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ELIZABETH A. STRANGE

First Assistant United States Attorney

District of Arizona

KEVIN M. RAPP (Ariz. Bar No. 14249, 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)

JOHN J. KUCERA (Cal. Bar No. 274184, john.kucera@usdoj.gov) 

Assistant U.S. Attorneys

40 N. Central Avenue, Suite 1800

Phoenix, Arizona 85004-4408

Telephone (602) 514-7500

BRIAN BENCZKOWSKI 

Assistant Attorney General

Criminal Division, U.S. Department of Justice

REGINALD E. JONES (Miss. Bar No. 102806, reginald.jones4@usdoj.gov) 

Senior Trial Attorney, U.S. Department of Justice

Child Exploitation and Obscenity Section 

950 Pennsylvania Ave N.W., Room 2116

Washington, D.C. 20530

Telephone (202) 616-2807 

Attorneys for Plaintiff

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

United States of America,

Plaintiff, 

vs. 

Michael Lacey, et al.,

Defendants.

CR-18-00422-PHX-SPL (BSB) 

UNITED STATES’ NOTICE OF 

EXPERT WITNESSES

Pursuant to Rules 702, 703, 704 and 705, Fed. R. Evid., the following witnesses 

may give testimony that might be construed as falling within the purview of these rules of 

evidence. Through discovery and subsequent disclosures, specific reports and analyses 

have been or will be directed to defense counsel regarding the specific nature of the 

expected testimony, if any, to be given by these individuals. To the extent not previously 

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disclosed in discovery, subsequent disclosures to defense counsel will isolate the reports, 

analyses, summaries and other findings associated with any potential expert testimony. 

This notice is meant merely as a broader initial overview of the individuals and subjects 

the government may seek to present evidence of by way of expert testimony.

1. J. Patrick Cullen, Special Agent, Federal Bureau of Investigations and Mathew 

Frost, Information Technology Specialist Forensic Examiner (“ITS-FE”)

Special Agent Cullen and Mr. Frost will testify as to how the computer evidence 

and electronic data were downloaded for analysis. Special Agent Cullen and Mr. Frost

were responsible for acquiring and analyzing certain computer evidence from servers and 

devices obtained from Backpage.com and also personal digital devices obtained from some 

of the Defendants. They will testify as to the forensic protocols and tools they implemented 

to analyze the hard drives and other electronic devices. Their curricula vitae are attached 

as Exhibits A & B.

2. Quoc Thai, Special Agent, Internal Revenue Service: Financial Analyst and 

Virtual Currency Expert

Special Agent Thai is a financial analyst, expert in virtual currency, and special 

agent with the Internal Revenue Service, Criminal Investigation Division. Special Agent 

Thai will testify about (1) the financial structure of Backpage and its various corporate 

entities and (2) Backpage’s use of various payment systems to include virtual currency.

Special Agent Thai will explain the how the financial records show the flow of funds 

to and from various entities and financial institutions over the past decade, and how the 

funds were expended and transferred from Backpage accounts domestically and 

internationally. Special Agent Thai will also testify about: (1) centralized and 

decentralized virtual currencies (i.e., bitcoin, bitcoin cash); (2) the sale or exchange of 

virtual currencies; (3) the use of virtual currencies to pay for goods or services: (4) the 

anonymity the use of virtual currency provides; (5) the mechanics of transferring virtual 

currency from wallet to wallet or person to person; (6) the identification of origination and 

destination addresses through analysis of the blockchain code; (7) the price fluctuation over 

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time of virtual currency, and the conversion and exchange of virtual currency to a “fiat 

money system” or “fiat currency system” or simply put, regular currency. Special Agent 

Thai will explain Backpage’s use of virtual currency and how the money flowed through 

its various domestic and international entities. Additionally, Special Agent Thai will 

explain Backpage’s use of third party payment processors, who processed and received 

customer payments originating from virtual currency payments, credit card payments, 

check & money order payments, and gift card payments. Special Agent Thai will further 

explain how these payments flo from purchasers of Backpage advertisements and follow 

their flow to the accounts and purchase of assets by Backpage and Backpage officers and 

owners.

Special Agent Thai’s opinion will be based on his education, training, and 

experience as a Special Agent. The financial records and documents underlying Special 

Agent Thai’s testimony has been provided to the defense in discovery; the summary 

analyses will be provided through supplemental disclosures. Special Agent Thai’s 

curriculum vitae is attached as Exhibit C.

3. Donald Ellsworth, Special Agent, Internal Revenue Service: Virtual Currency 

Expert

Special Agent Donald Ellsworth will testify about virtual currency, encrypted 

communications, Bank Secrecy Act requirements, and undercover operations involving 

virtual currency. Special Agent Ellsworth will testify about: (1) how the movement of 

legal and illegal proceeds in the form of bitcoin or other forms of virtual currency can be 

applied to federal money laundering statutes and bank secrecy laws; (2) how bitcoin and 

other forms of virtual currency can be obtained and used to pay for goods or services; and 

(3) the anonymity provided with the use of virtual currency. 

Special Agent Ellsworth will also testify about virtual currency in general, how it is 

acquired, exchanged, used to purchased goods or services; how transactions can be traced 

through analysis of the blockchain code; and the value of virtual currency and how it is 

converted and exchanged into a fiat money system, or regular currency. Special Agent 

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Ellsworth’s opinion will be based on his education, training, and experience as a Special 

Agent; including the courses and seminars has attended and taught through his work with 

the IRS. Special Agent Ellsworth curriculum vitae is attached as Exhibit D.

4. Detective Christina Decouflé, Phoenix Police Department: Human Trafficking 

Expert

Detective Decouflé will provide testimony at trial about how human trafficking, 

with a focus on sex trafficking occurs, and how it occurs through online media, such as 

social networking websites, applications, and the internet in general. Detective Decouflé

has been a law enforcement officer with the Phoenix Police Department since 2000. In 

2005, she became a detective in the Vice Enforcement Unit. In 2013, Detective Decouflé

became a member of the Federal Bureau of Investigation, Human Trafficking Task Force, 

Phoenix Division. The Ninth Circuit has affirmed the expert testimony of Detective 

Decouflé in the area of human trafficking and this court should permit Detective Decouflé

to testify as to her expert opinions here. See United States v. Brooks, 610 F.3d 1186, 1195-

96 (9th Cir. 2010).1 

Detective Decouflé will describe how sex trafficking and prosecution industries 

have changed with the advent of the internet, including websites such as 

www.craigslist.com, www.backpage.com, and others. Detective Decouflé will describe 

how law enforcement conducts human trafficking investigations; with a focus on how 

investigations shifted from craigslist.com to backpage.com. She will testify about her 

knowledge of The Erotic Review (TER), it’s owner David Elms, and TER’s connection to 

websites such as craigslist.com and backpage.com. Detective Decouflé will describe how 

she posted advertisements on online websites like craigslist.com and backpage.com 

advertising herself (undercover) as seller of commercial sex. She will compare and 

contrast how different prostitution websites (including craigslist and backpage) operated 

 

1 At the time of Detective Decouflé’s testimony in United States v. Brooks she went 

by the surname Hein. In between, she also went by the surname Bill. 

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and how they responded to law enforcement. She will also testify about descriptors and 

definitions of terms often used in sex trafficking and the prostitution industry, such as 

“trick,” “John,” “pimp,” “the game,” “dates,” “choosing up,” as examples. Lastly, 

Detective Decouflé will discuss the relationship between sex traffickers and pimps and 

their victims. She will describe the methods and process traffickers and pimps utilize to 

entice, coerce, or control their victims. 

The bases and reasons for the opinions summarized above centers around Detective 

Decouflé’s extensive experience conducting sex trafficking investigation. Detective 

Decouflé has an extensive experience interviewing prostitutes, pimps, and individuals who 

solicit commercial sex and has herself has engaged in numerous investigations requiring 

knowledge of the methods that sex traffickers and pimps utilize, whether through online 

media or through face-to-face contact, to recruit women into prostitution. Detective 

Decouflé has interviewed hundreds of victims and survivors, which enables her to 

understand the particular language and methods utilized in the prostitution industry. 

Detective Decouflé’s curriculum vitae is attached as Exhibit E. The government 

will also separately provide the defense with copies of transcripts where Detective 

Decouflé has testified in both state and federal court, as an expert in the area of human 

trafficking. 

5. Dominique E. Roe-Sepowitz, M.S.W., Ph.D.: Sex Trafficking Expert

Dr. Roe-Sepowitz is expected to testify as a fact witness in this matter, regarding 

her interactions with Backpage, the National Center of Missing and Exploited Children 

(NCMEC), human sex trafficking prevention and outreach groups in relation to Backpage 

related prostitution advertising, as well as Backpage related interactions with state and 

federal law enforcement. In an abundance of caution, however, the government provides

notice identifying Dr. Roe-Sepowitz as a potential “expert” in the area of human 

trafficking, specifically, sex trafficking. 

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Dr. Roe-Sepowitz is an Associate Professor in the School of Social Work at Arizona 

State University. She is the director of the Office of Sex Trafficking Intervention Research 

at Arizona State University. Dr. Roe-Sepowitz’s area of specialty and expertise is in 

human sex trafficking with juveniles and adults, with an aim on prevention and awareness, 

intervention and treatment. 

Dr. Roe-Sepowitz can testify about her research in the area of human sex trafficking. 

Specifically and recently, Dr. Roe-Sepowitz participated in (1) a six year analysis of sex 

trafficking of minors: exploring characteristics and sex trafficking patterns; (2) a Las Vegas 

based study on how violence is often tied to teen sex trafficking; and (3) a Hawaii based 

study exploring online sex buyers in Hawaii. Dr. Roe-Sepowitz has also researched the 

impact the Super Bowl had on sex trafficking. Dr. Roe-Sepowitz’s research can be found 

at https://socialwork.asu.edu/stir/research. While the government intends for Dr. RoeSepowitz to testify as a fact witness at trial, her education, training, and experience, could 

lead one to believe that she is an expert in the area of human sex trafficking. 

Dr. Roe-Sepowitz’s curriculum vitae is attached as Exhibit F. The government will 

also separately provide the defense with copies of several articles Dr. Roe-Sepowitz has 

authored or co-authored, in the area of human trafficking, which will further explain the 

nature, breadth and foundation of her testimony. 

6. Sharon W. Cooper, M.D.: Sex Trafficking Expert 

Dr. Cooper will testify about (1) how a victim can fall into the world of sex 

trafficking, through the grooming process, force, or abduction, etc. and why certain victims 

may be targeted; (2) the harmful, lasting impact sex trafficking can have on its victims, 

primarily child victims; (3) the relationship and loyalty a child sex trafficking victim may 

have and show towards her trafficker; (4) common ways a sex trafficker can use force, 

fraud, and coercion to maintain control over his victims; (5) reasons why child sex 

trafficking is cited as the most underreported form of child abuse; and (6) the role Backpage 

played in the victimization of her patients and clients. 

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Dr. Cooper is a developmental and forensic pediatrician who evaluates and treats 

children who have been victims of all forms of abuse, with a primary area of expertise in 

sexual exploitation. She is a member of the Board of Directors for the National Center for 

Missing and Exploited Children and a retired Colonel with the United States Armed Forces. 

Dr. Cooper has testified before the United States Congress, the Russian Parliament, the 

Italian Senate and the European Commission on child sexual exploitation. She has also 

testified as an expert medical witness in over two dozen federal trials. Dr. Cooper is 

familiar with how victims were trafficked on Backpage and her opinions will be based on 

her education, training, and her clinical and forensic experiences treating victims of sex 

trafficking. Dr. Cooper’s curriculum vitae is attached as Exhibit G. 

7. James E. Hardie, Supervisory Special Agent, Federal Bureau of Investigation: 

Human Trafficking Expert 

Supervisory Special Agent James E. Hardie will testify about (1) terminology 

commonly used in the sex trafficking, such as pimp, “bottom bitch,” MOB (money over 

bitches), “date,”, “roses” (money), “the game”, etc.; (2) common dynamics between sex 

traffickers and their victims and how a trafficker may use drugs, force, fraud, and coercion 

to maintain control over their victims; (3) how human trafficking takes place in our 

communities from a law enforcement prospective; and (4) the role the internet and 

Backpage played in his knowledge and understanding of human trafficking and how 

Backpage became part of the law enforcement investigations for human trafficking over 

the years. 

Supervisory Special Agent Hardie began investigating sex trafficking cases 

involving both minor and adult victims in 2008, which has resulted in his experience in 

interviewing hundreds of victims and witnesses and two dozen pimps or traffickers. From 

2008 – 2013, Agent Hardie served as the coordinator of the FBI’s Violent Crimes Against 

Children Task Force in Ohio. From 2013 – 2015, he served as the FBI’s representative to 

the National Center for Missing and Exploited Children (NCMEC), where he coordinated 

sex trafficking reporting between NCMEC and the FBI child exploitation task forces. 

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Since 2011, Supervisory Special Agent Hardie has presented or provided instruction at 

conferences and seminars, internationally and domestically, in the area of sex trafficking. 

Supervisory Special Agent Hardie’s opinions are based on his training and 

experience in the area of human sex trafficking. Supervisory Special Agent Hardie has 

testified as an expert in sex trafficking in both state and federal court and has testified 

before the Ohio House of Representative Judiciary and Ethics Committee regarding sex 

trafficking matters. Supervisory Special Agent Hardie’s curriculum vitae is attached as 

Exhibit H. 

8. Derek Stigerts, Investigator, Sacramento District Attorney’s Office: Human 

Trafficking Expert 

Investigator Stigerts will testify about (1) how sex trafficking occurs; (2) common 

terminology used by individuals involved in sex trafficking; (3) the role of the internet and 

technology in human trafficking; (4) methods of recruitment, manipulation, and control by 

a trafficker with his victims; and (5) the role the internet and Backpage has played in human 

trafficking. 

Investigator Stigerts has been involved in the investigation of human trafficking 

offenses for over a decade. Investigator Stigerts has interviewed over 300 females involved 

in prostitution, including 80 juvenile victims, as well as over 30 suspected pimps or 

traffickers. He has presented at instructional courses presented by NCMEC and the FBI. 

Investigator Stigerts’ opinions are based on his training and experience in the area of 

human sex trafficking. Investigator Stigerts has testified as an expert in sex trafficking in 

various state and federal court all over the United States and his curriculum vitae is attached 

as Exhibit I. 

9. Shannon Wolf, Ph.D., LPC-S: Human Trafficking Expert 

Dr. Wolf will testify about the connection between trauma bonds and personal 

identity in victims of sex trafficking and how to understand them, including ways to 

interact with child sex trafficking victims to avoid secondary trauma, and the role Backpage 

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has played in causing trauma to victims trafficked through its website. Dr. Wolf is a 

licensed professional counselor with supervisory status and a Professor of Psychology and 

Counseling at B.H. Carroll Theological Institute. Dr. Wolf’s provides counseling and 

therapy to victims of sex trafficking and her current research focus is on child sex 

trafficking. She has previously testified as an expert in sex trafficking. Dr. Wolf’s 

curriculum vitae is attached as Exhibit J. 

10. Staca Shehan, Executive Director Case Analysis Division, NCMEC

Ms. Shehan is a fact witness as she met on several occasions with Backpage 

Defendants. Ms. Shehan is the Executive Director of the Case Analysis Division at the 

National Center for Missing and Exploited Children (NCMEC). As a result of her 

employment, Ms. Shehan’s testimony will cover topics that could be perceived as expert 

testimony. In an abundance of caution, the government provides notice identifying Ms. 

Shehan as a potential “expert” in the area of human trafficking, sex trafficking, and child 

exploitation. 

Specifically, Ms. Shehan will testify to the creation of a dedicated Child Sex 

Trafficking Team at NCMEC to respond to the increased need for technical assistance and 

analysis in cases involving child sex trafficking. These unique resources include analysis 

of potential suspect names or aliases, unique tattoos, link analysis about child sex 

trafficking victims/potential victims, telephone numbers, addresses and/or link analysis 

about child sex trafficking victims/potential victims, telephone numbers, addresses and/or 

online postings.

The government reserves the right to question the expert regarding other matters 

that may be raised during cross-examination by Defendants, based upon testimony 

provided by defense experts (if any), or other witnesses and evidence introduced by 

Defendants. This disclosure of the government’s notice of expert witnesses also serves as 

the government’s request for notice of rebuttal or expert testimony by Defendants, pursuant 

to Rule 16 of the Federal Rules of Criminal Procedure. The government requests the 

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Defendants provide the government with a written summary of testimony Defendants 

intend to present at trial pursuant to Federal Rules of Evidence 702, 703, and 705, and this 

Court’s scheduling order (CR 131.) 

Respectfully submitted this 14

th day of December, 2018.

ELIZABETH A. STRANGE

First Assistant United States Attorney

District of Arizona

BRIAN BENCZKOWSKI 

Assistant Attorney General

Criminal Division, USDOJ

REGINALD E. JONES

Senior Trial Attorney

U.S. Department of Justice, Criminal Div.

Child Exploitation and Obscenity Section

s/ Kevin M. Rapp_____

KEVIN M. RAPP

MARGARET PERLMETER

PETER S. KOZINETS

ANDREW C. STONE

JOHN J. KUCERA

Assistant U.S. Attorneys

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Certificate of Service

I hereby certify that on this date, December 14, 2018, 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 following CM/ECF registrants: Paul J. 

Cambria Jr. Esq. and Erin E. McCampbell, Esq., Lipsitz Green Scime Cambria, LLC, 

Thomas H. Bienert, Jr., Esq., Anthony R. Bisconti, Esq., Kenneth M. Miller, Esq., and 

Whitney Bernstein, Esq., Bienart, Miller & Katzman, PLC, Mike Piccarreta, Esq., Jim 

Grant Esq., Davis Wright Termaine, LLP, Michael D. Kimerer, Esq. and Rhonda Elaine 

Neff, Esq., Steve Weiss Esq., Robert Corn-Revere Esq., Bruce Feder, Esq., Gary 

Linenberg, Esq., Ariel Neuman, Esq., Gopi K. Panchapakesan.

s/ Angela Schuetta

U.S. Attorney’s Office

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