Exhibit 3 – Part B

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 1 of 77
Case 2:18-mj-02872-DUTY ; SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 76 of 

Case 2:18-mj-02031-DU-1 SEALE~ 36ocfcflHih~t f P£)EALED Filed 08/07/18 Page 3 of 

121 Page ID #:327 

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

attended the University of Southern California in Los Angeles, 

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

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

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

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

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

enforcement officer with the U. S . Immigration and Naturalization 

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

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

smuggling and international sex trafficking . 

3 . I am familiar with the facts and circumstances 

described herein . This affidavit is based upon my personal 

involvement in this investigation, my training and experience , 

and information obtained from various law enforcement personnel 

and witnesses, including information that has been reported to 

me either directly or indirectly . This affidavit does not 

purport to set forth my complete knowledge or understanding of 

the facts related to this investigation . Unless specifically 

indicated otherwise , all conversations and statements described 

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

figures, times, and calculations set forth herein are 

approximate. 

- 2 -

ATTACHMENT B 

DOJ-BP-0004 719160 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 2 of 77
Case 2:18-mj-02872-DUTY *.SEALED* Document 3-1 *SEALED* 

. ~36 Paae ID #·501 Case 2:18-mJ-02031-DUT'i _;EALED Document 5-1 *SEALEDt 

121 Page ID #:328 

II. SUMMARY AND PURPOSE OF AFFIDAVIT 

Filed 10/31/18 Page 77 of 

.:iled 08/07/18 Page 4 of 

4 . This affidavit is made in support of applications for 

warrants to seize all funds held in certain SUBJECT ACCOUNTS 1 

(identified specifical ly below at paragraph 10) , all owned, 

controlled, or held for the benefit of "Backpage . com" (referred 

to herein as "Backpage" ) , associated entities, and their owners 

and operators . 

A. Background 

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

Federal Bureau of Investigation ("FBI " ) and the Internal Revenue 

Servi ce- Cri minal Investigation (" IRS- CI " ) , with assistance from 

the Los Ange l es Joint Regiona l Intelligence Center . 

6 . The focus of the investigation has been on violations 

by Backpage , its associ ated entities, and their owners and 

operators, of Title 18 , United States Code , Sections 1591(a) , 

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

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

1957 , (Money Laundering) . 

7 . From speaking with other agents in this investigation, 

1 The numbering of the SUBJECT ACCOUNTS picks up from prior 

warrant applications for different accounts, the contents of 

which h ave already been seized or restrained following seizure 

warrants issued in this District . See 18-MJ- 711 ; 18- MJ- 712 ; 18-

MJ- 71 3 ; 18-MJ-715 ; 18 - MJ- 716 ; 18- MJ-178 ; 18-MJ-720 ; 18 - MJ- 721 ; 

18 - MJ- 722 ; 18-MJ-723 ; 18-MJ-724 ; 18 - MJ- 751 ; 18-MJ-752 ; 18-MJ797 ; 18-MJ-798 ; 18- MJ- 996 ; 18 - MJ-1863 ; and 18-MJ- 1864 . 

- 3 -

ATTACHMENT B 

DOJ-BP-0004 719161 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 3 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 78 of 

Case 2:18-mj-02031-DUT; ..;EALE& 36

o cfcflfheeh?!-r 9~EALED' _ .-=iled 08/07/18 Page 5 of 

121 Page ID #:329 

and reviewing emails, internal documents , and other records 

related to this investigation, I know the following : 

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

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

on-line classified advertisements . These advertisements include 

sections dedicated to a variety of matters, including adult , 

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

rentals and services. Backpage receives between 75 million to 

100 mi llion unique internet visitors per month . 

b. Backpage realizes p rofits in the tens of millions 

of dollars per year from adult advertisement . Historically, 

adult ads, where Backpage advertisers post sex trafficking ads , 

constitute less than ten percent of all advertisements posted on 

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

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

revenue and profits from adult service ads, incl uding 

advertising for sex trafficking . 2 

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

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

what they characterized as " adult entertainment ." Backpage ' s 

internal documents suggest that this 90% figure has been 

consistent since its 2004 inception . 

- 4 -

ATTACHMENT B 

DOJ-BP-0004 719162 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 4 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED*_ Filed 10/31/18 Page 79 of ~ . / 

Case 2:18-mj-02031-DUT; _ 3EALE~ 3~cfcmm~h~&i5

~ EALED Filed 08/07/18 Page 6 of 

121 Page ID #:330 

c . In or about 2004, operators Michael Lacey 

(" Lacey"), James Larkin ("Larkin" ) , and Carl Ferrer ("Ferrer") 

created Backpage . There were also two minority owners ; John 

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

(" Spear" ) , who owned 4 . 09 percent . From 2004 until 2015 , Lacey 

and Larkin oversaw the website ' s policies and strategic 

direction . I n 2015 , Lacy and Larkin purportedly sold all or 

substantially all of their interests in Backpage to Ferrer. 3 

However Lacey and La rkin re tained signifi cant control over the 

website , ahd both Lacey and La rkin continue to receive tens of 

mill ions of dollars of annual distributions of Backpage revenue . 

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

the original officers of Backpage , having i nitially served as 

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

CEO of several Backpage related entities in the Netherlands, 

including "Website Technologies," "Amstel Rive r Ho l d i ngs," and 

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

Backpage grossed almost $105 million from adverti sing "adult 

entertainment ." During t his same period, Backpage grossed only 

$1 . 6 million from all other advertisements combined . Assuming 

that Backpage has accurately estimated t hat 90% of its revenues 

are generated from " adult " and "escort" ads , Backpage has 

generated as much as $500 mill ion in prostitution- related 

revenue since 2004 . 

3 From my review of financial records related to Ferrer' s 2015 

agreement to purchase Backpage , it appears that, through a 

series of loans from other Backpage Operators to be repaid by 

Ferrer, Ferrer agreed to purchase Backpage for approximately 

$400 million . 

- 5 -

ATTACHMENT B 

DOJ-BP-0004 719163 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 5 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 80 of 

. 1 136 Paae ID #:504 Case 2:18-mJ-02031-DUTY'- ..,EALED* Docuf'tlent 5-1 *SEALED* iled 08/07/18 Page 7 of 

121 Page ID #:331 

"Ad Tech BV . " 

e . Michael Thomas Gage (" Gage " ) has no formal 

position at Backpage , but is the President, Chief Executive 

Officer, Treasurer, and Secretary of another Backpage controlled 

entity, "Posting Solutions," a wholly owned subsidiary of 

Backpage that receives payments from Backpage advertisers . 

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

Financial Officer of Website Technologies . Based on emails he 

has sent and wire transfer information, Gage appears to control 

much of the international and domestic f i nancial transactions of 

Backpage and its related entities. 

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

and Marketing Director of Backpage . He remains an account 

signatory for Backpage controlled entities, including Website 

Technologies . 

8 . Throughout this affidavit , the individuals identified 

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

this affidavit, are collectively referred to as the "Backpage 

Operators . " 

9. Based on a review of publicly available materials 

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

the Backpage website , I have learned the following : 

a . The majority of the paid advertisements on the 

Backpage website relate to prostitution activities in violation 

- 6 -

ATTACHMENT B 

DOJ-BP-0004 719164 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 6 of 77
Case 2:18-mj-02872-DUTY *~EALED* Document 3-1 *SEALED* Filed 10/31/18 Page 81 of 

( 136 Paqe ID #:505 

Case 2:18-mj-02031-DUT'I _,EALED* Document 5-1 *SEALED*l :iled 08/07/18 Page 8 of 

121 Page ID #:332 

of 18 U. S . C. §§ 1591 and 1952 . 

b . As further described below, Backpage i tself, as 

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

ACCOUNTS (as defined below), is in the business of promoting the 

trafficking of children and adults for sex . Sex trafficking of 

a dults is a violation of 18 U. S . C. § 1952 , and sex trafficking 

of children is a violation of 18 U. S . C. 1591 , each of which 

statutes is a Specified Unlawful activity (" SUA") within t he 

meaning of federal law. (see 18 U. S . C. § 1956(c ) (7) (A), 

identifying as SUA certain " racketeering activity" as defined in 

18 u.s . c . § 1961 (a)) . 

c . The SUBJECT ACCOUNTS are located both i nside and 

outside the United States. The domestic accounts have received 

wire transfers from places outside of t he United States or have 

received funds traceable to wire transfers from p l aces outside 

of the United States, which f unds Backpage has used to promote 

sex trafficking, in violation of 18 U. S . C. § 1956(a) (2) (A) 

(International Money Laundering). Some of the SUBJECT ACCOUNTS 

have received transfers or deposits i n excess of $10 , 000 

traceable to t h e SUA , in violation of 18 U. S . C. § 1 957 (Money 

Laundering Spending Statute) . 

d . Bac kpage, unti l recent ly, controlled numerous 

domain names that have since been seized by the government 

pursuant to a seizure warrant issued i n t h is district i n case 

- 7 -

ATTACHMENT B 

DOJ-BP-0004 719165 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 7 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED~ Filed 10/31/18 Page 82 of 

Case 2:18-mj-02031-DU~. .5EALE& 36odcflAi\h?ti5

PgEALED Filed 08/07/18 Page 9 of 

121 Page ID #:333 

no . CR . Misc . 2 : 18-MJ-00711 . 4 The Seized Domains are registered 

by "ASCIO TECHNOLOG IES INC" OBA " 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 and maintained wi th funds 

traceable to the money laundering sch eme described herein , 

specifically with funds from an account sei zed pursuant to a 

sepa r ate seizure warrant in case no . CR . Misc . 2 : 18-MJ-00721 , 

and the Seized Domains were the mechanism Backpage used to 

promote the prostituti on and sex trafficking activity described 

bel ow . 

B. SUBJECT ACCOUNTS 

10. This affidavit is offered in support of applications 

for warrants to seize all funds and securiti es held in the 

4 On March 28 , 2018 , the Honorab l e Patrick J. Walsh , United 

States Magistrate Judge for the Central District of Cali fornia , 

issued seizure warrants for certain Backpage owned or controlled 

domain names (see 18-MJ-00711). On April 6 , 2018 , pursuant to 

that warrant , Backpage . com was seized and ceased operations . 

Th e domain names seized pursuant to that warrant are referred to 

herein as the "seized domains ." 

- 8 -

ATTACHMENT B 

DOJ-BP-0004 719166 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 8 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* _ Filed 10/31/18 Page 83 of 1 136 Paqe ID #:507 

Case 2:18-mj-02031-DUT , _,EALED* Doculilent 5-1 *SEALED*· .-= iled 08/07/18 Page 10 of 

121 Page ID #:334 

fol l owing U. S. and foreign bank accounts 5 (hereinafter referred 

to collectively as the "SUBJECT ACCOUNTS") : 

a . SUBJECT ACCOUNT 26 : 6 Funds in the amount of 

$2 , 412 , 785 . 47 originating from MidFirst Bank account number 

8061024139 . Thi s account was held in the name of John Becker 

with Michael Lacey as the sole beneficiary . The ac~ount was 

c l osed by the bank and used to purchase an un-negotiated 

cashier' s check #317503 from MoneyGram . 

b . SUBJECT ACCOUNT 27 : Bank of America account 

50033414 in an " Interest on Lawyers Trust Account" ("IOLTA" ) 

held in the name of Davis Wright Tremaine . Based on my 

conversations with Backpage CEO , Carl Ferrer, and Bank of 

America employees , I beli eve that Backpage or Backpage 

5 Pursuant to 1 8 U. S . C. § 981(b) (3) , this Court has authority to 

issue a seizure order for foreign accounts ("Notwithstanding the 

provisions of Rule 4l(a) of the Federal Rules of Criminal 

Procedure , a seizure warrant may be issued . .. in any district 

i n which a forfeiture action may be filed ... and may be · 

transmitted to the central authority of any foreign state for 

service with any treaty or other i nternational agreement " ) . 

6 Previously, on July 19 , 2018 , the Honorable Rozella Oliver, 

United States Magistrate Judge for the Central District of 

California , issued a seizure wa r rant to MidFirst Bank (see MJ1864) . However, upon service of the warrant on MidFirst Bank , I 

learned that Midfirst Bank contracted with a third party for the 

purchase of a cashier' s check, and the funds have been 

transferred to a n account with MoneyGram . Upon learning of the 

prior seizure warrant for these funds served upon MidFirst Bank, 

MoneyGram has stopped payment on the check in anticipation of a 

seizure warrant related to these f unds and directed to MoneyGram . 

- 9 -

ATTACHMENT B 

DOJ-BP-0004 719167 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 9 of 77
Case 2:18-mj-02872-DUTY *~EALED* Document 3-1 *SEALED* _ Filed 10/31/18 Page 84 of 

. ' 136 Paqe ID #:508 , . Case 2:18-mJ-02031-DUTY. _,EALED* Docuri1ent 5-1 *SEALED*' . -1led 08/07/18 Page 11 of 

121 Page ID #:335 

controlled entities are the beneficiaries of this account . As 

further described and traced in this affidavit, $8,778,802.96 of 

funds from this account are criminally derived proceeds from 

Backpage . From my conversations with bank employees, I 

understand that, as of the date of this affidavit, SUBJECT 

ACCOUNT 27 currently holds approximately $3 million or $4 

million in funds, which is less than the approximately 

$8 , 778 , 802 . 96 in funds that have been traced to the alleged 

criminal activity. 

III. APPLICABLE LAW 

11 . There is probable cause to believe that funds and/or 

securities on deposit in the SUBJECT ACCOUNTS are subject to 

seizure and forfeiture by the Uni ted States under the following 

provisions : 

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

and/or securities are involved in, and traceable to, one or more 

t ransactions or attempted transactions in violation of 18 U. S . C. 

§ 1956(h) (Conspiracy to Launder Money), 18 U. S . C. § 1956(a) (2) 

(International Money Laundering for Promotion), and 18 U. S . C. § 

1957 (Financial Transactions Involving Illicit Proceeds). 

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

transaction, or attempted transaction, in violation of 18 U. S . C. 

§§ 1956 or 1957, or any property traceable to such property, is 

subject to forfeiture to the United States; and 

- 10 -

ATTACHMENT B 

DOJ-BP-0004 719168 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 10 of 77
Case 2:18-mj-02872-DUTY : sEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 85 of 

Case 2:18-mj-02031-DUT\ .SEALEot

3

t of u~~riPs:f'/l~tALED1 Filed 08/07/18 Page 12 of 

121 Page ID #:336 

b . 18 U. S . C. § 981 (a) (1) (C) , because the funds 

and/or securities constitute and are derived from proceeds 

traceable to one or more violations of 18 U. S . C. § 1956(h) , 18 

U. S . C. § 1956(a) (2) , and 1 8 U. S . C. § 1957 . 

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

financial transactions involving the proceeds of SUAs 

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

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

knowing the transaction i s designed to conceal the source , 

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

the transaction is designed to avoid anti- laundering financial 

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

more parties agreeing to accomplish the unlawful purpose of 

money laundering . 

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

knowingly engaging in a monetary transaction in excess of 

$1-0 , 000 with property that is criminally derived from some SUA . 

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

Laundering for Promotion) makes it a crime to transport, 

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

transfer, monetary instruments or funds (including funds that 

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

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

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

- 11 -

ATTACHMENT B 

DOJ-BP-0004 719169 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 11 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* .. Filed 10/31/18 Page 86 of 

. 136 Paqe ID #:510 

Case 2:18-mJ-02031-DUTY ..,EALED* Document 5-1 *SEALED*· . . -iled 08/07/18 Page 13 of 

121 Page ID #:337 

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

1956 (cl (7) . 

15 . The "Trave l Act ," 18 U.S . C. § 1952(a) , an SUA, 

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

interstate or foreign commerce with the intent to otherwise 

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

promotion, management , establishment, or carrying on of any 

unlawful activity, by any person who thereafter performs or 

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

on , or facilitate the promotion, management , establishment and 

carrying on of such unlawful activity . " Unlawful Activity," as 

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

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

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

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

Cal . Penal Code§ 647(b) . ) 

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

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

SUA . 

IV. DIGITAL CURRENCY/BITCOIN 

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

generally defined as an electronic- sourced unit of value that 

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

created and regulated by a sovereign government) . It exists 

- 12 -

ATTACHMENT B 

DOJ-BP-0004 719170 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 12 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* _ Filed 10/31/18 Page 87 of 

136 Paqe ID #:511 . Case 2:18-mj-02031-DUTY' ,.,EALED* Document 5-1 *SEALED*• . ·lled 08/07/18 Page 14 of 

121 Page ID #:338 

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

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

instead generated and controlled through computer software 

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

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

legitimate financial transactions. However, it is often used to 

conduct illegal transactions, such as the sale of controlled 

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

promote prostitution . 

18 . Bitcoin is a type of digital currency accepted by 

Backpage . Bitcoin payments are recorded on a public ledger that 

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

maintained by a single administrator or entity . Individuals can 

acquire Bitcoins either by "mining" them or purchasing Bitcoins 

from other individuals . An individual can "mine" Bitcoins by 

a l lowing his/her computing power to verify and record the 

Bitcoin payments into a public ledger . Individuals are rewarded 

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

bought and sold in fractions . 

19 . Backpage also accepts other digital currencies, 

including Litecoin, Bitcoin Cash , and Ether . Sometimes called 

"alt-coins," because they are alternatives to Bitcoins, these 

digital currencies were created after Bitcoin to address 

perceived weaknesses or problems with Bitcoin technology . Based 

- 13 -

ATTACHMENT B 

DOJ-BP-0004 719171 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 13 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* _ Filed 10/31/18 Page 88 of 

136 Paqe ID #:512 

Case 2:18-mj-02031-DUT ...1EALED* Document 5-1 *SEALED*· .~iled 08/07/18 Page 15 of 

121 Page ID #:339 

on my review of Backpage transactions, the majority of 

Backpage ' s digital currency transactions are in Bitcoin . 

20 . An individual can send a n d receive Bitcoi ns through 

peer-to-peer digital transactions or by u sing a third-party 

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

including laptop computers and smart phones . 

21 . Digital currency is generally stored in digital 

" wallets," which essentially store the access codes that all ows 

individual s to conduct d i gital currency tran sacti ons on the 

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

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

private address (or " private key" ) . The public address can be 

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

like a password used to access an online account. 

22 . Even though the public addresses of those engaging i n 

Bitcoi n transactions are recorded on the publi c ledger, t he tru e 

i dentities of t h e i ndividual s or entities behind the public 

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

linked to a public address, it would be possible to determi ne 

what tran sactions were conducted by that individual or entity . 

For these reasons, digi tal currency transactions are described 

as "pseudonymous ," meaning they are partially a n onymous . 

- 14 -

ATTACHMENT B 

DOJ-BP-0004 719172 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 14 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* _ Filed 10/31/18 Page 89 of 

136 Paqe ID #:513 

Case 2:18-mj-02031-DUT'-/ .JEALED* Document 5-1 *SEALED"' .-=iled 08/07/18 Page 16 of 

121 Page ID #:340 

V. STATEMENT OF PROBABLE CAUSE 

C. Buying a Backpage Ad 

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

as an advertising purchaser, engaged in the regular process of 

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

the places on Backpage.com where prostitution ads are commonly 

found . Through this process, I learned the following : 

a . A person looking to post an advertisement on 

Backpage (an " advertiser") must first create an account . Once 

an account is created, the adverti ser clicks on a link called 

"Post an ad ," which will then toggle certain categories 

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

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

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

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

opting to post in mo re than one geographical area , or opting to 

post more frequently occurring ads will increase the 

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

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

ad. 

b . Once an advertiser selects the desired options, 

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

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

- 15 -

ATTACHMENT B 

DOJ-BP-0004 719173 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 15 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED~ Filed 10/31/18 Page 90 of 

Case 2:18-mj-02031-DUTY ... EALEot

3

t of~~riPs~i q_h\ALED>I . ,-=iled 08/07/18 Page 17 of 

121 Page ID #:341 

Backpage website claims to verify the advertiser' s phone number 

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

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

must first buy "credits." Backpage offers several ways for an 

advertiser to acquire credits: 

i . A Backpage advertiser may mail gift cards, 

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

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

associated with Posting Solutions and Seized Account 1) . 7 

ii . Backpage directly accepts credit card 

payment through a third-party credit card payment processor . 

iii . Backpage also accepts several types of 

digital currency (specifically, Backpage accepts Bitcoin, 

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

selects this option , Backpage provides a digital currency wallet 

address where the advertiser can send t he electronic transfer of 

the digital currency . 

7 I have reviewed the cash purchase of USPS money orders 

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

and June 2016 , several mill ions of dollars in money orders were 

p urchased in what appears to have been structured transactions 

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

certain reporting requirements that USPS maintains for money 

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

hundreds of these money orders include email addresses with 

words consistent with prostitution, such as " sex" or " sexy." 

- 16 -

ATTACHMENT B 

DOJ-BP-0004 71917 4 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 16 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 91 of 

l 136 Page ID #:515 / 

Case 2:18-mj-02031-DUTY *SEALED* Document 5-1 *SEALED" riled 08/07/18 Page 18 of 

121 Page ID #:342 

iv . Backpage also accepts cash, but only through 

third party payment processors . Based on information gathered 

during this investigation, I believe that once t he thi rd- party 

payment processor receives cash, it converts the cash into 

digital currency and then electronically transfers that digital 

currency to a Backpage digital currency wallet . 

24. Digi tal Currency is processed through the subject 

accounts in the fo l lowing way : 

a . When Backpage receives digital currency , it will 

aggregate the digital currency and t hen transfer it to a thirdparty exchanger l ike GoCoin . 8 

b. In exchange for the digital currency, the exchanger 

transfers U. S . doll ars from its foreign bank accounts into 

Backpage operating accounts, such as Seized Account 1. The 

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

Bitcoin marke ts. 

25 . I reviewed records obtained from GoCoin . From this 

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

on Backpage.com a re ads within the Central District of California 

8 GoCoin is a digital currency exchanger that converts Bitcoin, 

Litecoin and another digital currency into fiat currency, like 

the U. S . Dol lar or the Euro . GoCoin is owned by Manx 

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

offices in Singapore and Santa Monica , California and appears to 

hold bank accounts i n several countries outside the United 

States. 

- 17 -

ATTACHMENT B 

DOJ-BP-0004 71917 5 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 17 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* _ Filed 10/31/18 Page 92 of 

136 Paqe ID #:516 

Case 2:18-mj-02031-DUTY *SEALED* Document 5-1 *SEALED* . ·iled 08/07/18 Page 19 of 

121 Page ID #:343 

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

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

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

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

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

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

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

SanGabrielValley .Backpage . com . These specific ads generated 

approximately $184 , 479 in revenue . 

D. Backpage Promotion of Prostitution and Sex Trafficking 

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

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

have also reviewed the criminal records of certain of the pimps 

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

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

the following : 

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

girl, for sex . The pimp advertised S . F . on Backpage ' s "Escort" 

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

ad contained phrases such as " New In Town" and "Sexy Dark Asian 

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

Backpage included multipl e pictures showing her legs, stomach, 

shoulders and buttocks. Later, the pimp was arrested and 

convicted on state sex trafficking charges, and sentenced to 196 

- 18 -

ATTACHMENT B 

DOJ-BP-0004 719176 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 18 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 93 of 

\ 136 Paqe ID #:517 

Case 2:18-mj-02031-DUTY *SEALED* Document 5-1 *SEALED'// r iled 08/07/18 Page 20 of 

121 Page ID #:344 

years imprisonment. 

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

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

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

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

like fire ." The Backpage ad selling A. C. incl uded pictures of her 

showing her legs, stomach, shoulder, and bu ttocks, and posed her 

in sexually provocative positions. 

c . Between November 2015 and December 20 15 , in a 

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

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

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

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

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

The ads the girls posted included pictures of them sitting on the 

bed showing t heir but tocks . Another image I saw was of a naked 

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

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

mirror. However, these ads used phrases like "I'm sweet as a 

treat maybe even sweeter" and "not a lot need to be said. my pie 

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

trafficking charges and a federal court sentenced him to 300 

months i n prison. 

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

- 19 -

ATTACHMENT B 

DOJ-BP-0004 719177 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 19 of 77
Case 2:18-mj-02872-DUTY ,*SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 94 of 

I 136 Page ID #:518 

Case 2:18-mj-02031-DUTY *SEALED* Document 5-1 *SEALED* riled 08/07/18 Page 21 of 

121 Page ID #:345 

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

pimp draft ed the ads that were placed on Backpage ad containing 

words and phrases such as , "W' E' L' L_W' O' R'T' H_I ' T***/\***150HR" and 

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

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

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

over 26 years imprisonment on charges related to sex trafficking . 

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

victim, 0.0., who was between the ages of 1 4 and 19 during those 

years, was sold for sex through Backpage ads . D. O.' s fema le pimp 

instructed 0 . 0 . that Backpage was the safest place to advertise 

because Backpage did not require age verification . 0 . 0 .'s 

Backpage ads included words and phrases that were indicative of 

prostitution, such as "roses " (mone y) and " back door " (anal sex). 

Some of the customers who responded to 0 . 0 .' s Backpage ads forced 

0.0 . to perform sexual acts at gunpoi nt, choked her to t h e point 

- 20 -

ATTACHMENT B 

DOJ-BP-0004 719178 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 20 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 95 of 

\ 136 Paqe ID #:519 , Case 2:18-mj-02031-DUTY *SEALED* Document 5-1 *SEALED* riled 08/07/18 Page 22 of 

121 Page ID #:346 

of having seizures, and gang-raped her . 9 

27 . I have reviewed documents and reports from multiple 

state and government agencies and authorities regarding Backpage ' s 

promotion of sex trafficking and prostitution . From these 

reports, and from my review of internal Backpage correspondence 

foll owing Backpage management receiving these reports, I am aware 

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

role in promoting _ criminal activity . For example : 

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

general wrote a letter to Backpage observing that " ads for 

prostitution-including ads traffickin g children-are rampant on t he 

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

adequately screen these ads, it should stop accepting them 

9 Using these examples, I also reviewed financial transactions 

for some of these ads. Using email addresses and other 

identifi ers associated with the Backpage ads , I reviewed GoCoin 

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

found bitcoin payments associated with the email addresses used 

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

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

(described in paragraphs 26(a) and (b)) prosecuted in Ari zona , 

the bitcoin payments for these ads were made in November and 

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

(described in paragraph 26(c)) prosecuted in Missouri, the 

bitcoin payments were made in October and November 2015 . As 

described in paragraph 45 of this affidavit, between December 

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

totaling over $16 . 8 million was sent to a Website Technologies 

account at Branch Bank & Trust Company account number 

1440001712008 . Between December 2015 and October 2016 , 32 wires 

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

Properties Account 9361116211 at Arizona Bank and Trust , which 

made its way into 11 accounts named in prior seizure warrants . 

- 21 -

ATTACHMENT B 

DOJ-BP-0004 719179 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 21 of 77
Case 2:18-mj-02872-DUTY 1SEALED* Document 3-1 *SEALED* _ Filed 10/31/18 Page 96 of 

136 Paqe ID #:520 ' . Case 2:18-mj-02031-DUTY *SEALED* Document 5-1 *SEALED*' . -1led 08/07/18 Page 23 of 

121 Page ID #:347 

altogether." The state AGs acknowledged that this step would 

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

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

just ify the scourge of illegal prostitution, and the misery of the. 

women and children who will continue to be victimized in the 

marketplace provided by backpage ." 

b . Following t h is letter, on September 25 , 2010 , 

Ferrer wrote an email explaining that Backpage was unwilling to 

delete ads that included terms indicative of prostitution because 

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

elsewhere" and force Backpage to refund those customers' fees . 

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

Permanent Investigations (" Subcommittee" } conducted a lengthy 

investigati on into sex trafficking and Backpage . I have reviewed 

the Subcommittee ' s 50- page report entitled "Backpage . com' s Knowing 

Facil i t ation of Online Sex Trafficking ." This report concluded, 

among other things, that virtuall y all of Backpage ' s " adult " ads 

are actually soli citations for illegal prostitution services and 

that "Backpage has maintained a practice of altering ads before 

publication by deleting words, phrases, and images indicative of 

criminality, including child sex trafficking ... Those 

practices served to sanitize the content of innumerable 

advertisements for illegal transactions-even as Backpage 

represented to the public and the courts that it merely hosted 

- 22 -

ATTACHMENT B 

DOJ-BP-0004 719180 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 22 of 77
Case 2:18-mj-02872-DUTY ,*SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 97 of 

. 1 136 Paqe ID #:~21 r Case 2:18-mJ-02031-DUTY *SEALED* Document 5-1 SEALED* .~i led 08/07/18 Page 24 of 

121 Page ID #:348 

content others had created ." In response to the Subcommittee ' s 

report , Backpage purpor ted to shut down the " adult " section of its 

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

Backpage ads, I believe that the prostitution ads simply migrated 

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

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

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

identified an a larming number of juvenile prostitutes advertised 

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

was dissimilar from other companies whose products and services 

are " occasionally or incidentally" utilized by criminals because 

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

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

recommended that Backpage require in-person age verification for 

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

gained through this i nvestigation, I do not believe that Backpage 

has ever instituted an in- person age verification . 

28 . I have reviewed internal documents, emails, and 

correspondence among Backpage employees and management . From 

those emails I have learned that Backpage has instituted policies 

and procedures designed to main tain its promoti on of sex 

trafficking and prostitution, but which " sanitize" some of the 

language Backpage customers use to advertise in order to make the 

advertising of sex trafficking less overt . From my review of 

- 23 -

ATTACHMENT B 

DOJ-BP-0004 719181 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 23 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 98 of 

. I 136 Paae ID #:522 - Case 2:18-mJ-02031-DUTY "SEALED* Document 5-1 *SEALED* .-=iled 08/07/18 Page 25 of 

121 Page ID #:349 

Backpage documents, I know that Backpage refers to this practice 

as "moderation ." For example : 

a . In April 2008 , Ferrer wrote an email explaining 

that , although he was " under pressure to clean up phoenix ' s adult 

content ," he was unwilling to delete prostitution ads because 

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

craig[slist] " 10 and result in " lost pagevi ews and revenue ." Thus, 

Ferrer instructed Backpage ' s technical staff to edit the wording 

of such ads by removing particular terms that were indicative of 

prostitution, and then allow the rema i nder of the ad to be 

featured on Backpage ' s website . 

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

email threatening to fire any Backpage emp l oyee who acknowledged, 

in writing, that a customer was advertising prostitution : 

"Leaving notes on our site that imply that we ' re aware of 

prostitution, or in any positi on to define it, is enough to lose 

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

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

job . 11 

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

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

1° Craigslist is a competing internet based advertising company 

that features classified ads . 

- 24 -

ATTACHMENT B 

DOJ-BP-0004 719182 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 24 of 77
Case 2:18-mj-02872-DUTY :"SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 99 of 

. 1 136 Paqe ID #:523 ~ Case 2:18-mJ-02031-DUTY "'SEALED* Document 5-1 *SEALED • ,-= iled 08/07/18 Page 26 of 

121 Page ID #:350 

contained two attachments providing guidance on how to "moderate " 

ads . The first was a PowerPoint presentation that displayed a 

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

depicted graphic sex acts . Next to each picture was an 

instruction as to whether it should be approved or disapproved by 

a Backpage moderator. These instructions included "Approve . Nude 

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

genitalia ." and "Approve. Rear shot okay . Transparent wet 

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

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

be "stripped" from ads before publication . The Backpage manager 

concluded the email by stating , "[I]t' s the language in ads that's 

really killing us with the Attorneys General . Images are almost 

an afterthought to them." 

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

a separate internal email explaining, "I'd like to still avoid 

Deleting ads when possible ," that "we're still allowing phrases 

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

editing should be sufficient ." 

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

acknowledging that the " [i]llegal content removed" through 

Backpage ' s moderation processes was " usually money for sex act." 

This email also explained that, after the "sex act pies are 

removed ," the " ad text may stay ." 

- 25 -

ATTACHMENT B 

DOJ-BP-0004 719183 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 25 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED*,,. Filed 10/31/18 Page 100 of 

Case 2:18-mj-02031-DUT~ "'SEALEoi 3i otlf"M~rlPs~t l ~i:ALED" riled 08/07/18 Page 27 of 

121 Page ID #:351 

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

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

80% " of the ads it received from c u stomers . 

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

law enforcement official about a particular ad that included the 

term " amber alert ." In response, Ferrer acknowledged this might 

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

Ferrer then forwarded this exchange to a Backpage manager and 

instru cted that the term " amber alert" be added to Backpage ' s 

" strip out " l ist . I believe that this email indicates that 

Backpage did not require all future ads i nvolving this particular 

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

Backpage , but merely requi red that such ads be edited before 

publication . 

h . On August 31 , 2011 , Backpage managers exchanged 

emails in which they discu ssed a list of 1 00 " soli d sex for money 

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

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

that Backpage ma n agement and employees too closely identified with 

the obvious promotion of sex trafficking and prostitution. 

i . Based on knowledge gained during this investigation 

and my training and experience , I believe that this manager 

acknowledged that a large proportion of the ads originally 

submitted by Backpage ' s customers contained text and pictu res that 

- 26 -

ATTACHMENT B 

DOJ-BP-0004 719184 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 26 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* I 136 Paqe ID #:525 

Case 2:18-mj-02031-DUTY *SEALED* Document 5-1 *SEALED* 

121 Page ID #:352 

Filed 10/31/18 Page 101 of 

,led 08/07/18 Page 28 of 

were indicative of sex trafficking . Nevertheless, Backpage would 

still publish those ads after editing them to appear less obvious 

in promoting illegal activity . Using the words the Backpage 

manager used in the email described in paragraph 28(d) above , I 

believe that Backpage sex trafficking ads have adapted to 

Backpage ' s moderation policy by using "phrases with nuance" when 

promoting sex trafficking . Al so , based on knowl edge ga i ned during 

this investigation, and my training and experience , I believe 

that, following the implementation of "moderation ," Backpage ' s 

l ist of prohibited terms needed to change and evolve to adjust to 

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

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

previously associated with sex- for-money would become too fami liar 

and associated with certain sex traff icking activities in the 

Backpage community of advertisers, Backpage's "moderation" policy 

would need to a dapt by adding such words or phrases to the \ 

" blocked" list or risk being too obvious in its promotion . 

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

internal Backpage document s and correspondence , I believe that 

Backpage ' s policy of "moderation" only cau sed ads explicitly 

promoting sex trafficki ng to become more coded and implicit in t he 

ads' purpose . I have reviewed several thousand Backpage ads 

posted in the various " adult " categories of Backpage (incl uding 

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

- 27 -

ATTACHMENT B 

DOJ-BP-0004 719185 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 27 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 102 of 

. l 1-36 Paae ID #:526 Case 2:18-mJ-02031-DUTY *SEALED Document 5-1 *SEALED*' ,-iled 08/07/18 Page 29 of 

121 Page ID #:353 

learned the following : 

a . Well over half of the Backpage classified ads in 

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

experience, I believe to be consistent with sex trafficking and 

prostitution . These terms and phrases include , "roses " (money , 

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

to the prostitute ' s location) , " outcall " (where the prostitute 

goes to the customer' s location) , "GFE" (girlfriend experience) , 

and "PSE" (porn star experience) . 

b . Other Backpage ads use language that can be mostly 

free of coded language , but that include sexually provocative 

pictures . In my training and experience , the sexually suggestive 

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

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

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

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

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

sexual positions wearing lingerie and pictures of a woman bending 

over revealing her naked buttocks . 

c . Based on knowledge gained through this 

investigation, and my training and experience , I believe that 

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

Moderation has caused and allowed otherwise neutral or innocuous 

terms to be understood within the Backpage community as coded 

- 28 -

ATTACHMENT B 

DOJ-BP-0004 719186 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 28 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 103 of 

Case 2:18-mj-02031-DUT~ *SEALEol

3

fbo~S-~~riPs~i

5

*r EALED*· >iled 08/07/18 Page 30 of 

121 Page ID #:354 

language for sex trafficking and prostitution . Because of this 

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

with the particular vocabulary used in Backpage " adult" ads may 

readily identify coded terms and images indicating an ad for 

prostitution, while an uninitiated reader may not understand these 

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

30 . Notwithstanding many Backpage advertisements' use of 

seemingly innocuous language in promoting prostitution, based on 

my conversations with law enforcement officers around the country 

and from my review of law enforcement officers' statements and 

reports regarding Backpage , I believe tha t the majority of 

Backpage ads that appear in the traditional ly "adult " categories 

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

advertisements promoting sex trafficking or prostitution . For 

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

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

Trafficking Task Force made a sworn statement t ha t provided, in 

pertinent part , 

Since 2014 , the Seattle Police Department has made arrests 

t hat include hundreds of re lated charges, such as charges 

for patronizing a prostitute/sexual exploitation, hundreds 

of charges for prostitution, dozens of charges [of] 

Promoting Prostitution, up to 100 charges for Commercial 

Sexual Abuse against a Minor and have investigated dozens 

of rape reports involving victims who are p rostitutes and 

one mu rder of a prost itute . As a result of hundreds of 

investigations, the Seattle Police Department Vice/High 

- 29 -

ATTACHMENT B 

DOJ-BP-0004 719187 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 29 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 104 of 

l 136 Paqe ID #:528 

Case 2:18-mj-02031-DUTY ... SEALED* Document 5-1 *SEALED*' . ·i led 08/07/18 Page 31 of 

121 Page ID #:355 

Risk Victims Unit has found that Backpage . com has become 

the primary web site in Seattle/Washington State for those 

looking to solicit a prostitute, post prostitution ads or 

traffic prostitutes and minors . 

Vice/High Risk Victims Unit Detectives also make use of 

this site to respond to ads posted under the ' escorts' and 

' body rubs' categori es posing as male customers and 

successfully arrest females and males who charge 

undercover operatives money in exchange for sex . To date , 

no Detective within the Seattle Police Department ' s 

Vice/High Risk Victims Unit has ever found a legitimate 

' escort', (person who charges simply for companionship 

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

legitimate and licensed massage therapy rather than sex) 

while responding to ads placed in these categories on 

Backpage.com. 

As s tated previously, every time the Seattle Police 

Department Vice/High Risk Victims Unit has responded to an 

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

that the ad was a posting for i llegal activity . The 

Seattle Police Department Vice/High Risk Victims Unit has 

not once found that the individual posting or responding 

to one of our decoy ads in t he adult section of 

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

legal activity . In my professional experience , t he adult 

section of Backpage . com not only contains ads for illegal 

activity, including prostitution, solicitation and 

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

is well known for that purpose in the sex trafficking 

industry in the city of Seattle and State of Washington . 

Additionally, in August 2015 , the Sergeant Detective who is 

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

Massachusetts Police Department made a sworn statement that 

provided, in pertinent part, 

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

include enticement of a minor into prostitution, sex 

trafficking of a minor, sex trafficking of an adult , 

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

prostitute . 

- 30 -

ATTACHMENT B 

DOJ-BP-0004 719188 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 30 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 105 of 

Case 2:18-mj-02031-DUTY\ "~EALEo*

3

i or uartl~riPs~i ~§1:ALED*' ·iled 08/07/18 Page 32 of 

121 Page ID #:356 

As a result of investigations, the HTU has found that 

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

looking to solicit a prostitute , post prostitution ads, 

and recruit and traffic young women and minors . The 

detectives have been able to identify numerous would- be 

exploiters by setting up decoy ads and responding to ads 

on the site . The have arrested pimps , traffickers and 

buyers who facilitate prostitution and fuel the harmful 

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

site that detectives go to in order to look for underage 

girls who are on the run and are being commercially 

sexually exploited by pimps . 

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

both adults and minors through Backpage . com ads 

exclusively in hotel stings. 

Since 2013, 12 indivi duals have been charged in federa l 

court for sex trafficking of both minors and adults . In 

all these aforementioned cases, Backpage . corn played a 

pivotal role in facilitating these crimes . 

Detectives of the HTU often get tips about illegal 

activity concerning ads posted on the escort, adult and 

massage sections of Backpage . com . In almost every case 

detectives have found that in fact there was illegal 

activity which resulted in fines , arrests, or further 

investigations of sex trafficking . 

Therefore , in my professional experience as a law 

enforcement officer for over thi rty years, the adult 

section of Backpage . com not only contains ads for illegal 

activity, including prostitution, solicitation and 

trafficking, but it is also the primary source for such 

ads and well known for that purpose i n the sex trafficking 

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

section provides a vehicle and anonymity for its users who 

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

humble opinion that the adult section of Backpage . com 

serves no legitimate service and nearly all the cases we 

find associated with it involve pimp controlled 

prostitution . 

31 . Almost all "adult " -type Backpage ads list phone numbers 

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

- 31 -

ATTACHMENT B 

DOJ-BP-0004 719189 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 31 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 106 of 

136 Page ID #:530 

Case 2:18-mj-02031-DUTY *SEALED* Document 5-1 *SEALED* .-iled 08/07/18 Page 33 of 

121 Page ID #:357 

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

found within Backpage ads with phone numbers and emails that 

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

that Backpage advertisers u se to pay Backpage for those ads . From 

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

email appears in multiple Backpage ads as the contact information 

to ma ke an appointment . For example : 

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

in Duarte , Ca l ifornia , made payabl e to " Posting Solutions PO BOX 

802426 , Dallas, TX ," and thereafter deposited into a Seized 

Account, included writing on t he mon ey order l isting a phone 

number and the words " Dulce Latina ." From a search of Backpage 

ads, I found almost 800 advertisements listing the same phone 

number found on t he $25 USPS Money Order. 

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

Californ ia , a n d later deposi ted int o a Seized Account , incl uded 

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

a search of Backpage ads, I found almost 1300 advertisements 

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

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

Arizon a , and made payable to " Posting Solutions," incl uded an 

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

t h e email address l i sted on this $150 money order, I found 

advertisements on several female escort websites that directed 

- 32 -

ATTACHMENT B 

DOJ-BP-0004 719190 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 32 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 107 of 

. t 136 Paae ID #:531 Case 2:18-mJ-02031-DUTY "~EALED* Document 5-1 *SEALED* ·iled 08/07/18 Page 34 of 

121 Page ID #:358 

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

then searched Backpage . com records for this phone number and found 

approximately 760 ads that included this same phone number . My 

review of these Backpage ads revealed images indicative of 

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

"massage" section included sexual images such as a woman lying on 

a bed wearing lingerie and a woman laying naked on h er stomach . I 

One of the ads describes, " Pampering provider I Body Rub Massage 

Body Shampoo I Body Scrub I 4 h ands I Walk ins or appo i ntment ." 

From my training and experience , I know that legal massage 

advertisements do not typically depict sexual images . This 

advertisement depicted sexual images and included terms like " 4 

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

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

indi cative of prostitution . 

32 . Despite t h e fact that several thousand Backpage ads 

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

advertiser, these same ads included sexually suggestive images of 

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

multiple different women do not share t h e same email address or 

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

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

or prostitution agenc i es that are using t he same phone numbe r or 

email to adverti se several different women (or girls) to 

- 33 -

ATTACHMENT B 

DOJ-BP-0004 719191 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 33 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* 

. ·, 1⁄436 Paqe ID #·532 

Case 2:18-mJ-02031-DUTY "SEALED Document 5-1 *SEALED*' 

121 Page ID #:359 

prospective prostitution clients . 

Filed 10/31/18 Page 108 of 

·iled 08/07/18 Page 35 of . 

33. On March 28 , 2018 , in the District of Arizona , a grand 

jury returned a 93 count indictment charging certain Backpage 

Operators with criminal violations of 18 U. S.C . § 371 

(Conspiracy) , § 1952 (Travel Act-Facilitation of Prostitution) , § 

1956 (Money Laundering) , § 1957 (Financial Transactions Involving 

Illicit Proceeds) , and including Forfeiture Allegations pursuant 

to 18 U. S . C. §§ 981 and 982 (seeking criminal forfeiture of, among 

other assets, the Seized Accounts and the Seized Domains) . A copy 

of that indictment is attached hereto (as Exhibit A) and 

incorporated herein as though fully set forth. 

34 . On July 25 , 2018 , also in the District of Arizona , a 

grand jury returned a 100 count nFirst Superseding Indictment" 

charging certain Backpage Operators with additional criminal 

violations of 18 U.S.C. § 371 (Conspiracy) , § 1952 (Travel ActFac~litation of Prosti tution) , § 1956 (Money Laundering) , § 1957 

(Financial Transactions Involving I llicit Proceeds) , and including 

Forfeiture Allegations p u rsuant to 18 U. S . C. §§ 981 and 982 

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

Accounts and the Seized Domains) . Additionally, the grand jury 

made specific findings of probable cause for forfeitability of all 

the Seized and Restrained Accounts listed in this affidavit . 

Further, the grand jury specifically found probable cause that the 

funds held in SUBJECT ACCOUNT 26 were subject to forfeiture . A 

- 34 -

ATTACHMENT B 

DOJ-BP-0004 719192 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 34 of 77
Case 2:18-mj-02872-DUTY ~SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 109 of 

. \ 136 Paqe ID #:533 Case 2:18-mJ-02031-DUTY "SEALED* Document 5-1 *SEALED*' ·iled 08/07/18 Page 36 of 

121 Page ID #:360 

copy of the ''First Superseding Indictment " is attached hereto (as 

Exhibit B) and i ncorporated herein as though fully set forth . 

E . THE SEIZED ACCOUNTS AND SUBJECT ACCOUNTS 11 

1. Seized Account 1 

i . Foreign Transfers Into SEIZED ACCOUNT 1 

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

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

using cash, money orders, or digital currency . 

36. From my review of Posting Solutions' application for the 

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

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

BOX Application were the names of several Backpage Operators, 

including Ferrer . 

37. I have reviewed bank records for Seized Account 1 . 

Based on my review, I know the following : 

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

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

opened Prosperity Bank account number 216887188 (Seized Account 

11 Because of the extensive movement of money by the Backpage 

operators, it is necessary to include here a discussion both of 

the accounts targeted in the prior warrant applications 

(referred to herein as Seized Accounts 1 through 17 , 22 and 25 ; 

or Restrained Accounts 18 through 21B, 23 and 24) and of the 

SUBJECT ACCOUNTS . 

- 35 -

ATTACHMENT B 

DOJ-BP-0004 719193 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 35 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* _ Filed 10/31/18 Page 110 of 

Case 2:18-mj-02031-DUT~ n.::,EALEot

3

i ofS}R~n

I

f t~~~iALED* ·iled 08/07/18 Page 37 of 

121 Page ID #:361 

' 

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

b . Gage is the President, Chief Executive Officer, 

Treasurer and Secretary of Posting Solutions LLC . 

38 . Based on my knowledge of thi s investigation, having 

spoken to law enforcement personnel , and my review of the 

financial records, when an advertiser purchases an ad for 

prostitution using digita l currency, the payments to Backpage (and 

certain subsequent expenditures) then proceed in the following 

manner : 

a . A " poster" of a prostitution ad on backpage . com 

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

as previously described above . 

b . The poster would already have Bitcoin or Backpage 

would direct t he poster to a third-party exchanger in order to b u y 

Bitcoin . 

c . Backpage would then provide the poster. with a 

wallet address to send the specific amount of Bitcoin . 

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

Backpage . 

e. In batches, generally valued in hundreds .of 

thousands of dollars, Backpage would sel l the Bitcoin to a third 

party exchanger, frequentl y " GoCoin ," in order to convert the 

Bitcoin into U. S . or foreign c u rrency, which GoCo i n general ly 

holds in foreign bank accounts . 

- 36 -

ATTACHMENT B 

DOJ-BP-0004 719194 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 36 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* 

, 136 Paae IR #· q.35 Case 2:18-mj-02031-DUTY ·- ::;EALED Documen 5-1 SEALED*' 

Filed 10/31/18 Page 111 of 

:iled 08/07/18 Page 38 of 

121 Page ID #:362 

f . GoCoin would wire funds from these foreign accounts 

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

controlled domestic operating accounts . 

g . Backpage operators would hold these receiving 

accounts in the names of entiti es controlled by Backpage , such as 

Ad Tech BV , Posting Solutions (Seized Account 1 is held in the 

name of Posting Soluti ons) , Websi te Technologies, or Cereus 

Properties (Seized Account 2A is held in the name of Cereus 

Properties) . 

h . These funds that originated from foreign 

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

Los Angeles, or would be transferred to Backpage Operators' 

accounts and accounts held in their family members' names . 

39 . I have reviewed records of wi re transfers from countries 

outside the United States deposited into the Seized Account 1 . 

Just for the period of Au gust 1 thr ou gh September 1 , 2017 , Sei zed 

Account 1 received over $2 . 7 million in wire transfers from 

outsi de the Uni ted States. For example : 

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

"Binary Tr ading SG PTE LTD" ("Binary Trading" ) wi red $535 , 500 from 

an account in Singapor e i nto Seized Account 1 . Based on my review 

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

- 37 -

ATTACHMENT B 

DOJ-BP-0004 719195 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 37 of 77
Case 2:18-mj-02872-DUTY *~EALED* Document 3-1 *SEALED* Filed 10/31/18 Page 112 of 

~ 136 Paqe ID #:536 

Case 2:18-mj-02031-DUTY *!::iEALED* Document 5-1 *SEALED* '· .led 08/07/18 Page 39 of 

121 Page ID #:363 

used by GoCoin . 12 

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

another $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 Binary 

Trading 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 l ines from these wires list "GC" or 

" GC FOR INTERNET SERVICES ." I understand " GC" to mean GoCoin . 

ii. Seized Account 1 Payments for Backpage Operations 

40 . 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 . 

b . On August 4 , 2017 , Seized Account 1 wired $4 , 137 to 

" Netnames," also known as ASCIO , to pay for the registration 

renewal of all the Seized Domains , including Backpage . com . 

c . In August 2017 , Seized Account 1 sent numerous 

12 Further, accordi ng to GoCoin ' s website , GoCoi n maintains 

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

from " Bi nary Trading ." 

- 38 -

ATTACHMENT B 

DOJ-BP-0004 719196 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 38 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* . Filed 10/31/18 Page 113 of 

Case 2:18-mj-02031-DUT~ ASEALEol

3

Ebor~~riPs~i

5

*¥ EALED"' ,-=i led 08/07/18 Page 40 of 

121 Page ID #:364 

automated clearinghouse payments to "Netchex Tax Prep Clients " 

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

Netchex is a human resources company that provides payroll and 

other such services to Backpage . 

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

2017 , Seized Account 1 wired approximately $77 , 800 to S&W Payroll 

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

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

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

division . 

e . On August 11, 2017 , Seized Account 1 wired 

$5 , 319 . 79 to the Telesign Corporation , located in Marina de l Ray , 

California . According to their website , Telesign is a 

communications platform t hat delivers security for websites. 

f . On August 18 , 2017 , Seized Account 1 wired $1 , 497 

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

for Backpage ' s on- line data backup . 

41. Based on my review of bank records for Seized Account 1 

throughout the existence of the account, these types of 

transactions and expenditures were typical . 

2 . Seized Account 2A 

i. Transfers From Seized Account 1 

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

Seized Account 2A is a Compass Bank business bank account owned 

- 39 -

ATTACHMENT B 

DOJ-BP-0004 719197 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 39 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 114 of 

l 136 Page ID #:538 

Case 2:18-mj-02031-DUTY *SEALED* Document 5-1 *SEALED*\ . iled 08/07/18 Page 41 of 

121 Page ID #: 365 

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 : 

a . On July 25 , 2017 , Seized Account 1 sent two wire 

transfers totaling about $566 , 562 . 47 to Seized Account 2A . 

b . On August 8 , 2017 , Seized Account 1 sent a wire 

tota l ing $62 , 198 . 51 to Seized Account 2A . 

c . On August 31 , 20 17 , Seized Account 1 sent a wire 

transfe r 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 . 

ii . Fore ign Transfers into Seized Account 2A 

43 . I have reviewed financial records from a foreign bank 

in the Netherlands (the " Fore ign Account " ) . I have also 

revi ewed emails related to this account . From my review of 

these records, I learned the following : 

a . The Foreign Account was opened in Ma rch 2015 and 

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

and iden tifies Ferrer as the CEO and Gage as the CFO . 

b . From March 2015 through November 2017 , the 

- 40 -

ATTACHMENT B 

DOJ-BP-0004 719198 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 40 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* 

1 J-36 Paae ID_#·~39 Case 2:18-mj-02031-DUTY ·SEALED Documenr5-1 SEALED*· 

Filed 10/31/18 Page 115 of 

.~i led 08/07/18 Page 42 of 

121 Page ID #:366 

Foreign Account received millions of dollars from Binary Trading 

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

Seized Account 1. In an April 4 , 2017 , email to employees of 

the bank that maintains the Foreign Account , Gage explained, 

Binary Capital is our trading partner, they hold money in 

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

wire fees which make our transactions unprofitable , they 

act as our agent and disburse payments directl y from our 

trust account to our merchant. 

c . During this same period, the Foreign Account wire 

transferred several mi llion dollars into Seized Account 2A. For 

exampl e , an April 25 , 2017 , an email from Gage to individuals at 

the bank holding the Foreign Account directed the bank to wire 

" USO $2 , 337 , 048 " to Seized Account 2A . Thereafter, I reviewed a 

wire record and confirmed that on April 25 , 2017 , the Foreign 

Account wired $2,337,048 into Se i zed Account 2A, as Gage 

directed in his email . In reviewing the records, I found the 

following additional wires sent to Seized Account 2A : 

i . In December 2016 , the Foreign Account wired 

approximately $1 million do llars to Seized Account 2A . 

ii . On February 28 , 2017 , the Foreign Account 

wired $2 , 324 , 390 into Seized Account 2A . 

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

$2 , 247 , 858 into Seized Account 2A. 

iv. On May 31 , 2017 , the Forei gn Account wired 

$2 , 335 , 076 to Seized Account 2A . 

- 41 -

ATTACHMENT B 

DOJ-BP-0004 719199 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 41 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 .Page 116 of 

136 Paqe ID #:540 

Case 2:18-mj-02031-DUTY *SEALED* Docurl"ient 5-1 *SEALED* 1 iled 08/07/18 Page 43 of 

121 Page ID #:367 

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

$2 , 324 , 390 to Seized Account 2A . 

vi . July 27 , 2017 , the Foreign Account wired 

$1 0 , 928 to Seized Account 2A . 

iii. Seized Account 2A Payments for Backpage Operations 

44 . I then reviewed Seized Account 2A records for payments 

to promote Backpage operations . 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. I believe that 

Backpage uses Cox Communications to facilitate its internet 

presence and promote i t s sale of p rostitution advertising . 

3 . Seized Account 2B 

45 . I reviewed records Seized Account 2A and Seized 

Account 2B . On February 2 , 2018 , Seized Account 2A wired 

transferred $135 , 956 . 59 into Seized Account 2B . I am aware of 

no other funding sources for Seized Account 2B . 

4 . Seized Account 3A, 3B, 3C 

46 . I have reviewed records for Se i zed Account 3A as well 

as the following accounts : Branch Banking & Trust account 

number 1440001712008 , be longing to Website Technologies (as 

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

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

- 42 -

ATTACHMENT B 

DOJ-BP-0004 719200 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 42 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* . Filed 10/31/18 Page 117 of 

\ 136 Page ID #:541 

Case 2:18-mj-02031-DUTY *SEALED* Document 5-1 *SEALED*

1 iled 08/07/18 Page 44 of 

121 Page ID #:368 

be l onging 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 i n the United 

States. 

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

$1 89 , 57 1 to Ve r izon in Los Angeles , California , i n payment for 

Backpage int ernet services . 

c . Between January 21 , 201 6, and Augu st 31 , 20 1 6 , i n 

approximately 27 wires, the BBT Accou nt transferred 

app roximately $48 mi l lion to the AZBT Account. 

d . Between March 1 , 20 1 6 , and July 1 , 2016 , the AZBT 

Accoun t wired $892 , 426 into Seized Accoun t 3A . 

47 . According t o records for Seized Account 3A, 3B, and 

3C : 

a . On September 1 4 , 2017 , Seized Account 2A wi red 

$50 , 162 . 05 i n to Seized Account 3A . 

b . On October 1 2 , 2017 , Se i zed Account 3A wired 

approximately $21 , 500 into Seized Account 3B . 

c . On Janu ary 5 , 2018 , Seized Account 3A wired 

approximately $600 , 000 into Seized Account 3C . 

- 43 -

ATTACHMENT B 

DOJ-BP-0004719201 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 43 of 77
Case 2:18-mj-02872-DUTY ~SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 118 of 

1 136 Page ID #:542 

Case 2:18-mj-02031-DUTY .::,EALED* Document 5-1 *SEALED"' .--= iled 08/07/18 Page 45 of 

121 Page ID #:369 

5 . Seized Account 4 

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 r emained in Seized Account 4 since the 

account was opened . 

6 . Seized Account SA and SB 

49 . I have reviewed financial records related to Seized 

Accounts SA and SB, held in the name of Natasha Spear, Scott 

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

following : 

a . On February 23 , 20 17 , Seized Account 3A wired 

approximatel y $50 , 000 into Seized Account SA . 

b . On the February 23 , 2017 , Seized Account 3A wired 

$50 , 000 into Seized Account SB . 

7 . Seized Account 6 

50 . From my review of financial records related to Seized 

Account 2A, 2B and 6 , I learned t h e followi ng : 

a . On Octobe r 2 , 20 1 7 , Seized Account 2A wired 

approxi mately $297 , 79S into Seized Account 6 . 

- 44 -

ATTACHMENT B 

DOJ-BP-0004 719202 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 44 of 77
Case 2:18-mj-02872-DUTY ~,SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 119 of 

. { 136 Page ID #:543 : 

Case 2:18-mJ-02031-DUTY .::;EALED* Document 5-1 *SEALED*· :iled 08/07/18 Page 46 of 

121 Page ID #:370 

ll----- 10/2/2017 -----u- ~ J-.\ ----------~/_,.. $297,795.54 t:..~-v-

="' CEREUS PROPERTI.ES MIOiAB_ I.ACEY 

673B45B73 51103620 

COMPASS BANK FIRST FEDER/IL SA VIN GS 

(SUBJECT ACCOUNT 2) & LOAN Of SAN RAFAEL 

(SUBJECT ACCOUNT 6) 

8. Seized Accounts 7A, 7B, and 70 

MIOiAH. LACEY 

SAFE DEPOSIT BOX 

FIRST FEDERAL SAVINGS 

&LOAN OFSAN RAFAEL 

(SUBJECT SAFE DEPOSIT BOX 2) 

51 . From my review of financial records of Account 7C13 and 

Seized Accounts 2A, 2B , 7A, 7B, 7D , and 12A, I learned the 

fo l lowing: 

a. On July 6 , 2017 , Seized Account 2A wired 

$971,651 . 51 into Seized Account 7A. 

b . On July 28 , 2017 , Seized Account 7A wired 

$400 , 000 into Seized Account 7B. 

52 . From my review of financia l records of Seized Account 

1 and Account 7C , as well as those concerning t h e Veritex Bank 

accoun t ending in - 1462 , held i n the name of Posting Solutions 

("Account -1462 " ), 1 4 I learned the following : 

13 Previously, by way of affidavit in support of a seizure 

warrant , the government contemplated seizing an "Account 7C ," 

held by C. F. at all relevant times. Since then, Account 7C has 

been the subject of a separate agreement with the account 

holder . 

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

Posting Solutions opened Veritex Bank account -1462 on or about 

January 5 , 2017 . 

- 45 -

ATTACHMENT B 

DOJ-BP-0004 719203 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 45 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 120 of 

136 Page ID #:544 

Case 2:18-mj-02031-DUTY -:iEALED* Document 5-1 *SEALED.,_ .~iled 08/07/18 Page 47 of 

121 Page ID #:371 

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

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

into Account -1462 . 

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

$5,395 to Verizon, in Los Angeles . 

c . On August 8 , 2017 , Seized Account 1 wired $62 , 000 into 

Seized Account 12A . 

d . On November 3 , 2017 , Seized Account 12A wired $100 , 000 

into Seized Account 7D . 

9 . Seized Accounts 7E 

53 . I have reviewed the f inancial records of The Foreign 

Account , Seized Account 2A, Wells Fargo Bank account -9863 , 15 

Seized Account 25 , and Seized Account 7E , I learned the 

following : 

a . On December 2, 2016 , the Foreign Account wired 

$324,055 . 85 to Seized Account 2A . 

15 Wells Fargo Bank account -9863 is held in the name of "Voice 

Media Group ." Lacy and Larkin owned Village Voice Media, which 

in turn owned Backpage and other media publications. Around 

2012 , Larkin, Lacey , and other Backpage operators sold certain 

small media publications to the Voice Media Group , but retained 

their ownership of Backpage . However, based on regular payments 

that continued to be made from Voice Media Group to Lacy and 

Larki n fol lowing the sale , I believe that Backpage Operators 

still own a portion of Voice Media Group , or at least Backpage 

Operators may be carrying the loan or part of the loan that 

funded the sale of the small publications to Voice Media Group . 

- 4 6 -

ATTACHMENT B 

DOJ-BP-0004 719204 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 46 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 121 of 

. , 136 Page ID #:545 

Case 2:18-mJ-02031-DUTY ~EALED* Document 5-1 *SEALED"' ,.:iled 08/07/18 Page 48 of 

121 Page ID #:372 

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 . On September 19 , 2017 Seized Account 2A wired 

$83 , 063 to Wells Fargo Bank account -9863 (see Paragraph 53) . 

e . Between September 20 , 2017 , and December 8 , 2017 , 

in a total of 7 wire transfers, Wells Fargo Bank account -9863 

sent a combined total of $944 , 729 . 25 to Seized Account 25 . 

f . On December 13 , 2017 , Seized Account 25 wired 

$406 , 211 . 10 to Seized Account 7E . 

10 . Seized Account 8A, 8B, 8C, and 8D 

54 . From my review of the records for Seized Accounts 2A 

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

a . On February 2 , 2018 , Seized Account 2A wired 

$28 , 337 into Seized Account BA . 

b . Also on February 2 , 2018 , Seized Account 2A wired 

$28 , 337 into Seized Account 8B . 

55 . From my review of Seized Account 1 , SC, and 8D , I 

learned the fol lowing : 

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 . 

- 47 -

ATTACHMENT B 

DOJ-BP-0004 719205 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 47 of 77
Case 2:18-mj-02872-DUTY *;,EALED* Document 3-1 *SEALED* Filed 10/31/18 Page 122 of 

\ 136 Paqe ID #:546 ' 

Case 2:18-mj-02031-DUTY • 0EALED* Docuri'lent 5-1 *SEALED*\ iled 08/07/18 Page 49 of 

121 Page ID #:373 

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

S&W Payroll wired a total of $207 , 125 . 81 into Seized Account 8C . 

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

Seized Account SC wired $57,500 into Seized Account 8D. 

11 . Seized Accou nt 9 

56 . From my review of the records for Seized Account 2A 

2B, and 9 , I learned that on February 2 , 2018 , Seized Account 2A 

wi red $734,603 . 70 into Seized Account 9 . 

12 . Seized Account 10 

57. From my review of records for Seized Accounts 2A and 

10 , I learned that on February 2 , 2018 , Seized Account 2A wired 

$94 ,1 54 . 89 into Seized Account 10 . 

13 . Seized Account 11 

58 . From my review of Seized Accounts 1, BC , 8D, and 11 , 

as well as Account - 1 462 (as described in Paragraph 51 above , a 

Post ing Solutions' Veritex Bank account) , I learned the 

fo llowing: 

a . - On January 4 , 2017 , GoCoin ' s Singapore account 

wired $489 , 500 i nto Account - 1 462, and on January 20 , 2017 , 

GoCoin' s Singapore account directed two additional wires, for 

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

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

Account - 14 62) . 

- 48 -

ATTACHMENT B 

DOJ-BP-0004 719206 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 48 of 77
Case 2:18-mj-02872-DUTY *,SEALED* Document 3-1 *SEALED* _ Filed 10/31/18 Page 123 of 

. 136 Paae ID #

1

·547 -·i d / / f Case 2:18-mJ-02031-DUT -:>EALED Documenr 5- *SEALED'· .-t e 08 0718 Page 50 o 

121 Page ID #:374 

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

approximately $1 . 3 million into S&W Payroll . 

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

total of $9 , 913 . 53 into Seized Account 11 . 

14 . Seized Accounts 12A and 12B 

60 . 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 wi red $62 , 000 

into Seized Account 12A . 

61 . On December 8 , 1 2017 , Seized Account 12A wired $20 , 000 

into Seized Accou nt 12B . 

15 . Seized Account 13 

62. From my review of financial records for Seized 

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

a . In January 2017 , eized Account 1 wired $62 , 000 

into Seized Account 12A. 

b . On August 16 , 2017 , Seized Account 12A wired 

$20 , 000 into Seized Account 13 . 

16. Seized Account 14 

63 . 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 

- 49 -

ATTACHMENT B 

DOJ-BP-0004 719207 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 49 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 124 of 

. 

1 

136 Page ID #:548 

Case 2:18-mJ-02031-DUTY -:iEALED* Document 5-1 *SEALED,\ . :iled 08/07/18 Page 51 of 

121 Page ID #:375 

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) . 16 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 learned the following : 

a . On September 6 , 2015 , a bitcoi n account 

associated with t he 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 t he trafficking of those victims in Palm 

Springs, California . 

b . On Sept ember 15 , 2015 , an email f rom 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 t hat to " Fund Account " 

16 As previously described, the pimp who trafficked A. C. and 

S . F . was convicted and sentenced to 196 years' imprisonment , and 

the pimp who trafficked T. S ., S . L ., K. O., and R. W. was convicted 

and sentenced to 300 months' imprisonment . 

- 50 -

ATTACHMENT B 

DOJ-BP-0004 719208 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 50 of 77
Case 2:18-mj-O2872-DUTY *_SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 125 of 

136 Paqe ID #:549 

Case 2:18-mj-O2O31-DUTY 0EALED* Document 5-1 *SEALED*1 ·iled 08/07/18 Page 52 of 

121 Page ID #:376 

means that the email address owner provided bitcoin to Backpage 

as payment for credit t o be used at a later time to pay for 

Backpage ads . 

c . On Oct ober 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 b i tcoi n account associated 

with t he 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 pos t an ad promoting the trafficki ng of those victims in 

Columbu s , Oh io . 

e . On November 2 , 2015 , this same email address 

owner paid Bac kpage about $1 worth of bitcoi n to "Move Ad to Top 

of Listings " in the Columbus, Oh i o Backpage ads . 

f . On November 21 , 2015 , this same email address 

own er paid Backpage ab out $1 worth of bitcoin to Backpage for 

credit for that email owner' s Backpage ad account . 

g . During the period of September 4 , 20 15 , 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 duri ng this period were the six 

payments the p i mps made to Backpage to purchase ads to promote 

child prostitution . 

- 51 -

ATTACHMENT B 

DOJ-BP-0004 719209 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 51 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 126 of 

I 136 Page ID #:550 

Case 2:18-mj-02031-DUTY 3EALED* Document 5-1 *SEALED.. .~iled 08/07/18 Page 53 of 

121 Page ID #:377 

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 BET 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 . 

1. In July 21 , 2017 , t h e Northern Trust Account 

wir ed $6 . 01 4 million to the Morgan Stanley Account . 

m. I n or about November 2017 , Morgan Stanley elected 

to terminate its business r e l ationship with Larkin . 

n . Following this, on November 30 , 2017 , Larki n 

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 1 4 were used , 

among other things, to purchase bonds a nd/or securities, which 

assets remain held in Seized Account 14 . 

- 52 -

ATTACHMENT B 

DOJ-BP-0004 719210 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 52 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* _ Filed 10/31/18 Page 127 of 

, 136 Page ID #:551 

Case 2:18-mj-02031-DUTY .:;EALED* Document 5-1 *SEALED* :iled 08/07/18 Page 54 of 

121 Page ID #:378 

17 . Seized Accounts 15A through 15G 

64 . 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 Famil y Trust ("WFB 

Account· - 474 " ) . Additionally, I have reviewed GoCoin 

transactions related to certain ads posted on Backpage , 

specifical ly 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 learned the following : 

a . On September 6 , 2015 , a b i tcoin account 

associated with the owner of the email address who trafficked 

A.C . and S . F . paid Backpage abou t $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" 

- 53 -

ATTACHMENT B 

DOJ-BP-0004719211 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 53 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* 

. 1 136 Paae ID #:552 Case 2:18-mJ-02031-DUTY .:5EALED* Document 5-1 *SEALED"' 

121 Page ID #:379 

Filed 10/31/18 Page 128 of 

.~iled 08/07/18 Page 55 of 

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 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 mi l lion . Included 

among the bitcoin sold to GoCoin during this period were the six 

payments t he pimps made to Backpage to purchase ads to promote 

child prostitution. 

- 54 -

ATTACHMENT B 

DOJ-BP-0004 719212 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 54 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* 

. 1 136 Paqe ID #:553 Case 2:18-mJ-02031-DUTY ..:iEALED* Document 5-1 *SEALED* 

Filed 10/31/18 Page 129 of 

. ~iled 08/07/18 Page 56 of 

121 Page ID #:380 

h. During the period of December 14 , 2015 , t hrough 

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 beli eve that this 

$1 . 25 million represented GoCoin ' s partial payment to Ba ckpage 

for the bitcoin Backpage sold to GoCoin during the period of 

September 4 , 2015 , t hrough 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 ,4 59 to the WFB Account - 891 . 

k . On January 4, 2017 , the AZBT Account wired 

another $258 , 841 to the WFB Account -891 . 

1. On January 5 , 2017 , the WFB Account transferred 

$300 , 000 to WFB Account -4 74 . 

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

$1 . 5 million into Seized Account 15A . 

n . On May 23 , 2017 Seized Accou nt 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 . 

- 55 -

ATTACHMENT B 

DOJ-BP-0004 719213 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 55 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 130 of 

Case 2:18-mj-02031-DUT"t .:>EALED*

3

i of uarH~riPs~f1%i:ALED' - .~iled 08/07/18 Page 57 of 

121 Page ID #:381 

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 Account 15F . 

s . On September 15 , 2017 , Seized Account 15C 

transferred about $500 , 000 to Seized Account 15G . 

18 . Seized Accounts 16A, 16B, 16C, 16D, 16E , 16F, 16G, 

16H, and 161 

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 

$1 99 , 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 voi ce-over-internet phone and 

cable services. I believe t hat Backpage uses Cox Communications 

to facilitate its internet presence and promote its sale of 

prostitution advertising . 

- 56 -

ATTACHMENT B 

DOJ-BP-0004 719214 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 56 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 131 of 

136 Page ID #:555 

Case 2:18-mj-02031-DUTY "SEALED* Document 5-1 *SEALED* ,...:iled 08/07/18 Page 58 of 

121 Page ID #:382 

e . On May 31 , 2017 , Seized Account 2A wired 

approximately $676 , 808 . 04 into Seized Account 16A . 

f . On June 30 , 2017 Seized Account 16A transferred 

$600,000 to Seized Account 16B . 

g . On April 16 , 2018 , Lacey personally went into the 

Republic Bank of Arizona , withdrew $500 , 000 from Seized Account 

16A and opened Seized Account 16C with an initial deposit of the 

$500,000 he had just withdrawn from Seized Account 16A. 

h . On or about February 15 , 2018 , Lacey drafted two 

checks totaling $1 . 2 million, which he used to fund his "CDARS " 

accounts at Republic Bank of Arizona. The first check was drawn 

from Seized Account 6 in the amount of $600 , 000 . The second 

check was drawn from Seized Account 9 , also in the amount of 

$600 , 000 . The combination of these two checks totaling $1 . 2 

million were split and deposited between Seized Account 160 

(which received $600 , 000) , Seized Account 16E (which received 

$300 , 000) and 16F (which received $300,000) . 

i . On or about February 8, 2018 , Larkin drafted a $1 

million check drawn from Seized Account 7B and made payable to 

Republic Bank of Arizona in order to fund his "CDARS" accounts 

at that bank . Seized Account 16G received $500 , 000 , Seized 

Account 16H rece ived $250 , 000 , and Seized Account 161 received 

$250 , 000 . 

- 57 -

ATTACHMENT B 

DOJ-BP-0004 719215 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 57 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 132 of 

136 Page ID #:556 

Case 2:18-mj-02031-DUTY ·· .::iEALED* Document 5-1 *SEALED* . ·iled 08/07/18 Page 59 of 

121 Page ID #:383 

19 . Seized Account 17 

66 . I have reviewed records for Seized 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 beneficiar y . From this review, I learned the following: 

a . Between December 14 , 2015 , and January 15 , 20 1 6 , 

in approximately 26 wires, a GoCoin account in Slovakia 

transferred over $2 . 5 million to the BBT Account in the Uni ted 

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 , 20 1 6 , 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 Annu ity Trusts 

Accounts sent five wires totaling $16 . 5 million to the Johnson 

Financial Bank Account . 

- 58 -

ATTACHMENT B 

DOJ-BP-0004 719216 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 58 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 133 of 

136 Page ID #:557 

Case 2:18-mj-02031-DUTY h.::>EALED* Document 5-1 *SEALED*' ded 08/07/18 Page 60 of 

121 Page ID #:384 

f . On January 3 , 2017 , the Johnson Financial Account 

wired the $16 . 5 million to the Seized Account 17 in Hungary. 

20 . Restrained Accounts 18A, 18B, 18C, 18D, 18E , 18F, 

18G, 18H, 181 , 18J, 18K, and 18L 

67 . 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 p l ea agreement , Ferrer 

agreed to " take all steps within his power to forfeit to the 

United States all corporate assets and other property owned or 

control led by Website Technologies, LLC , which own and operates 

the Backpage website , as well as corporate assets and other 

property owned or contr olled by Backpage . com, LLC , Posting 

Solutions LLC , Amstel River Holdings, LLC , Ad Tech BV, and UGC 

Tech Group CV ." That same day , also in t he Di strict of Arizona , 

Backpage . com, LLC and related entities plead guil ty to 18 U. S . C. 

§ 1956(h) (money laundering conspiracy) . 

68 . On April 17 and April 18 , 2018 , along with other l aw 

enforcement agents and prosecutors, I spoke with Ferrer and his 

attorneys in Phoenix, Arizona . Following this in- person 

interview, I also have spoken with Ferrer on the phone and 

communicated via email . From my review of Service Level 

- 59 -

ATTACHMENT B 

DOJ-BP-0004 719217 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 59 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 134 of 

~ 136 Paqe ID #:558 

Case 2:18-mj-02031-DUTY ..::.iEALED* Document 5-1 *SEALED .... 1 :iled 08/07/18 Page 61 of 

121 Page ID #:385 

Agreements ( " SLAs " ) , 17 financial records related to Restrained 

Accounts 18, and records and statements provided by Ferrer, I 

know the following : 

a . Restrained 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, 

Restrained 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 Restrained 

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. 

b . Restrained Accounts 180, lBE, and lBF are 

accounts held by a t hird party, Gold Leaf SRO . According to 

Ferrer and SLAs between Ad Tech BV, a Backpage owned company and 

Gold Leaf SRO , which SLAs I have reviewed , the funds and/or 

securities in these accounts are the criminally derived proceeds 

of Backpage ads, including ads promoting prostitution . The SLAs 

17 Service Level Agreements are service related contracts, 

commitments, and agreements between a service provider and a 

client . 

- 60 -

ATTACHMENT B 

DOJ-BP-0004 719218 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 60 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 135 of 1 136 Paqe ID #:559 

Case 2:18-mj-02031-DUTY '".:,EALED* Document 5-1 *SEALED* \ ,led 08/07/18 Page 62 of 

121 Page ID #:386 

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 . 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 . 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 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 and are not 

co-mingled with other funds , and are therefore subject to 

seizure and forfeiture to t he United States . 

c . Restrained 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, 

- 61 -

ATTACHMENT B 

DOJ-BP-0004 719219 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 61 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* _ Filed 10/31/18 Page 136 of 

Case 2:18-mj-02031-DUTY .::iEALED*

3~ ot~~~rlPs~t i ~ ALED' .-=iled 08/07/18 Page 63 of 

121 Page ID #:387 

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 . 

d . Restrained Accounts lSJ, 18K, lBL are accounts 

held by a third party, Varicok SRO . According to Ferrer and an 

agreement between Varicok SRO and Ad Tech BV , which I have 

reviewed , the arrangement is essentially the same as the Gold 

Leaf SRO , and Protecttio SRO. 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. 

21 . Restrained Accounts 19A, 19B, 19C, and 19D 

69 . From speaking with Ferrer and reviewing financial 

records, I learned the following : 

a . Restrained Accounts 19A, 19B, 19C, and 19D, are 

owned by Ad Tech BV , with Ferrer as the ultimate beneficial 

- 62 -

ATTACHMENT B 

DOJ-BP-0004 719220 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 62 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-2 *SEALED* Filed 10/31/18 Page 1 of 49 

Page ID #:561 

Case 2:18-mj-02031-DUTY -- ~EALED* Document 5-1 *SEALED*' lied 08/07/18 Page 64 of 

121 Page ID #:388 

owner . According to Ferrer, Restrained Accounts 19A, 19B, 19C 

and 19D are accounts receivable banking accounts . Payment 

processors and merchant processors would take credit card 

payments, and payments such as bitcoin payments from ~ackpage 

customers for prostitution and other ads , and would transfer· 

these funds to accounts such as Restrained Accounts 19A, 19B, 

19C, and 19D . These accounts contain funds and/or securities 

that are criminally derived and are subject to forfe i ture . 

Ferrer and Backpage has agreed to surrender t h ese funds and/ or 

securities as they are criminally derived . 

22 . Restrained Account 20 

70 . From speaking with Ferrer and reviewing financial 

records, I learned the followin g : 

a . Restrained Account 20 at Knab Bank in the 

Netherlands is an account held by a t h ird party, Procop Services 

BV . Accordi ng to Ferrer the arrangement is essentially the same 

as the Gold Leaf SRO and Protecttio SRO , as described with 

respect to Restrained Accounts 19 . This business arr angement 

existed for the sole purpose of all owing purchasers of 

p r ostitution ads to p u rchase ads on Backpage websites whi le 

evading the credit card company blockade . Ferrer explained that 

these accounts are owned by Backpage and are not co-mi ngled with 

other funds and/or securities, and are therefore subject to 

seizure and forfeiture to the United States . 

- 63 -

ATTACHMENT B 

DOJ-BP-0004 719221 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 63 of 77
Case 2:18-mj-02872-DUTY *,SEALED* Document 3-2 *SEALED* 

Paqe ID #:562 

Case 2:18-mj-02031-DUTY .::>EALED* Docl.Jment 5-1 *SEALED"'-

Filed 10/31/18 Page 2 of 49 

.-=iled 08/07/18 Page 65 of 

121 Page ID #:389 

23 . Restrained Accounts 21A and 21B 

71 . From speaking with Ferrer and reviewing financial 

records and business agreements, I learned the following: 

a . Restrained Account 21A is an account iu the 

Netherlands held in the name of Gulietta Group BV . According to 

Ferrer and the relevant SLA, the funds and/or securities in t his 

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 . 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 Restrained Accounts 18D, 18E , and 18F . Ferrer 

explained that t hese accounts are owned by Backpage and are not 

co-mingled with other f unds and/or securities, and are therefore 

subject to seizure and forfeiture to the United States . 

b. Restrained Account 21B is an account in the 

Netherlands held in the name of UnivsersAds BV. According to 

Ferrer and the SLAs between t he companies, the funds and/or 

securities in this account are derived from selling 

advertisements online , most of which are for prostitution 

advertisements. The SLAs state t hat 99 . 5% of t he net proceeds 

are to be paid to Ad Tech BV which is owned by Backpage . 

According to Ferrer, the arrangement between UniversAds BV and 

- 64 -

ATTACHMENT B 

DOJ-BP-0004 719222 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 64 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-2 *SEALED* Filed 10/31/18 Page 3 of 49 

, \ Page ID #:563 

Case 2:18-mj-02031-DUTy· .::>EALED* Document 5-1 *SEALED*' . ~iled 08/07/18 Page 66 of 

~ - GC)COffl 

(5LOVAA!~) 

121 Page ID #:390 

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. 

24. Seized Account 22 

!2/H/21l;S· !/29/2016[391Jns) ~ 3/2l'20J6,3(31/2016~iil, ~/l/2016· 1W6i20J6(!2tms) ~ __ 7/;J/:i~W2\:t:-@, .J.95ll.s57.78 L~ SJ.694,013.60 L~ si6,sos,ssJ.oo L--:;tz i/;/i0i7s2.sooooo L~- WEBSITE TEC!t'ICX.OGIES Cl:PfUSPROPl:RlES JAMES LI\Rl(JII ' 

144000171:.000 936l1162ll OIA~ 501'.'/AB ACIGlCOIMl1⁄4lttOO Fund, LI' •Acct RCGOOll2 

BR~l[CJI 11.\JIKllG !I. TRUST ARIZotl-\ BAI«& TIIUST ,907'693 OcotlloF an~ Ttust 

PerslmgLlC 

DIAGRAM OF ILLICT FUNDS TRACED TO SUBJECT ACCO T 22 

72 . I have reviewed records for Seized Account 22 as well 

as t he 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 " ) ; Charles Schwab account number 49074693 belonging to 

James Larkin (" Schwab Account " ) ; and Pershing, LLC Account 

number RG001121 belongi ng to the Acacia Conservation Fund , a 

hedge fund that banks with Pershing LCC (" Pershing 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 . 

- 65 -

ATTACHMENT B 

DOJ-BP-0004 719223 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 65 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-2 *SEALED* _ Filed 10/31/18 Page 4 of 49 

Case 2:18-mj-02031-DUTY '_;,EALED* &IeWih~Prl 5?f1sEALED*1 :iled 08/07/18 Page 67 of 

121 Page ID #: 391 

(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 learned the following : 

t . 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 trafficki ng of those victi ms in Palm 

Springs, California . 

u . 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" 

mean s that t he email address owner provided bitcoin to Backpage 

as paymen t for credit to be used at a later time to pay for 

Backpage ads . 

v . On October 6, 2015 , the same email address owner 

paid Backpage abou t $1 worth of bitcoin to " Fund Account " on 

palmsprings . backpage . com . 

w. 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. p aid Backpage about $1 worth of b i tcoin in order 

- 66 -

ATTACHMENT B 

DOJ-BP-0004 719224 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 66 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-2 *SEALED* Filed 10/31/18 Page 5 of 49 

. ( Paqe ID #:565 

Case 2:18-mJ-02031-DUTY 0EALED* Doc1tment 5-1 *SEALED""- ·iled 08/07/18 Page 68 of 

121 Page ID #:392 

to post an ad promoting the trafficking of those victims in 

Columbus, Ohio . 

x . 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 , Ohi o Backpage ads . 

y . 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 . 

z . 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 . I ncluded 

among the bitcoin sold to GoCoin during this period were the six 

payments the pimps made to Backpage to purchase ads to promote 

chil d prostitution . 

aa. During the period of December 14 , 2015 , through 

January 29, 2015 , a GoCoin account held in Slovakia wired about 

$3 , 959 , 557 . 78 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 $3 , 959,557 . 78 million represented GoCoin ' s partial 

payment to Backpage for the bitcoin Backpage sold to GoCoi n 

during the period of September 4 , 2015 , through November 23 , 

2015 . 

- 67 -

ATTACHMENT B 

DOJ-BP-0004 719225 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 67 of 77
Case 2:18-mj-02872-DUTY ~SEALED* Document 3-2 *SEALED* _Filed 10/31/18 Page 6 of 49 

Case 2:18-mj-02031-DUTY · -=iEALED* 8&~Jr111

Pnf~£QSEALED*, .~iled 08/07/18 Page 69 of 

121 Page ID #:393 

bb . During t he period of March 23 , 2016 , through 

March 31 , 2016, in three transactions, the BBT Account wired 

$3 , 694 , 813.60 to the AZBT Account . 

cc . During the period of April 1 , 20 1 6, through July 

1 , 2016 , in f ive transactions, the AZBT Account wired $5 , 750 , 294 

to the Schwab Account . 

dd . On July 1, 2016 , the Schwab Account wired $15 

million to Seized Accou nt 22 . 

ee . During the period of August 2 , 2016 , t h rough 

October 6, 2016 , in six transactions, the AZBT Account wired 

$9 , 550 , 315 to the Schwab Account . 

ff . On January 3 , 2017 , the Schwab Account wired $2.5 

mill ion to Seized Account 22. 

gg . On January 4, 2017 , the Schwab Account wired $2 . 5 

mill i on to Seized Account 22 . 

25 . Restrained Account 23 

73 . 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 l aundering} . As part of his plea agreement , Ferrer 

agreed to " take a ll steps within his power to forfeit to the 

United States a ll corporate assets and other property owned or 

controlled by Website Technologies, LLC, which own and operates 

- 68 -

ATTACHMENT B 

DOJ-BP-0004 719226 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 68 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-2 *SEALED* 

. .\ Paae ID #:567 Case 2:18-mJ-02031-DUTY .:iEALED* Document o-1 *SEALED,,. 

121 Page ID #:394 

Filed 10/31/18 Page 7 of 49 

.~iled 08/07/18 Page 70 of 

the Backpage website , as well as corporate assets and other 

property owned or controlled by Backpage . com, LLC, Posting 

Solutions LLC , Amste l River Ho l dings , LLC , Ad Tech BV, and UGC 

Tech Group CV ." That same day , also in t he District of Arizon a , 

Backpage . com, LLC and related entities plead guilty to 18 U. S . C. 

§ 1956 (h) (money laundering conspiracy) . 

74 . On April 17 and April 18 , 2018 , along with other law 

enforcement agents and prosecutors, I spoke with Ferrer and his 

attorneys in Phoenix, Arizona. Following this in- person 

interview, I have also spoken with Ferrer on the phone and 

communi cated via email . Additionally I have communicated with 

United Kingdom law enforcement regarding these accounts . From 

my review of these SLAs , 18 financial records related to 

Restrain ed Account 23 , and records and statements provided by 

Ferrer and U. K. Law Enforcement , I understand that Restrained 

Account 23 conta i ns 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 . 

18 Here, the SLAs are between Backpage (as the " client " ) and 

entities t hat Ferrer referred to as " third-party affiliate 

companies," such as Guilietta Group B. V. , Proccop Services B.V., 

Universads B. V., Proteccio SRO , and Olist OU and Ad Tech B. V. 

- 69 -

ATTACHMENT B 

DOJ-BP-0004 719227 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 69 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-2 *SEALED* 

Paqe ID #:568 1 

Case 2:18-mj-02031-DUTY -:iEALED* Document 5-1 *SEALED* 

121 Page ID #:395 

Filed 10/31/18 Page 8 of 49 

·iled 08/07/18 Page 71 of 

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") . 

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 I 

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 

- 70 -

ATTACHMENT B 

DOJ-BP-0004 719228 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 70 of 77
Case 2:18-mj-02872-DUTY *SEALED* Document 3-2 *SEALED* Filed 10/31/18 Page 9 of 49 

- Paqe ID #:56~ 

Case 2:18-mj-02031-DUTY .::iEALED* Docu ment 5-1 SEALED*1 -iled 08/07/18 Page 72 of 

121 Page ID #:396 

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 

prohi bited credit card payments for Backpage ads . Ferrer 

explained that t h ese funds are owned by Backpage and are not comingled with other funds . 

26 . Restrained Account 24 

76 . From speaking with Ferrer and reviewing financial 

records and busi ness agreements, I learned that Restrained 

Account 24 is an account maintained in the Republic of Estonia , 

h eld in the name of Olist OU . According to Ferrer and t h e SLAs , 

the funds and/or securities in this account are derived from 

selli ng advertisements onli ne , most of which ads are fo r 

prostitution advertisements . The SLAs state that 99 . 5% of the 

n e t proceeds are to be p a i d to Ad Tech BV, which is owned by 

Backpage . Accordi ng to Ferrer, the arrangement between Olist OU 

and Ad Tech BV (Backpage) was p u t i nto p l ace to avoid t he same 

credit card " blockade" described in relation to Restrained 

Accounts 23 . Ferrer explained that these accounts are owned by 

Backpage and are not co-mingled with other funds and/or 

securities. 

- 71 -

ATTACHMENT B 

DOJ-BP-0004 719229 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 71 of 77
Case 2: 18-mj-02872-DUTY *SEALED* Document 3-2 *SEALED* Filed 10/31/18 Page 10 of 

49 Paqe ID #:570 

Case 2:18-mj-02031-DUTY ..:iEALED* Document 5-1 *SEALED* .·iled 08/07/18 Page 73 of 

121 Page ID #:397 

27. Seized Account 25 

• ~" __my2016-12/30/~( ~ --9/19/201z_____,..( j~~~. ___ 9_t;0{~sA~~~~1

_

7 

__ .,../E(';} ;Jl.· $1,023,995,

95 \ ~ A $B3

,o53 \,: ~ TOTAUNG $944,729.25 \! .. : . .# 

MlID-1 BV ""',/ • ~ _e? 

BANK FRICK CEREU S PROPERTIES 

'3873 

COMPASS BANK 

(SUBJECT ACCOUNT 2A) 

I 

3/3/2017 - 12/8/2017 

$9,155.59 

l 

·---' COX COMMUNICATIONS 

(PROMOTION) 

VOICE MEDIA GROUP CEREUS PROPERTIES 

'9863 '4862 

WELLS FARGO COMPASS BANK 

77 . I have reviewed the financial records of The Foreign 

Account in the Netherlands, Seized Account 2A, Wells Fargo Bank 

account -9863 (see Paragraph 53 , above), and Seized Account 25. 

From this review I learned t he following : 

a. On December 2, 2016, t he Foreign Account in the 

Netherlands wired $324,055 . 85 to Seized Account 2A. 

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 . On September 19, 2017, Seized Account 2A 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 Seized Account 25. 

f. On December 13 , 2017 , Seized Account 25 wired 

- 72 -

ATTACHMENT B 

DOJ-BP-0004 719230 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 72 of 77
Case 2: 18-mj-02872-DUTY *SEALED* Document 3-2 *SEALED* Filed 10/31/18 Page 11 of 1 49 Paqe ID #:571 . Case 2:18-mj-02031-DUT ,.>EALED* Docunient 5-1 *SEALED*l !led 08/07/18 Page 74 of 

121 Page ID #:398 

$406 , 211 . 10 to Seized Account 7E . 

28 . SUBJECT ACCOUNT 26 

J/30/2017- $)01,77 •. 03 

S/'5/2017 - $676,808.01 

~ --=l/l=a/2017-J/20~~ __ Chect 2/23/2017 $27,8'7~ f:?i; ;• _ 7/6/2017 - $9SB,811.Jg --'=11.. ~nt dosed July~0 ~ .,, 

t ~ ff SltJU,800 ~ Wl'c 2/23(17 $413,011 1 t.~ 8/9/201'7 - $1,90-4,921.+4 L3⁄4· Chcdc Issued 

GOCOIH POSTJNG SOllJT)QNS ; 9/14/2017 - $315,813.75 MldArst Bank Offtdtd Check 

(S1-iGA.PORE) 11462 CCRG.IS PROPER.TE> TOTAL $4.0S8,(l63.65 14139 $2,112,785.17 

VERITEX BAIi!( '3873 (SIJ8JECT ACCOIJl/r 26) 

COMPASS BAH.IC 

(ACCOU!lr 2A) 

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 Accoun t -1 462 

(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 . 

d . In July 2018 , SUBJECT ACCOUNT 26 was closed and a 

cashier' s check totaling $2 , 412 , 785 . 47 was issued to Michael 

- 73 -

ATTACHMENT B 

DOJ-BP-0004 719231 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 73 of 77
Case 2: 18-mj-02872-DUTY" *SEALED* Document 3-2 *SEALED* Filed 10/31/18 Page 12 of 

Case 2:18-mj-02031-DUT'\ SEALED*

4%dcflfti /R~ J?l~ ALEDi1 .-=iled 08/07/18 Page 75 of 

121 Page ID #:399 

Lacey ' s Annuity Fund held by his attorney . As of the date of 

this affidavit, this check has not been negotiated. 

29 . SUBJECT ACCOUNT 27 

Wires 

~---- - - ---------~%~:g:: g:~::::---➔--- A01ECH8V 9/27/2017 •• S778,80l-96 

BAN>< FRIO( 

(FOREIGN ACCOUNT) 

.,.,,--'-------~--- [\ 8/16/'1.017 • 8/J0/2017 FOSTING S0UJTIONS SWJECT ACCOUNT 27 

-----$Z,7 MllLION ;:,sd:v~~~ / DA~\~:H~~~AINE 

----- / (TOTAl RECEIVED 8,778,802.96) 

1?1t ~ /6/22/2017 •• S!,000,000 

GOC.OIH 

(SINGAPORE) 

}filf_l017 • 1/20/1~17 ;, f"i!l~, $l,11B.,80D ~it POSTING SOL\ITIONS 

'1162 

VERITEC8ANK 

79 . 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 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.corn, 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) . 

- 74 -

ATTACHMENT B 

DOJ-BP-0004 719232 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 74 of 77
Case 2: 18-mj-02872-DUTY *SEALED* Document 3-2 *SEALED* 

49 Paqe ID #:573 

Case 2:18-mj-02031-DUTY 0EALED* Docurnent 5-1 *SEALED* \ 

121 Page ID #:400 

Filed 10/31/18 Page 13 of 

1led 08/07/18 Page 76 of 

80 . From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 27 is an IOLTA account 

held in the name of the law firm Davis Wright Tremaine (~DWT") . 

Based on my conversations with Backpage CEO, Carl Ferrer, and 

Bank of America employees, I believe that Backpage or Backpage 

controlled entities are the beneficiaries of this account . This 

account has received $8,778 , 802 . 96 of unearned funds in 

prepayment of future legal services. These funds are owned by 

Backpage, but held by DWT and are subject to forfei ture. 

81 . Based upon my review of the financial records SUBJECT 

ACCOUNT 27, Seized Account 1, Posting Solutions Veritex Bank 

account - 1462 , a nd the Foreign Account , I learned the following : 

a. Between January 13, 2017 , and January 20 , 2017 , a 

GoCoin account wired $1 , 318 , 800 to Posti ng Solution Veritex Bank 

-1462 . 

b. On June 22 , 2017, Veritex Bank account -1462 

wired $1 , 000 , 000 into SUBJECT ACCOUNT 27 . 

c. On April 27 , 2017 , the Foreign Account Wired 

$2 , 500 , 000 to SUBJECT ACCOUNT 27 . 

d . On April 28 , 2017 , t he Foreign Account Wired 

$2,500,000 to SUBJECT ACCOUNT 27 . 

e. On May 24 , 2017 , Seized Account 1 wired $500 , 000 

into SUBJECT ACCOUNT 27 . 

f . On September 13, 2017 , Seized Account 1 wired 

- 75 -

ATTACHMENT B 

DOJ-BP-0004 719233 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 75 of 77
Case 2: 18-mj-02872-DUTY *SEALED* Document 3-2 *SEALED* _ Filed 10/31/18 Page 14 of 

• 1 49 Paae ID #:5z 4 ·1 d / / f Case 2:18-mJ-02031-DUTY ,::,EALED* Document 5-1 SEALED*' .~, e 08 07 18 Page 77 o 

121 Page ID #:401 

$1 , 000 , 000 into SUBJECT ACCOUNT 27 . 

g . On September 27 , 2017 , t he Foreign Account wired 

about $778 , 802 . 96 into SUBJECT ACCOUNT 27 . 

h . On October 20 , 2017 , Seized Account 1 Wired 

$500 , 000 into SUBJ ECT ACCOUNT 27 . 

Approximate Am.ount of Wire 

Transfers from Foreign Account Credits into SUBJECT AC<!::OUNT 27 

Date(s) and Veritex Bank - 1462 

-

From To Amount Amount To 7 

1/13/2017 Veritex 

- GoCoin Bank - 1,318 , 800 . 00 

1/20/2017 1462 

4/27/2017 GoCoin 2 , 500 , 000 . 00 Subject 

Account 27 

4/28/2017 GoCoin 2 , 500 , 000 . 00 Subject 

Account 27 

5/24/2017 Seized Account 1 500 , 000 . 00 Subject 

Account 27 

08/16/2017 Seized 

- GoCoin Singapore Account 2 , 700 , 000 . 00, 

08/30/2017 1 

9/13/2017 Seized Account 1 1 , 000 , 000 . 00 Sub j ect 

Account 27 

9/27/2017 Foreign Account 778,802 . 96 Subject 

Account 27 

10/20/2017 Seized Account 1 500 , 000.00 Subject 

Account 27 

VI. CONCLUSION 

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

to believe that the funds and/or securities on deposi t in 

- 76 -

ATTACHMENT B 

DOJ-BP-0004 719234 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 76 of 77
Case 2: 18-mj-02872-DUTY *SEALED* Document 3-2 *SEALED* . Filed 10/31/18 Page 15 of 

Case 2:18-mj-02031-DUTY .:>EALED*

49

ocfcm:Weh? tf lgEALED"' . .:iled 08/07/18 Page 78 of 

121 Page ID #:402 

SUBJECT ACCOUNT 26 and SUBJECT ACCOUNT 27 are subject to seizure 

and forfeiture by the United States under the following 

provisions : 

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

and/or securities in SUBJECT ACCOUNT 26 and SUBJECT ACCOUNT 27 

are involved in, and traceable to, one or more transactions or 

attempted transactions in violation of 18 U. S . C. § 1956(h) 

(Conspiracy to Launder Money) , 18 U. S . C. § 1956(a) (2) 

(International Money Laundering for Promotion ), and 18 U. S . C. § 

1957 (Financial Transactions Involving Illicit Proceeds) ; and 

b . 18 U. S . C. § 981 (a) (1) (C), because .the f unds 

and/or securities in SUBJECT ACCOUNT 26 and SUBJECT ACCOUNT 27 

constitute and are derived from proceeds traceable to one or 

mo re violations of 18 U. S . C. § 1591 and 18 U. S . C. § 1952 . 

Subscribed to and sworn to me 

this 7th day of August , 2018 

/s/ Jacqueline Chooljian 

United Stat es Magistrate Judge 

Isl 

Lyndon Versoza 

U. S . Postal Inspector 

- 77 -

ATTACHMENT B 

DOJ-BP-0004 719235 

Case 2:18-cr-00422-DJH Document 1968-2 Filed 11/13/23 Page 77 of 77