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

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

United States of America,

Plaintiff,

vs.

Michael Lacey, et al.,

 Defendants.

CASE NO. 2:18-cr-00422-PHX-DJH

DECLARATION OF DANIEL J. 

QUIGLEY

Pursuant to 28 U.S.C. § 1746, I, Daniel J. Quigley, declare as follows:

1. My name is Daniel J. Quigley. 

2. I am over the age of eighteen (18) years and competent to make this declaration. 

I make this declaration based on my personal knowledge. The facts stated in this declaration 

all are true and correct and, if called to testify, I would and could competently testify as set 

forth below.

3. Throughout 2017, I was a partner with the law firm of Rusing Lopez & Lizardi, 

PLLC (“RLL”). In mid-2018, I left RLL and since then have been with the firm of Daniel J. 

Quigley, PLC. 

4. During my time with RLL, I did extensive work for Medalist Holdings, Inc. 

(“Medalist”) and its subsidiaries (including Cereus Properties, LLC) and was the lawyer with 

principal responsibility for that client relationship.

5. My work for Medalist in 2017 included assisting with the defense of James 

Larkin and Michael Lacey, who were officers and directors of Medalist, in litigation in the 

California Superior Court in Sacramento County captioned People of the State of California

v. Carl Ferrer, Michael Lacey, and James Larkin, Case No. 16FE024013 (the “second 

California criminal case”).

Case 2:18-cr-00422-DJH Document 1871-1 Filed 10/18/23 Page 1 of 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

DANIEL J.

QUIGLEY, PLC

5425 E. Broadway Boulevard, Suite 352

Tucson, Arizona 85711

Telephone: (520) 867-4430

6. From the outset of the second California criminal case in 2016 through today, 

I have represented only Medalist and its officers and directors in connection with that 

litigation. I never represented Carl Ferrer, or any entities that he owned or controlled, in 

connection with the second California criminal case.

7. During 2017, my work for Medalist also included assisting with the defense of

more than a dozen civil lawsuits around the country that were filed against Medalist and/or 

some of its officers and directors. With one exception, which I’ll discuss below, I represented

only Medalist and its officers and directors in connection with those litigation matters. 

Backpage.com, LLC. and/or Carl Ferrer also were parties to each of those litigation matters. 

With the one exception I’ll discuss below, I did not represent Backpage.com, LLC. and/or 

Carl Ferrer in those litigation matters. 

8. One of those civil suits was Sojourner Center v. Backpage.Com LLC; et al. in 

the United States District Court for the District of Arizona, Case No. 2:17-cv-00399-GMS

(the “Arizona civil suit”). The Arizona civil suit was filed in February 2017 and was 

dismissed in July 2017. 

9. Sojourner Center, a non-profit organization providing shelter, support, 

counseling, and care to survivors of domestic violence, claimed that it had to expand its 

missions to provide support and shelter to trafficking victims and sought injunctive relief 

and to recover damages. In the Arizona civil suit, I served as local counsel for the 

defendants, including Michael Lacey, James Larkin, John E. Brunst, Scott Spear, their 

companies Medalist Holdings, Inc. and Camarillo Holdings, LLC, and Carl Ferrer and 

various entities he then owned and controlled. Mr. Ferrer was one of the numerous parties I 

briefly represented in the Arizona civil suit, but that joint representation of Mr. Ferrer was 

the only time I ever represented Mr. Ferrer and I never served as his “personal counsel.”

Case 2:18-cr-00422-DJH Document 1871-1 Filed 10/18/23 Page 2 of 3
Case 2:18-cr-00422-DJH Document 1871-1 Filed 10/18/23 Page 3 of 3