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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 

PROPOSED STIPULATED JOINT 

STATEMENT OF THE CASE

United States’ Proposed Joint Statement of the Case

Six individuals (Michael Lacey, James Larkin, Scott Spear, John “Jed” Brunst, 

Andrew Padilla, and Joye Vaught) (“Defendants”) have been charged with: (1) conspiracy 

to commit violations of the Travel Act by facilitating prostitution; and (2) violations of the 

Travel Act. 

Four of these Defendants, Michael Lacey, James Larkin, Scott Spear, John “Jed” 

Brunst, have also been charged with: (1) conspiracy to commit money laundering; (2) 

concealment money laundering; (3) intentional promotional money laundering; and (4) 

transactional money laundering. 

In addition, Defendant Michael Lacey has been charged with international 

concealment money laundering. 

The charges arise from the Defendants’ various roles in the creation, operation, and 

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management of the website Backpage.com. Each Defendant has pleaded not guilty to the 

charges against him or her and are presumed innocent. The United States has the burden 

of proving an individual guilty beyond a reasonable doubt.

Defendants’ Objections

The government’s language inaccurately summarizes the alleged violation of the 

Travel Act. One cannot violate the Travel Act by generally “facilitating prostitution” (or 

conspiring to “facilitate prostitution”). Rather, someone must “travel in interstate or 

foreign commerce” or “use” a “facility interstate or foreign commerce, with intent to . . . 

promote, manage, establish, carry on, or facilitate the promotion, management, 

establishment, or carrying on, of a . . . business enterprise involving . . . prostitution 

offenses in violation of the laws of the State in which they are committed,” and “thereafter 

perform or attempt[] to perform” an act to “promote” or “facilitate.” 18 U.S.C. 

§ 1952(a)(3), (b)(i). Defendants’ proposed joint statement more accurately describes the 

charges and also provides some plain-english background to the case that may be helpful 

to prospective jurors.

Defendants’ Proposed Joint Statement of the Case

This is a criminal case brought by the United States government. Michael Lacey, 

James (Jim) Larkin, John (Jed) Brunst, Scott Spear, Andrew Padilla, and Joye Vaught are 

charged with various crimes related to their alleged roles in the creation, ownership, 

development, and management of the website Backpage.com. Each defendant has pleaded 

not guilty to all charges and is presumed innocent. The United States has the burden of 

proving an individual guilty beyond a reasonable doubt.

Backpage.com was an online classified advertising website. The government 

alleges that the defendants, in their various roles related to the website, agreed to and did 

knowingly and intentionally facilitate specific business enterprises involving prostitution 

offenses. The defendants deny these allegations.

The government alleges that defendants Lacey, Larkin, Brunst, and Spear also 

agreed to and did engage in various financial transactions designed to conceal or promote 

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the conduct at Backpage.com that the government alleges was criminal. The defendants 

deny these allegations.

Each defendant is charged in Count 1, Conspiracy to Violate the Travel Act and 

Counts 2-51, Violations of the Travel Act. Michael Lacey is charged in Counts 53-62, 

Concealment Money Laundering; Counts 63-68, International Promotional Money 

Laundering; Counts 69-70, 81, 83-84, 86, 88-92, and 94-99, Transactional Money 

Laundering; and Count 100, International Concealment Money Laundering. James Larkin 

is charged in Count 52, Conspiracy to Commit Money Laundering; Counts 53-62, 

Concealment Money Laundering; Counts 63-68, International Promotional Money 

Laundering; and Counts 80 and 87, Transactional Money Laundering.

Scott Spear is charged in Count 52, Conspiracy to Commit Money Laundering; 

Counts 53-62, Concealment Money Laundering; Counts 63-68, International Promotional 

Money Laundering; and Counts 71-78, 85 and 93, Transactional Money Laundering.

John “Jed” Brunst is charged in Count 52, Conspiracy to Commit Money 

Laundering; Counts 53-62, Concealment Money Laundering; Counts 63-68, International 

Promotional Money Laundering; and Counts 69-70, 78-84, and 86-93, Transactional 

Money Laundering.

United States’ Objections

The United States wrote its proposed statement of the case so that it was consistent 

with the joint statement in the proposed juror pre-screening questionnaire as requested by 

the Court. (Doc. 1524 at 5, n.3.) In addition to varying substantially from the joint 

statement in the proposed juror pre-screening questionnaire, Defendants’ statement is 

clunky and difficult to follow. Including all the Counts is unnecessary and will simply 

serve to confuse the jury. The United States’ proposed statement should be read.

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