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Paul J. Cambria, Jr. (NY Bar No.1430909, admitted pro hac vice) 

Erin McCampbell Paris (NY Bar No. 4480166, admitted pro hac vice) 

LIPSITZ GREEN SCIME CAMBRIA LLP

42 Delaware Avenue, Suite 120

Buffalo, New York 14202

Telephone: (716) 849-1333

Facsimile: (716) 855-1580

pcambria@lglaw.com

emccampbell@lglaw.com

Attorneys for Michael Lacey

Gary S. Lincenberg (CA Bar No. 123058, admitted pro hac vice)

Ariel A. Neuman (CA Bar No. 241594, admitted pro hac vice)

Gopi K. Panchapakesan (CA Bar No. 279856, admitted pro hac vice)

BIRD, MARELLA, BOXER, WOLPERT, NESSIM,

DROOKS, LINCENBERG & RHOW PC

1875 Century Park East, 23rd Floor

Los Angeles, California 90067-2561

Telephone: (310) 201-2100

Facsimile: (310) 201-2110

glincenberg@birdmarella.com

aneuman@birdmarella.com

gpanchapakesan@birdmarella.com

Attorneys for John Brunst

Additional counsel listed on next page

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

United States of America,

 Plaintiff,

vs.

Michael Lacey, et al., 

 

 Defendants.

NO. CR-18-00422-PHX-DJH

DEFENDANTS’ MOTION TO DISMISS 

OR TO STRIKE TESTIMONY, AND 

REQUEST FOR A HEARING DUE TO 

THE GOVERNMENT’S JENCKS AND 

BRADY VIOLATIONS

 
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Eric Kessler

KESSLER LAW GROUP

6720 N. Scottsdale Rd., Suite 210

Scottsdale, AZ 85253

Telephone: (480) 644-0093

eric@kesslerlawgroup.com

Attorney for Scott Spear

Bruce Feder (AZ Bar No. 004832)

FEDER LAW OFFICE PA

2930 E. Camelback Road, Suite 160

Phoenix, Arizona 85016

Telephone: (602) 257-0135

bf@federlawpa.com

Attorney for Scott Spear

David Eisenberg (AZ Bar No. 017218)

DAVID EISENBERG PLC

3550 N. Central Ave., Suite 1155

Phoenix, Arizona 85012

Telephone: (602) 237-5076

Facsimile: (602) 314-6273

david@deisenbergplc.com

Attorney for Andrew Padilla

Joy Malby Bertrand (AZ Bar No. 024181)

JOY BERTRAND ESQ LLC

P.O. Box 2734

Scottsdale, Arizona 85252

Telephone: (602)374-5321

Facsimile: (480)361-4694

joy.bertrand@gmail.com

Attorney for Joye Vaught
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Motion

The Defendants, by and through their undersigned counsel, move for a dismissal of 

the indictment or, in the alternative, for an order striking the testimony of government 

witnesses Carl Ferrer and Quoc Thai relating to money transfers through accounts referenced 

in Exhibit “A,” the 90-page November 4, 2021, Asset Tracing Report by Quoc Thai and 

Lyndon Versoza (hereafter, the “Thai Report”). This motion is premised on the government’s 

failure to disclose a statement co-authored by Mr. Thai until after the close of evidence, in 

violation of both 18 U.S.C. § 3500 and the requirements of Brady v. Maryland, 373 U.S. 83 

(1963). Because the full extent of the government’s disclosure violation is not yet known, 

Defendants respectfully request an evidentiary hearing to fully develop the record on the 

violation to guide this Court as to the proper remedy.

Memorandum

1. The Government’s Untimely Disclosure

On November 8, 2023, government counsel emailed the Thai Report to defense 

counsel, saying it “may” be considered a “statement” subject to disclosure under 18 U.S.C. 

§ 3500 because the statement was co-authored by government witness Quoc Thai. Along with 

the Thai report, the government transmitted to defense counsel an October 18, 2023, email 

from Mr. Thai to government counsel describing the Thai Report as a report “Lyndon 

[Versoza] and I put together years ago” (Exhibit B). 

In his October 18 email to government counsel, Mr. Thai said: “I wanted to share with 

you the latest draft of the tracing document that Lyndon and I put together years ago. You 

might already have a copy of a prior draft.” The Thai Report is a Microsoft Word file with 

the name “2018-07-20 TRACING FOR ALL ASSETS QT_LV Edits 5.docx,” suggesting that 

the Report initially was created more than five years ago and that there are four earlier versions 

of the Report that have yet to be produced. On its cover page, the Report says that it was 

updated November 4, 2021. Moreover, the text of the Report suggests there also is a version 

6 of the Report, as the Report says on the page numbered 71: “As set forth below, financial 
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transactions involving illicit proceeds were deposited (TRACING TO BE COMPLETED 

ON MONDAY).” The government has yet to produce any prior or subsequent versions of the Thai Report. 

The government has long possessed the Thai Report. It was part of an October 18, 

2023 email between Mr. Thai and government counsel (the day after Thai completed his trial 

testimony and well before the close of evidence in this case). Nonetheless, government 

counsel withheld the Thai Report until after the conclusion of the trial. 

2. The Thai Report Was Material

The defense plainly could have used the untimely Jencks material to cross-examine Quoc 

Thai and Ferrer on the indictment’s money laundering counts. The following statements of 

Mr. Thai from the Thai Report could have been using during cross:

• The Thai Report states that “M.G.” (presumably Michael Gage, the CFO of Backpage 

after its sale to Ferrer in April 2015) was the “sole signatory” on the Posting Solutions, 

LLC account. Exh. A at ¶ 1. This statement could have been used to counter the 

impression delivered by Ferrer and the government that Brunst and other Defendants 

still maintained control over Backpage bank accounts following the sale of the business.

• Throughout his Report, Thai referenced “Backpage Operators” in regard to the 

individuals who formed companies, opened bank accounts, and purportedly engaged 

in deceptive conduct towards banks and credit card companies. These discussions in

the Report could have been used to examine Thai regarding whom he considered to 

be a “Backpage Operator.” Ferrer appears to be the only individual identified in this 

respect. Id. at ¶ 2. 

• Thai states in the Report that “[a] go-between is an account set up for the main purpose 

of transferring funds from one or more bank accounts to one or more other bank 

accounts. Commonly used as a means of concealing the original source of the funds.” 

Id. at p. 9 n.1. As to the indictment’s concealment money laundering counts, the 

defense could have cross-examined Thai regarding whether and to what extent the 

Cereus Properties account at BBVA Compass Bank identified in these counts was used 

as a “go-between” account for the purposes of concealment, as opposed to an account 
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that the sellers of Backpage (Lacey, Larkin, Spear, and Brunst) merely used to receive 

loan payments on the sale of Backpage per Ferrer’s direct testimony. The Thai Report 

does not identify the Cereus Properties account as a “go-between” account (yet makes 

this claim about other accounts), an omission that could have been used during cross 

of Thai to establish that the Cereus Properties account was not used to conceal the 

source of funds as to the indictment’s concealment money laundering counts (Counts 

53-62).

• Throughout his Report, Thai said “[i]n furtherance of their money laundering scheme, 

and in an attempt to further conceal the true nature of the money,” as a preface to his 

description of a bank account. See, e.g., id. at ¶¶ 8, 13, 14, 16, 18, 24, 27, 28, 61, 146(a). 

This places the Report in its proper context, namely that it is a report concerning the 

indictment’s money laundering allegations, not merely forfeiture as now claimed by the 

government.

• Throughout his Report, Thai said that – based on statements Ferrer made to him – 

foreign companies and agreements with foreign partners were set up by Backpage “for 

the sole purpose of allowing purchasers of prostitution ads to purchase ads on 

Backpage websites while evading the credit card company blockade.” See, e.g., id. at ¶¶ 

34, 36, 39, 41, 46, 54, 65 (referencing companies like Gold Leaf SRO, Protecctio SRO, 

and Varicok Company SRO). The implication from the Thai Report is that it was 

Ferrer – not Brunst or any other Defendant – who set up these companies and made 

these arrangements. With the benefit of this Report, the defense could have combatted 

the government’s sweeping claim that Brunst or other Defendants were involved in 

setting up foreign bank accounts and managing them, even after the sale of Backpage 

in April 2015.

Additionally, the defense could have used the Thai Report to directly impeach Mr. Thai on 

a critical issue pertaining to the money laundering charges. Specifically, the government 

elicited (false) testimony from Thai that “Cereus Properties appears to be an entity used to pay 

the various payroll expenses of the . . . activity relating to the Backpage.com.” Trial Tr., 
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10/13/23 a.m., at 136/16-20. This testimony was made with reference to the indictment’s 

money laundering charges concerning wire transfers to Cereus Properties, each of which 

occurred after the April 2015 sale of Backpage. E.g., Doc. 230 at Counts 53-62, 64-68. There 

was not a shred of evidence at trial or anything in the discovery produced by the government 

corroborating Thai’s assertion regarding Cereus Properties. Yet the government repeated this 

testimony during its closing argument in support of the indictment’s promotional money 

laundering counts. Trial Tr., 10/27/23 a.m., at 26:5-13 (“Well, Cereus Properties appears to 

be an entity used to pay the various payroll expenses. This is the promotional money 

laundering. Plowing the money back in or the activity related to Backpage.com.”). 

The Thai Report, however, confirms the opposite, noting that “[o]n August 2 and 

August 8, 2017, Prosperity Account bank ‘7188 wired $33,700 and $44,000, respectively, to 

S&W Payroll, a company Backpage uses to pay its employees.” Exh. A at ¶ 21(a) 

(emphasis added). In other words, Thai admitted, in a document he co-authored, that (1) 

S&W Payroll (not Cereus Properties) was Backpage’s payroll company following the sale of 

Backpage and (2) the funds for Backpage’s payroll came from Prosperity Bank. As noted 

above, Thai stated in his Report that Michael Gage (Backpage’s CFO following the sale) was 

the sole signatory on the Prosperity Bank account (not Brunst or any of the other Defendants) 

and that the account was held by Posting Solutions, LLC (not Cereus Properties). Id. at ¶ 1. 

Without this obviously impeachable testimony from Mr. Thai, the government has no case as 

to promotional money laundering.
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Finally, in its opening statement,1 in its closing statements,2 and through testimony the 

government repeatedly elicited during the trial,3 the government told the jury that Backpage 

had its customers pay for ads by mailing money orders to Posting Solutions, LLC’s post office 

box (e.g., Gov’t. Exh. 2044, p. 26), with the aim of concealing that those payments were 

associated with Backpage. The Thai Report discloses, however, that when Posting Solutions 

applied for its post office box in Dallas, Texas, it disclosed on the application that 

Backpage.com, Website Technologies, Carl Ferrer, and other “Backpage Operators” would be 

registered users of the post office box:

2. “Posting Solutions’ application for the USPS Dallas, 

Texas P.O. BOX, lists the box being registered to “Website 

Technologies, LLC/Backpage.com.” Also listed on the P.O. 

 

1 “Money orders deposited into shell company bank accounts, and money moved to other 

Backpage shell companies.” (Tr. Trans., 8/31/23 p.m., p. 171:3-8)

2 “You heard lots of evidence that they were having banking issues, so they have to engage 

in activities that conceal the origin, the source, the nature of that money.” (Tr. Trans., 

10/27/23, p. 20:21-23); “[P]rostitute[s] bought ads on Backpage, they paid with money 

orders, the money orders were deposited to shell company bank accounts, and the money 

was moved to other Backpage shell companies. All about the concealment of money 

laundering.” ((Tr. Trans., 10/27/23, p. 24:16-21); “This is Defense Exhibit 5364. This 

shows sort of the web of concealment; right? ... [T]hey created all these holding companies 

at the sale with the idea that they would actually conceal the source of the money.” (Tr. 

Trans., 10/27/23, p. 25:18-22); “Counts 53 to 62 are concealment money laundering. It’s 

shown through the use of numerous shell companies that they didn’t need for the first eight 

years of Backpage’s existence.” (Tr. Trans., 11/01/23, p. 68:7-9).

3 “[W]e’re asking customers to mail us money orders. So they would go to 7-Eleven or the 

Post Office and then mail us a money order.... And some days were $70,000 a day coming 

in on money orders.” (Tr. Trans., 9/21/23 p.m., p. 45:19-46:4); “Well, we had a company 

called Posting Solutions. So then we would open up a bank with the company Posting 

Solutions and then deposit the checks under Posting Solutions.... [U]usually Monday was 

an extremely busy day because you had the mail for, you know, Saturday, Monday, you had

multiple days and so there were times when it was over $100,000 in money orders being 

deposited. Q. Did you ever advise the posters to make the money order out to Backpage? 

A. No. We would not advise them because we didn’t have a bank called Backpage so we 

wouldn't be able to deposit them.” (Tr. Trans., 9/21/23 p.m., p. 47:18-48:20); “Posting 

Solutions was another shell company similar to, like, Website Technologies, very generic 

sounding company that we could open bank accounts with....It was used to open up a 

banking account and for money orders to be made in the name of Posting Solutions and 

then those money orders would be deposited into the bank account.” (Tr. Trans., 9/21/23 

p.m., p. 89:6-24); 
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BOX Application were the names of several Backpage 

Operators, including FERRER.

If the government had timely disclosed the Thai Report, the defense would have crossexamined both Thai and Ferrer about Posting Solutions’ disclosure to the federal government 

of information that the prosecution claimed Backpage sought to conceal. Separate from and 

in addition to its obligations under the Jencks Act, the government also was obligated to turn 

the Thai Report (and related communications) over to the defense under Brady, as the Report 

was “both favorable to the accused and ‘material either to guilt or to punishment.’” United 

States v. Bundy, 968 F.3d 1019, 1031 (9th Cir. 2020). “‘Brady evidence’ can be favorable ‘either 

because it is exculpatory or impeaching’”—and this information was both. Id. The 

prosecution has an affirmative obligation to learn of potentially favorable evidence and 

provide it to the defense. Id. at 1038. Here, however, the government knew of the favorable 

evidence, but kept it from the defense until after the close of evidence. 

In sum, there are numerous statements in the Thai Report that could have been used 

to cross-examine, impeach, and refresh recollection. These statements go to the heart of the 

government’s money laundering case, namely the alleged concealment of Backpage funds, 

promotion of Backpage through wire transfers, and the role Ferrer played in these purported 

schemes (and the comparative lack of a role Brunst and the other Defendants played).

3. The government’s disclosure obligations 

As discussed below in greater detail, the Thai Report (and its prior versions and any 

subsequent versions) should have been disclosed to the defense long before the start of trial 

as both Jencks and Brady material.

Under the Jencks Act, the government is required to produce any statement of the 

witness in the possession of the United States that relates to the subject matter on which the 

witness testified. “The purpose of production of statements is to give defendants 

impeachment materials at a time when they can effectively use them.” United States v. McKoy, 

78 F.3d 446, 452 (9th Cir. 1996). This disclosure implicates more than just a defendant’s 

statutory rights. It is a matter of due process and fundamental fairness as recognized by the 

Supreme Court in Jencks v. United States, 353 U.S. 657, 667-72 (1957). Further, the Supreme 
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Court has recognized that, “in some situations, denial of production of a Jencks Act type of a 

statement might be a denial of a Sixth Amendment right.” United States v. Augenblick, 393 U.S. 

348, 356 (1969). Additionally, the Ninth Circuit has recognized that when a conviction “rests 

heavily on the credibility of a single accomplice...the unproduced Jencks material may well 

implicate confrontation clause or compulsory process issues.” United States v. Wallace, 848 F.2d 

1464, 1471 (9th Cir. 1988). 

“The Jencks Act requires the government to produce any written statements by a 

government witness that relate to the subject matter of any direct testimony by the witness.” 

United States v. Brumel-Alvarez, 991 F.2d 1452, 1463 (9th Cir. 1992). “Moreover, it is sufficient 

that, in determining whether the statements in question ‘related to’ the direct testimony of the 

witness, it must relate generally to the events and activities testified to.” Id. at 1464 

(quoting United States v. O’Brien, 444 F.2d 1082, 1086 (7th Cir. 1971)) (alterations and 

quotations omitted, emphasis in original). “There are no exceptions to the Jencks rule that all 

statements relevant to the subject matter of the witness’ testimony must be produced after 

direct examination of the witness.” United States v. Bibbero, 749 F.2d 581, 585 (9th Cir.) 

(reversing conviction because government failed to produce all versions of a DEA report); see 

also United States v. Carrasco, 537 F.2d 372, 375-76 (9th Cir. 1976) (reversing conviction because 

trial court failed to strike witness testimony under Jencks concerning the government’s failure 

to disclose that the witness provided the government with a “diary” that the witness referred 

to as the “original report” concerning drug transactions, even though the government’s agent 

claimed that the agent had included all information from the “original report” in his notes of 

the witness’s interview). 

Courts routinely order pretrial disclosure of all Jencks materials, as this Court did here, 

ordering the government to produce all Jencks Act statements on or before February 25, 2019, 

and then ordering a final disclosure no later than August 20, 2019. (Docs. 131, 730.)4 Here, 

 

4 Notably, upon the filing of an ex parte motion by the government, the Court extended 

the deadline for disclosure of Jencks Act statements by Mr. Ferrer to June 25, 2019. (Doc. 

535.) When the government failed to comply with this order, the Defendants filed a motion 

to compel. (Doc. 662.) The Court then ordered the government to disclose all Jencks Act 
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the Court took such a broad view of the disclosure requirements that the Defendants were 

required to disclose text messages in which a defense witness texted a link to his published 

resume and an email from a defense investigator in which the investigator transmitted a 

handful of government exhibits to the witness, on the bases that these communications could 

be deemed to be “statements” of the witnesses under Rule 26.2. As discussed below, the Thai 

Report has far more relevance to the substance of witness testimony than these ordered 

disclosures.

4. Jencks Act Remedies

Critically, the Jencks Act provides remedies for the defense when, like here, the 

government fails to comply with its disclosure obligations. “Enforcement of the Jencks Act 

is an affirmative duty of the trial court,” which “may not rely on government assertions alone 

to resolve disputes about the adequacy of disclosure under the Act.” United States v. McKenzie, 

768 F.2d 602, 607-08 (5th Cir. 1985). “If the United States elects not to comply with an order 

of the court under subsection (b) or (c) hereof to deliver to the defendant any such statement, 

or such portion thereof as the court may direct, the court shall strike from the record the 

testimony of the witness, and the trial shall proceed unless the court in its discretion shall 

determine that the interests of justice require that a mistrial be declared.” 18 U.S.C. § 3500(d). 

Further, under Rule 26.2 of the Federal Rules of Criminal Procedure (“Rule 26.2”), “which 

basically implements the Jencks Act,” if the government fails to comply with its disclosure 

obligations, the district court “shall declare a mistrial if required by the interest of justice.” 

United States v. Riley, 189 F.3d 802, 805 (9th Cir. 1999) (quoting Rule 26.2(e)). “In imposing 

sanctions against the government for violations of the Jencks Act, the district court should 

consider the culpability of the government . . . and the injury to the defendants.” United States 

v. McKoy, 78 F.3d 446, 451 (9th Cir. 1996) (affirming grant of mistrial due to government’s 

unintentional failure to disclose Jencks Act material). 

 

material not previously disclosed no later than August 20, 2019. (Doc. 730.) The disclosure 

of the Thai Report occurred on November 8, 2023, more than four years after the deadline 

for Jencks Act disclosures and, more importantly, after the close of evidence. 
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“It is now well established that individual ‘notes and reports’ of agents of the 

Government who testify for the Government, made in the course of a criminal investigation, 

are the proper subject of inquiry and may be subject to production under the Jencks Act.” 

United States v. Johnson, 521 F.2d 1318, 1319 (9th Cir. 1975) (vacating conviction because, 

although the government disclosed the case agent’s report, the government failed to disclose 

the case agent’s written notes and, if the notes constituted a Jencks Act “statement,” which 

the district court was required to determine on remand, the district court must grant the 

defendant a new trial if his substantial rights were affected by the failure to make the statement 

available). The lengthy Thai Report clearly constitutes “notes or a report” of a government 

witness. There can be no dispute that the content of the Report ‘related to’ the direct 

testimony of Thai and Ferrer. The Thai Report discusses financial transactions, statements by 

Ferrer, and facts about Ferrer (such as his ownership interest in various entities) that were the 

focus of the government’s case in chief. As a result, the tracing report is subject to this Court’s 

disclosure orders. See, e.g., Brumel-Alvarez, 991 F.2d at 1463-64 (reversing conviction because 

government’s failure to disclose a memorandum written by a government witness that related 

to the testimony of the witness violated the Defendant’s rights under the Jencks Act, among 

other rights).

It also is troubling that the only reason the government has now produced the Thai 

Report seems to be that Mr. Thai put it at the top of the prosecutors’ in-box during trial. Once 

he did so, the government faced the dilemma of continuing to withhold the Jencks material 

hoping the defense would never learn of it versus disclosing it late and risking that the Court 

would strike Mr. Thai’s trial testimony. On October 18, the government apparently chose the 

former, to continue to withhold the Report. Post-trial, in anticipation of Mr. Thai testifying 

again, the government apparently chose the latter (hoping this Court would not sanction it for 

the discovery violation). Of course, the government’s decision not to produce the Thai Report 

on October 18 further precluded defense counsel from considering the Report in formulating 

strategy over what defense witnesses to call, what to say in response to the government’s 

closing arguments on the wire transfers, and how to respond to the government’s arguments 
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regarding the purpose of the establishment of entities such as Website Technologies and 

Posting Solutions. 

Moreover, the prejudice to the Defendants is particularly egregious here because the 

Jencks Act material at issue concerns the government’s only witness on the wires relating to 

the 49 money laundering counts, Mr. Thai, and its most important witness in the case, Mr. 

Ferrer. While prejudice need not be shown to establish a discovery violation, the deprivation 

has caused undue prejudice to the Defendants because “the withheld evidence could have 

affected the outcome of the trial.” See, e.g., Brumel-Alvarez, 991 F.2d at 1464 (concluding that 

the failure to disclose a memorandum concerning a case agent’s impressions of a central 

government witness was not harmless and undermined the outcome of the trial). 

5. The Court Should Hold an Evidentiary Hearing

Defendants are entitled to a hearing to develop the full record on the violation and to 

enable this Court to fashion an appropriate remedy. The hearing is particularly important 

here, where the document at issue refers to prior versions and a future version, the document 

contains statements from witnesses (such as Ferrer’s contributions), and the circumstances 

that led to the failure to timely disclose the statement are unknown. 

In United States v. Miller, 771 F.2d 1219 (9th Cir. 1985), the Ninth Circuit explained that 

the district court commits error when it relies on statements from government counsel 

claiming that a particular witness statement is not Jencks material. See id. at 1231-33. Instead, 

the proper course of action is to conduct a hearing to determine whether the statement is 

Jencks material and, if so, the circumstances that led to the failure to disclose the statement. 

See id.; accord Campbell v. United States, 365 U.S. 85, 92-99 (1961) (indicating that an evidentiary 

hearing is “a proper, even a required, proceeding” when the government disputes whether a 

statement constitutes Jencks material and when the creation of the statement is at issue); United 

States v. Smith, 746 F.2d 1183, 1184 (6th Cir. 1984) (reversing conviction for district court’s 

acceptance of government statement and failure to hold a hearing and noting that “[our] cases 

have held that such a hearing is required whenever there is a disputed request for Jencks Act 
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material in order to determine whether the documents in question are actually statements of a 

witness”).

RESPECTFULLY SUBMITTED this 13th day of November, 2023, 

Paul J. Cambria, Jr.

Erin McCampbell Paris

LIPSITZ GREEN SCIME CAMBRIA LLP

 By: /s/ Paul J. Cambria, Jr. 

Paul J. Cambria, Jr.

Attorneys for Michael Lacey

Pursuant to the District’s Electronic Case Filing Administrative Policies and Procedures Manual (Jan. 

2020) § II (C) (3), Paul J. Cambria hereby attests that all other signatories listed, and on whose behalf this 

filing is submitted, concur in the filing’s content, and have authorized its filing.

Gary S. Lincenberg

Gopi K. Panchapakesan

BIRD, MARELLA, BOXER, WOLPERT, NESSIM,

DROOKS, LINCENBERG & RHOW, P.C.

By: /s/ Gary Lincenberg 

Gary Lincenberg

Attorneys for John Brunst

Eric W. Kessler

KESSLER LAW OFFICE

By: /s/ Eric W. Kessler 

Eric W. Kessler

Attorneys for Scott Spear

Bruce Feder

FEDER LAW OFFICE, P.A.

By: /s/ Bruce Feder 

Bruce Feder

Attorneys for Scott Spear
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David Eisenberg

DAVID EISENBERG, P.L.C.

By: /s/ David Eisenberg 

David Eisenberg

Attorneys for Andrew Padilla

 Joy Bertrand

JOY BERTRAND, ESQ.

By: /s/ Joy Bertrand 

Joy Bertrand

Attorneys for Joye Vaught

On November 13, 2023, a PDF version of this document was 

filed with Clerk of the Court using the CM/ECF System 

for filing and for Transmittal of a Notice of Electronic 

Filing to the to the CM/ECF registrants who have 

entered their appearance as counsel of record