stated that three packages filled with money 

orders were being sent—one containing $129,193.61 of money orders made out to 

Backpage, another containing $244,353.63 of money orders made out to Posting Solutions, 

and the last containing an additional $67,861.75 of money orders made out to Posting 

Solutions. 

• And again, on January 29, 2016, a Posting Solutions account wired $2.4 

million to a Website Technologies account. PADILLA and C.F. were both authorized 

signers on the recipient account. 

 151. In addition to receiving millions of dollars from Posting Solutions, the 

Website Technologies accounts also served as the repository for millions of dollars of wires 

from international bank accounts controlled by Backpage-associated entities. For example, 

between January 2015 and December 2016, Website Technologies accounts received over 

$45.4 million in wire transfers from Backpage-associated bank accounts in Liechtenstein, 

over $30.1 million in wire transfers from Backpage-associated bank accounts in Iceland, 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 95 of 117

 Page ID #:139

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 95 of

 117 Page ID #:268

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 98 of 120
- 40 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

and over $3.9 million in wire transfers from Backpage-associated bank accounts in the 

Netherlands. 

152. In many instances, the next stage of the money-laundering process was for 

money to be wired from Website Technologies accounts to bank accounts held by a

different entity called Cereus Properties LLC (“Cereus Properties”). The authorized 

signers on the Cereus Properties accounts included SPEAR and BRUNST. Between 

around December 2015 and October 2016, Website Technologies accounts sent wire 

transfers totaling over $47 million to accounts held by Cereus Properties. 

153. Accounts held by Cereus Properties also received money directly from 

international bank accounts controlled by Backpage-associated entities. For example, 

between around August 2016 and November 2016, Cereus Properties accounts received 

over $11.3 million in deposits and wire transfers from Backpage-associated accounts in the 

Netherlands. 

154. After money reached Cereus Properties, large portions of it were funneled 

back to Backpage or to certain BACKPAGE DEFENDANTS. For example, between 

January 2016 and January 2017, LACEY (and LACEY’s family members) received 

distributions totaling over $30.3 million and LARKIN separately received distributions 

totaling over $21 million. 

155. Backpage also furthered its money laundering efforts through the use of 

bitcoin processing companies. Over time, Backpage utilized companies such as CoinBase, 

GoCoin, Paxful, Kraken, and Crypto Capital to receive payments from customers and/or 

route money through the accounts of related companies. 

 156. Backpage also furthered its money laundering efforts by developing ways for 

customers to purchase ads using gift cards issued by third-party vendors. This process was 

described in a July 23, 2015, email exchange between various Backpage employees on 

which HYER and others were copied. This exchange included the following: “[W]hat if 

we used a customers [sic] payment method, say visa prepaid card, to buy [bitcoin] from 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 96 of 117

 Page ID #:140

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 96 of

 117 Page ID #:269

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 99 of 120
- 41 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

our seller account . . . giving said bitcoin to our catch-all wallet elsewhere (instead of to 

user), simultaneously adding credits/purchasing paid ad or upsells? From the user’s 

perspective they just input their prepaid card and get their credits or purchase.”

COUNT 1

(Conspiracy) 

157. The factual allegations in Paragraphs 1-156 are incorporated by reference 

and re-alleged as though fully set forth herein.

 158. Beginning in or around 2004, and continuing through the present, in the 

District of Arizona and elsewhere, defendants LACEY, LARKIN, SPEAR, HYER, 

PADILLA, and VAUGHT, and others known and unknown to the grand jury, knowingly 

and intentionally agreed, confederated, and conspired with each other, and with others 

known and unknown to the grand jury, to commit the following offenses against the United 

States: 

 a. 18 U.S.C. § 1952(a)(3)(A) (Travel Act—Facilitate Prostitution). 

OBJECT OF THE CONSPIRACY 

 159. The object of the conspiracy was to obtain money. 

MANNER AND MEANS OF THE CONSPIRACY 

 160. The manner and means of the conspiracy are described in paragraphs 1-156 

above, incorporated by reference and re-alleged as though fully set forth herein. 

OVERT ACTS

 161. Overt acts were committed in furtherance of the conspiracy, including but 

not limited to those described in paragraphs 1-156 above, incorporated by reference and 

re-alleged as though fully set forth herein. 

 In violation of 18 U.S.C. § 371.

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 97 of 117

 Page ID #:141

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 97 of

 117 Page ID #:270

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 100 of 120
- 42 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

COUNTS 2-51 

(Travel Act—Facilitate Prostitution) 

162. The factual allegations in Paragraphs 1-161 are incorporated by reference 

and re-alleged as though fully set forth herein.

 163. On or about the dates set forth below, each instance constituting a separate 

count of this Indictment, in the District of Arizona and elsewhere, defendants LACEY, 

LARKIN, SPEAR, HYER, PADILLA, and VAUGHT, and others known and unknown to 

the grand jury, used the mail and any facility in interstate and foreign commerce with intent 

to otherwise promote, manage, establish, carry on, and facilitate the promotion, 

management, establishment, and carrying on of an unlawful activity, to wit: prostitution 

offenses in violation of the laws of the State in which they are committed and of the United 

States, including but not limited to Title 13, Arizona Revised Statutes, Section 13-3214, 

and thereafter performed and attempted to perform an act that did promote, manage, 

establish, carry on, and facilitate the promotion, management, establishment, and carrying 

on of the unlawful activity, as follows: 

Count Date Description

2. Sept. 10, 2013 Publish ad depicting Victim 5 entitled “Get freaky Tuesday . 

. Come spend ur day with us – 19,” with accompanying text 

“Doin incalls and outcalls” 

3. Jan. 27, 2014 Publish ad involving P.R. entitled “50 Red R*O*S*E*S 

S*P*E*C*I*A*L - DONT MISS OUT!!!!!” 

4. Jan. 29, 2014 Publish ad depicting Victim 8 entitled “Puerto Rican mami in 

walpole area INCALLS –19” after deleting one picture from 

the originally-submitted ad

5. Jan. 31, 2014 Publish ad depicting Victim 8 entitled “Exotic latina, south 

portland area, ready to play, INCALLS, 30 min specials!!! – 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 98 of 117

 Page ID #:142

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 98 of

 117 Page ID #:271

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 101 of 120
- 43 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

19” after deleting one picture from the originally-submitted 

ad

6. Feb. 6, 2014 Publish ad involving P.R. entitled “75 Red R*O*S*E*S 

S*P*E*C*I*A*L - DONT MISS OUT!!!!!”

7. Apr. 20, 2014 Publish ad involving P.R. entitled “50 Red R*O*S*E*S 

S*P*E*C*I*A*L - DONT MISS OUT!!!!!” 

8. May 7, 2014 Publish ad involving P.R. entitled “50 Red R*O*S*E*S 

S*P*E*C*I*A*L - DONT MISS OUT!!!!!” 

9. May 31, 2014 Publish ad involving P.R. entitled “50 Red R*O*S*E*S 

S*P*E*C*I*A*L - DONT MISS OUT!!!!!” 

10. July 1, 2014 Publish ad involving P.R. entitled “50 Red R*O*S*E*S 

S*P*E*C*I*A*L - DONT MISS OUT!!!!!”

11. Aug. 19, 2014 Publish ad involving P.R. entitled “50 Red R*O*S*E*S 

S*P*E*C*I*A*L - DONT MISS OUT!!!!!” 

12. Nov. 23, 2014 Publish ad depicting Victim 10 entitled “New in Town Super 

Hot Skinny Mixed Cuban Girl With Long Black Hair – 18” 

after deleting picture from originally-submitted ad 

13. Jan. 29, 2015 Publish ad depicting Victim 12 entitled “New in Town Sexy 

Dark Asain Bombshell with a Nice & Tight {Booty} – 23” 

after deleting one picture from the originally-submitted ad 

14. Jan. 31, 2015 Publish ad depicting Victim 10 entitled “NEW IN TOWN 

sexy sweet European mixed Cuban California girl – 21”

15. Jan. 31, 2015 Publish ad depicting Victim 12 entitled “New in Town Sexy 

Dark Asian mixed Bombshell – 23” after deleting one picture 

from the originally-submitted ad 

16. Feb. 4, 2015 Publish ad depicting Victim 11 entitled “Upscale Independent 

BRUNETTE BOMBSHELL 5-Star Fantasy – 26,” after 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 99 of 117

 Page ID #:143

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 99 of

 117 Page ID #:272

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 102 of 120
- 44 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

deleting pictures from originally-submitted ad 

17. Feb. 18, 2015 Publish ad depicting Victim 11 entitled “Alexis Foxx the 

HOTTEST in town!!!!! – 26,” after deleting six pictures from 

the originally-submitted ad

18. Feb. 26, 2015 Publish ad involving P.R. entitled “50 Red R*O*S*E*S 

S*P*E*C*I*A*L - DONT MISS OUT!!!!!” 

19. May 18, 2015 Publish ad depicting Victim 15 entitled “GORGEOUS ebony 

PLAYMATE Perfect Curves...Skills to make ur TOES 

CURL – 19,” after removing one picture of originallysubmitted ad, with accompanying text “you agree . . . you are 

not affiliated with any law enforcement agency” and “Incalls 

& Outcall!!!” 

20. May 19, 2015 Publish ad depicting Victim 15 entitled “Hot & Driping 

Submissive Ebony Playmates – 20,” after removing one 

picture of originally-submitted ad, with accompanying text 

“you agree . . . you are not affiliated with any law enforcement 

agency” and “We’re ready to please and accommodate all of 

your needs and wants!! With a mouth that’ll ROCK your [] 

and a [picture of cat] that’ll leave you purring for more” 

21. July 1, 2015 Publish ad depicting Victim 17 entitled “AbSoLuTeLy 

AmAziNg CoMe PLaY WiTh Me #1 MoST WaNtEd SwEeT 

SEXii PlAymate – 20,” with accompanying text “By 

contacting me you agree that you are not affiliated with any 

form of law enforcement,” PERFECT & Will satisfy your 

every need,” and “IN/CALLS – ONLY” 

22. July 2, 2015 Publish ad depicting Victim 17 entitled “SeXy!! Exotic 

playmate Call me! the girl you NEED to See! – 20,” with 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 100 of

 117 Page ID #:144

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 100 of

 117 Page ID #:273

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 103 of 120
- 45 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

accompanying text “I DO NOT OFFER 40$, 50$, 60$ 

SPECIALS” and “IN/CALLS – ONLY” 

23. Aug. 13, 2015 Publish ad depicting Victim 13 entitled “Young SEXY 

PUERTO RICAN – 19,” which accompanying text “I do half 

hour sessions that vary in donation prices, 80 for head, 120 

for hooking up without head and 150 for hooking up with 

head”

24. Aug. 15, 2015 Publish ad depicting Victim 16 entitled “Outcalls Now 

Freaky Curvy Caramel Lady OUTCALLS NOW – 23” 

25. Sept. 13, 2015 Publish ad involving P.R. entitled “50 Red R*O*S*E*S 

S*P*E*C*I*A*L - DONT MISS OUT!!!!!”

26. Nov. 28, 2015 Publish ad involving P.R. entitled “50 Red R*O*S*E*S 

S*P*E*C*I*A*L - DONT MISS OUT!!!!!” 

27. Apr. 21, 2016 Publish ad entitled “Finally!! PSE & GFE – Kimber Rae and 

MIA Marie Together BOOK NOW” 

28. Nov. 3, 2016 Publish ad entitled “GFEE New – 18” 

29. Nov. 11, 2016 Publish ad entitled “Mind blowing Tiffany. Incall in Taunton 

– 37,” with accompanying text “Soft GFE . . . Im real and 

reviewed”

30. Nov. 14, 2016 Publish ad entitled “Top Model 2016 Special ‘Best Looking 

Young Asian’ . . . – 22,” with accompanying text “Sexy Asian 

Girl Incall Service” and “GFE” 

31. Nov. 14, 2016 Publish ad entitled “Sometimes It’s All About The Journey, 

And The Destination.....Erectile Dysfunctional G F E 

Provider – 44,” with accompanying test “You can find a few 

current reviews at T3R xxxxxx#” and “I have been EROS 

authenticated” 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 101 of

 117 Page ID #:145

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 101 of

 117 Page ID #:274

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 104 of 120
- 46 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

32. Nov. 19, 2016 Publish ad entitled “The True (G)irl (F)riend (E)xperience... 

Visiting November 27th Sunday ~ PRE-BOOKING 

SPECIAL ~ - 100,” with accompanying text “Let’s blur 

restrictions between financial transaction & Romantic 

Connection” 

33. Nov. 24, 2016 Publish ad entitled “Top Asian Grand Opening 100% Young 

100% Sexy . . . – 23,” with accompanying text “BEST 

INCALL IN TOWN!” and “GFE” 

34. Nov. 26, 2016 Publish ad entitled “I LOVE MEN!! I’m a GFE. OutCall and 

Incall with exception on the Incall!! – 42” 

35. Dec. 20, 2016 Publish ad entitled “OMG Sexy Sensual 36DD-24-36 

Stacked College Coed With The Best Mouth Ever! BOOK 

NOW! -24,” with accompanying text “I do ALL the things 

YOU Wish Your Wife Did!!” and “(G).(F).(E) 30 min/$180”

36. Jan. 15, 2017 Publish ad entitled “Real & Reviewed Girlfriend 

Theonesweet.weebly.com – 30,” with accompanying text 

“250 G F E” 

37. Apr. 4, 2017 Publish ad entitled “KISSING & GFE KOREAN GIRLS – 

20”

38. Apr. 11, 2017 Publish ad entitled “Pettit Sexy #Corey# 4407239339 – 39,” 

with accompanying text “complete GFE experience” 

39. July 3, 2017 Publish ad entitled “WANNA HANG OUT NOW UpScale 

New In Town! Call ME now for an unforgettable visit – 20,” 

with accompanying text “100% GFE with 100% no Pimps”

40. July 15, 2017 Publish ad entitled “Ready for some fun daddy? This is your 

chance too have a amazing time - 21,” with accompanying 

text “Slim body, nice tits, freaky, GFE” 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 102 of

 117 Page ID #:146

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 102 of

 117 Page ID #:275

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 105 of 120
- 47 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

41. July 15, 2017 Publish ad entitled “New in town BiGBubble Booty 

SWEETLiPS HOT BODY – 24,” with “GFE” in 

accompanying text 

42. July 21, 2017 Publish ad entitled “Pettit Sexy #Corey# 4407239339 – 30,” 

with accompanying text “complete GFE experience” 

43. July 23, 2017 Publish ad entitled “ASIAN GODDESS young – 20,” with 

accompanying text “100% Discreet service” and “#GFE” 

44. Jan. 26, 2018 Publish ad entitled “GFE Service Available! Private 

Encounters w/ Pampering Beauty” 

45. Jan. 30, 2018 Publish ad entitled “241 & white plans area Carfun Perfect 

Treat Available No Rush,” with “Sweet Sexy GFE” in 

accompanying text 

46. Jan. 30, 2018 Publish ad entitled “GFE REAL HOT Sweet DREAM 

AMAZING BEST RELAX”

47. Jan. 30, 2018 Publish ad entitled “Tall, Slim & Sexy Luxe Goddess * 

NARCISA * Sensual Body Rub + Fetish Sessions,” with 

accompanying text “gfe Hh: $160 H: $220” 

48. Jan. 31, 2018 Publish ad entitled “Exotic Asian Beauty,” with 

accompanying text “I am an independent GFE with excellent 

massage skills” 

49. Feb. 1, 2018 Publish ad entitled “Nuru (Best GFE ever) incall only” 

50. Feb. 6, 2018 Publish ad entitled “Tuesday with Ashleigh. Available now,” 

with “GFE” in accompanying text

51. Feb. 6, 2018 Publish ad entitled “GFE Kisskisspop 100% Real Photo 

Choice 9Asian girl Nurunude” 

 In violation of 18 U.S.C. § 1952(a)(3)(A) and (b)(1)(i).

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 103 of

 117 Page ID #:147

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 103 of

 117 Page ID #:276

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 106 of 120
- 48 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

COUNT 52

(Conspiracy To Commit Money Laundering)

 164. The factual allegations in Paragraphs 1-163 are incorporated by reference 

and re-alleged as though fully set forth herein. 

 165. Beginning in or around 2004, and continuing through the present, in the 

District of Arizona and elsewhere, defendants LACEY, LARKIN, SPEAR, BRUNST, and 

HYER, and others known and unknown to the grand jury, knowingly and intentionally 

agreed, confederated, and conspired with each other, and with others known and unknown 

to the grand jury, to commit the following offenses against the United States: 

 a. 18 U.S.C. § 1956(a)(1)(A)(i) (Promotional Money Laundering) 

 b. 18 U.S.C. § 1956(a)(1)(B)(i) (Concealment Money Laundering) 

 c. 18 U.S.C. § 1956(a)(2)(A) (Int’l Promotional Money Laundering) 

 d. 18 U.S.C. § 1956(a)(2)(B)(i) (Int’l Concealment Money Laundering) 

e. 18 U.S.C. § 1597 (Transactional Money Laundering) 

 In violation of 18 U.S.C. § 1956(h). 

COUNTS 53-62

(Concealment Money Laundering)

 166. The factual allegations in Paragraphs 1-165 are incorporated by reference 

and re-alleged as though fully set forth herein. 

167. On or about the dates set forth below, each instance constituting a separate 

count of this Indictment, in the District of Arizona and elsewhere, defendants LACEY, 

LARKIN, SPEAR, BRUNST, and HYER, and others known and unknown to the grand 

jury, knowing that the property involved in a financial transaction represented the proceeds 

of some form of unlawful activity, conducted and attempted to conduct such a financial 

transaction which in fact involved the proceeds of specified unlawful activity knowing that 

the transaction was designed in whole and in part to conceal and disguise the nature, the 

location, the source, the ownership, and the control of the proceeds of the specified 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 104 of

 117 Page ID #:148

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 104 of

 117 Page ID #:277

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 107 of 120
- 49 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

unlawful activity, as follows: 

Count Date Amount Description

53. May 18, 2016 $1,476,505.00 Website Technologies (x2008) to Cereus 

Properties (x6211)

54. May 18, 2016 $264,438.00 Website Technologies (x2008) to Cereus 

Properties (x6211) 

55. May 31, 2016 $3,171,675.80 Website Technologies (x2008) to Cereus 

Properties (x6211) 

56. May 31, 2016 $432,961.87 Website Technologies (x2008) to Cereus 

Properties (x6211) 

57. June 20, 2016 $842,878.00 Website Technologies (x2008) to Cereus 

Properties (x6211)

58. June 30, 2016 $3,076,147.75 Website Technologies (x2008) to Cereus 

Properties (x6211) 

59. July 27, 2016 $3,252,681.62 Website Technologies (x2008) to Cereus 

Properties (x6211)

60. July 27, 2016 $438,818.86 Website Technologies (x2008) to Cereus 

Properties (x6211) 

61. Aug. 16, 2016 $804,250.00 Website Technologies (x2008) to Cereus 

Properties (x6211) 

62. Aug. 31, 2016 $3,171,264.42 Website Technologies (x2008) to Cereus 

Properties (x6211) 

 In violation of 18 U.S.C. § 1956(a)(1)(B)(i).

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 105 of

 117 Page ID #:149

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 105 of

 117 Page ID #:278

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 108 of 120
- 50 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

COUNTS 63-68

(International Promotional Money Laundering)

 168. The factual allegations in Paragraphs 1-167 are incorporated by reference 

and re-alleged as though fully set forth herein. 

169. On or about the dates set forth below, each instance constituting a separate 

count of this Indictment, in the District of Arizona and elsewhere, defendants LACEY, 

LARKIN, SPEAR, BRUNST, and HYER, and others known and unknown to the grand 

jury, transported, transmitted, and transferred, and attempted to transport, transmit, and 

transfer, a monetary instrument and funds from a place in the United States to and through 

a place outside the United States, and to a place in the United States from and through a 

place outside the United States, with the intent to promote the carrying on of specified 

unlawful activity, as follows: 

Count Date Amount Description

63. Mar. 4, 2014 $6,450.00 U.S. Bank (x1165) to S.B. (web developer 

in India)

64. Aug. 5, 2016 $5,005,732.86 Ad Tech B.V. (Netherlands) to Cereus 

Properties (x6211) 

65. Sept, 22, 2016 $2,916,955.00 Ad Tech B.V. (Netherlands) to Cereus 

Properties (x6211)

66. Oct. 3, 2016 $354,050.84 Ad Tech B.V. (Netherlands) to Cereus 

Properties (x6211) 

67. Nov. 2, 2016 $2,726,170.00 Ad Tech B.V. (Netherlands) to Cereus 

Properties (x6211)

68. Nov. 15, 2016 $351,403.54 Ad Tech B.V. (Netherlands) to Cereus 

Properties (x6211) 

 In violation of 18 U.S.C. § 1956(a)(2)(A).

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 106 of

 117 Page ID #:150

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 106 of

 117 Page ID #:279

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 109 of 120
- 51 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

COUNTS 69-93

(Transactional Money Laundering)

 170. The factual allegations in Paragraphs 1-169 are incorporated by reference 

and re-alleged as though fully set forth herein. 

171. On or about the dates set forth below, each instance constituting a separate 

count of this Indictment, in the United States and in the District of Arizona and elsewhere, 

the specified defendant, and others known and unknown to the grand jury, knowingly 

engaged and attempted to engage in a monetary transaction in criminally derived property 

of a value greater than $10,000 and is derived from specified unlawful activity, as follows:

Count Defendant Date Amount Description

69. LACEY,

BRUNST 

Aug. 21, 

2013 

$30,000.00 Bank of America (x1793) to 

Stewart Title (partial payment 

for Sedona property)

70. LACEY,

BRUNST 

Sept. 13, 

2013 

$62,491.47 BMO Harris to Stewart Title 

(partial payment for Sedona 

property) 

71. SPEAR June 11, 2014 $300,000.00 National Bank of Arizona 

(x0178) to Spear Family Trust 

72. SPEAR June 20, 2014 $200,000.00 National Bank of Arizona 

(x0178) to TD Ameritrade 

73. SPEAR Nov. 4, 2014 $1,000,000.00 National Bank of Arizona 

(x0178) to UBS Financial

74. SPEAR May 14, 2015 $250,000.00 National Bank of Arizona 

(x0178) to Lincoln National 

Life 

75. SPEAR May 26, 2015 $50,000.00 National Bank of Arizona 

(x0178) to Industrial Property 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 107 of

 117 Page ID #:151

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 107 of

 117 Page ID #:280

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 110 of 120
- 52 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Trust 

76. SPEAR Nov. 3, 2015 $300,000.00 National Bank of Arizona 

(x0178) to Ally Bank

77. SPEAR Dec. 1, 2015 $200,000.00 National Bank of Arizona 

(x0178) to Wells Fargo

78. SPEAR, 

BRUNST 

Jan. 11, 2016 $133,045.00 Cereus Properties (x6211) to 

National Bank of Arizona 

(x0178) 

79. BRUNST Jan. 26, 2016 $101,974.00 Cereus Properties (x6211) to 

Wells Fargo (x4891) 

80. LARKIN,

BRUNST

Feb. 3, 2016 $1,507.944.00 Cereus Properties (x6211) to 

Charles Schwab

81. LACEY,

BRUNST 

Mar. 1, 2016 $1,692,020.00 Cereus Properties (x6211) to 

Bank of America (x5554) 

82. BRUNST Apr. 1, 2016 $220,944.00 Cereus Properties (x6211) to 

Wells Fargo (x4891)

83. LACEY,

BRUNST 

June 27, 2016 $397,9500.00 Arizona Bank & Trust (x1793) 

to Fidelity Title (partial payment 

for San Francisco property) 

84. LACEY,

BRUNST 

July 20, 2016 $12,859,152.57 Arizona Bank & Trust (x1793) 

to Fidelity Title (partial payment 

for San Francisco property)

85. SPEAR July 22, 2016 $50,000.00 National Bank of Arizona 

(x0178) to Strategic Storage 

Trust II 

86. LACEY,

BRUNST 

Aug. 2, 2016 $16,243.00 Cereus Properties (x6211) to 

Wells Fargo (x0495) 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 108 of

 117 Page ID #:152

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 108 of

 117 Page ID #:281

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 111 of 120
- 53 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

87. LARKIN,

BRUNST 

Oct. 6, 2016 $1,206,356.00 Cereus Properties (x6211) to 

Charles Schwab (x4693) 

88. LACEY,

BRUNST

Oct. 6, 2016 $268,016.00 Cereus Properties (x6211) to 

Arizona Bank & Trust (x1967)

89. LACEY,

BRUNST 

Oct. 6, 2016 $268,016.00 Cereus Properties (x6211) to 

Arizona Bank & Trust (x1972) 

90. LACEY,

BRUNST 

Oct. 6, 2016 $268,016.00 Cereus Properties (x6211) to 

Arizona Bank & Trust (x1986) 

91. LACEY,

BRUNST 

Oct. 6, 2016 $268,016.00 Cereus Properties (x6211) to 

Arizona Bank & Trust (x1991) 

92. LACEY,

BRUNST

Oct. 6, 2016 $268,016.00 Cereus Properties (x6211) to 

Arizona Bank & Trust (x2014)

93. SPEAR, 

BRUNST 

Oct. 6, 2016 $141,444.00 Cereus Properties (x6211) to 

National Bank of Arizona 

(x0178) 

 In violation of 18 U.S.C. § 1957. 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 109 of

 117 Page ID #:153

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 109 of

 117 Page ID #:282

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 112 of 120
- 54 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

FORFEITURE ALLEGATION ONE 

[18 U.S.C. 981(a)(1)(C) and 28 U.S.C. § 2461(c)] 

1. Pursuant to Rule 32.2 of the Federal Rules of Criminal Procedure, notice is 

hereby given that the United States will seek forfeiture as part of any sentence, pursuant to 

Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United States Code, 

Section 2461(c), in the event of any defendant’s conviction under Counts 1 through 51 of 

this Indictment. Each defendant so convicted shall forfeit to the United States the 

following: 

a. All right, title, and interest in any and all property, real or personal, 

constituting, or derived from, any proceeds obtained, directly or indirectly, as a result of 

the offense. Such property includes, but is not limited to, the real property located at the 

following addresses: 

i. 1100 UNION ST #0700 SAN FRANCISCO CA 94109-2019 

ii. 2043 PLEASANT HILL RD SEBASTOPOL CA 95472-4947 

iii. 343 PRESIDIO AVE, SAN FRANCISCO, CA 94115 

iv. 2755 FILLMORE ST, SAN FRANCISCO, CA 94123 

v. 5300 STELLA LANE, PARADISE VALLEY, AZ 85253 

vi. 16901 COLEGROVE DR., DALLAS, TX 75248 

vii. 10647 NORTH STATE ROUTE 89A, SEDONA, AZ 

viii. 493 ZINFANDEL LN, ST HELENA, CA 94574 

ix. 5555 N. CASA BLANCA DR, PARADISE VALLEY, AZ 85253 

x. 1308 E. 56TH ST UNIT 2, CHICAGO, IL 60637 

Such property also includes, but is not limited to, funds held in the following bank 

accounts: 

i. Prosperity Bank account number XXXXX7188 

ii. Compass Bank Account number XXXXXX3873 

iii. Compass Bank Account number XXXXXX3825 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 110 of

 117 Page ID #:154

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 110 of

 117 Page ID #:283

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 113 of 120
- 55 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

iv. National Bank of Arizona Account number XXXX0178

v. National Bank of Arizona Account number XXXX0151

vi. National Bank of Arizona Account number XXXX3645

vii. Live Oak Bank Account Number XXXXXXXXXX2523 

viii. Ascensus Broker Dealer Services Account Number XXXXX6943-01 

ix. Ascensus Broker Dealer Services account Number XXXXX5280-01 

x. First Federal Savings & Loan of San Rafael account number XXXX3620 

xi. Republic Bank of Arizona account number XXXX1889

xii. Republic Bank of Arizona account number XXXX2592

xiii. Republic Bank of Arizona account number XXXX2912

xiv. Republic Bank of Arizona account number XXXX2500

xv. Republic Bank of Arizona account number XXXX1938

xvi. Bank of America Account number XXXXXXXXXXXX8225 

xvii. Bank of America Account number XXXXXXXXXXXX7054 

xviii. Bank of America Account number XXXXXXXXXXXX9342 

xix. Bank of America Account number XXXXXXXXXXXX0071 

xx. San Francisco Fire Credit Union Account Number XXXXXXXXXX2523 

xxi. Ally Bank Account Number XXXXXX6292 

xxii. Branch Banking and Trust Bank account number XXXXXXXXX0218 

xxiii. Green Bank Account number XXX4832 

xxiv. Green Bank Account number XXXXXX4293 

xxv. Plains Capital Bank account number XXXXXX1098 

Such property further includes, but is not limited to, the following domain names: 

i. atlantabackpage.com 

ii. backpage.be 

iii. backpage.com 

iv. backpage.com.br 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 111 of

 117 Page ID #:155

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 111 of

 117 Page ID #:284

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 114 of 120
- 56 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

v. backpage.cz 

vi. backpage.dk 

vii. backpage.ee 

viii. backpage.es 

ix. backpage.fi 

x. backpage.fr 

xi. backpage.gr 

xii. backpage.hu 

xiii. backpage.ie 

xiv. backpage.it 

xv. backpage.lt 

xvi. backpage.mx 

xvii. backpage.net 

xviii. backpage.no 

xix. backpage.pl 

xx. backpage.pt 

xxi. backpage.ro 

xxii. backpage.si 

xxiii. backpage.sk 

xxiv. backpage.us 

xxv. backpage-insider.com 

xxvi. bestofbackpage.com 

xxvii. bestofbigcity.com 

xxviii. bigcity.com 

xxix. chicagobackpage.com 

xxx. denverbackpage.com 

xxxi. newyorkbackpage.com 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 112 of

 117 Page ID #:156

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 112 of

 117 Page ID #:285

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 115 of 120
- 57 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

xxxii. phoenixbackpage.com 

xxxiii. sandiegobackpage.com 

xxxiv. seattlebackpage.com 

xxxv. tampabackpage.com 

b. To the extent such property is not available for forfeiture, a sum of 

money equal to the total value of the property described in subparagraph (a). 

2. Pursuant to Title 21, United States Code, Section 853(p), as incorporated by 

Title 28, United States Code, Section 2461(c), the defendant shall forfeit substitute 

property, up to the total value of the property described in the preceding paragraph if, as 

the result of any act or omission of the defendant, the property described in the preceding 

paragraph, or any portion thereof: (a) cannot be located upon the exercise of due diligence; 

(b) has been transferred, sold to or deposited with a third party; (c) has been placed beyond 

the jurisdiction of the court; (d) has been substantially diminished in value; or (e) has been 

commingled with other property that cannot be divided without difficulty. 

FORFEITURE ALLEGATION TWO 

[18 U.S.C. § 982(a)(1)] 

1. Pursuant to Rule 32.2 of the Federal Rules of Criminal Procedure, notice is 

hereby given that the United States will seek forfeiture as part of any sentence, pursuant 

Title 18, United States Code, Section 982(a)(1), in the event of any defendant’s conviction 

under Counts 52 through 93 of this Indictment. Each defendant so convicted shall forfeit 

to the United States the following: 

a. All right, title, and interest in any and all property, real or personal, 

involved in or traceable to any transaction set forth in Counts 52 through 93 of this 

Indictment. Such property includes, but is not limited to, the real property located at the 

following addresses: 

i. 1100 UNION ST #0700 SAN FRANCISCO CA 94109-2019 

ii. 2043 PLEASANT HILL RD SEBASTOPOL CA 95472-4947 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 113 of

 117 Page ID #:157

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 113 of

 117 Page ID #:286

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 116 of 120
- 58 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

iii. 343 PRESIDIO AVE, SAN FRANCISCO, CA 94115 

iv. 2755 FILLMORE ST, SAN FRANCISCO, CA 94123 

v. 5300 STELLA LANE, PARADISE VALLEY, AZ 85253 

vi. 16901 COLEGROVE DR., DALLAS, TX 75248 

vii. 10647 NORTH STATE ROUTE 89A, SEDONA, AZ 

viii. 493 ZINFANDEL LN, ST HELENA, CA 94574 

ix. 5555 N. CASA BLANCA DR, PARADISE VALLEY, AZ 85253 

x. 1308 E. 56TH ST UNIT 2, CHICAGO, IL 60637 

Such property also includes, but is not limited to, funds held in the following bank

accounts: 

i. Prosperity Bank account number XXXXX7188 

ii. Compass Bank Account number XXXXXX3873 

iii. Compass Bank Account number XXXXXX3825 

iv. National Bank of Arizona Account number XXXX0178

v. National Bank of Arizona Account number XXXX0151

vi. National Bank of Arizona Account number XXXX3645

vii. Live Oak Bank Account Number XXXXXXXXXX2523 

viii. Ascensus Broker Dealer Services Account Number XXXXX6943-01 

ix. Ascensus Broker Dealer Services account Number XXXXX5280-01 

x. First Federal Savings & Loan of San Rafael account number XXXX3620 

xi. Republic Bank of Arizona account number XXXX1889

xii. Republic Bank of Arizona account number XXXX2592

xiii. Republic Bank of Arizona account number XXXX2912

xiv. Republic Bank of Arizona account number XXXX2500

xv. Republic Bank of Arizona account number XXXX1938

xvi. Bank of America Account number XXXXXXXXXXXX8225 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 114 of

 117 Page ID #:158

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 114 of

 117 Page ID #:287

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 117 of 120
- 59 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

xvii. Bank of America Account number XXXXXXXXXXXX7054 

xviii. Bank of America Account number XXXXXXXXXXXX9342 

xix. Bank of America Account number XXXXXXXXXXXX0071 

xx. San Francisco Fire Credit Union Account Number XXXXXXXXXX2523 

xxi. Ally Bank Account Number XXXXXX6292 

xxii. Branch Banking and Trust Bank account number XXXXXXXXX0218 

xxiii. Green Bank Account number XXX4832 

xxiv. Green Bank Account number XXXXXX4293 

xxv. Plains Capital Bank account number XXXXXX1098 

Such property further includes, but is not limited to, the following domain names: 

i. atlantabackpage.com 

ii. backpage.be 

iii. backpage.com 

iv. backpage.com.br 

v. backpage.cz 

vi. backpage.dk 

vii. backpage.ee 

viii. backpage.es 

ix. backpage.fi 

x. backpage.fr 

xi. backpage.gr 

xii. backpage.hu 

xiii. backpage.ie 

xiv. backpage.it 

xv. backpage.lt 

xvi. backpage.mx 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 115 of

 117 Page ID #:159

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 115 of

 117 Page ID #:288

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 118 of 120
- 60 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

xvii. backpage.net 

xviii. backpage.no 

xix. backpage.pl 

xx. backpage.pt 

xxi. backpage.ro 

xxii. backpage.si 

xxiii. backpage.sk 

xxiv. backpage.us 

xxv. backpage-insider.com 

xxvi. bestofbackpage.com 

xxvii. bestofbigcity.com 

xxviii. bigcity.com 

xxix. chicagobackpage.com 

xxx. denverbackpage.com 

xxxi. newyorkbackpage.com 

xxxii. phoenixbackpage.com 

xxxiii. sandiegobackpage.com 

xxxiv. seattlebackpage.com 

xxxv. tampabackpage.com 

b. To the extent such property is not available for forfeiture, a sum of 

money equal to the total value of such property. 

2. Pursuant to Title 21, United States Code, Section 853(p), as incorporated by 

Title 18, United States Code, Section 982(b), each defendant convicted under Counts 52 

through 93 of this Indictment shall forfeit substitute property, if, by any act or omission of 

that defendant, the property described in the preceding paragraph, or any portion thereof, 

cannot be located upon the exercise of due diligence; has been transferred, sold to, or 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 116 of

 117 Page ID #:160

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 116 of

 117 Page ID #:289

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 119 of 120
- 61 - 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

deposited with a third party; has been placed beyond the jurisdiction of the court; has been 

substantially diminished in value; or has been commingled with other property that cannot 

be divided without difficulty. 

A TRUE BILL 

S/ 

FOREPERSON OF THE GRAND JURY 

 Date: March 28, 2018 

ELIZABETH A. STRANGE 

First Assistant United States Attorney 

District of Arizona 

JOHN P. CRONAN 

Acting Assistant Attorney General

Criminal Division, U.S. Department of Justice 

S/ KEVIN M. RAPP 

DOMINIC LANZA 

MARGARET PERLMETER 

JOHN J. KUCERA 

Assistant U.S. Attorneys 

REGINALD E. JONES 

Senior Trial Attorney 

U.S. Department of Justice, Criminal Division 

Child Exploitation and Obscenity Section 

Attachment A

Case 2:18-mj-00722-DUTY *SEALED* Document 2 *SEALED* Filed 03/28/18 Page 117 of

 117 Page ID #:161

Case 2:18-mj-00722-DUTY *SEALED* Document 4-1 *SEALED* Filed 03/28/18 Page 117 of

 117 Page ID #:290

Case 2:18-cr-00422-DJH Document 1366-16 Filed 10/26/21 Page 120 of 120