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IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA

United States of America,

 Plaintiff,

vs.

Michael Lacey, et al., 

 

 Defendants.

NO. CR-18-00422-PHX-SPL (BSB)

CERTIFICATE OF PAUL J. CAMBRIA,

JR., IN SUPPORT OF DEFENDANTS’

MOTION FOR DISCLOSURE OF

DOCUMENTS RELATED TO

PRETRIAL SEIZURE OF

DEFENDANTS’ ASSETS

STATE OF NEW YORK )

COUNTY OF ERIE ) ss.:

CITY OF BUFFALO )

Paul J. Cambria, Jr., Esq., being duly sworn, certifies that:

1) I am an attorney at law duly licensed to practice in the State of New 

York and am a partner in the law firm of Lipsitz Green Scime Cambria LLP, located at 42 

Delaware Avenue, Suite 300, Buffalo, New York, attorneys for Defendant Michael Lacey. I 

was admitted to this Court pro hac vice for the instant prosecution.

Case 2:18-cr-00422-DJH Document 141-1 Filed 05/11/18 Page 1 of 3
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2) I make this certificate based on personal knowledge and in support of 

Defendants’ Motion for Disclosure of Documents Related to Pretrial Seizure of Defendants’ 

Assets (“Defendants’ Motion”).

3) As set forth in greater detail in the Memorandum of Points and 

Authorities in Defendants’ Motion, Defendants have requested the government to provide 

Defendants with prompt disclosure of the documents upon which the government relied to 

seek the pretrial seizure of Defendants’ assets.

4) Initially, the government declined Defendants’ request on the ground 

that the documents Defendants sought were subject to a sealing order. More recently, the 

government has stated that it would promptly provide bank records the government used to 

trace Defendants’ assets, but would not be able to provide the requested seizure warrants, 

warrant applications, and forfeiture orders and earlier than the end of this month, which is 

nearly two months after the assets were seized.

5) I have personally consulted with the government in a good faith and 

sincere effort to resolve this discovery dispute without the filing of a motion.

6) Unfortunately, the parties have reached an impasse and are unable to 

reach a satisfactory resolution of Defendants’ discovery demand. In light of this impasse, it 

was necessary to file Defendants’ Motion with this Court.

7) I therefore certify, pursuant to LRCrim 12.1 and LRCiv 7.2(j), that after 

personal consultation and sincere efforts to do so, counsel have been unable to satisfactorily 

resolve this matter.

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DATED: May 11, 2018 Respectfully Submitted,

LIPSITZ GREEN SCIME CAMBRIA LLP

/s/ Paul J. Cambria, Jr.

PAUL J. CAMBRIA, JR.

Attorneys for Defendant Michael Lacey

Sworn to before me this 

11th day of May, 2018.

s/ April Kelly

Commissioner of Deeds

In and For the City of Buffalo, N.Y.

My Commission expires December 31, 2018

Case 2:18-cr-00422-DJH Document 141-1 Filed 05/11/18 Page 3 of 3