EXHIBIT A 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 1 of 38
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 

May 24, 2018 

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) 

KC Maxwell, Esq. 

Law Office of K.C. Maxwell 

235 Montgomery Street, 

Suite 1070 

San Francisco, CA 94104 

(attorney for Dan Hyer) 

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) 

Mike Piccarreta, Esq. 

Piccarreta Davis Keenan Fidel, PC 

2 East Congress Street, 

Suite 1000 

Tucson, AZ 85701 

(attorney for Andrew Padilla) 

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 205 

Phoenix, AZ 85016 

(attorney for Scott Spear) 

Steve Weiss 

Attorney at Law 

Karp & Weiss, PC 

3060 North Swan Rd. 

Tucson, AZ 85712 

(attorney for Joye Vaught) 

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 two hard drives 

containing the government's initial disclosure.' The drive labeled Hard Drive #1 contains the 

following Bates Stamped records: 

1 Hard Drives containing disclosure for defendants Michael Lacey and James Larkin are being provided to Paul J. 

Cambria Jr. and Thomas H. Bienart Jr., respectively. 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 2 of 38
Lacey, et. al. Discovery Letter 1 

May 24,2018 

Page 2 

• USAO 108 Subpoena — D0J-BP-0000000001-D0J-BP-0001037594 

• Permanent Subcommittee Investigation (PSI) — D0J-BP-0001037595-D0J-BP0002102561 

• USAO 359 Subpoena — D0J-BP-0002102562-D0J-BP-0002137199 

• California Department of Justice — D0J-BP-0002137200-D0J-BP-0003851025 

• Carl Ferrer Gmail — D0J-BP-0003851026-D0J-BP-0004425148 

• Additional Co-Star2— D0J-BP-0004425149-D0J-BP-0004425622 

• SW Applications/Affidavits and Sealed GJ Pleadings/Orders — D0J-BP-0004425623-

D0J-BP-0004426152 

• USAO 108 Subpoena (supplemental) — D0J-BP-0004426153-D0J-BP-0004426710 

The drive labeled Hard Drive #2 contains Co-Star Bates Stamped records 17-0040000000001-

17-0040005901038 and 17-0040 MOBILE 000000001-17-0040_MOBILE_000047872. 

Any discovery provided which is not mandated by court order, the Federal Rules of 

Criminal Procedure, federal statute, or federal case law is provided voluntarily solely to expedite 

litigation of this case. Additional Rule 16 discovery within the government's possession will be 

provided to you by the court-imposed compliance deadline of December 3, 2018. The remainder 

of this letter sets forth government requests, and concludes with general discovery expectations. 

A. Defense requests 

Pursuant to Rule 16.1 of the Arizona Local Rules of Criminal Procedure and Rules 12(b)(4) 

and 16(a)(1)(A) & (B) of the Federal Rules of Criminal Procedure, the government gives notice of 

its intent to use at trial the following information: (1) the substance of any relevant oral statements 

made by the defendant before or after arrest in response to interrogation by any person then known 

to the defendant to be a government agent if such statements will be used at trial; (2) any relevant 

written or recorded statements made by the defendant before or after arrest in response to 

interrogation by any person then known to the defendant to be a government agent; (3) any written 

record containing the substance of any relevant oral statement made before or after arrest if the 

defendant made the statement in response to interrogation by a person the defendant knew was a 

government agent; and (4) any recorded testimony by the defendant before a grand jury relating to 

the charged offense. In the event that additional evidence of this nature becomes available, it will 

be provided to you as part of the discovery process. 

In the event that any interview notes subsequently prove to be discoverable, and pursuant 

to U.S. v. Harris, 543 F.2d 1247 (9th Cir. 1976), federal government agents have preserved and 

will continue to preserve any notes of interviews with the defendants in this case. 

The United States does not share the view, nor is it aware of authority to support the 

position, that the Sentencing Guidelines create additional defense discovery privileges. Please be 

advised that the United States will continue to comply with its discovery obligations pursuant to 

2Co-Star records produced to the government without assigned bates numbers. 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 3 of 38
Lacey, et. al. Discovery Letter 1 

May 24,2018 

Page 3 

applicable constitutional requirements, federal discovery rules, and applicable case law, including 

but not limited to Brady v. Maryland, 373 U.S. 83 (1963). 

Pursuant to Rule 16(a)(1)(F) & (G), the government intends to use expert testimony at trial. 

The government will supplement this response by the deadline specified in the scheduling order 

(i.e., December 14, 2018) after the experts have been retained and their reports have been prepared 

and their intended testimony is known. 

Pursuant to Rule 404(b) of the Federal Rules of Evidence, the discovery now being 

provided to you (as well as the discovery materials that will be produced in the future) may relate 

to other acts by the defendant which may be relevant to the actions of the defendant that resulted 

in the criminal charges in this case. This letter serves as notice of the government's intent to use 

this evidence at trial. 

You have also requested notice of all evidence which may be used at trial by the 

government. Pursuant to Rule 12(b)(4)(B) and Rule 16(a)(1)(E), the government may use all 

evidence disclosed at trial. The government reserves the right to supplement the evidence 

disclosed prior to trial. 

B. Government requests 

Please also consider this letter the government's request for reciprocal discovery pursuant 

to Rule 16(b)(1)(A) and (B) of the Federal Rules of Criminal Procedure by the court-imposed 

March 4, 2019 deadline. I am requesting permission to inspect and copy or photograph any books, 

papers, documents, photographs, tangible objects, or copies of portions thereof, which are in your 

possession, custody or control, and which you intend to introduce as evidence in your case-in-chief 

at trial. We also request permission to inspect and copy or photograph any results or reports of 

physical or mental examinations, scientific tests or experiments made in connection with the case, 

or copies thereof, within your possession, custody, or control, which you intend to introduce as 

evidence in your case-in-chief at trial, or which were prepared by a witness whom you intend to 

call at trial. 

Pursuant to Rule 16(b)(1)(C), I am requesting a written summary of any expert testimony 

the defendant intends to use as evidence at trial by the court-imposed March 14, 2019. 

I also wish to respectfully call your attention to Rules 12.1, 12.2, and 12.3 of the Federal 

Rules of Criminal Procedure with respect to the defenses of alibi, mental capacity and public 

authority. Failure to comply with the time limits of those rules may result in a refusal by the court 

to pennit testimony in support of those defenses. 

Pursuant to Rule 12.1(a) of the Federal Rules of Criminal Procedure, the government 

specifically requests that the defendant serve upon the undersigned a written notice of intention to 

offer an alibi defense within ten days of the receipt of this letter. Please include in your response 

each specific place your client claims to have been as well as the names, addresses, and telephone 

numbers of any witnesses upon whom you intend to rely to establish the alibi. The government 

hereby states that the offenses were committed on the dates set forth in the charging document and 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 4 of 38
Lacey, et. al. Discovery Letter 1 

May 24, 2018 

Page 4 

that the offenses were committed at the locations indicated in the charging document and/or 

discovery materials. 

C. General expectations 

To avoid delay during the trial, it is my intention that information, statements, and reports 

discoverable under the Jencks Act and Fed. R. Crim. P. 26.2 which are not provided sooner will 

be produced by the court-imposed February 25, 2019 deadline. In order to avoid delay in the 

defense obligations under Rule 26.2, please provide me with any typed, handwritten or recorded 

statements made by any defense witnesses other than the defendant by the court-imposed May 27, 

2019 deadline.. 

We have no desire to prosecute the wrong person, and would appreciate the opportunity to 

evaluate the necessity of proceeding in light of any information you have indicating that your client 

did not commit the offense or offenses charged. Please communicate this request to your client so 

that, through you, we can receive and consider any such information. 

Finally, the government will comply with, and expects reciprocal compliance with, Fed. R. 

Crim. P. 16(c), which states as follows: 

"A party who discovers additional evidence or material before or during trial must 

promptly disclose its existence to the other party or the court if: (1) the evidence 

or material is subject to discovery or inspection under this rule; and (2) the other 

party previously requested, or the court ordered, its production." 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 5 of 38
Lacey, et. al. Discovery Letter 1 

May 24, 2018 

Page 5 

Thank you for your cooperation. Please call with any questions or concerns. 

Sincerely, 

ELIZABETH A. STRANGE 

First Assistant United States 

Attorney 

s/Kevin M. Rapp 

KEVIN M. RAPP 

MARGARET PERLMETER 

PETER S. KOZINETS 

ANDREW STONE 

Assistant U.S. Attorneys 

JOHN J. KUCERA 

Special Assistant U.S. Attorney 

REGINALD E. JONES 

Senior Trial Attorney, USDOJ 

KMR/sh 

Enclosures 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 6 of 38
EXHIBIT 13 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 7 of 38
i: DavisWright 

Tremaine LLP 

Suite 2200 

1201 Third Avenue 

Seattle, WA 98101-3045 

James Grant 

206-757-8096 tel 

206-757-7096 fax 

jimgrant@dwt.com 

VIA EMAIL & HAND DELIVERY 

September 15, 2017 

Dominic Lanza 

Kevin M. Rapp 

Office of the United States Attorney 

District of Arizona 

40 North Central Ave., Suite 1200 

Phoenix, AZ 85004-4408 

DLanza@usa.doj.gov 

Kevin.Rapp@usdoj.gov 

Reginald E. Jones 

United States Department of Justice 

1400 New York Ave., N.W. 

Washington, DC 20530 

Reginald.Jones4@usdoj.gov 

Re: Production in Response to Grand Jury Subpoena No. 16-04-108 

Dear Counsel: 

I write in response to your email of September 7 inquiring about production of materials in 

response to Grand Jury Subpoena No. 16-04-108 in light of the issuance of the Ninth 

Circuit's mandate. From DOJ's representations to the Ninth Circuit, we understand that you 

already have the materials covered by the subpoena, but we are producing them again with 

the hard copy version of this letter. We are also providing privilege logs. Please note that 

among the privileged documents that have been identified but not produced are ones that 

were inadvertently produced previously (and were identified) to the U.S. Senate Permanent 

Subcommittee on Investigations. 

We are also providing a sheet providing instructions and passwords for accessing the 

documents on the hard drive. 

Will you please send me a note acknowledging your receipt of the hard drive. Further, I 

suggest we provide a joint statement to the District Court that Backpage and Mr. Ferrer have 

complied with the Court's April 7 order. If you are agreeable, I will send a draft. 

Anchorage New York Seattle 

Bellevue Portland Shanghai 

Los Angeles San Francisco Washington, D.C. x wpm dwt.corn 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 8 of 38
/9--7 

7=7 

James C. Grant 

Messrs. Lanza, Rapp and Jones 

September 15, 2017 

Page 2 

Sincerely, 

DAVIS WRIGHT TREMAINE LLP 

Enclosure (w/ hardcopy version of letter) 

cc: Tom Henze 

Janey Henze Cook 

(w/o encl.) 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 9 of 38
EXHIBIT C 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 10 of 38
From: Jones, Reginald (CRM) 

To: Paul Cambria; Rapp, Kevin (USAAZ) 

Cc: Erin E. McCampbell 

Subject: RE: Discovery updates 

Date: Tuesday, August 14, 2018 12:38:00 PM 

Attachments: 17-0040 005368175.pdf 

17-0040 000002818.pdf 

17-0040 000337834. oclf 

17-0040 005364265. oclf 

17-0040 005369208.pdf 

17-0040 005368419.pdf 

17-0040 005366927.pdf 

17-0040 000043883.pdf 

17-0040 005366836.pdf 

17-0040 001529836.pdf 

17-0040 000002819.pdf 

imaoe001.pnq 

Paul: 

On July 19, the government disclosed more than 1,070 pages of documents it believes support the 

allegations contained in the indictment. See Bates Stamped Records D0J-BP-0004601039-D0J-BP0004602110. This production included, to our knowledge, all of the emails and other internal 

Backpage documents that are referenced in the indictment. It's therefore surprising to hear you 

contend that "[a]lthough [it] included a few of the emails referenced in the indictment, it did not 

include many of the documents, including copies of the ads." Other than victim ads (which are 

addressed in more detail below), we believe the July 19 disclosure was quite comprehensive. 

Furthermore, we intend to disclose the additional documents we believe support the new 

allegations contained in the superseding indictment within the next few weeks. 

We also intend to provide victim-related materials (including the ads discussed in Counts 2-51). 

Although we hope to include this material in our next wave of disclosure, the privacy-redaction 

process is time-consuming. 

With respect to the Backnage.comserver data, we are still trying to address some technical issues 

and hope to make it available to the defense in the near future. That said, it is massive in volume, so 

it may make sense for your technical folks to speak directly with our technical folks to ensure that 

everybody is on the same page. 

Finally, with respect to CoStar materials, enclosed with this email are some individual documents 

that we believe are relevant and might be utilized at trial. We will continue, in the coming months, 

to identify additional CoStar documents that are relevant, although we don't anticipate that the 

number of documents so identified will be voluminous. 

Reginald E. Jones 

U.S. Department of Justice, Criminal Division 

T: 202.616.2807 I reginald.jones4Pusdoj.gov 

From: Kristina Drewery [mailto:kdrewery@Iglaw.com] On Behalf Of Paul Cambria 

Sent: Wednesday, August 8, 2018 9:22 AM 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 11 of 38
To: Jones, Reginald (CRM) <Reginaldiones@CRM.USDOIGOV>; Rapp, Kevin (USAAZ) 

<Kevin.Rapp@usdoj.gov> 

Cc: Erin E. McCampbell <emccampbell@Iglaw.com> 

Subject: Discovery updates 

Kevin and Reggie: 

When we conferred on July 3 about the government's production of documents to the 

defendants, you said you would be producing to us, in short order, copies of all the documents 

referenced in the indictment, including copies of ads, emails, and the like. Although your 

subsequent "hot docs" production included a few of the emails referenced in the indictment, 

it did not include many of the documents, including copies of the ads. When can we expect to 

see the remainder of the documents referenced in the indictment (and now superseding 

indictment)? 

Also, at the end of that same call we discussed the status of the Backpage.comwebsite and 

related databases, and our need to access data from the website/databases. You said you 

would inquire of your technical folks about the status of the Backpage.com 

website/databases. We've not heard back from you on that point either. 

Finally, you also said you would disclose individual documents from the "CoStar" production 

that you viewed as relevant to the indictment. Your "hot docs" production included a few 

emails mentioning Avion. Are those emails the universe of documents from the "CoStar" 

production that you view as relevant to the indictment? Or do you expect to produce 

additional documents (and, if so, when)? 

Lipsitz Green 

Scime Cambria_ 

Kristina Drewery 

Legal Assistant to Paul J. Cambria, Jr. 

42 Delaware Ave I Suite 120 I Buffalo, NY 14202 

TEL 716 849 1333 x346 I FAX 716 855 1580 

email I website I map 

NOTICE: This message contains privileged and confidential information intended only for the use of the persons named 

above. If you are not the intended recipient, you are hereby notified that any distribution or copying of this message is 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 12 of 38
prohibited. 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 13 of 38
EXHIBIT D 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 14 of 38
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 

July 19, 2018 

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) 

KC Maxwell, Esq. 

Maxwell Law PC 

899 Ellis Street 

San Francisco, CA 94104 

(attorney for Dan Hyer) 

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) 

Mike Piccarreta, Esq. 

Piccarreta Davis Keenan Fidel, PC 

2 East Congress Street, 

Suite 1000 

Tucson, AZ 85701 

(attorney for Andrew Padilla) 

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) 

Steve Weiss 

Attorney at Law 

Karp & Weiss, PC 

3060 North Swan Rd. 

Tucson, AZ 85712 

(attorney for Joye Vaught) 

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

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

Dear Counsel: 

Pursuant to the government's agreement to disclose documents it believes support the 

allegations contained in the indictment, please find enclosed a DVD containing the following Bates 

Stamped records: 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 15 of 38
Lacey, et. al. 

July 19, 2018 

Page 2 

• "Hot Does" — D0J-BP-0004601039-D0J-BP-00046021101 

This disclosure is without prejudice and will be supplemented throughout the case. 

Please let us know if you have any questions or concerns. 

Sincerely, 

ELIZABETH A. STRANGE 

First Assistant United States 

Attorney 

s/Reginald E. Jones 

REGINALD E. JONES 

Senior Trial Attorney, USDOJ 

KEVIN M. RAPP 

MARGARET PERLMETER 

PETER S. KOZINETS 

ANDREW STONE 

Assistant U.S. Attorneys 

JOHN J. KUCERA 

Special Assistant U.S. Attorney 

Enclosures 

1 A DVD containing disclosure for defendants Michael Lacey and James Larkin are being provided to Paul J. 

Cambria Jr. and Thomas H. Bienart Jr., respectively. 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 16 of 38
EXHIBIT E 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 17 of 38
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 

September 24, 2018 

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 

23°' Floor 

Los Angeles, CA 90067 

(attorney for Jed Bruns° 

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 a thumb drive 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 18 of 38
Lacey, et. al. Discovery Letter 1 

September 24, 2018 

Page 2 

containing the government's fourth disclosure.1The thumb drive contains the following Bates 

Stamped records: 

• Backpage Agendas — D0J-BP-0004602111-D0J-BP-0004602507 

• Backpage Superseding Indictment "Hot Does" — D0J-BP-0004602508-D0J-BP0004602851 

• Co-Star "Hot Does" — D0J-BP-0004602852-D0J-BP-0004602926 

• Financial Records — D0J-BP-0004602927-D0J-BP-0004683544 

Please call with any questions or concerns. 

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 

regina1d.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 

Enclosures 

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 Michael Kimerer respectively. 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 19 of 38
EXHIBIT F 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 20 of 38
From: Lanza Dominic (USAAZI 

To: Michael Piccarreta 

Cc: Rano, Kevin (USAAZ); 3ones, Reginald (CRM); Perimeter, Margaret (USAAZ1 

Subject: RE: Andrew Padilla 

Date: Thursday, December 21, 2017 4:59:41 PM 

Attachments: Padilla Docs.ocif 

Hi, Mike: 

Nice speaking with you today. Here are some of the case citations I mentioned, which involve 

prosecutions under 18 USC 1952 (Travel Act) and 18 USC 1956/1957 (money laundering) of folks 

who were helping facilitate escort businesses or strip clubs that were fronts for prostitution: 

• United States v. Nader, 542 F.3d 713 (9th Cir. 2008) (affirming Travel Act convictions of 

the owner and operator of a massage studio that operated as a front for prostitution). 

• United States v. Vitich, 357 F. Supp. 102 (W.D. Wisc. 1973) (sustaining Travel Act charges 

against the operators of a laundry service who supplied sheets, towels, and linens to 

prostitutes who were operating out of a casino hotel—the provision of laundry services was 

enough to "facilitate" a state-law prostitution offense). 

• United States v. Hurant, 2017 WL 3475052 (E.D.N.Y. 2017) (founder of MyRentBoy.com 

pleaded guilty to 1952 charges) 

• United States v. Omuro N.D. Cal. No. CR 14-CR-336-WHO (founder of MyRedbook.com 

pleaded guilty to 1952 charges). 

• United States v. Sigalow, 812 F.2d 783 (2d Cir. 1987) (affirming Travel Act conviction of the 

manager of a massage parlor thIat acted as a front for prostitution and holding that the 

company's publication of advertisements in The Village Voice helped supply the requisite 

interstate link) 

• United States v. Fedele, 2014 WL 3847402 (W.D. Ark. 2014) ("[T]he Government did not 

have to prove that the Defendant persuaded, induced, enticed, or coerced the escorts to 

have sexual relations with clients; rather, the Government only had to prove that Defendant 

knew the escorts were engaging in acts of prostitution and that Defendant used a facility of 

interstate commerce to facilitate the carrying on of this activity."). 

• United States v. Baker, 227 F.3d 955 (7th Cir. 2000) (holding that all of the ATM 

transactions and bank transactions of a massage parlor that was a front for prostitution can 

be charged as promotional money laundering: "It is not necessary, as Baker contends, for 

the government to separate out income from bona fide massages (whatever those were) 

from income from sexual services."). 

Also, I've enclosed some of documents that we discussed during the meeting. This email includes all 

of the .pdf files that we discussed, which I've combined into a single file. In a few moments, I'll be 

sending a separate email containing all of the Word docs, Excel sheets, and Powerpoint 

presentations that we discussed. (Space limitations prevent me from including everything in a single 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 21 of 38
1111111111111111111111111111111111111111111111._ 

email.) 

Please let me know if you need anything else. Otherwise, happy holidays and hope to hear from you 

in January. 

-Dom 

From:' Michael Piccarreta [mailto:m1p@pd-law.cornj 

Sent: Monday, December 18, 2017 3:33 PM 

To: Lanza, Dominic ((JSAAZ) <DLanza@usa.doj.gov>; Rapp, Kevin (USAAZ) <KRapp@usa.doj.gov> 

Subject: RE: Andrew Padilla 

We are on for Thursday 9 am at your office. mlp 

Michael L. Piccarreta, Esq. 

Piccarreta Davis Keenan Fidel PC I 2 East Congress Street, Suite 1000, Tucson, AZ 85701 

t 520.622.6900, ext. 133 If 520-622-0521 I www pd-law,com 

From: Lanza, Dominic (USAAZ) [mailto:Dominic.Lanzausdoj.gov] 

Sent: Wednesday, December 13, 2017 10:43 AM 

To: Michael Piccarreta; Rapp, Kevin (USAAZ) 

Subject: RE: Andrew Padilla 

Yes, that works. Thanks. 602-514-7651. 

From: Michael Piccarreta [mailto:mlpftpd-law.corn] 

Sent: Wednesday, December 13, 2017 10:18 AM 

To: Lanza, Dominic (USAAZ) <DLanzaPusa.cloj.gov>; Rapp, Kevin (USAAZ) <KRappPusa.doj.gov> 

Subject: RE: Andrew Padilla, 

I will call you tomorrow after lunch 2pmish. Does that wok for you? mlp 

• Michael L. Piccarreta, Esq. 

Piccarreta Davis Keenan Fidel PC I 2 East Congress Street, Suite 1000, Tucson, AZ 85701 

t 520.622.6900, ext. 133 If 520-622-0521 I www.pd-law.com 

From: Lanza, Dominic (USAAZ) [mailto:Dominiclanza(ausdoj.gov] 

Sent: Wednesday, December 13, 2017 9:35 AM 

To: Rapp; Kevin (USAAZ); Michael Piccarreta 

Subject: RE: Andrew Padilla 

Hi, Mike: 

Just wanted to follow up on this. I'm pretty free this afternoon (other than 2:30 — 3:30) or tomorrow 

afternoon if you have a few minutes. 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 22 of 38
From: Rapp, Kevin (USAAZ) 

Sent: Wednesday, December 06, 2017 4:29 PM 

To: Michael Piccarreta <mIpPpd-law.com> 

Cc: Lanza, Dominic (USAAZ) <DLanzaPusa.doj.gov> 

Subject: Re: Andrew Padilla 

Yes, no problem. We are around next week. 

Sent from my iPhone 

On Dec 6, 2017, at 407 PM, Michael Piccarreta <mlpPpd-law.com> wrote: 

Is next Week ok? I am wrapping up a trial but should be back in the office next week. 

Mlp 

Sent from my iPad 

On Dec 4, 2017, at 10:42 AM, Rapp, Kevin (USAAZ) <Kevin.RappPusdoj.gov> wrote: 

Mike: 

We received your letter last week. Let us know if you have a time for a call 

this week. Thanks. 

Kevin M. Rapp l Assistant U.S. Attorney 

Senior Litigation Counsel 

Financial Crimes and Public Integrity Section 

U.S. Department of Justice I Office of the United States Attorney 

40 N. Central Ave., Ste. 1200, Phoenix, AZ 85004 

602.514.7609, kevin.rapp@usdoj.gov 

Kevin M. Rapp Assistant U.S. Attorney 

Senior Litigation Counsel 

Financial Crimes and Public Integrity Section 

U.S. Department of Justice I Office of the United States Attorney 

40 N. Central Ave., Ste. 1200, Phoenix, AZ 85004 

602.514.7609, kevin.rapp@usdoj.gov 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 23 of 38
EXHIBIT G 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 24 of 38
From: 

To: 

Cc: 

Subject: 

Date: 

Bruce Feder 

Jones, Reginald (CRM) 

Ram Kevin (USAAZ); Feder Law 

Re: Indictment-related documents specific to Spear - email 1 

Monday, August 27, 2018 2:25:29 PM 

Reggie, 

I received the emails. On 9/6, I'm available anytime in the afternoon. 

Bruce Feder 

2930 East Came!back Road, Suite 160 

Phoenix, Arizona 85016 

(602) 257-0135 

bf@federlawpa.com 

Confidentiality Notice 

This email or fax, including attachments, is covered by the Electronic Communications Privacy Act, 18 U.S.C. 1510 et seq. The information 

contained in this electronic mail or fax transmission, including any accompanying attachment, is intended solely for its authorized 

recipient, and may be confidential and/or legally privileged. If you are not an intended recipient, or responsible for delivering some or all 

of this transmission to an intended recipient, you have received this transmission in error and are hereby notified that you are strictly 

prohibited from reading, copying, printing, distributing, or disclosing any of the information contained in it. In that event, please contact 

me immediately by telephone at (602) 257-0135 or by electronic email at bf@federlawpa.comand delete the original and all copies of 

this transmission, including any attachments, without reading or saving them in any manner. 

From: Jones, Reginald (CRM) <Reginald.Jones4@usdoj.gov> 

Sent: Sunday, August 26, 2018 6:14 PM 

To: Bruce Feder 

Cc: Rapp, Kevin (USAAZ) 

Subject: Indictment-related documents specific to Spear - email 1 

Bruce, 

As a follow up to your request for indictment specific documents related to Spear, please find 

attached more than 50 hot docs specifically relating to Spear. I'll send the attachments in 

several emails. Please confirm that you have received all emails and attachments. 

Additionally, I know we had originally set Tuesday at 1:30pm PT/4:30 ET to discuss these 

documents and your client's exposure, but I recently learned that I'll be out of the office most 

of this week. Could we please move our call to Thursday September 6th? I'm available 

anytime that day so let me know what time works best for your schedule. 

Thanks, 

Reggie 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 25 of 38
Reginald E. Jones 

U.S. Department of Justice, Criminal Division 

T: 202.616.2807 I reginaldjones4Pusdoj.gov 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 26 of 38
EXHIBIT H 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 27 of 38
From: Jones, Reginald (CRM) 

To: Michael Kimerer 

Cc: Rapp, Kevin (USAAZ); glincenbeitabirdmarella.com; Ariel A. Neuman (aneumanebirdmarella.com); 

gpanchapakesan(abirdmarella.com 

Subject: RE: Jed Brunst-tot documents" - EMAIL 1 

Date: Wednesday, October 3, 2018 10:15:00 AM 

Attachments: Brunst - website technology.pdf 

Brunst - signature card.pdf 

Brunst - Cereus properties.pdf 

I, paragraph 141 part 2.pdf 

I, Paragraph 142.pdf 

paragraph 119 part 2.pdf 

SSI, Paragraph 57 attachment.xlsx 

A few additional "hot docs" pertaining to Brunst attached. 

From: Michael Kimerer [mailto:mdk@kimerer.com] 

Sent: Tuesday, October 2, 2018 3:25 PM 

To: Jones, Reginald (CRM) <Reginaldiones@CRM.USDOIGOV> 

Cc: Rapp, Kevin (USAAZ) <Kevin.Rapp@usdotgov>; glincenberg@birdmarella.com; Ariel A. Neuman 

(aneuman@birdmarella.com) <aneuman@birdmarella.com>; gpanchapakesan@birdmarella.com 

Subject: RE: Jed Brunst-"hot documents" - EMAIL 1 

ReggieThank you for responding so quickly to my request for the "Hot Docs" that relate to our client Jed 

Brunst. I have forwarded them to Gary Lincenberg's firm who are also counsel of record for Jed. It 

would be helpful if you could include those attorneys in any future communications. Their email 

addresses are above. 

When we've had a chance to review the "hot docs" we may well have some questions for you. 

Thanks again. 

BestMike 

Michael D. Kimerer, Esq. 

KIMERER & DERRICK, P.C. 

THE BEST IN CRIMINAL DEFENSE 

Telephone: (602) 279.5900 

Email: mdk@kimerer.com 

1313 E. Osborn Road, Phoenix, AZ 85014 

wwvv.kimerer.com 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 28 of 38
From: Jones, Reginald (CRM) 

To: Michael Kimerer 

Cc: Rapp, Kevin (USAAZ) 

Subject: RE: Jed Brunst-"hot documents" - EMAIL 1 

Date: Tuesday, October 2, 2018 10:36:00 AM 

Attachments: I, Paragraph 26.pdf 

I. Paragraph 28-30.pdf 

I, Paragraph 97.pdf 

I, Paragraph 100.pdf 

I, Paragraph 117 part 1.pdf 

I, Paragraph 117 part 2.pdf 

I, Paragraph 119.pdf 

I Paragraph 140.pdf 

I, Paragraph 141, part 1.pdf 

I, Paragraph 143.pdf 

Mike, 

Per your request, we have segregated approximately 35 "hot docs" that pertain to the allegations 

against Brunst. I will send these documents to you in several emails. 

Once you have reviewed these documents, let us know if you would like to schedule a call to discuss 

the significance of these documents and the allegations against Mr. Brunst in further detail. 

Best, 

Reggie 

Reginald E. Jones 

U.S. Department of Justice, Criminal Division 

T: 202.616.2807 I reginaldjones4Pusdoj.gov 

From: Rapp, Kevin (USAAZ) [mailto:Kevin.Rapp@usdoj.gov] 

Sent: Monday, October 1, 2018 5:32 PM 

To: Michael Kimerer <mdk@kimerer.com> 

Cc: Jones, Reginald (CRM) <Reginaldiones@CRM.USDOIGOV> 

Subject: RE: Jed Brunst-"hot documents" 

Mike, 

Reggie advises that we should have the hot docs to you by Wednesday. Thanks. 

Kevin 

From: Michael Kimerer <mdkPkimerer.com> 

Sent: Monday, September 24, 2018 2:11 PM 

To: Rapp, Kevin (USAAZ) <KRappP usa.dotgov> 

Cc: Gary S. Lincenberg <glincenbery@birdmarella.com>; Ariel A. Neuman 

(aneumanPbirdmarella.com) <aneumanl@birdmarella.com>; gpanchapakesanPbirdmarella.com; 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 29 of 38
Jones, Reginald (CRM) <Reginaldiones4Pusdoj.gov>; Kozinets, Peter (USAAZ) 

<PKozinetsPusa.doj.gov>; Stone, Andrew (USAAZ) <AStonelPusa.doj.gov> 

Subject: RE: Jed Brunst-"hot documents" 

KevinIt would be great and much appreciated if you could segregate the "hot documents" relating to Jed 

and get them to us next week. 

Mike 

Michael D. Kimerer, Esq. 

An*KIMERER & DERRICK, P.C. 

THE BEST IN CRIMINAL DEFENSE 

Telephone: (602) 279.5900 

Email: mdk@kimerer.com 

1313 E. Osborn Road, Phoenix, AZ 85014 

www.kimerer.com 

From: Rapp, Kevin (USAAZ) [mailto:Kevin.Rapp(ausdoj.gov] 

Sent: Monday, September 24, 2018 2:02 PM 

To: Michael Kimerer 

Cc: Gary S. Lincenberg; Ariel A. Neuman (aneumanbirdmarella.com); 

gpanchapakesanbirdmarella.com; Jones, Reginald (CRM); Kozinets, Peter (USAAZ); Stone, Andrew 

(USAAZ) 

Subject: RE: Jed Brunst-"hot documents" 

Mike, 

The "hot docs" are documents related specifically to the allegations contained in the superseding 

indictment. These docs are going out day. They are not segregated by defendant but we could 

segregate them for Brunst and send them next week if you would like. We are always willing to 

discuss the significance of the documents. Just let us know. 

Best, 

Kevin M. Rapp' Assistant U.S. Attorney 

Senior Litigation Counsel 

Financial Crimes and Public Integrity Section 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 30 of 38
U.S. Department of Justice I Office of the United States Attorney 

40 N. Central Ave., Ste. 1800, Phoenix, AZ 85004 

602.514.7609, kevin.rapp(&usdoj.gov 

From: Michael Kimerer <mdkPkimerer.com> 

Sent: Monday, September 24, 2018 1:41 PM 

To: Rapp, Kevin (USAAZ) <KRappPusa.doLgov> 

Cc: Gary S. Lincenberg <glincenbergPbirdmarella.com>; Ariel A. Neuman 

(aneumanPbirdmarella.com) <aneuman@birdmarella.com>; gpanchapakesanPbirdmarella.com 

Subject: RE: Jed Brunst-"hot documents" 

KevinThanks for getting back to me about the "hot documents" pertaining to Jed Brunst. Will the "hot 

documents" that we will be receiving regarding Jed's allegations be segregated as to him or included 

with a "generic" group of "hot documents" for all defendants? It would be helpful if you could 

segregate them. Also we've all been talking about "hot documents", but I'm not sure exactly what 

that means. Other than testimony, are these the documents that provide the most incriminating 

evidence against each defendant? 

After we have had a chance to review all the "hot documents" pertaining to Jed, we may want to 

accept your invitation to sit down and discuss them. 

Best regardsMike 

Michael D. Kimerer, Esq. 

"41mth' KIMERER EL DERRICK, RC. 

THE BEST IN CRIMINAL DEFENSE 

Telephone: (602) 279.5900 

Email: mdk@kimerer.com 

1313 E. Osborn Road, Phoenix, AZ 85014 

www.kimerer.com 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 31 of 38
From: Rapp, Kevin (USAAZ) [m a i Ito : Kevin. Ra pp(a usd oj goy] 

Sent: Wednesday, September 19, 2018 3:54 PM 

To: Michael Kimerer 

Subject: RE: Jed Brunst-"hot documents" 

Mike, 

You should be receiving hot docs through discovery this week or next. After you have an 

opportunity to review let me know if you want to discuss. 

Best, 

Kevin M. Rapp' Assistant U.S. Attorney 

Senior Litigation Counsel 

Financial Crimes and Public Integrity Section 

U.S. Department of Justice I Office of the United States Attorney 

40 N. Central Ave., Ste. 1800, Phoenix, AZ 85004 

602.514.7609, kevin.rapp@usdoj.gov 

From: Michael Kimerer <mdk@kimerer.com> 

Sent: Thursday, September 13, 2018 1:27 PM 

To: Rapp, Kevin (USAAZ) <KRappPusa.doj.gov> 

Subject: Jed Brunst-"hot documents" 

KevinSeveral weeks ago, before the Superseding Indictment was filed, you shared with me some of the 

"hot documents" that pertained to the allegations against Jed Brunst. You indicated there may be 

others but gave me what was readily available. Would you check and see if there are any other "hot 

documents" pertaining to Jed and share copies with me so we have a complete set of what you think 

are the "hot documents" that support the Brunst allegations. 

Hope all is well. 

Mike 

Michael D. Kimerer, Esq. 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 32 of 38
EXHIBIT I 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 33 of 38
Jones, Reginald (CRM) 

From: Jones, Reginald (CRM) 

Sent: Wednesday, January 9, 2019 3:17 PM 

To: 'sweiss@karpweiss.com'; 'cmcgarvey@karpweiss.com'; 'vvitolo@karpweiss.com' 

Cc: Rapp, Kevin (USAAZ) 

Subject: Joyce Vaught - "hot docs" 

Attachments: SSI, paragraph 139.pdf; SSI, paragraph 145.pdf; SSI, paragraph 148.pdf; SSI, paragraph 

149.pdf; SSI, paragraph 157, part 1.pdf; SSI, paragraph 157, part 2.pdf; SSI, paragraph 

185.pdf; SSI, paragraph 129.pdf; SSI, paragraph 133.pdf; SSI, paragraph 137.pdf 

Good afternoon, Steve: 

As you are aware, we have provided defense counsel with "hot docs" related to allegations contained in the indictment 

and superseding indictment in this case. We also want to provide you with approximately 25 "hot docs" that pertain 

specifically to the allegations against Defendant Joye Vaught. I will send these documents to you in several emails. 

When you have reviewed these documents, let us know if you would like to schedule a call to discuss their significance 

and the allegations against Vaught in detail. 

Best, 

Reggie 

Reginald E. Jones 

U.S. Department of Justice, Criminal Division 

T: 202.616.2807 J reginald.iones4@usdoi.gov 

1 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 34 of 38
EXHIBIT J 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 35 of 38
U.S. Department of Justice 

United States Attorney 

District of Arizona 

The Two Renaissance Square Main: (602) 514-7500 

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

Phoenix, AZ 85004-4408 

December 10, 2018 

Paul J. Cambria Jr. 

Attorney at Law 

Lipsitz Green Scime Cambria 

42 Delaware Ave Suite 120 

Buffalo, NY 14202 

(attorney for Michael Lacey) 

Thomas H. Bienart, Jr., Esq. 

Beinart, Miller & Katzman, 

PLC 

903 Calle Amanecer, Suite 350 

San Clemente, CA 92673 

(attorney for James Larkin) 

Gary Lincenberg,Esq. 

Arid l A. Neuman, Esq. 

Bird, MareIla, Boxer, Wolpert, 

Nessim, Drooks, Lincenberg & 

Rhow, P.C. 

1875 Century Park East, 23rd 

Floor 

Los Angeles, California 

90067-2561 

(attorney for Jed Brunst) 

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 

Phoenix, AZ 85014 

(attorney for Jed Brunst) 

Mike Piccarreta, Esq. 

Piccarreta Davis Keenan Fidel PC 

2 East Congress Street, Suite 1000 

Tucson, AZ 85701 

(attorney for Andrew Padilla) 

Robert Corn-Revere 

Davis Wright Tremaine LLP 

1919 Pennsylvania Avenue NW, 

Suite 800 

Washington, DC 20006 

(attorney for Lacey and Larkin) 

Bruce Feder, Esq. 

2930 East Camelback Road, Suite 

160 

Phoenix, Arizona 85016 

(attorney for Scott Spear) 

Steve Weiss 

Attorney at Law 

Karp & Weiss, P.C. 

3060 North Swan Rd. 

Tucson, Arizona 85712 

(attorney for Joye Vaught) 

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

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

Dear Counsel: 

This letter is meant to address the content on a number of servers that were seized and how 

we intend to comply with our Rule 16 obligations. As background, the United States seized 32 

servers and three hard drives located in Tucson at an Internet service provider known as Desert 

Net. Desert Net was the primary domestic (Internet) host for Backpage. The servers have varying 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 36 of 38
December 10, 2018 

Page 2 

amounts of storage: some have 14.4 Terabyte (TB), another 7.2 TB, others 19.2 TB while others 

have 120 TB of storage. We have not gone through every server to determine the capacity. In the 

last subpoena we wrote, we estimated the capacity at approximately 500 TB or 1/2 petabyte (PB). 

Five additional servers were seized from Dallas, TX; one from Backpage Headquarters, and four 

additional servers from a datacenter in Dallas. Investigating agents also located 40 servers at a 

datacenter in Amsterdam, the Netherlands. Agents took possession of nine of the 40 servers in 

Amsterdam pursuant to an MLAT request and brought those servers to the Pocatello FBI office 

for examination. To date, two of the servers seized from the Tucson, AZ datacenter have been 

imaged, and the examination is ongoing. Also, four of the servers from the Amsterdam datacenter 

have been imaged. 

All seized servers are being prioritized to be added to the queue to be imaged and prepared 

for review. One of the domestic servers contain literally millions of images that were uploaded 

for postings. The second server has over 100 separate databases which were used by Backpage to 

house, organize, and store data for the Backpage websites. The server's databases were named 

based on geographic regions. Some databases correlate with airport codes and others are a threeletter code that represent a yet undetermined geographic region. From this server we have access 

to the raw database files and are working to reconstruct the .ibd and .frm database files. These 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. Investigators were informed by the DesertNet 

administrators that the 31 servers remaining in Amsterdam did not contain pertinent data, but were 

utilized for frontend websites associated with Backpage. Once all servers are imaged, 

investigators will be able to provide hash verified image copies of all imaged drives. Due to the 

capacity of the Backpage servers this will be a time intensive undertaking and the imaged copies 

will be distributed over hundreds of hard disk drives. 

In the final analysis, these servers contain millions of postings, both domestic and 

international, that are typical of the ads that are referenced in the PSI report, the Superseding 

Indictment, and provided discovery. As you know, the international postings contain considerably 

more explicit text and photos indicative of prostitution because they were not subject to moderation 

and in some of the countries, unlike the United States, prostitution is legal. A random sampling 

demonstrates that the domestic postings are typical of all too familiar ads that contain coded text 

and photos indicative of prostitution. It is unclear how a review of each posting would lend itself 

to the stated defense that they are protected by the First Amendment. In any event, we intend to 

provide defendants a single copy of the hard drives for review. If you disagree with this process 

please advise so that we may promptly raise this issue with the Court. 

Case 2:18-cr-00422-DJH Document 444-1 Filed 01/18/19 Page 37 of 38
December 10, 2018 

Page 3 

BRIAN BENCZKOWSKI 

Assistant Attorney General 

Criminal Division 

U.S. Department of Justice 

REGINALD E. JONES 

Senior Trial Attorney, CEOS 

(202) 616-2807 

regina ld ones4@usdoj gov 

ELIZABETH A. STRANGE 

First Assistant U.S. Attorney 

s/ Kevin M. Rapp 

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 444-1 Filed 01/18/19 Page 38 of 38