EXHIBIT A 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 1 of 49
U.S. Department of Justice 

United States Attorney 

District of Arizona 

Two Renaissance Square Main: (602) 514-7500 

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

Phoenix, AZ 85004-4408 

February 22, 2019 

Paul J. Cambria Jr. 

Attorney at Law 

Lipsitz Green Scime Cambria, 

LLC 

42 Delaware Ave, Suite 120 

Buffalo, NY 14202 

(attorney for Michael Lacey) 

Thomas H. Bienert, Jr., Esq. 

Bienert, Miller & Katzman, 

PLC 

903 Calle Amanecer, Suite 350 

San Clemente, CA 92673 

(attorney for James Larkin) 

Mike Piccarreta, Esq. 

Piccarreta Davis Keenan Fidel, 

PC 

2 East Congress Street, 

Suite 1000 

Tucson, AZ 85701 

(attorney for Andrew Padilla) 

Jim Grant 

Davis Wright Tremaine, LLP 

920 Fifth Avenue, 

Suite 3300 

Seattle, WA 98104 

(attorney for Lacey and Larkin) 

Michael D. Kimerer, Esq. 

1313 E. Osborn Road, 

Suite 100 

Phoenix, AZ 85014 

(attorney for Jed Brunst) 

Steve Weiss 

Attorney at Law 

Karp & Weiss, PC 

3060 North Swan Rd. 

Tucson, AZ 85712 

(attorney for Joye Vaught) 

Robert Corn-Revere 

Davis Wright Tremaine, LLP 

1919 Pennsylvania Avenue N.W., 

Suite 800 

Washington, DC 20006 

(attorney for Lacey and Larkin) 

Bruce Feder, Esq. 

2930 East Camelback Road, 

Suite 160 

Phoenix, AZ 85016 

(attorney for Scott Spear) 

Gary Lincenberg 

Bird, Marella, Boxer, Wolpert, 

Nessim, Drooks, Lincenberg & Rhow, 

P.C. 

1875 Century Park East 

23rdFloor 

Los Angeles, CA 90067 

(attorney for Jed Brunst) 

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

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

Dear Counsel: 

Pursuant to your request for discovery and the government's obligations under Fed. R. Crim. 

P. 16 and the stipulated scheduling order in this case, please find enclosed 7 digital media devices 

containing the government's seventh disclosure.1 

1Digital media devices containing disclosure for defendants Michael Lacey, James Larkin, and Jed 

Brunst are being provided to Paul J. Cambria Jr., Thomas H. Bienert Jr., and Gary Lincenberg 

respectively. 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 2 of 49
Lacey, et. al. Discovery Letter 7 

February 22, 2019 

Page 2 

• The thumb drive contains the following Bates Stamped records: 

o BDO Consulting Documents — DOJ-BP-0004720537 to DOJ-BP-0004735011 

o Reports of Interviews — DOJ-BP-0004735012 to DOJ-BP-0004735223 

o Subpoena Compliance, Reports of Interviews, and other FBI Case Documents — DOJBP-0004735224 to DOJ-BP-0004746570 

• The DVD labeled Backpage Hyer Docs contains reports of interviews for Defendant Daniel 

Hyer. 

• The DVD labeled Jail Calls contains jail calls for Defendants Michael Lacey and James 

Larkin 

• The DVD labeled Macomb County Prosecutor contains recorded interviews from the 

Macomb County, Michigan, quadruple murder investigation of James C. Brown. In February 

of 2014, Brown was convicted of killing four women he met through Backpage.com. 

• The DVD labeled Recorded Interviews with Victim #4 contains recorded interviews from 

Victim 4's local investigation. Victim 4's summary is included in paragraph 163 of the 

Superseding Indictment. 

• The 2 DVD's labeled JDPA Office Gretna, LA contains case-related documents from the 

local investigation of Victim #15 trafficked via Backpage.com. Victim 15's summary is 

included in paragraph 174 of the Superseding Indictment. 

Additionally, the government has in its possession copies of tax returns and related 

transmittals prepared by BDO USA Consulting for Backpage and related clients. These documents 

will not be made generally available to counsel. If you believe you have a basis to access these 

documents, please let us know and we will address this matter with the Court. 

Lastly, during our execution of search warrants on April 5, 2018, we seized data from Jill 

Anderson's personal devices. Neither the prosecution team nor the taint team have reviewed (or 

intend to review) this data. If you would like to review this data, please let us know and we will 

facilitate your review at an FBI facility in Phoenix. 

Please reach out with any questions. 

Sincerely, 

BRIAN BENCZKOWSKI 

Assistant Attorney General 

Criminal Division 

U.S. Department of Justice 

/s Reginald Jones 

REGINALD E. JONES 

Senior Trial Attorney, CEOS 

(202) 616-2807 

reginald.jones4@usdoj.gov 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 3 of 49
Lacey, et. al. Discovery Letter 7 

February 22, 2019 

Page 3 

ELIZABETH A. STRANGE 

First Assistant U.S. Attorney 

KEVIN M. RAPP 

MARGARET PERLMETER 

PETER S. KOZINETS 

ANDREW STONE 

JOHN J. KUCERA 

Assistant United States Attorneys 

Enclosures 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 4 of 49
EXHIBIT B 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 5 of 49
U.S. Department of Justice 

United States Attorney 

District of Arizona 

Two Renaissance Square Main: (602) 514-7500 

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

Phoenix, AZ 85004-4408 

March 14, 2019 

Paul J. Cambria Jr. 

Attorney at Law 

Lipsitz Green Scime Cambria, 

LLC 

42 Delaware Ave, Suite 120 

Buffalo, NY 14202 

(attorney for Michael Lacey) 

Thomas H. Bienart, Jr., Esq. 

Bienart, Miller & Katzman, 

PLC 

903 Calle Amanecer, Suite 350 

San Clemente, CA 92673 

(attorney for James Larkin) 

Mike Piccarreta, Esq. 

Piccarreta Davis Keenan Fidel, 

PC 

2 East Congress Street, 

Suite 1000 

Tucson, AZ 85701 

(attorney for Andrew Padilla) 

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, 

Suite 100 

Phoenix, AZ 85014 

(attorney for Jed Brunst) 

Steve Weiss 

Attorney at Law 

Karp & Weiss, PC 

3060 North Swan Rd. 

Tucson, AZ 85712 

(attorney for Joye Vaught) 

Robert Corn-Revere 

Davis Wright Tremaine, LLP 

1919 Pennsylvania Avenue N.W., 

Suite 800 

Washington, DC 20006 

(attorney for Lacey and Larkin) 

Bruce Feder, Esq. 

2930 East Camelback Road, 

Suite 160 

Phoenix, AZ 85016 

(attorney for Scott Spear) 

Gary Lincenberg 

Bird, Marella, Boxer, Wolpert, 

Nessim, Drooks, Lincenberg & Rhow, 

P.C. 

1875 Century Park East 

23rdFloor 

Los Angeles, CA 90067 

(attorney for Jed Brunst) 

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

CR-18-00422-PHX-SMB 

Dear Counsel: 

Pursuant to your request for discovery and the government's obligations under Fed. R. Crim. 

P. 16 and the stipulated scheduling order in this case, please find enclosed a thumb drive containing 

the government's eighth disclosure.1 

1 A thumb drive containing disclosure for defendants Michael Lacey, James Larkin, and Jed Brunst 

are being provided to Paul J. Cambria Jr., Thomas H. Bienart Jr., and Gary Lincenberg respectively. 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 6 of 49
Lacey, et. al. Discovery Letter 8 

March 14, 2019 

Page 2 

• The thumb drive contains the following Bates Stamped records: 

o Additional Financial Records — D0J-BP-0004746571-D0J-BP-0004791098 

o Additional Reports of Interviews — D0J-BP-0004791099-D0J-BP-0004791128 

o Additional Subpoena Compliance, Reports of Interviews, and other FBI Case 

Documents —D0J-BP-0004791129-D0J-BP-0004791240 

Additionally, as we indicated in our November 30, 2018 discovery transmittal letter, Amazon 

Web Service ("AWS") data and a virtual machine on which some of the MySQL database was 

obtained from the State of California pursuant to a search warrant are available upon request. The 

AWS data includes raw MySQL data the State of California understood was data from the Backpage 

Payment Processing Island—a web server hosted by AWS that received credit card and similar 

payment data from Backpage users. The virtual machine includes some of the MySQL database 

data received from AWS. 

Also, we have separately mailed counsel Whitney Bernstein of Bienart, Miller & Katzman a 

DVD that contains a sampling of approximately 70 Backpage ads with associated databases and 

images (as such ads appear in the server data the government has imaged and made available to you), 

to include ads referenced in the Superseding Indictment. 

Please reach out with any questions. 

Sincerely, 

BRIAN BENCZKOWSKI 

Assistant Attorney General 

Criminal Division 

U.S. Department of Justice 

REGINALD E. JONES 

/s Reginald Jones 

Senior Trial Attorney, CEOS 

(202) 616-2807 

reginald.jones4@usdoj.gov 

ELIZABETH A. STRANGE 

First Assistant U.S. Attorney 

KEVIN M. RAPP 

MARGARET PERLMETER 

PETER S. KOZINETS 

ANDREW STONE 

JOHN J. KUCERA 

Assistant United States Attorneys 

Enclosures 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 7 of 49
EXHIBIT C 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 8 of 49
U.S. Department of Justice 

United States Attorney 

District of Arizona 

Two Renaissance Square Main: (602) 514-7500 

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

Phoenix, AZ 85004-4408 

March 18, 2019 

Via E-MAIL 

Thomas H. Bienert, Jr. 

Bienert, Miller & Katzman, PLC 

(attorney for James Larkin) 

Paul J. Cambria Jr. 

Lipsitz Green Scime Cambria, 

LLC 

(attorney for Michael Lacey) 

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

CR-18-00422-111X-SMB 

Dear Counsel: 

We write to infonn you that we have imaged the personal devices and documents seized from 

Defendants Michael Lacey and James Larkin pursuant to a court-authorized search warrant. The hard drives 

and CD's containing this data are available for pick-up at an FBI facility in Phoenix.' As you are aware, 

the government's filter protocol was recently approved by the Court on January 22, 2019 (see CR 445); 

thus, the aforementioned data is being processed for our review in accordance with the approved filter 

procedures. However, in order to avoid delay of any review you may want to conduct of these materials, 

we are providing them to you at this time. We will also provide you with exhibits of any of the abovementioned data the government might utilize at trial. 

Please reach out to me to schedule a time to pick-up these materials. 

BRIAN BENCZKOWSKI 

Assistant Attorney General 

Criminal Division 

U.S. Department of Justice 

s/Reginald E. Jones 

REGINALD E. JONES 

Senior Trial Attorney, CEOS 

As detailed in our February 22, 2019 discovery transmittal letter to you, hard drives containing data seized from 

Jill Anderson's personal devices are also available for pick-up at an FBI facility in Phoenix. 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 9 of 49
March 18, 2019 

Page 2 

(202) 616-2807 

reginald ones4(&,usdoj .gov 

ELIZABETH A. STRANGE 

First Assistant U.S. Attorney 

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-DJH Document 524-1 Filed 04/16/19 Page 10 of 49
EXHIBIT D 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 11 of 49
U.S. Department of Justice 

United States Attorney 

District of Arizona 

Two Renaissance Square Main: (602) 514-7500 

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

Phoenix, AZ 85004-4408 

March 18, 2019 

VIA E-MAIL 

Paul J. Cambria Jr. 

Attorney at Law 

Lipsitz Green Scime Cambria, 

LLC 

(attorney for Michael Lacey) 

Thomas H. Bienert, Jr., Esq. 

Bienert, Miller & Katzman, 

PLC 

(attorney for James Larkin) 

Mike Piccarreta, Esq. 

Piccarreta Davis Keenan Fidel, 

PC 

(attorney for Andrew Padilla) 

Jim Grant 

Davis Wright Tremaine, LLP 

(attorney for Lacey and Larkin) 

Michael D. Kimerer, Esq. 

1313E. Osborn Road, 

(attorney for Jed Bruns° 

Steve Weiss 

Attorney at Law 

Karp & Weiss, PC 

(attorney for Joye Vaught) 

Robert Corn-Revere 

Davis Wright Tremaine, LLP 

(attorney for Lacey and Larkin) 

Bruce Feder, Esq. 

2930 East Camelback Road, 

(attorney for Scott Spear) 

Gary Lincenberg 

Bird, Marella, Boxer, Wolpert, 

Nessim, Drooks, Lincenberg & Rhow, 

P.C. 

(attorney for Jed Brunst) 

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

CR-18-00422-PHX-SMB 

Dear Counsel: 

We write to inform you that data seized from Backupify (a company Backpage utilized to 

backup and recover its cloud service data) pursuant to a court-authorized search warrant is available 

for pick-up at an FBI facility in Phoenix. Additionally, as per my March 7, 2019 letter to counsel for 

James Larkin (letter attached as Exhibit A), hard drives containing Backpage-related email data 

seized from Backpage servers located in Dallas, Texas are also available for pick-up.' As you are 

aware, the government's filter protocol was recently approved by the Court on January 22, 2019 (see 

CR 445); thus, the aforementioned data is being processed for our review in accordance with the 

approved filter procedures. However, in order to avoid delay of any review you may want to conduct 

of these materials, we are providing them to you at this time. We will also provide you with exhibits 

of any of the above-mentioned data the government might utilize at trial. 

1 On March 8, 2019 we provided Counsel Bruce Feder with hard drives containing the entire marketplace of 

Backpage ads (i.e. all of the ads that were on Bacicpage.com at the time the website was seized). 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 12 of 49
Lacey, et. al. Discovery Letter 8 

March 18, 2019 

Page 2 

Please reach out to me to schedule a time to pick-up these materials. 

Sincerely, 

BRIAN BENCZKOWSKI 

Assistant Attorney General 

Criminal Division 

U.S. Department of Justice 

/s Reginald Jones 

REGINALD E. JONES 

Senior Trial Attorney, CEOS 

(202) 616-2807 

reginald.jones4@usdoj.gov 

ELIZABETH A. STRANGE 

First Assistant U.S. Attorney 

KEVIN M. RAPP 

MARGARET PERLMETER 

PETER S. KOZ1NETS 

ANDREW STONE 

JOHN J. KUCERA 

Special Assistant U.S. Attorney 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 13 of 49
U.S. Department of Justice 

United States Attorney 

District of Arizona 

Two Renaissance Square Main: (602) 514-7500 

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

Phoenix, AZ 85004-4408 

March 7, 2019 

Via E-Mail 

Whitney Z. Bernstein 

Bienart, Miller & Katzman PLC 

EMail:wbemstein@bmkattomeys.com 

(attorney for Defendant James Larkin) 

Re: Your letter of February 2642019 

Dear Ms. Bernstein: 

We write in response to your February 26, 2019 letter summarizing our February 

20, 2019 phone call regarding Backpage server data. Your letter contains a number of 

inaccuracies. However, instead of addressing each inaccuracy contained within the letter, 

we believe it would be most fruitful to provide you with the below written summary of the 

government's handling of the Backpage server data to date. 

Total Servers 

The government has 46 Backpage servers in its possession obtained from 

Amsterdam, Netherlands ("Amsterdam"), Tucson, Arizona ("Tucson"), and Dallas, Texas 

("Dallas"). We are currently awaiting receipt of approximately 60 additional servers from 

Amsterdam through the Mutual Legal Assistance Treaty ("MLAT") process. 

Amsterdam Servers 

We currently have in our possession nine servers obtained from Amsterdam through 

the MLAT process. Of these nine servers, three are slave database servers, three are image 

servers, two are master database servers, and one is a backup server. Backpage operated 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 14 of 49
March 7, 2019 

Page 2 

as a classified advertising website for approximately 14 years so we're certain you are 

aware of the content hosted on the site. However, we extracted all of the Backpage 

marketplace database files (i.e. all of the ads that were on Backpage.com) from these 

servers and have imaged the server containing all of the Backpage images in order to help 

facilitate any review you would like to conduct of this data. As I indicated in my March 4, 

2019 email to you, the hard drives containing this data are available for pick-up at an FBI 

facility in Phoenix. Additionally, in accordance with Federal Rule of Criminal Procedure 

16(a)(1)(E), these nine servers are available for your inspection at an FBI data center 

facility in Pocatello, Idaho. Our forensic examiners located at this facility are available to 

facilitate your review of these servers and answer any technical questions you may have 

regarding this particular data. 

In addition to the aforementioned nine servers currently in the government's 

possession, we are awaiting receipt of approximately 60 servers from Dutch officials 

through the MLAT process. We have been advised by a former Backpage employee who 

managed these servers that these 60 servers contain payment processing data and data 

redundancy from the nine Amsterdam servers currently in the government's possession. 

These servers will also be available for your inspection at an FBI data center facility in 

Pocatello, Idaho when we receive them. 

Dallas Servers 

We currently have in our possession five Backpage servers seized from Dallas. Of 

these five servers, we were advised by a former Backpage employee who managed these 

servers that two of these servers contain Backpage-related email data. These two servers 

have been imaged and the hard drives containing this data are available for pick-up at an 

FBI facility in Phoenix. The former Backpage employee who managed these servers also 

advised us that the remaining three Dallas servers in our possession contain antivirus 

servers, asset tracking/inventory software, a backup server, web user interface, virtual 

private network for end point, VM servers, and WSUS. In accordance with Federal Rule 

of Criminal Procedure 16(a)(1)(E), these three servers are available for your inspection at 

an FBI data center facility in Pocatello, Idaho. Our forensic examiners located at this 

facility are available to facilitate your review of these servers and answer any technical 

questions you may have regarding this particular data. 

Tucson Servers 

We currently have in our possession 32 servers and three hard drives seized from 

Tucson. We were advised by a former Backpage employee who managed these servers 

that they contain data redundancy of the marketplace database files and images from the 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 15 of 49
March 7, 2019 

Page 3 

Amsterdam servers. We have imaged the master marketplace database and image servers. 

The hard drives containing this data are available for pick-up at an FBI facility in Phoenix. 

In accordance with Federal Rule of Criminal Procedure 16(a)(1)(E), these 32 servers are 

available for your inspection at an FBI data center facility in Pocatello, Idaho. Our forensic 

examiners located at this facility are available to facilitate your review of these servers and 

answer any technical questions you may have regarding this particular data. 

Sampling of Ad data and Ad data the Government Might Utilize at Trial 

During our February 20, 2019 phone conversation (and again in your February 26, 

2019 letter), you requested samples of "[Backpage] advertisements as such ads now appear 

in the data the government has imaged." You also requested "discrete parts of all 

advertisements that are the subject of counts in the Superseding Indictment." To be clear, 

the government has previously produced to you in discovery ads that are referenced in 

counts in the Superseding Indictment. However, we are willing to produce samples of 

Backpage ads as the ads appear in the server data the government has imaged, to include 

ads referenced in counts in the Superseding Indictment. Although we had hoped to have 

this sampling to you this week, our forensic examiner culling this data was unexpectedly 

away from the office for a number of days, so we will need additional time to compile the 

requested sampling. We will send this sampling to you as soon as possible. Also, as 

previously noted, the entire marketplace of Backpage ads have been extracted for you and 

is available for pick-up at your convenience. 

Additionally, given the voluminous amount of server data, the government agrees 

to provide to you with exhibits of any server data that we might utilize at trial. This should 

greatly assist you in focusing your efforts and attention on server data relevant to the case. 

Please reach out to me with additional questions. We will continue to work 

diligently to answer them and facilitate your review of materials in this case. 

BRIAN BENCZKOWSKI 

Assistant Attorney General 

Criminal Division 

U.S. Department of Justice 

s/Reginald E. Jones 

REGINALD E. JONES 

Senior Trial Attorney, CEOS 

(202) 616-2807 

reginaldjones4@usdoj.gov 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 16 of 49
March 7, 2019 

Page 4 

ELIZABETH A. STRANGE 

First Assistant U.S. Attorney 

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-DJH Document 524-1 Filed 04/16/19 Page 17 of 49
EXHIBIT E 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 18 of 49
From: Barbara Polowetz 

To: Rapp, Kevin (USAAZ) 

Cc: Michael Piccarreta; Jones, Reginald (CRM) 

Subject: Andrew Padilla: taint team procedures 

Date: Monday, February 11, 2019 11:59:23 AM 

Kevin: 

It appears that the government is going forward in reviewing records through use of its taint 

team to cull out any privileged communications it discovers. In order to avoid further 

problems with this procedure, I would request the following: 

1. A listing of all of the attorneys, firm names, etc. that that the taint team is using 

in its search to remove privileged matters. 

2. The names, departments, and agencies of the individuals who are members of 

the taint team. 

I think it is a good idea for the defense to review this list in case some names have been 

inadvertently omitted and thus potentially exposing members of the prosecution team to 

privileged materials which would cause all of us problems and a verification on our end that 

none of the taint teams members have any role that would lead to future motions if not 

disclosed until later. Best wishes. 

Mike Piccarreta 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 19 of 49
EXHIBIT F 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 20 of 49
PICCAR_RETA DAVIS KEENAN FIDEL PC 

LAWYERS 

MICHAEL L. PICCARRETA 

JEFFERSON KEENAN 

LOUIS S. FIDEL 

2 EAST CONGRESS STREET, SUITE 1000 

TUCSON, ARIZONA 86701 

(520) 822-6900 

FAX (520) 622-0521 

BARRY M. DAVIS WWW.P D-LAW. CO M 

(1948-2016) March 25, 2019 

VIA EMAIL: andrew.stone(&,usdoLgov 

Andrew Stone, Esq. 

United States Attorney's Office 

Two Renaissance Square 

40 N. Central Avenue, Ste. 1200 

Phoenix, AZ 85004-4408 

Re: United States v. Lacey, et al, No. CR-18-00422-PI-1X-SPL (BSB) 

Dear Andy: 

Thanks for your response regarding defendants' concerns about potentially 

privileged materials. The government indicated search terms for how it is 

segregating materials for taint team review, and we have examined exhibit H to the 

government's reply on its motion to restore privilege issues (doc. 269-8). In some 

respects, the list appears to omit some attorneys and law films that have performed 

work covered by the privilege. Enclosed is a more comprehensive list. All 

communications involving or mentioning these individuals should be segregated as 

likely privileged (including, of course, all variations on the respective names). 

Additionally, this list should be used in addition to the government's prior list (doe. 

269-8) for all review by your taint team whether done before or still to be done if 

and when you resume this process. 

Defendants' other requests remain outstanding (e.g., identification of 

individuals assigned to the taint team when it resumes review; production to 

defendants of documents the taint team proposed to disclose, see Doc. 452, and we 

reserve all rights as to the review process as a whole. 

We have attached is what we believe is the list of counsel that should be 

screened as privileged and thus segregated from review by the government in its 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 21 of 49
PICCARRETA DAVIS KEENAN FIDEL PC 

review of electronic and/or paper documents. We've created this list separately from 

the list the government created last summer. The government had some lawyers on 

their list that are not on the attached list but that does not mean they should not be 

included in the filtering process. We have provided data from which the government 

can create appropriate searches — we've not attempted to create the searches 

themselves (your list had both names and search terms). In Reggie's recent letter, he 

indicated the court has approved the government's filtering process but did not note 

that there is pending motion before the court to clarify this process (does. 452 and 

462) that has yet to be ruled on. I think it would be prudent to wait for a court ruling 

to avoid future legal issues. Best wishes. 

Sincerely, 

Mic el L. Piccarreta 

MLP :bp 

2 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 22 of 49
Name Firm Position Email Address

Craig L. Meredith Adams and Reese LLP Attorney craig.meredith@arlaw.com

Lucian T. Pera Adams and Reese LLP Attorney lucian.pera@arlaw.com

Andrew F. Newman Akin Gump Strauss Hauer & Feld LLP Attorney anewman@akingump.com

Benjamin Harris Akin Gump Strauss Hauer & Feld LLP Staff bharris@akingump.com

Carrie Varner Akin Gump Strauss Hauer & Feld LLP Attorney cvarner@akingump.com

Daniel S. Park Akin Gump Strauss Hauer & Feld LLP Attorney dspark@akingump.com

Jaime S. Rodriguez Akin Gump Strauss Hauer & Feld LLP Staff

Jeffrey Mutterperl Akin Gump Strauss Hauer & Feld LLP Staff jmutterperl@akingump.com

Katlyne N. "Katie" Miller Akin Gump Strauss Hauer & Feld LLP Attorney millerk@akingump.com

Keertain D. Chauhan Akin Gump Strauss Hauer & Feld LLP Attorney kchauhan@akingump.com

M. Scott Barnard Akin Gump Strauss Hauer & Feld LLP Attorney sbarnard@akingump.com

Megan L. Greer Akin Gump Strauss Hauer & Feld LLP Attorney megreer@akingump.com

Molly E. Whitman Akin Gump Strauss Hauer & Feld LLP Attorney mwhitman@akingump.com

Pratik A. Shah Akin Gump Strauss Hauer & Feld LLP Attorney pshah@akingump.com

Richard M. Cella Akin Gump Strauss Hauer & Feld LLP Attorney rcella@akingump.com

Scarlett Ann York-Cockrill Akin Gump Strauss Hauer & Feld LLP Legal Assistant syork-cockrill@akingump.com

Stanley M. Brand Akin Gump Strauss Hauer & Feld LLP Attorney sbrand@akingump.com

Steven R. Ross Akin Gump Strauss Hauer & Feld LLP Attorney sross@akingump.com

Thomas C. Moyer Akin Gump Strauss Hauer & Feld LLP Attorney tmoyer@akingump.com

Alex Wood Arguedas Cassman Headley & Goldman LLP Legal Assistant wood@achlaw.com

Cristina C. Arguedas Arguedas Cassman Headley & Goldman LLP Attorney arguedas@achlaw.com

Julie Salamon Arguedas Cassman Headley & Goldman LLP Attorney salamon@achlaw.com

Ted W. Cassman Arguedas Cassman Headley & Goldman LLP Attorney cassman@achlaw.com

John R. Becker Becker & House Attorney john@beckerandhouse.com

Anthony "Tony" Bisconti Bienert Miller Katzman PLC Attorney tbisconti@bmkattorneys.com

John Littrell Bienert Miller Katzman PLC Attorney jlittrell@bmkattorneys.com

Kenneth M. Miller Bienert Miller Katzman PLC Attorney kmiller@bmkattorneys.com

Thomas H. Bienert, Jr. Bienert Miller Katzman PLC Attorney tbienert@bmkattorneys.com

Toni Lindemann Bienert Miller Katzman PLC Legal Assistant tlindemann@bmkattorneys.com

Toni Thomas Bienert Miller Katzman PLC Legal Assistant tthomas@bmkattorneys.com

Whitney Bernstein Bienert Miller Katzman PLC Attorney wbernstein@bmkattorneys.com

Ariel A. Neuman Bird Marella Boxer Wolpert Nessim Drooks Lincenberg & Rhow, P.C. Attorney aneuman@birdmarella.com

Gary S. Lincenberg Bird Marella Boxer Wolpert Nessim Drooks Lincenberg & Rhow, P.C. Attorney glincenberg@birdmarella.com

Gopi K. Panchapakesan Bird Marella Boxer Wolpert Nessim Drooks Lincenberg & Rhow, P.C. Attorney gpanchapakesan@birdmarella.com

Hemanshu "Hemu" Nigam Bitiya Consulting, Inc. dba SSP Blue Attorney hnigam@sspblue.com 

Simrin Hooper Bitiya Consulting, Inc. dba SSP Blue shooper@sspblue.com

Elizabeth L. (Liz) McDougall Brentwood, Inc. Attorney lmcdougall@backpage.com

Angelo Calfo Calfo Harrigan Leyh & Eakes (nka Calfo Eakes & Ostrovsky) Attorney angeloc@calfoharrigan.com

Ian O'Neill Cooley Attorney ioneill@cooley.com

Susan Lyon Cooley Attorney slyon@cooley.com

Della Bryan Copeland Franco Screws & Gill Legal Assistant Bryan@copelandfranco.com

Robert D. "Bobby" Segall Copeland Franco Screws & Gill Attorney Segall@copelandfranco.com

Ronda Benavidez Copeland Franco Screws & Gill Staff Benavidez@copelandfranco.com

Christopher F. Allen Cozen O'Connor Attorney callen@cozen.com 

Daniel J. Quigley Daniel J. Quigley, PLC Attorney quigley@djqplc.com

David W. Dratman David W. Dratman Attorney dwdratman@aol.com

Ambika K. Doran Davis Wright Tremaine LLP Attorney ambikadoran@dwt.com

Andrew J. Lorentz Davis Wright Tremaine LLP Attorney AndrewLorentz@dwt.com

Anita Miller Davis Wright Tremaine LLP Legal Assistant AnitaMiller@dwt.com

Brendan Charney Davis Wright Tremaine LLP Attorney BrendanCharney@dwt.com

Bret Masterson Davis Wright Tremaine LLP Staff bretmasterson@dwt.com

Brian J. Hurh Davis Wright Tremaine LLP Attorney brianhurh@dwt.com

Candice Tewell Davis Wright Tremaine LLP Attorney candicetewell@dwt.com

Candice Woods Davis Wright Tremaine LLP Attorney candicewoods@dwt.com

Carol Kaltenbaugh Davis Wright Tremaine LLP Legal Assistant carolkaltenbaugh@dwt.com

Chris Ott Davis Wright Tremaine LLP Attorney ChrisOtt@dwt.com

Chris Swift Davis Wright Tremaine LLP Attorney chrisswift@dwt.com

Christine Kruger Davis Wright Tremaine LLP Legal Assistant ChristineKruger@dwt.com

Daniela Najera Davis Wright Tremaine LLP Legal Assistant DanielaNajera@dwt.com

David Maas Davis Wright Tremaine LLP Attorney jamesmann@dwt.com

Eric M. Stahl Davis Wright Tremaine LLP Attorney ericstahl@dwt.com

James C. Grant Davis Wright Tremaine LLP Attorney jamesgrant@dwt.com

James H. (Jamie) Wendell Davis Wright Tremaine LLP Attorney jamiewendell@dwt.com

James H. Mann Davis Wright Tremaine LLP Attorney jamesmann@dwt.com

Jeffrey B. Coopersmith Davis Wright Tremaine LLP Attorney jeffcoopersmith@dwt.com

Jennifer Cygnor Davis Wright Tremaine LLP Legal Assistant JenniferCygnor@dwt.com

Joe Weinstein Davis Wright Tremaine LLP Attorney oeweinstein@dwt.com

John A. Goldmark Davis Wright Tremaine LLP Attorney johngoldmark@dwt.com

Kathleen Forgette Davis Wright Tremaine LLP Legal Assistant kathleenforgette@dwt.com

Keith Morton Davis Wright Tremaine LLP Legal Assistant keithmorton@dwt.com

Lesley Smith Davis Wright Tremaine LLP Legal Assistant lesleysmith@dwt.com

Linda Nordstedt Davis Wright Tremaine LLP Staff lindanordstedt@dwt.com

Lisa B. Zycherman Davis Wright Tremaine LLP Attorney lisazycherman@dwt.com

Mark Bartlett Davis Wright Tremaine LLP Attorney markbartlett@dwt.com 

Marni Shapiro Davis Wright Tremaine LLP Legal Assistant marnishapiro@dwt.com

Matt Cooper Davis Wright Tremaine LLP Attorney mattcooper@dwt.com

Melissa Andrzejewski Davis Wright Tremaine LLP Legal Assistant melissaandrzejewski@dwt.com

Nara Neves Davis Wright Tremaine LLP Legal Assistant naraneves@dwt.com

Nathan W. Rouse Davis Wright Tremaine LLP Attorney nathanrouse@dwt.com

Nicole Phillis Davis Wright Tremaine LLP Attorney NicolePhillis@dwt.com

Patrick J. Curran, Jr. Davis Wright Tremaine LLP Attorney patcurran@dwt.com

Peter Karanjia Davis Wright Tremaine LLP Attorney peterkaranjia@dwt.com

Robert Corn-Revere Davis Wright Tremaine LLP Attorney bobcornrevere@dwt.com

Robert E. Miller Davis Wright Tremaine LLP Attorney robertmiller@dwt.com

Ronald G. London Davis Wright Tremaine LLP Attorney ronnielondon@dwt.com

Scott Commerson Davis Wright Tremaine LLP Attorney ScottCommerson@dwt.com

Suzette Barber Davis Wright Tremaine LLP Legal Assistant suzettebarber@dwt.com

Thomas E. Scanlon Davis Wright Tremaine LLP Attorney tomscanlon@dwt.com

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 23 of 49
Tim Cunningham Davis Wright Tremaine LLP Attorney TimCunningham@dwt.com

Tom Wyrwich Davis Wright Tremaine LLP Attorney tomwyrwich@dwt.com

Zana Bugaighis Davis Wright Tremaine LLP Attorney zanabugaighis@dwt.com 

Larry L. Debus Debus, Kazan & Westerhausen, Ltd. Attorney lld@dkwlawyers.com

Lawrence I. "Larry" Kazan Debus, Kazan & Westerhausen, Ltd. Attorney lik@dkwlawyers.com

Avi Schick Dentons US LLP (fka SNR Dentons fka Sonnenschein Nath & Rosenthal) Attorney avi.schick@dentons.com

Jeff Modisett Dentons US LLP (fka SNR Dentons fka Sonnenschein Nath & Rosenthal) Attorney jeff.modisett@dentons.com

Kenneth G. Kolmin Dentons US LLP (fka SNR Dentons fka Sonnenschein Nath & Rosenthal) Attorney kenneth.kolmin@dentons.com

Rebecca Stroder Dentons US LLP (fka SNR Dentons fka Sonnenschein Nath & Rosenthal) Attorney rebecca.stroder@snrdenton.com

Rodney J. Boyd Dentons US LLP (fka SNR Dentons fka Sonnenschein Nath & Rosenthal) Attorney rodney.boyd@dentons.com 

Samuel Fifer Dentons US LLP (fka SNR Dentons fka Sonnenschein Nath & Rosenthal) Attorney samuel.fifer@dentons.com

Don Bennett Moon Don Bennett Moon, PC Attorney donbennettmoon@gmail.com

Bruce Feder Feder Law Office, P.A. Attorney bf@federlawpa.com

Jason H. Fisher Fisher Law Group Attorney jfisher@fisherlg.com

Hannah H. Porter Gallagher & Kennedy Attorney hannah.porter@gknet.com

Janey Henze Cook Gallagher & Kennedy Attorney janey.henze@gknet.com

Kiersten A. Murphy Gallagher & Kennedy Attorney KAM@gknet.com

Quintin H. Cushner Gallagher & Kennedy Attorney quintin.cushner@gknet.com

Rhonda L. Russo Gallagher & Kennedy Legal Assistant rlr@gknet.com

Sheila M. Rath Gallagher & Kennedy Legal Assistant smr@gknet.com

Tom E. Henze Gallagher & Kennedy Attorney teh@gknet.com

Lori S. Smith Goodwin Procter, LLP Attorney @goodwinlaw.com

Francoise Gilbert Greenberg Traurig LLP Attorney gilbertf@gtlaw.com

Timonthy Alger Greenberg Traurig LLP Attorney algert@gtlaw.com

Janey Henze Cook Henze Cook Murphy PLLC Attorney Janey@henzecookmurphy.com

Kiersten Murphy Henze Cook Murphy PLLC Attorney kiersten@henzecookmurphy.com

Tom E. Henze Henze Cook Murphy PLLC Attorney tom@henzecookmurphy.com

Stephen M. Weiss Karp & Weiss Attorney sweiss@karpweiss.com

Vicki Vitolo Karp & Weiss Legal Assistant vvitolo@karpweiss.com

Edward E. McNally Kasowitz, Benson Torres LLP Attorney emcnally@kasowitz.com 

Gunnar Martz Kasowitz, Benson Torres LLP Legal Assistant gmartz@kasowitz.com

Lyn R. Agre Kasowitz, Benson Torres LLP Attorney LAgre@kasowitz.com

Maria Gorecki Kasowitz, Benson Torres LLP Attorney mgorecki@kasowitz.com

Mark E. Kasowitz Kasowitz, Benson Torres LLP Attorney mkasowitz@kasowitz.com

Shalini K. Rajoo Kasowitz, Benson Torres LLP Attorney srajoo@kasowitz.com

Tamara Bruno Kasowitz, Benson Torres LLP Attorney tbruno@kasowitz.com 

Kenneth M. Miller Ken Miller Law Attorney Ken@KMMillerLaw.Com 

James M. Wagstaffe Kerr & Wagstaffe LLP Attorney wagstaffe@kerrwagstaffe.com

Melissa Wallingsford Kimerer & Derrick PC Attorney mwallingsford@kimerer.com

Michael D. Kimerer Kimerer & Derrick PC Attorney mdk@kimerer.com

Rhonda E. Neff Kimerer & Derrick PC Attorney rneff@kimerer.com

Susan Lu Lyon-Hintze Law Office of Susan Lyon Hintze Attorney susan@hintzelaw.com

Erin McCampbell Paris Lipsitz Green Scime Cambria LLP Attorney emccampbell@lglaw.com

Paul Cambria Lipsitz Green Scime Cambria LLP Attorney pcambria@lglaw.com

David Wakukawa Maxwell Law Attorney dsw@kcmaxlaw.com

K.C. Maxwell Maxwell Law Attorney kcm@kcmaxlaw.com

Bruce S. Rosen McCusker, Anselmi, Rosen & Carvelli, P.C. Attorney brosen@marc.law 

Sam Neel McDermott Will & Emery Attorney sneel@mwe.com 

Stephen Ryan McDermott Will & Emery Attorney sryan@mwe.com

Andrew D. Herman Miller & Chevalier Attorney aherman@milchev.com

James A. Bensfield Miller & Chevalier Attorney jbensfield@milchev.com

Anne M. Chapman Mitchell Stein Carey Chapman, PC Attorney anne@mscclaw.com

Julie Greenwood Mitchell Stein Carey Chapman, PC Legal Assistant julie@mscclaw.com

Lee D. Stein Mitchell Stein Carey Chapman, PC Attorney lee@mscclaw.com

Michael Morrissey Mitchell Stein Carey Chapman, PC Attorney michael@mscclaw.com

David J. Leviss O'Melveny & Myers LLP Attorney dleviss@omm.com

Dawn Dybdahl Osborn Maledon, P.A. Legal Assistant ddybdahl@omlaw.com

Joseph Roth Osborn Maledon, P.A. Attorney jroth@omlaw.com

Larry A. Hammond Osborn Maledon, P.A. Attorney lhammond@omlaw.com

Timothy J. Eckstein Osborn Maledon, P.A. Attorney teckstein@omlaw.com

Arielle S. Lapiano Paul Hastings LLP Attorney ariellelapiano@paulhastings.com

Chris A. Wenger Paul Hastings LLP Attorney chriswenger@paulhastings.com

Christopher F. Allen Paul Hastings LLP Attorney christopherallen@paulhastings.com

Daren F. Stanaway Paul Hastings LLP Attorney darenstanaway@paulhastings.com

Elizabeth Dorsi Paul Hastings LLP Attorney elizabethdorsi@paulhastings.com

Gerald S. Sachs Paul Hastings LLP Attorney geraldsachs@paulhastings.com

Jamie S. Gardner Paul Hastings LLP Attorney jamiegardner@paulhastings.com

Lindsey B. Meyers Paul Hastings LLP Attorney lindseymeyers@paulhastings.com

Robert D. Luskin Paul Hastings LLP Attorney robertluskin@paulhastings.com

Stephen B. Kinnaird Paul Hastings LLP Attorney stephenkinnaird@paulhastings.com

Thomas P. Brown Paul Hastings LLP Attorney tombrown@paulhastings.com 

Albert "Al" Gidari, Jr. Perkins Coie LLP Attorney agidari@perkinscoie.com

Alisha C. Burgin Perkins Coie LLP Attorney aburgin@perkinscoie.com

Ann Marie Painter Perkins Coie LLP Attorney ampainter@perkinscoie.com

Breena M. Roos Perkins Coie LLP Attorney broos@perkinscoie.com

Brian Lake Perkins Coie LLP Attorney blake@perkinscoie.com

Brian Larson Perkins Coie LLP Attorney blarson@perkinscoie.com

Clair Wendt Perkins Coie LLP Legal Assistant cwendt@perkinscoie.com

Erin Weinkauf Perkins Coie LLP Legal Assistant eweinkauf@perkinscoie.com

Harry H. Schneider Perkins Coie LLP Attorney hschneider@perkinscoie.com

J. Camille Fisher Perkins Coie LLP Attorney CFisher@perkinscoie.com

Jamie L. Sheppard Perkins Coie LLP Legal Assistant JamieSheppard@perkinscoie.com

Jason R. Elliott Perkins Coie LLP Attorney jelliott@perkinscoie.com

Jay Rossiter Perkins Coie LLP Attorney jrossiter@perkinscoie.com

Jean-Jacques "J" Cabou Perkins Coie LLP Attorney JCabou@perkinscoie.com

Joel W. Nomkin Perkins Coie LLP Attorney JNomkin@perkinscoie.com

Karin S. Aldama Perkins Coie LLP Attorney kaldama@perkinscoie.com

Katherine Luck Perkins Coie LLP Legal Assistant kluck@perkinscoie.com

Kendra L. Harr Perkins Coie LLP Attorney khaar@perkinscoie.com

Kenneth R. Rastello Perkins Coie LLP Staff krastello@perkinscoie.com

Kristine Beaudoin Perkins Coie LLP Attorney kbeaudoin@perkinscoie.com

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 24 of 49
Lauren M. Kulpa Perkins Coie LLP Attorney lkulpa@perkinscoie.com

Matthew Gehringer Perkins Coie LLP Attorney MGehringer@perkinscoie.com

Mimi Ho Perkins Coie LLP Staff mimiho@perkinscoie.com

Paul F. Eckstein Perkins Coie LLP Attorney peckstein@perkinscoie.com

Ralph A. "Tony" Caliendo Perkins Coie LLP Attorney tcaliendo@perkinscoie.com

Roxann Ditlevson Perkins Coie LLP Legal Assistant RDitlevson@perkinscoie.com

Scott Minder Perkins Coie LLP Attorney sminder@perkinscoie.com

Sherrye S. Andrews Perkins Coie LLP Legal Assistant SAndrews@perkinscoie.com

Simon Conant Perkins Coie LLP Staff

Stephen Folkins Perkins Coie LLP Staff sfolkins@perkinscoie.com

Steven D. Merriman Perkins Coie LLP Attorney smerriman@perkinscoie.com

Sunita Bali Perkins Coie LLP Attorney SBali@perkinscoie.com

Timothy L. Alger Perkins Coie LLP Attorney talger@perkinscoie.com

Trisha Marino Perkins Coie LLP Legal Assistant tmarino@perkinscoie.com

Barbara Polowetz Piccarreta Davis Keenan Fidel PC Legal Assistant bpolowetz@pd-law.com

Jefferson Keenan Piccarreta Davis Keenan Fidel PC Attorney jkeenan@pd-law.com

Melissa Hahn Piccarreta Davis Keenan Fidel PC Legal Assistant mhahn@pd-law.com

Michael L. Piccarreta Piccarreta Davis Keenan Fidel PC Attorney mlp@pd-law.com

Antoinette Dellacroce Poltrock & Giampietro/Wayne B. Giampietro LLC Legal Assistant adellacroce@giampietrolaw.com

Wayne B Giampietro Poltrock & Giampietro/Wayne B. Giampietro LLC Attorney wgiampietro@giampietrolaw.com

Dunning, Dwight Prince Lobel Tye LLP Attorney ddunning@princelobel.com

James W. Lawson Prince Lobel Tye LLP Attorney jlawson@princelobel.com

Jeffrey J. Pyle Prince Lobel Tye LLP Attorney JPyle@princelobel.com

Michelle Sawyer Prince Lobel Tye LLP Staff msawyer@princelobel.com

Robert A. Bertsche Prince Lobel Tye LLP Attorney RBertsche@princelobel.com

Andrea S. Tazioli Quarles & Brady LLP Attorney andrea.tazioli@quarles.com

Carol Fitch Quarles & Brady LLP Legal Assistant carol.fitch@quarles.com

Marla J. Weems Quarles & Brady LLP Staff Marla.Weems@quarles.com

Robert S. Bornhoft Quarles & Brady LLP Attorney bob.bornhoft@quarles.com

Susan G. Boswell Quarles & Brady LLP Attorney Susan.Boswell@quarles.com

Aneta Wrzeszcx Rusing Lopez & Lizardi, PLLC Legal Assistant AWrzeszcz@rllaz.com

Caroline Caputo Rusing Lopez & Lizardi, PLLC Staff ccaputo@rllaz.com

Christopher "Chris" Ambrosio Rusing Lopez & Lizardi, PLLC Attorney cambrosio@rllaz.com

Daniel J. Quigley Rusing Lopez & Lizardi, PLLC Attorney quigley@rllaz.com

Diane Sitzman Rusing Lopez & Lizardi, PLLC Staff dsitzman@rllaz.com

Ed Moomjian Rusing Lopez & Lizardi, PLLC Attorney edm@rllaz.com

Ettore Stella Rusing Lopez & Lizardi, PLLC Attorney estella@rllaz.com

Isaac S. Crum Rusing Lopez & Lizardi, PLLC Attorney ICrum@rllaz.com

J. William "Bill" Brammer, Jr. Rusing Lopez & Lizardi, PLLC Attorney wbrammer@rllaz.com

Jacqueline A. "Jackie" Franks Rusing Lopez & Lizardi, PLLC Legal Assistant jfranks@rllaz.com

Jason Linamon Rusing Lopez & Lizardi, PLLC Legal Assistant jlinaman@rllaz.com

Jon Saffer Rusing Lopez & Lizardi, PLLC Attorney jsaffer@rllaz.com

Michael J. "Mick" Rusing Rusing Lopez & Lizardi, PLLC Attorney mrusing@rllaz.com

Oscar S. Lizardi Rusing Lopez & Lizardi, PLLC Attorney olizardi@rllaz.com

P. Andrew Sterling Rusing Lopez & Lizardi, PLLC Attorney asterling@rllaz.com

Patricio P. "Pat" Lopez Rusing Lopez & Lizardi, PLLC Attorney plopez@rllaz.com

Paul L. Grijalva Rusing Lopez & Lizardi, PLLC Attorney PGrijalva@rllaz.com

Robert J. Lloyd Rusing Lopez & Lizardi, PLLC Attorney Rlloyd@rllaz.com

Sarah S. Letzkus Rusing Lopez & Lizardi, PLLC Attorney SLetzkus@rllaz.com

Timothy J. Reckart Rusing Lopez & Lizardi, PLLC Attorney treckart@rllaz.com

Charles H.R. (Chip) Peters Schiff Hardin LLP Attorney cpeters@schiffhardin.com

Sebastien Angel Schiff Hardin LLP Attorney sangel@schiffhardin.com

Seetha Ramachandran Schulte Roth & Zabel LLP Attorney seetha.ramachandran@srz.com

Kathleen M. Miller Smith Katzenstein & Jenkins, LLP Attorney kmm@skjlaw.com

Patrick T. Carr Smith Katzenstein & Jenkins, LLP Legal Assistant ptc@skjlaw.com

Robert K. Beste Smith Katzenstein & Jenkins, LLP Attorney rkb@skjlaw.com

Steven P. Suskin Suskin Law Attorney sps@backpage.com

Anthony F. Blum Thompson Coburn LLP Attorney ablum@thompsoncoburn.com 

Jan Paul Miller Thompson Coburn LLP Attorney jmiller@thompsoncoburn.com

Mark A. Mattingly Thompson Coburn LLP Attorney mmattingly@thompsoncoburn.com

Mark Sableman Thompson Coburn LLP Attorney msableman@thompsoncoburn.com 

Michael L. Nepple Thompson Coburn LLP Attorney mnepple@thompsoncoburn.com 

Elizabeth L. (Liz) McDougall Village Voice Media Holdings, LLC Attorney liz.mcdougall@villagevoicemedia.com

Amber Torina Walters Law Group Legal Assistant amber@firstamendment.com

Lawrence (Larry) Walters Walters Law Group Attorney larry@firstamendment.com

Lisa Brown Walters Law Group Legal Assistant lisa@firstamendment.com

Alexandria E. Kane White and Williams LLP Attorney Kanea@whiteandwilliams.com

Lori S. Smith White and Williams LLP Attorney smithl@whiteandwilliams.com

Joseph Steinfield

The following lawyers represented Carl Ferrer, Backpage.com, LLC, or its affiliates, but some communications will be privileged under a joint defense privilege or common interest privilege:

Adam Atlas Adam Atlas Attorney at Law Attorney atlas@adamatlas.com

Larry L. Shosid Bell Nunnally, LLP/Bell Nunnally & Martin, LLP Attorney lshosid@bellnunnally.com

David Wakukawa Browne George Ross LLP Attorney dwakukawa@bgrfirm.com

K.C. Maxwell Browne George Ross LLP Attorney kmaxwell@bgrfirm.com

Jonathan Baum Clarence Dyer Attorney jbaum@clarencedyer.com

Nanci Clarence Clarence Dyer Attorney nclarence@clarencedyer.com

Shaneeda Jaffer Clarence Dyer Attorney sjaffer@clarencedyer.com

Brad L. Whitlock Scheef & Stone, L.L.P. Attorney brad.whitlock@solidcounsel.com

E.G. ("Gerry") Morris The Law Office of E.G. Morris Attorney egm@egmlaw.com

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 25 of 49
Email Address Email Address Email Address Email Address

ken@kmmillerlaw.com

liz@backpage.com lmcdougall@postonlinewith.me lizmcd4@gmail.com

angeloc@calfoeakes.com

slyonhintze@cooley.com

dquigley@djqplc.com quigley@quigley.us quigley@tanqueverde.com

cmtewell@gmail.com 

fka Candice Tewell

jimgrant@dwt.com

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 26 of 49
jeff.modisett@snrdenton.com jeff.modisett@nextlawnetwork.com 

kenneth.kolmin@snrdenton.com

rodney.boyd@snrdenton.com rboyd@sonnenschein.com

samuel.fifer@snrdenton.com samuel.fifer@sonnenschein.com sfifer@sonnenschein.com

Don.Moon@azbar.org don@donbennettmoon.com donbmoon@yahoo.com

eparis@lglaw.com

marc-law.com

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 27 of 49
simon_conant@hotmail.com

dquigley@rllaz.com quigley@protonmail.com

steve.suskin@villagevoicemedia.com steve.suskin@newtimes.com steve@suskinlaw.com steve.suskin@voicemediagroup.com

lmcdougall@backpage.com liz@backpage.com lizmcd4@gmail.com

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 28 of 49
EXHIBIT G 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 29 of 49
U.S. Department of Justice 

United States Attorney 

District of Arizona 

Two Renaissance Square Main: (602) 514-7500 

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

Phoenix, AZ 85004-4408 

April 11, 2019 

Paul J. Cambria Jr. 

Attorney at Law 

Lipsitz Green Scime Cambria, 

LLC 

42 Delaware Ave, Suite 120 

Buffalo, NY 14202 

(attorney for Michael Lacey) 

Thomas H. Bienert, Jr., Esq. 

Bienert, Miller & Katzman, 

PLC 

903 Calle Amanecer, Suite 350 

San Clemente, CA 92673 

(attorney for James Larkin) 

Mike Piccarreta, Esq. 

Piccarreta Davis Keenan Fidel, 

PC 

2 East Congress Street, 

Suite 1000 

Tucson, AZ 85701 

(attorney for Andrew Padilla) 

Jim Grant 

Davis Wright Tremaine, LLP 

920 Fifth Avenue, 

Suite 3300 

Seattle, WA 98104 

(attorney for Lacey and Larkin) 

Michael D. Kimerer, Esq. 

1313 E. Osborn Road, 

Suite 100 

Phoenix, AZ 85014 

(attorney for Jed Brunst) 

Steve Weiss 

Attorney at Law 

Karp & Weiss, PC 

3060 North Swan Rd. 

Tucson, AZ 85712 

(attorney for Joye Vaught) 

Robert Corn-Revere 

Davis Wright Tremaine, LLP 

1919 Pennsylvania Avenue N.W., 

Suite 800 

Washington, DC 20006 

(attorney for Lacey and Larkin) 

Bruce Feder, Esq. 

2930 East Camelback Road, 

Suite 160 

Phoenix, AZ 85016 

(attorney for Scott Spear) 

Gary Lincenberg 

Bird, Marella, Boxer, Wolpert, 

Nessim, Drooks, Lincenberg & Rhow, 

P.C. 

1875 Century Park East 

23rd Floor 

Los Angeles, CA 90067 

(attorney for Jed Brunst) 

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

CR-18-00422-PHX-SMB 

Dear Counsel: 

Pursuant to your request for discovery and the government's obligations under Fed. R. Crim. 

P. 16 and the stipulated scheduling order in this case, please find enclosed a thumb drive containing 

the government's ninth disclosure.1 

1 A thumb drive containing disclosure for Defendants Michael Lacey, James Larkin, and Jed Brunst 

are being provided to Paul J. Cambria Jr., Thomas H. Bienert Jr., and Gary Lincenberg respectively. 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 30 of 49
Lacey, et. al. Discovery Letter 

April 11, 2019 

Page 2 

• The thumb drive contains the following Bates Stamped records: 

o Additional BDO Consulting Docs — D0J-BP-0004791241-D0J-BP-0004809000 

o EPIQ data — D0J-BP-0004809001-D0J-BP-0004854243 

o Sampling of Backpage Ads with Associated Databases and Images2— DOJ-BP0004854244-D0J-BP-0004857289 

Please reach out with any questions. 

Sincerely, 

BRIAN BENCZKOWSKI 

Assistant Attorney General 

Criminal Division 

U.S. Department of Justice 

Reginald E. Jones 

REGINALD E. JONES 

Senior Trial Attorney, CEOS 

(202) 616-2807 

reginald.jones4@usdoj.gov 

ELIZABETH A. STRANGE 

First Assistant U.S. Attorney 

KEVIN M. RAPP 

MARGARET PERLMETER 

PETER S. KOZINETS 

ANDREW STONE 

JOHN J. KUCERA 

Assistant United States Attorneys 

Enclosures 

2This data was previously provided to counsel for Defendant Larkin as per their request on March 

14, 2019; however, we wanted to provide counsel with Bates Stamped copies of these records. 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 31 of 49
EXHIBIT H 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 32 of 49
U.S. Department of Justice 

United States Attorney 

District of Arizona 

Two Renaissance Square Main: (602) 514-7500 

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

Phoenix, AZ 85004-4408 

March 7, 2019 

Via E-Mail 

Whitney Z. Bernstein 

Bienart, Miller & Katzman PLC 

EMail:wbernstein@bmkattorneys.com 

(attorney for Defendant James Larkin) 

Re: Your letter of February 26, 2019 

Dear Ms. Bernstein: 

We write in response to your February 26, 2019 letter summarizing our February 

20, 2019 phone call regarding Backpage server data. Your letter contains a number of 

inaccuracies. However, instead of addressing each inaccuracy contained within the letter, 

we believe it would be most fruitful to provide you with the below written summary of the 

government's handling of the Backpage server data to date. 

Total Servers 

The government has 46 Backpage servers in its possession obtained from 

Amsterdam, Netherlands ("Amsterdam"), Tucson, Arizona ("Tucson"), and Dallas, Texas 

("Dallas"). We are currently awaiting receipt of approximately 60 additional servers from 

Amsterdam through the Mutual Legal Assistance Treaty ("MLAT") process. 

Amsterdam Servers 

We currently have in our possession nine servers obtained from Amsterdam through 

the MLAT process. Of these nine servers, three are slave database servers, three are image 

servers, two are master database servers, and one is a backup server. Backpage operated 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 33 of 49
March 7, 2019 

Page 2 

as a classified advertising website for approximately 14 years so we're certain you are 

aware of the content hosted on the site. However, we extracted all of the Backpage 

marketplace database files (i.e. all of the ads that were on Backpage.com) from these 

servers and have imaged the server containing all of the Backpage images in order to help 

facilitate any review you would like to conduct of this data. As I indicated in my March 4, 

2019 email to you, the hard drives containing this data are available for pick-up at an FBI 

facility in Phoenix. Additionally, in accordance with Federal Rule of Criminal Procedure 

16(a)(1)(E), these nine servers are available for your inspection at an FBI data center 

facility in Pocatello, Idaho. Our forensic examiners located at this facility are available to 

facilitate your review of these servers and answer any technical questions you may have 

regarding this particular data. 

In addition to the aforementioned nine servers currently in the government's 

possession, we are awaiting receipt of approximately 60 servers from Dutch officials 

through the MLAT process. We have been advised by a foimer Backpage employee who 

managed these servers that these 60 servers contain payment processing data and data 

redundancy from the nine Amsterdam servers currently in the government's possession. 

These servers will also be available for your inspection at an FBI data center facility in 

Pocatello, Idaho when we receive them. 

Dallas Servers 

We currently have in our possession five Backpage servers seized from Dallas. Of 

these five servers, we were advised by a former Backpage employee who managed these 

servers that two of these servers contain Backpage-related email data. These two servers 

have been imaged and the hard drives containing this data are available for pick-up at an 

FBI facility in Phoenix. The former Backpage employee who managed these servers also 

advised us that the remaining three Dallas servers in our possession contain antivirus 

servers, asset tracking/inventory software, a backup server, web user interface, virtual 

private network for end point, VM servers, and WSUS. In accordance with Federal Rule 

of Criminal Procedure 16(a)(1)(E), these three servers are available for your inspection at 

an FBI data center facility in Pocatello, Idaho. Our forensic examiners located at this 

facility are available to facilitate your review of these servers and answer any technical 

questions you may have regarding this particular data. 

Tucson Servers 

We currently have in our possession 32 servers and three hard drives seized from 

Tucson. We were advised by a former Backpage employee who managed these servers 

that they contain data redundancy of the marketplace database files and images from the 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 34 of 49
March 7, 2019 

Page 3 

Amsterdam servers. We have imaged the master marketplace database and image servers. 

The hard drives containing this data are available for pick-up at an FBI facility in Phoenix. 

In accordance with Federal Rule of Criminal Procedure 16(a)(1)(E), these 32 servers are 

available for your inspection at an FBI data center facility in Pocatello, Idaho. Our forensic 

examiners located at this facility are available to facilitate your review of these servers and 

answer any technical questions you may have regarding this particular data. 

Sampling of Ad data and Ad data the Government Might Utilize at Trial 

During our February 20, 2019 phone conversation (and again in your February 26, 

2019 letter), you requested samples of "[Backpage] advertisements as such ads now appear 

in the data the government has imaged." You also requested "discrete parts of all 

advertisements that are the subject of counts in the Superseding Indictment." To be clear, 

the government has previously produced to you in discovery ads that are referenced in 

counts in the Superseding Indictment. However, we are willing to produce samples of 

Backpage ads as the ads appear in the server data the government has imaged, to include 

ads referenced in counts in the Superseding Indictment. Although we had hoped to have 

this sampling to you this week, our forensic examiner culling this data was unexpectedly 

away from the office for a number of days, so we will need additional time to compile the 

requested sampling. We will send this sampling to you as soon as possible. Also, as 

previously noted, the entire marketplace of Backpage ads have been extracted for you and 

is available for pick-up at your convenience. 

Additionally, given the voluminous amount of server data, the government agrees 

to provide to you with exhibits of any server data that we might utilize at trial. This should 

greatly assist you in focusing your efforts and attention on server data relevant to the case. 

Please reach out to me with additional questions. We will continue to work 

diligently to answer them and facilitate your review of materials in this case. 

BRIAN BENCZKOWSKI 

Assistant Attorney General 

Criminal Division 

U.S. Depaitment of Justice 

s/Reginald E. Jones 

REGINALD E. JONES 

Senior Trial Attorney, CEOS 

(202) 616-2807 

reginald.jones4gusdoj.gov 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 35 of 49
March 7, 2019 

Page 4 

ELIZABETH A. STRANGE 

First Assistant U.S. Attorney 

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-DJH Document 524-1 Filed 04/16/19 Page 36 of 49
EXHIBIT I 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 37 of 49
Biener Katzman PLC 

February 28, 2019 

Via E-Mail 

Kevin Rapp 

Assistant U.S. Attorney 

E-Mail: kevin.rapp@usdoj.gov 

Re: United States v. Lacey, et al., 18-CR-0422-PHX-SPL 

Backpage.comDiscovery Production Issues 

Mr. Rapp: 

We have encountered some issues with the government's discovery productions. Many of the 

files were not made in a format that cannot be loaded into a database such as Relativity. We hope to 

quickly remedy these issues. 

To date, the government has made eight discovery productions: (1) May 24, 2018; (2) July 2, 

2018; (3) July 19, 2018; (4) September 24, 2018; (5) October 4, 2018; (6) October 10, 2018; (7) 

November 30, 2018; and (8) February 22, 2019. Additional discovery productions of Jencks material 

and the approximately 500 terabytes of Backpage.comserver data is anticipated as well. 

We have not yet reviewed the most recent production. Nonetheless, we are missing images 

for 2,744 files produced from the first seven productions. See attached list of files by Bates stamp that 

are missing images and/or natives. Please reproduce these 2,744 files in load ready format with natives 

and images as soon as possible. 

Thank you in advance for your timely attention to this matter. Please let us know the date by 

which you intend to reproduce these discovery productions without error. Please also feel free to 

reach me at (949) 369-3700. 

Very truly yours, 

10if1 /4 -1 

Whitney Z. Bernstein 

Bienert j Katzman PLC 

cc: Thomas H. Bienert, Jr. 

Paul Cambria, Jr. 

Gary Lincenberg 

Bruce Feder 

Michael Piccarreta 

Stephen Weiss 

903 Calle Amanecer, Suite 350 • San Clemente, CA 92673 

Tel. (949) 369-3700 • Fax (949) 369-3701 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 38 of 49
EXH BIT J 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 39 of 49
U.S. Department of Justice 

United States Attorney 

District of Arizona 

Two Renaissance Square Main: (602) 514-7500 

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

Phoenix, AZ 85004-4408 

March 6, 2019 

Via E-Mail 

Whitney Z. Bernstein 

Bienart, Miller & Katzman PLC 

EMail:wbernstein@bmkattorneys.com 

(attorney for Defendant James Larkin) 

Re: Your letter of February 28, 2019 

Dear Ms. Bernstein: 

We write in response to your February 28, 2019 letter. Your letter begins by 

asserting that defense has encountered issues with some of the government's discovery 

production. Specifically, you state that "many of the [discovery] files were not made in a 

format that cannot be loaded into a database such as Relativity." You then provide 

beginning Bates numbers for 2,744 documents you contend "are missing images and/or 

natives." To start, the government has produced more than 7.8 million documents to you 

in discovery over the past nine months. Of these more than 7.8 million documents, the 

documents you identify in your letter as being produced with missing images and/or natives 

(2,740 PSI documents and 4 CA DOJ documents)-2,744 documents disclosed to you 

more than nine months ago—were produced to you in the same manner they were produced 

to us. Some of the 2,744 documents were produced to the government in native format 

only, image format only, or text format only. Others were produced to us in native, image, 

and text format. Nevertheless, all 2,744 files can be loaded into and viewed in a database 

such as Relativity—the commonly-used discovery platform both parties agreed at the 

outset of the case would be used to produce discovery. Additionally, upon receiving your 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 40 of 49
March 6, 2019 

Page 2 

February 28th letter, the government located and viewed a sampling of the 2,744 

documents in native, image and/or text format in our Relativity database without issue. 

Please reach out with any additional questions. 

BRIAN BENCZKOWSKI 

Assistant Attorney General 

Criminal Division 

U.S. Department of Justice 

s/Reginald E. Jones 

REGINALD E. JONES 

Senior Trial Attorney, CEOS 

(202) 616-2807 

reginald.jones4@usdoj.gov 

ELIZABETH A. STRANGE 

First Assistant U.S. Attorney 

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-DJH Document 524-1 Filed 04/16/19 Page 41 of 49
EXHIBIT K 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 42 of 49
U.S. Department of Justice 

United States Attorney 

District of Arizona 

Two Renaissance Square Main: (602) 514-7500 

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

Phoenix, AZ 85004-4408 

March 14, 2019 

Via FedEx 

Whitney Z. Bernstein 

Bienart, Miller & Katzman PLC 

903 Calle Amanecer, Suite 350 

San Clemente, CA 92673 

(attorney for James Larkin) 

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

CR-18-00422-PHX-SMB 

Dear Ms. Bernstein: 

As per your request, please find enclosed a DVD that contains a sampling of 

approximately 70 Backpage ads with associated databases and images (as such ads appear 

in the server data the government has imaged and made available to you), to include ads 

referenced in the Superseding Indictment. 

Please reach out with any questions. 

BRIAN l3ENCZKOWSKI 

Assistant Attorney General 

Criminal Division 

U.S. Department of Justice 

s/Reginald E. Jones 

REGINALD E. JONES 

Senior Trial Attorney, CEOS 

(202) 616-2807 

reginald.jones4@usdoj.gov 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 43 of 49
EXHIBIT L 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 44 of 49
Bienert Katzman PLC 

March 4, 2019 

Via Overnight Mail and Electronic Link 

Kevin M. Rapp 

Assistant United States Attorney 

United States Attorney's Office 

District of Arizona 

2 Renaissance Square 

40 N. Central Avenue, Suite 1800 

Phoenix, AZ 85004 

E-Mail: kevin.rapp@usdoj.gov 

Re: United States v. Lacey, et al, 18-CR-0422-PHX-DLR 

Defendants' Joint Reciprocal Rule 16 Production 

Dear Mr. Rapp: 

Defendants' Rule 16 obligations are reciprocal in nature and are therefore limited by 

the government's failure to comply with its own Rule 16 obligations in a timely fashion. 

Because the government has not completed its Rule 16 disclosures in this case, Defendants 

are not obligated to make reciprocal disclosures at this time. See Fed. R. Crim. Proc. 

16(b)(1)(A) (a defendant's Rule 16 obligations are triggered only if "the government 

complies" with its own Rule 16 obligations). 

Substantial discovery—tens of billions of pages—are stilloutstanding. On December 

10, 2018, you wrote that the government "seized 32 servers and three hard drives located in 

Tucson at an Internet service provider known as Desert Net. . . In the last subpoena we 

wrote, we estimated the capacity at approximately 500 [terabytes] or 1/2 petabyte (PB)" of 

data from the Backpage.comservers. See Rapp Dec. 10, 2018 Letter at page 1. You then 

listed that, in addition to the Desert Net servers of approximately 500 terabytes of data, the 

government also seized "fflive additional servers from Dallas, TX" and "Nnvestigating 

agents also located 40 servers at a datacenter in Amsterdam, the Netherlands." Id. at page 2. 

Defendants have not received any of this discovery to date. This will be the subject of a 

forthcoming motion, but it also limits Defendants' ability to meaningfully analyze the case 

and make Rule 16 disclosures. 

There are numerous additional examples of the government's failures, not all of 

which are identified here. 

903 Calle Amanecer, Suite 350 • San Clemente, CA 92673 

Tel. (949) 369-3700 • Fax (949) 369-3701 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 45 of 49
March 4, 2019 

U.S. v. Lacy, et al., 18-CR-0422-PHX-DLR 

Page 2 

First, the government has not complied with the Court's Scheduling Order, which 

required the government's initial compliance with Rule 16 discovery by December 3, 2018. 

See 18-CR-0422-PHX-SPL at Doc. 131. On February 22, 2019, the government produced 

voluminous Rule 16 discovery. Defendants received this discovery production on February 

25, 2019 and have not yet had an opportunity to review it. However, the government's 

cover letter makes clear that this production includes 11,346 pages of BDO Consulting 

Documents, Reports of Interviews, and other FBI Case Documents. In addition to these 

11,346 pages of Rule 16 discovery, the government also produced, for the very first time, six 

DVDs containing reports of interviews of cooperating Defendant Daniel Hyer, jail calls 

from April 2018 for Defendants Michael Lacey and James Larkin, and documents pertaining 

to Victim 15. No explanation was provided for the production of this Rule 16 discovery 

nearly three months after the deadline provide for in the Court's Scheduling Order. Further, 

additional Rule 16 discovery (such as items taken from Defendants at the time of their arrest 

nearly one year ago, including their cell phones, computers, and other documents and items 

taken from Backpage.comin addition to the servers such as personal computers and other 

documents) have yet to be produced. 

Second, the government has apparently moved in camera to defer the disclosure of 

Carl Ferrer's Jencks Act statements. Mr. Ferrer is the government's key cooperator whose 

testimony will be central to the government's case at trial. Given that it is public knowledge 

that Mr. Ferrer has entered into a "cooperation" deal with the government, it is unclear what 

justification the government could possibly have for seeking to defer disclosure of Ferrer's 

statements. Without such statements, Defendants cannot meaningfully analyze the 

government's case, and certainly cannot analyze what evidence the defense may present to 

rebut his anticipated testimony. Given that the government did not disclose the existence of 

the motion to defer disclosure of the Ferrer statements to the defense, Defendants do not 

know what other evidence the government is withholding at this time. Further, the 

government seized Ferrer's mails and has yet to produce these as well. 

Third, Reggie Jones explained during a telephone call on February 20, 2019, that the 

government has retrieved only- nine of the 40 Backpage.comservers it seized in Amsterdam 

through the MLAT process. Of those nine servers, it has imaged only five. Mr. Jones 

represented that the servers which have yet to be produced to the defense contain at least 

500 terabytes of data, the equivalent of —37.5 billion pages. When that material is finally 

produced, it will substantially dwarf the government's document productions in this matter 

to date. 

Nor has the government identified a timeline for when it anticipates retrieving the 

remaining 31 servers located in Amsterdam. Defendants do not have access to this data 

given that the government has seized the servers through the MLAT process but has not 

produced it to the defense. The size of those remaining servers is believed to be enormous, 

and they are believed to contain important evidence relevant to the defense of this matter. 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 46 of 49
3 

March 4, 2019 

U.S. v. Lacey, et al., 18-CR-0422-PHX-DLR 

Page 3 

Fourth, as to the five servers that the government imaged, Mr. Jones told us they 

consist of the marketplace of advertisements posted on Backpage.com, the very backbone of 

the government's allegations in the indictment. Your December 10, 2018 letter represented 

that "Nhese 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." 

However, Mr. Jones and others working for the government recently told us that the 

government does not have the resources to recreate the relational database and that the 

forthcoming discovery will be in disparate, uncorrelated files of hundreds of millions of 

individual advertisements disconnected from the data under/ying those advertisements. Thus, due to 

the government's actions, we cannot yet tell, from the information the government has 

provided, whether it will be possible to determine when a given advertisement was posted, 

who posted it, how it was paid for, whether any information was added to or deleted from it, 

whether it was reported to authorities or NCMEC, etc. and, as a result, the information 

contained on these servers may now be functionally useless 

In a case where the government alleges that Defendants intended to facilitate 

prostitution through the publishing of specific advertisements, it is unfathomable that the 

government would deconstruct the servers containing these very advertisements in such a 

way that effectively transformed the underlying data into hundreds of millions of puzzle 

pieces that no party — not even the government — is capable of putting back together. 

Fifth, the government has not provided discovery related to money laundering 

charges, including a failure to produce the servers that contain payment processing data for 

Backpage.com. This material is critical to Defendants' assessment of the government's 

money laundering allegations. To make matters worse, Mr. Jones explained that the 

government does not know where the servers that contain this material are located and thus has no idea 

when or if it will ever be produced to the defense. 

Given that the government is nowhere close to producing all of the material that it 

represented to the Court and Defendants it would produce, and only recently began 

producing Jencks Act material, Defendants are hobbled in their ability to make meaningful 

Rule 16 disclosures at this time. 

Despite the fact that disclosure by the defense is not required given the government's 

failure to complete its own disclosures, and despite the government's egregious failure to 

produce the most basic evidence in this case, Defendants hereby advise you that they 

potentially might use the following material at trial: 

• Material produced by the government in discovery 

• Defense Bates pages DEFENSE000001 through DEFENSE004461 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 47 of 49
3 

March 4, 2019 

U.S. v. Lacey, etal., 18-CR-0422-PHX-DLR 

Page 4 

Defendants reserve the right to supplement these disclosures in response to the 

government's continuing disclosures and obligations and as additional materials become 

available to defendants. 

Very truly yours, 

BIENERT KATZMAN PLC 

s / Whitney Z. Bernstein 

Whitney Z. Bernstein 

Thomas H. Bienert, Jr. 

Attorneys for James Larkin 

LIP SITZ GREEN SCIME CAMBRIA LLP 

s / Paul J. Cambria, Jr. 

Paul J. Cambria, Jr. 

Erin E. McCampbell 

Attorneys for Michael Lacey 

FEDER LAW OFFICE PA 

s/ Bruce S. Feder 

Bruce S. Feder 

Attorneys for Scott Spear 

BIRD MARELLA BOXER WOLPERT 

NESSIM DROOKS LINCENBERG AND 

RHOW PC 

s/ Gag S. Lincenberg 

Gary S. Lincenberg 

Arid l A. Neuman 

Gopi K. Panchapakesan 

Attorneys for John Brunst 

PICCARRETA DAVIS KF,ENAN FIDEL PC 

5/ Michael L. Piccarreta 

Michael L. Piccarreta 

Attorneys for Andrew Padilla 

KARP & WEISS PC 

s / Stephen M. Weiss 

Stephen M. Weiss 

Attorneys for Joye Vaught 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 48 of 49
3 

March 4, 2019 

U.S. v. Lacey, etal., 18-CR-0422-PHX-DLR 

Page 5 

cc: AUSA Reginald E. Jones (Reginald.Jones4@usdoj.gov) 

AUSA Andrew Stone (Andrew.Stone@usdoj.gov) 

AUSA Peter Kozinets (Peter.Kozinets@usdoj.gov) 

AUSA Margaret Perimeter (Margaret.Perlmeter@usdoj.gov) 

AUSA John Kucera Gohn.Kucera@usdoj.gov) 

Thomas H. Bienert, Jr. 

Paul Cambria, Jr. 

Gary Lincenberg 

Bruce Feder 

Michael Piccarreta 

Stephen Weiss 

Case 2:18-cr-00422-DJH Document 524-1 Filed 04/16/19 Page 49 of 49