Exhibit M

Case 2:18-cr-00422-DJH Document 1366-15 Filed 10/26/21 Page 1 of 9
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UNITED STATES DISTRICT COURT 

DISTRICT OF ARIZONA 

United States of America, 

Plaintiff, 

vs. 

Michael Lacey, et al., 

Defendants. 

CASE NO. 2:18-cr-00422-004-PHX-SMB 

DECLARATION OF DANIEL J. 

QUIGLEY 

I, Daniel J. Quigley, pursuant to 28 U.S.C. § 1746, declare as follows: 

1. My name is Daniel J. Quigley. I am over the age of eighteen (18) years and 

competent to make this declaration. I make this declaration based on my personal knowledge. 

The facts stated in this declaration all are true and correct and, if called to testify, I would and 

could competently testify as set forth below. 

Rusing Lopez & Lizardi Trust Account 

2. From mid-2010 to May 2018, I was a partner with the law firm of Rusing 

Lopez & Lizardi, PLLC (formerly Rusing and Lopez, PLLC) (“RLL”). 

3. During my time with RLL, I did extensive work for Medalist Holdings, Inc. 

(“Medalist”) and its subsidiaries (including Cereus Properties, LLC) and was the lawyer with 

principal responsibility for that client relationship. 

4. In April 2015, Medalist sold the Backpage.com operations in the United States 

to Atlantische Bedrijven, C.V. (“ABC”), an entity owned and controlled by Carl Ferrer 

(“Ferrer”). At the same time, Medalist sold the international operations of Backpage.com to 

UGC Tech Group C.V. (“UGC”), an entity also owned and controlled by Ferrer. ABC and 

UGC both owed substantial amounts of money to one of Medalist’s subsidiaries under 

promissory notes they executed to pay for the Backpage.com operations they purchased. 

Case 2:18-cr-00422-DJH Document 1366-15 Filed 10/26/21 Page 2 of 9
 

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DANIEL J.

QUIGLEY, PLC

5425 E. Broadway Boulevard, Suite 352 

Tucson, Arizona 85711 

Telephone: (520) 867-4430 

5. In 2017 and 2018, Medalist deposited substantial sums into RLL’s trust account 

in anticipation of future litigation. To fund those deposits, Medalist directed ABC and UGC 

to pay certain sums they owed to Medalist’s subsidiary under the notes directly to RLL. 

6. On or about March 8, 2018, I prepared an accounting of Medalist’s deposits to 

the RLL client trust account for John Brunst, the Chief Financial Officer of Medalist. An 

accurate copy of that accounting is attached as Exhibit A. 

7. Later that day, Mr. Brunst forwarded the accounting to Michael Gage, the Chief 

Financial Officer for Backpage.com, LLC and its affiliates. In his email to Mr. Gage, Mr. 

Brunst confirmed that the payments to RLL would be accounted for as loan payments and 

asked Mr. Gage to identify whether the payments would be accounted for as domestic loan 

payments (ABC) or foreign loan payments (UGC). 

8. Mr. Gage responded the following day, March 9, 2018, identifying 

$2,000,000.00 of the deposits as being payments on behalf of ABC (to be applied to reduce 

the domestic debt) and $3,279,173.07 as being payments on behalf of UGC (to be applied to 

reduce the foreign debt). An accurate copy of that email string is attached as Exhibit B. 

Perkins Coie Trust Account 

9. In July 2012, three subsidiaries of Medalist were named as defendants in a civil 

action in Washington state. Those subsidiaries were Camarillo Holdings, LLC (which then 

was known as Village Voice Media Holdings, LLC), Backpage.com, LLC, and New Times 

Media, LLC. 

10. In January 2017, I began to manage the Washington litigation for Medalist, 

which then owned only Camarillo, having sold New Times Media in January 2013 and 

Backpage.com in April 2015. 

11. At that time, Perkins Coie LLP represented Camarillo, Backpage.com, and 

New Times Media in the Washington litigation. 

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DANIEL J.

QUIGLEY, PLC

5425 E. Broadway Boulevard, Suite 352 

Tucson, Arizona 85711 

Telephone: (520) 867-4430 

12. After commencing to manage the litigation, I sought reimbursement from the 

Traveler’s insurance company for the costs of defending the litigation, under a policy of 

insurance Medalist had obtained to insure itself and its subsidiaries. Perkins Coie assisted in 

that endeavor. 

13. On March 8, 2018, as Traveler’s was concluding its evaluation of the claim, I 

asked the Perkins Coie lawyer assisting me with the claim to direct Traveler’s to wire any 

insurance proceeds from the claim to Perkins Coie’s trust account—which he did later that 

day. 

14. On March 13, 2018, the Traveler’s representative handling the claim informed 

me that Traveler’s had agreed to reimburse legal fees of $1,764,860.75 and other defense 

costs of $407,618.89—a total of $2,172,479.64. She said she expected Traveler’s wire of 

those funds to go out on March 15, 2018. 

15. On March 14, 2018, I asked Perkins Coie to provide me with a complete 

accounting of all deposits to and withdrawals from its trust account in 2017 and 2018. Later 

that day, Perkins Coie transmitted an accounting to me showing a trust balance of zero on 

June 7, 2017, a series of deposits and withdrawals from June 7, 2017, to October 2, 2017, and 

a trust balance of $323,921.28 as of March 14, 2018. 

16. On March 16, 2018, Perkins Coie informed me it had received the 

$2,172,479.64 wire from Traveler’s and the funds were in its trust account. 

17. On March 17, 2018, I asked Perkins Coie to hold the funds from Traveler’s in 

its trust account for future criminal and civil defense costs. 

18. The government seeks to forfeit approximately $2,900,000.00 that Perkins Coie 

held in its trust account. Approximately seventy-five percent (75%) of those funds are the 

proceeds of Traveler’s reimbursement of defense costs for the Washington litigation on or 

about March 16, 2018 

/// 

Case 2:18-cr-00422-DJH Document 1366-15 Filed 10/26/21 Page 4 of 9
 

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DANIEL J.

QUIGLEY, PLC

5425 E. Broadway Boulevard, Suite 352 

Tucson, Arizona 85711 

Telephone: (520) 867-4430 

Other Trust Accounts 

In the course of coordinating the defense of numerous litigation matters for Medalist, I was 

directly involved in arranging deposits to the trust accounts of numerous law firms in 

connection with pending or anticipated litigation, with those deposits being made by 

Backpage-associated entities involved either in domestic operations or foreign operations. 

With respect to the trust deposits at issue in the motion to which this declaration relates, I 

believe that substantial portions of those trust deposits were made by entities involved in 

foreign operations, just as was the case with the RLL trust deposits. 

October 25, 2021. 

/s/ Daniel J. Quigley

Case 2:18-cr-00422-DJH Document 1366-15 Filed 10/26/21 Page 5 of 9
Exhibit A

Case 2:18-cr-00422-DJH Document 1366-15 Filed 10/26/21 Page 6 of 9
Monday, October 25, 2021 at 09:02:51 Mountain Standard Time

Page 1 of 1

Subject: RLL Trust Deposits

Date: Thursday, March 8, 2018 at 12:46:09 PM Mountain Standard Time

From: Daniel Quigley

To: John Brunst

Jed

The informaGon we have about the trust deposits is as follows:

Cereus 

Wire Date Amount Sending Bank Reference No. Wire Reference No.

5/5/17 $499,970.00 3370492123JXLING 170505001067

6/2/17 $1,000,000.00 0339999151JS4870 170602001110

9/18/17 $1,000,000.00 0918128221004021 170918000635

10/3/17 $779,203.07 3136865709 170927001712

11/6/17 $500,000.00 20171106000869UXC 171106008050

1/9/18 $750,000.00 20180109000234 180109003107

1/19/18 $750,000.00 20180119000484 180119005130

 

 $5,279,173.07 

Unfortunately our statements don’t have any informaGon about the originaGng bank (beyond anything that might be

disclosed in the informaGon above—which looks like nothing).

Dan

--

Daniel J. Quigley (dquigley@rllaz.com)

Rusing Lopez & Lizardi, PLLC

6363 N. Swan Road, Suite 151

Tucson, Arizona 85718

(520) 792-4800

(520) 203-0202 (fax to email)

www.rllaz.com

Case 2:18-cr-00422-DJH Document 1366-15 Filed 10/26/21 Page 7 of 9
Exhibit B

Case 2:18-cr-00422-DJH Document 1366-15 Filed 10/26/21 Page 8 of 9
Case 2:18-cr-00422-DJH Document 1366-15 Filed 10/26/21 Page 9 of 9