ATTACHMENT 

A 

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DECLARATION OF SPECIAL AGENT RICHARD ROBINSON

I, Special Agent Richard Robinson, declare:

INTRODUCTION

1. I am a Special Agent with the Internal Revenue Service Criminal Investigation (IRS-CI) and

have been employed in this capacity since 2004. During my law enforcement career, I have 

investigated multiple violations of federal law within the jurisdiction of IRS-CI.

2. During most of that time I was assigned to the Phoenix Field Office. My primary 

responsibilities there included working on white collar crime investigations including, but not 

limited to, cases involving allegations of: bankruptcy fraud, mail fraud, wire fraud, money 

laundering, and income tax violations. I have recently been reassigned as a Computer 

Investigative Specialist in the E-Crimes Section of IRS-CI.

3. I have participated extensively in the investigation leading up to the indictment in United 

States v. Michael Lacey, et al. This declaration is submitted in support of the government's 

request for pretrial detention of defendant JAMES LARKIN (“LARKIN”). If called upon, I 

could competently testify as set forth below:

4. The following is information based on my personal observations, the observations of other 

federal and state law enforcement agents, a review of records and evidence during the course of 

the investigation, and evidence obtained through search warrants and subpoenas.

Transfers of Assets Abroad

5. Beginning at least as early as March 2016, LARKIN began a series of wire transfers from 

one investment account to various parties in France totaling over $750,000. (See summary in 

Exhibit A) LARKIN also sent over $300,000 from this same account to a bank account 

apparently in the names of LARKIN and his wife held with the institution Banque Wormser 

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Freres, a bank based in Paris, France. Wire request forms appear to bear signatures for both 

LARKIN and his wife. (See Exhibits A & B)

6. At least one of the wire transfers to France was to pay for renovation of an apartment at the 

address of 14, rue Saint Guillaume in Paris, France. The invoice for this renovation was sent by 

the billing company named A+B Kasha to LARKIN and his wife, listing their address as the 

French apartment. In my training and experience, the facts that LARKIN occupied the apartment 

and was renovating the apartment together indicate that LARKIN was likely the owner of said 

apartment. (See Exhibit C)

Domestic Financial Account Activity

7. From at least as early as January 2016, LARKIN made transfers from one of his investment 

accounts to other U.S. based accounts that he controls or appears to control. While I and other 

investigators have requested records related to these accounts, we have not yet received all of the 

records needed to trace these funds to their current state or final disposition. These transfers 

included (See also summary on Exhibit D):

a. Three wire transfers totaling $20,000,000 sent to an account with Pershing, LLC in the 

name of the Acacia Conservation Fund, LP. Research into this entity revealed that it is 

an investment pool with both U.S. and foreign holdings.

b. Three wire transfers totaling $16,250,000 sent to an account with The Northern Trust 

Company in the name of The Ocotillo Family Trust, a trust of which LARKIN and his 

wife have historically been the trustees. The Ocotillo Family Trust is also the name 

under which LARKIN’S homes in Paradise Valley, Arizona and Saint Helena, CA are 

held. While I have seen some documents indicating that at least $500,000 in funds from 

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this account were transferred to LARKIN’S aforementioned account in France, I have not 

yet received the records to determine the ultimate source or disposition of those funds. 

c. Twenty wire transfers totaling $11,247,500 sent to an account at Wells Fargo Bank in 

the names of LARKIN and his wife. 

d. Four wire transfers totaling $503,000 sent to an account at Wells Fargo Bank in the 

name of Magnolia Tree Holdings and LARKIN’S wife, Margaret Larkin.

e. LARKIN also transferred over $30,000 in three wires to an entity named Executive 

Aircraft Services in 2016.

International Travel

8. Despite facing pending prosecution for bank fraud and money laundering charges in 

California, LARKIN has been granted leave to travel internationally. In fact, LARKIN recently 

traveled in the region around the United Kingdom and Ireland and was arrested upon his return 

to the U.S. on Friday, April 6. 

9. Prior to that, LARKIN traveled to France from February 16, 2018 to February 24, 2018. 

Sources of Income 

10. LARKIN and his long-time business partner Michael Lacey (“LACEY”) each made more 

than $100 million in profits from their beneficial ownership of Backpage.com since 2013, 

receiving over $30 million in each of the years from 2013-2015 based on reviews of tax and 

business documents. Prior to that, LARKIN’S annual income was about $5 million or less. The 

import of this is that the vast majority of LARKIN’S accumulated wealth and assets are new 

money derived from the promotion of prostitution by Backpage.com and related money 

laundering activities that are the subject of the recent indictment against LACEY, LARKIN and 

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other owners and employees of Backpage.com. As such, assets traceable to the proceeds from 

Backpage.com are subject to seizure and forfeiture allegations that accompany that indictment. 

11. Forfeiture allegations were made in the indictment in this case with regard to LARKIN’S 

following domestic assets totaling over $5 million in estimated value:

No. Property Last Sale Price or 

Approximate Value

1 Paradise Valley, AZ $2,500,000

2 Chicago, IL $138,000

3 Saint Helena, CA $2,787,186

12. Since at least 2012, LARKIN has had no significant source of income that was not 

Backpage-derived. LARKIN’S salary from Cereus Properties, LLC in 2013 and 2014 was about 

$17 million and $27 million respectively. That is in addition to flow-through income from the 

holding company that owned Backpage of about $20 million and $22 million respectively. 

13. In 2015, LARKIN’S income took on a more passive character. LARKIN ceased to receive a 

salary of more than $1 million, but he received over $14 million in interest income as a result of 

being 45% owner1 of the company that holds the $600 million in promissory notes from the 

business entities that acquired Backpage and related companies. 

14. While the Agave Rose Wine Company, LLC has inventory and assets, such as wine or liquor 

licenses in both Arizona and California, from 2012 to 2015 it did not appear to turn a profit. 

Continued Operation and Control of Backpage.com 

 

1 According to the 2015 tax return for Medalist Holdings, Inc., LARKIN has a 42.759% interest in the 

company. However, trusts for both Ramon Larkin and Troy Larkin were each given a 1.181% interest in 

the company. Adding these three numbers together arrives at an ownership interest for LARKIN of 

45.121%, exactly the same share as LACEY’S interest.

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15. In reviewing both business documents and correspondence of Backpage.com and related 

entities over the course of the investigation, I noted that the owners of Medalist Holdings 

(LARKIN, LACEY, Jed Brunst (BRUNST) and Scott Spear (SPEAR)) retained some aspects of 

control over the Backpage entities even after the sale transactions in 2014 and 2015, in which

Carl Ferrer (FERRER) bought ownership of the Backpage entities. For example, FERRER 

continued to report to BRUNST and SPEAR, and BRUNST and SPEAR continued to report to 

LARKIN. 

16. Beneficial interest also remained with LARKIN, LACEY, BRUNST and SPEAR after the 

sale to FERRER. As proof of this, contrast FERRER’S total income on his 2015 tax return of 

$1.2 million with LARKIN’S $32 million, even though they are dependent on the same sources 

of income and FERRER is doing the bulk of the work. 

17. Similarly misleading was the claim that Backpage.com put on its site in January 2017 that it 

had closed down its Adult/Escort ad sections in response to government censorship. From 

discussions with agents and detectives who work cases involving prostitution and human 

trafficking, I understand that the Women Seeking Men personals section of Backpage had a 

dramatic increase in the number of paid ads, and that the ads there were tied to prostitution from 

that time forward. (Exhibit E)

18. Even through last Friday, April 6, when Backpage ads for Women Seeking Men contained

no text other than a phone number, the images strongly suggested that the ads were for 

prostitution. (Exhibit F)

Imminent Loss of CDA Protection

19. The California indictment that led to LACEY and LARKIN being arrested in October 2016 

was dismissed shortly thereafter by a judge who cited immunity granted by 15 U.S.C § 230 –

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The Communications Decency Act (CDA). Several civil lawsuits and potential state-court 

prosecutions against Backpage, LACEY and LARKIN over the past several years have been 

dismissed under the CDA. 

20. However, since that time, three important developments have undermined the CDA 

protection that LACEY and LARKIN had previously enjoyed:

a. The U.S. Senate Permanent Subcommittee on Investigations publicly released a report 

in January titled Backpage.com’s Knowing Facilitation of Online Sex Trafficking. The 

report was accompanied by an appendix containing underlying and supporting 

documents obtained by the subcommittee over the course of its investigation that 

demonstrated: (1) knowledge on the part of Backpage principals of the nature of 

Backpage’s adult ads and efforts to sanitize those ads to conceal the nature (2) that 

over 90% of Backpage’s revenue was derived from those adult ads and (3) that 

LACEY and LARKIN retained an interest in Backpage even though they had sold it in 

2014 and 2015. 

b. Both the Senate and House passed bills to amend the CDA to eliminate immunity in 

cases where child sex trafficking is involved. Once signed into law, this amendment 

to the CDA would potentially open the floodgates for criminal prosecutions from any 

of the 50 states as well as innumerable civil lawsuits from and on behalf of victims of 

human trafficking promoted by Backpage.

c. Federal charges have never been brought against LACEY and LARKIN for their 

promotion of prostitution and sex trafficking and money laundering. The CDA 

specifically provides no immunity to federal criminal charges. 

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I declare under penalty of perjury that the forgoing is true and correct to the best of my 

knowledge and belief. Executed this 9th day of April 2018 at Phoenix, Arizona.

_s/Richard Robinson___________________

Richard Robinson, Special Agent – Computer Investigative Specialist

Internal Revenue Service Criminal Investigation

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