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Paul J. Cambria, Jr. (NY Bar No.1430909, admitted pro hac vice) 

Erin E. McCampbell Paris (NY Bar No. 4480166, admitted pro hac vice) 

LIPSITZ GREEN SCIME CAMBRIA LLP 

42 Delaware Avenue, Suite 120 

Buffalo, New York 14202 

Telephone: (716) 849-1333 

Facsimile: (716) 855-1580 

pcambria@lglaw.com 

emccampbell@lglaw.com 

Attorneys for Michael Lacey 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

United States of America, 

 Plaintiff, 

vs. 

Michael Lacey, et al., 

 

 Defendants. 

NO. CR-18-00422-PHX-SMB 

DEFENDANT MICHAEL LACEY’S 

REPLY IN FURTHER SUPPORT OF 

SUPPLEMENT TO RULE 29 MOTION 

CONCERNING COUNT 100 

(Oral argument requested) 

 Michael Lacey (“Lacey”), by and through his undersigned counsel, files the instant reply in 

further support of his Rule 29 Motion Concerning Count 100, and Rule 29 Supplement (Doc. 2004). 

In its Response (Doc. 2020), the government has not provided this Court with a single case that 

affirms a concealment money laundering conviction (domestic or international) with facts like this 

case; namely: (1) a defendant who repeatedly stated his intent to file all disclosure forms with the 

federal government related to the funds, pay taxes on the funds at issue, and avoid tax shelters of 

any kind; (2) a defendant who timely filed the required disclosure forms, which identified the 

attributes of the funds at issue (his relationship to the funds, their location, the amount, etc.); (3) a 

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defendant who sought the advice of an attorney on how to stabilize banking and who was advised 

by the attorney to explore an offshore trust; (4) a defendant who relied on two attorneys to form 

and execute an offshore trust; (5) documentation of the purposes of forming the trust that have 

nothing to do with concealment; and, most damaging to the government’s case, (6) a government 

witness who testified that he was able to follow each and every transaction with ease because the 

bank accounts were held in the proper names of parties at issue. (See Doc. 2004.) The Response 

does not provide a single case with facts remotely comparable to Count 100 because there was no 

concealment here, intended or actual, but instead, mere money spending, which court after court 

has held is not money laundering and, thus, not illegal. This Court should acquit Lacey of his 

conviction for Count 100 because the proof is insufficient as a matter of law. 

ARGUMENT 

I. There is no proof of intent to conceal. 

 The government’s only purported evidence of intent to conceal is evidence of nothing at all. 

Lacey’s stated interest in placing funds where government parties could not “access” those funds 

does not, as the government claims, establish his intent to conceal. The word “access” does not 

mean the same thing as the word “conceal,” just like “hide” does not mean the same thing as 

“possess.” The government has provided zero authority for the analytical leap it asks this Court to 

take. Critically, this Court defined “concealment” for the jury as “the act of preventing disclosure 

or refraining from disclosing.” (Dkt. 1999 at 4.) The word “access” is defined as “freedom or ability 

to obtain or make use of something.” See Websters-Miriam Dictionary, available at 

https://www.merriam-webster.com/dictionary/access (last visited on Jan. 5, 20245). Nothing in 

the definition of “access” provides any implication – let evidence – of “concealment.” 

More importantly, Mr. Lacey’s statement about “access” cannot be read in a vacuum. The 

testimony and exhibits admitted at trial demonstrate that, while Mr. Lacey was concerned about the 

government interfering with his ability to bank or taking possession of his assets, , he never expressed 

an intent to hide his assets from the government. Instead, Lin Howard testified that Lacey said that 

“he wanted to make it clear that he wasn’t looking to avoid paying taxes, that he had a BDO 

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he directed [sic] to make sure that all taxes were paid and no tax shelters were taken.” 

(10/12/13 P.M. Tr. at 11.) That testimony was consistent with Lacey’s own words as documented 

in an email: “I think I am ready to move forward with the visit to the Los Angeles lawyer you 

recommended who has expertise in off-shore. [T]o revisit for just a moment, I am not interested 

in any tax avoidance.” (Ex. 1 (emphasis added).) Even Lin Howard testified that she did not 

understand Mr. Lacey to be asking her for help concealing or hiding anything. (Day 17 P.M. 

at 16, 22.) Thus, even if “access” could be read in isolation to mean “conceal,” Lacey 

nonetheless identified many steps he intended to take to disclose the funds at issue to the 

government, and he followed through with those intended disclosures. (See Exs. 5541, 5545, 

5546; Day 19 AM Tr. at 63; Day 23 PM Tr. at 81.) 

 The government’s second claim as to proof of intent to conceal is equally unavailing. Unable 

to distance itself from the overwhelming evidence of intent to disclose, followed by actual 

disclosure, the government claims that the flow of the funds from Backpage (a company then 

owned and controlled by Ferrer) to Website Technologies (a company also then owned and 

controlled by Ferrer) and then to Cereus Properties (a company co-owned by Lacey) that occurred 

prior to the funds ever reaching Lacey’s bank accounts is proof of intent to conceal. Here, again, 

the government’s evidence is proof of nothing. 

 First, the government’s own authority – United States v. Wilkes, 662 F.3d 524 (9th Cir. 2011) 

– demonstrates that these transactions are not relevant. As the Ninth Circuit recognized, an essential 

element of concealment money laundering conviction is proof that “the defendant conducted or 

attempted to conduct a financial transaction”—and the only transaction relevant to Count 100 is 

the transfer from Becker’s trust account to Lacey’s Hungary trust. Id. at 545. This element is 

required because the “money laundering statute criminalizes behavior that masks the relationship 

between an individual and his illegally obtained proceeds.” Id. (quoting United States v. 

Adefehinti, 510 F.3d 319, 322 (D.C. Cir. 2007)). Critically, the Ninth Circuit did not begin its analysis 

of proof of Wilkes’ intent to conceal until the funds at issue were put in possession of Wilkes. See 

Wilkes, 662 F.3d at 547 (discussing financial transactions after Wilkes had control of the funds at 

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issue). The transactions that preceded the deposit of the funds into an account controlled by Wilkes 

were not considered. See id. As a result, the only proof that is relevant to Lacey’s intent is what he 

did with the funds once they were deposited into his accounts – and as discussed throughout – his 

transactions were both easy to follow and timely disclosed to the government. 

 Moreover, the transactions the government now seeks to loop in – transfers from Backpage 

to Website Technologies and then to Cereus Properties – involve transfers made by companies 

controlled by Ferrer after he purchased Backpage. Those transactions not only are not relevant to 

Count 100, but there was no proof that Lacey was involved with those transfers or was even aware

of those transfers, so those transfers could have no bearing on Lacey’s intent. In addition to the 

government’s lack of proof on this requisite element, there is significant proof that, as a general 

matter, Lacey had nothing to do with Backpage’s operations even before Ferrer bought 

Backpage.com. Several witnesses testified that Lacey had nothing to do with the business side of 

any of the companies because there was a wall between the business and editorial side of their media 

company, like most media companies. (Day 24 A.M. at 46-50; 97-98.) The government’s lead 

witness, Ferrer, testified that Lacey was a “layer away” from Backpage, and Hyer, a top Backpage 

employee, never interacted with Lacey the entire time Backpage operated. (Day 13 A.M. Tr. at 11; 

10/19/23 Tr. P.M. at 112.) Lacey could not have intended to conceal something about which he 

had no knowledge, so the government’s failure to prove Lacey’s knowledge of or involvement with 

the transactions that preceded the deposit of funds into his accounts renders those transactions 

irrelevant to the issue of Lacey’s intent. 

 Additionally, the financial transactions at issue in Wilkes are readily distinguishable from the 

transactions in this case. In that case, Wilkes was convicted of domestic concealment money 

laundering (among other convictions), for concealing the payoff of a Congressman’s second 

mortgage, as part of a greater bribery conspiracy. See Wilkes, 662 F.3d at 530. Although the Ninth 

Circuit summarized the facts concerning proof of concealment in its opinion, the government’s 

appellate brief provided a more detailed discussion of the proof of intent to conceal, which 

demonstrates that the proof of intent in Wilkes was far different than what the government cobbled 

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together here. (See Brief for United States submitted on Mar. 14, 2011 in United States v. Wilkes, 

Ninth Circuit Case no. 08-50063 attached hereto as Exhibit A.) 

 As relevant, Wilkes and a colleague, Wade, bribed a Congressman to give government 

contracts to their companies. During the conspiracy, the Congressman obtained two mortgages on 

a home that he wanted paid off by Wilkes and Wade. (Ex. at 21-22.) Wade paid off the first 

mortgage; however, Wilkes failed to pay off the second mortgage as quickly as the Congressman 

had requested. (Id. at 22.) Wilkes began to undertake efforts to pay off the mortgage on May 6, 

2004, which took over a week, including: (1) Wilkes depositing funds derived from the bribery 

conspiracy into a company he controlled, ADCS, Inc.; (2) Wilkes transferring that money to another 

company he controlled, WBR Equities; and (3) Wilkes then transferring the money to Parkview 

Financial Inc., a company controlled by Thomas Kontogiannis. (Id.; see also id. at 23 n.13.) But that 

is not where the story ends. Before Wilkes began this series of transfers, Kontogiannis, through 

Parkview Financial Inc., paid off the second mortgage, which was held by a company with no 

association with Wilkes or Kontogiannis. (Id. at 23 n.13.) As such, there was no way to connect the 

dollars that paid off the mortgage to the dollars Wilkes obtained from his criminal scheme, because 

the mortgage was paid off before Wilkes made the final transfer to Parkview Financial, Inc. 

In contrast with Wilkes, the proof at trial here showed that the money flowed from one 

account to another in sequential order with proper account names for each account holder. (Day 

19 AM Tr. at 62, Ex. 1479.) Further, the only third party who was involved was Lacey’s lawyer, 

Becker, who on his own initiative, consolidated Lacey’s five grantor trust accounts into his 

IOLTA, where the funds were held in an account for Lacey’s benefit, and then transferred to 

a trust Lacey formed. Becker did not use his own funds to fund the trust only thento be 

reimbursed by Lacey, like Kontogiannis in the Wilkes case, who used funds from a corporation he 

controlled to pay off the Congressman’s mortgage who was then reimbursed by Wilkes. Instead, 

Becker used Lacey’s funds that came directly from bank accounts that bore Lacey’s name. The 

transactions followed a normal sequential order with no break in Lacey’s association or control of 

the funds – a material distinction between this case and the Wilkes case – that the government tries 

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to ignore. 

Another critical set of facts absent from Wilkes is the overwhelming evidence of intent to 

disclose and actual disclosure of the attributes of the funds. Prior to forming and funding the 

trust, Lacey told a bank employee and his lawyer that he wanted to pay taxes on the assets, and avoid 

tax shelters of any kind, meaning, he intended to tell the government about the offshore trust by 

declaring it on his tax returns and paying any taxes due. Then, a few weeks after the trust was funded, 

on February 21, 2017 – more than a year before he was indicted – Lacey asked Becker about 

who would be filing the disclosure forms with the government (Exs. 1, 6264), again, demonstrating 

Lacey’s intent to disclose and directly negating any intent to conceal. The government makes much 

out of the fact that the first FBAR was not filed until 18 months after the funds were sent to Hungary 

– but that claim ignores the fact that the initial FBAR was not due until April 14, 2018, and that 

Lacey’s lawyers, on their own initiative and not at the request of Lacey, sought the short automatic 

extension available to all filers. (10/24/13 P.M. Tr. at 132:4-6 (“Mr. Becker, did Mr. Lacey ever ask 

that there be an extension for the filing of the FBAR? A. No.”). 

Lacey has timely filed the requisite disclosure forms each year. The disclosure is not de 

minimis, as the government claims, but instead, identifies the attributes of the funds – the very facts 

that the government claims that Lacey has concealed from the government. The FBARs tell the 

government that he is the taxpayer associated with the funds, the amount of the funds, the location 

of the funds, and additionally provide a copy of the trust, which itself identifies all relevant parties. 

(Exs. 5541, 5545, 5546.) Indeed, there is no concealment money laundering case involving 

substantive disclosures like here cited by the government or located through research. 

There is another important distinction between Wilkes and this case. Wilkes involved 

domestic concealment money laundering. Lacey was convicted of international concealment 

money laundering. The only transaction that occurred at Lacey’s direction that provided a basis for 

charging him with international concealment money laundering was the transfer that Becker made 

from his IOLTA account to the trust account in Hungary, for which there is no proof of intent to 

conceal or concealment of any kind. If the government believed, as it now claims, that the transfers 

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from Backpage to Website Technologies and then Website Technologies to Cereus Properties and 

then Cereus Properties to Lacey’s grantor trust bank accounts were proof of concealment, the 

government could have charged Lacey with domestic concealment money laundering. Instead, the 

government charged him with transactional money laundering for those transfers (for which the 

jury rendered no verdict). 

II. There is no proof of intent to conceal, in part. 

 The government’s next claim is that, even if there was proof of intent to accomplish some 

other objective – like stabilizing Lacey’s banking and the formation of a trust for the benefit of 

Lacey’s sons – there still is proof of intent to conceal, in part, which is sufficient proof to establish 

the intent element. Here, again, there is no proof to support the government’s claim. 

 First, the record demonstrates that there was no concealment in part. The government’s 

own witness killed this argument when he testified that the accounts bore the names of the relevant 

party and that he was able to follow each transaction with ease. (Day 19 AM Tr. at 62, see also Ex. 

1479.) On top of this testimony, the proof at trial demonstrated an intent to disclose and actual 

disclosure. None of these facts provide support for the government’s concealment-in-part claim 

and, as discussed above, depriving the government of access to a bank account is not the same thing 

as concealing the bank account, even in part. 

Second, the cases that the government cited for its concealment-in-part claim are readily 

distinguishable. For example, in United States v. Singh, 995 F.3d 1069 (9th Cir. 2021), the defendant 

transferred funds through an alternative “money transferring network” called “hawala” that was 

“designed to transfer funds from point to point” with no “record keeping” or “government 

oversight.” Id. at 1073. On top of that, the defendant used additional “secrecy” techniques such as 

switching out Sim cards, using burner phones, using code words at transfers, and putting serial 

numbers on dollar bills to verify the recipient of each transaction. See id. at 1074. Nothing about 

that case is at all similar to the standardized banking transfers at issue here. 

In United States v. Abouammo, 2022 WL 17584238 (N.D. Cal. Dec. 12, 2022), the defendant 

opened an account in Lebanon under his father’s name, directed funds to be deposited to that 

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account, and then directed funds to be transferred from that account to his account below the 

reporting amount and with the subject line “family fund.” See id. at *16-17. United States v. Huy Chi 

Luong, 468 F. App’x 710 (9th Cir. 2012), also involved extensive evidence of intent to conceal. The 

defendant had a third-party purchase teller’s checks to make payments on a home that was titled in 

his parents’ name, but which the defendant, in reality, actually owned. Again, none of that deception 

is present here. In United States v. Chang, 2020 WL 5702131 (N.D. Cal. Sept. 24, 2020), the defendant 

created two entities with names that sounded similar to the name of his church and then used those 

entities to siphon donations intended for the church for his personal gain. In doing so, among other 

things, he used identification of another church member to create one of the bank accounts through 

which he moved the funds that correlated to the concealment money laundering charges. None of 

the deception like these cases is present here. 

Notably, United States v. Sun, 673 F. App’x 729 (9th Cir. 2016), supports acquittal on Count 

100. In that case, the defendant put “illegal cash proceeds from his medical practice into his personal 

bank account, rather than his business account” and told investigators that he did so to “avoid 

reporting [the funds] to the IRS.” Id. at 733. The opposite is true here. Lacey directed Becker to 

engage in a transaction that he was advised and knew would trigger a disclosure to the federal 

government, he stated that he intended to make the disclosure, he directed his lawyers to make the 

disclosure, and he has been making the disclosure ever since. 

Finally, United States v. Twitchell, 69 F. App’x 892 (9th Cir. 2003), provides too little of a factual 

discussion to be helpful and, in any event, is an unreported case that pre-dates the Supreme Court’s 

seminal case on concealment, Cuellar v. United States, 553 U.S. 550 (2008). Similarly, United States 

v. Kellum, 119 F. App’x 32 (9th Cir. 2004), is another unreported case that pre-dates Cuellar. It 

involves a defendant who used ill-gotten gains to purchase a cashier’s check and the proof was that 

this transaction made it harder for the government to discover the origin of the funds. Kellum stands 

in stark contrast with this case where the government’s witness testified that the transactions were 

easy to follow. (Day 19 AM Tr. at 62, see also Ex. 1479.) 

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III. The transactions at issue were open and obvious. 

 The government’s claim that the “transactions were not ‘open and obvious’” is at odds with 

the testimony of the government’s own witness, Quoc Thai. Indeed, Thai testified that all of the 

accounts had accurate names for the account holders and he could trace the funds from account to 

account, even with respect to the use of Becker’s IOLTA account because an attorney IOLTA 

account is “an account held in the name of a client . . . [b]y an attorney.” (Day 19 AM Tr. at 62, 64-

65; see also Ex. 1479.) Because the funds were associated with Lacey before and after the transfer to 

Hungary, and the transactions were easy to follow, the transactions were open and obvious. 

IV. There is no proof that Lacey knew that the trust was funded with proceeds. 

 There is no conviction that establishes that Lacey had knowledge that the funds at issue were 

proceeds of specified unlawful activity in the form of Travel Act violations for the facilitation of 

prostitution business enterprises. As a preliminary matter, the jury reached no verdict as to Lacey 

on conspiracy or any Travel Act count. The jury’s finding of guilt as to other defendants does 

not establish Lacey’s knowledge about anything. 

 Furthermore, as has been litigated in this case, and as this Court instructed the jury, the First 

Amendment presumption for protected expression is at issue here. Lacey, like any other person, is 

entitled to presume that third-party speech is protected expression unless he has information that a 

particular ad was an ad for prostitution services as opposed to an ad for lawful sexual services such 

as stripping, sensual massage, etc. There is no proof that Lacey believed anything other than that 

the speech at issue – the publication of third-party ads – was protected expression. 

 The evidence the government points to as proof of his knowledge is, again, is not proof of 

anything. For example, Lacey’s authoring of the draft article entitled, Backpage Understood, shows 

that he believed that Backpage had extensive technology in place to keep ads proposing illegal 

transactions off the website. (Ex. 113A.) To the extent that article can be read to suggest that Lacey 

somehow had knowledge of ads proposing illegal transactions on the website, Ferrer quickly 

dispelled that notion, advising Lacey that “I do not have prostitution ads.” (Ex. 115B.) 

 The remainder of the government’s proof of knowledge is episodic/anecdotal opinions 

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about ads from elected officials, religious leaders, and journalists opining that anybody can tell that 

the ads were prostitution ads. This anyone-can-tell evidence was contradicted by law enforcement 

witnesses who testified that ads did not provide probable cause to make an arrest, including one 

who testified even the one charged ad that arguably was an express offer of sex for money did not 

provide probable cause for an arrest. (Day 17 P.M. 117-18 (Det. Murray testifying no probable 

cause to arrest based solely on ad saying “80 for head, 120 for hooking up without head, 150 

for hooking up with head.”).) This anyone-can-tell evidence was further contradicted by an 

expert who testified that it is impossible to know from the face of an ad whether the poster 

was engaged in prostitution and, further, it is statistically impossible to know what percentage 

of ads on Backpage were associated with prostitution. (Day 24 P.M. 43-44, 48-53, 87-96.) 

This testimony came from an expert who responded to ads and met in person with people 

who posted ads (unlike Ferrer, who testified he had never done so). (Id.) Further, counsel for 

Backpage expressed the unequivocal view that Backpage was a lawful platform for the 

publication of third-party ads concerning adult entertainment. (Ex. 171.) 

 Finally, even if all that evidence was to be disregarded, the government’s own proof 

demonstrated that no less than 6% of revenue originated from non-adult ad categories as to which 

the government admits the ads were lawful. (Ex. 1480). Because the government did no tracing of 

the funds at issue in Count 100, there was no evidence that the funds Lacey transferred to Hungary 

were criminal proceeds, as opposed to revenues from the publication of unquestionably lawful nonadult ads (which the government’s evidence proved accounted for at least 6% of Backpage.com 

revenues) or from adult ads the jury was required to assume were constitutionally protected. The 

government had the burden to prove that the funds transferred to the Hungarian trust were criminal 

proceeds, but, as Thai conceded, he did not do an ad-by-ad analysis and had no idea if any particular 

revenue to Backpage was tied to the publication of a constitutionally unprotected ad. (Day 19 AM 

at 44-48, 54.) That concession is fatal to the government’s claim that the transfer constituted 

criminal proceeds and to Lacey’s knowledge of proceeds. 

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 RESPECTFULLY SUBMITTED this 18th day of January, 2024, 

Paul J. Cambria, Jr. 

Erin McCampbell Paris 

LIPSITZ GREEN SCIME CAMBRIA LLP 

 By: /s/ Paul J. Cambria, Jr. 

Paul J. Cambria, Jr. 

Attorneys for Michael Lacey 

On January 18, 2024, a PDF version 

of this document was filed with 

Clerk of the Court using the CM/ECF 

System for filing and for Transmittal 

Of a Notice of Electronic Filing to the 

Following CM/ECF registrants: 

Kevin Rapp, kevin.rapp@usdoj.gov 

Peter Kozinets, peter.kozinets@usdoj.gov 

Daniel Boyle, daniel.boyle2@usdoj.gov 

Margaret Perlmeter, margaret.perlmeter@usdoj.gov 

Andrew Stone, andrew.stone@usdoj.gov 

Austin Maxwell Berry, austin.berry2@usdoj.gov

Case 2:18-cr-00422-DJH Document 2033 Filed 01/18/24 Page 11 of 11