PICCARRETA DAMS KEENAN FIDEL PC

LAWYERS

MICHAEL L. PICCARRETA

JEFFER50N KEENAN

LOUIS S. FIDEL

2 EAST CONGRESS STREET, SUITE 1000

TUCSON, RRIZQNA 85701

(5 ~0) 62Z-6800

FAX <5Z0) 622-0521

BARRY M. DRVIS

(1848-ZO 16)

~_ ~ _ ~~ ~

May 1, 2018 WWW.PD-LAW.COM

Dominic Lanza (Dominic.Lanza{a7usdoj~ov)

Kevin Rapp (Kevin.Rapp(a,usdo~~ov)

United States Attorney's Office

Two Renaissance Square

40 N. Central Avenue, Ste. 1200

Phoenix, AZ 85004-4408

Re: United States v. Lacey, et al.

Dear Dom and Kevin:

I have been asked by the defendants to request early production by the government of the

following categories of documents as soon as possible so that they can be made part of the record in

regards to the government's motion for disqualification. These requested docwnents, which are attached

to this letter, are necessary in order to properly prepare the response and also prepare whatever related

motions need to be filed and heard with the government's motion. I would hope that we could receive

some or all of whatever records can be gathered together as quickly as possible.

I am willing to modify my request for ease of production or clarify it if you have any questions.

MLP:mh

Enclosure

cc: Tom Bienert (via email: tbienert(a),bmkattorneys.com}

Paul Cambria {via email: pcambria,~n,lglaw.coin)

Bruce Feder (via email: bf nci,federlawpa.com; fl cr,federlawPa.com)

Mike Kimerer (via email: mclk(a~kimerer.com)

Gary Lincenberg (via email: ~a,sl~,birdmarella.conn)

KC Maxwell (via email: kmaxwellnb~xfzm.com)

Steve Weiss (via email: sweiss(a~,karpweiss.com)

Case 2:18-cr-00422-DJH Document 202-1 Filed 06/28/18 Page 1 of 3
LIST OF DOCUMENTS

1. All communications between the USAO or any other governmental law

enforcement authorities and Cari Ferrer or his counsel concerning DWT's representation

of any Backpage parties (this and all of the following requests include any and all

communications between Carl Ferrer, his counsel, or any other government

representative),

2. All documents including engagement letters, common interest or joint

defense agreements or related communications among counsel, parties or others related to

joint representation or defense of Backpage parties that have been provided to the

government by Mr. Ferrer or his counsel.

3. All communications with Mr. Ferrer or his counsel about representation or

putative conflicts of counsel, including all correspondence that has been received from

April 5, 2018, onward.

4. Any documents that reflect the date upon which Mr. Ferrer's counsel first

had communications with the government related to possible cooperation or with the

intention of exploring possible cooperation.

5. All correspondence, documents, writings, tangible or electronic, that were

provided by the law firm of Clarence Dyer &Cohen {CDC) to any representative of the

government in relation to the criminal and civil resolution of the legal issues relating to

Carl Ferrer, Backpage, or any of its related entities.

6. Any correspondence, documents, writings, tangible ar electronic, that were

provided to any govermnent representatives by the law arm of CDC in relation to the

criminal and civil resolution of the legal issues relating to Carl Ferrer, Backpage, or any of

its related entities.

7. All reports, FBI Form 302s, or other memoranda prepared by the USAO or

any federal law enforcement agency relating to information provided by Carl ~ errer or his

legal counsel to the government relating to the entering of a negotiated civil and/or criminal

agreement or provided to the government subsequent to entering into a plea agreement.

8. All written agreements between Carl Ferrer, Backpage, or any related entities

and the government, or any of its cooperating governmental entities relating to the

investigation of Mr. Ferrer, Backpage or any of its related entities that have not previously

been provided.

9. Any notes, memoranda, or summaries of any oral conversafiions or telephone

calls between any representative of the government and any representatives of CDC or Carl

Case 2:18-cr-00422-DJH Document 202-1 Filed 06/28/18 Page 2 of 3
Ferrer related to the negotiated civil and/or criminal resolution of the legal issues relating

to Carl Ferrer, Backpage, ar any of its related entities, whether prior or subsequent to the

negotiated resolution of these matters.

10. Copies of any tapes or electronic memorialization of any conversations,

interviews, discussions with the law firm of CDC or Carl Ferrer related to the negotiated

resolution of the case or subsequent to the negotiated resolution of the case.

1 1. Any written or recorded statements or testimony provided by Carl Ferrer

about the operations of Backpage, or any of its related entities, or any of the defendants.

12. All communications with the USAO or any other government authorities to

and from lawyers representing plaintiffs in litigation against Backpage, its employees, or

related entities.

Case 2:18-cr-00422-DJH Document 202-1 Filed 06/28/18 Page 3 of 3