1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

ELIZABETH A. STRANGE

First Assistant United States Attorney

District of Arizona

KEVIN M. RAPP (Ariz. Bar No. 014249, kevin.rapp@usdoj.gov)

MARGARET PERLMETER (Ariz. Bar No. 024805, margaret.perlmeter@usdoj.gov)

PETER S. KOZINETS (Ariz. Bar No. 019856, peter.kozinets@usdoj.gov) 

ANDREW C. STONE (Ariz. Bar No. 026543, andrew.stone@usdoj.gov)

JOHN J. KUCERA (Cal. Bar No. 274184, john.kucera@usdoj.gov) 

Assistant U.S. Attorneys

40 N. Central Avenue, Suite 1800

Phoenix, Arizona 85004-4408

Telephone (602) 514-7500

BRIAN BENCZKOWSKI

Assistant Attorney General

Criminal Division, U.S. Department of Justice

REGINALD E. JONES (Miss. Bar No. 102806, reginald.jones4@usdoj.gov) 

Senior Trial Attorney, U.S. Department of Justice Child Exploitation and Obscenity Section 

950 Pennsylvania Ave N.W., Room 2116

Washington, D.C. 20530

Telephone (202) 616-2807 

Attorneys for Plaintiff

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

United States of America,

Plaintiff, 

v. 

Michael Lacey, et al.,

Defendants.

CR-18-422-PHX-SMB

UNITED STATES’ STATUS 

MEMORANDUM

[Status Conference set for

April 23, 2019, 2:30 p.m.]

I. Government’s Second Status Memorandum

On January 18, 2019, the government filed its first status memorandum detailing its 

compliance with the Court-issued Scheduling Order deadlines. (CR 444; see CR 131 

(Scheduling Order)). Also, on January 18, 2019, Defendants’ filed a mislabeled “Joint 

Status Report” that in actuality was a motion seeking a four-month delay of their 

Case 2:18-cr-00422-DJH Document 524 Filed 04/16/19 Page 1 of 12
- 2 -

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Scheduling Order deadlines. In their motion, Defendants contended they needed a 

continuance because all of their “assets have been seized, virtually, all of the money in 

their attorneys’ trust accounts designated to fund the defense has been seized or is 

effectively frozen, and the defendants are currently litigating those issues in the Central 

District of California and Ninth Circuit Court so they can continue to fund their defense.” 

Defendants also asserted that a four-month continuance would allow the Central District 

of California (CDCA) and/or Ninth Circuit time to address these challenges. (CR 443 at 

3). 

On January 23, 2019, the government filed a response to Defendants’ motion and 

opposed the requested continuance because: (1) Defendants had not made a showing that 

they lacked sufficient untainted funds to continue with their current counsel; (2) the

timeline for resolving their litigation in the CDCA and the Ninth Circuit regarding the 

government’s pre-trial seizure of assets linked to Backpage.com, LLC (Backpage) was

unknowable; and (3) the government vigorously disagreed with Defendants’ belief that

they would be successful in the CDCA and/or Ninth Circuit. (See CR 446 at 1-3). 

On January 25, 2019, Judge Logan conducted a status conference, heard argument 

from the government and Defendants, and denied Defendants’ motion for a four-month 

continuance. (See CR 448; see also CR 459 Tr. 1/25/19 at 66-67 (Judge Logan: “This 

Court is in receipt of Document Number 443, which is the defendants’ joint status report. 

This court, after reading the 15-page document several times, I will consider it as a motion 

requesting a continuance or as was described earlier by Mr. Piccarreta, a request to stay the 

defendants’ obligations. . . . After carefully considering all of the issues, the motion . . . 

will be denied. The current deadlines in the scheduling order that are spelled out in 

Document Number 131, the government and defense, I am ordering you both to continue 

to meet those deadlines. In the event that the Ninth Circuit Court of Appeals comes out 

with a decision, and that decision is one in which this District Court needs to act on it based 

on if funds are freed or whatever way that they decide the case and send it back to the 

District Court, I look forward to weighing in on those issues.”)). 

Case 2:18-cr-00422-DJH Document 524 Filed 04/16/19 Page 2 of 12
- 3 -

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Since the January 25, 2019, status conference, the government has continued to 

comply with Court-ordered scheduling deadlines as set forth below.

II. Discovery

On February 22, 2019, the government provided Defendants with, among other 

documents, approximately 75 reports of witness interviews and Jencks statements. (See

Exhibit A). The government provided Defendants with additional documents, including

approximately 10 additional reports of witness interviews, on March 14, 2019. (See

Exhibit B). 

Moreover, on March 18, 2019, the government informed Defendants Michael Lacey 

and James Larkin that their personal device data seized pursuant to a court-authorized 

search warrant was available for pick-up at an FBI facility in Phoenix. (See Exhibit C). 

The government also informed all Defendants that additional Backpage cloud service data 

was available for pick-up at an FBI facility in Phoenix. (See Exhibit D).1

 The government 

had indicated to Defendants and the Court at the status conference that this data would be 

forthcoming. (See CR 459 Tr. 1/25/19 at 14 (Mr. Jones: “Now that our filter protocol has 

been reviewed, we have a few categories, documents, i.e., the defendants tax records, 

[documents from a] third-party IT firm, Your Honor, and also some of the personal devices 

that need to go through that attorney filter review. But those documents should be 

disseminated to them as well within the next couple of months or so since the filter protocol 

is in place.”)). However, on February 11, 2018, Defendants requested the government 

provide them “a listing of all attorneys, firm names, etc. that the taint team is using in its 

search to remove privileged matters.” Defendants further requested to “review this list in 

case some names had been inadvertently omitted and thus potentially exposing members 

of the prosecution team to privileged materials.” (See Exhibit E). The government 

subsequently provided Defendants a list of more than 265 terms (See CR 269-8, Exhibit 

 

1 In a meet and confer session with counsel for Defendant Larkin on April 9, 2019, counsel indicated that she would pick-up the aforementioned data the week of April 22, 2019.

Case 2:18-cr-00422-DJH Document 524 Filed 04/16/19 Page 3 of 12
- 4 -

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

H) related to attorney representation that it had segregated through its filter review, that the 

Court had previously found sufficient to reasonably identify any privileged documents 

present in its discovery materials. (See Court’s order approving government’s filter review; 

CR 445). In order to prevent delay of any review Defendants might want to make of the 

materials, the government made these materials available to Defendants on March 18, 

2019. On March 25, 2019, Defendants provided the government with a list of additional 

counsel “that should be screened as privileged and thus segregated from review by the 

government.” (See Exhibit F). The government will conduct any review of the 

aforementioned materials after potentially privileged material has been segregated through 

the Court-approved filter protocol.2

On April 11, 2019, the government produced to Defendants the remaining BDOConsulting as well as Epiq data. (See Exhibit G). The government will provide Defendants 

with exhibits of any of the above-mentioned data that it might utilize at trial. 

To date, the government has provided Defendants with nearly all discovery nine

months before trial.3

 In fact, approximately 90 percent of discovery in this case was

provided to Defendants on May 24, 2018 – nearly 20 months prior to trial. (See CR 444; 

Exhibit A). Moreover, this discovery has been produced to Defendants in an electronic, 

load-ready, industry-standard format4 – a format agreed to by all parties at the outset of the 

case. (See CR 137, Tr. 4/30/18). 

Approximately 20 percent of discovery produced to Defendants are documents 

 

2 The government has added the additional names provided by Defendants on March 25, 2019, to its list of terms to be segregated through its filter review.

3 Any remaining records produced by the government in this case will be nominal. However, as per the Court-issued Scheduling Order, any additional records obtained during 

pre-trial preparation shall be disclosed to Defendants as soon as possible. (See CR 121, p.1 at 27-28 (“If additional records are discovered by, or disclosed to, the government during pretrial preparation or otherwise, pursuant to Rule 16(c), Fed. R. Crim. P., the government shall promptly disclose any additional documentary evidence or materials to the defense as 

soon as practicable after such disclosure or discovery occurs.”)).

4 This format allows documents to be easily searched by text or metadata fields (e.g., email date, sender, etc.).

Case 2:18-cr-00422-DJH Document 524 Filed 04/16/19 Page 4 of 12
- 5 -

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Defendants previously provided the U.S. Senate Permanent Subcommittee on 

Investigations (PSI) in 2016 as part of its investigation into Backpage,

5 and were 

subsequently compelled by the Arizona District Court to be produced to the government in 

September 2017 as part of the USAO 108 subpoena litigation. (See CR 444, Exhibit B). 

Consequently, Defendants have been in possession of these records for at least two and a 

half years. 

Another nearly 60 percent of discovery provided to Defendants originated from a 

source from which the government agreed to disclose to Defendants materials that it might 

utilize from that source at trial; the government disclosed the more than 100 pages of such 

materials from that source to Defendants more than eight months ago. (See CR 444,

Exhibit C). In sum, nearly 80 percent of discovery provided to Defendants in this case are 

either documents Defendants previously produced to the government, or a category of 

materials whereby the government has provided Defendants with any documents the 

government might utilize at trial.

The government has also taken several additional steps to facilitate Defendants’ 

review of discovery in this case. Among other things, the government: 

(1) Made available a Department of Justice (DOJ) discovery specialist to assist 

Defendants with technical questions;6

 

(2) Provided detailed indexes to the discovery consisting of nearly 40 categories 

denoting the source from which the materials were obtained; 

 

5 Declaration of Breena Ross, Senate Permanent Subcommittee on Investigations v. 

Carl Ferrer, Misc. No. 1:16-mc-00625-RMC (D.D.C. Nov. 30, 2016).

6 To date, the only technical issue involving accessing discovery in the agreed industry-standard platform Defendants have asserted is a February 28, 2019, letter wherein they contended that 2,744 documents that had been provided to them more than nine 

months prior could not be loaded into their discovery database. (See Exhibit I). The 

government promptly looked into the matter and on March 6, 2019, notified Defendants 

that the 2,744 documents at issue had been provided to them in the same manner they were 

produced to the government, and that the 2,744 files could be loaded into and viewed in a 

discovery database such as the platform both parties agreed at the outset of the case would 

be used to produce discovery. The government also located and viewed a sampling of the 2,744 documents in its discovery database without issue. (See Exhibit J).

Case 2:18-cr-00422-DJH Document 524 Filed 04/16/19 Page 5 of 12
- 6 -

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

(3) Produced subsets of approximately 1,500 “hot documents” – documents 

specifically related to the allegations in the Superseding Indictment to all Defendants 

approximately 18 months prior to trial; (See CR 444, Exhibits D and E); and

(4) Provided counsel for a number of Defendants (upon request) with subsets of “hot 

documents” specifically related to the allegations in the Superseding Indictment against 

their respective clients; the government has also offered to meet (and have met with several 

Defendants) with Defendants to discuss its theory of the case and the allegations against 

the Defendants in detail. (See CR 444, Exhibits F, G, H, and I).

III. Backpage Server Data

On March 7, 2019, the government sent Defendants a letter summarizing its 

handling of the Backpage server data to date. (See Exhibit H). As detailed in this letter, 

the government has 46 Backpage servers in its possession. Backpage operated as a 

classified advertising website for a decade and a half so the government is certain 

Defendants are familiar with the data (including ads and images) hosted on its servers. The 

Court also shared this view and expressed such at the 1/25/19 status hearing. (CR 459, Tr. 

1/25/19, p.22 (Judge Logan: “Who is familiar with those documents that Mr. Jones and 

Mr. Rapp just proffered on the record? Is anybody? Has anybody heard of a Backpage 

ad? Is anybody familiar with Backpage, with what they do as it relates to ads? Would 

anyone argue that if Backpage is responsible for receiving compensation to post an ad, 

Backpage should know about the ad? Would everyone agree with that?”)). However, (as 

it has done throughout this case) the government went above and beyond its discovery 

obligations under Federal Rule Criminal Procedure Rule 16, and extracted all of the 

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

and imaged the server containing all of the Backpage images in order to assist Defendants 

in any review they would like to conduct of server data. The extracted ad and image data 

were made available to Defendants on March 7, 2019.

Additionally – although the government had previously provided Defendants with 

Backpage ads that are referenced in the Superseding Indictment – on March 14, 2019 (as 

Case 2:18-cr-00422-DJH Document 524 Filed 04/16/19 Page 6 of 12
- 7 -

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

per Defendants request), the government provided Defendants a sampling of 

approximately 70 Backpage ads referenced in counts in the Superseding Indictment as the 

ads appear in the server data the government imaged. (See Exhibit K). Moreover, the 

government has made all Backpage servers in its possession available for defense 

inspection, in accordance with Federal Rule of Criminal Procedure 16(a)(1)(E).7

 

 The government is awaiting receipt of approximately 60 additional servers from 

Amsterdam through the Mutual Legal Assistance Treaty (“MLAT”) process. The 

government has been informed by the former Chief Technology Officer for Backpage that 

the 60 additional servers contain largely duplicate data from the servers currently in the 

government’s possession (and has been made available to defense), as well as Backpage 

payment processing data. (See Exhibit H at 2). These servers are expected to arrive within 

the next month or so and will be available for Defendants’ inspection at an FBI facility.

Also, given the voluminous amount of Backpage server data, the government has agreed 

to provide Defendants with exhibits of any server data it might utilize at trial to assist 

Defendants in focusing their efforts and attention on server data relevant to the case. (See

Exhibit H at 3). This is in addition to the entire marketplace of Backpage ads, images, and 

email data that the government has already extracted and provided Defendants. Based on 

the foregoing, it is indisputable that the government has exceeded its discovery obligations 

in facilitating Defendants’ review of materials in this case.

IV. Initial Expert Disclosures

On March 14, 2019, Defendants filed their notice of expert witnesses. (See CR 

500).

8

 

7 Defendants are scheduled to inspect the Backpage servers located in Pocatello on April 18, 2019. Additionally, Defendants are scheduled to inspect the Backpage servers 

located at FBI Phoenix the week of April 22, 2019. 

8 As indicated in its January 18, 2019 status memorandum, the government filed its notice of expert witnesses on December 14, 2018 – providing Defendants with an overview of the individuals and subjects that it may seek to present evidence of by way of expert testimony. (See CR 422). 

Case 2:18-cr-00422-DJH Document 524 Filed 04/16/19 Page 7 of 12
- 8 -

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

V. Reciprocal Rule 16 Discovery

On March 4, 2019, Defendants provided the government with more than 4,400 

pages of reciprocal discovery. (See Exhibit L). Defendants’ transmittal letter 

accompanying the reciprocal discovery contained a number of inaccuracies regarding 

Backpage server data which the government addressed in its March 7, 2019 letter to 

Defendants. (See Exhibit H). Additionally, Defendants’ assertions in its transmittal letter 

that the government has not complied with the deadlines set forth in the Scheduling Order 

are also misplaced. Discovery provided to Defendants since the government’s initial 

discovery deadline of December 3, 2018 (i.e., the government’s productions on February 

22, 2019, March 14th, 2019, and April 11th, 2019) represent less than zero and thirteen 

thousandths of one percent (0.013) of discovery produced in this case and is certainly in 

line with the government’s representation to the Court at the January 25, 2019 status 

conference that it had already produced over 90 percent of discovery to Defendants in the 

case. (See CR 459 Tr. 1/25/19 at 13 (Judge Logan: “Percentage-wise, how much discovery 

has been given to the defense? How much was given by the 3rd of December of 2018?”)). 

In response, the government indicated that other than documents subject to the 

government’s filter protocol and the server data (which have now been made available to 

Defendants), more than 90 percent of discovery had been provided to Defendants by 

December 3, 2018 (more than 13 months before trial). (See CR 459 Tr. 1/25/19 at 14. (Mr. 

Jones: “To answer your question [your Honor], first, other than these two outstanding areas 

that I’m about to address, [documents subject to filter protocol and server data], more than 

90 percent of the discovery has been given to defendants to date.”)). 

Moreover, as previously indicated, the government has agreed to provide 

Defendants with exhibits of any of these materials it might utilize at trial months prior to 

the commencement of trial. Thus, any contention that the government has somehow 

shirked or failed to comply with its discovery obligations is simply inaccurate.

VI. Preliminary Exhibit and Witness List

On April 1, 2019, more than nine months prior to trial, the government disclosed its 

Case 2:18-cr-00422-DJH Document 524 Filed 04/16/19 Page 8 of 12
- 9 -

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

preliminary witness and exhibit list to Defendants and agreed to periodically provide 

updated and revised preliminary exhibit and witness list to Defendants in the coming 

months. (CR 511). The vast majority of the government’s exhibits are documents 

Defendants disclosed to the Senate Permanent Subcommittee in the fall of 2016, and were 

compelled to re-disclose to the government in September 2017. As a result, Defendants 

have been in possession of most of the government’s trial exhibits for at least the past two 

and a half years.

VII. Pending Motions

The parties await the Court’s ruling on the following motions: (1) Defendants’

Motion for Further Clarification Regarding CR 445 Order Allowing the Government to 

Continue Review of Privileged Communications (CR 452); (2) Defendants’ Motion for 

Designation of 39 Documents Subject to this Court’s Destruction Order to be Preserved as 

Part of the In Camera Record in the Prosecution (CR 453)9

; (3) Defendants’ Motion to 

Dismiss Due to Government Interference with Right to Counsel and Request for Disclosure 

or, in the Alternative Motion to Withdraw (CR 456); Defendants’ Motion for Hearing 

Regarding CR 456 (CR 501); and Defendant Michael Lacey’s Motion to Modify 

Conditions of Release (CR 503).

VIII. Upcoming Deadlines:

A. May 27, 2019 – Defendants’ production of Rule 26.2 material as to intended 

witnesses, if any, is due; 

B. June 17, 2019 – Government’s rebuttal expert disclosures, if any, are due; 

C. July 1, 2019 – Defendants’ disclosure of preliminary exhibit and witness list is 

 

9 The government previously responded to this motion requesting the Court Order Defendants Michael Lacey, James Larkin, Scott Spear, and Andrew Padilla to destroy the 

39 inadvertently-disclosed documents ordered destroyed within 24 hours or be ordered to show cause why they are not in contempt of the Court’s January (CR 449) Order. (CR 466). Defendants Lacey, Larkin, Spear, and Padilla have since filed replies to CR 466 indicating 

that they have destroyed the 39 inadvertently-disclosed documents at issue. (CR 468, 469, 

474, and 475). Therefore, the only outstanding issue pertaining to this motion is whether 

the Court requests the government to file all of the inadvertently-disclosed documents ex 

parte under seal for the in camera record in the case.

Case 2:18-cr-00422-DJH Document 524 Filed 04/16/19 Page 9 of 12
- 10 -

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

due; 

D. July 15, 2019 – Substantive motions filing deadline; Government’s rebuttal 

exhibit and witness list due.

IX. Conclusion

As articulated above, the government has promptly fulfilled its obligations under 

the Scheduling Order. By the January 15, 2020 trial, Defendants will have had access to 

the vast majority of discovery in this case for nearly 20 months, and most of the 

government’s trial exhibits for more than two and a half years. The government’s 

discovery production has been accompanied by detailed indexes denoting the source from 

which the materials were obtained. The government has also assisted Defendants in 

understanding its key evidence by providing subsets of “hot documents” to all Defendants 

more than 18 months before trial, and even went a step further by providing counsel for a 

number of Defendants with subsets of “hot documents” specifically related to the 

allegations in the Superseding Indictment against their respective clients. The government 

has also offered to meet and have met with Defendants to discuss its theory of the case, 

key evidence, and the allegations against the Defendants in great detail. The 90-page 

Superseding Indictment (CR 230) also clearly identified the government’s theory in this 

case and discussed some of the most important pieces of the government’s evidence.

Additionally, the government has extracted all of the Backpage ads contained on 

servers for Defendants and even provided Defendants samples of ads as they appear in the

server data that are referenced in counts in the Superseding Indictment. The government 

has also agreed to provide Defendants with exhibits of any server data it might utilize at 

trial months prior to the commencement of trial. Further, the government provided 

Defendants with a preliminary witness and exhibit list more than nine months before trial 

that it will continue to update and provide to Defendants periodically within the coming 

months. It has also promptly responded to Defendants’ request for assistance and made 

available a DOJ discovery specialist to assist Defendants with any technical issues. 

In sum, the government has expended significant resources with the expectation that 

Case 2:18-cr-00422-DJH Document 524 Filed 04/16/19 Page 10 of 12
- 11 -

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

trial will begin January 15, 2020. The Court set this firm trial date nearly two years postindictment in this case because of the time Defendants asserted they needed to prepare for 

trial. The government’s witnesses (including numerous sex trafficking victims) have 

cleared their schedules to be available for trial to begin on this date. To this end, the 

government will continue to work diligently to comply with the Scheduling Order, and will 

also continue to work with Defendants over the course of the next months leading up to 

trial to facilitate Defendants’ review of materials in this case.

Respectfully submitted this 16th day of April, 2019.

BRIAN BENCZKOWSKI

Assistant Attorney General

Criminal Division, U.S. Department of Justice

s/Reginald E. Jones

REGINALD E. JONES

Senior Trial Attorney

U.S. Department of Justice, Criminal Division

Child Exploitation and Obscenity Section

ELIZABETH A. STRANGE

First Assistant United States Attorney

District of Arizona

KEVIN M. RAPP

MARGARET PERLMETER

PETER S. KOZINETS

ANDREW C. STONE

JOHN J. KUCERA

Assistant U.S. Attorneys

Case 2:18-cr-00422-DJH Document 524 Filed 04/16/19 Page 11 of 12
- 12 -

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

CERTIFICATE OF SERVICE

I hereby certify that on this date, April 16, 2019, I transmitted the foregoing under- seal document for filing to the Clerk of the United States District Court and sent a copy via electronic mail to: Paul J. Cambria Jr. Esq. and Erin e. McCambpell, Esq., Lipsitz Green 

Scime Cambria, LLC, 42 Deleware Ave, Suite 120, Buffalo, NY 14202, 

pcambria@lglaw.com and emccampbell@lglaw.com, Thomas H. Bienert, Jr., Esq., Anthony R. Bisconti, Esq., Kenneth M. Miller, Esq., and Whitney Bernstein, Esq., Bienart, 

Miller & Katzman, PLC, 903 Calle Amanecer, Suite 350, San Clemente, CA 92673, 

tbienert@bmkattorneys.com, tbisconti@bmkattorneys.com, kmiller@bmkattorneys.com, wbernstein@bmkattorneys.com; Mike Piccarreta, Esq., Piccarreta Davis Keenan Fidel, PC, 2 East Congress Street, Suite 1000, Tucson, AZ 85701, 

mlp@pd-law.com; Jim Grant Esq., Davis Wright Termaine, LLP, 1201 Third Avenue, 

Suite 2200, Seattle, WA 98101, jimgrant@dwt.com; Michael D. Kimerer, Esq. and Rhonda Elaine Neff, Esq., 1313 E. Osborn Road, Suite 100, Phoenix, AZ 85014, 

MDK@kimerer.com and rneff@kimerer.com; Steve Weiss Esq., Karp & Weiss, PC, 3060 North Swan Rd., Tucson, AZ 85712, sweiss@karpweiss.com; Robert Corn-Revere 

Esq., Davis Wright Termaine, LLP, 1919 Pennsylvania Avenue N.W., Suite 800, 

Washington, D.C., 20006, bobcornrevere@dwt.com; Bruce Feder, Esq., 2930 East Camelback Road, Suite 160, Phoenix, AZ 85016, bf@federlawpa.com; Gary Linenberg, Esq., Ariel Neuman, Esq., Gopi K. Panchapakesan, Esq., Bird, Marella, Boxer, Wolpert, 

Nessim, Drooks, Lincenberg & Rhow, P.C., 1875 Century Park East, 23rd Floor, Los 

Angeles, CA 90067, glincenberg@birdmarella.com, aan@birdmarella.com, 

gkp@birdmarella.com.

s/ Angela Schuetta

Angela Schuetta

U.S. Attorney’s Office

Case 2:18-cr-00422-DJH Document 524 Filed 04/16/19 Page 12 of 12