EXHIBIT INDEX TO DEFENDANTS’ RESPONSE TO GOVERNMENT’S 

MOTION TO PRECLUDE DEFENSE FROM REFERENCING CRAIGSLIST 

MEETINGS WITH ATTORNEYS GENERAL

United State of America v. Michael Lacey, et al.

2:18-cr-00422-PHX-DJH

Exhibit Description

A Def. Trial Ex. 5054

B Gov’t Trial Ex. 17

Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 1 of 10
EXHIBIT A

Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 2 of 10
craigslist, the Attorneys General listed below, and the National Center for Missing and Exploited

Children ("NCMEC"), announce new measures that craigslist is taking to help combat unlawful activity

and improve public safety on its web site.

This agreement culminates a series of discussions and in person meetings between Jim Buckmaster,

CEO ofcraigslist, Richard Blumenthal, Attorney General ofthe State of Connecticut, and NCMEC.

craigslist is a popular internet classifieds service that provides the public with many benefits. Like

all communication tools, it can unfortunately be misused to facilitate unlawful activity.

craigslist has a long record of implementing measures to prevent misuse of its web site, assisting

law enforcement investigations, and of improving safety for craigslist users. Law enforcement personnel

have called craigslist's attention to misuse of craigslist's "erotic services" category to facilitate unlawful

activity. This problem requires new safeguards for craigslist and new ways of working together with law

enforcement. Further innovation and collaboration in addressing these issues will be beneficial for the

safety of craigslist users and the general public. Accordingly, craigslist, the Attorneys General, and

NCMEC, announce the following measures for combating unlawful activity and improving public safety

on craigslist:

• craigslist has implemented a community self-policing program which allows users to "flag" a

posting the user believes violates the terms of use, including the prohibition against pornography.

The objectionable posting is eliminated automatically if it receives above a threshold number of

flags.

• craigslist uses electronic screening to block certain advertisements that craigslist believes will

violate its Terms of Use before they are posted.

• craigslist digitally tags adult sections of the site using industry standard PICS rating headers to

facilitate the effectiveness of PC-based parental screening software.

• craigslist has implemented a telephone verification system for the "erotic services" section of the

site requiring any person seeking to post an advertisement to provide a working telephone number.

• Telephone verification enables craigslist to permanently block the phone number of any person

posting unlawful or inappropriate advertisements.

• craigslist plans to implement credit card verification and fee to post for its "erotic services"

category. Persons wishing to post ads in this category will be required to pay a fee using a valid

credit card.

• Credit card verification and fee to post will reduce ad volume significantly, and encourage more

responsible usage.

Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 3 of 10
• Credit Card verification provides additional identifying information that will enable craigslist to

block the accounts of persons who violate craigslist's terms of use.

• credit card information would be available to law enforcement agencies through a subpoena

process.

• craigslist plans to contribute 100% of the net revenues from these advertisements to charity. A

public accounting firm will verify the net revenue amounts.

• Misuse of craigslist is facilitated by companies providing spamming, posting, and/or flagging

services. These businesses seek financial profit by providing services and/or software that

circumvent craigslist's terms of use and defense mechanisms or facilitate circumvention by other

persons.

• craigslist has initiated (or will soon initiate) lawsuits against a number of these companies that

violate craigslist's terms of use (or facilitate the violation ofcraigslist's terms of use by others).

• craigslist will provide evidence of unlawful activity by these operators to the Attorneys General for

potential prosecution.

• craigslist has developed search capabilities that enhance its ability to assist NCMEC and law

enforcement agencies to locate missing persons, and identify exploited minors and victims of

human trafficking.

• craigslist is continuing its development efforts in this area to further enhance its ability to assist law

enforcement NCMEC and even social welfare agencies in their efforts to protect children from this

type of victimization.

• craigslist is visited by more than 40 million Americans each month, generating more than 12 billion

monthly page views. Information presented by craigslist can help raise awareness among

Americans regarding the enormous suffering caused by human trafficking and the exploitation of

minors in this country.

• craigslist, the Attorneys General, and NCMEC will work together to further refine and improve

educational materials that are currently available on craigslist.

• craigslist and the Attorneys General will meet on a regular basis to discuss design and functionality

improvements to combat unlawful activity and improve safety on its web site.

Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 4 of 10
• craigslist will explore the implementation and use of technology that prevents image uploads likely

to violate its terms of use.

• craigslist will work with the Attorneys General to develop more robust electronic screening of

language used in craigslist postings.

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Jim Buckmaster

President and Chief Executive Officer

craigslist, Inc.

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Ernie Allen

President and Chief Executive Officer

National Center for Missing and Exploited

Children

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Terry Goddard

Attorney General of Arizona

Richard Blumenthal

Attorney General of Connecticut

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Dustin B. McDaniel

Attorney General of Arkansas

John W. Suthers

Attorney General of Colorado

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Richard S. Gebelein

Acting Attorney General of Delaware

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P~ter J.1'l1ickles

Attorney General ofthe District of Columbia

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Thurbert E. Baker

Attorney General of Georgia

Alicia G. Limtiaco

Attorney General of Guam

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Mark J. Bennett

Attorney General of Hawaii

Lawrence G. Wasden

Attorney General of Idaho

Lisa

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Madigan

Attorney General of Illinois

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Stephen Carter

Attorney General of Indiana

Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 5 of 10
Tom Miller

Attorney General of Iowa

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Attorney General of Kansas

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Jac:conway"O

Attorney General of Kentucky

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James D. "Buddy" Caldwell

Attorney General of Louisiana

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Douglas F. Gansler

Attorney General of Maryland

Steven Rowe

Attorney General of Maine

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Jim Hood

Attorney General of Mississippi

Mike McGrath

Attorney General of Montana

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Catherine Cortez Masto

Attorney General of Nevada

Jon Bruning

Attorney General of Nebraska

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Kelly A. Ayotte

Attorney General of New Hampshire

Anne Milgram

Attorney General of New Jersey

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Roy Cooper

Attorney General of North Carolina

Gary King

Attorney General of New Mexico

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Wayne Stenehjem

Attorney General of North Dakota

Nancy H. Rogers

Attorney General of Ohio

Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 6 of 10
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Hardy Myers

Attorney General of Oregon

Drew Edmondson

Attorney General of Oklahoma

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Tom Corbett

Attorney General of Pennsylvania

Patrick C. Lynch

Attorney General of Rhode Island

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Henry McMaster

Attorney General of South Carolina

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Attorney General of South Dakota

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Robert E. Cooper, Jr.

Attorney General of Tennessee

Mark L. Shurtleff

Attorney General of Utah

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William H. Sorrell

Attorney General of Vermont

Vincent F. Frazer

Attorney General of the Virgin Islands

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Robert F. McDonnell

Attorney General of Virginia

Rob McKenna

Attorney General of Washington

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Darrell V. McGraw, Jr.

Attorney General of West Virginia

J. B. Van Hollen

Attorney General of Wisconsin

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Bruce A. Salzburg

Attorney General of Wyoming

Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 7 of 10
EXHIBIT B

Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 8 of 10
From: 

Sent: 

To: 

Subject: 

Carl Ferrer [carl.ferrer@backpage.com] on behalf of Carl Ferrer 

Saturday, November 22, 2008 4:01 PM 

carlferrer1 S@gmail.com 

Fwd: Re: Fwd: Re: Backpage.com November Revenue Report 

Date: Sat, 22 Nov 2008 09:00:36 -0700 

From: "Dan Hyer" <Dan.Hyer@dallasobserver.com> 

To: "Carl Ferrer" <Carl.Ferrer@backpage.com> 

Subject: Re: Fwd: Re: Backpage.com November Revenue Report 

Wow - thanks for the nod! 

I notice we were having a really good month. Did we let someone back in who was out? I'd 

love to attribute that to Christina's aggregation efforts, but the ads she posted were free, 

so we haven't likely reaped the reward of her efforts. 

Thomas trained Bailey on Friday to do MBS aggregation, so she's an under the radar aggregator 

that will eventually become a bp.com employee. I think the females will have better success 

with MBS - if a male calls, they first think it's a client and are on guard. 

>>> Carl Ferrer 11/21/08 11:28 PM>>> 

fyi. ... 

I think in LA, we need to find the agencies and get them started with 25 posting credits. 

btw: the revenue wasn;t the great except for dallas. Most of the sites with banner ads are 

down or flat. 

earl 

>>> Carl Ferrer 11/21/2008 5:35 PM>>> 

Dallas sure gave us a nice bump. Hyer's done an awesome job with his marketing crew. 

Now, it's about building LA. It starts with improved content and Dan's on it. 

I want a strong west coast market. 

Carl 

>>> Jim Larkin <Jim.Larkin@VillageVoiceMedia.com> 11/21/2008 4:46 PM>>> 

Carl: 

Congratulations!!!!!!!! 

Another great month, you're leading the way for the whole WM enterprise onto the web! 

Larkin 

On Nov 21, 2008, at 3:51 PM, Jess Adams wrote: 

> Hello everyone - here is November's report. 

> 

> Highlights: 

> 

CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER-ATTORNEYS' EYES ONLY BACKPAGE00033590 

DOJ-BP-0004602604 

Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 9 of 10
> Total Revenue $540K - record 4 week month Web Revenue - record 4 week 

> month, best month ever in terms of weekly/ 7 day average National 

> Revenue - record 4 week month Total ads 1,161,140 - record 4 week 

> month, best month ever in terms of weekly/ 7 day average Visits 

> 13,437,390 - record 4 week month, best month ever in terms of weekly/ 

> 7 day average PageViews 221,405,718 - record 4 week month, best month 

> ever in terms of weekly/ 7 day average 

> 

> We had a 10.2 million page view day this past week (best day ever), 

> and we jumped 3.5 million page views per week across the network in 

> November over October. 

> 

> You are probably aware that Craigslist has begun charging for adult 

> postings in conjunction with a settlement reached with 40 state 

> attorney generals. This represents validation of our adult business 

> model (screening out underage posters, financial data for law 

> enforcement subpoenas, etc) and represents a tremendous growth 

> opportunity for Backpage.com -> when Craig was free, users were still 

> paying to post with us. Now the free competitor is gone ... 

> 

> Thank you, 

> 

> 

> Jess Adams 

> Accountant 

> Backpage.com 

> (602) 440-1125 

> <Backpage - November 2008 Revenue Report.xls> 

2 

CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER-ATTORNEYS' EYES ONLY BACKPAGE00033591 

DOJ-BP-0004602605 

Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 10 of 10