1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

GARY M. RESTAINO 

United States Attorney 

District of Arizona 

KEVIN M. RAPP (Ariz. Bar No. 014249, kevin.rapp@usdoj.gov) MARGARET PERLMETER (Ariz. Bar No. 024805, margaret.perlmeter@usdoj.gov) PETER S. KOZINETS (Ariz. Bar No. 019856, peter.kozinets@usdoj.gov) ANDREW C. STONE (Ariz. Bar No. 026543, andrew.stone@usdoj.gov) 

Assistant U.S. Attorneys 

40 N. Central Avenue, Suite 1800 

Phoenix, Arizona 85004-4408 

Telephone (602) 514-7500 

DAN G. BOYLE (N.Y. Bar No. 5216825, daniel.boyle2@usdoj.gov) Special Assistant U.S. Attorney 

312 N. Spring Street, Suite 1400 

Los Angeles, CA 90012 

Telephone (213) 894-2426 

KENNETH POLITE 

Assistant Attorney General 

Criminal Division, U.S. Department of Justice 

AUSTIN M. BERRY (Texas Bar No. 24062615, austin.berry2@usdoj.gov) 

U.S. Department of Justice 

Child Exploitation and Obscenity Section 

1301 New York Avenue, NW, 11th Floor 

Washington, D.C. 20005 

Telephone (202) 412-4136 

Attorneys for Plaintiff 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

United States of America, 

 Plaintiff, 

 v. 

Michael Lacey, et al., 

 Defendants. 

CR-18-422-PHX-DJH 

AMENDED NOTICE OF INTENT TO 

INTRODUCE EXPERT TESTIMONY 

– CHRISTINA DECOUFLE 

(Doc. 422)

The United States of America, by and through its undersigned attorneys, pursuant 

to Fed. R. Crim. P. 16(a)(1)(F) and (G), hereby amends its previously filed Notice of Expert 

Witnesses and Notice of Rebuttal Expert Witnesses. (Docs. 422, 638.) As explained below, 

Case 2:18-cr-00422-DJH Document 1627 Filed 07/03/23 Page 1 of 6
- 1 - 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

the United States intends to introduce Christi Decouflé as an expert witness in prostitution

at trial, and to offer testimony under Fed. R. Evid. 702, 703 and/or 705 during its case-inchief and/or rebuttal.1

 

Background 

In December 2018, the United States filed its Notice of Expert Witnesses, 

identifying ten individuals as potential expert witnesses. (Doc. 422.) In April 2020, 

Defendants filed a Motion in Limine to Preclude Expert Testimony. (Doc. 928.) 

Defendants’ motion sought to preclude expert testimony related to sex trafficking, 

specifically, child sex trafficking. (Doc. 928 at 4, 7-12.) In a written order, the Court noted 

that Defendants did not challenge the qualifications or the reliability of the United States’ 

expert witnesses. (Doc. 1081 at 15.) The Court found four areas of expert testimony 

relevant; and, due to concerns about overlapping and “unnecessarily cumulative” expert 

testimony, held that the United States could call one expert witness on each of the following 

four topics: 

1. How human/sex trafficking occurs through online media; 

2. How law enforcement conducts trafficking investigations, with a focus on how 

investigations shifted from craigslist.com to backpage.com; 

3. Explanation of terminology often used in trafficking and prostitution industry; 

and, 

4. The relationship between traffickers and pimps and their victims, including 

common methods a sex trafficker uses to maintain control over a victim. 

(Doc. 1081 at 17.) 

After September 2021 trial began, the Court decided that “No. 4,” expert testimony 

1 Except for Matthew Frost, the United States no longer intends to call at trial the 

remaining witnesses it previously noticed as potential experts and rebuttal experts in Docs. 

422 and 638. The United States will be filing a separate amended notice of expert witness for Matthew Frost. However, several other witnesses, specifically, J. Patrick Cullen, Quoc 

Thai, Staca Shehan, Brian Fichtner, and Donna Gavin will be testifying as fact witnesses in the United States’ case-in-chief and/or rebuttal. 

Case 2:18-cr-00422-DJH Document 1627 Filed 07/03/23 Page 2 of 6
- 2 - 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

regarding the relationship between traffickers and pimps and their victims, was no longer 

relevant. (Doc. 1343 at 114.) The United States reserved the opportunity to object to that 

ruling2

. (Doc. 1343 at 114.) 

As trial proceeded, the United States informed the Court that Dr. Cooper would be 

testifying about how sex trafficking occurs online, and the terminology and vernacular 

often used in the trafficking and prostitution industry. (Doc. 1345 at 7.) Defendants orally 

moved to preclude this testimony under relevance grounds. (Doc. 1345 at 8.) The Court 

denied Defendants’ oral motion, finding the topics of testimony were properly noticed, but 

cautioned that if [Dr. Cooper] testified about prostitution terminology, then the other expert 

would not be allowed to also testify about it. (Doc. 1345 at 10.) During her testimony, Dr. 

Cooper testified about words often heard and used when one is involved in prostitution.

(Doc. 1346 at 41-47.) The United States does not plan to call Dr. Cooper as a witness in 

the retrial. 

Updates and Amendments to Expert Notice 

The United States will call retired Detective Christi Decouflé to testify as an expert 

about: (1) how prostitution or trafficking occurs through online media; (2) how law 

enforcement investigates prostitution, with a focus on how investigations shifted from 

craigslist.com to backpage.com; and (3) the use and meaning of terminology often used in 

trafficking and prostitution industry. (See Doc. 1081 at 17.) 

Detective Decouflé has a Bachelor of Science in Psychology and Military Science 

from Northern Kentucky University, and a Masters of Education in Human Services from 

Northern Arizona University. 

Detective Decouflé was employed by the Phoenix Police Department from 2000 

until her retirement in December 2021. For most of her career, Detective Decouflé was 

2

 Regarding the relevance of testimony describing the relationship between a trafficker or pimp and the victim, the Court agreed there was “potential that the defense 

may have already opened the door or may in the future. So [United States] can re-urge it at a later time for rebuttal if necessary.” (Doc. 1345 at 10-11.) 

Case 2:18-cr-00422-DJH Document 1627 Filed 07/03/23 Page 3 of 6
- 3 -

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

part of the Phoenix Police Department’s Vice Unit (now the Human Exploitation and 

Trafficking Unit, or HEAT), where she investigated prostitution and trafficking offenses. 

The United States intends to elicit opinion testimony from Detective Decouflé. See

Rule 16(a)(1)(G)(iii). Specifically, Detective Decouflé will offer the opinion that the vast 

majority of the ads posted in the adult or escort section of backpage.com were ads for

prostitution. Detective Decouflé will opine that while the term “escorting” may also mean 

paying a person for companionship only, it is frequently used as a code word for 

prostitution. Indeed, “escorting” is just the word used to not make it look so bad, or to 

attempt to make it appear legal. As she explained during her expert testimony in United 

States v. Terrill Smith, CR-16-0734-PHX-SPL (previously disclosed to Defendants in this 

case), Detective Decouflé will explain that during her 13 years of work as a Vice Detective, 

the term “escorting” is used interchangeably with prostitution or a commercial sex act. 

Detective Decouflé’s opinions are based on her training and experience in her 13 

years as a Vice Detective. During this time, she conducted over 300 forensic interviews of 

adult and child sex trafficking victims and approximately 200 interviews of sex traffickers 

and witnesses. (Doc. 422-5 at 2.) Detective Decouflé has worked in an undercover 

capacity posing as a prostitute on the street, in motels, and online. Detective Decouflé has 

participated in numerous undercover sting operations where law enforcement posts an ad 

on Backpage in an attempt to arrest traffickers, johns, rescue prostitutes, and to generally

disrupt prostitution activity in the Phoenix area. Detective Decouflé has attended and 

presented at numerous conferences and trainings related to sex trafficking, prostitution, 

interviewing trafficking victims, and undercover law enforcement investigations. (Doc. 

422-5 at 3-6.) Her experience enables her to understand how prostitution works and the 

methods utilized by individuals to facilitate prostitution services. 

Additionally, Detective Decouflé will testify about topics previously identified in 

Docs. 422 and 1081 that the Court previously deemed relevant and admissible.

3

 She will 

3 Testimony will not include testimony related to “the day in the life of a prostitute.” 

Case 2:18-cr-00422-DJH Document 1627 Filed 07/03/23 Page 4 of 6
- 4 -

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

testify that, in her observations and experience as a Vice Detective, after Craigslist closed 

its “adult services” section in 2010, the vast majority of online prostitution activity 

migrated to Backpage. After that, and through 2018, almost all of Detective Decouflé’s 

online prostitution investigations involved ads posted on Backpage. 

Detective Decouflé will testify about terminology often used in the prostitution 

industry, including, but not limited to prostitution code words and emojis. Some examples 

of prostitution code words include, but are not limited to, in call/out call, roses, GFE, and 

100% independent. Detective Decouflé will testify that posters engaged in techniques to 

avoid detection by law enforcement. One example was to list a telephone number as a 

combination of words and numbers, to make it less searchable. 602-123-4567 would 

become 6o2-one-23-4-5-six 7. Another example would be to include in the ad, “by 

contacting me you agree you are not affiliated with any kind of law enforcement,” “all 

donations are for time and companionship only anything else that may occur is between 

two consenting adults,” or “any cash exchanged is for companionship.” These words, 

phrases and emojis are commonly observed on Backpage ads, and Detective Decouflé’s 

testimony would assist the jury in understanding the evidence. 

Detective Decouflé has not authored any publications in the previous 10 years. 

Within the previous four years, Detective Decouflé testified as an expert witness in child 

sex trafficking in State of Arizona v. William McElroy Jr.

4

, CR2018-002562-001 in July 

2021 (Superior Court of Maricopa County). The United States provides this information 

out of an abundance of caution because the United States will be calling Detective Decoufle 

as an expert in prostitution and not child sex trafficking. The United States has provided 

//

(Doc. 1347 at 4-5.) 

4 Detective Decouflé was the case agent for this matter and testified as both a fact and expert witness. 

Case 2:18-cr-00422-DJH Document 1627 Filed 07/03/23 Page 5 of 6
- 5 -

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

the defense with Detective Decouflé’s curriculum vitae, which lists cases where she has 

testified both as a fact and expert witness. (Doc. 422, Exhibit E.) 

I, Christi Decouflé, have read and approved the contents of this disclosure regarding my 

anticipated testimony in the above captioned matter. 

___________________________ 

Christi Decouflé 

Respectfully submitted this 3rd day of July, 2023.

GARY M. RESTAINO 

United States Attorney 

District of Arizona 

KENNETH POLITE 

Assistant Attorney General 

Criminal Division, U.S. Department of Justice 

 s/Margaret Perlmeter 

KEVIN M. RAPP 

MARGARET PERLMETER 

PETER KOZINETS 

ANDREW STONE 

DANIEL BOYLE

Assistant U.S. Attorneys 

AUSTIN M. BERRY 

Trial Attorney 

CERTIFICATE OF SERVICE 

I hereby certify that on July 3, 2023, I electronically transmitted the 

attached document to the Clerk’s Office using the CM/ECF System for filing and 

transmittal of a Notice of Electronic Filing to the CM/ECF registrants who have entered 

their appearance as counsel of record. 

s/ Daniel Parke

Daniel Parke

U.S. Attorney’s Office 

Case 2:18-cr-00422-DJH Document 1627 Filed 07/03/23 Page 6 of 6