Exhibit C 

Case 2:18-cr-00422-DJH Document 627-4 Filed 06/01/19 Page 1 of 4
U.S. Department of Justice 

United States Attorney 

District of Arizona 

The Two Renaissance Square Main: (602) 514-7500 

40 N. Central Ave., Suite 1800 Main Fax: (602) 514-7693 

Phoenix, AZ 85004-4408 

December 10, 2018 

Paul J. Cambria Jr. 

Attorney at Law 

Lipsitz Green Scime Cambria 

42 Delaware Ave Suite 120 

Buffalo, NY 14202 

(attorney for Michael Lacey) 

Thomas H. Bienart, Jr., Esq. 

Beinart, Miller & Katzman, 

PLC 

903 Calle Amanecer, Suite 350 

San Clemente, CA 92673 

(attorney for James Larkin) 

Gary Lincenberg,Esq. 

Arid l A. Neuman, Esq. 

Bird, MareIla, Boxer, Wolpert, 

Nessim, Drooks, Lincenberg & 

Rhow, P.C. 

1875 Century Park East, 23rd 

Floor 

Los Angeles, California 

90067-2561 

(attorney for Jed Brunst) 

Jim Grant 

Davis Wright Tremaine LLP 

1201 Third Avenue, Suite 2200, 

Seattle, WA 98101 

(attorney for Lacey and Larkin) 

Michael D. Kimerer, Esq. 

1313 E. Osborn Road 

Phoenix, AZ 85014 

(attorney for Jed Brunst) 

Mike Piccarreta, Esq. 

Piccarreta Davis Keenan Fidel PC 

2 East Congress Street, Suite 1000 

Tucson, AZ 85701 

(attorney for Andrew Padilla) 

Robert Corn-Revere 

Davis Wright Tremaine LLP 

1919 Pennsylvania Avenue NW, 

Suite 800 

Washington, DC 20006 

(attorney for Lacey and Larkin) 

Bruce Feder, Esq. 

2930 East Camelback Road, Suite 

160 

Phoenix, Arizona 85016 

(attorney for Scott Spear) 

Steve Weiss 

Attorney at Law 

Karp & Weiss, P.C. 

3060 North Swan Rd. 

Tucson, Arizona 85712 

(attorney for Joye Vaught) 

Re: U.S. v. Michael Lacey, et al. 

CR-18-00422-PHX-SPL (BSB) 

Dear Counsel: 

This letter is meant to address the content on a number of servers that were seized and how 

we intend to comply with our Rule 16 obligations. As background, the United States seized 32 

servers and three hard drives located in Tucson at an Internet service provider known as Desert 

Net. Desert Net was the primary domestic (Internet) host for Backpage. The servers have varying 

Case 2:18-cr-00422-SPL Document 444-1 Filed 01/18/19 Page 36 of 38 Case 2:18-cr-00422-DJH Document 627-4 Filed 06/01/19 Page 2 of 4
December 10, 2018 

Page 2 

amounts of storage: some have 14.4 Terabyte (TB), another 7.2 TB, others 19.2 TB while others 

have 120 TB of storage. We have not gone through every server to determine the capacity. In the 

last subpoena we wrote, we estimated the capacity at approximately 500 TB or 1/2 petabyte (PB). 

Five additional servers were seized from Dallas, TX; one from Backpage Headquarters, and four 

additional servers from a datacenter in Dallas. Investigating agents also located 40 servers at a 

datacenter in Amsterdam, the Netherlands. Agents took possession of nine of the 40 servers in 

Amsterdam pursuant to an MLAT request and brought those servers to the Pocatello FBI office 

for examination. To date, two of the servers seized from the Tucson, AZ datacenter have been 

imaged, and the examination is ongoing. Also, four of the servers from the Amsterdam datacenter 

have been imaged. 

All seized servers are being prioritized to be added to the queue to be imaged and prepared 

for review. One of the domestic servers contain literally millions of images that were uploaded 

for postings. The second server has over 100 separate databases which were used by Backpage to 

house, organize, and store data for the Backpage websites. The server's databases were named 

based on geographic regions. Some databases correlate with airport codes and others are a threeletter code that represent a yet undetermined geographic region. From this server we have access 

to the raw database files and are working to reconstruct the .ibd and .frm database files. These raw 

database files cannot be simply reviewed or loaded into a viewer to reconstruct the data. We are 

currently working on a solution to review these database files and correlate the images posed to 

the image server to the posts from the database files. Investigators were informed by the DesertNet 

administrators that the 31 servers remaining in Amsterdam did not contain pertinent data, but were 

utilized for frontend websites associated with Backpage. Once all servers are imaged, 

investigators will be able to provide hash verified image copies of all imaged drives. Due to the 

capacity of the Backpage servers this will be a time intensive undertaking and the imaged copies 

will be distributed over hundreds of hard disk drives. 

In the final analysis, these servers contain millions of postings, both domestic and 

international, that are typical of the ads that are referenced in the PSI report, the Superseding 

Indictment, and provided discovery. As you know, the international postings contain considerably 

more explicit text and photos indicative of prostitution because they were not subject to moderation 

and in some of the countries, unlike the United States, prostitution is legal. A random sampling 

demonstrates that the domestic postings are typical of all too familiar ads that contain coded text 

and photos indicative of prostitution. It is unclear how a review of each posting would lend itself 

to the stated defense that they are protected by the First Amendment. In any event, we intend to 

provide defendants a single copy of the hard drives for review. If you disagree with this process 

please advise so that we may promptly raise this issue with the Court. 

Case 2:18-cr-00422-SPL Document 444-1 Filed 01/18/19 Page 37 of 38 Case 2:18-cr-00422-DJH Document 627-4 Filed 06/01/19 Page 3 of 4
December 10, 2018 

Page 3 

BRIAN BENCZKOWSKI 

Assistant Attorney General 

Criminal Division 

U.S. Department of Justice 

REGINALD E. JONES 

Senior Trial Attorney, CEOS 

(202) 616-2807 

regina ld ones4@usdoj gov 

ELIZABETH A. STRANGE 

First Assistant U.S. Attorney 

s/ Kevin M. Rapp 

KEVIN M. RAPP 

MARGARET PERLMETER 

PETER S. KOZINETS 

ANDREW STONE 

Assistant United States Attorneys 

JOHN J. KUCERA 

Special Assistant U.S. Attorney 

Case 2:18-cr-00422-SPL Document 444-1 Filed 01/18/19 Page 38 of 38 Case 2:18-cr-00422-DJH Document 627-4 Filed 06/01/19 Page 4 of 4