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GARY M. RESTAINO

United States Attorney

District of Arizona

KEVIN M. RAPP (Ariz. Bar No. 014249, 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) 

Assistant U.S. Attorneys 

40 N. Central Avenue, Suite 1800 

Phoenix, Arizona 85004-4408 

Telephone (602) 514-7500 

DAN G. BOYLE (N.Y. Bar No. 5216825, daniel.boyle2@usdoj.gov) Special Assistant U.S. Attorney 

312 N. Spring Street, Suite 1400 

Los Angeles, CA 90012 

Telephone (213) 894-2426 

Nicole M. Argentieri

Acting Assistant Attorney General 

Criminal Division, U.S. Department of Justice 

AUSTIN M. BERRY (Texas Bar No. 24062615, austin.berry2@usdoj.gov) 

U.S. Department of Justice 

Child Exploitation and Obscenity Section 

1301 New York Avenue, NW, 11th Floor 

Washington, D.C. 20005 

Telephone (202) 412-4136 

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-DJH 

NOTICE TO COURT

The United States files this Notice to the Court regarding the media’s intent to 

attempt to communicate with the jurors after the trial. On November 15, 2023, the United 

States received an email from David Morgan, a reporter, of the media’s intent to 

communicate with jurors after they have been discharged from jury service. (Exhibit A). 

Case 2:18-cr-00422-DJH Document 1975 Filed 11/16/23 Page 1 of 3
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Attached to Mr. Morgan’s email is a flyer stating that jurors may discuss the verdict, their 

deliberations, their opinions of the jury, prosecutors, defense attorney and the defendants - 

“any aspect of their experience as a juror – with anyone, including the media, the lawyers, 

or your family.” (emphasis added). (Exhibit B). 

The flyer misstates the Local Rules. Interviews with jurors after trial by or on 

behalf of parties involved in the trial are prohibited except on condition that the attorney

or party involved desiring such an interview file with the Court written interrogatories 

proposed to be submitted to the juror(s), together with an affidavit setting forth the 

reasons for such proposed interrogatories. L.R. Civ. P. 39.2(b). Absent a showing of 

good cause, and approval by the Court, the parties involved in the trial, or individuals acting 

on behalf of parties, are not permitted to interview with jurors. 

The United States respectfully requests the Court inform the jurors at the conclusion 

of their service that while they may be approached by members of the media or the public, 

they have no obligation to speak to or communicate with anyone about their jury service. 

L.R.Civ.P. 39.2(c) (no juror is compelled to communicate with anyone concerning any trial 

in which the juror has been a participant.) 

Respectfully submitted this 16th day of November, 2023.

 GARY M. RESTAINO United States Attorney District of Arizona Nicole M. Argentieri

Acting Assistant Attorney General 

Criminal Division, U.S. Department of Justice 

s/Peggy Perlmeter

KEVIN M. RAPP

MARGARET PERLMETER

PETER KOZINETS

ANDREW STONE

DANIEL BOYLE

 Assistant U.S. Attorneys 

 AUSTIN M. BERRY Trial Attorney

Case 2:18-cr-00422-DJH Document 1975 Filed 11/16/23 Page 2 of 3
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CERTIFICATE OF SERVICE

I hereby certify that on November 16, 2023, 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 CM/ECF registrants who have entered their appearance 

as counsel of record.

s/ Daniel Parke

Daniel Parke

U.S. Attorney’s Office 

Case 2:18-cr-00422-DJH Document 1975 Filed 11/16/23 Page 3 of 3