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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, 

v. 

Michael Lacey, et al.,

Defendants.

CR-18-422-PHX-SPL (BSB) 

UNITED STATES’ MOTION FOR 

ACCESS TO THE JOINT 

REPRESENTATION AND JOINT 

DEFENSE AGREEMENTS 

PREVIOUSLY SUBMITTED BY 

DEFENDANTS MICHAEL LACEY 

AND JAMES LARKIN FOR IN 

CAMERA REVIEW

Preliminary Statement

The United States respectfully seeks an order compelling Defendants Michael 

Lacey and James Larkin to provide the government with copies of the following joint 

representation and joint defense agreements that they previously submitted for in camera

review as Exhibits A-C to the Declaration of James C. Grant (see CR 180 at 6-8):

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Exhibit A Joint Engagement Letter dated December 12, 2016 (Engagement Letter); 

Exhibit B Common Interest/Litigation Management Agreement dated 

December 31, 2016 (Joint Representation Agreement, or JRA); and

Exhibit C Joint Defense Agreement dated June 2017 (JDA).

These in camera filings played a central role in the Court’s analysis of two recentlylitigated motions: (1) the government’s motion to disqualify Davis Wright Tremaine LLP 

(DWT) and Henze Cooke Murphy LLP (HCM); and (2) the government’s motion to 

resolve certain attorney-client privilege issues. (CR 338 (Disqualification Order) and CR 

345 (Privilege Order)). The Court based the Disqualification Order primarily on its finding 

that “[t]he express terms of the JRA and JDA are fatal to the Government’s argument for 

disqualification.” (CR 338 at 7.) The Court similarly grounded the Privilege Order on its 

finding that “the plain text of the JDA” prevented Backpage.com’s CEO and 100% owner, 

Carl Ferrer, from waiving Backpage.com’s corporate attorney-client privilege without 

“first obtain[ing] the written consent of all parties who may be entitled to a claim of 

privilege over the materials.” (CR 345 at 4; see id. at 4 (the JDA “set[s] forth other 

protections for information and communications exchanged between [the] parties”).) 

In entering these orders, the Court recognized “it may be difficult for the 

Government to understand what it cannot see....” (CR 338 at 9.) For several reasons, the 

government respectfully seeks access to these agreements so that it may evaluate their 

contents and make informed decisions about next steps in this litigation and related issues. 

Argument

I. THE AGREEMENTS ARE NOT PRIVILEGED.

Lacey and Larkin asserted the agreements “are privileged” and may only be 

provided to the Court in camera. (CR 180 at 6 (“Because the agreements about DWT’s 

representation are privileged, they are provided in camera declaration [sic] and are 

described here only generally.”).) However, engagement letters and similar agreements 

generally are not privileged, and the agreements should be disclosed for this threshold 

reason.

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The attorney-client privilege protects from discovery “confidential communications 

between attorneys and clients, which are made for the purpose of giving legal advice.” 

United States v. Richey, 632 F.3d 559, 566 (9th Cir. 2011). The privilege is “narrowly and 

strictly construed,” and the party asserting it bears the burden of proving that it applies. 

Vasudevan Software, Inc. v. IBM Corp., 2011 WL 1599646, at *1 (N.D. Cal. Apr. 27, 

2011); accord United States v. Bergonzi, 216 F.R.D. 487, 493 (N.D. Cal. 2003) (party 

asserting privilege “must make a prima facie showing” that privilege applies). 

“The Ninth Circuit has repeatedly held retainer agreements are not protected by the 

attorney-client privilege or work product doctrine.” Gusman v. Comcast Corp., 298 F.R.D. 

592, 599–600 (S.D. Cal. 2014); Hoot Winc, LLC v. RSM McGladrey Fin. Process 

Outsourcing, LLC, 2009 WL 3857425, at *1-2 (S.D. Cal. Nov. 4, 2009) (citing Ralls v. 

United States, 52 F.3d 223, 225 (9th Cir. 1995); United States v. Blackman, 72 F.3d 1418, 

1424 (9th Cir.1995); In re Michaelson, 511 F.2d 882 (9th Cir.1975)); see also Carrizosa 

v. Stassinos, 2006 WL 2529503, at *3 (N.D. Cal. Aug. 31, 2006) (under Ninth Circuit law, 

fee agreements generally fall outside the scope of the attorney-client privilege; disclosure 

warranted where litigant describes terms of the agreement in court filings). Moreover, 

“[c]ommunications between attorney and client that concern the identity of the client, the 

amount of the fee, the identification of payment by case file name, and the general purpose 

of the work performed are usually not protected from disclosure by the attorney-client 

privilege.” Clarke v. Am. Commerce Nat'l Bank, 974 F.2d 127, 129 (9th Cir. 1992). 

However, documents that reveal the client’s “motive...in seeking representation, litigation 

strategy, or the specific nature of the services provided” may be privileged. Id. 

Engagement letters are often publicly disclosed in this District when a party submits an 

application for attorneys’ fees. See LRCiv 54.2(d)(2). 

Here, Defendants have made no showing that the attorney-client privilege applies

to any of the three agreements identified above. Defendants have not demonstrated that 

any of the agreements reveal confidential communications between a client and a lawyer 

transmitting legal advice. The JRA, for example, consisted of a 10-page, single-spaced 

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contract between Lacey, Larkin, Ferrer, and entities they respectively controlled; it was not

a communication between a client and a lawyer. (CR 193-9, Exhibit I, Declaration of Carl 

Ferrer (Ferrer Decl.) ¶¶ 28-29.) While the agreements may set forth the terms of the certain 

representations, or understandings among parties regarding how they propose to arrange 

their business and/or legal relationships, there is no indication that the agreements disclose 

the specific contents of any confidential legal advice, particular litigation strategies or 

theories, or the details of any legal services performed. Accordingly, the agreements are 

not privileged and should be disclosed. See, e.g., United States v. Stepney, 246 F. Supp.

2d 1069, 1078 (N.D. Ca. 2003) (“To the extent that joint defense agreements simply set 

forth the existence of attorney-client relationships—implied or otherwise—between 

various attorneys and defendants, the contents of such agreements do not fall within the 

attorney-client privilege.”); Pacific Coast Steel v. Leany, 2011 WL 4572008, at *3 (D. Nev. 

Sept. 30, 2011) (“Joint defense agreements are generally not privileged. They serve only 

to formalize the invocation of the joint defense or common interest.”); Rodriguez v. Gen. 

Dynamics Armament and Tech. Products, Inc., 2010 WL 1438918, at *2 (D. Haw. Apr. 12, 

2010) (Joint Defense Agreement held not to contain “any privileged or protected 

material”); United States v. Hsia, 81 F. Supp. 2d 7, 11 n.3 (D.D.C. 2000) (expressing doubt 

that “either the existence or the terms of a [joint defense agreement] are privileged”).

II. THE AGREEMENTS ARE HIGHLY RELEVANT AND MATERIAL.

The Disqualification and Privilege Orders both relied on the cited agreements and 

stated that the government does not dispute the “validity” of the agreements. (See CR 388 

at 7 n.5 (“Importantly, the Government does not dispute the existence or validity of either 

agreement [the JRA and JDA].”); CR 345 at 4 n.3 (“Neither party disputes the validity of 

the agreements [the JRA and JDA].”).) In fact, the government – and Ferrer – vigorously 

disputed the agreements’ validity. (See, e.g., CR 193 at 6-9; CR 193-9, Ferrer Decl. ¶¶ 23-

44.) In his Declaration, Ferrer made clear that the conflict waivers cited by Defendants did

not reflect his informed consent and cannot support the conclusion that the waivers are 

valid and enforceable. Ferrer explained he never “gave informed written consent to DWT’s 

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joint representation of me, Mr. Larkin and Mr. Lacey, even if we were to become adverse 

in a later criminal case.” (CR 193-9, Ferrer Decl. ¶ 24.) Rather, it was his understanding, 

after signing the December 12, 2016 Engagement Letter, “that if any of the individual 

defendants became adverse to one another, that DWT would immediately cease 

representing all the previously represented individual defendants. I never agreed to waive 

all conflicts regarding such joint representation, and, especially, regarding criminal charges 

that may be brought against me in the future.” (CR 193-9, Ferrer Decl. ¶ 26.)1

 

To the extent other language in the Engagement Letter purports to suggest that 

Ferrer waived, in advance, his right to seek disqualification of DWT from representing 

Larkin and Lacey in criminal proceedings adverse to himself, any such waiver was not the 

product of informed consent. Rather, Ferrer averred that he “did not consult with any 

independent lawyer before signing the joint representation letter with DWT, and no DWT 

attorney ever recommended that I do so. I also do not recall ever discussing the nature of 

potential conflicts that may arise, or the potential impact on my interests with DWT or any 

other lawyer before signing this engagement letter.” (CR 193-9, Ferrer Decl. 27.)

Ferrer similarly did not provide informed consent regarding any waiver in the 

December 31, 2016 JRA. The JRA was sent to him with other documents as part of a larger 

re-negotiation of the debt he owed to Lacey and Larkin. (CR 193-9, Ferrer Decl. ¶¶ 30-

34.) He was given only 48 hours to review and sign the JRA, and felt he had to sign (“I 

had no choice but to sign it”) to avoid losing his entire investment and “facing financial 

ruin.” (CR 193-9, Ferrer Decl. ¶¶ 30-34.) The JRA was not an attorney-client 

communication, but rather was a contract among businessmen and the entities they 

controlled. (CR 193-9, Ferrer Decl. ¶¶ 28-29.)

 

1 This is consistent with the quoted language of the Engagement Letter in Ferrer’s letter to 

DWT dated April 13, 2018, and attached as Exhibit A to the government’s disqualification 

motion. (See CR 118-1 at 2, n.1, quoting Engagement Letter, Page 3, para. 1: “If an incurable conflict were to arise among the three of you...and agreement cannot be reached 

regarding DWT’s continued representation of one or more of you, DWT will withdraw 

from representing each and all of you individually, while continuing to represent Backpage.com, as set forth above.”) 

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Critically, when he signed the JRA, Ferrer did not intend to waive any future 

conflicts of interest regarding his attorneys, especially conflicts that could arise in future 

criminal proceedings. (CR 193-9, Ferrer Decl. ¶ 35.) Rather, Ferrer averred “[t]he 

possibility of future conflicts of interest among the parties was never discussed before I 

signed that agreement.” (CR 193-9, Ferrer Decl. ¶ 36.) Still worse, Mr. Larkin’s lawyer, 

Don Moon, discouraged Ferrer from discussing the JRA with his own personal lawyers, 

“because he said that doing so would be a ‘waste of time.’” (CR 193-9, Ferrer Decl. ¶ 37.) 

This is the opposite of “informed consent.” See, e.g., ER 1.0(e) (informed consent requires 

the lawyer to communicate to the client “adequate information and explanation about the 

material risks of and reasonably available alternatives to the proposed course of conduct”); 

ER 1.7, comment 21 (an open-ended advance waiver “ordinarily likely will be ineffective, 

because it is not reasonably likely that the client will have understood the material risks 

involved”); Roosevelt Irrigation Dist. v. Salt River Project Agricultural Improvement and 

Power Dist., 810 F. Supp. 2d. 929, 950-57 (D. Ariz. 2011) (waiver invalid because it did 

not address the scenario that later resulted in conflict). 

The government should at a minimum be afforded access to the JRA so that it may 

analyze whether and to what extent the JRA detailed the types of future conflicts that may 

arise, explained the risks and benefits of proceeding with joint representation in view of 

those potential future conflicts, and confirmed that the signatories had obtained, or been 

afforded sufficient and meaningful opportunity to obtain, independent legal advice. 

 The government and Ferrer also vigorously contested whether the June 2017 JDA 

contained an advance conflict waiver regarding conflicts his personal attorneys (including 

DWT) might develop in the future. Ferrer stated it was his understanding that the JDA 

“was formed to allow the lawyers for the individual targets and subjects to share materials 

and access a shared database of Backpage.com documents.” (CR 193-9, Ferrer Decl. ¶ 40.) 

It was not his understanding that, by signing the JDA, he “would be waiving any future 

conflicts of interest involving my own personal attorneys.” (CR 193-9, Ferrer Decl. ¶ 41.) 

As far as he knew, DWT was not a party to the JDA. (CR 193-9, Ferrer Decl. ¶¶ 42-43.) 

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Courts have long recognized that JDA provisions must be clear and explicit in order 

to provide notice to the clients and the ability to obtain informed consent. The JDA should 

identify the signatory attorneys whom the client is agreeing not to seek disqualification of. 

Stepney, 246 F. Supp. 2d at 1085 (adopting ABA model JDA which identifies signatory 

attorneys). Based on Ferrer’s description, the June 2017 JDA failed these tests. The 

government should be allowed access to the JDA to assess whether the JDA complied with 

the foregoing requirements.

Access to the JDA is warranted for another reason: In the Privilege Order, the Court 

rejected the government’s primary argument – that Ferrer had executed a written waiver of 

Backpage’s attorney-client privilege in his capacity as Backpage’s CEO and 100% owner 

– based entirely on the contents of the JDA. (CR 345 at 3-4.) The Court wrote: “Based on 

the Court’s in camera review...the Court finds that the plain text of the JDA states that the 

materials shared between the parties to the JDA are to be protected from disclosure unless 

the disclosing party first obtains the written consent of all parties who may be entitled to a 

claim of privilege over the materials.” (CR 345 at 4.) Because Ferrer had not obtained 

consent from the other “listed parties to the JDA before executing his written waiver of 

attorney-client privilege,” “the Government’s argument for access to the privileged 

communication fails.” (CR 345 at 4.) The Court specifically found that the JDA “not only 

established joint-defense privileges, but also set forth other protections for information and 

communications exchanged between parties to the agreement.” (CR 345 at 4.) The Court 

concluded that Ferrer’s written privilege waiver constituted an ineffective attempt “to 

circumvent the terms of the JDA.” (CR 345 at 4.) The government cannot meaningfully 

evaluate the Court’s ruling without having access to the terms of the JDA. 

Moreover, as in the Disqualification Order, the Privilege Order is premised in 

significant part on the notion that the government does not dispute the “validity” of these 

agreements. (See CR 345 at 4 n.3 (“Neither party disputes the validity of [the JRA and 

JDA].”).) However, the government in fact disputed the validity of these agreements to 

the extent Defendants suggested they could be read to apply retroactively to 

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communications that predated the agreements’ existence. As the government pointed out,

joint defense agreements provide prospective protection to confidences shared among the 

parties and their attorneys in furtherance of a joint defense. To be protected by the JDA, 

the disclosures in question must occur during and as a result of that joint defense. Stepney, 

246 F. Supp. 2d at 1085. (CR 193 at 7; CR 269 at 9-10.) Nevertheless, the JDA appears 

to have been cited to justify retroactive application of that agreement to communications 

and documents that existed long before the JDA’s creation. (See CR 345 at 3-4.) Here, 

the Order has the effect of sweeping into the universe of protected materials 

communications between Backpage and its attorneys dating to the company’s inception in 

2004 – 13 years before the JDA was executed. The government should be allowed to 

review an agreement that provides such broad privileges to its signatories. 

In sum, the government contested the validity and existence of any purported joint 

representation or joint defense agreement that could have operated to prevent Ferrer from 

waiving Backpage.com’s corporate attorney-client privilege over communications that 

predated these written agreements. (See, e.g., CR 269 at 9-10 (“[I]t is highly unlikely that 

any of the documents currently segregated in the government’s filter review contain 

material covered by the joint-defense privilege. Indeed, the filter team has confirmed that 

none of the segregated documents involves communications from December 2016 or later. 

This is relevant because Ferrer, Lacey, and Larkin didn’t enter into a joint-defense 

agreement until late December 2016.”).) The government should be permitted to review 

the JDA to assess whether the agreement sweeps so broadly as to include all Backpage.com 

privileged communications generated since the company’s founding in 2004.

III. ANY PRIVILEGE HAS BEEN WAIVED.

The Ninth Circuit addressed waiver of the attorney-client privilege in Chevron 

Corp. v. Pennzoil Co., 974, F.2d 1156 (9th Cir. 1992), stating that the privilege “may not 

be used as both a sword and a shield....Where a party raises a claim which in fairness 

requires disclosure of the protected communication, the privilege may be implicitly 

waived.” Id. at 1162. An implied privilege waiver occurs when: (1) the party asserts the 

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privilege as a result of an affirmative act, such as asserting a claim or defense; (2) through 

the affirmative act, the asserting party puts the privileged information at issue; and (3) 

allowing the privilege would deny the opposing party access to information needed to 

litigate its rights effectively. Home Indem. Co. v. Lane Powell Moss and Miller, 43 F.3d 

1322, 1326 (9th Cir. 1995). See also In re Grand Jury Proceedings John Doe Co. v. United 

States, 350 F.3d 299, 303 (2d. Cir. 2003) (“The unfairness courts have found which 

justified imposing [implied waiver] generally resulted from a party’s advancing a claim to 

a court or jury...while relying on its privilege to withhold from a litigation adversary 

materials that the adversary might need to effectively contest or impeach the claim.”). All 

three requisites of implied waiver are satisfied here.

First, Lacey and Larkin asserted a claim or defense based on the three agreements. 

In response to the disqualification motion, they affirmatively argued that Ferrer had waived 

the conflicts described in the motion – and agreed not to seek disqualification – based on 

the agreements. (See, e.g., CR 180 at 6-8, 12-16.) Among other things, they represented 

that the Engagement Letter and JRA “requested that DWT act as joint counsel”; “[a]s to 

any claims – civil or criminal, whether then pending or that might arise in the future –

Ferrer agreed to waive any actual or potential conflicts of interest to allow for the joint 

representation”; the parties agreed to share information “with the understanding that doing 

so would not provide any basis to assert putative conflicts”; and “the agreements 

contemplated that the parties interests could diverge...[and] allowed that a party could 

withdraw from the joint representation but could not move to disqualify counsel from 

continuing to represent other parties.” (CR 180 at 7.) Lacey and Larkin also represented 

that the JDA provided for information sharing and conflict waivers for the California 

criminal case “or other proceedings,” and that Ferrer agreed “not to seek disqualification 

of counsel” should he later withdraw from the JDA. (CR 180 at 7-8.) They asserted “it 

was acknowledged that DWT was encompassed within the joint defense undertakings and 

protections.” (CR 180 at 8.)

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Second, Lacey and Larkin put the contents of the three agreements at issue by 

extensively summarizing the agreements’ terms in public court filings and at the October 

5, 2018 motion hearing, and by arguing that those terms required denying the government’s 

motions. (See, e.g., CR 180 at 6-8, 12-16; 10/5/18 Hr’g Tr. at 32-34, 49-50, 83-84.)

Third, allowing the privilege to curtail the government’s access to the agreements 

deprives the government of information it needs to litigate its interests effectively in this 

case. Lacey and Larkin asserted that the agreements “are privileged” and may only be 

provided to the Court in camera. (CR 180 at 6.) Without providing the government access 

to the agreements2

, the Court ruled that the agreements were “fatal” to the disqualification 

motion. (CR 338 at 7.) The Court also ruled that the JDA swept so broadly as to prohibit 

Ferrer from executing a valid waiver of Backpage.com’s corporate attorney-client privilege 

regarding documents covered by any time period. (CR 345 at 4.) 

Without access to the agreements, the government can neither meaningfully assess 

the recent rulings nor evaluate whether, inter alia: (1) the agreements described the present 

conflict sufficiently to allow Ferrer to have provided informed consent; (2) the agreements 

confirm that Ferrer was afforded meaningful opportunity to obtain independent advice3

; 

(3) the conflict waivers apply retroactively to representations predating Ferrer’s execution 

of the agreements; and (4) the agreements restrict Ferrer, in his capacity as Backpage.com’s 

CEO and 100% owner, from waiving Backpage.com’s corporate attorney-client privilege 

for communications generated at any time since the company’s founding in 2004.

 

2 The government previously sought disclosure of the December 31, 2016 JRA. The 

government noted that the JRA wasn’t signed by any lawyers, and that Ferrer’s description suggested it wasn’t covered by the attorney-client privilege. “If the Court agrees,” the government wrote, “it should order the defendants to provide a copy to the government.” (CR 193 at 7.)

3

The Disqualification Order contains no finding that Ferrer signed the JRA under advice of counsel. (Cf. CR 338 at 7-8). 

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Conclusion

For the foregoing reasons, the government respectfully requests that the Court order 

Defendants Lacey and Larkin to provide the government with the agreements attached as 

Exhibits A-C to the Grant Declaration (see CR 180 at 6-8). In addition, the government 

requests that the Court continue the government’s deadline for seeking reconsideration of 

the Disqualification and/or Privilege Orders until 14 days after service of the requested 

agreements on the government. A proposed order is attached.

Respectfully submitted this 26th day of October, 2018.

ELIZABETH A. STRANGE

First Assistant United States Attorney District of Arizona

s/Peter Kozinets

KEVIN M. RAPP

MARGARET PERLMETER

PETER S. KOZINETS

ANDREW C. STONE

JOHN J. KUCERA

Assistant U.S. Attorneys

BRIAN BENCZKOWSKI 

Assistant Attorney General

Criminal Division, U.S. Department of Justice

REGINALD E. JONES

Senior Trial Attorney

U.S. Department of Justice, Criminal Division

Child Exploitation and Obscenity Section

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Certificate of Service

I hereby certify that on this date, 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: Anne Chapman, Erin McCampbell, Gregory Zamora, James Grant, Lee Stein, Paul Cambria, Robert Corn-Revere, Ronald London, 

Janey Henze Cook, John Littrell, Kenneth Miller, Thomas Bienart, Jr., Bruce Feder, 

Michael Kimerer, Rhonda Neff, KC Maxwell, David Wakukawa, Michael Piccarreta, 

Stephen Weiss, Gopi Panchapakesan, Ariel Neuman, Gary Lincenberg, Anthony Bisconti, Whitney Bernstein, Seetha Ramachandran.

s/Sally Hawley

U.S. Attorney’s Office

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