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Timothy J. Eckstein, 018321

Joseph N. Roth, 025725

Sarah P. Lawson, 036436

OSBORN MALEDON, P.A.

2929 North Central Avenue, 20th Floor

Phoenix, Arizona 85012-2793

(602) 640-9000

teckstein@omlaw.com

jroth@omlaw.com

slawson@omlaw.com

Attorneys for James Larkin

Additional counsel on following pages

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

United States of America,

Plaintiff,

vs.

Michael Lacey, et al.,

Defendants.

Case No. 2:18-cr-00422-PHX-DJH

DEFENDANTS’ REPLY IN 

SUPPORT OF MOTION FOR 

RECONSIDERATION

Case 2:18-cr-00422-DJH Document 1630 Filed 07/06/23 Page 1 of 16
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Paul J. Cambria, Jr. (NY 15873, admitted pro hac vice)

Erin E. McCampbell (NY 4480166, admitted pro hac vice)

LIPSITZ GREEN SCIME CAMBRIA LLP

42 Delaware Avenue, Suite 120

Buffalo, New York 14202

(716) 849-1333

pcambria@lglaw.com

emccampbell@lglaw.com

Attorneys for Michael Lacey

Bruce S. Feder (AZ 004832)

FEDER LAW OFFICE PA

2930 E. Camelback Rd., Suite 160

Phoenix, Arizona 85016

(602) 257-0135

bf@federlawpa.com

Eric Walter Kessler

KESSLER LAW OFFICE

6720 N. Scottsdale Rd., Suite 210

Scottsdale, Arizona 85253

(480) 644-0093

Eric.kesslerlaw@gmail.com

Attorneys for Scott Spear

Gary S. Lincenberg

Ariel A. Neuman

Gopi K. Panchapakesan

BIRD, MARELLA, BOXER, WOLPERT, NESSIM,

DROOKS, LINCENBERG & RHOW P.C.

1875 Century Park E., Suite 2300

Los Angeles, California 90067

(310) 201-2100

glincenberg@birdmarella.com

gpanchapakesan.@birdmarella.com

aneuman@birdmarella.com

Attorneys for John Brunst

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David S. Eisenberg

DAVID EISENBERG PLC

3550 N. Central Ave., Ste. 1155

Phoenix, Arizona 85012

(602) 237-5076

david@eisenbergplc.com

Attorneys for Andrew Padilla

Joy Malby Bertrand

JOY BERTRAND ESQ LLC

P.O. Box 2734

Scottsdale, Arizona 85252

(480) 656-3919

joyous@mailbag.com

Attorneys for Joye Vaught

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Defendants’ motion to dismiss (Doc. 1557) hinged on the argument that the crime 

of “promoting” or “facilitating” someone else’s business enterprise involving prostitution 

offenses under the Travel Act is an aiding and abetting offense. Rejecting that view, the 

Court ruled that the Superseding Indictment (SI) need not allege the elements of aiding 

and abetting to state an offense under the Travel Act. Doc. 1587. Defendants moved for

reconsideration based on the Supreme Court’s subsequent opinion in United States v. 

Hansen, 599 U.S. __, 2023 WL 4138994 (2023), which provides a basis for the Court to 

revisit its conclusions that a charge of “promoting” or “facilitating” the prostitution 

offenses of third parties need not allege the essential elements of aiding and abetting, 

including that defendants intended “the specific and entire” underlying offense and that 

“the underlying offense has been committed,” even if defendants were not principals in 

the underlying crime.

The government argues that Hansen has no bearing on the Travel Act, as the 

decision does not discuss the Travel Act directly or its pleading requirements. That 

assertion is belied by the government’s position in the Woodhull appeal, where it promptly 

alerted the D.C. Circuit to Hansen, arguing that the terms “promote” and “facilitate” in 

FOSTA “are used in accord with their specialized criminal-law meanings for the same 

reasons discussed by the Court in Hansen.” See Exhibit A. Of course, as defendants’ 

motion to dismiss discussed, the government also has argued in Woodhull that the terms 

“promote” or “facilitate” under the Travel Act are “equivalent to” aiding and abetting and 

that the terms “promote” or “facilitate” in FOSTA should be construed as they are in the 

Travel Act.

The government cannot contend in Hansen and Woodhull that criminal-law terms 

used in federal criminal statutes must be construed in accordance with their specialized 

criminal-law meanings, which constrain the scope of liability under those statutes, but here 

argue that those same criminal-law terms should be construed in accordance with their 

ordinary (and much broader) meanings. Regardless, Hansen confirms that the 

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government’s position in Woodhull is correct: “whatever meaning ‘promote’ or ‘facilitate’ 

might have in everyday speech, their meaning as terms of art in criminal statutes, invoking 

traditional principles of accomplice liability, is established.” Doc. 1557-1 at 46.

The Court should reconsider its decision because Hansen confirms that 

“facilitating” is the same as “aiding and abetting,” and the SI fails to include allegations 

sufficient to establish that each defendant specifically intended to aid and abet the 

purportedly unlawful business enterprises involving prostitution offenses that supposedly 

were facilitated by the publication of the fifty ads that are the basis of the Travel Act 

charges. See SI ¶¶ 196a, 200 (describing offense as “Travel Act – Facilitate Prostitution”). 

For the reasons set forth in the Motion to Dismiss and the Reply, the SI does not allege 

the essential elements of those offenses, or the related conspiracy charge, in violation of 

defendants’ Fifth Amendment rights.

A. After Hansen, the government cannot credibly argue that “promote” and 

“facilitate” mean something other than “aid and abet” under the Travel Act.

The government argues that Hansen is irrelevant to the Travel Act because the 

opinion does not directly discuss that statute or the word “promote.” The government

goes on to argue that “promote” and “facilitate” under the Travel Act would allow for 

punishment of a wide array of offenses based on the common, non-legal dictionary 

definitions of “promote” and “facilitation of promotion.” See Doc. 1628 at 14-15 (arguing, 

based on dictionary definitions, that a mere “advertisement” of allegedly unlawful activity 

can violate the Travel Act even if there never is any actual underlying unlawful activity). 

The Court should give no weight to this self-serving doublespeak. In Hansen, the 

government successfully argued that when Congress uses certain words (such as 

encourage, induce, solicit, or facilitate) in federal criminal statutes, those words carry with 

them specialized criminal law meanings. The Supreme Court agreed, holding that the 

relevant statute used such terms in their “specialized, criminal-law sense,” not their 

“ordinary,” everyday meanings. 2023 WL 4138994, at *7. As the Court explained, “when 

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Congress borrows terms of art in which are accumulated the legal tradition and meaning 

of centuries of practice, it presumably knows and adopts the cluster of ideas that were 

attached to each borrowed word.” Id. (internal quotation marks and citation omitted).

In Woodhull, the government is pressing the same argument to the D.C. Circuit

about FOSTA and the Travel Act. See Doc. 1557 at 4; Doc. 1557-1 at 41-46. As the 

government puts it in that appeal: “The phrase ‘promote or facilitate’ as used in criminal 

statutes is equivalent to ‘aid or abet.’” Doc. 1557-1 at 41.

The government’s lawyers here not only are making arguments directly contrary to 

those they have pressed in other cases, but the Supreme Court now has adopted the 

government’s position, holding that, when used in federal criminal statutes, terms like 

“facilitate” must be construed using their specialized criminal-law meanings, not their usual

dictionary definitions.

Notably, while the government argued to the D.C. Circuit that the terms “promote” 

and “facilitate” must mean aiding and abetting, see Doc. 1557-1 at 41-46, here the 

government just proposed jury instructions saying “[i]n the context of the Travel Act, the 

term ‘facilitate’ means ‘to make easy or less difficult,’” arguing the term must be “given its 

‘ordinary meaning: to make easy or less difficult,’” Doc. 1626-3 at 135. The SI also 

informed the grand jury that defendants “are charged in this superseding indictment with 

the crimes of facilitating prostitution . . . .” Doc. 230 ¶ 17. Using the government’s 

“ordinary” definition plainly would have allowed the grand jury to indict for conduct falling 

far short of aiding and abetting the specific crimes of specific business enterprises. 

This Court should reject the government’s contrary position here.

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B. The government cites no cases addressing the essential elements that must 

be alleged to indict a non-principal under the Travel Act for facilitating the 

crimes of others. 

The government’s primary argument (at 6-8)1 is that Hansen should be disregarded 

because it does not change Ninth Circuit law outlining the pleading standards for a Travel 

Act violation and that, in general, all the government must do is recite the text of the 

statute. This argument fails because Hansen tells us that the word “facilitate,” when used 

in a federal criminal statute, has a meaning unique to criminal law—not its ordinary 

meaning—and the statutory language of the Travel Act would not have conveyed to the 

grand jury all the necessary elements when a non-principal is alleged to have violated the 

act by facilitating the crimes of others.

An indictment relying on the words of the statute to set forth the offense is only 

sufficient if those words “fully, directly, and expressly, without any uncertainty or 

ambiguity, set forth all the elements necessary to constitute the offense intended to be 

punished.” Russell v. United States, 369 U.S. 749, 765 (1962). Otherwise, “a defendant could 

then be convicted on the basis of facts not found by, and perhaps not even presented to, 

the grand jury which indicted him” in violation of the Fifth Amendment. Id. See also United 

States v. Keith, 605 F.2d 462, 464 (9th Cir. 1979) (reversing conviction where indictment 

tracked the language of statute but nonetheless omitted two essential elements because “an 

indictment is inadequate when it fails to allege an essential element of the offense even 

when it tracks the language of the statute.”); United States v. Outler, 659 F.2d 1306, 1310-11 

(5th Cir. 1981) (“We recognize that an element is not always an ‘essential element’ simply 

because the prosecution carries the burden of proof; however, here the element embodies 

the culpability of the offense. Without behavior beyond professional practice, there is no 

crime. We believe, therefore, that the lack of a legitimate medical reason is as essential to 

the offense charged against Dr. Outler as the requisite mens rea . . . Unless every element 

1 Citations to the government’s opposition at Doc. 1628 are to the ECF-generated page 

number.

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of an offense appears in the indictment, it is impossible to assure the defendant that a 

grand jury properly determined probable cause of the offense.”).

Although numerous courts have held that a charge under the Travel Act that a 

defendant “facilitated” (or “promoted” or “facilitated the promotion” of) his own criminal 

conduct through interstate travel or the use of the facilities in interstate commerce may be 

adequately set forth using the statutory language alone, that is not the case when, as here, 

the government seeks to charge a defendant with facilitating the criminal conduct of 

others. The Travel Act’s text does not “fully, directly, and expressly, without any 

uncertainty or ambiguity set forth all the elements,” Russell, 369 U.S. at 765, required for 

an aiding and abetting offense against a defendant who was not a principal in the 

underlying offense.

The government is wrong when it claims defendants’ interpretation of Hansen 

would “upend[] decades of Travel Act precedent” regarding the sufficiency of a Travel Act 

indictment. The government cites to no authority involving the sufficiency of an 

indictment under the Travel Act where the defendant was charged with facilitating (aiding 

and abetting) a crime in which he was not a principal. The sole exception is United States 

v. Gibson Specialty Co., 507 F.2d 446 (9th Cir. 1974), where the court affirmed the dismissal 

of the indictment.2

Rather, every decision the government cites involved a defendant who was charged 

under the Travel Act with facilitating a crime in which the defendant was a principal. 

Consider the government’s oft-cited United States v. Tavelman, 650 F.2d 1133 (9th Cir. 1981). 

There, the defendants traveled from California to Nevada to buy ten pounds of cocaine, 

were busted in a sting operation, and were charged with conspiracy to possess cocaine with 

intent to distribute and a Travel Act violation. The defendants moved to dismiss the 

indictment for failing to allege specific overt acts. The district court denied the motion 

2 The government often charges defendants, under 18 U.S.C. § 2, with aiding and abetting 

the Travel Act offenses of others, but those indictments necessarily must satisfy the 

pleading requirements for aiding and abetting.

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and the Ninth Circuit affirmed, noting that an indictment was sufficient if it “fully, directly, 

and expressly set forth all the elements necessary to constitute the offense intended to be 

proved.” Id. at 1137. The Ninth Circuit said “[a]n indictment under the Travel Act requires 

allegations of each of the three elements of the crime: (1) . . . use of interstate facility (2) 

with intent to promote an unlawful activity and (3) a subsequent overt act in furtherance 

of that unlawful activity.” Id. at 1138. The Ninth Circuit’s holding that the indictment in 

sufficiently alleged the “intent to promote an unlawful activity” where the defendants’ 

interstate travel promoted their own drug-trafficking crime, id. at 1136, says nothing about 

whether the indictment would have sufficiently alleged intent had the defendants been 

alleged to have promoted or facilitated the drug crimes of others. 

The defendants in Tavelman necessarily “participate[d] in a criminal venture with full 

knowledge of the circumstances constituting the charged offense,” Rosemond v. United States, 

572 U.S. 65, 77 (2014), as the underlying offense was their own offense. When a non-principal 

is charged with facilitating someone else’s unlawful activity, however, to “fully, directly, 

and expressly set forth all the elements necessary to constitute the offense intended to be 

proved” the indictment must include allegations sufficient to establish the defendants’ 

specific intent to “aid and abet” the third party’s crime. As Hansen clarified, the words of 

the statute must be “filtered through the elements of solicitation or facilitation,” including, 

“importantly, the requirement . . . that a defendant intend to bring about a specific result,” 

2023 WL 4138994, at *11 (citing Rosemond, 572 U.S. at 76). “What matters for purposes 

of gauging intent . . . is that the defendant has chosen, with full knowledge, to participate 

in the illegal scheme.” Rosemond, 572 U.S. at 79. 

In other words, contrary to the government’s argument, defendants do not contend 

that Hansen swept away decades of precedent or even altered the elements of a Travel Act 

offense. Rather, if the government seeks to indict a defendant under the Travel Act for 

promoting or facilitating the prostitution offenses of a business enterprise, and the 

defendant was not a principal in the unlawful business enterprise, then to establish the 

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requisite intent the indictment also must allege the essential elements of aiding and abetting 

liability to state a valid offense. That is, as Hansen directs, the elements in Tavelman must 

be read as if the word “promote” or “facilitate” was “aid and abet” and the indictment’s 

allegations must be sufficient to establish aiding and abetting.

The numerous cases the government cites involving defendants who were 

principals in the underlying crimes are not contrary and have no relevance to the question 

of the sufficiency of an indictment charging a purported accomplice to the state law 

offenses committed by others: 

• United States v. Childress, 58 F.3d 693, 719 (D.C. Cir. 1995) (rejecting post-conviction 

challenge to the sufficiency of Travel Act charges by defendants who were direct 

and active participants in a major drug trafficking ring and who argued the 

indictment was deficient for failing to allege specific subsequent overt acts)

• United States v. Gordon, 641 F.2d 1281 (9th Cir. 1981) (affirming conviction under 18 

U.S.C. § 371 for conspiracy to violate the Travel Act, and holding that trial court 

properly denied motion for acquittal arguing the indictment was deficient for failing 

to cite the statute comprising the predicate “unlawful activity,” where defendants 

were charged with conspiracy based on placing interstate phone calls and engaging 

in interstate travel to bribe Nevada Gaming Commissioners)

• McIntosh v. United States, 385 F.2d 274 (8th Cir. 1967) (affirming convictions and 

holding trial court properly denied motion to quash the indictment arguing that 

defendants’ unsuccessful extortion attempt could not serve as the underlying 

offense for a Travel Act conviction, where one defendant “brutally assaulted” the 

victim and the other then unsuccessfully sought to extort money from the victim’s 

brother through an interstate telephone call)

• United States v. Montague, 29 F.3d 317 (7th Cir. 1994) (rejecting post-conviction 

challenge to the sufficiency of the evidence supporting conviction for conspiracy 

to violate 18 U.S.C. § 1956(a)(1)(A)(i) (money laundering), where defendant 

operated several escort businesses engaged in prostitution and also personally 

engaged in prostitution)

• United States v. Monu, 782 F.2d 1209 (4th Cir. 1986) (affirming Travel Act conviction 

and holding that trial court properly denied motion for acquittal challenging the 

sufficiency of the evidence, where defendant received five packages of heroin and 

marijuana via international mail)

• United States v. Muskovsky, 863 F.2d 1319 (7th Cir. 1988) (rejecting post-conviction 

challenge to the sufficiency of the evidence supporting Travel Act convictions and 

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to the indictment’s failure to allege specific subsequent overt acts, where defendants 

owned and managed a nude dancing establishment that also offered prostitution 

services)

• United States v. Palfrey, 499 F.Supp.2d 34 (D.C. Cir. 2007) (denying motion to dismiss 

Travel Act counts, where defendant owned and operated a multi-state escort 

business that also offered prostitution services)

• United States v. Polizzi, 500 F.2d 856 (9th Cir. 1974) (affirming Travel Act convictions 

and rejecting challenge to related jury instructions, which were imprecise but 

sufficient, where defendants had been charged with violating the Travel Act by 

owning, operating, and receiving profits from a Las Vegas, Nevada, casino by 

persons who were not licensed by, and whose interest in the casino had been 

concealed from, agencies of the State of Nevada, in violation of Nevada law)

• United States v. Stafford, 831 F.2d 1479 (9th Cir. 1987) (affirming imposition of 

separate, consecutive sentences for convictions under 18 U.S.C. §§ 1510 and 1952, 

where defendant endeavored to bribe a witness to prevent him “from informing 

the FBI” of federal crimes and traveled interstate to do so)

• United States v. Tavelman, 650 F.2d 1133 (9th Cir. 1981) (affirming convictions and 

holding that trial court properly denied motion to dismiss indictment for failing to 

allege specific subsequent overt acts, where defendants travelled interstate 

intending to purchase ten pounds of cocaine)

• United States v. Welch, 327 F.3d 1081 (10th Cir. 2003) (reversing dismissal of 

indictment for failing to state a claim where defendants were alleged to have 

misappropriated funds and then paid $1,000,000 in bribes to International Olympic 

Committee officials)

• United States v. Winslow, 962 F.2d 845 (9th Cir. 1992) (affirming sufficiency of the 

evidence to support Travel Act convictions, where defendants “traveled from 

Hayden Lake, Idaho to Seattle, Washington for the purpose of exploding a bomb 

in a gay bar” (i.e. arson)).

Indeed, the only Travel Act case either party cites where the defendants were not directly 

involved in the underlying unlawful activity is Gibson, 507 F.2d at 446, where, despite its 

unusual procedural posture, the Ninth Circuit affirmed the dismissal of the indictment 

“because neither the defendants’ intention to facilitate nor the defendants’ actual 

facilitation . . . were shown.” Id. at 449.

It is the government that seeks to stretch the Travel Act to cover new ground. But, 

as Hansen makes clear, the crime of “facilitation” cannot be stretched so far. That term has

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longstanding meaning when used in federal criminal statutes and, without allegations 

establishing aiding and abetting, there is no criminal facilitation. For the reasons stated in 

defendants’ Motion to Dismiss, the SI fails to allege the crime of facilitating of “unlawful 

activity” under the Travel Act and, therefore, the related conspiracy charge also fails.

C. Given Hansen, the government’s indictment for “facilitation” is insufficient 

because it does not include the essential elements of aiding and abetting.

The government contends that Hansen should not cause the Court to change its 

earlier conclusion that the government need not allege either that each defendant had the 

specific intent that the particular offense be committed or the commission of an underlying 

offense, but this argument simply fights with the natural consequence of the Supreme

Court’s reasoning in Hansen. If “facilitation” equals aiding and abetting, then the 

indictment necessarily must include the essential components of aiding and abetting—“the 

provision of assistance to a wrongdoer with the intent to further an offense’s commission,” 

including the “intent to bring about a particular unlawful act,” Hansen, 2023 WL 4138994, 

at *6—for it is those elements that distinguish the lawful from the unlawful. This simple 

logic cannot be squared with the Court’s conclusion, for example, that the Travel Act does 

not require an “intent element go to the specific and entire crime charged, as it must in an 

aiding and abetting charge.” Doc. 1587 at 13 (internal quotation marks and citation 

omitted). Hansen’s definition of facilitation (incorporating aiding and abetting elements) 

and this Court’s rejection of the need for those aiding and abetting elements cannot both 

be right.

Indeed, contrary to its self-serving position here, the government acknowledged as 

much in its summary judgment briefing in Woodhull: “§ 2421A, like the Travel Act, is 

structured as an aiding and abetting offense, which also requires specific intent . . . The 

requisite scienter is akin to that required for aiding and abetting under 18 U.S.C. § 2 . . . .” 

Woodhull, Case No. CV 18-1552, Opp. to Pl. Mot. for Summary Judgment (D.D.C., Doc. 

37 at 37). Given Hansen’s reasoning that federal criminal statutes using criminal-law words 

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carry their specialized criminal-law meanings, this Court cannot interpret the Travel Act to 

require a watered-down version of “facilitation” for non-principals nor accept an 

indictment that falls far short of alleging aiding and abetting.

D. The government’s other arguments do not change that the SI does not allege 

the essential elements of aiding and abetting.

The government repeats its argument that nothing more is needed because aiding 

and abetting is implied in every federal criminal offense. But the government’s argument

confuses the issues. Defendants do not dispute that the government could convict for 

aiding and abetting another person’s Travel Act offense under the SI, if the SI properly 

alleged such a substantive offense. But that does not mean that the government has 

properly alleged the substantive offense here when the substantive Travel Act offense 

itself is an aiding and abetting offense. The Court’s original order repeated the 

government’s circular logic, but that conclusion should be revisited considering Hansen’s

clarity about the meaning of “facilitation.” When the substantive offense alleged is itself 

an aiding and abetting offense, as it must be to “facilitate” another’s business enterprise 

state law offenses, the essential elements of aiding and abetting must be alleged in the 

indictment otherwise the grand jury has not authorized an indictment of the crime.

The government also tries to avoid Hansen by arguing that defendants are charged 

as principals under the Travel Act. That misses the fundamental point: the substantive 

charges allege that defendants facilitated the state law prostitution offenses of third parties 

or, in other words, aided and abetted those business enterprises’ state law prostitution 

offenses. Defendants are not alleged to have been principals in those state law offenses. 

Indeed, the government contends it does not even have to prove that defendants knew 

anything about the specific offenses or the related “business enterprise[s] involving . . . 

prostitution offenses.” 18 U.S.C. § 1952(a)(3), (b)(1). And that is the crux of the problem 

with the SI—defendants are charged with aiding and abetting business enterprises involved

in state law prostitution offenses, but the SI has no allegations to support aiding and

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abetting.

Similarly, the government contends that promotion or advertisement is a completed 

offense. This is exactly the kind of result that Hansen rejects, and that the Government 

argued against in Woodhull. Indeed, if the words “promote” or “facilitate the promotion” 

are as broad as the government says, the government could subject large swaths of 

protected speech to prosecution based on the mere allegation that an advertisement—

though legal on its face—was associated with prostitution.

To avoid such overreach, the elements of “aiding and abetting” must be “essential 

elements” because the existence of those elements differentiates between protected speech 

from unprotected speech and legal conduct from illegal conduct. Hess v. Indiana, 414 U.S. 

105, 107 (1973) (“It hardly needs repeating that ‘(t)he constitutional guarantees of freedom 

of speech forbid the States to punish the use of words or language not within ‘narrowly 

limited classes of speech.’’”); Gooding v. Wilson, 405 U.S. 518, 521–22 (1972) (“The 

constitutional guarantees of freedom of speech forbid the States to punish the use of words 

or language not within ‘narrowly limited classes of speech’ . . . [T]he statute must 

be...authoritatively construed to punish only unprotected speech and not be susceptible 

of application to protected expression.”). 

E. Conclusion 

The Court’s prior order denying defendants’ motion to dismiss is incompatible with 

the Supreme Court’s new decision in Hansen. The Court should reconsider and grant the 

motion. 

DATED this 28th day of June, 2023. 

OSBORN MALEDON, P.A.

By s/ Joseph N. Roth

Timothy J. Eckstein

Joseph N. Roth

Sarah P. Lawson

2929 North Central, 20th Floor

Phoenix, Arizona 85012-2794 

Attorneys for James Larkin

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LIPSITZ GREEN SCIME CAMBRIA LLP

By s/ Paul J. Cambria, Jr. (w/permission) 

Paul J. Cambria, Jr. (pro hac vice) 

Erin E. McCampbell (pro hac vice) 

42 Delaware Avenue, Suite 120

Buffalo, New York 14202

Attorneys for Michael Lacey

FEDER LAW OFFICE PA

By s/ Bruce S. Feder (w/permission) 

Bruce S. Feder

2930 E. Camelback Road, Suite 160

Phoenix, Arizona 85016

KESSLER LAW OFFICE

By s/ Eric W. Kessler (w/permission) 

Eric W. Kessler

6720 N. Scottsdale Rd., Suite 210

Scottsdale, Arizona 85253

Attorneys for Scott Spear

BIRD, MARELLA, BOXER, WOLPERT,

NESSIM, DROOKS, LINCENBERG & 

RHOW P.C.

By s/ Gary S. Lincenberg (w/permission) 

Gary S. Lincenberg

Gopi K. Panchapakesan

Ariel A. Neuman

1875 Century Park E., Suite 2300

Los Angeles, California 90067

Attorneys for John Brunst

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DAVID EISENBERG PLC

By s/ David S. Eisenberg (w/permission) 

David S. Eisenberg

3550 N. Central Ave., Ste. 1155

Phoenix, Arizona 85012

Attorneys for Andrew Padilla

JOY BERTRAND LAW 

By s/ Joy M. Bertrand (w/permission) 

Joy M. Bertrand

P.O. Box 2734

Scottsdale, Arizona 85252

Attorneys for Joye Vaught

Case 2:18-cr-00422-DJH Document 1630 Filed 07/06/23 Page 16 of 16