Exhibit B 

Case 2:18-cr-00422-DJH Document 1267-2 Filed 09/03/21 Page 1 of 4
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Case 2:12-cv-00954-RSM Document 44 Filed 07/10/12 Page 1 of 3 

The Honorable RICARDO S. MARTINEZ 

UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF WASHINGTON 

BACKP AGE.COM, LLC, 

Plaintiff, 

V. 

ROBERT M. MCKENNA, Attorney 

General of Washington State, et al, 

Defendants. 

I, Paula Selis, declare: 

ATSEATfLE 

NO. 2:12-cv-00954-RSM 

DECLARATION OF PAULA 

SELIS IN OPPOSITION TO 

PLAINTIFF1

S MOTION FOR 

TEMPORARY RESTRAINING 

ORDER 

1. I am an Assistant Attorney General with the State of W~hington's Attorney 

18 General's Office Consumer Protection Division. I am over the age of eighteen and qualified 

19 to make this Declaration. 

20 2. On June 30, 2011, I met with representatives ofBackpage.com at the Office of 

21 the Attorney General to discuss the company's escort advertising. The meeting was held at 

22 the request of Back.page.com. Back.page.corn's representatives at the meeting were 

23 Carl Ferrer, Vice President of Sales and Marketing for the company; Don Bennett Moon, an 

24 attorney and member of Board of Directors for Village Voice Media, Backpage.com' s parent 

25 company; and Kenneth Stocker, Publisher of the Seattle Weekly, a Village Voice Media 

26 publication. The Attorney General's Office was represented at the meeting by Chris Johnson, 

DECLARATION OF PAULA SELIS IN 

OPPOSITION TO PLAINTIFF'S MOTION 

FOR TEMPORARY RESTRAINING 

ORDER 

NO. 2:12-CV-00954-RSM 

BP-AZGJ005724 70 

AITORNEY GENERAL'S OFFICE 

Criminal Justice Division 

800 Fifth Avenue, Suite 2000 

Seattle, WA 9& 104-3188 

(206) 4-64-6430 

BP-PSl-544201 

DOJ-BP-0004457055 

Case 2:18-cr-00422-DJH Document 1267-2 Filed 09/03/21 Page 2 of 4
Case 2:12-cv-00954-RSM Document 44 Filed 07/10/12 Page 2 of 3 

1 the Attorney General's Office Policy Director; Dan Sytman, Deputy Communications 

2 Director for the Attorney General's Office, and me. 

3 3. Backpage.com told us their purpose rn asking for the meeting was to 

4 demonstrate their efforts to police their website for underage human trafficking. After 

5 discussing their efforts, Dan Sytman asked whether . there were any illegal ads on the 

6 Backpage.com website. They responded that there,were no ads that offered sex for money. I 

7 took them to task for this and said "You mean to tell me that if someone responded to an 

8 advertisement, the woman they called for services would be offering to go out for coffee? 

9 '!'hat's what you are advertising?" At that point, Don Moon looked at Carl Ferrer and said 

10 "Don't deny the undeniable" and laughed. It was clear that Mr, Moon meant it was 

11 undeniable that the ads on Backpage.com were for prostitution services, and they should not 

12 pretend otherwise. After Mr. Moon made this statement, he followed up by saying that the 

13 First Amendment gave Backpage.com the right to advertise in the manner they have chosen. 

14 This confirmed to me that he understood the true nature of the advertising, but believed 

15 Backpage.com had a right to distribute it nonetheless. 

16 II I I 

17 //// 

18 // / / 

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20 Ill/ 

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22 II I I 

23 // / / 

24 II I I 

25 II I I. 

26 II I I 

DECLARATION OF PAULA SELIS IN 

OPPOSITION TO PLAINTIFF'S MOTION 

FOR TEMPORARY RESTRAINING 

ORDER 

NO. 2:12-CV-00954-RSM 

2 

BP-AZGJ005724 71 

AITORNEY GENERAL'S OFFICE 

Criminal Justice Division 

800 Fifth AVC!lue, Suite 2000 

Seattle, WA 98104-3188 

(206) 464-6430 

BP-PSl-544202 

DOJ-BP-0004457056 

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Case 2:12-cv-00954-RSM Document 44 Filed 07/10/12 Page 3 of 3 

4. During the conversation, I also asked whether Back.page.com had proactively 

called the people who advertise on their website to determine what, exactly, they were 

offering for sale. My question was not answered. Rather, the Backpage.com representatives 

turned the discussion to the Communications Decency Act and Mr. Moon's claim that it 

absolutely protected Back.page.com from liability. 

I declare under penalty of perjury under the laws of the state of Washington that the 

foregoing is true and correct. . 1h . 

DATED this cf--] c.iay ofJune, 2012, at Seattle, Washington. 

ROBERT M. MCKENNA 

Attorney General 

(?~~~ PAULA L. SELIS, WSBA #12823 

Senior Assistant Attorney General · 

Attorney General's Office 

800 5th A venue, Suite 2000 

Seattle, WA 98104 

Telephone (206) 464-7662; Fax (206)587-5636 

DECLARATION OF PAULA SELIS IN 

OPPOSITION TO PLAINTIFF'S MOTION 

FOR TEMPORARY RESTRAINING 

ORDER 

3 AITORNEY GENERAL'S OFFICE 

Criminal Ju~tice Division 

NO. 2:12-CV-00954-RSM 

BP-AZGJ005724 72 

800 Fifth Avenue, Suite 2000 

Seattle, WA 98104-3188 

(206) 464-6430 

BP-PSl-544203 

DOJ-BP-0004457057 

Case 2:18-cr-00422-DJH Document 1267-2 Filed 09/03/21 Page 4 of 4