3891320.2

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

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

Erin 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

Gary S. Lincenberg (CA Bar No. 123058, admitted pro hac vice)

Ariel A. Neuman (CA Bar No. 241594, admitted pro hac vice)

Gopi K. Panchapakesan (CA Bar No. 279856, admitted pro hac vice)

BIRD, MARELLA, BOXER, WOLPERT, NESSIM,

DROOKS, LINCENBERG & RHOW PC

1875 Century Park East, 23rd Floor

Los Angeles, California 90067-2561

Telephone: (310) 201-2100

Facsimile: (310) 201-2110

glincenberg@birdmarella.com

aneuman@birdmarella.com

gpanchapakesan@birdmarella.com

Attorneys for John Brunst

[Additional counsel listed on next page]

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-DJH

DEFENDANTS’ RESPONSE TO 

GOVERNMENT’S OBJECTIONS TO 

ADMISSION OF EVIDENCE

Case 2:18-cr-00422-DJH Document 1803 Filed 09/21/23 Page 1 of 13
3891320.2 2

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Eric Kessler (AZ Bar No. 009158)

KESSLER LAW GROUP

6720 N. Scottsdale Rd., Suite 210

Scottsdale, AZ 85253

Telephone: (480) 644-0093

eric@kesslerlawgroup.com

Attorney for Scott Spear

Bruce Feder (AZ Bar No. 004832)

FEDER LAW OFFICE PA

2930 E. Camelback Road, Suite 160

Phoenix, Arizona 85016

Telephone: (602) 257-0135

bf@federlawpa.com

Attorney for Scott Spear

David Eisenberg (AZ Bar No. 017218)

DAVID EISENBERG PLC

3550 N. Central Ave., Suite 1155

Phoenix, Arizona 85012

Telephone: (602) 237-5076

Facsimile: (602) 314-6273

david@deisenbergplc.com

Attorney for Andrew Padilla

Joy Malby Bertrand (AZ Bar No. 024181)

JOY BERTRAND ESQ LLC

P.O. Box 2734

Scottsdale, Arizona 85252

Telephone: (602)374-5321

Facsimile: (480)361-4694

joy.bertrand@gmail.com

Attorney for Joye Vaught

Case 2:18-cr-00422-DJH Document 1803 Filed 09/21/23 Page 2 of 13
3891320.2 3

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Defendants, by and through their undersigned counsel, respond to the Government’s 

motion (Dkt. 1801), which seeks to preclude defense evidence of good faith that specifically 

rebuts the Government’s evidence and testimony introduced through Carl Ferrer. 

I. It is black letter law that the defense has the right to cross-examine

a government witness on the witness’s prior statements.

“A basic rule of evidence provides that prior inconsistent statements may be used to 

impeach the credibility of a witness.” United States v. Bao, 189 F.3d 860, 865-66 (9th Cir. 

1999). Not only is a defendant entitled to cross-examine a government witness on prior 

inconsistent statements, the Jencks Act mandates that the government disclose such 

statements to the defense to enable the defense to cross a witness on his or her prior 

statements. See, e.g., United States v. Brumel-Alvarez, 991 F.2d 1452, 1458 (9th Cir. 1992) 

(reversing conviction on basis that undisclosed prior statement would have been used to 

impeach the witness and deprived defendants of exculpatory evidence). Simply put, when it 

comes to prior statements of a witness, there is no exception to the right to crossexamination. It is universally understood that the defense is entitled to cross-examine

a defendant on any prior statement, particularly, as here, when the prior statements address 

the very issues put before the jury by the Government on its direct exam. Precluding 

defense counsel from cross-examining Ferrer on his prior statements, including those made 

under oath, will deprive Defendants of their right to a fair trial and create reversible error. 

See Holley v. Yarborough, 568 F.3d 1091, 1099-1101 (9th Cir. 2009) (granting writ of habeas 

corpus to a defendant who was barred from cross-examining a key government witness 

about her prior statements).

Moreover, the Federal Rules of Evidence extend even further when the prior 

statement at issue was made under oath as part of a prior court case. Indeed, a “prior 

inconsistent statement may be offered to establish the truth of its assertion if it was 

given under oath at a trial, hearing, or other proceeding, or in a deposition.” Bao, 189 F.3d at 

866 n.1 (citing Rule 801(d)(1)(A) (emphasis added)). In these prior statements, Ferrer speaks 

to the very allegations asserted in this case regarding moderation, Backpage’s terms of use, 

Case 2:18-cr-00422-DJH Document 1803 Filed 09/21/23 Page 3 of 13
3891320.2 4

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

and whether the ads on the site proposed acts of prostitution or were associated with 

prostitution. There is no limitation under the Rule that the prior trial, hearing, or proceeding 

concern the same charges as those at issue in the instant case.

On these bases, the defense is entitled, as a matter of law, to cross-examine Ferrer on 

any of his prior statements, and to seek admission of those that he previously gave under 

oath under Rule 801(d)(1)(A) and as evidence of Defendants’ good faith reliance on the 

lawfulness of the operation of Backpage.

II. It is black letter law that the defense is allowed to cross-examine a government 

witness about any topic on which the government solicited testimony during 

direct.

It is black letter law that when a litigant opens the door on a topic, “it is fair 

advocacy” for the opposing party “to enter.” See United States v. Del Toro Barboza, 673 F.3d 

1136, 1153 (9th Cir. 2012). 

The government has repeatedly—each day at trial—elicited testimony from Ferrer 

and has admitted exhibits through Ferrer that opened the door to the existence and results 

of prior proceedings and litigation, including prior investigations of Backpage, grand jury 

investigations, the Senate’s Permanent Subcommittee on Investigation’s hearing and report, 

and testimony from Ferrer and other Backpage employees during these proceedings. The 

attached chart (Exhibit A) details the government’s door opening through Ferrer. The 

Defendants’ right to a fair trial requires that Defendants be allowed “to enter” each and 

every door the government opened to elicit evidence of their good faith. 

Further, the government has repeatedly elicited testimony regarding subpoenas in 

“prostitution” cases, Ferrer’s testimony in those cases, assistance given to law enforcement, 

and purported failures to disclose certain aspects of the Backpage business to law 

enforcement. While the government has stipulated to the admission of many of the law 

enforcement accolades the defense intends to introduce, it purports to dictate which 

accolades the defense should be permitted to introduce and which are cumulative before the 

defense even stands up to cross-examine Ferrer. That law enforcement commended 

Case 2:18-cr-00422-DJH Document 1803 Filed 09/21/23 Page 4 of 13
3891320.2 5

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Backpage regarding their efforts to assist in the prosecution of wrongdoers is a central theme 

of the defense and directly negates an alleged intent to facilitate business enterprises involved 

in prostitution. The Court should not preclude evidence the government concedes is 

relevant before the defense even has an opportunity to present the evidence.

Regarding evidence that Backpage notified law enforcement of ads on other sites, this 

evidence also negates intent, as it shows efforts on the part of Backpage to bring wrongdoers

to justice. Backpage’s cooperation with law enforcement in this respect is inconsistent with 

the notion that it intended to facilitate business enterprises involved in prostitution. The 

government has also elicited through Ferrer that other websites, like Craigslist, had taken 

actions to eliminate adult content from their site—the implication being that Backpage was 

a bad actor by comparison. The proffered evidence would also rebut this charge.

III. The Dart saga is plainly relevant to the Government’s claims of “credit card 

Armageddon.”

As to the Backpage v. Dart litigation—which plays a central role in what the 

government has called “credit card Armageddon”—the basis for the admission of exhibits 

tied to Dart is set forth at Dkt. 1780 (Brunst’s opposition to the government’s motion for 

curative instruction). In short, (1) in June 2015, Sheriff Dart of Cook County, Illinois sent 

threatening letters to MasterCard and Visa (Gov. Exs. 459, 478); (2) within days, those credit 

card companies terminated their relationships with Backpage (Ex. 6011); (3) Backpage then 

sued Sheriff Dart in federal court in an attempt to get its credit card relationships back; 

(4) Mr. Ferrer and Backpage communicated internally and with credit card 

companies/processors regarding the litigation (Gov Ex. 1127, Ex. 6013, Ex. 6025); and 

(5) on November 30, 2015, the Seventh Circuit Court of Appeals enjoined Sheriff Dart from 

making further threats toward financial institutions with whom Backpage had a relationship

(Ex. 5104, cert. denied. Ex. 5106).

While Mr. Ferrer has artfully attempted to avoid a reference to “Dart” during his trial 

testimony, he referenced Sheriff Dart during his interviews with the government (as 

documented in FBI 302s produced to the defense) nearly 40 times, using phrases like the

Case 2:18-cr-00422-DJH Document 1803 Filed 09/21/23 Page 5 of 13
3891320.2 6

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

“Dart credit card ban,” “Dart incident,” and “credit card· Armageddon/Dart incident.” 

Ferrer also testified today that he came to learn in July 2015 that Visa and MasterCard 

bowed to “pressure put on them.” That “pressure” was exerted by Dart, a fact which the 

government’s interviews of Ferrer and Ferrer’s contemporaneous emails show Ferrer 

understood. See Gov Exh. 1127 (July 1, 2015 e-mail from Ferrer to others at Backpage, 

stating, “[Mastercard] and Sheriff Dart are now deciding what is legal and illegal speech. 

[A]re now arbiters of legal speech. We have our legal team on it. We have a good track 

record on these issues.”); Exh. 6025 (July 21, 2015 email from Ferrer to Trent Voight [CEO 

of JetPay, a credit card processor] stating that, “If we win on Dart, then Visa has cover for 

protected speech.”). 

By putting at issue these credit card terminations in its indictment, opening 

statement, and during Ferrer’s testimony, the government has opened the door to crossexamination regarding (1) why the credit card companies terminated their relationships with 

Backpage; (2) Ferrer’s understanding of the basis for those terminations (as reflected in 

contemporaneous emails, prior statements under oath, and in his statements during 

interviews to the government); and (3) what Backpage did in response, namely that it sued 

Dart and ultimately prevailed. 

That Backpage prevailed in Dart served to counteract any purported “notice” that the 

credit card terminations were triggered by anything illegal that Backpage or Defendants were 

doing, as opposed to illegal coercion on the part of a law enforcement official. Backpage.com,

LLC v. Dart, 807 F.3d 229, 230 (7th Cir. 2015) (Posner, J.) (“Visa and MasterCard bowed to 

pressure from Sheriff Dart and others by refusing to process transactions in which their 

credit cards are used to purchase any ads on Backpage, even those that advertise indisputably 

legal activities.”) (emphasis in original); id. (“[W]hile [Dart] has a First Amendment right to 

express his views about Backpage, a public official who tries to shut down an avenue of 

expression of ideas and opinions through ‘actual or threatened imposition of government 

power or sanction’ is violating the First Amendment.”) (quoting American Family Association,

Inc. v. City & County of San Francisco, 277 F.3d 1114, 1125 (9th Cir. 2002)); id. at 232 (Dart “is 

Case 2:18-cr-00422-DJH Document 1803 Filed 09/21/23 Page 6 of 13
3891320.2 7

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

intimating that two of the world’s largest credit card companies may be criminal 

accomplices” and that “Visa and MasterCard got the message and cut all their ties to

Backpage.”) (emphasis in original).

Ferrer submitted a declaration and was deposed in Dart. (Gov Exhs. 1629, 1687). 

He also submitted a declaration in another case in which he stated that Dart had “started 

a campaign against Backpage,” attaching the Dart opinion. Chilly Dil v. JetPay, Case No. 3:14-

cv-02749 (N.D. Tex.). Ferrer was plainly aware of and relied on the Dart opinion at the 

time. Ferrer’s prior statements are directly relevant to impeach any testimony by Ferrer 

claiming that Defendants or Ferrer were operating in bad faith at the time.

IV. It is reversible error to preclude the defense from admitting evidence of good 

faith or evidence of state of mind/lack of intent.

It is well-settled that the Federal Rules of Evidence “reflect the fact that individuals 

accused of criminal behavior should be permitted to present, within reason, the strongest 

case they are able to marshal in their defense.” United States v. Thomas, 32 F.3d 418, 421 (9th 

Cir. 1994) (“revers[ing] defendant’s conviction because the district court impermissibly and 

prejudicially limited the evidence that this criminal defendant was entitled to present” 

concerning his subjective intent). “[B]arring a defendant from presenting all evidence in 

support of a cognizable defense, or from challenging an element of the crime, is structural 

error.” See United States v. Smith-Baltiher, 424 F.3d 913, 922 (9th Cir. 2005) (reversing illegal 

entry conviction because district court barred introduction of defendant’s mother’s U.S. 

birth certificate and testimony of a mental health expert, which precluded the defendant 

from negating an element of the charged crime as well as his defense of good faith belief that 

he did not need documentation to enter). 

A. At a minimum, non-privileged letters and memoranda written by 

attorneys are admissible.

Evidence of non-privileged attorney opinions or letters and a defendant’s awareness 

of that evidence is admissible to demonstrate defendants’ good faith and negate alleged 

intent. For example, in Cheek v. United States, 498 U.S. 192 (1991), the Supreme Court 

Case 2:18-cr-00422-DJH Document 1803 Filed 09/21/23 Page 7 of 13
3891320.2 8

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

recognized that “forbidding the jury to consider evidence that might negate willfulness 

would raise a serious question under the Sixth Amendment’s jury trial provision.” Id. at 203. 

In that case, the defendant was charged with tax violations. He presented evidence in 

support of his defense that he did not willfully violate the law, including evidence that: he 

attended seminars sponsored by groups that claimed that the tax code was invalid; he 

attended presentations by attorneys wherein the attorneys expressed their opinion that the 

tax code was invalid; he possessed a letter written by one of those attorneys for the seminar 

attendees that expressed the view that taxing a person’s salary was incompatible with the 

Sixteenth Amendment; and that he relied on all of this information in declining to file or pay 

taxes. See id. at 195-96. Rather than suggest that such evidence should be precluded, the 

Supreme Court not only blessed the admission of this evidence, but indicated that the 

district court’s erroneous instruction on willfulness prejudiced the defendant’s presentation 

of his good faith defense.

Non-privileged attorney opinions or letters are admissible even if the defendant 

does not seek or qualify for an advice-of-counsel jury instruction. For example, in United 

States v. Munoz, 233 F.3d 1117 (9th Cir. 2000), the Ninth Circuit ruled that the denial of an 

advice-of-counsel instruction was proper (where a good faith jury instruction was given). 

However, the Ninth Circuit expressly ruled that the evidence at issue—attorney opinion 

letters drafted by attorneys with whom the defendant never consulted and based on 

inaccurate facts—were admissible and adequately covered under a general good faith 

instruction. See id. at 1131-32; accord United States v. Frame, 236 F. App’x 15, 18-19 (5th Cir. 

2007) (recognizing that evidence of Frame’s good faith and advice-of-counsel defenses were

presented and those theories were “central” to his closing, even though the court declined 

his requested instructions); United States v. Way, 2018 WL 3062159, at *8 (E.D.C.A. 2018) 

(“[T]he court concludes that evidence regarding this [attorney opinion] letter and defendant’s 

awareness of its content are admissible on the question of whether defendant acted with a 

culpable state of mind. Whether defendant is entitled to an advice-of-counsel jury 

instruction will be resolved at the appropriate time during the court of trial”); United States v. 

Case 2:18-cr-00422-DJH Document 1803 Filed 09/21/23 Page 8 of 13
3891320.2 9

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Brandner, 2016 WL 354866, at *2-3 (D. Alaska Jan. 28, 2016) (indicating that defendant was 

allowed to present evidence that he relied on advice of a disbarred attorney to argue good 

faith, even though he was unable to establish the prerequisites for an advice-of-counsel jury 

instruction).

Moreover, attorney advice is admissible even when the court understands the defense 

at issue to be an “implicit or imperfect” advice-of-counsel defense. See United States v. Napoli, 

2011 WL 1302317, at *6 (N.D.C.A. Apr. 5, 2011); cf. United States v. Mieill, 2008 WL 5101313 

at *4 (N.D. Iowa Nov. 25, 2008) (denying government motion to preclude admission of 

evidence of good faith, even if the defendant’s evidence is “laughable” because the jury is the 

entity to decide the weight to be assigned to good faith evidence). Again, Napoli

demonstrates that attorney opinions and letters are admissible regardless of whether the 

defense asks for a formal instruction on advice of counsel. 

For all these reasons, at a minimum, the non-privileged documents drafted by 

attorneys that were known to the Defendants are admissible, including letters to Backpage 

staff authored by Steven Suskin; responsive letters to the National Association of Attorneys 

General and other governmental entities authored by attorneys, memoranda drafted by 

attorneys for third parties; case pleadings drafted and filed by attorneys on behalf of 

Backpage, and amicus briefing by civil rights organizations in support of Backpage’s right to 

exist as a First Amendment protected platform for First Amendment protected speech, 

particularly when the moderation, marketing (in the form of free offers to publish ads on 

Backpage that were published elsewhere), and alleged “notice” evidence concerning 

trafficking and prostitution, was in the public docket of these cases. 

B. Court decisions, statutes, and statements of public officials or entities 

known to the Defendants are admissible.

Information conveyed by a public official and a defendant’s awareness of that 

information is not only admissible as to good faith, but exclusion of such evidence is 

reversible error. See United States v. Certified Envirnmtl. Servs. Inc, 753 F.3d 72, 88-91 (2d Cir. 

2014). In Certified Environmental Servs., the Second Circuit reversed the convictions because 

Case 2:18-cr-00422-DJH Document 1803 Filed 09/21/23 Page 9 of 13
3891320.2 10

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

the district court precluded presentation of three communications between the defendants 

and the New York Department of Labor: a telephone call, and email, and a Department of 

Labor Code Rule. See id. The Second Circuit rejected the claim that such evidence was 

inadmissible hearsay, ruling that “the statements were not hearsay since they were offered, 

not for their truth, but for their effect on defendants’ state of mind, which was very much in 

dispute. Id. at 89. The evidence at issue was highly relevant to “the question of the 

defendants’ intent and good faith.” Id. at 90. Moreover, although these communications did 

not address the specific conduct that allegedly violated the law, the first communication 

“concerned the nature of an ongoing regulatory requirement and, according to the 

defendants, informed the creation of a consistent company policy,” much like the CDA 

informed Backpage’s moderation policy. Id. The communication that postdated the 

conspiracy was admissible as “evidence of the content of a longstanding continuous mental 

process.” Id. at 90.

Notably, the Sixth Circuit has reversed Travel Act convictions when the jury 

instructions precluded consideration of evidence of the defendant’s good faith attempt to 

comply with law. In United States v. Stagman, 446 F.2d 489 (6th Cir. 1971), the defendant 

sought to operate bingo games at a facility located across state lines in Kentucky. See id. at 

490. The defendant’s “only defense is that he believed in good faith, and had reasonable 

grounds for doing so, that the Flamingo bingo game was legal under Kentucky law.” Id. 

The district court permitted the defendant to testify that “the Sheriff, Deputy Sheriff, and an 

assistant Commonwealth’s Attorney . . . advised him that bingo games were legal, if certain 

rules were observed,” and that “he and others associated with the Flamingo operation 

complied with these rules.” Id. On appeal, the Sixth Circuit did not tether its reasoning to 

whether the prerequisites of an advice-of-counsel defense were met. Instead, the Sixth

Circuit reversed the convictions because the district court’s jury instructions “precluded any 

consideration of this defense.” Id. at 492. On retrial, the district court was instructed to not 

only allow this evidence, but with instruction that “the defense of good faith attempts at 

compliance should be submitted to the jury.” Id. at 493. The Court further elaborated that:

Case 2:18-cr-00422-DJH Document 1803 Filed 09/21/23 Page 10 of 13
3891320.2 11

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

[W]hen, as here, a defendant introduces evidence of good faith 

attempts to comply with the law, a court has a clear obligation

to submit the issue of specific intent with explicit instructions to 

the jury. It is then for the jurors to decide whether this 

evidence has raised a reasonable doubt of the defendant’s guilt. 

Our system of justice assumes that jurors can make the kinds of 

judgements required here and can determine whether a 

defendant’s asserted belief in the legality of his conduct is 

implausible.

Id. (emphasis added).

Similarly, evidence that a defendant was aware of and relied on information found in 

a publicly available government document is admissible as evidence in support of a good 

faith theory of defense. See United States v. Caro, 454 F. App’x 817, 872-74 (11th Cir. 2012) 

(expressing approval for district court’s use of model jury instruction on good faith made on 

the basis of defendant’s presentation of review of a FINCEN advisory opinion regarding 

reporting requirements).

Case law and statutes that a defendant was aware of and relied upon are admissible 

and are relevant to a defendant’s state of mind in connection with specific intent crimes like 

the Travel Act. See United States v. Powell, 955 F.2d 1206, 1213-14 (9th Cir. 1991) (recognizing 

that case law and statutes known to and relied upon by a defendant are admissible and 

relevant to the defendant’s state of mind and to the jury’s assessment of the sincerity of 

those views).

For all these reasons, statements from government actors concerning the operation 

of websites, and Backpage in particular—whether it be testimony, judicial decisions, case 

pleadings filed on public dockets, or public announcements—and Defendants’ awareness of 

those statements are admissible as evidence of good faith, lack of criminal intent, and state 

of mind as a matter of law.

V. Conclusion

For all these reasons, Defendants respectfully request that this Court grant the relief 

requested herein and deny the government’s objections.

Case 2:18-cr-00422-DJH Document 1803 Filed 09/21/23 Page 11 of 13
3891320.2 12

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

RESPECTFULLY SUBMITTED this 21st day of September, 2023, 

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

Pursuant to the District’s Electronic Case Filing Administrative Policies and Procedures Manual (Jan. 

2020) § II (C) (3), Paul J. Cambria hereby attests that all other signatories listed, and on whose behalf this 

filing is submitted, concur in the filing’s content and have authorized its filing.

Gary S. Lincenberg

Gopi K. Panchapakesan

BIRD, MARELLA, BOXER, WOLPERT, NESSIM,

DROOKS, LINCENBERG & RHOW, P.C.

By: /s/ Gary Lincenberg

Gary Lincenberg

Attorneys for John Brunst

Eric W. Kessler

KESSLER LAW OFFICE

By: /s/ Eric W. Kessler

Eric W. Kessler

Attorneys for Scott Spear

Bruce Feder

FEDER LAW OFFICE, P.A.

By: /s/ Bruce Feder

Bruce Feder

Attorneys for Scott Spear

David Eisenberg

DAVID EISENBERG, P.L.C.

By: /s/ David Eisenberg

David Eisenberg

Attorneys for Andrew Padilla

Case 2:18-cr-00422-DJH Document 1803 Filed 09/21/23 Page 12 of 13
3891320.2 13

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Joy Bertrand

JOY BERTRAND, ESQ.

By: /s/ Joy Bertrand

Joy Bertrand

Attorneys for Joye Vaught

On September 21, 2023, 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 to the CM/ECF registrants who have 

entered their appearance as counsel of record

Case 2:18-cr-00422-DJH Document 1803 Filed 09/21/23 Page 13 of 13