Exhibit 8

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 1 of 62
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“ASSET TRACING MASTER DOCUMENT DRAFT” COMPARED WITH 

PREVIOUSLY DISCLOSED DOCUMENTS

“ASSET TRACING MASTER 

DOCUMENT DRAFT”

PREVIOUSLY DISCLOSED 

DOCUMENTS

1. On February 15, 2017, Posting 

Solutions LLC, located at 13601 

Preston Rd., Ste. 801E, Dallas, Texas 

75240, opened Prosperity Bank 

account number ‘7188. “M.G.”, the 

President, Chief Executive Officer, 

Treasurer and Secretary of Posting 

Solutions LLC is the sole signatory on 

the account. Posting Solutions LLC is 

a company owned by and controlled 

by Backpage.

36(a). On February 15, 2017, Posting 

Solutions LLC, located at 13601 Preston Rd., 

Ste. 801E, Dallas, Texas 75240, opened 

Prosperity Bank account number 216887188 

(Seized Account 1, which lists Gage as the 

sole signatory on the account). 

(Versoza Affidavit, 4/26/2018 Bates No. 

DOJ-BP-0004598397-DOJ-BP-0004598524, 

attached as Exhibit 1, at ¶ 36(a).) 

36(b). Gage is the President, Chief Executive 

Officer, Treasurer and Secretary of Posting 

Solutions LLC. 

(Ex. 1 at ¶ 36(b).) 

137(g). These accounts were held and 

controlled by Backpage Operators in the 

names of entities controlled by Backpage, 

including Ad Tech BV, Posting Solutions, 

Website Technologies, and Cereus Properties. 

(First Amended Consolidated Master Verified 

Complaint for Forfeiture, filed June 1, 2020, 

Case No. CV-18-8420-RGK, Central District 

California, attached as Exhibit 2, at ¶ 137(g).)

2. Posting Solutions’ application for the 

USPS Dallas, Texas P.O. BOX, lists 

the box being registered to “Website 

Technologies, LLC/Backpage.com.” 

Also listed on the P.O. BOX 

Application were the names of several 

Backpage Operators, including 

FERRER.

35. From my review of Posting Solutions' 

application for the USPS Dallas, Texas P.O. 

BOX, I learned that it was registered to 

“Website Technologies, LC/Backpage.com.” 

Also listed on the P.O. BOX Application 

were the names of several Backpage 

Operators, including Ferrer. 

(Ex. 1 at ¶ 35.)

3. Records of wire transfers from 

countries outside the United States 

deposited into the Prosperity Account 

‘7188 for the period of August 1 

through September 1, 2017, shows 

38. I have reviewed records of wire transfers 

from countries outside the United States 

deposited into the Seized Account 1. Just for 

the period of August 1 through September 1, 

2017, Seized Account 1 received over $2.7 

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this account received over $2,781,750 

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 Prosperity Account 

‘7188. Binary Trading is a 

company used by GoCoin. 

B. On or about August 17, 2017, 

Binary Trading wired another 

$528,500 from a Singapore 

account into Prosperity Account 

‘7188. 

C. On or about August 30, 2017, a 

company named Trilix PTE LTD 

(“Trilex”), 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 Prosperity Account 

‘7188. Memo lines from these 

wires list "GC" or "GC FOR 

INTERNET SERVICES." The 

government understands "GC" to 

mean GoCoin.

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 Seized Account 1. 

Based on my review of records related 

to this transaction, Binary Trading is a 

name used by GoCoin.

B. On or about August 17, 2017, Binary 

Trading wiredvanother $528,500 from 

a Singapore account into Seized 

Account 1.

C. On or about August 30, 2017, a 

company named "TRILIX PTE LTD," 

listing the same Singapore address as 

BinaryTrading and GoCoin, in four 

wires ranging from $385,450 to 

$492,250, sent approximately 

$1,717,750 from a Singapore account 

into Seized Account 1. Memo lines 

from these wires list "GC" or

"GC FOR INTERNET SERVICES." I 

understand "GC" to mean GoCoin. 

(Ex. 1 at ¶¶ 38(a)-(c).)

4. A substantial percentage of outgoing 

payments from Prosperity Account 

‘7188 are payments for the operation 

of Backpage.com. For example, 

between July and October, 2017, 

Prosperity Account ‘7188 wired 

$572,027 to pay for the following:

A. Between July and October 2017, 

Prosperity Account ‘7188 wired 

$570,530 to Verizon Digital Media 

Services in Los Angeles for a service 

for the Backpage.com website.

B. On August 18, 2017, Prosperity 

Account ‘7188 wired $1,497 to 

39. I have reviewed outgoing payments from 

Seized Account 1 and found that substantial 

percentages of these payments are for

the operation of Backpage.com. For example, 

between July and October, 2017, Seized 

Account 1 wired over $1.1 million to pay for

the following:

A. Between July and October 2017, 

Seized Account 1 wired $570,530 to 

Verizon Digital Media Services in Los 

Angeles.

F. On August 18, 2017, Seized Account 

1 wired $1,497 and $6,984, 

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“Backupify,” a company that provided 

data backup for Backpage.

respectively, to two separate data 

backup companies

for Backpage's on-line data backup. 

(Ex. 1 at ¶ 39(a) & (f).)

5. Compass Bank account ‘3873 is 

owned by Cereus Properties LLC, 

identifying SPEAR as the sole 

signatory. This account was funded 

with transfers from Prosperity 

Account ‘7188. It is used as a funnel 

account to pay Backpage Operators 

with funds from the SUA. On 

average, during each month of 2017, 

Prosperity Account ‘7188 transferred 

several hundred thousand dollars into 

Compass Bank account ‘3873. For 

example:

A. On August 31, 2017, Prosperity 

Account ‘7188 sent a wire transfer 

totaling $487,491.45 to Compass 

Bank account ‘3873.

B. On September 15, 2017, Prosperity 

Account ‘7188 sent a wire transfer 

totaling $91,672.67 to Compass Bank 

account ‘3873.

C. On October 2, 2017, Prosperity 

Account ‘7188 sent a wire transfer 

totaling $471,766 to Compass Bank 

account ‘3873.

40. From my review of bank documents, I 

have learned that Seized 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 Seized Account 1. On average, 

during each month of 2017, Seized Account 1 

transferred several hundred thousand dollars 

into Seized Account 2A. For example:

c. On August 31, 2017, Seized Account 1 

sent a wire transfer totaling $487,491.45 to 

SU Seized Account 2A.

d. On September 15, 2017, Seized Account 1 

sent a wire transfer totaling $91,672.67 to 

Seized Account 2A.

e. On October 2, 2017, Seized Account 1 sent 

a wire transfer totaling $471,766 to Seized 

Account 2A.

(Ex. 1 at ¶¶ 40(c)-(e).

6. Compass Bank Account number ‘3825 

is held in the name of Brunst. This account 

was funded with transfers from Compass 

Bank Account ‘3873.

193. Account 24 is held in the name of 

Brunst, and was used in furtherance of the 

money laundering scheme described herein, 

and in an attempt to further conceal or 

disguise the nature, location, source, 

ownership or control of the proceeds of SUA. 

(Ex. 2 at ¶ 193.)

7. On February 2, 2018, Cereus 

Properties Compass Bank account ‘3873 

wired transferred $135,956.59 into Seized 

Account 2B. 

194. On February 2, 2018, Account 2 wire 

transferred $135,956.59 into Account 24. 

(Ex. 2 at ¶ 194.)

8. National Bank of Arizona accounts 

'0178, ‘0151, and ‘3645 are held in the name 

of SPEAR. In furtherance of their money 

37. $404,374.12 in bank funds seized From 

National Bank of Arizona Account No. ‘0178 

(“NBA ‘0178 Funds” or “Account 31”) held 

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laundering scheme, and in an attempt to 

further conceal the true nature of the money, 

Backpage Operators used these accounts as 

go-betweens to funnel money from one 

account to another.

in the name of Scott Spear (“Spear”). Spear 

and Natasha Spear (“N. Spear”) filed a claim 

in member case number CV 18-8423 RGK 

(PJWx).

38. $1,925.80 in bank funds seized from 

National Bank of Arizona Account No. ‘0151 

(“NBA ‘0151 Funds” or “Account 32”), held

in the name of Scott and Ellona Spear (“E. 

Spear”). Spear and N. Spear filed a claim in 

member case number CV 18-8423 RGK 

(PJWx).

39. $613,573.28 in bank funds seized from 

National Bank of Arizona Account No. ‘3645 

(“NBA ‘3645 Funds” or “Account 33”), held

in the name of Scott G. Spear and Ellona 

Spear Family Trust. Spear and N. Spear filed 

a claim in member case number CV 18-8423 

RGK (PJWx).

(Ex. 2 at ¶¶ 37-39.)

9. The tracing involved numerous accounts 

including: Branch Banking & Trust account 

number ‘2008, belonging to Website 

Technologies; Arizona Bank & Trust account 

number ‘6211 belonging to Cereus 

Properties, and a GoCoin account in 

Slovakia.

A. Between December 14, 2015, and 

January 15, 2016, in approximately 26 

wires, a GoCoin account in Slovakia 

transferred over $2.5 million to Branch 

Banking & Trust account number ‘2008 

in the United States. 

B. On January 15, 2016, Branch Banking 

& Trust account number ‘2008 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, 

45. I have reviewed records for Seized 

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 

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Branch Banking & Trust account 

number ‘2008 transferred approximately 

$48 million to Arizona Bank & Trust 

account number ‘6211. 

D. Between March 1, 2016, and July 1, 

2016, Arizona Bank & Trust account 

number ‘6211 wired $892,426 into 

National Bank of Arizona account '0178.

 

E. On September 14, 2017, Compass Bank 

account ‘3873 wired $50,162.05 into 

National Bank of Arizona account '0178. 

F. On October 12, 2017, National Bank of 

Arizona account '0178 wired 

approximately $21,500 into National 

Bank of Arizona account ‘0151.

G. On January 5, 2018, National Bank of 

Arizona account '0178 wired 

approximately $600,000 into National 

Bank of Arizona account ‘3645.

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 Seized Account 3A.

(Ex. 1 at ¶¶ 45(a)-(d).)

46.

a. On September 14, 2017, Seized 

Account 2A wired $50,162.05 into 

Seized Account 3A.

b. On October 12, 2017, Seized Account 

3A wired approximately $21,500 into 

SUBJ Seized Account 3B.

c. On January 5, 2018, Seized Account 

3A wired approximately $600,000 

into Seized Account 3C.

(Ex. 1 at ¶¶ 46(a)-(c).)

10. The Live Oak Bank account ‘6910 is held 

in the name of SPEAR.

40. $260,283.40 in bank funds seized from 

Live Oak Bank Account No. ‘6910 (“LOB 

‘6910 Funds” or “Account 34”), held in the 

name of Scott Gary Spear and Ellona Spear 

Family Trust. Spear and N. Spear filed a 

claim in member case number CV 18-8423 

RGK (PJWx).

(Ex. 2 at ¶ 40.)

11. On or about March 16, 2016, National 

Bank of Arizona account ‘0178 transferred 

$250,000 into Live Oak Bank ‘6910 in the 

name of Scott Spear as an opening deposit. 

On March 20, 2018, Live Oak Bank 

confirmed that these funds have remained 

in Live Oak Bank account ‘6910 since the 

account was opened. 

48. From my review of the records for Seized 

Account 4 (belonging to Spear), I learned 

that on or about March 16, 2016, Seized 

Account 3A transferred $250,000 into Seized 

Account 4 as an opening deposit. On March 

20, 2018, Live Oak Bank confirmed that 

these funds have remained in Seized Account 

4 since the account was opened.

(Versoza Affidavit, 10/31/2018 Bates No. 

DOJ-BP-0004719085-DOJ-BP-0004719327, 

attached as Exhibit 3, at ¶ 48.)

12. Ascensus Broker Services ‘4301 (5A) and 

‘8001 (5B) are held in the name of 

199. Accounts 35 and 36 are held in the 

name of N. Spear, Spear’s adult daughter, 

and were funded with proceeds traceable to

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Natasha Spear, Scott Spear’s adult 

daughter. 

a. On February 23, 2017, National Bank 

of Arizona account ‘0178 wired 

approximately $50,000 into Ascensus 

Broker Services account ‘4301.

b. On the February 23, 2017, National 

Bank of Arizona account ‘0178 wired 

$50,000 into Ascensus Broker Services 

account ‘8001. 

SUA, involved in money laundering, or both.

a. On February 23, 2017, Account 31 

transferred approximately $50,000 into 

Account 35; and

b. On the February 23, 2017, Account 31 

transferred $50,000 into Account 36.

(Ex. 2 at ¶ 199(a)-(b).)

13. First Federal Savings & Loan of San 

Rafael account ‘3620 is held in the name 

of Michael LACEY. In furtherance of 

their money laundering scheme, and in an 

attempt to further conceal the true nature 

of the money, Backpage Operators used 

this account as a go-between1 funneling 

money from one account to another.

a. On October 2, 2017, Compass 

Bank account ‘3825 owned by Cereus 

Properties, wired approximately 

$297,795 into First Federal Savings & 

Loan of San Rafael account ‘3620.

155. Account 4, held in the name of Lacey, 

was funded with transfers from foreign and 

domestic banks, which funds were 

traceable to SUA, involved in money 

laundering, or both. On October 2, 2017,

Account 24 (which was itself funded with 

transfers from foreign and domestic banks 

with proceeds traceable to SUA, involved 

in money laundering, or both), transferred 

$297,795 into Account 4, as further

described below.

(Ex. 2 at ¶ 155.)

14. Republic Bank of Arizona account ‘1889 

is held in the name of LARKIN. In 

furtherance of their money laundering 

scheme, and in an attempt to further 

conceal the true nature of the money, 

Backpage Operators used this account as 

a go-between funneling money from one 

account to another. Republic Bank of 

Arizona account ‘2592 is held in the 

name of James LARKIN

a. On July 6, 2017, Compass Bank 

account ‘3873 wired $971,651.51 

into Republic Bank of Arizona 

account ‘1889.

b. On July 28, 2017, Republic Bank 

of Arizona account ‘1889 wired 

$400,000 into Republic Bank of 

17. $1,546,076.35 in bank funds seized from 

Republic Bank of Arizona Account No. ‘1889 

(“RBA ‘1889 Funds” or “Account 13”) held 

in the name of James Larkin (“Larkin”). 

Larkin and Margaret Larkin (“M. Larkin”) 

have filed claims in member case number CV 

18-8420 RGK (PJWx).

177. Account 13, held in the name of Larkin, 

was funded with proceeds alleged to have 

been traceable to SUA, involved in money

laundering, or both.

a. On July 6, 2017, Account 2 

transferred $971,651.51 into 

Account 13; and

b. On July 28, 2017, Account 13 

transferred $400,000 into Account 

14.

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Arizona account ‘2592.

(Ex. 2 at ¶¶ 17, 177.)

15. Republic Bank of Arizona account ‘8103 

is a CDARS held in the name of James 

LARKIN, Value: $500,000.00. Republic 

Bank of Arizona account ‘8162 is a 

CDARS held in the name of James 

LARKIN, Value: $250,000.00. Republic 

Bank of Arizona account ‘8189 is a 

CDARS held in the name of James 

LARKIN, Value: $250,000.00.

10(g). SUBJECT ACCOUNT 16G: Republic 

Bank of Arizona account number 1021078103 

is a CDARS account held in the name of 

Larkin. 

10(h). SUBJECT ACCOUNT 16H: Republic 

Bank of Arizona account number 1021078162

is a CDARS account held in the name of 

Larkin.

10(i). SUBJECT ACCOUNT 16I: Republic 

Bank of Arizona account number

1021078189 is a CDARS account held in the 

name of Larkin.

(Ex. 1 at ¶¶ 10(g)-(i).)

19. $501,248.14 in bank funds seized from 

Republic Bank of Arizona Account No. ‘8103 

(“RBA ‘8103 Funds” or “Account 16”) held 

in

the name of John Larkin (“J. Larkin”). Larkin 

and M. Larkin have filed claims in member 

case number CV 18-8420 RGK (PJWx).

20. $251,436.93 in bank funds seized from 

Republic Bank of Arizona Account No. ‘8162 

(“RBA ‘8162 Funds” or “Account 17”) held 

in the name of James Larkin. Larkin and M. 

Larkin have filed claims in member case 

number CV 18-8420 RGK (PJWx).

21. $253,639.96 in bank funds seized from 

Republic Bank of Arizona Account ‘8189 

(“RBA ‘8189 Funds” or “Account 18”) held 

in the name of James A. Larkin. Larkin and 

M. Larkin have filed a claim in member case 

number CV 18-8420 RGK (PJWx).

(Ex. 2 at ¶¶ 19-21.)

16. Republic Bank of Arizona account ‘2485 

is held in the name of LACEY. In 

furtherance of their money laundering 

scheme, and in an attempt to further 

10(a). SUBJECT ACCOUNT 16A: Republic 

Bank of Arizona account number 11402485 is 

a money market account held in the name of 

Lacey.

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conceal the true nature of the money, 

Backpage Operators used this account as 

a go-between funneling money from one 

account to another. Republic Bank of 

Arizona account ‘3126 is held in the 

name of LACEY. Republic Bank of 

Arizona account ‘1897 is held in the 

name of LACEY. In furtherance of their 

money laundering scheme, and in an 

attempt to further conceal the true nature 

of the money, Backpage Operators used 

these account as a go-between funneling 

money from one account to another.

a. On December 2, 2016, the Foreign 

Account in the Netherlands wired 

$324,055.85 to Compass Bank account ‘3873.

b. On December 8, 2016, the Netherland 

Account wired $499,970.00 to Compass Bank 

account ‘3873.

c. On December 27, 2016, the Foreign 

Account wired $199,970.00 to Compass Bank 

account ‘3873.

d. From March through December 2017, 

Compass Bank account ‘3873 paid over 

$9,000 to "Cox Communications," an internet 

services company that Backpage uses to 

facilitate its internet presence and promote its 

sale of prostitution advertising. 

e. On May 31, 2017, Compass Bank 

account ‘3873 wired approximately 

$676,808.04 into Republic Bank of Arizona 

account ‘2485. 

f. On June 30, 2017 Republic Bank of 

Arizona account ‘2485 transferred $600,000 

to Republic Bank of Arizona account ‘1897.

On April 16, 2018, LACEY personally went 

into the Republic Bank of Arizona, withdrew 

$500,000 from Republic Bank of Arizona 

10(b). SUBJECT ACCOUNT 16B: Republic 

Bank of Arizona account number 11101897 is 

a checking account held in the name of Lacey.

10(c). SUBJECT ACCOUNT 16C: Republic 

Bank of Arizona account number 11003126 is 

an account held in the name of Lacey.

(Ex. 1 at ¶¶ 10(a)-(c).)

153. Funds from Account 2 were also used to 

promote and facilitate prostitution. For

example:

a. On December 2, 2016, the Netherlands 

Account transferred $324,055.85 to Account 2;

b. On December 8, 2016, the Netherlands 

Account transferred $499,970.00 to Account 2;

c. On December 27, 2016, the Netherlands 

Account transferred $199,970.00 to Account 2;

d. From March to December 2017, Account 2 

paid over $9,000 to “Cox Communications,” 

an internet services company that Backpage 

used to facilitate its internet presence and 

promote its sale of prostitution advertising.

156. Accounts 5 and 7, each held in the name 

of Lacey, were funded with transfers from 

foreign and domestic banks, which funds were 

traceable to SUA, involved in money 

laundering, or both. Backpage Operators used 

Accounts 5 and 7 as pass-through accounts.

a. On May 31, 2017, Account 2 transferred 

approximately $676,808.04 into Account 5;

(Ex. 2 at ¶¶ 153, 156.)

17(b). On June 30, 2017 SUBJECT 

ACCOUNT 16A transferred $600,000 to 

SUBJECT ACCOUNT 16B.

17(c). On April 16, 2018, Lacey personally 

went into the Republic Bank of Arizona, 

withdrew $500,000 from SUBJECT 

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account ‘2485 and opened Republic Bank of 

Arizona account ‘3126 with an initial deposit 

of the $500,000 he had just withdrawn from 

Republic Bank of Arizona account ‘2485.

ACCOUNT 16A and opened SUBJECT 

ACCOUNT 16C with an initial deposit of the 

$500,000 he had just withdrawn from 

SUBJECT ACCOUNT 16A.

(Ex. 1 at ¶¶ 17(b)(c).)

17. Republic Bank of Arizona account ‘8103 

is a CDARS held in the name of James 

LARKIN, Value: $500,000.00. Republic 

Bank of Arizona account ‘8162 is a 

CDARS held in the name of James 

LARKIN, Value: $250,000.00. Republic 

Bank of Arizona account ‘8189 is a 

CDARS held in the name of James 

LARKIN, Value: $250,000.00.

a. On July 28, 2017, Republic Bank 

of Arizona account ‘1889 wired 

$400,000 into Republic Bank of 

Arizona account ‘2592.

b. On or about February 8, 2018, 

LARKIN wrote a check from $1 

million drawn from Republic 

Bank of Arizona account ‘2592. 

This check was paid to Republic 

Bank of Arizona and was used to 

fund LARKIN’s CDARS 

accounts; Republic Bank of 

Arizona account ‘8103 (which 

received $500,000), Republic 

Bank of Arizona account ‘8162 

(which received $250,000), and 

Republic Bank of Arizona 

account ‘8189 (which received 

$250,000).

10(g). SUBJECT ACCOUNT 16G: Republic 

Bank of Arizona account number 1021078103 

is a CDARS account held in the name of

Larkin.

10(h). SUBJECT ACCOUNT 16H: Republic 

Bank of Arizona account number 1021078162 

is a CDARS account held in the name of

Larkin.

10(i). SUBJECT ACCOUNT 16I: Republic 

Bank of Arizona account number 1021078189 

is a CDARS account held in the name of 

Larkin.

(Ex. 1 at ¶¶ 10(g)-(i).)

177(b). On July 28, 2017, Account 13 

transferred $400,000 into Account 14.

179(b). On or about February 8, 2018, $1 

million in funds from Account 14 was used to 

fund Account 16 (which received $500,000),

Account 17 (which received $250,000), and 

Account 18 (which received $250,000).

(Ex. 2 at ¶¶ 177(b), 179(b).)

18. Republic Bank of Arizona account ‘8316 

is a Certificate of Deposit Account 

Registry Service (“CDARS”) and is held 

in the name of LACEY. Republic Bank 

of Arizona account ‘8324 is a Certificate 

of Deposit Account Registry Service 

(“CDARS”) and is held in the name of 

10(d). SUBJECT ACCOUNT 16D: Republic 

Bank of Arizona account number 1021078316 

is a Certificate of Deposit Account

Registry Service ("CDARS") account held in 

the name of Lacey.

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LACEY. Republic Bank of Arizona 

account ‘8332 is a Certificate of Deposit 

Account Registry Service (“CDARS”) 

and is held in the name of LACEY. In 

furtherance of their money laundering 

scheme, and in an attempt to further 

conceal the true nature of the money, 

Backpage Operators used this account as 

a go-between funneling money from one 

account to another.

a. On October 2, 2017 Cereus Properties 

at Compass Bank account ‘3873 wired 

two wires to LACEY controlled 

accounts:

i. $694,856.25 was wired to 

LACEY’s San Francisco Fire 

Credit Union account ‘2523

ii. 297,795.54 was wired to LACEY’s 

First Federal Savings & Loan of 

San Rafael account ‘3620.

b. On or about February 15, 2018, 

LACEY drafted two checks totaling 

$1.2 million, which he split between 

three of his “CDARS” accounts at 

Republic Bank of Arizona: ‘8316, 

‘8324 and ‘8332. The first check was 

drawn from First Federal Savings & 

Loan of San Rafael account ‘3620 in 

the amount of $600,000. The second 

check was drawn from San Francisco 

Fire Credit Union account ‘2523, also 

in the amount of $600,000. The 

combination of these two checks 

totaling $1.2 million. Republic Bank

of Arizona account ‘8316 received 

$600,000.

e. SUBJECT ACCOUNT 16E: Republic 

Bank of Arizona account number 1021078324 

is a CDARS account held in the name of

Lacey.

f. SUBJECT ACCOUNT 16F: Republic Bank 

of Arizona account number 1021078332 is a 

CDARS account held in the name of

Lacey.

(Ex. 1 at ¶¶ 10(d)-(f).)

Accounts 5, 7-10 (RBA ‘2485, ‘3126, ‘8316, 

‘8324, and ‘8332)

156. Accounts 5 and 7, each held in the name 

of Lacey, were funded with transfers from 

foreign and domestic banks, which funds

were traceable to SUA, involved in money 

laundering, or both. Backpage Operators used

Accounts 5 and 7 as pass-through accounts.

156(f). On October 2, 2017, Account 2 made 

two transfers:

i. $297,795.54 transferred to Account 4; 

and

ii. $694,856.25 wired to Account 11.

156(g). On or about February 15, 2018, Lacey 

drafted two $600,000 checks (totaling $1.2 

million). One check was drawn from Account 

11, and the second was drawn from Account 

4. These two checks were used to fund 

Accounts 8, 9, and 10, respectively, with 

$600,000.00, $300,000.00, and $300,000.00.

(Ex. 2 at ¶¶ 156.)

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19. The Bank of America account ‘8225 is 

held in the name of Troy Larkin.

a. On February 2, 2018, Compass Bank 

account ‘3873 wired $28,337 into 

Bank of America account ‘8225.

182. Account 22 is held in the name of one of 

Larkin’s children, T. Larkin, and was used in 

furtherance of the money laundering scheme

described herein, and in an attempt to further 

conceal or disguise the nature, location, 

source, ownership or control of the criminal

proceeds.

183. On February 2, 2018, Account 2 wire 

transferred $28,337 into Account 22.

(Ex. 2 at ¶¶ 182-183.)

20. The Bank of America account ‘7054 is 

held in the name of Ramon Larkin.

a. On February 2, 2018, Compass Bank 

account ‘3873 wired $28,337 into 

Bank of America account ‘7054.

184. Account 23 is held in the name of R. 

Larkin. On February 2, 2018, Account 2 wire 

transferred $28,337 into Account 23.

(Ex. 2 at ¶ 184.)

21. The Bank of America account ‘9342 is 

held in the name of Daniel Hyer and 

Melissa Deeann Row-Hyer.

a. On August 2 and August 8, 2017, 

Prosperity Account bank ‘7188 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 

Bank of America account ‘9342.

53. From my review of Seized Account 1, 

BC, and 8D, I learned the following:

a. On August 2 and August 8, 2017, 

Seized 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 

Seized Account BC.

(Ex. 1 at ¶ 53.)

22. The Bank of America account ‘9342 is 

held in the name of Daniel Hyer.

a. Between November 3, 2017, and 

December 8, 2017, Bank of America 

account ‘9342 wired $57,500 into 

Bank of America account ‘0071.

52(c). Between November 3, 2017, and 

December 8, 2017, Seized Account BC wired 

$57,500 into Seized Account 8D.

(Ex. 1 at ¶ 52(c).)

23. The San Francisco Fire Credit Union 

account ‘2523 was held in the name of 

Michael LACEY and Jean K. Warren.

a. On February 2, 2018, Compass Bank 

account ‘3873 wired $734,603.70 into 

San Francisco Fire Credit Union 

account ‘2523.

54. From my review of the records for Seized 

Account 2A, 2B, and 9, I learned that on 

February 2, 2018, Seized Account 2A

wired $734,603.70 into Seized Account 9.

(Ex. 1 at ¶ 54.)

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 12 of 62
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24. The Green Bank accounts ‘4831 and 

‘4293 were held in the name of FERRER.

a. On August 8, 2017, Prosperity 

Account bank ‘7188 wired $62,000 

into Green Bank account ‘4832. 

b.On December 8, 2017, Seized 

Account 12A wired $20,000 into 

Green Bank account ‘4293.

58. From my review of financial records for 

Seized Account 1, 12A, and 12B, I learned 

the following:

a. On August 8, 2017, Seized Account 1 

wired $62,000 into Seized Account 12A.

59. On December 8, 2017, Seized Account 

12A wired $20,000 into Seized Account 12B.

(Ex. 1 at ¶ 58-59.)

25. Perkins Coie Trust Company account 

number ‘0012 held in the name of 

Margaret LARKIN, LARKIN’S spouse. 

In furtherance of their money laundering 

scheme, and in an attempt to further 

conceal the true nature of the money, 

Backpage Operators used this account in 

a series of transfer between payments 

made for the SUA and other accounts.

61. “I have reviewed records for Seized 

Account 14 as well as the following accounts: 

the BBT Account; the AZBT Account; 

Charles Schwab account number 49074693 in 

the name of Larkin ("Schwab Account"); 

Northern Trust Company account number 

2389562 under the name "Ocotillo Family 

Trust," belonging to James Larkin" 

("Northern Trust Account"); and Morgan 

Stanley account number 237-061673 

belonging to James Larkin and his wife, 

Margaret Larkin (the "Morgan Stanley 

Account"). Additionally, I have reviewed 

GoCoin transactions related to certain ads 

posted on Backpage, specifically including 

ads that related to child victims A.C., S.F., 

T.S., S.L., K.O., and R.W. (previously 

described in paragraph 26, above). Finally, I 

reviewed emails associated with the email 

addresses used to post some of the ads 

promoting the trafficking of A.C., S.F., T.S.,

S.L., K.O., and R.W.”

(Ex. 1 at ¶ 61.)

26. The different accounts involved in this 

tracing include: Branch Banking & Trust 

account number ‘2008, belonging to 

Website Technologies; Arizona Bank & 

Trust account number ‘6211 belonging to 

Cereus Properties, Charles Schwab 

account number ‘4693 in the name of 

LARKIN; Northern Trust Company 

account number ‘9562 under the name 

“Ocotillo Family Trust,” belonging to 

James LARKIN”; and Morgan Stanley 

account number ‘1673 belonging to 

James LARKIN and his wife, Margaret 

61. “I have reviewed records for Seized 

Account 14 as well as the following accounts: 

the BBT Account; the AZBT Account; 

Charles Schwab account number 49074693 in 

the name of Larkin ("Schwab Account"); 

Northern Trust Company account number 

2389562 under the name "Ocotillo Family 

Trust," belonging to James Larkin" 

("Northern Trust Account"); and Morgan 

Stanley account number 237-061673 

belonging to James Larkin and his wife, 

Margaret Larkin (the "Morgan Stanley 

Account"). Additionally, I have reviewed 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 13 of 62
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LARKIN; and GoCoin transactions 

related to certain ads posted on 

Backpage, specifically including ads that 

related to child victims A.C., S.F., T.S., 

S.L., K.O., and R.W.

a. On September 6, 2015, a bitcoin account 

associated with the owner of the email 

address who trafficked A.C. and S.F. paid 

Backpage about $4 worth of bitcoin in 

order to post an ad promoting the 

trafficking of those victims in Palm 

Springs, California.

b. On September 15, 2015, an email from the 

same email address owner indicated a 

payment to Backpage of about $8 worth 

of bitcoin in order to "Fund Account"2 for 

palmsprings.backpage.com. 

c. On October 6, 2015, the same email 

address owner paid Backpage about $1 

worth of bitcoin to "Fund Account" on 

palmsprings.backpage.com.

d. On October 30, 2015, a bitcoin account 

associated with the owner of the email 

address who trafficked T.S., S.L., K.O., 

and R.W. paid Backpage about $1 worth 

of bitcoin in order to post an ad promoting 

the trafficking of those victims in 

Columbus, Ohio.

e. On November 2, 2015, this same email 

address owner paid Backpage about $1 

GoCoin transactions related to certain ads 

posted on Backpage, specifically including 

ads that related to child victims A.C., S.F., 

T.S., S.L., K.O., and R.W. (previously 

described in paragraph 26, above) . Finally, I 

reviewed emails associated with the email 

addresses used to post some of the ads 

promoting the trafficking of A.C., S.F., T.S.,

S.L., K.O., and R.W.”

a. On September 6, 2015, a bitcoin account

associated with the owner of the email 

address who trafficked A.C. and S.F. paid 

Backpage about $4 worth of bitcoin in 

order to post an ad promoting the 

trafficking of those victims in Palm 

Springs, California.

b. On September 15, 2015, an email from 

the same email address owner indicated a 

payment to Backpage of about $8 worth 

of bitcoin in order to "Fund Account" for 

palmsprings.backpage.com. Based on 

information I have learned through this 

investigation, I believe that to "Fund 

Account" means that the email address 

owner provided bitcoin to Backpage as 

payment for credit to be used at a later 

time to pay for Backpage ads.

c. On October 6, 2015, the same email 

address owner paid Backpage about $1 

worth of bitcoin to "Fund Account" on 

palmsprings.backpage.com. 

d. On October 30, 2015, a bitcoin account 

associated with the owner of the email 

address who trafficked T.S., S.L., K.O.,

and R.W. paid Backpage about $1 worth 

of bitcoin in order to post an ad 

promoting the trafficking of those victims 

in Columbus, Ohio.

e. On November 2, 2015, this same email 

address owner paid Backpage about $1 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 14 of 62
14

worth of bitcoin to "Move Ad to Top of 

Listings" in the Columbus, Ohio 

Backpage ads.

f. On November 21, 2015, this same email 

address owner paid Backpage about $1 

worth of bitcoin to Backpage for credit for 

that email owner's Backpage ad account.

g. During the period of September 4, 2015, 

and November 23, 2015, Backpage 

advertisers used bitcoin to purchase about 

1,000,000 "adult" ads from Backpage. 

Backpage then sold that bitcoin to GoCoin 

for approximately $8.6 million. Included 

among the bitcoin sold to GoCoin during 

this period were the six payments the 

pimps made to Backpage to purchase ads 

to promote child prostitution.

h. During the period of December 14, 2015, 

through December 29, 2015, a GoCoin 

account held in Slovakia wired over $1.25 

million to Branch Banking & Trust 

account ‘2008 in the United States. The 

$1.25 million represented GoCoin's partial 

payment to Backpage for the bitcoin 

Backpage sold to GoCoin during the 

period of September 4, 2015, through 

November 23, 2015. 

i. On December 31, 2015, Branch Banking 

& Trust account ‘2008 wired $811,424 to 

Arizona Bank & Trust account ‘6211.

j. On January 11, 2016, Arizona Bank & 

Trust account ‘6211 wired approximately 

$1.3 million to Charles Schwab account 

‘4693.

k. On January 14, 2016, Charles Schwab 

account ‘4693 wired approximately $13.5 

million to the Northern Trust Account.

l. In July 21, 2017, Northern Trust 

Company account ‘9562 wired $6.014 

million to Morgan Stanley account ‘1673.

worth of bitcoin to "Move Ad to Top of 

Listings" in the Columbus, Ohio 

Backpage ads.

f. On November 21, 2015, this same email 

address owner paid Backpage about $1 

worth of bitcoin to Backpage for credit 

for that email owner's Backpage ad 

account.

g. During the period of September 4, 2015, 

and November 23, 2015, Backpage 

advertisers used bitcoin to purchase about 

1,000,000 "adult" ads from Backpage. 

Backpage then sold that bitcoin to 

GoCoin for approximately $8.6 million. 

Included among the bitcoin sold to 

GoCoin during this period were the six 

payments the pimps made to Backpage to 

purchase ads to promote child 

prostitution.

h. During the period of December 14, 2015, 

through December 29, 2015, a GoCoin 

account held in Slovakia wired over 

$1.25 million to the BBT Account in the 

United States. Based on my review of

GoCoin's financial records and GoCoin's 

pattern of payments to Backpage for 

bitcoin sales, I believe that this $1.25 

million represented GoCoin's partial 

payment to Backpage for the bitcoin 

Backpage sold to GoCoin during the 

period of September 4, 2015, through 

November 23, 2015.

i. On December 31, 2015, the BBT 

Account wired $811,424 to the AZBT 

Account.

j. On January 11, 2016 the AZBT Account 

wired approximately $1.3 million to the 

Schwab Account.

k. On January 14, 2016, the Schwab 

Account wired approximately $13.5 

million to the Northern Trust Account.

l. In July 21, 2017, the Northern Trust 

Account wired $6.014 million to the 

Morgan Stanley Account.

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 15 of 62
15

m. In or about November 2017, Morgan 

Stanley elected to terminate its business 

relationship with LARKIN. 

n. Following this, on November 30, 2017, 

LARKIN wired all the funds then held 

Morgan Stanley account ‘1673, about $10 

million dollars, to Perkins Coie Trust

Company account number ‘0012.

o. Some of the funds in Perkins Coie Trust 

Company account number ‘0012 were 

used, among other things, to purchase 

bonds and/or securities, which assets 

remain held in Perkins Coie Trust 

Company account number ‘0012.

m. In or about November 2017, Morgan 

Stanley elected to terminate its business 

relationship with Larkin.

n. Following this, on November 30, 2017, 

Larkin wired all the funds then held the 

Morgan Stanley Account, about $10 

million dollars, to Seized Account 14.

o. Some of the funds in Seized Account 14 

were used, among other things, to 

purchase bonds and/or securities, which 

assets remain held in Seized Account 14.

(Ex. 1 at ¶¶ 61.)

27. Alliance Bernstein accounts ‘6878, ‘4954, 

‘7892, ‘7889, ‘7888 ‘0582, and ‘6485 are 

held in the name of the “BRUNST Family 

Trust.” BRUNST and his wife, Mary 

BRUNST, are the sole trustees for these 

accounts. In furtherance of their money 

laundering scheme, and in an attempt to 

further conceal the true nature of the 

money, Backpage Operators used this 

account as a go-between funneling money 

from one account to another.

a. During the period between September 4, 

2015, and November 23, 2015, Backpage 

advertisers used bitcoin to purchase about 

1,000,000 “adult” ads from Backpage. 

Backpage then sold that bitcoin to GoCoin 

for approximately $8.6 million. Included 

among the bitcoin sold to GoCoin during 

this period were the six payments the 

pimps made to Backpage to purchase ads 

to promote child prostitution.

b. During the period of December 14, 2015, 

through December 29, 2015, a GoCoin 

account held in Slovakia wired over $1.25 

62. I have reviewed records for Seized 

Account 15 as well as the following accounts: 

the BBT; the AZBT Account; Wells Fargo 

Bank Account number 6324184891, 

belonging to John Brunst ("WFB Account -

891"); and Wells Fargo Bank Account 

number 00007910147474, belonging to the 

Brunst Family Trust ("WFB Account -474"). 

Additionally, I have reviewed GoCoin 

transactions related to certain ads posted on 

Backpage, specifically including ads that 

related to child victims A.C., S.F., T.S., S.L., 

K.O., and R.W. (previously described in 

paragraph 26, above.) Finally, I reviewed 

emails associated with the email addresses 

used to post some of the ads promoting the 

trafficking of A.C., S.F., T.S., S.L., K.O., and 

R.W. From this review I observed the 

following: 

g. During the period of September 4, 2015, 

and November 23, 2015, Backpage 

advertisers used bitcoin to purchase about 

1,000,000 "adult" ads from Backpage. 

Backpage then sold that bitcoin to GoCoin 

for approximately $8.6 million. Included 

among the bitcoin sold to GoCoin during 

this period were the six payments the 

pimps made to Backpage to purchase ads 

to promote child prostitution.

h. During the period of December 14, 2015, 

through December 29, 2015, a GoCoin 

account held in Slovakia wired over $1.25

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 16 of 62
16

million to Branch Banking & Trust 

account ‘2008 Account belonging to 

Website Technologies in the United States 

which represented GoCoin’s partial 

payment to Backpage for the bitcoin 

Backpage sold to GoCoin during the 

period of September 4, 2015, through 

November 23, 2015. 

c. On December 31, 2015, the Branch 

Banking & Trust account ‘2008 wired 

$811,424 to Arizona Bank & Trust 

account ‘6211 belonging to Cereus 

Properties.

d. On December 6, 2016, Arizona Bank & 

Trust account ‘6211 wired $161,459 to 

Wells Fargo Bank account ‘4891, 

belonging to BRUNST.

e. On January 4, 2017, Arizona Bank & 

Trust account ‘6211 wired another 

$258,841 to Wells Fargo Bank account 

‘4891.

f. On January 5, 2017, Wells Fargo Bank 

account ‘4891 transferred $300,000 to 

Wells Fargo Bank account ‘7474 

belonging to the BRUNST Family Trust.

g. On May 19, 2017, Wells Fargo Bank 

account ‘7474 wired about $1.5 million 

into Alliance Bernstein account ‘6878.

h. On May 23, 2017, Alliance Bernstein 

account ‘6878 transferred about $350,000 

to Alliance Bernstein account ‘6878.

i. On June 7, 2017, Alliance Bernstein 

account ‘6878 transferred about $1.34 

million to Alliance Bernstein account 

‘6878.

j. On September 13, 2017, Alliance 

Bernstein account ‘6878 transferred about 

$581,000 to Alliance Bernstein account 

‘7892.

k. On September 13, 2017, Alliance 

Bernstein account ‘6878 transferred about 

$250,000 to Alliance Bernstein account 

‘7889.

l. On September 13, 2017, Alliance 

Bernstein account ‘6878 transferred about 

million to the BBT Account in the United 

States. Based on my review of GoCoin's 

financial records and GoCoin's pattern of 

payments to Backpage for bitcoin sales, I 

believe that this $1.25 million represented 

GoCoin's partial payment to Backpage for 

the bitcoin Backpage sold to GoCoin 

during the period of September 4, 2015, 

through November 23, 2015. 

i. On December 31, 2015, the BBT Account 

wired $811,424 to the AZBT Account.

j. On December 6, 2016 the AZBT Account 

wired $161,459 to the WFB Account -

891.

k. On January 4, 2017, the AZBT Account 

wired another $258,841 to the WFB 

Account -891.

l. On January 5, 2017, the WFB Account 

transferred $300,000 to WFB Account -

474.

m. On May 19, 2017 the WFB Account -474 

wired about $1.5 million into Seized 

Account 15A.

n. On May 23, 2017 Seized Account 15A 

transferred about $350,000 to Seized 

Account 15B.

o. On June 7, 2017, Seized Account 15A 

transferred about $1.34 million to Seized 

Account 15C.

p. On September 13, 2017, Seized Account 

15C transferred about $581,000 to Seized 

Account 15D.

q. On September 13, 2017, Seized Account 

15C transferred about $250,000 to Seized 

Account 15E.

r. On September 13, 2017, Seized Account 

15C transferred about $250,000 to Seized 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 17 of 62
17

$250,000 to Alliance Bernstein account 

‘7888.

m. On September 15, 2017, Alliance 

Bernstein account ‘6878 transferred about 

$500,000 to Alliance Bernstein account 

‘6485.

Account 15F.

s. On September 15, 2017, Seized Account 

15C transferred about $500,000 to Seized 

Account 15G.

(Ex. 1 at ¶¶ 62.)

28. K&H Bank account ‘1210 is located in 

Hungary, and held in the name of Primus 

Trust Company (“Binghampton Trust”) 

for the benefit of LACEY. In furtherance 

of their money laundering scheme, and in 

an attempt to further conceal the true 

nature of the money, Backpage Operators 

used this account as a go-between 

funneling money from one account to 

another.

64. I have reviewed records for SUBJECT 

ACCOUNT 17 as well as the following 

accounts: the BBT Account; the AZBT 

Account; Arizona Bank & Trust annuity trust 

account numbers 9361121967,

9361121972, 9361121986, 9361121991, and 

9361122014, all held in Lacey's name 

("AZBT Annuity Accounts"); and Johnson 

Financial account number 1000879992 held 

in an IOLTA with Lacey as the sole 

beneficiary. From this review, I learned the 

following:

(Ex. 1 at ¶ 64.)

29. The tracing of this account involves 

numerous banks and bank accounts both 

foreign and domestic. The accounts 

include: Branch Banking & Trust account 

‘2008, belonging to Website 

Technologies; Arizona Bank & Trust 

account ‘6211 belonging to Cereus 

Properties; Arizona Bank & Trust annuity 

trust account numbers ‘1967, ‘1972, 

‘1986, ‘1991, and ‘2014, all held in 

LACEY’s name (“AZBT Annuity 

Accounts”); and Johnson Financial 

account ‘9992 held in an IOLTA with 

LACEY as the sole beneficiary.

a. Between December 14, 2015, and January 

15, 2016, in approximately 26 wires, a 

GoCoin account in Slovakia transferred 

over $2.5 million to Branch Banking & 

Trust account ‘2008 in the United States. 

b. On January 15, 2016, Branch Banking & 

Trust account ‘2008 wired $189,571 to 

Verizon in Los Angeles, California, in 

payment for Backpage internet services. 

64. I have reviewed records for SUBJECT 

ACCOUNT 17 as well as the following

accounts: the BBT Account; the AZBT 

Account; Arizona Bank & Trust annuity trust 

account numbers 9361121967,

9361121972, 9361121986, 9361121991, and 

9361122014, all held in Lacey's name 

("AZBT Annuity Accounts"); and Johnson 

Financial

account number 1000879992 held in an 

IOLTA with Lacey as the sole beneficiary. 

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.

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 18 of 62
18

c. Between January 21, 2016, and August 

31, 2016, in approximately 27 wires, 

Branch Banking & Trust account ‘2008 

transferred approximately $48 million to 

Arizona Bank & Trust account ‘6211.

d. Between April 1, through October 6, 

2016, in approximately 12 transactions, 

Arizona Bank & Trust account ‘6211 

transferred over $18 million to the AZBT 

Annuity Trust Accounts.

e. On December 29, 2016, LACEY's AZBT 

Annuity Trusts Accounts sent five wires 

totaling $16.5 million to Johnson 

Financial account ‘9992.

f. On January 3, 2017, Johnson Financial 

account ‘9992 wired the $16.5 million to 

K&H Bank account ‘1210 in Hungary.

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 April 1, 2016, through October 

6, 2016, in approximately 12 transactions, 

the AZBT Account transferred over $18 

million to the AZBT Annuity Trust 

Accounts.

e. On December 29, 2016, Lacey's AZBT 

Annuity Trusts Accounts sent five wires 

totaling $16.5 million to the Johnson

Financial Bank Account.

f. On January 3, 2017, the Johnson Financial 

Account wired the $16.5 million to the 

SUBJECT ACCOUNT 17 in Hungary.

(Ex. 1 at ¶ 64.)

30. Fio Bank accounts ‘5803, ‘5801, and 

‘5805 are located in the Czech Republic, 

and held in the name of Ad Tech BV, with 

FERRER as the ultimate beneficial owner. 

According to FERRER, all funds in these 

accounts are the criminally derived 

proceeds of ads promoting prostitution.

66(a). SUBJECT ACCOUNTS 18A, 18B, 

18C are accounts owned by Ad Tech BV and 

controlled by Backpage. According to Ferrer,

all funds in this account are the criminally 

derived proceeds of ads promoting 

prostitution. According to Ferrer, SUBJECT 

ACCOUNTS 18A, 18B, and 18C are 

accounts receivable bank accounts. Payment 

processors and merchant processors would 

take credit card payments, and payments such 

as bitcoin payments from Backpage 

customers for prostitution and other ads, and 

would transfer these funds to accounts such as 

SUBJECT ACCOUNTS 18A, 18B and 18C. 

Per his plea agreement and his cooperation, 

Ferrer has agreed to surrender these funds 

and/or securities to the United States.

(Ex. 1 at ¶ 66.)

31. Fio Bank accounts ‘5803, ‘5801, and 

‘5805 are accounts receivable accounts. 

As such, Payment processors and 

merchant processors would take credit 

card payments, and payments such as 

bitcoin payments from Backpage 

customers for prostitution and other ads, 

and would transfer these funds to accounts 

66(a). SUBJECT ACCOUNTS 18A, 18B, 

18C are accounts owned by Ad Tech BV and 

controlled by Backpage. According to Ferrer, 

all funds in this account are the criminally 

derived proceeds of ads promoting 

prostitution. According to Ferrer, SUBJECT 

ACCOUNTS 18A, 18B, and 18C are 

accounts receivable bank accounts. Payment 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 19 of 62
19

such as Fio Bank accounts ‘5803, ‘5801, 

and ‘5805. 

i. On May 8, 2018, within the Stipulation for 

Preliminary Order of Forfeiture, CR18-465-

PHX-SPL, FERRER as CEO of 

Backpage.com, stipulated that any and all 

bank funds, securities, or other assets on 

deposit or seized from these accounts are 

forfeitable property.

processors and merchant processors would 

take credit card payments, and payments such 

as bitcoin payments from Backpage 

customers for prostitution and other ads, and 

would transfer these funds to accounts such as 

SUBJECT ACCOUNTS 18A, 18B and 18C. 

Per his plea agreement and his cooperation, 

Ferrer has agreed to surrender these funds 

and/or securities to the United States.

(Ex. 1 at ¶ 66.)

Doc. 21 – CR18-465-PHX; Stipulation for 

Preliminary Order of Forfeiture

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

located in the Czech Republic, and held in 

the name of Gold Leaf SRO. All funds 

and securities in these accounts are held 

for Backpage.com by a third party, Gold 

Leaf SRO. According to FERRER and the 

Service Level Agreement ("SLA") 

between Ad Tech BV, a Backpage owned 

company and Gold Leaf SRO, the funds 

and/or securities in these accounts are the 

criminally derived proceeds of Backpage 

ads, including ads promoting prostitution. 

10(n). SUBJECT ACCOUNT 18D: Fio Bank, 

in the Czech Republic, account number 

CZ7020100000002001002226, is an account 

held in the name of Gold Leaf SRO. All funds 

and securities in this account are held for 

Backpage.com by a third party, Gold Leaf 

SRO. 

10(o). SUBJECT ACCOUNT 18E: Fio Bank, 

in the Czech Republic, account number 

CZ7620100000002101002231, is an account 

held in the name of Gold Leaf SRO. All funds 

and securities in this account are held for 

Backpage.com by a third party, Gold Leaf 

SRO. 

10(p). SUBJECT ACCOUNT 18F: Fio Bank, 

in the Czech Republic, account number 

CZ8520100000002501002230, is an account 

held in the name of Gold Leaf SRO. All funds 

and securities in this account are held for 

Backpage.com by a third party, Gold Leaf 

SRO. 

(Ex. 1 at ¶ 10.)

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 20 of 62
20

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

18F are accounts held by a third party, Gold 

Leaf SRO. According to Ferrer and

Service Level Agreements ("SLA") between 

Ad Tech BV, a Backpage owned company 

and Gold Leaf SRO, which I have reviewed, 

the funds and/or securities in these accounts 

are the criminally derived proceeds of 

Backpage ads, including ads promoting 

prostitution. 

(Ex. 1 at ¶ 66.)

33. The SLAs state that 99.5% of the net 

proceeds are to be paid to Ad Tech BV, 

which is owned by Backpage. According 

to FERRER, the arrangement between 

Gold Leaf, SRO, and Backpage was put 

into place to evade what he called a 

"blockade by credit card companies." 

FERRER explained that beginning 

around 2015, U.S. credit card companies 

such as MasterCard and Visa refused to 

process credit card payments for 

Backpage due to the negative press 

surrounding sex trafficking and 

prostitution content on Backpage. 

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

proceeds are to be paid to Ad Tech BV, which 

is owned by Backpage. According to Ferrer, 

the arrangement between Gold Leaf, SRO, 

and Backpage was put into place to evade 

what he called a "blockade by credit card 

companies." Ferrer explained that beginning 

around 2015, U.S. credit card companies such 

as MasterCard and Visa refused to process 

credit card payments for Backpage due to the 

negative press surrounding sex trafficking and 

prostitution content on Backpage.

(Ex 1 at ¶ 66.)

34. As one of the ways around this 

"blockade," Backpage Operators set up 

agreements with foreign persons and 

partners to "franchise" websites for the 

sole purpose of accepting credit card 

payments. 

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

"blockade," Backpage Operators set up 

agreements with foreign persons and partners 

to "franchise" websites for the sole purpose of 

accepting credit card payments.

(Ex 1 at ¶ 66.)

35. According to FERRER, this use of 

foreign third-parties and foreign accounts 

allowed Backpage to continue to accept 

credit card payments for prostitution ads 

while concealing from the credit card 

companies that the payments were for 

Backpage ads. 

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

third parties and foreign accounts allowed 

Backpage to continue to accept credit card 

payments for prostitution ads while

concealing from the credit card companies 

that the payments were for Backpage ads.

(Ex 1 at ¶ 66.)

36. FERRER said that Gold Leaf SRO 

existed for the sole purpose of funneling 

to Backpage accounts otherwise 

prohibited credit card payments for 

Backpage ads. FERRER explained that 

66(b). Ferrer said that Gold Leaf SRO existed 

for the sole purpose of funneling to Backpage 

accounts otherwise prohibited credit card 

payments for Backpage ads. Ferrer explained 

that these accounts are owned by Backpage 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 21 of 62
21

these accounts are owned by Backpage 

and are not co-mingled with other funds, 

and are therefore subject to seizure and 

forfeiture to the United States.

i. On May 8, 2018, within the Stipulation 

for Preliminary Order of Forfeiture, 

CR18-465-PHX-SPL, FERRER as CEO 

of Backpage.com, stipulated that any and 

all bank funds, securities, or other assets 

on deposit or seized from these accounts 

are forfeitable property.

and are not co-mingled with other funds, and 

are therefore subject to seizure and forfeiture 

to the United States. 

(Ex 1 at ¶ 66.)

Document 21 CR18-465-PHX-SPL

37. Fio Bank accounts ‘4194, ‘4196 and 

‘4198 are located in the Czech Republic, 

and held in the name of Protecctio SRO. 

All funds and securities in these accounts 

are held for Backpage.com by a third 

party, Protecctio SRO. According to 

FERRER and the Service Level 

Agreement ("SLA") between Protecctio, 

a Backpage owned company and 

Protecctio SRO, the funds and/or 

securities in these accounts are the 

criminally derived proceeds of Backpage 

ads, including ads promoting prostitution. 

66(c). SUBJECT ACCOUNTS 18G, 18H, 

and 18I are accounts held by a third party, 

Protecttio SRO. According to Ferrer and

an agreement between Protecttio SRO and Ad 

Tech BV, which I have reviewed, the 

arrangements between these entities are

essentially the same as the Gold Leaf SRO 

arrangement. This business arrangement 

existed for the sole purpose of allowing

purchasers of prostitution ads to purchase ads 

on Backpage websites while evading the 

credit card company blockade. Ferrer

explained that these accounts are owned by 

Backpage and are not co-mingled with other 

funds and/or securities, and are therefore 

subject to seizure and forfeiture to the United 

States.

(Ex 1 at ¶ 66.)

38. The SLAs state that 99.5% of the net 

proceeds are to be paid to Ad Tech BV, 

which is owned by Backpage. According 

to FERRER, the arrangement between 

Protecctio SRO, and Backpage was put 

into place to evade what he called a 

"blockade by credit card companies." 

FERRER explained that beginning 

around 2015, U.S. credit card companies 

such as MasterCard and Visa refused to 

process credit card payments for 

Backpage due to the negative press 

surrounding sex trafficking and 

prostitution content on Backpage. 

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

proceeds are to be paid to Ad Tech BV, which 

is owned by Backpage. According

to Ferrer, the arrangement between Gold 

Leaf, SRO, and Backpage was put into place 

to evade what he called a "blockade by credit 

card companies." Ferrer explained that 

beginning around 2015, U.S. credit card 

companies such as MasterCard and Visa 

refused to process credit card payments for 

Backpage due to the negative press 

surrounding sex trafficking and prostitution 

content on Backpage.

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 22 of 62
22

(Ex 1 at ¶ 66.)

39. As one of the ways around this 

"blockade," Backpage Operators set up 

agreements with foreign persons and 

partners to "franchise" websites for the 

sole purpose of accepting credit card 

payments. 

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

"blockade," Backpage Operators set up 

agreements with foreign persons and partners 

to "franchise" websites for the sole purpose of 

accepting credit card payments.

(Ex 1 at ¶ 66.)

40. According to FERRER, this use of 

foreign third-parties and foreign accounts 

allowed Backpage to continue to accept 

credit card payments for prostitution ads 

while concealing from the credit card 

companies that the payments were for 

Backpage ads. 

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

thirdparties and foreign accounts allowed 

Backpage to continue to accept credit card 

payments for prostitution ads while 

concealing from the credit card companies 

that the payments were for Backpage ads.

(Ex 1 at ¶ 66.)

41. FERRER said that Protecctio SRO 

existed for the sole purpose of allowing 

purchasers of prostitution ads to purchase 

ads on Backpage websites while evading 

the credit card company blockade. 

FERRER explained that these accounts 

are owned by Backpage and are not comingled with other funds, and are 

therefore subject to seizure and forfeiture 

to the United States.

i. On May 8, 2018, within the Stipulation 

for Preliminary Order of Forfeiture, 

CR18-465-PHX-SPL, FERRER as 

CEO of Backpage.com, stipulated that 

any and all bank funds, securities, or 

other assets on deposit or seized from 

these accounts is forfeitable property.

66(c). According to Ferrer...Protecttio SRO. 

This business arrangement existed for the sole 

purpose of allowing purchasers of prostitution 

ads to purchase ads on Backpage websites 

will evading the credit card company 

blockade. Ferrer explained that these 

accounts are owned by Backpage and are not 

co-mingled with other funds, and are 

therefore subject to seizure and forfeiture to 

the United States.

(Ex 1 at ¶ 66.)

Doc. 21, Preliminary Order of Forfeiture, 

CR18-465-PHX-SPL

42. Fio Bank accounts ‘8083, ‘8086, and 

‘8080 are located in the Czech Republic, 

and held in the name of Varicok 

Company SRO. All funds and securities 

in these accounts are held for 

Backpage.com by a third party, Varicok 

Company SRO. 

10(t). SUBJECT ACCOUNT 18J: Fio Bank, 

in the Czech Republic, account number 

CZ4820100000002801118083, is an account

held in the name of Varicok Company SRO. 

All funds and securities in this account are 

held for Backpage.com by a third party, 

Varicok Company SRO.

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 23 of 62
23

According to FERRER and the Service Level 

Agreement ("SLA") between Varicok 

Company SRO, a Backpage owned company 

and Varicok Company SRO, the funds and/or 

securities in these accounts are the criminally 

derived proceeds of Backpage ads, including 

ads promoting prostitution. 

u. SUBJECT ACCOUNT 18K: Fio Bank, in 

the Czech Republic, account number 

CZ2020100000002701118086, is an account

held in the name of Varicok Company SRO. 

All funds and securities in this account are 

held for Backpage.com by a third party, 

Varicok Company SRO.

v. SUBJECT ACCOUNT 18L: Fio Bank, in 

the Czech Republic, account number 

CZ7620100000002901118080, is an account

held in the name of Varicok Company SRO. 

All funds and securities in this account are 

held for Backpage.com by a third party, 

Varicok Company SRO.

(Ex. 1 at 10(t)-(v).)

66(d). According to Ferrer, and an agreement 

between Varicok SRO and Ad Tech 

BV...[t]his business arrangement existed for 

the sole purpose of allowing purchasers of 

prostitution ads to purchase ads on Backpage 

websites while evading the credit card 

company blockage.

(Ex. 1 at ¶ 66.)

43. The SLAs state that 99.5% of the net 

proceeds are to be paid to Ad Tech BV, which 

is owned by Backpage. 

According to FERRER, the arrangement 

between Varicok Company SRO, and 

Backpage was put into place to evade what he 

called a "blockade by credit card companies." 

FERRER explained that beginning around 

2015, U.S. credit card companies such as 

MasterCard and Visa refused to process credit 

card payments for Backpage due to the 

negative press surrounding sex trafficking and 

prostitution content on Backpage. 

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

proceeds are to be paid to Ad Tech BV, which 

is owned by Backpage.

66(d). According to Ferrer, and an agreement 

between Varicok SRO and Ad Tech 

BV...[t]his business arrangement existed for 

the sole purpose of allowing purchasers of 

prostitution ads to purchase ads on Backpage 

websites while evading the credit card 

company blockage. 

66(b). Ferrer explained that beginning around 

2015, U.S. credit card companies such as 

MasterCard and Visa refused to process credit 

card payments for Backpage due to the 

negative press surrounding sex trafficking and 

prostitution content on Backpage. 

(Ex. 1 at ¶ 66.)

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 24 of 62
24

44. As one of the ways around this 

"blockade," Backpage Operators set up 

agreements with foreign persons and partners 

to "franchise" websites for the sole purpose 

of accepting credit card payments. 

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

"blockade," Backpage Operators set up 

agreements with foreign persons and partners 

to "franchise" websites for the sole purpose of 

accepting credit card payments. 

(Ex. 1 at ¶ 66.)

45. According to FERRER, this use of 

foreign third-parties and foreign accounts 

allowed Backpage to continue to accept 

credit card payments for prostitution ads 

while concealing from the credit card 

companies that the payments were for 

Backpage ads. 

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

third-parties and foreign accounts allowed 

Backpage to continue to accept credit card 

payments for prostitution ads while 

concealing from the credit card companies 

that the payments were for Backpage ads. 

(Ex. 1 at ¶ 66.)

46. FERRER said that Varicok Company 

SRO existed for the sole purpose of allowing 

purchasers of prostitution ads to purchase ads 

on Backpage websites while evading the 

credit card company blockade. 

FERRER explained that these accounts are 

owned by Backpage and are not co-mingled 

with other funds, and are therefore subject to 

seizure and forfeiture to the United States.

On May 8, 2018, within the Stipulation for 

Preliminary Order of Forfeiture, CR18-465-

PHX-SPL, FERRER as CEO of 

Backpage.com, stipulated that any and all 

bank funds, securities, or other assets on 

deposit or seized from these accounts is 

forfeitable property.

66(d). According to Ferrer, and an agreement 

between Varicok SRO and Ad Tech 

BV...[t]his business arrangement existed for 

the sole purpose of allowing purchasers of 

prostitution ads to purchase ads on Backpage 

websites while evading the credit card 

company blockage. 

66(d). Ferrer explained that these accounts are 

owned by Backpage and are not co-mingled 

with other funds, and are therefore subject to 

seizure and forfeiture to the United States.

(Ex. 1 at ¶ 66.)

Doc. 21, Preliminary Order of Forfeiture, 

CR18-465-PHX-SPL

47. Bank Frick accounts ‘K000 K, ‘K000 

U, ‘K000 E, and ‘K001 E are located in 

Principality of Liechtenstein, and held in the 

name of Ad Tech BV, and FERRER is the 

ultimate beneficial owner. 

10(w). SUBJECT ACCOUNT 19A: Bank 

Frick, located in Liechtenstein, account 

number LI09 0881 1060 7717 K000 K, is an

account held in the name of Ad Tech BV, and 

Ferrer is the ultimate beneficial owner.

x. SUBJECT ACCOUNT 19B: Bank Frick, in

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 25 of 62
25

According to FERRER these are accounts 

receivable banking accounts. 

Liechtenstein, account number LI30 0881 

1060 7717 K000 U, is an account held in the 

name of Ad Tech BV, and Ferrer is the

ultimate beneficial owner.

y. SUBJECT ACCOUNT 19C: Bank Frick, in

Liechtenstein, account number LI74 0881 

1060 7717 K000 E, is an account held in the 

name of Ad Tech BV, and Ferrer is the

ultimate beneficial owner.

z. SUBJECT ACCOUNT 19D: Bank Frick, in

Liechtenstein, account number LI90 0881 

1060 7717 K00l E, is an account held in the 

name of Ad Tech BV, and Ferrer is the

ultimate beneficial owner.

(Ex. 1 at ¶ 10(w)-(z).)

67(a). According to Ferrer, SUBJECT 

ACCOUNTS 19A, 19B, 19C and 19D are 

accounts receivable banking accounts. 

(Ex. 1 at ¶ 67.)

48. Payment processors and merchant 

processors would take credit card payments, 

and payments such as bitcoin payments from 

Backpage customers for prostitution and other 

ads, and would transfer these funds to Bank 

Frick accounts ‘K000 K, ‘K000 U, ‘K000 E, 

and ‘K001 E. 

67(a) Payment processors and merchant 

processors would take credit card payments, 

and payments such as bitcoin payments from 

Backpage customers for prostitution and other 

ads, and would transfer these funds to 

accounts such as SUBJECT ACCOUNTS 

19A, 19B, 19C and 19D.

(Ex. 1 at 67.)

49. These accounts contain funds and/or 

securities that are criminally derived and are 

subject to forfeiture. FERRER and Backpage 

has agreed to surrender these funds and/or 

securities as they are criminally derived. 

67(a). These accounts contain funds and/or 

securities that are criminally derived and are 

subject to forfeiture. Ferrer and Backpage has 

agreed to surrender these funds and/or 

securities as they are criminally derived. 

(Ex. 1 at 67.)

50. Knab Bank account ‘2452 is located in 

Kingdom of the Netherlands, and held in the 

name of Procop Services BV. All funds and 

securities in this account are held for 

Backpage.com by Procop Services BV. 

According to FERRER and the Service Level 

68(b). SUBJECT ACCOUNT 20 at Knab 

Bank in the Netherlands is an account held by 

a third party, Procop Services BV. According 

to Ferrer the arrangement is essentially the 

same as the Gold Leaf SRO and Protecttio 

SRO, as described with respect to SUBJECT 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 26 of 62
26

Agreement ("SLA") between Procop 

Services BV, a Backpage owned company 

and Procop Services BV, the funds and/or 

securities in these accounts are the criminally 

derived proceeds of Backpage ads, including 

ads promoting prostitution. 

ACCOUNTS 19. This business arrangement 

existed for the sole purpose of allowing 

purchasers of prostitution ads to purchase ads 

on Backpage websites while evading the 

credit card company blockade. Ferrer 

explained that these accounts are owned by 

Backpage and are not co-mingled with

other funds and/or securities, and are 

therefore subject to seizure and forfeiture to 

the United States.

(Ex. 3 at ¶ 68(b).)

51. The SLAs state that 99.5% of the net 

proceeds are to be paid to Ad Tech BV, which 

is owned by Backpage. According to 

FERRER, the arrangement between Procop 

Services BV, and Backpage was put into 

place to evade what he called a "blockade by 

credit card companies." FERRER explained 

that beginning around 2015, U.S. credit card 

companies such as MasterCard and Visa 

refused to process credit card payments for 

Backpage due to the negative press 

surrounding sex trafficking and prostitution 

content on Backpage. 

75. All four SLAs state that 99.5% of the net 

proceeds are to be paid to Ad Tech BV, which 

is owned by Backpage . According to Ferrer, 

the arrangements between these Entities , and 

Backpage were put into place to avoid what 

Ferrer described as , "a blockade [of 

Backpage] by credit card companies ." Ferrer 

explained that beginning around 2015 , U. S. 

credit card companies such as MasterCard 

and Visa refused to process credit card 

payments for Backpage due to the negative 

press surrounding sex trafficking and 

prostitution

content on Backpage.

(Ex. 3 at ¶ 75.)

52. As one of the ways around this 

"blockade," Backpage Operators set up 

agreements with foreign persons and partners 

to "franchise" websites for the sole purpose of 

accepting credit card payments. 

75. As a way around this "blockade," 

Backpage Operators set up agreements with 

foreign persons and partners to "franchise" 

websites for the sole purpose of accepting 

credit card payments.

(Ex. 3 at ¶ 75.)

53. According to FERRER, this use of 

foreign third-parties and foreign accounts 

allowed Backpage to continue to accept credit 

card payments for prostitution ads while 

concealing from the credit card companies 

that the payments were for Backpage ads. 

75. According to Ferrer, this use of foreign 

third-parties and foreign accounts allowed 

Backpage to continue to accept credit card 

payments for prostitution ads while 

concealing from the credit card companies 

that the payments were for Backpage ads . 

Ferrer said that the Entities existed for the

sole purpose of funneling to Backpage 

accounts otherwise prohibited credit card 

payments for Backpage ads. Ferrer

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 27 of 62
27

explained that these funds are owned by 

Backpage and are not comingled with other 

funds.

(Ex. 3 at ¶ 75.)

54. FERRER said that Procop Services 

BV existed for the sole purpose of allowing 

purchasers of prostitution ads to purchase ads 

on Backpage websites while evading the 

credit card company blockade. FERRER 

explained that these accounts are owned by 

Backpage and are not co-mingled with other 

funds, and are therefore subject to seizure and 

forfeiture to the United States.

75. According to Ferrer and the four separate 

SLAs between (1) Ad Tech BV, a Backpage 

owned company, and Guilietta Group B. V.; 

(2) Backpage and Procop Services B. V.; (3) 

Backpage and Universe Ads B. V.; and (4) 

Backpage and Proteccio SRO, all of which I 

have reviewed , the funds and/or securities 

held by these entities are the criminally 

derived proceeds of Backpage ads, including 

ads promoting prostitution. All four SLAs 

state that 99.5% of the net proceeds are to be 

paid to Ad Tech BV, which is owned by 

Backpage. According to Ferrer, the 

arrangements between these Entities, and 

Backpage were put into place to avoid what 

Ferrer described as, "a blockade [of 

Backpage] by credit card companies ." Ferrer 

explained that beginning around 2015, U. S. 

credit card companies such as MasterCard 

and Visa refused to process credit card 

payments for Backpage due to the negative 

press surrounding sex trafficking and 

prostitution content on Backpage. As a way 

around this "blockade," Backpage Operators 

set up agreements with foreign persons and 

partners to "franchise" websites for the sole 

purpose of accepting credit card payments. 

According to Ferrer, this use of foreign thirdparties and foreign accounts allowed 

Backpage to continue to accept credit card 

payments for prostitution ads while 

concealing from the credit card companies 

that the payments were for Backpage ads. 

Ferrer said that the Entities existed for the 

sole purpose of funneling to Backpage 

accounts otherwise prohibited credit card 

payments for Backpage ads. Ferrer explained 

that these funds are owned by Backpage and 

are not comingled with other funds.

(Ex. 3 at ¶ 75.)

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 28 of 62
28

55. According to FERRER and business 

agreements, Rabo Bank Account ‘2452 is an 

account in the Netherlands held in the name 

of Gulietta Group BV. The funds and/or 

securities in this account are derived from 

selling advertisements online, most of which 

are for prostitution advertisements. The SLAs 

state that 99.5% of the net proceeds are to be 

paid to Ad Tech BV which is owned by 

Backpage.

69(a). SUBJECT ACCOUNT 21A is an 

account in the Netherlands held in the name 

of Gulietta Group BV. According to Ferrer 

and the SLA, the funds and/or securities in 

this account are derived from selling 

advertisements online, most of which

are for prostitution advertisements. The SLAs 

state that 99.5% of the net proceeds are to be 

paid to Ad Tech BV which is owned by 

Backpage.

(Ex. 1 at ¶ 69(a).)

56. According to FERRER, the 

arrangement between Guilietta Group BV, 

and Backpage was put into place to evade 

what he called a "blockade by credit card 

companies." FERRER explained that 

beginning around 2015, U.S. credit card 

companies such as MasterCard and Visa 

refused to process credit card payments for 

Backpage due to the negative press 

surrounding sex trafficking and prostitution 

content on Backpage.

69(a). According to Ferrer, the arrangement 

between Guilietta Group BV and Ad Tech BV 

(Backpage) was put into place to evade the 

same credit card "blockade" described in with 

regard to SUBJECT ACCOUNTS 18D, 18E, 

and 18F. Ferrer explained that these accounts 

are owned by Backpage and are not comingled with other funds and/or securities, 

and are therefore subject to seizure and 

forfeiture to the United States.

(Ex. 1 at ¶ 69(a).)

57. As one of the ways around this 

"blockade," Backpage Operators set up 

agreements with foreign persons and partners 

to "franchise" websites for the sole purpose of 

accepting credit card payments.

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

"blockade," Backpage Operators set up 

agreements with foreign persons and partners 

to "franchise" websites for the sole purpose of 

accepting credit card payments.

(Ex. 1 at ¶ 66(b).)

58. This use of foreign third-parties and 

foreign accounts allowed Backpage to 

continue to accept credit card payments for 

prostitution ads while concealing from the 

credit card companies that the payments were 

for Backpage ads.

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

third-parties and foreign accounts allowed 

Backpage to continue to accept credit card 

payments for prostitution ads while 

concealing from the credit card companies 

that the payments were for Backpage ads.

(Ex. 1 at ¶ 66(b).)

59. Rabo Bank account ‘4721 is an 

account in the Netherlands held in the name 

of UnivsersAds BV. According to Ferrer and 

the SLA between the companies, the funds 

and/or securities in this account are derived 

from selling advertisements online, most of 

which are for prostitution 

10(cc). SUBJECT ACCOUNT 21B: Rabo 

Bank, in the Netherlands, account number 

NL64RABO0307604721, is an account

held in the name of UniversAds BV. All 

funds and securities in this account are held 

for Backpage.com by UniversAds BV.

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 29 of 62
29

advertisements. The Service Level 

Agreements state that 99.5% of the net 

proceeds are to be paid to Ad Tech BV which 

is owned by Backpage.

(Ex. 1 at ¶ 10(cc).)

69(b). According to Ferrer, the arrangement 

between UniversAds BV and Ad Tech BV or 

Backpage was put into place to evade the 

same credit card blockade described above. 

Ferrer explained that these accounts are 

owned by Backpage and are not co-mingled 

with other funds and/or securities, and are 

therefore subject to seizure and forfeiture to 

the United States.

(Ex. 1 at ¶ 69(b).)

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

proceeds are to be paid to Ad Tech BV, which 

is owned by Backpage.

(Ex. 1 at ¶ 66(b).)

60. According to Ferrer, the arrangement 

between UniversAds BV and Ad Tech BV or 

Backpage was put into place to evade the 

same credit card blockade described 

above. Ferrer explained that these accounts 

are owned by Backpage and are not comingled with other funds and/or securities, 

and are therefore subject to seizure and 

forfeiture to the United States.

69(b). According to Ferrer, the arrangement 

between UniversAds BV and Ad Tech BV or 

Backpage was put into place to evade the 

same credit card blockade described above. 

Ferrer explained that these accounts are 

owned by Backpage and are not co-mingled 

with other funds and/or securities, and are 

therefore subject to seizure and forfeiture to 

the United States.

(Ex. 1 at ¶ 69(b).)

61. Acacia Conservation Fund LP account 

‘0112 are investment funds held in the name 

of Ocotillo Family Trust. Ocotillo Family 

Trust is owned by JAMES and Margaret 

LARKIN. In furtherance of their money 

laundering scheme, and in an attempt to 

further conceal the true nature of the money, 

Backpage Operators used these accounts as 

go-betweens to funnel money from one 

account to another.

a. The tracing involved numerous 

accounts including: Branch Banking & Trust 

account number ‘2008, held in the name of 

Website Technologies; Arizona Bank & Trust 

account number ‘6211 held in the name of 

23. Approximately $9,882,828.72 in 

securities and/or investment funds seized 

from Perkins Coie Trust Company Account 

No. ‘0012 (“PCTC Investment Funds” or 

“Account 20”) held in the name of Margaret 

G. Larkin. Larkin, M. Larkin, CFT and OFT 

have filed claims in member case number CV 

18-8420 RGK (PJWx).

24. Approximately $34,149,280.00 in 

securities and/or investment funds seized 

from Acacia Conservation Fund LP Account 

No. ‘2020 (“ACF Funds” or “Account 21”), 

held in the name of the Ocotillo Family Trust. 

Larkin, M. Larkin, CFT and OFT have filed 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 30 of 62
30

Cereus Properties; Charles Schwab account 

number ‘4693 held in the name of JAMES 

LARKIN; and Pershing, LLC Account 

number ‘1121 held in the name of Acacia 

Conservation Fund; and GoCoin transactions 

related to certain ads posted on Backpage, 

specifically including ads that related to child 

victims A.C., S.F., T.S., S.L., K.O., and R.W.

b. On September 6, 2015, a bitcoin 

account associated with the owner of the 

email address who trafficked A.C. and S.F. 

paid Backpage about $4 worth of bitcoin in 

order to post an ad promoting the trafficking 

of those victims in Palm Springs, California.

c. On September 15, 2015, an email 

from the same email address owner indicated 

a payment to Backpage of about $8 worth of 

bitcoin in order to "Fund Account" for 

palmsprings.backpage.com. 

d. On October 6, 2015, the same email 

address owner paid Backpage about $1 worth 

of bitcoin to "Fund Account" on 

palmsprings.backpage.com. 

e. On October 30, 2015, a bitcoin 

account associated with the owner of the 

email address who trafficked T.S., S.L., K.O., 

and R.W. paid Backpage about $1 worth of 

bitcoin in order to post an ad promoting the 

trafficking of those victims in Columbus, 

Ohio.

f. On November 2, 2015, this same 

email address owner paid Backpage about $1 

worth of bitcoin to "Move Ad to Top of 

Listings" in the Columbus, Ohio Backpage 

ads.

g. On November 21, 2015, this same 

email address owner paid Backpage about $1 

worth of bitcoin to Backpage for credit for 

that email owner's Backpage ad account. 

claims in member case number CV 18-8420 

RGK (PJWx).

(Ex. 2 at ¶¶23-24.)

63(a). On September 6, 2015, a Bitcoin 

account associated with the owner of the 

email address who trafficked A.C. and S.F. 

paid Backpage about $4 worth of bitcoin in 

order to post an ad promoting the trafficking 

of those victims in Palm Springs, California. 

63(b). On September 15, 2015, an email from 

the same email address owner indicated a 

payment to Backpage of about $8 worth of 

Bitcoin in order to "Fund Account" for 

palmsprings.backpage.com. 

63(c). On October 6, 2015, the same email 

address owner paid Backpage about $1 worth 

of Bitcoin to "Fund Account" on 

palmsprings.backpage.com. 

63(d). On October 30, 2015, a bitcoin account 

associated with the owner of the email 

address who trafficked T.S., S.L., K.O., and 

R.W. paid Backpage about $1 worth of 

Bitcoin in order to post an ad promoting the 

trafficking of those victims in Columbus, 

Ohio.

63(e). On November 2, 2015, this same email 

address owner paid Backpage about $1 worth 

of bitcoin to "Move Ad to Top of Listings" in 

the Columbus, Ohio Backpage ads.

(Ex 3 at ¶ 63(a)-(g).)

63(f). On November 21, 2015, this same 

email address owner paid Backpage about $1 

worth of bitcoin to Backpage for credit for 

that email owner's Backpage ad account. 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 31 of 62
31

h. During the period of September 4, 

2015, and November 23, 2015, Backpage 

advertisers used bitcoin to purchase about 

1,000,000 "adult" ads from Backpage. 

Backpage then sold that bitcoin to GoCoin for 

approximately $8.6 million. Included among 

the bitcoin sold to GoCoin during this period 

were the six payments the pimps made to 

Backpage to purchase ads to promote child 

prostitution.

i. During the period of March 23, 2016, 

through March 31, 2016, in three transactions, 

Branch Banking and Trust Bank account 

‘2008 wired $3,694,813.60 to the Arizona 

Bank and Trust Account ‘6211.

j. During the period of April 1, 2016, 

through July 1, 2016, in five transactions, the 

Arizona Bank and Trust Account ‘6211 wired 

$5,750,294 to LARKIN’s Charles Schwab 

account ‘4693. 

k. On July 1, 2016, the Charles Schwab 

account ‘4693 wired $15 million to the 

Acacia Conservation Fund, LP account ‘0112.

l. During the period of August 2, 2016, 

through October 6, 2016, in six transactions, 

the Arizona Bank and Trust Account ‘6211 

wired $9,550,315 to LARKIN’s Charles 

Schwab account ‘4693. 

m. On January 3, 2017, the Charles

Schwab account ‘4693 wired $2.5 million to 

the Acacia Conservation Fund, LP account 

‘0112.

n. On January 4, 2017, the Charles 

Schwab account ‘4693 wired $2.5 million to 

the Acacia Conservation Fund, LP account 

‘0112.

63(g). During the period of September 4, 

2015, and November 23, 2015, Backpage 

advertisers used bitcoin to purchase about 

1,000,000 "adult" ads from Backpage. 

Backpage then sold that bitcoin to GoCoin for 

approximately $8.6 million. Included among 

the bitcoin sold to GoCoin during this period 

were the six payments the pimps made to 

Backpage to purchase ads to promote child 

prostitution. 

(Ex 3 at ¶ 63(f)-(g).)

181(a). During the period of March 23 

through March 31, 2016, Website Tech 

Account ‘2008 sent three wire transfers 

totaling $3,694,813.60 to Arizona Bank and 

Trust account number ‘6211, belonging to 

Cereus Properties (“Account ‘6211”). 

181(b). During the period of April 1, 2016, 

through July 1, 2016, Account ‘6211 sent five 

wire transfers totaling $5,750,294 to Charles 

Schwab account ‘4693. 

181(c). On July 1, 2016, Charles Schwab 

Account ‘4693 transferred $15,000,000 to 

Account 21. 

181(d). During the period of August 2, 2016, 

through October 6, 2016, Account ‘6211 sent 

six wire transfers totaling $9,550,315 to 

Charles Schwab Account ‘4693. 

181(e). On January 3, 2017, Charles Schwab 

account ‘4693 transferred $2,500,000 to 

Account 21. 

181(f). On January 4, 2017, Charles Schwab 

account ‘4693 transferred $2,500,000 to 

Account 21.

(Ex 2 at ¶¶ 181(a)-(f).)

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 32 of 62
32

72. I have reviewed records for Seized 

Account 22 as well as the following accounts: 

Branch Banking & Trust account number [-

2008], belonging to Website Technologies; 

.... Arizona Bank & Trust account number [-

6211] belonging to Cereus Properties; ... 

Charles Schwab account number [-4693] 

belonging to James Larkin...; and Pershing, 

LLC Account number [-1121] belonging to 

Acacia Conservation Fund... Additionally, I 

have reviewed GoCoin transactions related to 

certain ads posted on Backpage, specifically 

including ads that related to child victims 

A.C., S.F., T.S., S.L., K.O., and R.W. 

(Ex 3 at ¶ 72.) 

62. Saxo Payments account number 

00011262 is a United Kingdom-based 

account held in the name of Cashflows 

Europe Limited (“Cashflows”). Cashflows is 

holding these funds for the benefit of Gulietta 

Group B.V., Universads B.V, Procop Services 

B.V., and Proteccio SRO, each of which 

company is a Backpage owned or controlled 

entity. United Kingdom law enforcement 

officials have restrained the funds held by 

these four companies and consolidated them 

into this Saxo Payments account. 

74. From my review of these SLAs , financial 

records related to Restrained Account 23, and 

records and statements provided by Ferrer and 

U. K. Law Enforcement, I understand that 

Restrained Account 23 contains funds 

consolidated by U.K. Law Enforcement and a 

payment processing company called 

Cashflows Europe Limited. This account 

contains funds from three separate entities 

that U.K. Law Enforcement restrained 

following the indictments and information 

charging Backpage and its operators .

That is, Restrained Account 23 contains funds 

from (1) Gulieta Group B. V.; (2) Procop 

Services B. V.; {3) Universads B.V.; and ( 4) 

Proteccio SRO , (collectively referred to as , 

the "Entities") . 

(Ex. 3 at ¶ 74.)

63. On April 5, 2018, pursuant to a plea 

agreement in the District of Arizona, 

FERRER plead guilty to a single-count 

information charging him with a violation of 

18 U.S.C. § 371, conspiracy to violate 18 

U.S.C. §§ 1952 (the Travel Act) and 1956 

(money laundering). As part of his plea 

agreement, FERRER agreed to "take all steps 

within his power to forfeit to the United 

States all corporate assets and other property 

Plea agreement in United States v. Ferrer,

CR-18-464-PHX-DJH. DOJ-BP0004899878. Defense Trial Exhibit 5994-2; 

see also, CR-18-465-PHX-DJH, United States 

v. Backpage.com, LLC; Website 

Technologies, LLC; Posting Solutions LLC; 

AdTech BV; and UCG Tech Group BV (“the 

Entities”) (Doc. 8-2 through 8-7.) 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 33 of 62
33

owned or controlled by Website 

Technologies, LLC, which own and operates 

the Backpage website, as well as corporate 

assets and other property owned or controlled 

by Backpage.com, LLC, Posting Solutions 

LLC, Amstel River Holdings, LLC, Ad Tech 

BV, and UGC Tech Group CV." 

That same day, also in the District of Arizona, 

Backpage.com, LLC and related entities plead 

guilty to 18 U.S.C. § 1956(h) (money 

laundering conspiracy). 

64. Saxo Payments account ‘1262 

contains funds from (1) Gulieta Group B.V.; 

(2) Procop Services B.V.; (3) Universads 

B.V.; and (4) Protecctio SRO, (collectively 

referred to as, the "Entities"):

61. Approximately 747,664.15 GBP seized 

from SAXO Payments

(United Kingdom) Account No. ‘1262 (“SP 

‘1262 Funds” or “Account

55”), held in the name of the Cashflows 

Europe Limited (“Cashflows”).

Medalist, Leeward, Camarillo, Vermillion, 

Cereus, Shearwater, Broadway, Larkin, T. 

Larkin, R. Larkin, Spear, Lacey, and Brunst 

have filed claims in member case number CV 

18-8753 RGK (PJWx).

Account 55 is located in the United Kingdom 

and held by a third party entity, “Cashflows 

Europe Limited” (“Cashflows”). Although 

Backpage is the ultimate beneficiary of 

Account 55, Cashflows acts first as an entity 

holding this account for the benefit of Gulietta 

Group B.V., Universads B.V., Procop 

Services B.V., and Proteccio SRO, each of 

which company is owned or controlled

by Backpage. 

(Ex. 2 at ¶¶ 61, 216.)

65. According to FERRER and the four 

separate SLAs between (1) Ad Tech BV, a 

Backpage owned company, and Guilietta 

Group B.V.; (2) Backpage and Procop 

Services B.V.; (3) Backpage and Universe 

Ads B.V.; and (4) Backpage and Protecctio 

SRO, the funds and/or securities held by these 

entities are the criminally derived proceeds of 

Backpage ads, including ads promoting 

prostitution. All four SLAs state that 99.5% 

75. According to Ferrer and the four separate 

SLAs between (1) Ad Tech BV, a Backpage 

owned company, and Guilietta Group B.V.; 

(2) Backpage and Procop Services B.V.; (3) 

Backpage and Universe Ads B.V.; and (4) 

Backpage and Protecctio SRO, all of which I 

have reviewed, the funds and/or securities 

held by these entities are the criminally 

derived proceeds of Backpage ads, including 

ads promoting prostitution. All four SLAs 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 34 of 62
34

of the net proceeds are to be paid to Ad Tech 

BV, which is owned by Backpage. According 

to FERRER, the arrangements between these 

Entities, and Backpage were put into place to 

avoid what FERRER described as, "a 

blockade [of Backpage] by credit card 

companies." FERRER explained that 

beginning around 2015, U.S. credit card 

companies such as MasterCard and Visa 

refused to process credit card payments for 

Backpage due to the negative press 

surrounding sex trafficking and prostitution 

content on Backpage. As a way around this 

"blockade," Backpage Operators set up 

agreements with foreign persons and partners 

to "franchise" websites for the sole purpose of 

accepting credit card payments. According to 

FERRER, this use of foreign third-parties and 

foreign accounts allowed Backpage to 

continue to accept credit card payments for 

prostitution ads while concealing from the 

credit card companies that the payments were 

for Backpage ads. FERRER said that the 

Entities existed for the sole purpose of 

funneling to Backpage accounts otherwise 

prohibited credit card payments for Backpage 

ads. FERRER explained that these funds are 

owned by Backpage and are not co-mingled 

with other funds, and the funds held in Saxo 

Payments account ‘1262 are therefore subject 

to seizure and forfeiture to the United States.

state that 99.5% of the net proceeds are to be 

paid to Ad Tech BV, which is owned by 

Backpage. According to Ferrer, the 

arrangements between these Entities, and 

Backpage were put into place to avoid what 

Ferrer described as, "a blockade [of 

Backpage] by credit card companies." Ferrer 

explained that beginning around 2015, U.S. 

credit card companies such as MasterCard 

and Visa refused to process credit card 

payments for Backpage due to the negative 

press surrounding sex trafficking and 

prostitution content on Backpage. As a way 

around this "blockade," Backpage Operators 

set up agreements with foreign persons and 

partners to "franchise" websites for the sole 

purpose of accepting credit card payments. 

According to Ferrer, this use of foreign thirdparties and foreign accounts allowed 

Backpage to continue to accept credit card 

payments for prostitution ads while 

concealing from the credit card companies 

that the payments were for Backpage ads. 

Ferrer said that the Entities existed for the 

sole purpose of funneling to Backpage 

accounts otherwise prohibited credit card 

payments for Backpage ads. Ferrer explained 

that these funds are owned by Backpage and 

are not co-mingled with other funds. 

(Ex. 3 at ¶ 75.)

66. Restrained Account 24 is an account 

maintained in the Republic of Estonia, held in 

the name of Olist OU. The funds and/or 

securities in this account are derived from 

selling advertisements online, most of which 

ads are for prostitution advertisements. The 

SLAs state that 99.5% of the net proceeds are 

to be paid to Ad Tech BV, which is owned by 

Backpage. The arrangement between Olist 

OU and Ad Tech BV (Backpage) was put into 

place to avoid the same credit card 

“blockade” described in relation to Saxo 

Payments account ‘1262. These accounts are 

owned by Backpage and are not co-mingled 

with other funds and/or securities.

76. I learned that Restrained Account 24 is an 

account maintained in the Republic of 

Estonia, held in the name of Olist OU. 

According to Ferrer and the SLAs, the funds 

and/or securities in this account are derived 

from selling advertisements online, most of 

which ads are for prostitution advertisements. 

The SLAs state that 99.5% of the net proceeds 

are to be paid to Ad Tech BV, which is owned 

by Backpage. According to Ferrer, the 

arrangement between Olist OU and Ad Tech 

BV (Backpage) was put into place to avoid 

the same credit card "blockade" described in 

relation to Restrained Accounts 23. Ferrer

explained that these accounts are owned by

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 35 of 62
35

Backpage and are not co-mingled with other 

funds and/or securities. 

(Ex. 3 at ¶ 76.)

67. The Compass Bank account was 

opened in the name of Cereus Properties:

a. On December 2, 2016, the Foreign 

Account in the Liechtenstein wired 

$324,055.85 to Compass Bank account ‘3873.

b. On December 8, 2016, the Foreign 

Account wired $499,970.00 to Compass Bank 

account ‘3873.

c. On December 27, 2016, the Foreign 

Account wired $199,970.00 to Compass Bank 

account ‘3873.

d. On September 19, 2017, Compass 

Bank account ‘3873 wired $83,063 to Wells 

Fargo Bank account ‘9863.

e. Between September 20, 2017, and 

December 8, 2017, in a total of seven wire 

transfers, Wells Fargo Bank account -9863 

sent a combined total of $944,729.25 to 

Compass Bank account ‘4862.

f. On December 13, 2017, Compass 

Bank account ‘4862 wired $406,211.10 to 

Republic Bank of Arizona account 1938.

152. Account 2 is Compass ‘3873 Funds and 

is a Cereus Properties Asset. 

153(a). On December 2, 2016, the 

Netherlands Account transferred $324,055.85 

to Account 2

153(b). On December 8, 2016, the 

Netherlands Account transferred $499,970.00 

to Account 2. 

153(c). On December 27, 2016, the 

Netherlands Account transferred $199,970.00 

to Account 2. 

(Ex. 2 at ¶¶ 152, 153.) 

77(d). On September 19, 2017, Seized 

Account 2A wired $83,063 to Wells Fargo 

Bank account -9863. 

42. Seized Account 2A is a Compass Bank 

business account owned by “Cereus 

Properties LLC.” 

(Ex. 3. at ¶¶ 77, 42.)

156(b). Between September 20, 2017 and 

December 8, 2017, Account ‘9863 transferred 

approximately $944,729.25 among seven 

transactions into Account 3. 

(Ex. 2 at ¶ 156(b).)

178(e). On December 13, 2017, Account 3 

transferred $406, 211.10 to Account 15. 

(Ex. 2 at ¶ 178(e).)

68. The Midfirst Bank account was held in the 

name of John Becker’s IOLTA for 

MICHAEL LACEY.

158. Account 12 was an IOLTA held for the 

benefit of Lacey, and was funded with 

proceeds traceable to SUA, involved in 

money laundering, or both.

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 36 of 62
36

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 (totaling $1,317,800 wired 

from GoCoin’s Singapore account into 

Account -1462).

b. On or about February 23, 2017, Account -

1462 sent two payments, a wire of $443,014 

and a check for $27,887.41 to Compass Bank 

account ‘3873.

c. Between March 30, 2017, and September 

14, 2017, Compass Bank account ‘3873 sent 

five wires totaling $4,058.063.65 to Midfirst 

Bank account ‘4139.

d. In July 2018, Midfirst Bank account ‘4139 

was closed and a cashier’s check totaling 

$2,412,785.47 was issued to Michael Lacey’s 

Annuity Fund held by his attorney. As of the 

date of this affidavit, this check has not been 

negotiated.

159. On January 4, 2017, the Singapore 

Account wired $489,500 into a Posting 

Solutions controlled account held at Veritex 

Bank (the “Veritex Account”). On January 

20, 2017, the Singapore Account directed two 

additional wires, for $358,150 and $470,150

respectively, into the Veritex Account. In 

total, the Singapore Account transferred 

$1,317,800 into the Veritex Account.

a. On or about February 23, 2017, the Veritex 

Account directed two payments to Account 2, 

a wire of $443,014, and a check for 

$27,887.41;

b. Between March 30 and September 14, 

2017, Account 2 sent five wires totaling 

$4,058.063.65 to Account 12; and

c. In July 2018, Account 12 was closed and a 

cashier’s check totaling $2,412,785.47 was 

issued to Lacey’s Annuity Fund, held at

Account 12.

(Ex. 2 at ¶¶ 158-159.)

69. Backpage, until recently, controlled 

numerous domain names that have since been 

seized by the government pursuant to a 

seizure warrant issued in this district. 

70. The Seized Domains are registered by 

“ASCIO TECHNOLOGIES INC” DBA 

“NETNAMES,” a domain registrar that 

manages the reservation of internet domain 

names. A domain registrar serves to ensure 

that a registered domain name, like each of 

the Seized Domains, is not double sold. 

71. Additionally, a domain registration 

will allow the owner of the domain to direct 

internet traffic to a company’s webserver. 

The Seized Domains were found to have been 

acquired and maintained with funds traceable 

9(d). Backpage, until recently, controlled 

numerous domain names that have since been 

seized by the government pursuant to a 

seizure warrant issued in this district in case 

no. CR. Misc. 2:18-MJ-00711. 

The Seized Domains are registered by 

"ASCIO TECHNOLOGIES INC" DBA 

"NETNAMES," a domain registrar that 

manages the reservation of internet domain 

names. A domain registrar serves to ensure 

that a registered domain name, like each of 

the Seized 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 Seized 

Domains were found to have been acquired 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 37 of 62
37

to the money laundering scheme described 

herein, specifically with funds from 

Prosperity Bank account ‘7188, and the 

Seized Domains were the mechanism 

Backpage used to promote the prostitution 

and sex trafficking activity.

and maintained with funds traceable to the 

money laundering scheme described herein,

specifically with funds from an account 

seized pursuant to a separate seizure warrant 

in case no. CR. Misc. 2:18-MJ-00721, and the 

Seized Domains were the mechanism 

Backpage used to promote the prostitution 

and sex trafficking activity described below.

(Ex. 3 at ¶9(d).)

72. The following domains constitute and 

are derived from proceeds traceable to one or 

more violations of 18 U.S.C. § 156(g), 18 

U.S.C. § 156(a)(2), and 18 U.S.C. § 1957:

73. atlantabackpage.com

74. backpage.be

75. backpage.com

76. backpage.com.br

77. backpage.cz

78. backpage.dk

79. backpage.ee

80. backpage.es

81. backpage.fi

82. backpage.fr

83. backpage.gr

84. backpage.hu

85. backpage.ie

86. backpage.it

87. backpage.lt

88. backpage.mx

223. The following domains constitute and 

are derived from proceeds traceable to SUA, 

involved in money laundering, or both:

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

n. backpage.it

o. backpage.lt

p. backpage.mx

(Ex. 2 at ¶ 223.)

89. backpage.net

90. backpage.no

91. backpage.pl

92. backpage.pt

93. backpage.ro

94. backpage.si

95. backpage.sk

96. backpage.us

97. backpage-insider.com

98. bestofbackpage.com

99. bestofbigcity.com

100. bigcity.com

101. chicagobackpage.com

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

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 38 of 62
38

102. denverbackpage.com

103. newyorkbackpage.com

104. phoenixbackpage.com

105. sandiegobackpage.com

106. seattlebackpage.com

107. tampabackpage.com

dd. denverbackpage.com

ee. newyorkbackpage.com

ff. phoenixbackpage.com

gg. sandiegobackpage.com

hh. seattlebackpage.com

ii. tampabackpage.com

(Ex. 2 at ¶ 223.)

[2043 Pleasant Hill Rd, Sebastopol, CA 

95472]

108. Michael LACEY 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 SUA activity in violation of 18 U.S.C. § 

1957.

109. As set forth below, financial 

transactions involving illicit proceeds were 

deposited in GoCoin (Singapore) which were 

then moved through the Posting Solutions 

Prosperity Bank account, then moved through 

the Cereus Properties Compass Bank account, 

then moved to the San Francisco Fire Credit 

Union account ‘2523 controlled by Michael 

LACEY. 

[The Sebastopol Property]

160. The Sebastopol Property was purchased 

and maintained, in whole or in part, using 

funds traceable to SUA, involved in money

laundering, or both.

161. In a series of transactions in December 

2016, illicit proceeds from the Netherlands 

Account would pass-through Account 2,

eventually ending up in Account 11. 

Additionally, between July and October 2017, 

additional illicit proceeds from the Singapore 

Account were passed-through Account 1 to 

Account 2, and eventually transferred to 

Account 11. On or about October 10, 2017, 

over $10,000 of funds from Account 11 were 

used to support and maintain the Sebastopol 

Property. 

(Ex. 2 at ¶¶ 160-161.)

110. Additional financial transactions 

involving illicit proceeds were deposited in 

Ad Tech BV Bank Frick account (XXXX) 

which were then moved through the Cereus 

Properties Compass Bank account, then 

moved to the San Francisco Fire Credit Union 

account ‘2523 controlled by Michael 

LACEY. LACEY issued a check from his 

San Francisco Fire Credit Union account 

‘2523 to the Sonoma County Tax Collector.

157. Account 11 is held in the name of Lacey 

and an individual listed in the Credit Union’s 

records as Lacey’s employee and bookkeeper. 

Account 11 was funded with proceeds alleged 

to have been traceable to SUA, involved in 

money laundering, or both. 

a. On February 2, 2018, Account 2 (which 

then contained funds traceable to SUA, 

involved in money laundering, or both) 

transferred $734,602.70 into Account 11.

(Ex. 2 at ¶ 157.)

111. As noted above, on October 10, 2017, 

LACEY issued a check for $12,956.25 to 

163. On October 10, 2017, Lacey issued a 

$12,956.25 check from Account 11 to 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 39 of 62
39

Sonoma County Tax Collector. The notation 

on this wire was “2043 Pleasant Hill Dr 

Sebastopol”.

Sonoma County Tax Collector. The notation 

on this wire was “2043 Pleasant Hill Dr 

Sebastopol.” 

(Ex. 2 at ¶ 163.)

112. Finca Manzana for Sebastopol, LLC, a 

Delaware limited liability company, which 

was the entity used to take title to 

SEBASTOPOL, CALIFORNIA PROPERTY, 

is owned by Michael LACEY. On February 

11, 2016, Deborah Chalsty transferred by 

grant deed, as instrument number 

2016010019 of the Sonoma County official 

records, SEBASTOPOL, CALIFORNIA 

PROPERTY to Michael LACEY, an 

unmarried man. On April 24, 2017, Michael 

LACEY, for no consideration, transferred by 

grant deed, as instrument number 

2017031052 of the Sonoma County official 

records, SEBASTOPOL, CALIFORNIA 

PROPERTY to Finca Manzana for 

Sebastopol, LLC. As noted in the grant deed:

“There was no consideration for this transfer. 

This is a transfer between an individual or 

individuals and a legal entity or between legal 

entities that results solely in a change in the 

method of holding title and in which 

proportional ownership inters in the realty 

remain the same. . .”

162. On February 11, 2016, a grant deed, 

instrument number 2016010019 of the 

Sonoma County official records, transferred 

the Sebastopol Property to Lacey. Thereafter, 

on April 24, 2017, for no consideration, 

Lacey transferred title of the Sebastopol 

Property to his Delaware limited liability 

company, Sebastopol, LLC. As noted in

the grant deed:

“There was no consideration for this transfer. 

This is a transfer between an individual or 

individuals and a legal entity or between legal 

entities that results solely in a change in the 

method of holding title and in which 

proportional ownership inters in the realty 

remain the same. . .”

(Ex. 2 at ¶ 162.)

113. LACEY used funds that had been 

moved through GoCoin and Ad Tech BV, 

through Posting Solution and Cereus 

Properties accounts, to an account controlled 

by himself, to acquire or maintain the real 

property known as 2043 Pleasant Hill Rd.

157. Account 11 is held in the name of Lacey 

and an individual listed in the Credit Union’s 

records as Lacey’s employee and bookkeeper. 

Account 11 was funded with proceeds alleged 

to have been traceable to SUA, involved in 

money laundering, or both. 

a. On February 2, 2018, Account 2 (which 

then contained funds traceable to SUA, 

involved in money laundering, or both) 

transferred $734,602.70 into Account 11.

163. On October 10, 2017, Lacey issued a 

$12,956.25 check from Account 11 to 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 40 of 62
40

Sonoma County Tax Collector. The notation 

on this wire was “2043 Pleasant Hill Dr 

Sebastopol.” 

(Ex. 2, page 52, at ¶¶ 157, 163.)

[343 Presidio Ave, San Francisco, CA 94115]

114. Michael LACEY 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 SUA activity in violation of 18 U.S.C. § 

1957.

[San Francisco, California Property 1]

164. San Francisco Property 1 was purchased 

and maintained, in whole or in part, using 

funds traceable to SUA, involved in money

laundering, or both.

(Ex. 2 at ¶ 164.)

115. As set forth below, financial 

transactions involving illicit proceeds were 

deposited in GoCoin (Singapore) which were 

then moved through the Posting Solutions 

Prosperity Bank account, then moved through 

the Cereus Properties Compass Bank account, 

then moved to the San Francisco Fire Credit 

Union account ‘2523 controlled by Michael 

LACEY.

165. In order to acquire San Francisco 

Property 1, Lacey used funds transferred 

through the Singapore Account, the Website 

Tech Account ‘2008, and Cereus Properties 

accounts, as well as annuity accounts that 

Lacey controlled, as follows:

a. Illicit proceeds were deposited into the 

Singapore Account, passed-through Account 

1, then passed-through Account 2 and

transferred to Account 11. Thereafter, funds 

from Account 11 were used to support and 

maintain San Francisco Property 1; 

(Ex. 2 at ¶ 165.)

116. Additional financial transactions 

involving illicit proceeds were deposited in 

Ad Tech BV Bank Frick account (XXXX) 

which were then moved through the Cereus 

Properties Compass Bank account, then 

moved to the San Francisco Fire Credit Union 

account ‘2523 controlled by Michael 

LACEY. Lacey issued a check from his San 

Francisco Fire Credit Union account to pay 

the San Francisco Tax Collector. 

165(a). Illicit proceeds were deposited into 

the Singapore Account, passed-through 

Account 1, then passed-through Account 2 

and transferred to Account 11. Thereafter, 

funds from Account 11 were used to support 

and maintain San Francisco Property 1; 

(Ex. 2 at ¶ 165(a).)

117. As noted above, on October 10, 2017, 

LACEY issued a check for $15,053.08 to San 

Francisco Tax Collector. The notation on this 

wire was “343 Presidio”.

165(c). Thereafter, on October 10, 2017, over 

$10,000 in funds from Account 11 were used 

to purchase or maintain San Francisco 

Property 1. 

(Ex. 2 at ¶ 165(c).)

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 41 of 62
41

118. On May 18, 2016, David H. Berg, 

Trustee and Geraldine B Berg, Trustee of The 

Berg Family Trust, dated August 15, 2005 

transferred by grant deed, as instrument 

number 2016-K245482-00 of the San 

Francisco County official records, 343 

Presidio Ave, to Michael G. LACEY, a single 

man and Alyson Talley, a single woman, as 

joint tenants with right of survivorship.

165(b). On May 18, 2016, a grant deed 

recorded as instrument number 2016-

K245482-00 in the San Francisco County 

official records, transferred San Francisco 

Property 1 to Lacey and his female partner;

(Ex. 2 at ¶ 165(b).)

119. LACEY used funds that had been 

moved through GoCoin and Ad Tech BV, 

through Cereus Properties accounts, to 

accounts controlled by himself, to acquire or 

maintain the real property known as SAN 

120. FRANCISCO, CALIFORNIA 

PROPERTY 1.

165(a). Illicit proceeds were deposited into 

the Singapore Account, passed-through 

Account 1, then passed-through Account 2 

and transferred to Account 11. Thereafter, 

funds from Account 11 were used to support 

and maintain San Francisco Property 1; 

(Ex. 2 at ¶ 165(a).)

[2755 Fillmore St, San Francisco, CA 94123] 

121. Michael LACEY 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 SUA activity in violation of 18 U.S.C. § 

1957.

[San Francisco Property 2]

166. San Francisco Property 2 was purchased 

and maintained, in whole or in part, using 

funds traceable to SUA, involved in money

laundering, or both. 

(Ex. 2 at ¶ 166.)

122. As set forth below, financial 

transactions involving illicit proceeds were 

deposited in GoCoin (Slovakia) which was 

then moved through the Website 

Technologies Branch Banking & Trust 

account, then moved through Cereus 

Properties Arizona Bank & Trust account, 

then moved through multiple Annuity trust 

accounts controlled by LACEY, then moved 

to Arizona Bank & Trust account ‘1793 

controlled by LACEY. Funds from

LACEY’s Arizona Bank & Trust account 

‘1793 were then wire transferred to Fidelity 

National Title Company. 

167. During the period of December 14 

through December 29, 2015, as GoCoin’s 

partial payment for the Bitcoin Backpage sold 

it during the period of September 4 through 

November 23, 2015, the Slovakia Account 

wired over $1,250,000 to Website Tech 

Account ‘2008.

168. After December 14, 2015, Website Tech 

Account ‘2008 then transferred funds via 

multiple pass-through accounts controlled by

Lacey and other Backpage Operators, which, 

as of June 21, 2016, resulted in approximately 

$5,400,000 ending up in Arizona Bank &

Trust account ‘1793, controlled by Lacey 

(“AB&T Account ‘1793”). 

(Ex. 2 at ¶ 167-168.)

123. As noted above, on June 27, 2016, 

LACEY wired, or caused to be wired, 

$397,500.00 to Fidelity National Title 

169. On June 27, 2016, AB&T Account ‘1793 

wired $397,500.00 to Fidelity National Title 

Company. The notation on this wire was

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 42 of 62
42

Company. The notation on this wire was 

“XXX(Earnest Money)XXXXXX”. On July 

20, 2016, LACEY wired, or caused to be 

wired, $12,859,152.57 to Fidelity National 

Title Company. The notation on this wire 

was “XX(Balance of Property)XXXXX”.

“XXX(Earnest Money)XXXXXX.” On July 

20, 2016, AB&T Account ‘1793 wired 

$12,859,152.57 to Fidelity National Title 

Company. The notation on this wire was 

“XX(Balance of Property)XXXXX.”

(Ex. 2 at ¶ 167-169.)

124. Casa Bahia for San Francisco, LLC, a 

Delaware limited liability company, which 

was the entity used to take title to SAN 

FRANCISCO, CALIFORNIA PROPERTY 2, 

is owned by Michael LACEY (“XXX”). On 

July 21, 2016, Hui Li and Ying Lan Li 

transferred by grant deed, as instrument 

number 2016-K291371-00 of the San 

Francisco County official records, 2755 

Fillmore St to Michael G. LACEY, an 

unmarried man. On June 21, 2017, Michael 

G. LACEY, for no consideration, transferred 

by grant deed, as instrument number 2017-

K466276099 of the San Francisco County 

official records, SAN FRANCISCO, 

CALIFORNIA PROPERTY 2 to Casa Bahai 

for San Francisco, LLC, a Delaware limited 

liability company. As noted in the grant deed:

“There was no consideration for this transfer. 

This is a transfer between an individual or 

individuals and a legal entity or between legal 

entities that results solely in a change in the 

method of holding title and in which 

proportional ownership inters in the realty 

remain the same. . .”

170. Casa Bahia for San Francisco, LLC, a 

Delaware limited liability company, was the 

entity used to take title to the San Francisco 

Property 2, and is owned by Lacey. On July 

21, 2016, by grant deed, San Francisco 

Property 2 was transferred to Lacey. On

June 21, 2017, by grant deed and for no 

consideration, Lacey transferred San 

Francisco Property 2 to Casa Bahia for San 

Francisco, LLC, a Delaware limited liability 

company, as evidenced by instrument

number 2017-K466276099 recorded in the 

San Francisco County official records. As 

noted in the grant deed:

There was no consideration for this transfer. 

This is a transfer between an individual or 

individuals and a legal entity or between legal 

entities that results solely in a change in the 

method of holding title and in which 

proportional ownership inters in the realty 

remain the same. . .

(Ex. 2 at ¶ 170.)

125. LACEY used funds that had been 

moved through GoCoin, Website 

Technologies and Cereus Properties accounts, 

as well as annuity accounts controlled by 

himself, to acquire the real property known as 

2755 Fillmore St.

166. San Francisco Property 2 was purchased 

and maintained, in

whole or in part, using funds traceable to 

SUA, involved in money

laundering, or both.

167. During the period of December 14 

through December 29, 2015, as GoCoin’s 

partial payment for the Bitcoin Backpage sold 

it during

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 43 of 62
43

the period of September 4 through November 

23, 2015, the Slovakia

Account wired over $1,250,000 to Website 

Tech Account ‘2008.

168. After December 14, 2015, Website Tech 

Account ‘2008 then

transferred funds via multiple pass-through 

accounts controlled by

Lacey and other Backpage Operators, which, 

as of June 21, 2016,

resulted in approximately $5,400,000 ending 

up in Arizona Bank &

Trust account ‘1793, controlled by Lacey 

(“AB&T Account ‘1793”).

(Ex. 2 at ¶¶ 166-168.)

D. 1100 Union St. #700, San Francisco, 

CA 94109

126. Michael LACEY, 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 SUA activity in violation of 18 U.S.C. § 

1957.

K. San Francisco Property 3

171. San Francisco Property 3 was purchased 

and maintained, in whole or in part, using 

funds traceable to SUA, involved in money

laundering, or both.

172. Beginning in February 2013, illicit funds 

from Backpage’s U.S. Bank account ‘1165 

passed-through various Backpage or 

Backpage Operators accounts, eventually 

ending up in BMO Harris account ‘5263,

owned or controlled by Lacey. In May 2015, 

over $10,000 of funds from BMO Harris 

account ‘5263 was used to purchase or 

maintain San Francisco Property 3.

(Ex. 2 at ¶¶ 171-72.)

127. As set forth below, funds originating 

from Backpage’s U.S. Bank account ‘1165 

was moved through the Camarillo Holdings 

LLC, BMO Harris Bank account, then moved 

to LACEY’s BMO Harris account ‘5263. 

LACEY’s BMO Harris account ‘5263 paid a 

check to a contractor for repairs to the 1100 

Union St. #700. In detail:

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 44 of 62
44

a. Between February 4, 2013 and 

February 11, 2013, over a series of 

wire transfers, Backpage.com U.S. 

Bank account wired about $3.2 

million to Camarillo Holdings LLC 

BMO Harris Bank account ‘7172.

b. On February 15, 2013, 

Camarillo Holdings LLC BMO Harris 

Bank account ‘7172 wire transferred 

$395,513.85 to LACEY’s BMO 

Harris Bank account ‘5263.

c. On May 12, 2015, LACEY 

using funds from his BMO Harris 

Bank account ‘5263, paid an 

$11,027.37 check to a contractor for 

water damage repair for 1100 Union 

St. #700.

186. Between February 4 and June 6, 2013, 

approximately $41,500,000 in illicit funds 

were transferred to Camarillo Holdings

LLC, BMO Harris Bank account ‘7172.

(Ex. 2 at ¶ 186.)

DOJ-BP-0004951056 page 226.

 

DOJ-BP-0004951056 page 197.

E. 493 Zinfandel Lane, Saint Helena, CA 

94574

128. James LARKIN, 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 SUA activity in violation of 18 U.S.C. § 

1957.

129. As set forth below, financial 

transactions involving illicit proceeds were 

deposited in from Backpage’s U.S. Bank 

account ‘1165, then moved to the Camarillo 

Holdings LLC BMO Harris Bank account 

7172, then moved to JAMES LARKIN’s 

BMO Harris Bank account ‘3110. These 

illicit funds were then used to pay for 

appraisal for 493 Zinfandel Lane: 

a. From February 4, 2013 

through June 6, 2013, a foreign 

account wire transferred $41.5 million 

Camarillo Holdings LLC, BMO 

Harris Bank account ‘7172.

R. Saint Helena Property

185. The Saint Helena Property was 

purchased and maintained, in

whole or in part, using funds traceable to 

SUA, involved in money laundering, or both.

186. Between February 4 and June 6, 2013, 

approximately $41,500,000 in illicit funds 

were transferred to Camarillo Holdings LLC, 

BMO Harris Bank account ‘7172. 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 45 of 62
45

b. On October 2, 2013, BMO 

Harris Bank account ‘7172 wired 

$26,130.64 to JAMES LARKIN’s 

BMO Harris Bank account ‘3110.

c. On November 3, 2016, 

LARKIN paid a check to an appraiser 

company. Annotated on the memo 

line: “Zinfandel Appraisal 2015”

On October 2, 2013, BMO Harris Bank 

account ‘7172 wired $26,130.64 to Larkin’s 

BMO Harris Bank account ‘3110. 

Thereafter, on November 3, 2016, over 

$10,000 of funds from BMO Harris Bank 

account ‘7172 were used to purchase or 

maintain the Saint Helena Property.

(Ex. 2 at ¶¶ 185-86.)

F. 1308 E. 56th Street, 2, Chicago, IL 

60637

130. James LARKIN, 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 SUA activity in violation of 18 U.S.C. § 

1957.

131. As set forth below, funds originating 

from Backpage’s U.S. Bank account ‘1165, 

was moved through the Camarillo Holdings 

LLC, BMO Harris Bank account, then moved 

to LARKIN’s BMO Harris account ‘3110. 

Funds from LARKIN’s BMO Harris account 

‘3110 were then wire transferred to Chicago 

Title for 1308 E. 56th Street, 2. Specifically:

a. Between February 4, 2013 and 

June 6, 2013, over a series of wire 

transfers, Backpage.com U.S. Bank 

account wired about $41.5 million to 

Camarillo Holdings LLC BMO Harris 

Bank account ‘7172.

b. On October 2, 2013, Camarillo 

Holdings LLC BMO Harris Bank 

account ‘7172 wire transferred 

$26,130.64 to LARKIN’s BMO Harris 

Bank account ‘3110.

c. On October 2, 2015, 

LARKIN’s BMO Harris Bank account 

‘3110 wired $138,000 to Chicago 

S. Chicago Property

187. The Chicago Property was purchased 

and maintained, in whole

or in part, using funds traceable to SUA, 

involved in money laundering, or both.

188. Illicit funds originating from Backpage’s 

U.S. Bank account ‘1165 were passedthrough accounts owned or controlled by 

Backpage or Backpage Operators, and ended 

up in BMO Harris Bank account ‘3110.

Thereafter, on October 2, 2015, BMO Harris 

Bank account ‘3110 transferred $138,000 to 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 46 of 62
46

Title and Trust Company as payment 

for the purchase of 1308 E. 56th 

Street, 2. 

Chicago Title and Trust Company as payment 

towards the purchase of the Chicago Property.

(Ex. 2 at ¶¶ 187-88.)

G. 10647 N. State Route 89A, Sedona, AZ 

86336

132. Michael LACEY knowingly engaged 

and attempted to engage in a monetary 

transaction through a place outside the United 

States to a place in the United States with the 

intent to promote the carrying on of a 

specified unlawful activity in violation of 18 

U.S.C. § 1956(a)(2)(A).

133. As set forth below, financial 

transactions involving illicit proceeds were 

deposited into Cereus Properties Compass 

Bank, which was then moved through 

Michael LACEY’s First Federal Savings and 

Loan of San Rafael account ‘3620. Funds 

from LACEY’s Arizona Bank & Trust 

account ‘1793 were then paid to the Coconino 

County Treasurer for tax obligations for 

10647 N. State Route 89A. In detail:

a. Between December 2, 2016 

and December 30, 2016, a foreign 

account wire transferred 

$1,023,995.95 into Cereus Properties 

Compass Bank account ‘3873.

b. Between March 3, 2017 and 

June 9, 2017, Cereus Properties 

Compass Bank account ‘3873 paid 

about $4,000 of these funds to “Cox 

Communications,” an internet services 

company that provides voice-overinternet phone and cable services.

c. On October 2, 2017, Compass 

Bank account ‘3825 owned by Cereus 

Properties, wired approximately 

L. Sedona Property.

173. The Sedona Property was purchased and 

maintained, in whole or in part, using funds 

traceable to SUA, involved in money 

laundering, or both.

65(a). On December 2, 2016, the Foreign 

Account (first described in paragraph 42, 

above) wired $324,055.85 to Seized Account 

2A (Compass Bank account - 3873).

b. On December 8, 2016, the Foreign Account 

wired $499,970.00 to Seized Account 2A.

c. On December 27, 2016, the Foreign 

Account wired $199,970.00 to Seized 

Account 2A .

d. From March through December 2017 , 

Seized Account 2A paid over $9,000 to " Cox 

Communications," an internet services 

company that provides voice-over-internet 

phone and cable services...

(Ex. 3 at ¶ 65(a)-(d).)

174. In October 2017, Account 2 wired 

approximately $297,795 to Account 4.3

3 “Account 2 (Compass ‘3873 Funds)” is more fully described in Ex. 2 at ¶¶ 152-53. 

“Account 4 (FFS&L of SR ‘3620 Funds)” is more fully described in Ex. 2 at ¶ 155.

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 47 of 62
47

$297,795 into First Federal Savings & 

Loan of San Rafael account ‘3620.

d. On November 13, 2018, 

LACEY issued a check from First 

Federal Savings & Loan of San Rafael 

account ‘3620 to the Coconino County 

Treasurer for tax obligations for 10647 

N. State Route 89A.

On November 13, 2018, $6,725.54 from 

Account 4 was used to support or maintain 

the Sedona Property.

(Ex. 2 at 54 ¶¶ 173-74.)

H. 5555 North Casa Blanca Drive, 

Paradise Valley, AZ 85253

134. James LARKIN, 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 SUA activity in violation of 18 U.S.C. § 

1957.

135. As set forth below, funds originating 

from Backpage’s U.S. Bank account ‘1165 

was moved through the Camarillo Holdings 

LLC, BMO Harris Bank account, then moved 

to LARKIN’s BMO Harris account ‘3110. 

Funds from LARKIN’s BMO Harris account 

‘3110 were then paid to a landscape and 

gardening service. In detail:

a. Between February 4, 2013 and 

June 6, 2013, over a series of wire 

transfers, Backpage.com U.S. Bank 

account wired about $41.5 million to 

Camarillo Holdings LLC BMO Harris 

Bank account ‘7172.

b. On October 2, 2013, Camarillo 

Holdings LLC BMO Harris Bank 

account ‘7172 wire transferred 

$26,130.64 to LARKIN’s BMO Harris 

Bank account ‘3110.

c. On December 11, 2014, 

LARKIN issued a $46,987.28 check 

from the BMO Harris Bank account 

‘3110 to a lawn and garden service 

T. Paradise Valley Property 1

189. Paradise Valley Property 1 was 

purchased and maintained, in whole or in part, 

using funds traceable to SUA, involved in 

money laundering, or both.

190. Approximately $41.5 million in illicit 

funds from Backpage’s U.S. Bank account 

‘1165 passed through various Backpage or 

Backpage Operators’ accounts. 

Following these various transfers, eventually, 

on October 2, 2013, a total of approximately 

$26,130.64 was transferred into BMO Harris 

account ‘3110, owned or controlled by 

Larkin. 

Thereafter, on December 11, 2014, BMO 

Harris Bank account ‘3110 paid $46,957.28 to 

maintain the Paradise Valley property 1.

(Ex. 2 at ¶¶ 189-90.)

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 48 of 62
48

company for landscape service for 

5555 North Casa Blanca Drive.

I. LACEY PURCHASES THE 

PARADISE VALLEY, ARIZONA 

PROPERTY 2 USING PROCEEDS 

TRANSACTIONAL MONEY 

LAUNDERING

136. Michael LACEY 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 SUA activity in violation of 18 U.S.C. 

§ 1957. 

As set forth below, financial transactions 

involving illicit proceeds were deposited 

(TRACING TO BE COMPLETED 

ON MONDAY)4

U. Paradise Valley Property 2

191. Paradise Valley Property 2 was 

purchased and maintained, in whole or in part, 

using funds traceable to SUA, involved in 

money laundering, or both. 

192. Illicit funds originating from Backpage’s 

U.S. Bank account ‘1165 were passedthrough accounts owned or controlled by 

Backpage or Backpage Operators, and ended 

up in BMO Harris Bank account ‘3110, from 

which account over $10,000 was paid to 

maintain Paradise Valley Property 2.

(Ex. 2 at ¶¶ 191-92.)

137. Michael LACEY, 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 SUA activity in violation of 18 U.S.C. 

§ 1957. 

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 

involving 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 unlawful activity. 

(Ex. 1 at ¶ 167.)

138. As set forth below, funds originating 

from Backpage’s U.S. Bank account ‘1165 

was moved through the Camarillo Holdings 

173. Beginning in February 2013, illicit funds 

from Backpage’s U.S. Bank account ‘1165 

passed-through various Backpage or 

4

 This parenthetical note in green highlighting was in the tracing document, further 

evidencing that this document was in draft form.

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 49 of 62
49

LLC, BMO Harris Bank account, then moved 

to LACEY’s BMO Harris account ‘5263. 

Funds from LACEY’s BMO Harris account 

‘5263 were then used to purchase 3304 E. 

Stella Lane. In detail:

138(a): Between February 4, 2013 and June 6, 

2013, over a series of wire transfers, 

Backpage.com U.S. Bank account wired 

about $41.5 million to Camarillo Holdings 

LLC BMO Harris Bank account ‘7172.

138(b): Between March 15, 2014 and 

September 18, 2014, Camarillo Holdings 

LLC BMO Harris Bank account ‘7172 wire 

transferred $11,489,258.12 to LACEY’s 

BMO Harris Bank account ‘5263.

138(c): On March 11, 2015, LACEY wire 

transferred $50,000 from his BMO Harris 

Bank account ‘5263 to Clear Title Agency as 

earnest money deposit for the purchase of the 

3304 E. Stella Lane.

138(d): On March 30, 2015, LACEY wire 

transferred $774,379.46 from his BMO Harris 

Bank account ‘5263 to Clear Title Agency to 

complete the purchase of 3304 E. Stella Lane.

Backpage Operators accounts, eventually 

ending up in BMO Harris account ‘5263, 

owned or controlled by Lacey.”)

186. Between February 4 and June 6, 2013, 

approximately $41,500,000 in illicit funds 

were transferred to Camarillo Holdings

LLC, BMO Harris Bank account ‘7172. On 

October 2, 2013, BMO Harris Bank account 

‘7172 wired $26,130.64 to Larkin’s BMO 

Harris Bank account ‘3110.

172. Beginning in February 2013, illicit funds 

from Backpage’s U.S. Bank account ‘1165 

passed-through various Backpage or 

Backpage Operators accounts, eventually 

ending up in BMO Harris account ‘5263, 

owned or controlled by Lacey.

(Ex. 2 at ¶¶ 173, 172, 186.)

139. Michael LACEY, 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 SUA activity in violation of 18 U.S.C. § 

1957.

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 

involving 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 unlawful activity.

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 50 of 62
50

(Ex. 1 at ¶ 167.)

140. As set forth below, funds originating 

from Backpage’s U.S. Bank account ‘1165 

was moved through the Camarillo Holdings 

LLC, BMO Harris Bank account, then moved 

to LACEY’s BMO Harris account ‘5263. 

Funds from LACEY’s BMO Harris account 

‘5263 were then wire transferred to an Interest 

on Lawyers Trust Account (“IOLTA”) for his 

attorney who further wired funds to purchase 

6300 N. 33rd Street, 6314 N. 33rd Street, 

3308 E. Stella Lane, and 3311 E. Stella Lane. 

In detail:

140(a): Between February 4, 2013 and 

February 11, 2013, over a series of wire 

transfers, Backpage.com U.S. Bank account 

‘1165, wired about $3.2 million to Camarillo 

Holdings LLC BMO Harris Bank account 

‘7172.

140(b): On February 15, 2013, Camarillo 

Holdings LLC BMO Harris Bank account 

‘7172 wire transferred $395,513.85 to 

LACEY’s BMO Harris Bank account ‘5263.

140(c): On May 12, 2015, LACEY wire 

transferred or caused a wire transfer from his 

BMO Harris Bank account ‘5263, $3,350,000 

to a his attorney’s IOLTA account.

140(d): On May 12, 2015, the IOLTA paid 

$100,000 to “Thomas Title & Escrow” for the 

purchase of 6300 N. 33rd Street, 6314 N. 

33rd Street, 3308 E. Stella Lane, and 3311 E. 

Stella Lane.

140(e): On May 26, 2015, the IOLTA paid 

$3,143,132.25 to “Thomas Title & Escrow” 

for the payoff of the PARADISE VALLEY 

PROPERTIES 4, 5, 6, and 7

186. Between February 4 and June 6, 2013, 

approximately $41,500,000 in illicit funds 

were transferred to Camarillo Holdings

LLC, BMO Harris Bank account ‘7172. On 

October 2, 2013, BMO Harris Bank account 

‘7172 wired $26,130.64 to Larkin’s BMO 

Harris Bank account ‘3110.

172. Beginning in February 2013, illicit funds 

from Backpage’s U.S. Bank account ‘1165 

passed-through various Backpage or 

Backpage Operators accounts, eventually 

ending up in BMO Harris account ‘5263, 

owned or controlled by Lacey.

176(a). Between February 4 and June 6, 2013, 

through a series of wire transfers, Backpage’s 

U.S. Bank account ‘1165 transferred 

approximately $41,500,000 to BMO Harris 

Bank account ‘5263.

(Ex. 2 at ¶ 186, 172, 176.)

141. Daniel HYER knowingly engaged and 

attempted to engage in a monetary transaction 

with funds derived from violations of 18 

U.S.C. § 1952.

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 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 51 of 62
51

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 

involving 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 unlawful activity.

(Ex. 1 at ¶ 167.)

142. As set forth below, funds originating 

from Backpage controlled Website 

Technologies payroll account. The payroll 

service company then deposited the funds into 

DANIEL HYER’s Bank of America account 

‘9342. These funds were then used to pay the 

mortgage on HYER’s property, 7006 San 

Mateo Blvd Apt 214. For example:

142(a): On February 14, 2014, Website 

Technologies, a Backpage controlled entity, 

through their payroll company deposited 

$5,379.09 to DANIEL HYER’s Bank of 

America account ‘9342.

142(b): On February 28, 2014, Website 

Technologies, a Backpage controlled entity, 

through their payroll company deposited 

$5,798.88 to DANIEL HYER’s Bank of 

America account ‘9342.

142(c): On March 3, 2014, HYER paid the 

mortgage for the DALLAS PROPERTY with 

funds from the Bank of America account 

‘9342

DOJ-BP-0005031377 page 419

DOJ-BP-0005031377 page 421

143. JAMES LARKIN 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 SUA activity in violation of 18 U.S.C. 

§ 1957.

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 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 52 of 62
52

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 

involving 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 unlawful activity”)

(Ex. 1 at ¶ 167.)

144. As set forth below, funds originating 

from Website Technologies (Backpage) 

Branch Banking and Trust account ‘2008 was 

moved through Cereus Properties Arizona 

Bank & Trust account ‘6211, which them 

moved through JAMES LARKIN’s Charles 

Schwab account ‘4693, then Northern Trust 

Account ‘9562, held by the Ocotillo Family 

Trust which is owned by LARKIN. These 

funds were then used to purchase and upgrade 

14, rue Saint Guillaurme.

144(a): On December 31, 2015, Website 

Technologies’ Branch Banking & Trust 

account ‘2008 wired $811,424 to Arizona 

Bank & Trust account ‘6211.

144(b): On January 11, 2016, Arizona Bank 

& Trust account ‘6211 wired approximately 

$1.3 million to Charles Schwab account 

‘4693.

144(c): On January 14, 2016, Charles Schwab 

account ‘4693 wired approximately $13.5 

million to the Northern Trust account ‘9562.

144(d): On February 9 2016, LARKIN wire 

transferred or caused a wire transfer of 

$3,357,878.91 from his Charles Schwab 

account ‘4693 to SCP Bonnart a real estate 

company in Paris, France.

144(e): On February 16, 2016, LARKIN wire 

transferred or caused a wire transfer of 

See SI Count 87 (alleging Oct, 6, 2016 

transfer of $1,206,356.00 from Cereus 

Properties (x6211) to Charles Schwab 

(x4693)

137(d). Between January 21 and August 31, 

2016, Website Tech Account ‘2008 sent 

approximately 27 wire transfers totaling 

approximately $48,000,000 to Arizona Bank 

& Trust account number ‘6211, belonging to 

Cereus Properties LLC, which is owned or 

controlled by Spear, Backpage, and/or other 

Backpage Operators.”)

180(c)-(d). On January 14, 2016, Charles 

Schwab Account ‘4693 transferred 

approximately $13,500,000 to Northern Trust 

Company account ‘9562 (under the name 

“Ocotillo Family Trust,” owned and

controlled by Larkin and Margaret Larkin) ... 

In July 21, 2017, Account ‘9562 transferred 

$6,014,000 to Morgan Stanley account ‘1673 

(held in the name of Larkin and Margaret 

Larkin).

(Ex. 2 at ¶ 137, 180.)

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 53 of 62
53

$36,752 from his Charles Schwab account 

‘4693 to A+B Kasha Designs, a real estate 

design company in Paris, France. The wire 

annotations for this wire referenced an 

invoice for the renovation of 14, rue Saint 

Guillaurme

145. John BRUNST knowingly engaged and 

attempted to engage in a monetary transaction 

through a place outside the United States to a 

place in the United States with the intent to 

promote the carrying on of a specified 

unlawful activity in violation of 18 U.S.C. 

§ 1956(a)(2)(A).

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 

involving 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 unlawful activity. 

(Ex. 1 at ¶ 167.)

146. As set forth below, financial transactions 

involving illicit proceeds were deposited in 

GoCoin (Slovakia) which was then moved 

through the Website Technologies Branch 

Banking & Trust account ‘2008. These 

international funds were used to promote the 

SUA, then moved through Cereus Properties 

Arizona Bank & Trust account ‘6211, then 

moved through John BRUNST’s Wells Fargo 

Bank account ‘4891. Funds from John 

BRUNST’s Wells Fargo Bank account ‘4891 

was used to pay the County Treasurer for tax 

obligations for 3353 Red Robin Road. In 

detail:

146(a): National Bank of Arizona accounts 

'0178, ‘0151, and ‘3645 are held in the name 

of SPEAR. In furtherance of their money 

laundering scheme, and in an attempt to 

further conceal the true nature of the money, 

Backpage Operators used these accounts as 

45(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.”)

234. Between January 21, 2016, and August 

31, 2016, Website Tech Account ‘2008 

initiated approximately 27 wire transfers 

totaling approximately $48 million to Arizona 

Bank & Trust account number ‘6211 (“AZBT 

‘6211”), belonging to Cereus Properties LLC, 

which is owned or controlled by Spear, 

Backpage, and or other Backpage Operators. 

196. Accounts 31, 32, AND 33 (NBA ‘0178, 

‘0151, and ’3645)... Accounts 31 and 32 are 

held in the name of Spear, which accounts 

were funded with proceeds traceable to SUA, 

involved in money laundering, or both. 

Account 33 is held in trust for the benefit of 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 54 of 62
54

go-betweens to funnel money from one 

account to another.

Spear and certain of his family members, 

which account was funded with proceeds 

traceable to SUA, involved in money 

laundering, or both. In furtherance of the 

money laundering scheme, and in an attempt 

to further conceal the true nature of the 

criminal proceeds, go-between accounts 

served to funnel money from one account to

another.

(Ex. 1 at ¶¶ 45, 234, 196.)

147. The tracing involved numerous accounts 

including: Branch Banking & Trust account 

number ‘2008, belonging to Website 

Technologies; Arizona Bank & Trust account 

number ‘6211 belonging to Cereus Properties, 

and a GoCoin account in Slovakia.

147(a): Between December 14, 2015, and 

January 15, 2016, in approximately 26 wires, 

a GoCoin account in Slovakia transferred 

$2,523,475.60 to Branch Banking & Trust 

account number ‘2008 in the United States.

147(b): On January 15, 2016, Branch Banking 

& Trust account number ‘2008 wired 

$189,571 to Verizon in Los Angeles, 

California, in payment for Backpage internet 

services.

147(c): Between March 23, 2016 and March 

31, 2016, in three wire transfers, Branch 

Banking & Trust account number ‘2008 

transferred approximately $3,694,813.60 to 

Arizona Bank & Trust account number ‘6211.

147(d): On January 4, 2017 Arizona Bank & 

Trust account ‘6211 wired $298,941 to JOHN 

BRUNST’s Wells Fargo Bank account ‘4891.

147(e): On January 31, 2017, BRUNST, 

using funds from his Wells Fargo Bank 

account ‘4891 paid $3,773.25 to the Navajo 

County Treasurer for tax obligations for the 

PINETOP PROPERTY.

45(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.”)

234. Between January 21, 2016, and August 

31, 2016, Website Tech Account ‘2008 

initiated approximately 27 wire transfers 

totaling approximately $48 million to Arizona 

Bank & Trust account number ‘6211 (“AZBT 

‘6211”), belonging to Cereus Properties LLC, 

which is owned or controlled by Spear, 

Backpage, and or other Backpage 

Operators.”)

195(b)-(c). On December 6, 2016, Account 

‘6211 transferred $161,459 to Wells Fargo 

Bank account ‘4891, belonging to Brunst 

(“Account ‘4891”)... On January 4, 2017, 

Account ‘6211 transferred another $298,841 

to Account ‘4891”)

(Ex. 1 at ¶¶ 45, 234, 195.)

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 55 of 62
55

147(f): On October 3, 2017, BRUNST, using 

funds from his Wells Fargo Bank account 

‘4891 paid $4,125.92 to the Navajo County 

Treasurer for tax obligations for 3353 Red 

Robin Road.

147(g): On February 12, 2017, BRUNST, 

using funds from his Wells Fargo Bank 

account ‘4891 paid $4,125.92 to the Navajo 

County Treasurer for tax obligations for 3353 

Red Robin Road.

148. Michael LACEY, 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 SUA activity in violation of 18 U.S.C. 

§ 1957.

13. 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.

(Ex. 3 at ¶ 13.)

149. As set forth below, financial 

transactions involving illicit proceeds were 

deposited in GoCoin (Singapore) which were 

then moved through the Posting Solutions 

Veritex Bank account ‘1462, then moved 

through the Cereus Properties Compass Bank 

account ‘3873, then moved to his attorney’s 

IOLTA account at MidFirst Bank account 

‘4139. Funds from MidFirst Bank account 

‘4139 was used to purchase the PHOENIX 

PROPERTY 1.

a. Between January 13, 2017 and January 

20, 2017, GoCoin (Singapore) wired 

$1,318,800 to Posting Solutions 

Veritex Bank account ‘1462

b. On or about February 23, 2017, 

Veritex Bank account ‘1462 sent two 

payments, a wire of $443,014 and a 

check for $27,887.41 to Cereus 

Properties Compass Bank account 

‘3873.

c. Between March 30, 2017, and 

September 14, 2017, Cereus Properties 

Compass Bank account ‘3873 sent five 

wires totaling $4,058.063.65 to the 

78. From my review of financial records for 

Account – 1462 (as described in Paragraph 51 

above, Account - 1462 is the Posting 

Solutions ' Veritex Bank account} , Seized 

Account 2A and SUBJECT ACCOUNT 26 , 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 (totaling $1,317,800 wired 

from GoCoin' s Singapore account into

Account - 1462)

b. On or about February 23, 2017, Account -

1462 sent two payments, a wire of $443,014 

and a check for $27,887.41 to Seized Account 

2A.

c. Between March 30, 2017, and September 

14, 2017, Seized Account '2A sent five wires 

totaling $4,058,063.65 to SUBJECT 

ACCOUNT 26.

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 56 of 62
56

attorney’s IOLTA for MICHAEL 

LACEY at MidFirst Bank account 

‘4139.

d. On January 3, 2018, LACEY, through 

his attorney, used funds from the 

MidFirst Bank IOLTA account ‘4139 

to purchase 2416 N. Foote Dr.

(Ex. 3 at ¶ 78(a-c).)

Bates No. DOJ-BP-0005062516.

150. John BRUNST 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 SUA activity in violation of 18 U.S.C. 

§ 1957.

13. 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.

(Ex. 3 at ¶ 13.)

151. As set forth below, financial 

transactions involving illicit proceeds from a 

Backpage controlled Ad Tech BV foreign 

account, were deposited into Cereus 

Properties Compass Bank ‘3873, which was 

then moved through BRUNST’s Compass 

Bank Account ‘3825. Funds from 

BRUNST’s Compass Bank Account ‘3825 

were then paid to Equity Title Agency Inc. for 

the purchase of 4931 E. White Gates Drive.

a. Between December 2, 2016 and 

December 30, 2016, a foreign account 

wire transferred $1,023,995.95 into 

Cereus Properties Compass Bank 

account ‘3873.

65. From my review of financial records 

related to Seized Accounts 2A, 6, 7B, and 9, 

and Seized Accounts 16A, 16B, 16C,

16D, 16E, 16F, 16G, 16H, and 161 , I learned 

the following:

a. On December 2, 2016, the Foreign 

Account (first described in paragraph 42, 

above) wired $324,055.85 to Seized 

Account 2A (Compass Bank account -

3873).

b. On December 8, 2016, the Foreign 

Account wired $499,970.00 to Seized 

Account 2A.

c. On December 27, 2016, the Foreign 

Account wired $199,970.00 to Seized 

Account 2A.

(Ex. 3 at ¶ 65(a-c).)

Account 24 (COMPASS BANK ‘3825)

193. Account 24 is held in the name of 

Brunst, and was used in furtherance of the 

money laundering scheme described herein, 

and in

an attempt to further conceal or disguise the 

nature, location, source, ownership or control 

of the proceeds of SUA.

194. On February 2, 2018, Account 2 wire 

transferred $135,956.59 into Account 24.

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 57 of 62
57

b. On November 3, 2017, Cereus 

Properties Compass Bank account ‘3873 

transferred $73,648.03 to BRUNST’s 

Compass Bank Account ‘3825.

c. On December 22, 2017, BRUNST wire 

transferred or caused a wire transfer of 

$1.6 million from his Compass Bank 

account ‘3825 to Equity Title Agency 

Inc. for the purchase of 4931 E. White 

Gates Drive. 

(Ex. 2 at ¶¶ 193-194.)

Bates No. DOJ-BP-0005044473 at pg. 770.

Bates No. DOJ-BP-0005060535.

152. JOHN BRUNST knowingly engaged 

and attempted to engage in a monetary 

transaction through a place outside the United 

States to a place in the United States with the 

intent to promote the carrying on of a 

specified unlawful activity in violation of 18 

U.S.C. § 1956(a)(2)(A).

195. Accounts 25, 26, 27, 28, 29, and 30 are 

held in the name of the “Brunst Family 

Trust.” Brunst and his wife are the sole 

trustees for these accounts, which were 

funded with proceeds traceable to SUA,

involved in money laundering, or both.

(Ex. 2 at ¶ 195.)

153. As set forth below, financial 

transactions involving illicit proceeds were 

deposited in GoCoin (Slovakia) which was 

then moved through the Website 

Technologies Branch Banking & Trust 

account ‘2008, then moved through Cereus 

Properties Arizona Bank & Trust account 

‘6211, which is a funnel account. These 

funds were then then used to promote pay tax 

obligations, then moved through John 

BRUNST’s Wells Fargo Bank account 

‘4891. Funds from John BRUNST’s Wells 

Fargo Bank account ‘4891 was used to pay 

the Maricopa County Treasurer for tax 

obligations for 5830 E. Calle Del Media 

(Medio):

a. The tracing involved numerous accounts 

including: Branch Banking & Trust 

account number ‘2008, belonging to 

Website Technologies; Arizona Bank & 

Trust account number ‘6211 belonging to 

Cereus Properties, and a GoCoin account 

in Slovakia.

b. Between December 14, 2015, and 

195(a). On December 31, 2015, Website Tech 

Account ‘2008 transferred $811,424 to 

Account ‘6211;

b. On December 6, 2016, Account ‘6211 

transferred $161,459 to

Wells Fargo Bank account ‘4891, belonging 

to Brunst (“Account ‘4891”);

c. On January 4, 2017, Account ‘6211 

transferred another $298,841 to Account 

‘4891;

(Ex. 2 at ¶ 195(a-c).)

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 58 of 62
58

December 29, 2015, in approximately 13 

wire transfers, a GoCoin account in 

Slovakia transferred $1,251,179.97 to 

Branch Banking & Trust account number 

‘2008 in the United States. 

c. On December 31, 2015, Branch Banking 

& Trust account number ‘2008 

transferred approximately $811,424.07 to 

Arizona Bank & Trust account number 

‘6211. 

d. On January 21, 2016, LACEY promoted 

his business by paying $43,013.76 to the 

Internal Revenue Service for business tax 

obligations.

e. Between January 26, 2016 and January 

28, 2016, Arizona Bank & Trust account 

‘6211 wired $166,367.10 to JOHN 

BRUNST’s Wells Fargo Bank account 

‘4891.

f. On September 23, 2016, BRUNST, using 

funds from his Wells Fargo Bank account 

‘4891 paid $5,959.42 to the Maricopa 

County Treasurer for tax obligations for 

5830 E. Calle Del Media (Medio).

g. On January 31, 2017, BRUNST, using 

funds from his Wells Fargo Bank account 

‘4891 paid $5,959.42 to the Maricopa 

County Treasurer for tax obligations for 

5830 E. Calle Del Media (Medio).

Bates No. DOJ-BP-0004905513; Bates No. 

DOJ-BP-0004905522

Bates No. DOJ-BP-0005041374.

154. SCOTT SPEAR 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 SUA activity in violation of 18 U.S.C. 

§ 1957.

240. Based on the facts set out above, 

Plaintiff alleges that the Defendant Assets 

were involved in, and are traceable to, 

property involved in one or more transactions 

or attempted transactions in violation of 

section 18 U.S.C. § 1957, and a conspiracy to 

commit such offenses, in violation of section 

18 U.S.C. §1956(h).

(Ex. 2 at ¶ 240.)

196. Accounts 31 and 32 are held in the name 

of Spear, which accounts were funded with 

proceeds traceable to SUA, involved in 

money laundering, or both. Account 33 is 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 59 of 62
59

held in trust for the benefit of Spear and 

certain of his family members, which account 

was funded with proceeds traceable to SUA, 

involved in money laundering, or both. In 

furtherance of the money laundering scheme, 

and in an

attempt to further conceal the true nature of 

the criminal proceeds,go-between accounts 

served to funnel money from one account to 

another.

(Ex. 2 at ¶ 196.)

155. As set forth below, financial 

transactions involving illicit proceeds from a 

Backpage controlled Ad Tech BV foreign 

account, were deposited into Cereus 

Properties Compass Bank ‘3873, which was 

then moved through SPEAR’s National Bank 

of Arizona account ‘0178, then to SPEAR’s 

National Bank of Arizona account ‘0151. 

Funds from SPEAR’s National Bank of 

Arizona account were used to pay for 

upgrades to 5751 N. 77th Place, Scottsdale, 

AZ 85250.

a. Between December 2, 2016 and 

December 30, 2016, a foreign account wire 

transferred $1,023,995.95 into Cereus 

Properties Compass Bank account ‘3873.

b. On September 14, 2017, Cereus 

Properties Compass Bank account ‘3873 

transferred $50,162.05 to SPEAR’s National 

Bank of Arizona account ‘0178.

c. On October 12, 2017, Cereus 

Properties Compass Bank account ‘3873 

transferred $50,162.05 to SPEAR’s National 

Bank of Arizona account ‘0178.

d. On December 3, 2017 SPEAR paid 

$11,925 to a wine cellar installation 

company for the installation of a wine cellar 

into 5751 N. 77th Place.

65. From my review of financial records 

related to Seized Accounts 2A, 6, 7B, and 9, 

and Seized Accounts 16A, 16B, 16C,

16D, 16E, 16F, 16G, 16H, and 161, I learned 

the following:

a. On December 2, 2016, the Foreign 

Account (first described in paragraph 42, 

above) wired $324,055.85 to Seized 

Account 2A (Compass Bank account -

3873).

b. On December 8, 2016, the Foreign 

Account wired $499,970.00 to Seized 

Account 2A.

c. On December 27, 2016, the Foreign 

Account wired $199,970.00 to Seized 

Account 2A.

(Ex. 3 at ¶ 65(a-c).)

On September 14, 2017, Account 2 wire 

transferred $50,162.05 into Account 31.

(Ex. 2 at ¶ 196(c).)

DOJ-BP-0005042955; Bates No. DOJ-BP0005046060)

156. SCOTT SPEAR 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 SUA activity in violation of 18 U.S.C. 

§ 1957.

196. Accounts 31 and 32 are held in the name 

of Spear, which accounts were funded with 

proceeds traceable to SUA, involved in 

money laundering, or both. Account 33 is 

held in trust for the benefit of Spear and 

certain of his family members, which account 

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 60 of 62
60

was funded with proceeds traceable to SUA, 

involved in money laundering, or both. In 

furtherance of the money laundering scheme, 

and in an attempt to further conceal the true 

nature of the criminal proceeds,go-between 

accounts served to funnel money from one 

account to another.

(Ex. 2 at ¶ 196.)

157. As set forth below, financial 

transactions involving illicit proceeds were 

deposited in GoCoin (Slovakia) which was 

then moved through the Website 

Technologies Branch Banking & Trust 

account ‘2008, then moved through Cereus 

Properties Arizona Bank & Trust account 

‘6211, which then moved through SPEAR’s 

National Bank of Arizona account ‘0178, and 

‘8441. Funds from SPEAR’s National Bank 

of Arizona account ‘8441 was used to 

purchase 8604 E. San Ardo Dr:

a. Between December 14, 2015, and 

January 29, 2016, in approximately 39 

wire transfers, a GoCoin account in 

Slovakia transferred $3,959,557.78 to a 

Backpage controlled Branch Banking & 

Trust account number ‘2008 in the 

United States. 

b. Between February 2, 2016 and February 

29, 2016, in five wire transfers, Branch 

Banking & Trust account number ‘2008 

transferred approximately $6,622,954.08 

to Arizona Bank & Trust account 

number ‘6211. 

c. On January 4, 2017 Arizona Bank & 

Trust account ‘6211 wired $313,168.00 

to SPEAR’s National Bank of Arizona 

account ‘0178.

d. On April 18, 2016 SPEAR, transferred 

283,332.93 from his National Bank of 

Arizona account ‘0178 to his National 

Bank of Arizona account ‘8441.

e. On April 19, 2016, SPEAR wire 

transferred or caused a wire transfer of 

$283,332.93 from his National Bank of 

Arizona account ‘8441 to Security Title 

45. I have reviewed records for Seized 

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 Seized Account 3A.

46. According to records for Seized Account 

3A, 3B, and 3C:

On September 14, 2017, Seized Account 2A 

wired $50,162.05 into Seized Account 3A.

(Ex. 1 at ¶¶ 45-46.)

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 61 of 62
61

Escrow to purchase 8604 E. San Ardo 

Dr.

Paragraph C corresponds to Bates No. DOJBP-0005034093 page 439

Paragraphs D & E correspond to Bates No. 

DOJ-BP-0005060537

Case 2:18-cr-00422-DJH Document 1966-7 Filed 11/13/23 Page 62 of 62