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NICOLA T. HANNA

United States Attorney

BRANDON D. FOX

Assistant United States Attorney

Chief, Criminal Division

STEVEN R. WELK (Cal. State Bar No. 149886)

Assistant United States Attorney

Chief, Asset Forfeiture Section

JOHN J. KUCERA (Cal. Bar No. 274184)

DAN G. BOYLE (Cal. Bar No. Pending)

Assistant United States Attorneys

Asset Forfeiture Section

1400 United States Courthouse

312 North Spring Street

Los Angeles, California 90012

Telephone: (213) 894-3391/2426

Facsimile: (213) 894-0142

E-mail: John.Kucera@usdoj.gov

Daniel.Boyle2@usdoj.gov

Attorneys for Plaintiff

UNITED STATES OF AMERICA

UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

WESTERN DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.

$1,546,076.35 IN BANK FUNDS SEIZED 

FROM REPUBLIC BANK OF ARIZONA 

ACCOUNT ‘1889, ET AL.,

Defendants.

Lead Case No. CV 18-8420 RGK 

(PJWx)

FIRST AMENDED CONSOLIDATED MASTER 

VERIFIED COMPLAINT FOR FORFEITURE

18 U.S.C. §§ 981(a)(1)(A) & (C) 

[U.S.P.I.S.]

//

//

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PERSONS AND ENTITIES ............................................... 6

A. Defendants ............................................... 6

NATURE OF THE ACTION AND CLAIMS FOR RELIEF ........................ 23

JURISDICTION AND VENUE ............................................ 24

II. The Formation and Evolution of Backpage ...................... 27

III. The Sources and Manipulation of Backpage Criminal Proceeds ... 29

A. Backpage Promotion of Prostitution and Sex Trafficking .. 29

B. Payments for Advertising on Backpage .................... 38

C. Bank Accounts Funded with Proceeds Traceable to SUA, 

Involved in Money Laundering, or Both ................... 43

D. Bases for Forfeiture .................................... 45

IV. Assets Representing, Traceable To, and Involved In 

Specified Unlawful Activity .................................. 46

A. Account 1 (Prosperity ‘7188 Funds) ...................... 46

CEREUS PROPERTIES ASSETS .......................................... 47

B. Account 2 (Compass ‘3873 Funds) ......................... 47

C. Account 3 (Compass ‘4862 Funds) ......................... 48

MICHAEL LACEY ASSETS .............................................. 49

D. Account 4 (FFS&L of SR ‘3620 Funds) ..................... 49

E. Accounts 5-10 (RBA ‘2485, ‘1897, ‘3126, ‘8316, ‘8324, 

and ‘8332) .............................................. 49

F. Account 11 (SFFCU ‘4S10 Funds) .......................... 50

G. Account 12 (IOLTA ‘4139) ................................ 50

H. The Sebastopol Property ................................. 51

I. San Francisco, California Property 1 .................... 52

J. San Francisco Property 2 ................................ 52

K. San Francisco Property 3 ................................ 53

L. Sedona Property ......................................... 54

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M. Paradise Valley Property 2 .............................. 54

JAMES LARKIN ASSETS ............................................... 55

N. Accounts 13, 16, 17, AND 18 (RBA ‘1889, ‘2592, ‘8103, 

‘8162, AND ‘8189) ....................................... 55

O. Accounts 19 AND 20 (PCTC ACCOUNT ‘0012 FUNDS, PERKINS 

COIE ‘0012) ............................................. 56

P. Account 21 (ACF ‘2020) .................................. 57

Q. Accounts 22 And 23 (BA ‘8225 and ‘7054) ................. 57

R. Saint Helena Property ................................... 58

S. Chicago Property ........................................ 58

T. Paradise Valley Property 1 .............................. 59

U. Paradise Valley Property 2 .... Error! Bookmark not defined.

JOHN BRUNST ASSETS ................................................ 59

V. Account 24 (COMPASS BANK ‘3825) ......................... 59

W. Account 25, 26, 27, 28, 29, 30 (AB ‘6878, ‘4954, 

‘7892, ‘7889, ‘7888 AND ‘6485) .......................... 60

SCOTT SPEAR ASSETS ................................................ 61

X. Accounts 31, 32, AND 33 (NBA ‘0178, ‘0151, and’3645) .... 61

Y. Account 34 (Live Oak Bank Account ‘6910) ................ 61

Z. Account 35 and 36 (Ascensus Broker Services ‘4301 

and’8001) ............................................... 62

PRIMUS TRUST ASSETS ............................................... 62

AA. Account 37 (K&H Bank Account ‘1210) ..................... 62

AD TECH BV ASSETS ................................................. 63

BB. Accounts 56, 57, and 58 (Fio Bank ‘5803, ‘5801, and ‘5805) .................................................. 63

CC. Accounts 47, 48, 49 and 50 (BF Accounts ‘K000 K, ‘K000 

U, ‘K000 E, and ‘K001 K) ................................ 64

GOLD LEAF SRO FUNDS HELD AT FIO BANK .............................. 64

DD. Account 38, 39, and 30 (Fio Bank ‘2226, ‘2231, and 

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‘2230) .................................................. 64

PROTECCTIO SRO FUNDS HELD AT FIO BANK ............................. 65

EE. Accounts 41, 42, and 43 (Fio Bank ‘4194, ‘4196, and 

‘4198) .................................................. 65

VARICOK SRO FUNDS HELD AT FIO BANK ................................ 65

FF. Accounts 44, 45, and 46 (Fio Bank ‘8083, ‘8086, and 

‘8080) .................................................. 65

PROCOP SERVICES BV FUNDS HELD AT KNAB BANK ........................ 66

GG. Account 51 (KB ‘7664) ................................... 66

GULIETTA GROUP BV FUNDS HELD AT RABO BANK ......................... 66

HH. Accounts 52 and 53 (RB ‘2452 and ‘4721) ................. 66

CASHFLOWS EUROPE LTD FUNDS HELD FOR GULIETTA GROUP B.V., 

UNIVERSADS B.V., PROCOPSERVICES B.V. and PROTECCIO SRO ....... 67

II. Account 55 (SP ‘1262) ................................... 67

JJ. Account 54 (LHVP ‘4431) ................................. 68

BACKPAGE-CONTROLLED DOMAIN NAMES .................................. 68

KK. ASCIO/WMB Inc Domain Names .............................. 68

LL. SURRENDERED DOMAIN NAMES ................................ 70

BACKPAGE SURRENDERED ASSETS ....................................... 80

MM. ASSETS BACKPAGE SURRENDERED TO THE GOVERNMENT ........... 80

NN. BACKPAGE ASSETS SURRENDERED TO THE GOVERNMENT BY 

OTHERS .................................................. 83

OO. BACKPAGE FUNDS PREVIOUSLY HELD AT DAVIS WRIGHT 

TREMAINE ................................................ 83

FUNDS HELD AT USAA SAVINGS BANK FOR THE BENEFIT OF MICHAEL LACEY .. 84

PP. Accounts 59, 60, 61, and 62 (USAA ‘2155, ‘2058, ‘2171, 

and, 1507) .............................................. 84

FIRST CLAIM FOR RELIEF ............................................ 86

(18 U.S.C. § 981(a)(1)(C)) ........................................ 86

SECOND CLAIM FOR RELIEF ........................................... 87

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(18 U.S.C. § 981(a)(1)(A)) ........................................ 87

THIRD CLAIM FOR RELIEF ............................................ 87

(18 U.S.C. § 981(a)(1)(A)) ........................................ 87

VERIFICATION ...................................................... 90

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The United States of America brings this first amended 

consolidated master complaint against the above-captioned asset(s)

and alleges as follows:

PERSONS AND ENTITIES

1. The plaintiff is the United States of America (“plaintiff”

or the “government”).

2. Plaintiff previously filed verified complaints seeking the 

civil forfeiture of the following assets (collectively, the 

“Defendant Assets”).

A. Defendants1

3. $689,884.48 in bank funds seized from First Federal Savings 

& Loan of San Rafael Account No. ‘3620 (“FFS&L of SR ‘3620 Funds” or 

“Account 4”), held in the name of Michael Lacey (“Lacey”). Lacey and 

Jill Anderson (“Anderson”) have filed claims in member case number CV 

18-8579 RGK (PJWx).

4. $515,899.85 in bank funds seized from Republic Bank of 

Arizona Account No. ‘2485 (“RBA ‘2485 Funds” or “Account 5”), held in 

the name of Michael Lacey. Lacey and Anderson have filed claims in 

member case number CV 18-8579 RGK (PJWx).

5. $500,000.00 in bank funds seized from Republic Bank of 

Arizona Account No. ‘3126 (“RBA ‘3126 Funds” or “Account 7”) held in 

the name of Michael Lacey. Lacey and Anderson have filed claims in 

member case number CV 18-8579 RGK (PJWx).

6. $601,827.10 in bank funds seized from Republic Bank of 

1 Pursuant to the Court’s Order dated December 18, 2019, the 

defendant assets from the member cases are described in this 

consolidated complaint. The original case number and claimant or 

claimants are identified in the description of each defendant in the 

instant consolidated complaint. 

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Arizona CDARS2 Account No. ‘8316 held in the name of Michael Lacey 

(“RBA ‘8316 Funds” or “Account 8”). Lacey and Anderson have filed 

claims in member case number CV 18-8579 RGK (PJWx).

7. $302,177.57 in bank funds seized from Republic of Bank of 

Arizona CDARS Account No. ‘8324 held in the name of Michael Lacey 

(“RBA ‘8324 Funds” or “Account 9”). Lacey and Anderson have filed 

claims in member case number CV 18-8579 RGK (PJWx).

8. $305,127.89 in bank funds seized from Republic Bank of 

Arizona CDARS Account No. ‘8332 (“RBA ‘8332 Funds” or “Account 10”)

held in the name of Michael Lacey. Lacey and Anderson have filed 

claims in member case number CV 18-8579 RGK (PJWx).

9. $484,745.72 in bank funds seized from SF Fire Credit Union 

Account No. ‘4S10 (“SFFCU ‘4S10 Funds” or “Account 11”), held in the 

name of Michael G. Lacey and Jean K. Warren. Lacey and Anderson have 

filed claims in member case number CV 18-8579 RGK (PJWx).

10. $2,412,785.47 in bank funds seized from Money Gram having 

originated from Midfirst Bank Account No. ‘4139 (“IOLTA3 ‘4139” or 

Account 12) held in the name of attorney, ““J.B.”“ for the benefit of 

Michael Lacey. Lacey, Anderson, and John R. Becker have filed claims

in member case number CV 18-8579 RGK (PJWx).

11. All right and title to the real property located in 

Sebastopol, California titled in the name of Finca Manzana for 

Sebastopol, LLC (“Sebastopol Property”), APN 076-100-0008-000, 

including all appurtenances, improvements, and attachments thereon, 

2 CDARS is a program that allows a depositor to spread funds 

across several banks in order to maintain account balances below the 

Federal Deposit Insurance Corporation’s insurance limits at any 

particular bank.

3 An “IOLTA” is an acronym for Interest on Lawyer Trust Account.

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as well as all leases, rents, and profits derived therefrom. 4 Lacey, 

Anderson, and Finca Manzana for Sebastopol, LLC. have filed claims in 

member case number CV 18-8730 RGK (PJWx).

12. All right and title to the real property located in San 

Francisco, California titled in the name of Lacey and Alyson Talley 

(“San Francisco Property 1”), APN Lot 057, Block 008, including all

appurtenances, improvements, and attachments thereon, as well as all 

leases, rents, and profits derived therefrom. Lacey, Anderson, and 

Alyson Talley have filed claims in member case number CV 18-8723 RGK

(PJWx).

13. All right and title to the real property located in San 

Francisco, California titled in the name of Casa Bahia for San 

Francisco, LLC. (“San Francisco Property 2”), APN Lot 029, Block 

0563, including all appurtenances, improvements, and attachments 

thereon, as well as all leases, rents, and profits derived therefrom. 

Casa Bahia, LLC., Lacey, and Anderson have filed claims in member

case number CV 18-8551 RGK (PJWx).

14. All right and title to the real property located in San 

Francisco, California titled in the name of Michael Lacey (“San 

Francisco Property 3”), APN Lot 008, Block 0097, including all 

appurtenances, improvements, and attachments thereon, as well as all 

leases, rents, and profits derived therefrom. Lacey and Anderson 

have filed claims in member case number CV 18-8763 RGK (PJWx).

15. All right and title to the real property located in Sedona, 

Arizona titled in the name of Creek Hideaway, LLC (“Sedona 

Property”), APN 405-06-001B, including all appurtenances, 

4 Pursuant to Local Rule 5.2-1, only the city and state of 

residence addresses are set forth in this Complaint

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improvements, and attachments thereon, as well as all leases, rents, 

and profits derived therefrom. Lacey, Creek Hideaway, LLC., and 

Anderson have filed claims in member case number CV 18-8556 RGK

(PJWx).

16. All right and title to the real property located in 

Paradise Valley, Arizona titled in the name of Lacey (“Paradise 

Valley Property 2”), APN 164-05-122, including all appurtenances, 

improvements, and attachments thereon, as well as all leases, rents, 

and profits derived therefrom. Lacey and Anderson have filed claims 

in member case number CV 18-8555 RGK (PJWx).

17. $1,546,076.35 in bank funds seized from Republic Bank of 

Arizona Account No. ‘1889 (“RBA ‘1889 Funds” or “Account 13”) held in 

the name of James Larkin (“Larkin”). Larkin and Margaret Larkin (“M. 

Larkin”) have filed claims in member case number CV 18-8420 RGK

(PJWx). 

18. $1,001,731.18 in bank funds seized from Republic Bank of 

Arizona Account No. ‘2592 (“RBA ‘2592 Funds” or “Account 14”) held in 

the name of James “Jed” Larkin. Larkin and M. Larkin have filed 

claims in member case number CV 18-8420.

19. $501,248.14 in bank funds seized from Republic Bank of 

Arizona Account No. ‘8103 (“RBA ‘8103 Funds” or “Account 16”) held in 

the name of John Larkin (“J. Larkin”). Larkin and M. Larkin have 

filed claims in member case number CV 18-8420 RGK (PJWx).

20. $251,436.93 in bank funds seized from Republic Bank of 

Arizona Account No. ‘8162 (“RBA ‘8162 Funds” or “Account 17”) held in 

the name of James Larkin. Larkin and M. Larkin have filed claims in 

member case number CV 18-8420 RGK (PJWx).

21. $253,639.96 in bank funds seized from Republic Bank of 

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Arizona Account ‘8189 (“RBA ‘8189 Funds” or “Account 18”) held in the 

name of James A. Larkin. Larkin and M. Larkin have filed a claim in 

member case number CV 18-8420 RGK (PJWx).

22. $621,832.06 in bank funds seized from Perkins Coie Trust 

Company Account No. ‘0012 (“PCTC ‘0012 Funds” or “Account 19”) held 

in the name of Margaret G. Larkin. Larkin, M. Larkin, Coyoacan 

Family Trust (“CFT”) and Ocotillo Family Trust (“OFT”) have filed 

claims in member case number CV 18-8420 RGK (PJWx).

23. Approximately $9,882,828.72 in securities and/or investment 

funds seized from Perkins Coie Trust Company Account No. ‘0012 (“PCTC 

Investment Funds” or “Account 20”) held in the name of Margaret G. 

Larkin. Larkin, M. Larkin, CFT and OFT have filed claims in member

case number CV 18-8420 RGK (PJWx).

24. Approximately $34,149,280.00 in securities and/or 

investment funds seized from Acacia Conservation Fund LP Account No. 

‘2020 (“ACF Funds” or “Account 21”), held in the name of the Ocotillo 

Family Trust. Larkin, M. Larkin, CFT and OFT have filed claims in 

member case number CV 18-8420 RGK (PJWx).

25. $278.73 in bank funds seized from Bank of America Account 

No. ‘8225 (“BA ‘8225 Funds” or “Account 22”) held in the name of Troy 

C. Larkin (“T. Larkin”). Larkin filed a claim in member case number 

CV 18-8420 RGK (PJWx).

26. $1,038.42 in bank funds seized from Bank of America Account 

No. ‘7054 (“BA ‘7054 Funds” or “Account 23”) held in the name of 

Ramon Larkin (“R. Larkin”). Larkin filed a claim in member case 

number CV 18-8420 RGK (PJWx).

27. All right and title to the real property located in 

Paradise Valley, Arizona titled in the name of James Larkin 

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(“Paradise Valley Property 1”), APN 173-11-006C, including all 

appurtenances, improvements, and attachments thereon, as well as all 

leases, rents, and profits derived therefrom. Larkin, M. Larkin, and 

OFT have filed claims in member case number CV 18-8764 RGK (PJWx).

28. All right and title to the real property located in Saint 

Helena, California (“Saint Helena Property”) titled in the name of

James Larkin and Margaret Larkin, Trustees for Ocotillo Family Trust, 

APN 030-050-028-000, including all appurtenances, improvements, and 

attachments thereon, as well as all leases, rents, and profits 

derived therefrom. Larkin, M. Larkin, and OFT have filed claims in 

member case number CV 18-8760 RGK (PJWx).

29. All right and title to the real property located in 

Chicago, Illinois titled in the name of John C. Larkin (“J.C. 

Larkin”), Margaret Larkin and James Larkin (“Chicago Property”), APN 

20-14-201-079-1054, including all appurtenances, improvements, and 

attachments thereon, as well as all leases, rents, and profits 

derived therefrom. Larkin and M. Larkin have filed claims in member

case number CV 18-8759 RGK (PJWx).

30. $359,527.06 in bank funds seized from BBVA Compass Bank 

Account No. ‘3825 (“Compass ‘3825 Funds” or “Account 24”) held in the 

name of the John Brunst Family Trust (“BFT”). The BFT, John Brunst 

(“Brunst”) and Mary Ann Brunst (“M.A. Brunst”) have filed claims in 

member case number CV 18-8568 RGK (PJWx).

31. Approximately $5,848,729.00 in securities and/or investment 

funds seized from Alliance Bernstein L.P. Account No. ‘6878 (“AB 

‘6878 Funds” or “Account 25”) held in the name of the John Brunst 

Family Trust. The BFT, Brunst and M.A. Brunst have filed claims in 

member case number CV 18-8568 RGK (PJWx).

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32. Approximately $372,878.00 in securities and/or investment 

funds seized from Alliance Bernstein L.P. Account No. ‘4954 (“AB 

‘4954 Funds” or “Account 26”) held in the name of the Brunst Family 

Trust. The BFT, Brunst and M.A. Brunst have filed claims in member

case number CV 18-8568 RGK (PJWx).

33. Approximately $342,596.00 in securities and/or investment 

funds seized from Alliance Bernstein Account L.P. Account No. ‘7982

(“AB ‘7982 Funds” or “Account 27”) held in the name of the Brunst 

Family Trust. The BFT, Brunst and M.A. Brunst have filed claims in 

member case number CV 18-8568 RGK (PJWx).

34. Approximately $306,277.00 in securities and/or investment 

funds Seized from Alliance Bernstein L.P. Account No. ‘7889 (“AB 

‘7889 Funds” or “Account 28”) held in the name of the Brunst Family 

Trust. The BFT, Brunst and M.A. Brunst have filed claims in member

case number CV 18-8568 RGK (PJWx).

35. Approximately $275,328.00 in securities and/or investment 

funds seized from Alliance Bernstein L.P. Account No. ‘7888 (“AB 

‘7888 Funds” or “Account 29”) held in the name of the Brunst Family 

Trust. The BFT, Brunst and M.A. Brunst have filed claims in member

case number CV 18-8568 RGK (PJWx).

36. Approximately $527,624.00 in securities and/or investment 

funds seized from Alliance Bernstein L.P. Account No. ‘6485 (“AB 

‘6485 Funds” or “Account 30”) held in the name of the Brunst Family 

Trust. The BFT, Brunst and M.A. Brunst have filed claims in member

case number CV 18-8568 RGK (PJWx).

37. $404,374.12 in bank funds seized From National Bank of 

Arizona Account No. ‘0178 (“NBA ‘0178 Funds” or “Account 31”) held in 

the name of Scott Spear (“Spear”). Spear and Natasha Spear (“N. 

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Spear”) filed a claim in member case number CV 18-8423 RGK (PJWx).

38. $1,925.80 in bank funds seized from National Bank of 

Arizona Account No. ‘0151 (“NBA ‘0151 Funds” or “Account 32”), held 

in the name of Scott and Ellona Spear (“E. Spear”). Spear and N. 

Spear filed a claim in member case number CV 18-8423 RGK (PJWx).

39. $613,573.28 in bank funds seized from National Bank of 

Arizona Account No. ‘3645 (“NBA ‘3645 Funds” or “Account 33”), held 

in the name of Scott G. Spear and Ellona Spear Family Trust. Spear

and N. Spear filed a claim in member case number CV 18-8423 RGK

(PJWx).

40. $260,283.40 in bank funds seized from Live Oak Bank Account 

No. ‘6910 (“LOB ‘6910 Funds” or “Account 34”), held in the name of 

Scott Gary Spear and Ellona Spear Family Trust. Spear and N. Spear

filed a claim in member case number CV 18-8423 RGK (PJWx).

41. $64,552.82 in bank funds seized from Ascensus Broker Dealer 

Services Account No. ‘4301 (“ABS ‘4301 Funds” or “Account 35”), held 

in the name of Natasha Spear. Spear and N. Spear have filed claims

in member case number CV 18-8423 RGK (PJWx).

42. $56,902.99 in bank funds seized from or frozen in Ascensus 

Broker Services Account No. ‘8001 (“ABS ‘8001 Funds” or “Account 

36”), held in the name of Natasha Spear. Spear and N. Spear have 

filed claims in member case number CV 18-8423 RGK (PJWx).

43. Approximately $16,500,000.00 in bank funds seized from K&H 

Account No. ‘1210 (“K&H ‘1210 Funds” or “Account 37”), held in the 

name of Primus Trust. Lacey and Anderson have filed claims in member

case number CV 18-8565 RGK (PJWx).

44. Approximately 1,680,028.85 EUR in bank funds seized from 

FIO Banka (Czech Republic) Account No. ‘2226 (“FIO ‘2226 Funds” or 

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“Account 38”), held in the name of Gold Leaf SRO. Medalist Holding, 

Inc. (“Medalist”); Leeward Holdings, LLC (“Leeward”); Camarillo 

Holdings, LLC (“Camarillo”); Vermillion Holdings, LLC (“Vermillion”); 

Cereus Properties, LLC (“Cereus”); Shearwater Investments, LLC 

(“Shearwater”); Broadway Capital Corp., LLC (“Broadway”); Larkin, 

Troy Larkin (“T. Larkin”); Ramon Larkin (“R. Larkin”); Spear, Lacey, 

and Brunst have filed claims in member case number CV 18-8569 RGK

(PJWx). 

45. Approximately 60.98 GDP in bank funds seized from FIO Banka 

(Czech Republic) Account No. ‘2231 (“FIO ‘2231 Funds” or “Account 

39”), held in the name of Gold Leaf SRO. Medalist, Leeward,

Camarillo, Vermillion, Cereus, Shearwater, Broadway, Larkin, T. 

Larkin, R. Larkin, Spear, Lacey, and Brunst have filed claims in 

member case number CV 18-8569 RGK (PJWx).

46. Approximately $72.87 in bank funds seized from FIO Banka

(Czech Republic) Account No. ‘2230 (“FIO ‘2230 Funds” or “Account 

40”), held in the name of Gold Leaf SRO. Medalist, Leeward, 

Camarillo, Vermillion, Cereus, Shearwater, Broadway, Larkin, T. 

Larkin, R. Larkin, Spear, Lacey, and Brunst have filed claims in 

member case number CV 18-8569 RGK (PJWx).

47. Approximately 3,213,937.82 EUR in bank funds seized from 

FIO Banka (Czech Republic) Account No. ‘4194 (“FIO ‘4194 Funds” or 

“Account 41”), held in the name of Protecctio SRO. Medalist, Leeward, 

Camarillo, Vermillion, Cereus, Shearwater, Broadway, Larkin, T. 

Larkin, R. Larkin, Spear, Lacey, and Brunst have filed claims in 

member case number CV 18-8577 RGK (PJWx). 

48. Approximately $52.90 in bank funds seized from FIO Banka 

(Czech Republic) Account No. ‘4196 (“FIO ‘4196 Funds” or “Account 

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42”), held in the name of Protecctio SRO. Medalist, Leeward, 

Camarillo, Vermillion, Cereus, Shearwater, Broadway, Larkin, T. 

Larkin, R. Larkin, Spear, Lacey, and Brunst have filed claims in 

member case number CV 18-8577 RGK (PJWx).

49. Approximately 52.65 GDP in bank funds seized from FIO Banka 

Account No. ‘4198 (“FIO ‘4198 Funds” or “Account 43”) held in the 

name of Protecctio SRO. Medalist, Leeward, Camarillo, Vermillion, 

Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. Larkin, Spear, 

Lacey, and Brunst have filed claims in member case number CV 18-8577 

RGK (PJWx). 

50. Approximately 605,976.95 EUR in bank funds seized from FIO 

Banka (Czech Republic) Account No. ‘8083 (“FIO ‘8083 Funds” or 

“Account 44”) held in the name of Varicok Company SRO. Medalist, 

Leeward, Camarillo, Vermillion, Cereus, Shearwater, Broadway, Larkin, 

T. Larkin, R. Larkin, Spear, Lacey, and Brunst have filed claims in 

member case number CV 18-8747 RGK (PJWx).

51. Approximately 458.99 GDP in bank funds seized from FIO 

Banka (Czech Republic) Account No. ‘8086 (“Fio ‘8086 Funds” or 

“Account 45”), held in the name of the Varicok Company SRO. 

Medalist, Leeward, Camarillo, Vermillion, Cereus, Shearwater, 

Broadway, Larkin, T. Larkin, R. Larkin, Spear, Lacey, and Brunst have 

filed claims in member case number CV 18-8747 RGK (PJWx).

52. Approximately $48.10 in bank funds seized from FIO Banka 

(Czech Republic) Account No. ‘8080 (“Fio ‘8080 Funds” or “Account 

46”), held in the name of the Varicok Company SRO. Medalist, 

Leeward, Camarillo, Vermillion, Cereus, Shearwater, Broadway, Larkin, 

T. Larkin, R. Larkin, Spear, Lacey, and Brunst have filed claims in 

member case number CV 18-8747 RGK (PJWx).

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53. An unknown amount of bank funds on deposit in Bank Frick 

(Liechtenstein) Account No. ‘000K (“BF ‘000K Funds” or “Account 47”),

held in the name of Ad Tech BV. Medalist, Leeward, Camarillo, 

Vermillion, Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. 

Larkin, Spear, Lacey, and Brunst have filed claims in member case 

number CV 18-8570 RGK (PJWx).

54. An unknown amount of bank funds on deposit in Bank Frick 

(Liechtenstein) Account No. ‘000U (“BF ‘000U Funds” or “Account 48”), 

held in the name of Ad Tech BV. Medalist, Leeward, Camarillo, 

Vermillion, Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. 

Larkin, Spear, Lacey, and Brunst have filed claims in member case 

number CV 18-8570 RGK (PJWx).

55. An unknown amount of bank funds on deposit in Bank Frick 

(Liechtenstein) Account No. ‘000E (“BF ‘000E Funds” or “Account 49”), 

held in the name of Ad Tech BV. Medalist, Leeward, Camarillo, 

Vermillion, Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. 

Larkin, Spear, Lacey, and Brunst have filed claims in member case 

number CV 18-8570 RGK (PJWx).

56. An unknown amount of bank funds on deposit in Bank Frick 

(Liechtenstein) Account No. ‘001K (“BF ‘001K Funds” or “Account 50”), 

held in the name of Ad Tech BV. Medalist, Leeward, Camarillo, 

Vermillion, Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. 

Larkin, Spear, Lacey, and Brunst have filed claims in member case 

number CV 18-8570 RGK (PJWx).

57. An unknown amount of bank funds on deposit in Knab Bank 

(Netherlands) Account No. ‘7664 (“KB ‘7664 Funds” or “Account 51”), 

held in the name of Procop Services BV. Medalist, Leeward, 

Camarillo, Vermillion, Cereus, Shearwater, Broadway, Larkin, T. 

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Larkin, R. Larkin, Spear, Lacey, and Brunst have filed claims in 

member case number CV 18-8748 RGK (PJWx).

58. An unknown amount of bank funds on deposit in Rabo Bank 

(Netherlands) Account No. ‘2452 (“RB ‘2452 Funds” or “Account 52”),

held in the name of the Gulietta Group BV. Medalist, Leeward, 

Camarillo, Vermillion, Cereus, Shearwater, Broadway, Larkin, T. 

Larkin, R. Larkin, Spear, Lacey, and Brunst have filed claims in 

member case number CV 18-8749 RGK (PJWx).

59. An unknown amount of bank funds on deposit in Rabo Bank 

(Netherlands) Account No. ‘4721 (“RB ‘4721 Funds” or “Account 53”), 

held in the name of the UniversAds BV. Medalist, Leeward, Camarillo, 

Vermillion, Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. 

Larkin, Spear, Lacey, and Brunst have filed claims in member case 

number CV 18-8750 RGK (PJWx).

60. An unknown amount of bank funds on deposit in LHV Pank 

(Estonia) Account No. ‘4431 (“LHVP ‘4431 Funds” or “Account 54”), 

held in the name of Olist OU (“OU”). Medalist, Leeward, Camarillo, 

Vermillion, Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. 

Larkin, Spear, Lacey, and Brunst have filed claims in member case 

number CV 18-8754 RGK (PJWx).

61. Approximately 747,664.15 GBP seized from SAXO Payments 

(United Kingdom) Account No. ‘1262 (“SP ‘1262 Funds” or “Account 

55”), held in the name of the Cashflows Europe Limited (“Cashflows”). 

Medalist, Leeward, Camarillo, Vermillion, Cereus, Shearwater, 

Broadway, Larkin, T. Larkin, R. Larkin, Spear, Lacey, and Brunst have 

filed claims in member case number CV 18-8753 RGK (PJWx).

62. Domain names associated with Backpage.com, and all rights

and privileges associated therewith. Medalist, Leeward, Camarillo, 

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Vermillion, Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. 

Larkin, Spear, Lacey, and Brunst have filed claims in member case 

number CV 18-8592 RGK (PJWx).

63. $699,940.00 in bank funds seized from ING Bank 

(Netherlands) Account No. ‘7684 (“ING ‘7684 Funds”) held in the name 

of Payment Solutions BV. Medalist, Leeward, Camarillo, Vermillion, 

Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. Larkin, Spear, 

Lacey, and Brunst have filed claims in member case number CV 18-8588 

RGK (PJWx).

64. $106,988.41 in bank funds seized from ING Bank 

(Netherlands) Account No. ‘2071 (“ING ‘2071 Funds”) held in the name 

of Payment Solutions BV. Medalist, Leeward, Camarillo, Vermillion, 

Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. Larkin, Spear, 

Lacey, and Brunst have filed claims in member case number CV 18-8588 

RGK (PJWx).

65. $499,910.01 in bank funds seized from US Bank Account No.

‘0239 (“US Bank ‘0239 Funds”) held in the name of Affordable Bail 

Bonds, LLC. Medalist, Leeward, Camarillo, Vermillion, Cereus, 

Shearwater, Broadway, Larkin, T. Larkin, R. Larkin, Spear, Lacey, and 

Brunst have filed claims in member case number CV 18-8588 RGK (PJWx).

66. $50,000.00 in bank funds seized from Enterprise Bank and 

Trust Account No. ‘7177 (“EBT ‘7177 Funds”) held in the name of 

Global Trading Solutions, LLC. Medalist, Leeward, Camarillo, 

Vermillion, Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. 

Larkin, Spear, Lacey, and Brunst have filed claims in member case 

number CV 18-8588 RGK (PJWx).

67. $1,876.36 in bank funds seized from ING Bank (Netherlands) 

Account No. ‘2071 (“ING ‘2071 Funds”) held in the name of Payment 

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Solutions BV. Medalist, Leeward, Camarillo, Vermillion, Cereus, 

Shearwater, Broadway, Larkin, T. Larkin, R. Larkin, Spear, Lacey, and 

Brunst have filed claims in member case number CV 18-8588 RGK (PJWx).

68. $50,357.35 in bank funds seized from ING Bank (Netherlands) 

Account No. ‘7684 (“ING ‘7684 Funds”) held in the name of Payment 

Solutions BV. Medalist, Leeward, Camarillo, Vermillion, Cereus, 

Shearwater, Broadway, Larkin, T. Larkin, R. Larkin, Spear, Lacey, and 

Brunst have filed claims in member case number CV 18-8588 RGK (PJWx).

69. $248,970.00 in bank funds seized from Citibank NA Account 

No. ‘0457 (“Citibank NA ‘0457 Funds”) held in the name of Paul 

Hastings, LLP. Medalist, Leeward, Camarillo, Vermillion, Cereus, 

Shearwater, Broadway, Larkin, T. Larkin, R. Larkin, Spear, Lacey, and 

Brunst have filed claims in member case number CV 18-8588 RGK (PJWx).

70. $52,500.00 in bank funds seized from Enterprise Bank and 

Trust Account No. ‘7177 (“EBT ‘7177 Funds”) held in the name of 

Global Trading Solutions, LLC. Medalist, Leeward, Camarillo, 

Vermillion, Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. 

Larkin, Spear, Lacey, and Brunst have filed claims in member case 

number CV 18-8588 RGK (PJWx).

71. $65,000.00 in bank funds seized from Enterprise Bank and 

Trust Account No. ‘7177 (“EBT ‘7177 Funds”) held in the name of 

Global Trading Solutions, LLC. Medalist, Leeward, Camarillo, 

Vermillion, Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. 

Larkin, Spear, Lacey, and Brunst have filed claims in member case 

number CV 18-8588 RGK (PJWx).

72. $5,534.54 in bank funds seized from Enterprise Bank and 

Trust Account ‘7177 (“EBT ‘7177 Funds”) held in the name of Global 

Trading Solutions, LLC. Medalist, Leeward, Camarillo, Vermillion, 

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Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. Larkin, Spear, 

Lacey, and Brunst have filed claims in member case number CV 18-8588 

RGK (PJWx).

73. $40,000.00 in bank funds seized from Enterprise Bank and 

Trust Account No. ‘7177 held in the name of Global Trading Solutions, 

LLC. Medalist, Leeward, Camarillo, Vermillion, Cereus, Shearwater, 

Broadway, Larkin, T. Larkin, R. Larkin, Spear, Lacey, and Brunst have 

filed claims in member case number CV 18-8588 RGK (PJWx).

74. Approximately 6 Bitcoins surrendered on or about April 6, 

2018, from a Backpage controlled wallet. 

75. Approximately 404.99984122 Bitcoins surrendered on or about 

April 6, 2018, from a Backpage controlled wallet. 

76. Approximately 199.99995716 Bitcoins surrendered on or about 

April 6, 2018, from a Backpage controlled wallet.

77. Approximately 173.97319 Bitcoins surrendered on or about 

April 26, 2018, from a Backpage controlled wallet. 

78. Approximately 411.00019 Bitcoins seized on or about April 

13, 2018, from a Backpage controlled wallet. 

79. Approximately 2.00069333 Bitcoins surrendered on or about 

May 7, 2018, from a Backpage controlled wallet. 

80. Approximately 136.6544695 Bitcoins surrendered on or about 

June 15, 2018, from a Backpage controlled wallet. 

81. Approximately 2,673.59306905 Bitcoin Cash surrendered on or 

about April 26, 2018, from a Backpage controlled wallet. 

82. Approximately 55.50826185 Bitcoin Cash surrendered on or 

about May 3, 2018, from a Backpage controlled wallet. 

83. Approximately 73.62522241 Bitcoin Cash surrendered on or 

about June 15, 2018, from a Backpage controlled wallet. 

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84. Approximately 16,310.79413202 Litecoins surrendered on or 

about April 26, 2018, from a Backpage controlled wallet. 

85. Approximately 783.9735116 Litecoins surrendered on or about 

June 15, 2018, from a Backpage controlled wallet. 

86. Approximately 509.81904619 Bitcoin Gold surrendered on or 

about June 21, 2018, from a Backpage controlled wallet.

87. Approximately 2.70447488 Bitcoins seized from Bitstamp 

Account No. ‘0831. Medalist, Leeward, Camarillo, Vermillion, Cereus, 

Shearwater, Lacey, Larkin, T. Larkin, R. Larkin, and Spear have filed 

a claim in member case number CV 19-9949 RGK (PJWx).

88. Approximately 3.54986077 Bitcoin Cash seized from Bitstamp 

Account No. ‘0831. Medalist, Leeward, Camarillo, Vermillion, Cereus, 

Shearwater, Lacey, Larkin, T. Larkin, R. Larkin, and Spear have filed 

a claim in member case number CV 19-9949 RGK (PJWx).

89. $518,172.92 in bank funds seized from Wells Fargo Bank 

Account No. ‘4455 (“BofA ‘4455 Funds” or “Account 66”) held in the 

name of Cardquiry, Inc. Medalist, Leeward, Camarillo, Vermillion, 

Cereus, Shearwater, and Broadway, Larkin, T. Larkin, R. Larkin,

Spear, Lacey, and Brunst filed a claim in member case number CV 19-

7048 RGK (PJWx).

90. $1,412,085.94 in bank funds seized from USAA Savings 

Account No. ‘2155 (“USAA ‘2155 Funds” or “Account 59”) held in the 

name of Anne Hawkins (“Hawkins”). Kathleen D. Larkin (“K. Larkin”), 

John C. Larkin (“J.C. Larkin”), Quinn M. Larkin (“Q. Larkin”), and 

Hawkins have filed claims in member case number CV 19-7032 RGK

(PJWx).

91. $1,502,927.74 in bank funds seized from USAA Savings 

Account No. ‘2058 (“USAA ‘2058 Funds” or “Account 60”) held in the 

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name of Anne Hawkins. K. Larkin, J.C. Larkin, Q. Larkin, and Hawkins

have filed claims in member case number CV 19-7032 RGK (PJWx).

92. $1,453,008.51 in bank funds seized from USAA Savings 

Account No. ‘2171 (“USAA ‘2171 Funds” or “Account 61”) held in the 

name of Anne Hawkins. K. Larkin, J.C. Larkin, Q. Larkin, and Hawkins

have filed claims in member case number CV 19-7032 RGK (PJWx).

93. $1,422,147.37 in bank funds seized from USAA Savings 

Account No. ‘1507 (“USAA ‘1507 Funds” or “Account 62”) held in the 

name of Anne Hawkins. K. Larkin, J.C. Larkin, Q. Larkin, and Hawkins

have filed claims in member case number CV 19-7032 RGK (PJWx).

94. $182,182.50 in bank funds seized from Amro Bank N.V. 

(Netherlands) Account No. ‘6352 (“Amro ‘6352 Funds” or “Account 63”) 

held in the name of Ad Tech BV with Stichting Zencotrust. Medalist, 

Leeward, Camarillo, Vermillion, Cereus, Shearwater, Larkin, T. 

Larkin, R. Larkin, Spear, Lacey, and Brunst have filed claims in 

member case number CV 19-7039 RGK (PJWx).

95. $23,175.00 in bank funds seized from Plains Capital Bank 

Account No. ‘3939 (“Plains Capital ‘3939 Funds” or “Account 64”) held 

in the name of Scheef & Stone, LLP. Medalist, Leeward, Camarillo, 

Vermillion, Cereus, Shearwater, Larkin, T. Larkin, R. Larkin, Spear, 

Lacey, and Brunst have filed claims in member case number CV 19-7039 

RGK (PJWx).

96. $11,802.76 in bank funds seized from Citibank Account No. 

‘6973 (“Citibank ‘6973 Funds” or “Account 65”) held in the name of

Schiff Hardin LLP. Medalist, Leeward, Camarillo, Vermillion, Cereus, 

Shearwater, Larkin, T. Larkin, R. Larkin, Spear, and Lacey have filed 

claims in member case number CV 19-7044 RGK (PJWx).

97. $3,374,918.61 in bank funds seized from Prosperity Bank 

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Account No. ‘7188 (“Prosperity ‘7188 Funds” or “Account 1”) held in 

the name of Posting Solutions, LLC. Medalist, Leeward, Camarillo, 

Vermillion, Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. 

Larkin, Lacey, and Brunst have filed claims in member case number CV 

18-8578 RGK (PJWx).

98. $5,462,027.17 in bank funds seized from BBVA Compass Bank 

Account No. ‘3873 (“Compass ‘3873 Funds” or “Account 2”), held in the 

name of Cereus Properties, LLC., an entity owned or controlled by 

Scott Spear. Medalist, Leeward, Camarillo, Vermillion, Cereus, 

Shearwater, Broadway, Larkin, T. Larkin, R. Larkin, Spear, Lacey, and 

Brunst have filed claims in member case number CV 18-8566 RGK (PJWx).

99. $407,686.14 in bank funds seized from BBVA Compass Bank 

Account No. ‘4862 (“Compass ‘4862 Funds” or “Account 3”) held in the 

name of Cereus Properties, LLC. Medalist, Leeward, Camarillo, 

Vermillion, Cereus, Shearwater, Broadway, Larkin, T. Larkin, R. 

Larkin, Spear, Lacey, and Brunst have filed a claim in member case 

number CV 18-8566 RGK (PJWx).

NATURE OF THE ACTION AND CLAIMS FOR RELIEF

100. This is a civil action in rem to forfeit assets derived 

from or traceable to proceeds of one or more crimes defined as 

“specified unlawful activity,” or “SUA”; and/or involved in one or 

more conspiracies to launder money, internationally launder money for 

promotion of one or more SUA, and/or financial transactions involving 

illicit proceeds. The property sought for forfeiture is located in 

the United States and abroad, including the Country of Hungary, the 

Czech Republic, the Principality of Liechtenstein, and the Kingdom of 

the Netherlands. 

101. The Defendant Assets represent property derived from or 

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traceable to proceeds of multiple knowing violations of federal laws 

constituting SUA (18 U.S.C. § 1956(c)(7)(A)), including 18 U.S.C. 

§§ 1591 (Sex Trafficking of Children) and 1952 (Interstate and 

Foreign Travel in Aid of Racketeering Enterprise). The Defendant 

Assets are therefore subject to forfeiture pursuant to 18 U.S.C. 

§ 981(a)(1)(C). 

102. Further, the Defendant Assets represent property involved 

in or traceable to one or more transactions or attempted transactions 

in violation of:

a. 18 U.S.C. § 1956(a)(1)(B)(i) (Money Laundering for 

Concealment) and a conspiracy to commit such offenses, in violation 

of 18 U.S.C. § 1956(h);

b. 18 U.S.C. § 1956(a)(2) (International Money Laundering for 

Promotion) and a conspiracy to commit such offenses, in violation of 

18 U.S.C. § 1956(h); and

c. 18 U.S.C. § 1957 (Monetary Transactions with Proceeds of 

SUA) and a conspiracy to commit such offenses, in violation of 18 

U.S.C. § 1956(h). 

The Defendant Assets are therefore subject to forfeiture pursuant to 

18 U.S.C. § 981(a)(1)(A). 

JURISDICTION AND VENUE

103. This civil forfeiture action is brought pursuant to 18 

U.S.C. § 981(a)(1). 

104. This Court has jurisdiction over this matter pursuant to 28 

U.S.C. §§ 1345 and 1355.

105. Venue lies in this district pursuant to 28 U.S.C. §§ 

1355(b)(1)(A) or 1355(b)(2) because acts and omissions giving rise to 

the forfeiture took place in the Central District of California 

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and/or 28 U.S.C. § 1395(b), because certain of the Defendant Assets

are located in the Central District of California.

INDIVIDUALS AND ENTITIES

106. Backpage.com, LLC, (“Backpage”) incorporated in Delaware in 

2004, was an internet-based company that allowed customers to post 

on-line classified advertisements. These advertisements were posted 

in a variety of categories, including adult, automotive, community, 

dating, jobs, local places, musicians, rentals and services. Prior 

to its closure by federal law enforcement authorities in April 2018, 

Backpage was visited by 75 to 100 million unique internet visitors 

per month.

107. Between 2004 and April 2018, Backpage realized annual 

profits of tens of millions of dollars from adult advertisements. 

Historically, the adult category, where Backpage advertisers posted 

sex trafficking ads, made up less than ten percent of all the 

website’s advertisements. However, those ads generated more than 90 

percent of Backpage’s revenue. 

108. Lacey was a co-creator of Backpage.com. Lacey was 

responsible for the website’s policies and strategic direction, and 

he maintained significant control over the website during the 

relevant period described in this complaint. Even after purportedly 

selling his interest in Backpage in 2015, Lacey continued to receive 

tens of millions of dollars in Backpage-related distributions.

109. Larkin was a co-creator of Backpage.com. Larkin was 

responsible for the website’s policies and strategic direction, and 

he maintained significant control over the website during the 

relevant period described in this complaint. Even after purportedly 

selling his interest in Backpage in 2015, Larkin continued to receive 

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tens of millions of dollars in Backpage-related distributions.

110. Carl Ferrer (“Ferrer”), though not an original owner, was a 

co-creator and one of the original officers of Backpage, having 

initially served as Backpage’s vice-president, and later as CEO. 

Ferrer is also the CEO of several Backpage-related entities in the 

Netherlands, including “Website Technologies,” “Amstel River 

Holdings,” and “Ad Tech BV.”

111. Brunst was a minority owner of Backpage who owned 5.67 

percent of the company at the time of its inception. Brunst served 

as the Chief Financial Officer of Backpage and several of Backpage’s 

parent companies.

112. Spear was a minority owner of Backpage who owned 4.09 

percent of the company at the time of its inception. Spear served as 

Executive Vice President of one of Backpage’s parent companies.

113. “M.G.” had no formal position at Backpage, but was the 

President, Chief Executive Officer, Treasurer, and Secretary of 

Posting Solutions LLC, a wholly owned Backpage subsidiary with a 

principal place of business in Dallas, Texas (“Posting Solutions”), 

which accepted payments from Backpage advertisers. M.G. was also the 

Chief Financial Officer of Website Technologies, and directed and 

controlled many of the international and domestic financial 

transactions of Backpage and its related entities.

114. Daniel Hyer (“Hyer”) served as Backpage’s Sales and 

Marketing Director. He remained an account signatory for numerous 

Backpage-controlled entities, including Website Technologies, until 

Backpage’s closure.

115. Andrew Padilla (“Padilla”) served as Backpage’s Operations 

Manager.

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116. Joye Vaught (“Vaught”) served as Backpage’s assistant 

Operations Manager.

117. Lacey, Larkin, Ferrer, Brunst, Spear, M.G., Hyer, Padilla, 

and Vaught are referred to collectively herein as “Backpage 

Operators.”

EVIDENCE SUPPORTING FORFEITURE

II. The Formation and Evolution of Backpage

118. Lacey and Larkin were the founders of the Phoenix New 

Times, an alternative newspaper based in Arizona. Lacey and Larkin 

subsequently acquired several other alternative newspapers that they 

operated through an entity called Village Voice Media Holdings 

(“VVMH”). Spear served as VVMH’s Executive Vice President and Brunst 

served as VVMH’s Chief Financial Officer.

119. As far back as the 1980’s, VVMH publications routinely 

included ads for prostitution.

120. By 2000, the popularity of the website www.craigslist.com 

(“Craigslist”), which offered free classified ads that included 

prostitution ads, began to disrupt VVMH’s business, which depended on 

classified advertising revenue.

121. Lacey and Larkin, assisted by Ferrer, sought to address 

this disruption by creating Backpage, which would compete directly 

with Craigslist. As stated in an internal Backpage document, “[I]n 

2004, in response to the Craigslist threat that was decimating daily 

newspapers, VVMH launched its own online classified site,

Backpage.com, named after the back page of VVMH’s print publication.”

122. From 2004 until 2015, Lacey and Larkin bore primary 

responsibility for Backpage’s policies and strategic direction. In 

2015, Lacey and Larkin purported to sell to Ferrer all or 

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substantially all of their respective interests in Backpage. In 

fact, Lacey and Larkin retained significant control over Backpage, 

and both continued to receive millions of dollars of annual 

distributions of Backpage revenue after the purported sale.

123. From its inception, most of Backpage’s earnings represented 

the proceeds of illegal activity, specifically prostitution and sex 

trafficking, including child sex trafficking. By 2015, the major 

credit card companies were refusing to process payments to or for 

Backpage, and banks were closing Backpage’s accounts out of concern 

the accounts were being used for illegal purposes.

124. In response to these measures, the Backpage Operators 

initiated and pursued a wide variety of money laundering strategies 

and techniques designed, in part, to conceal the source and location 

of the revenues generated by Backpage ads, including ads for human 

trafficking and illegal prostitution. These strategies included: (a) 

instructing customers to send checks and money orders to a Post 

Office box, funneling those funds into bank accounts held in the 

names of entities with no apparent connection to Backpage, and then 

giving customers a corresponding “credit” to purchase Backpage ads; 

(b) accepting Backpage proceeds through foreign bank accounts and 

thereafter redirecting the funds to Backpage Operators in the U.S. 

and abroad, or transferring the funds back to domestic bank accounts 

(to conceal the nature, source, location, ownership and control of 

those funds and promote Backpage’s ongoing illegal operations); and 

(c) converting customers payments and the proceeds of Backpage’s 

illegal business into and out of digital currency.5

5 Digital currency (also known as crypto-currency) is generally 

defined as an electronic-sourced unit of value that can be used as a 

(footnote cont’d on next page)

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III. The Sources and Manipulation of Backpage Criminal Proceeds

A. Backpage Promotion of Prostitution and Sex Trafficking

125. Numerous Backpage ads were used to sell minors for sex and 

forcibly traffic adult women for sex. Among the pimps and sex 

traffickers who used Backpage to advertise their victims were many 

who were later convicted of sex trafficking offenses. For example,

a. During 2014 and 2015, a pimp sold S.F., a minor girl, for 

sex. The pimp advertised S.F. on Backpage’s “Escort” section in the 

Los Angeles area of California and in Arizona. The ad contained 

phrases such as “New In Town” and “Sexy Dark Asian Bombshell with a 

Nice & Tight {Booty}.” The ad selling S.F. on Backpage included 

multiple pictures showing her legs, stomach, shoulders and buttocks. 

The pimp who placed the ad was ultimately arrested, convicted on 

state sex trafficking charges, and sentenced to 196 years 

imprisonment.

b. During 2014 and 2015, the same pimp sold A.C., a minor 

girl, for sex. In November 2014, at the age of 17, A.C. was first 

sold for sex through a Backpage ad using phrases such as “NEW IN 

TOWN,” “sexy sweet,” and “sweet like honey but super hot like fire.” 

The Backpage ad selling A.C. included pictures of her showing her 

legs, stomach, shoulder, and buttocks, and posed in sexually 

provocative positions.

c. Between November and December 2015, a pimp drove two women 

and four minor girls (T.S., S.L., K.O., and R.W.) from Columbus, Ohio 

substitute for fiat currency (i.e., currency created and regulated by 

a sovereign government). It exists entirely on the Internet and is 

not stored in any physical form. It is not issued by any government, 

bank, or company, but is instead generated and controlled through 

computer software operating on a decentralized peer-to-peer network. 

Bitcoin, Bitcoin Cash and Litecoin are types of crypto-currency. 

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to a hotel in St. Charles, Missouri. The next day, the pimp told the 

girls to post ads on Backpage.com. Some of the girls took calls and 

engaged in paid sex acts with Backpage customers who responded to the 

ads. The ads the girls posted included pictures of them on a bed 

showing their buttocks. Another image featured a naked girl’s body 

pressed against a mirror. Other pictures appeared more mundane, such 

as images of girls posing clothed in front of a mirror. However, 

these ads used phrases like “I’m sweet as a treat maybe even sweeter”

and “not a lot need to be said. my pic are 100% real.” In 2017, this 

pimp was convicted of Federal sex trafficking charges and sentenced 

to 300 months in prison.

d. In or around 2010, in Washington, J.S., a minor girl, was 

sold for sex through the use of Backpage ads. J.S.’s pimp drafted 

the ads, which contained words and phrases such as, 

“W’E’L’L_W’O’R’T’H_I’T***^***150HR” and “IT WONT TAKE LONG AT ALL.” 

The ads included pictures of J.S. in provocative positions showing 

her breasts and buttocks. On March 29, 2011, the pimp who sold J.S. 

for sex was sentenced to over 26 years’ imprisonment on Federal 

charges related to sex trafficking.

e. Between 2011 and 2016, a female victim, D.O., who was 

between the ages of 14 and 19 during those years, was sold for sex 

through Backpage ads. D.O.’s female pimp instructed D.O. that 

Backpage was the safest place to advertise because Backpage did not 

require age verification. D.O.’s Backpage ads included words and 

phrases that were indicative of prostitution, such as “roses” (money) 

and “back door” (anal sex). Some of the customers who responded to 

D.O.’s Backpage ads forced D.O. to perform sexual acts at gunpoint, 

choked her to the point of having seizures, and gang-raped her.

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126. Plaintiff alleges that all levels of Backpage management, 

including the Backpage Operators, were aware of Backpage’s role in 

promoting criminal activity. For example:

a. On September 21, 2010, a group of state attorneys general 

(“AG”) wrote a letter to Backpage observing that “ads for 

prostitution-including ads trafficking children-are rampant on the 

site,” and arguing that “[b]ecause Backpage cannot, or will not, 

adequately screen these ads, it should stop accepting them 

altogether.” The state AGs acknowledged that this step would cause 

Backpage to, “lose the considerable revenue generated by the adult 

services ads,” but stated that “no amount of money can justify the 

scourge of illegal prostitution, and the misery of the women and 

children who will continue to be victimized in the marketplace 

provided by Backpage.” 

b. Also in mid-September 2010, Ferrer wrote an email

explaining that Backpage was unwilling to delete ads that included 

terms indicative of prostitution because doing so would “piss[] off a 

lot of users who will migrate elsewhere,” and force Backpage to 

refund those customers’ fees.

c. In January 2017, the U.S. Senate Subcommittee on Permanent 

Investigations (“Subcommittee”) conducted a lengthy investigation 

into sex trafficking and Backpage, resulting in a 50-page report 

entitled “Backpage.com’s Knowing Facilitation of Online Sex 

Trafficking.” The report concluded, among other things, that 

virtually all of Backpage’s “adult” ads were actually solicitations 

for illegal prostitution services and that “Backpage [] maintained a 

practice of altering ads before publication by deleting words, 

phrases, and images indicative of criminality, including child sex 

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trafficking . . . . Those practices served to sanitize the content 

of innumerable advertisements for illegal transactions-even as 

Backpage represented to the public and the courts that it merely 

hosted content others had created.” In response to the 

Subcommittee’s report, Backpage purported to shut down the “adult”

section of its website. However, a review of several thousand 

Backpage ads demonstrated that the prostitution ads simply migrated 

to other sections of the website, where they remained accessible 

until the site was forced to shut down.

d. On August 5, 2011, Backpage received a letter from the 

mayor of Seattle. This letter warned, “Seattle Police have 

identified an alarming number of juvenile prostitutes advertised on 

Backpage.com since January 2010,” and explained that Backpage was 

dissimilar from other companies whose products and services are 

“occasionally or incidentally” utilized by criminals because “[y]our 

company is in the business of selling sex ads” and “your services are 

a direct vehicle for prostitution.” The letter recommended that 

Backpage require in-person age verification for all of the “escorts”

depicted in its ads. Backpage never instituted an in-person age 

verification requirement.

127. Backpage instituted and maintained policies and procedures 

designed to cultivate and sustain its promotion of sex trafficking 

and prostitution, but which “sanitized” some of the language Backpage 

customers used to advertise in order to make the advertising of sex 

trafficking less overt. Backpage referred to this practice as

“moderation.” For example:

a. In April 2008, Ferrer wrote an email explaining that, 

although he (Ferrer) was “under pressure to clean up Phoenix’s adult 

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content,” he was unwilling to delete prostitution ads because doing 

so “would put us in a very uncompetitive position with craig[slist]”

and result in “lost pageviews and revenue.” Ferrer instructed 

Backpage’s technical staff to edit the wording of such ads by 

removing particular terms that were indicative of prostitution, but 

allow the remainder of the ad to be featured on Backpage’s website.

b. On October 8, 2010, a Backpage manager sent an email to 

certain Backpage employees and managers threatening to fire any 

Backpage employee who acknowledged, in writing, that a customer was 

advertising prostitution: “Leaving notes on our site that imply that 

we’re aware of prostitution, or in any position to define it, is 

enough to lose your job over. . . . This isn’t open for discussion. 

If you don’t agree with what I’m saying completely, you need to find 

another job.” 

c. On October 16, 2010, the same Backpage manager sent an 

email to a large group of Backpage employees that contained two 

attachments providing guidance on how to “moderate” ads. The first 

was a PowerPoint presentation that displayed a series of 38 nude and 

partially-nude photographs, some of which depicted graphic sex acts. 

Next to each picture was an instruction as to whether it should be 

approved or disapproved by a Backpage moderator. These instructions 

included “Approve. Nude rear shots are okay as long the model is not 

exposing her anus or genitalia.” and “Approve. Rear shot okay. 

Transparent wet panties okay.” The second attachment was an Excel 

spreadsheet identifying 50 terms (all of which were indicative of 

prostitution) that should be “stripped” from ads before publication. 

The Backpage manager concluded the email by stating, “[I]t’s the 

language in ads that’s really killing us with the Attorneys General. 

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Images are almost an afterthought to them.”

d. On October 16, 2010, the same Backpage manager sent an 

internal email explaining, “I’d like to still avoid Deleting ads when 

possible;” “we’re still allowing phrases with nuance;” and “[i]n the 

case of lesser violations, editing should be sufficient.”

e. On October 25, 2010, Ferrer sent an email to Padilla 

acknowledging that the “[i]llegal content removed” through Backpage’s 

moderation processes was “usually money for sex act.” This email 

also explained that, after the “sex act pics are removed,” the “ad 

text may stay.” 

f. On October 27, 2010, a different Backpage manager sent an 

internal email stating that Backpage was “editing 70 to 80%” of the 

ads it received from customers. 

g. On June 7, 2011, Ferrer received an inquiry from a law 

enforcement official about a particular ad that included the term 

“amber alert.” In response, Ferrer acknowledged this might be “some 

kind of bizarre new code word for an under aged person.” Ferrer then 

forwarded this exchange to a Backpage manager and instructed that the 

term “amber alert” be added to Backpage’s “strip out” list. 

h. On August 31, 2011, Backpage managers exchanged emails in 

which they discussed a list of 100 “solid sex for money terms.” 

Later emails indicate that this list of terms changed but, in 

general, the list prohibited use of certain terms that Backpage 

management and employees closely identified with the obvious 

promotion of sex trafficking and prostitution. 

i. One Backpage manager acknowledged in the August 31, 2011 

email exchange that a large proportion of the ads originally 

submitted by Backpage’s customers contained text and pictures that 

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were indicative of sex trafficking. Nevertheless, Backpage published 

those ads after editing them to appear less obvious in promoting 

illegal activity. Backpage sex trafficking ads adapted to Backpage’s 

moderation policy by using “phrases with nuance” when promoting sex 

trafficking. Following the implementation of “moderation,”

Backpage’s list of prohibited terms changed and evolved over time to 

adjust to Backpage advertisers’ use of new code words to promote 

prostitution. In other words, once a code word or phrase not 

previously associated with sex-for-money became too familiar, or was 

deemed too closely associated with certain sex trafficking activities 

in the Backpage community of advertisers, Backpage’s “moderation”

policy would be adapted by adding such words or phrases to the 

“blocked” list or risk being too obvious in its promotion.

128. Plaintiff alleges that Backpage’s policy of “moderation”

only caused ads explicitly promoting sex trafficking to become more 

coded and implicit in the ads’ purpose. 

a. Well over half of the Backpage classified ads in various 

Backpage categories used terms and phrases (including “massage,”

“dating,” “escort” and others) that are consistent with sex 

trafficking and prostitution. These terms and phrases included, 

“roses” (money, e.g., “150 roses/half hour”), “in-call” (where the 

customer goes to the prostitute’s location), “outcall” (where the 

prostitute goes to the customer’s location), “GFE” (girlfriend 

experience), and “PSE” (porn star experience). 

b. Other Backpage ads used language that was mostly free of 

coded language, but included sexually provocative images. The 

sexually suggestive images included in these ads were typical of ads 

for prostitution. For example, one such ad posted in Backpage’s Los 

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Angeles dating section depicted images of a woman on a bed with her 

buttocks presented in a sexual manner; another included a picture of 

a woman’s cleavage; others included pictures of women posing in 

sexual positions wearing lingerie and pictures of a woman bending 

over, revealing her naked buttocks.

c. Backpage’s policy of moderation had the effect of causing 

and allowing otherwise neutral or innocuous terms to be understood 

within the Backpage community as coded language for sex trafficking 

and prostitution. Because of the evolving use of coded terms, a 

reader of such ads who was familiar with the particular vocabulary 

used in Backpage “adult” ads could readily identify coded terms and

images indicating an ad for prostitution, while an uninitiated reader 

may not understand these terms at all, or at least not as being 

associated with sex-for-money.

129. Almost all “adult”-type Backpage ads listed phone numbers 

or emails that a potential customer could use to make contact with 

the advertiser. Comparing a sample of phone numbers and emails found 

within Backpage ads with phone numbers and emails that were 

frequently included in the memo sections of checks that Backpage 

advertisers use to pay Backpage for ads, revealed that the same 

numbers and/or email addresses appeared in multiple Backpage ads as 

contact information. For example:

a. A $25 USPS Money Order purchased on June 15, 2017, in 

Duarte, California, made payable to “Posting Solutions PO BOX 802426, 

Dallas, TX,” and thereafter deposited into Account 1, bore a notation

listing a phone number and the words “Dulce Latina.” A search of 

Backpage ads showed almost 800 advertisements listing the same phone 

number.

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b. A $20 USPS Money Order purchased in Sacramento, California, 

and later deposited into Account 1, bore a notation listing a phone 

number and the words “love my lips.” A search of Backpage ads 

revealed almost 1300 advertisements listing the same phone number.

c. A $150 Wells Fargo Bank Money Order, purchased in Arizona, 

and made payable to “Posting Solutions,” bore an email address and 

the words, “red hot stuff.” The same email address was found to be 

associated with advertisements on several female escort websites that 

directed customers to contact an Arizona phone number ending in 2397. 

A search of Backpage.com for this phone number revealed approximately 

760 ads that included this phone number. These Backpage ads included 

images indicative of prostitution. For example, one such ad posted 

on Backpage’s “massage” section included sexual images such as a 

woman lying on a bed wearing lingerie and a woman laying naked on her 

stomach. One of the ads described, “Pampering provider | Body Rub 

Massage | Body Shampoo | Body Scrub | 4 hands | Walk ins or 

appointment.” Legal massage advertisements do not typically depict 

sexual images. This advertisement depicted sexual images and 

included terms like “4 hands,” which is coded language describing a 

massage given to a customer by two women. Such advertisements are 

indicative of prostitution.

130. The Backpage ads that shared the same phone number or email 

address typically also included sexually suggestive images of 

different women. Such ads are consistent with ads posted by pimps or 

prostitution agencies that are using the same phone number or email 

to advertise different women (or girls) to prospective prostitution 

clients.

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B. Payments for Advertising on Backpage

131. In order to post an ad on Backpage, an advertiser had to 

pay Backpage by one of several methods, including check, cash, and, 

until about 2015, credit card payments processed through U.S. credit 

card payment processors. The proceeds from these ads, the vast 

majority of which were sexually explicit in nature, would then be 

deposited into various Backpage owned or controlled bank accounts. 

For example, Backpage’s U.S. Bank account ‘1165, originated in or 

about April 2010, received several million dollars from the revenue 

generated from the sale of ads, including ads promoting the 

trafficking of minors and illegal prostitution. 

132. However, in or around 2015, following negative publicity 

associated with Backpage, some of the major credit card companies 

enacted what Backpage Operators termed a “blockade.” Essentially, 

these companies refused to process credit card payments directed to 

Backpage. In order to circumvent the blockade, Ferrer and other 

Backpage Operators set up agreements with foreign persons and 

partners to “franchise” websites for the sole purpose of accepting 

credit card payments outside of the United States, with the funds 

being funneled to Backpage. 

133. Also in or around 2015, in response to the blockade, 

Backpage designed a mechanism to allow advertisers to buy Backpage 

“credits,” which could be accomplished in several ways, including: 

a. Mailing gift cards, checks, or money orders to “Posting 

Solutions” at a P.O. Box in Dallas, Texas;

b. Using a credit card to buy credits through a third-party 

credit card payment processor;

c. Paying with digital currency (specifically, Backpage 

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accepted Bitcoin, Bitcoin Cash, Litecoin, and Ethereum). If the 

advertiser selected this option, Backpage provided a digital currency 

wallet address where the advertiser could send the electronic 

transfer of the digital currency; and

d. Paying with currency through a third party payment 

processor. Once the third-party payment processor received the 

currency, it would convert it to digital currency and then 

electronically transfer that digital currency to a Backpage digital 

currency wallet.

134. Digital Currency was processed through the defendant

accounts in the following way:

a. When Backpage received digital currency, it would aggregate 

the digital currency and transfer it to a third-party exchanger like 

GoCoin;6

b. In exchange for the digital currency, the exchanger would 

transfer U.S. dollars from its foreign bank account(s) into Backpage 

operating accounts in the United States or elsewhere. The exchanger 

could then sell its Bitcoin on various Bitcoin markets.

135. Bitcoin payments for ads have resulted in the trafficking 

of minors for sex. For example:

a. On September 6, 2015, a Bitcoin account associated with the 

owner of the email address later convicted of having trafficked 

minors for sex paid Backpage about $4 worth of Bitcoin in order to 

post an ad promoting the trafficking of certain victims in Palm 

6 GoCoin is a digital currency exchanger that converts Bitcoin 

and another digital currency into fiat currency, like the U.S. Dollar 

or the Euro. GoCoin is owned by Manx Broadcasting Corporation, based 

in the Isle of Man. GoCoin has offices in Singapore and Santa 

Monica, California, and GoCoin holds bank accounts in several 

countries, most or all of which are outside the United States. 

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Springs, California.

b. On September 15, 2015, an email from the same email address 

owner indicated a payment to Backpage of about $8 worth of Bitcoin in 

order to “Fund Account”7 for palmsprings.backpage.com. 

c. On October 6, 2015, the same email address owner paid 

Backpage about $1 worth of Bitcoin to “Fund Account” on 

palmsprings.backpage.com. 

d. On October 30, 2015, a Bitcoin account associated with the 

owner of the email address who trafficked minors for sex paid 

Backpage about $1 worth of Bitcoin in order to post an ad promoting 

the trafficking of certain victims in Columbus, Ohio.

e. On November 2, 2015, this same email address owner paid 

Backpage about $1 worth of Bitcoin to “Move Ad to Top of Listings” in 

the Columbus, Ohio Backpage ads; and

f. On November 21, 2015, this same email address owner paid 

Backpage about $1 worth of Bitcoin to Backpage for credit for that 

email owner’s Backpage ad account. 

136. Plaintiff contends that five to ten percent of the ads 

posted on Backpage.com were placed within the Central District of 

California (including Los Angeles and Orange Counties). Between 

January 10 and February 3, 2016, approximately 500,000 ads were 

posted on Backpage.com and paid for with Bitcoin, for which Backpage 

received over $3,840,000 in revenue. Of these approximately 500,000 

ads, approximately 28,400 were posted only in 

LosAngeles.Backpage.com, Ventura.Backpage.com, 

SanLuisObispo.Backpage.com, OrangeCounty.Backpage.com, and 

7 The email address owner provided Bitcoin to Backpage as a 

“Fund Account” payment, that is, payment to Backpage as credit to be 

used later to pay for Backpage ads.

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SanGabrielValley.Backpage.com. These specific ads generated 

approximately $184,479 in revenue.

137. When an advertiser (or “poster”) purchased an ad for 

prostitution using digital currency, the payment to Backpage (and 

certain subsequent expenditures) proceeded in the following manner:

a. A poster would choose a payment method online (e.g., 

through Bitcoin payments);

b. If the poster did not already have Bitcoin, the Backpage 

website would direct the poster to a third-party exchanger to buy 

Bitcoin;

c. Backpage would then provide the poster with a wallet 

address to send a specific amount of Bitcoin;

d. In return for sending the required payment, the poster 

would receive credit that could be used to post ads on Backpage.

e. Backpage would sell the Bitcoin to a third party exchanger, 

frequently GoCoin, in batches generally valued in hundreds of 

thousands of dollars, in order to convert the Bitcoin into U.S. or 

foreign flat currency, which GoCoin generally, if not always, would 

hold in foreign bank accounts;

f. GoCoin would then wire funds from foreign accounts to 

either (1) Backpage controlled foreign accounts; or (2) Backpage 

controlled operating accounts in the United States; 

g. These accounts were held and controlled by Backpage 

Operators in the names of entities controlled by Backpage, including 

Ad Tech BV, Posting Solutions, Website Technologies, and Cereus 

Properties;

h. The funds derived from these foreign transactions would be 

used by Backpage to pay service providers, like Verizon in Los 

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Angeles, or transferred to Backpage Operators’ accounts and accounts 

held in their family members’ names; and

i. For example:

a. In March 2015, Ad Tech BV, a Netherlands based 

company, listing Ferrer as CEO and M.G. as CFO, opened a bank account 

in the Netherlands (the “Netherlands Account”). M.G. is the 

President, CEO, Treasurer and Secretary of Posting Solutions. From 

March 2015 through November 2017, the Netherlands Account received 

millions of dollars from Binary Trading SG PTE, Limited (“Binary 

Trading”). On April 4, 2017, M.G. sent an email to employees of the 

bank that maintained the Netherlands Account. The email explained:

Binary Capital is our trading partner, they hold money in 

trust for Go Coin [sic]. Rather than incurring 3 sets of 

wire fees which make our transactions unprofitable, they 

act as our agent and disburse payments directly from our 

trust account to our merchant.

b. For the period of September 4 through November 23, 

2015, Backpage advertisers used Bitcoin to purchase about 1,000,000 

“adult” ads from Backpage. Backpage then sold those Bitcoin to 

GoCoin for approximately $8.6 million. Included among the Bitcoin

sold to GoCoin during this period were payments that pimps made to 

Backpage in order to purchase ads to promote child prostitution.

c. For the period of December 14, 2015, through August 

30, 2016, in approximately 154 wires, GoCoin accounts held in 

Slovakia (the “Slovakia Account”) and Singapore (the “Singapore 

Account”) transferred a total of approximately $26,100,235.83 to 

Branch Banking & Trust account ‘2008, in Plano, Texas, owned by 

Website Technology (“Website Tech Account ‘2008”). On January 15, 

2016, the Website Tech Account ‘2008 transferred $189,571 to Verizon 

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in Los Angeles, California, in payment for Backpage internet 

services. 

d. Between January 21 and August 31, 2016, Website Tech 

Account ‘2008 sent approximately 27 wire transfers totaling 

approximately $48,000,000 to Arizona Bank & Trust account number 

‘6211, belonging to Cereus Properties LLC, which is owned or 

controlled by Spear, Backpage, and/or other Backpage Operators. 

C. Bank Accounts Funded with Proceeds Traceable to SUA, 

Involved in Money Laundering, or Both

138. Between December 14, 2015, and February 9, 2017, a 

coordinated series of wire transfers were completed transferring 

criminal proceeds from Backpage-controlled bank accounts to four 

separate bank accounts at the USAA Savings Bank. All the USAA 

Savings Bank accounts were held in the name of different living 

trusts with the common factor of Hawkins being one of the Trustees on 

all four accounts. Hawkins is the sister-in-law of Larkin.

139. Criminal proceeds deposited with a company doing business 

for GoCoin initiated wire transfers of the criminal proceeds from the 

Slovakia account to Website Tech Account ‘2008 in the United States.

140. Website Tech Account ‘2008 then initiated wire transfer of 

the criminal proceeds to Arizona Bank & Trust Account number ‘6211 

(“AZBT ‘6211”), belonging to Cereus Properties LLC.

141. On January 4, 2017, AZBT ‘6211 initiated four wires:

a. $33,591.34 to Charles Schwab account ‘6039 held in the name 

of Oaxaca Living Trust with Kathleen D. Larkin as the sole 

beneficiary (“Schwab ‘6039”);

b. $33,591.34 to Charles Schwab account ‘9083, held in the 

name of Puebla Living trust with Rose L. Larkin as the sole 

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beneficiary (Schwab ‘9083”);

c. $33,591.34 to Charles Schwab account ‘7249, held in the 

name of Cuernavaca Living Trust with Quinn M. Larkin as the sole 

beneficiary (“Schwab ‘8628”); and

d. $33,591.34 to Charles Schwab account ‘8628, held in the 

name of Chiapas Living trust with John C. Larkin as the sole 

beneficiary (“Schwab ‘8628”).

142. Several days after the criminal proceeds were deposited 

into the four Charles Schwab accounts, they were then transferred to 

four AZBT accounts. 

a. On January 10, 2017 Schwab ‘6039 wired $840,692.69 to 

Arizona Bank & Trust account ‘3835, held in the name of Oaxaca Living 

Trust UTA with Lacey and Hawkins as the Trustees and Kathleen 

Dewhurst Larkin as the beneficiary (“AZBT ‘3835”);

b. On January 11, 2017 Schwab ‘9083 wired $840,672.72 to 

Arizona Bank & Trust account ‘3864 held in the name of Puebla Living 

Trust UTA with Lacey and Hawkins as the Trustees and Rose Lyons 

Larkin as the beneficiary (“AZBT ‘3864”);

c. On January 12, 2017 Schwab ‘7249 wired $840,672.70 to 

Arizona Bank & Trust account ‘3859 held in the name of Cuernavaca 

Living Trust UTA with Lacey and Hawkins as the Trustees and Quinn 

McCarthy Larkin as the beneficiary (“AZBT ‘3859”); and

d. And on January 10, 2017 Schwab ‘8628 wired $840,672.70 to 

Arizona Bank & Trust account ‘3840 held in the name of Chiapas Living 

Trust UTA with Lacey and Hawkins as the Trustees and John Carey 

Larkin as the beneficiary (“AZBT ‘3840”).

143. On January 11, 2018, and in addition to the previous wire 

transfers, AZBT ‘6211 transferred $33,591.34 to each of the Living 

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Trust accounts, AZBT ‘3835, AZBT ‘3864, AZBT ‘3859, and AZBT ‘3840.

144. On February 9, 2017, the four Oaxaca Living Trust account, 

AZBT ‘3835, AZBT ‘3864, AZBT ‘3859, and AZBT ‘3840, wire transferred 

approximately $874,330 to:

a. USAA Savings Account ‘2155 (“USAA ‘2155” or “Account 59”);

b. USAA Savings Account ‘2058 (“USAA ‘2058” OR “Account 60”);

c. USAA Savings Account ‘2171 (“USAA ‘2171” or Account 61”); 

and

d. USAA Savings Account ‘1507 (“USAA ‘1507” or Account 62”).8

D. Bases for Forfeiture

145. The Defendant Assets constitute, and are derived from, 

proceeds traceable to one or more violations of 18 U.S.C. §§ 1591 

(Sex Trafficking of Children), and/or 1952 (Interstate and Foreign 

Travel in Aid of Racketeering Enterprise), each of which is SUA under 

18 U.S.C. § 1956(c)(7)(A), and a conspiracy to commit such offenses. 

146. The Defendant Assets were involved in, and are traceable to 

property involved in, one or more transactions or attempted 

transactions in violation of 18 U.S.C. § 1956(a)(1)(B)(i) and a 

conspiracy to commit such offenses, in violation of 18 U.S.C. 

§ 1956(h). Specifically, the Defendant Assets were involved in and 

are traceable to property involved in one or more financial 

transactions, attempted transactions, or a conspiracy to conduct or 

attempt to conduct such transactions involving the proceeds of 

specified unlawful activity, that is, 18 U.S.C. §§ 1591 and 1952, and 

were designed in whole or in part to conceal or disguise the nature, 

8 Accounts 59, 60, 60, and 62, are all held in the name of Anne 

Hawkins, a sister-in-law to Larkin, and were funded with proceeds 

alleged to have been traceable to SUA, involved in money laundering, 

or both.

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location, source, ownership or control of the proceeds of the SUA in 

violation of 18 U.S.C. § 1956(a)(1)(B)(i). 

147. The Defendant Assets were involved in, and are traceable to 

property involved in, one or more transactions or attempted 

transactions in violation of 18 U.S.C. § 1957, or a conspiracy to 

commit such offenses, in violation of 18 U.S.C. § 1956(h). 

Specifically, the Defendant Assets were involved in and are traceable 

to property involved in one or more financial transactions, attempted 

transactions, or a conspiracy to conduct or attempt to conduct such 

transactions in criminally derived property of a value greater than 

$10,000 that was derived from SUA, that is, 18 U.S.C. §§ 1591 and 

1952.

IV. Assets Representing, Traceable To, and Involved In 

Specified Unlawful Activity

A. Account 1 (Prosperity ‘7188 Funds)

148. On February 15, 2017, Posting Solutions opened Account 1. 

M.G. is the sole signatory on the account (as described above, 

Posting Solutions is wholly owned by and controlled by Backpage).

149. The application for the P.O. Box identifies the renter of 

the box as “Website Technologies, LLC/Backpage.com.” Listed on the 

Application were the names of several Backpage Operators, including 

Ferrer.

150. Between August 1 and September 1, 2017, Account 1 received 

more than $2,781,750 in wire transfers from foreign banks. For 

example:

a. On or about August 16, 2017, Binary Trading wired $535,500 

from an account in Singapore into Account 1; 

b. On or about August 17, 2017, Binary Trading wired $528,500 

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from a Singapore account into Account 1; and

c. On or about August 30, 2017, a company named Trilix PTE LTD 

(“Trilex”), listing the same Singapore address as Binary Trading and 

GoCoin, sent four wire transfers from the Singapore account into 

Account 1, ranging from $385,450 to $492,250, totaling approximately 

$1,717,750. 

151. Plaintiff alleges that a substantial percentage of outgoing 

payments from Account 1 have been payments for the operation of 

Backpage.com. For example, between July and October 2017, funds were 

wired from Account 1, as following:

a. $570,530 to Verizon Digital Media Services in Los Angeles 

for services related to the Backpage.com website; and 

b. $1,497 to “Backupify,” a company that provided data backup 

services for Backpage.

CEREUS PROPERTIES ASSETS

B. Account 2 (Compass ‘3873 Funds)

152. Account 2 was held in the name of Cereus Properties LLC., 

and Spear was the sole signatory. This account was funded in part 

with transfers from Account 1, which funds are alleged to have been 

traceable to SUA, involved in money laundering, or both, and was used 

as a funnel account to pay Backpage Operators. On average, during 

each month of 2017, several hundred thousand dollars were transferred 

from Account 1 to Account 2. For example:

a. On August 31, 2017, Account 1 sent a wire transfer totaling 

$487,491.45 to Account 2;

b. On September 15, 2017, Account 1 sent a wire transfer 

totaling $91,672.67 to Account 2; and

c. On October 2, 2017, Account 1 sent a wire transfer totaling 

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$471,766 to Account 2. 

153. Funds from Account 2 were also used to promote and 

facilitate prostitution. For example: 

a. On December 2, 2016, the Netherlands Account transferred 

$324,055.85 to Account 2;

b. On December 8, 2016, the Netherlands Account transferred 

$499,970.00 to Account 2;

c. On December 27, 2016, the Netherlands Account transferred 

$199,970.00 to Account 2; and

d. From March to December 2017, Account 2 paid over $9,000 to 

“Cox Communications,” an internet services company that Backpage used 

to facilitate its internet presence and promote its sale of 

prostitution advertising.

C. Account 3 (Compass ‘4862 Funds)

154. Account 3, held in the name of Cereus Properties, was 

funded with transfers from foreign and domestic banks, which funds 

were traceable to SUA, involved in money laundering, or both, 

including funds transferred from the Netherlands Account through one

of the Backpage Operators’ go-between accounts9 (Wells Fargo Bank 

account ‘9863 (“Account ‘9863”)), and eventually funneled into 

Account 3. 

9 A “go-between” (a.k.a., a “pass-through”) is an account set up 

for the main purpose of transferring funds from one or more bank 

accounts to various other bank accounts, frequently as an attempt to 

further conceal the true source and nature of the funds.

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MICHAEL LACEY ASSETS10

D. Account 4 (FFS&L of SR ‘3620 Funds)

155. Account 4, held in the name of Lacey, was funded with 

transfers from foreign and domestic banks, which funds were traceable 

to SUA, involved in money laundering, or both. On October 2, 2017, 

Account 24 (which was itself funded with transfers from foreign and 

domestic banks with proceeds traceable to SUA, involved in money 

laundering, or both), transferred $297,795 into Account 4, as further 

described below.

E. Accounts 5, 7-10 (RBA ‘2485, ‘3126, ‘8316, ‘8324, and 

‘8332)

156. Accounts 5 and 7, each held in the name of Lacey, were 

funded with transfers from foreign and domestic banks, which funds 

were traceable to SUA, involved in money laundering, or both. 

Backpage Operators used Accounts 5 and 7 as pass-through accounts.

a. On May 31, 2017, Account 2 transferred approximately 

$676,808.04 into Account 5;

b. Between September 20, 2017 and December 8, 2017, Account 

‘9863 transferred approximately $944,729.25 among seven transaction

into Account 3. 

c. On December 13, 2017, Account 3 transferred approximately 

$428,645.09 into Account 5. 

d. On March 16, 2018, Account 3 transferred approximately 

$212,066.52 into Account 5. 

e. On April 6, 2018, Lacey personally went into the Republic 

10 On March 20, 2020, pursuant to a stipulation, this Court 

entered a consent judgment returning approximately $450,376.48 to 

Michael Lacey and Jill Anderson (see ECF No. 99, 2:18-cv-06742-RGKPJW). As a result, those funds are not included in this Amended 

Consolidated Complaint.

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Bank of Arizona, withdrew $500,000 from Account 5, and then used that 

$500,000 as the initial deposit to open Account 7; and

f. On October 2, 2017, Account 2 made two transfers:

i. $297,795.54 transferred to Account 4; and

ii. $694,856.25 wired to Account 11.

g. On or about February 15, 2018, Lacey drafted two $600,000 

checks (totaling $1.2 million). One check was drawn from Account 11, 

and the second was drawn from Account 4. These two checks were used 

to fund Accounts 8, 9, and 10, respectively, with $600,000.00, 

$300,000.00, and $300,000.00.

F. Account 11 (SFFCU ‘4S10 Funds)

157. Account 11 is held in the name of Lacey and an individual 

listed in the Credit Union’s records as Lacey’s employee and 

bookkeeper. Account 11 was funded with proceeds alleged to have been 

traceable to SUA, involved in money laundering, or both.

a. On February 2, 2018, Account 2 (which then contained funds 

traceable to SUA, involved in money laundering, or both) transferred 

$734,602.70 into Account 11.

G. Account 12 (IOLTA ‘4139)

158. Account 12 was an IOLTA held for the benefit of Lacey, and 

was funded with proceeds traceable to SUA, involved in money 

laundering, or both.

159. On January 4, 2017, the Singapore Account wired $489,500

into a Posting Solutions controlled account held at Veritex Bank (the 

“Veritex Account”). On January 20, 2017, the Singapore Account 

directed two additional wires, for $358,150 and $470,150

respectively, into the Veritex Account. In total, the Singapore 

Account transferred $1,317,800 into the Veritex Account.

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a. On or about February 23, 2017, the Veritex Account directed 

two payments to Account 2, a wire of $443,014, and a check for 

$27,887.41;

b. Between March 30 and September 14, 2017, Account 2 sent 

five wires totaling $4,058.063.65 to Account 12; and

c. In July 2018, Account 12 was closed and a cashier’s check 

totaling $2,412,785.47 was issued to Lacey’s Annuity Fund, held at 

Account 12.

H. The Sebastopol Property

160. The Sebastopol Property was purchased and maintained, in 

whole or in part, using funds traceable to SUA, involved in money 

laundering, or both.

161. In a series of transactions in December 2016, illicit 

proceeds from the Netherlands Account would pass-through Account 2,

eventually ending up in Account 11. Additionally, between July and 

October 2017, additional illicit proceeds from the Singapore Account 

were passed-through Account 1 to Account 2, and eventually

transferred to Account 11. On or about October 10, 2017, over 

$10,000 of funds from Account 11 were used to support and maintain 

the Sebastopol Property.

162. On February 11, 2016, a grant deed, instrument number 

2016010019 of the Sonoma County official records, transferred the 

Sebastopol Property to Lacey. Thereafter, on April 24, 2017, for no 

consideration, Lacey transferred title of the Sebastopol Property to 

his Delaware limited liability company, Sebastopol, LLC. As noted in 

the grant deed: 

“There was no consideration for this transfer. This is a 

transfer between an individual or individuals and a legal 

entity or between legal entities that results solely in a 

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change in the method of holding title and in which 

proportional ownership inters in the realty remain the 

same. . .”

163. On October 10, 2017, Lacey issued a $12,956.25 check from 

Account 11 to Sonoma County Tax Collector. The notation on this wire 

was “2043 Pleasant Hill Dr Sebastopol.”

I. San Francisco, California Property 1

164. San Francisco Property 1 was purchased and maintained, in 

whole or in part, using funds traceable to SUA, involved in money 

laundering, or both. 

165. In order to acquire San Francisco Property 1, Lacey used 

funds transferred through the Singapore Account, the Website Tech 

Account ‘2008, and Cereus Properties accounts, as well as annuity 

accounts that Lacey controlled, as follows:

a. Illicit proceeds were deposited into the Singapore Account, 

passed-through Account 1, then passed-through Account 2 and

transferred to Account 11. Thereafter, funds from Account 11 were 

used to support and maintain San Francisco Property 1;

b. On May 18, 2016, a grant deed recorded as instrument number 

2016-K245482-00 in the San Francisco County official records, 

transferred San Francisco Property 1 to Lacey and his female partner; 

and 

c. Thereafter, on October 10, 2017, over $10,000 in funds from 

Account 11 were used to purchase or maintain San Francisco Property 1.

J. San Francisco Property 2

166. San Francisco Property 2 was purchased and maintained, in 

whole or in part, using funds traceable to SUA, involved in money 

laundering, or both.

167. During the period of December 14 through December 29, 2015, 

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as GoCoin’s partial payment for the Bitcoin Backpage sold it during 

the period of September 4 through November 23, 2015, the Slovakia 

Account wired over $1,250,000 to Website Tech Account ‘2008. 

168. After December 14, 2015, Website Tech Account ‘2008 then 

transferred funds via multiple pass-through accounts controlled by 

Lacey and other Backpage Operators, which, as of June 21, 2016, 

resulted in approximately $5,400,000 ending up in Arizona Bank & 

Trust account ‘1793, controlled by Lacey (“AB&T Account ‘1793”). 

169. On June 27, 2016, AB&T Account ‘1793 wired $397,500.00 to 

Fidelity National Title Company. The notation on this wire was 

“XXX(Earnest Money)XXXXXX.” On July 20, 2016, AB&T Account ‘1793 

wired $12,859,152.57 to Fidelity National Title Company. The 

notation on this wire was “XX(Balance of Property)XXXXX.”

170. Casa Bahia for San Francisco, LLC, a Delaware limited 

liability company, was the entity used to take title to the San 

Francisco Property 2, and is owned by Lacey. On July 21, 2016, by 

grant deed, San Francisco Property 2 was transferred to Lacey. On 

June 21, 2017, by grant deed and for no consideration, Lacey

transferred San Francisco Property 2 to Casa Bahia for San Francisco, 

LLC, a Delaware limited liability company, as evidenced by instrument 

number 2017-K466276099 recorded in the San Francisco County official 

records. As noted in the grant deed:

There was no consideration for this transfer. This is a 

transfer between an individual or individuals and a legal 

entity or between legal entities that results solely in a 

change in the method of holding title and in which 

proportional ownership inters in the realty remain the 

same. . .

K. San Francisco Property 3 

171. San Francisco Property 3 was purchased and maintained, in 

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whole or in part, using funds traceable to SUA, involved in money 

laundering, or both.

172. Beginning in February 2013, illicit funds from Backpage’s 

U.S. Bank account ‘1165 passed-through various Backpage or Backpage 

Operators accounts, eventually ending up in BMO Harris account ‘5263, 

owned or controlled by Lacey. In May 2015, over $10,000 of funds 

from BMO Harris account ‘5263 was used to purchase or maintain San 

Francisco Property 3. 

L. Sedona Property 

173. The Sedona Property was purchased and maintained, in whole 

or in part, using funds traceable to SUA, involved in money 

laundering, or both.

174. In October 2017, Account 2 wired approximately $297,795 to 

Account 4. On November 13, 2018, $6,725.54 from Account 4 was used 

to support or maintain the Sedona Property. 

M. Paradise Valley Property 2

175. Paradise Valley Property 2 was purchased and maintained, in 

whole or in part, using funds traceable to SUA, involved in money 

laundering, or both.

176. In 2005, for approximately $1,500,000, Lacey purchased the 

Paradise Valley Property 2. In 2010, the Paradise Valley Property

was used as collateral for a $1 million loan (the “2010 Loan”). 

Beginning no later than January 2012, illicit proceeds were used to 

service the debt on the 2010 Loan. Specifically:

a. Between February 4 and June 6, 2013, through a series of 

wire transfers, Backpage’s U.S. Bank account ‘1165 transferred 

approximately $41,500,000 to BMO Harris Bank account ‘5263; and 

b. Between March 2013, and January 2016, through a series of 

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periodic transactions, approximately $174,749.39 from BMO Harris Bank 

account ‘5263 was used to service the debt on the 2010 Loan. 

JAMES LARKIN ASSETS11

N. Accounts 13, 15, 16, 17, AND 18 (RBA ‘1889, ‘2592, ‘8103, 

‘8162, AND ‘8189)

177. Account 13, held in the name of Larkin, was funded with 

proceeds alleged to have been traceable to SUA, involved in money 

laundering, or both.

a. On July 6, 2017, Account 2 transferred $971,651.51 into 

Account 13; and

b. On July 28, 2017, Account 13 transferred $400,000 into 

Account 14.

178. Account 15 is held in the name of Larkin. 

a. From March 2015 through November 2017, the Netherlands 

Account received several millions of dollars in criminal proceeds 

from Binary Trading;

b. On December 2, 2016, the Netherlands Account transferred 

$324,055.85 to Account 2;

c. On December 8, 2016, the Netherlands Account transferred 

$499,970.00 to Account 2;

d. On December 27, 2016, the Netherlands Account transferred 

$199,970.00 to Account 2, which account then transferred funds 

through Account ‘9863 and into Account 3; and

e. On December 13, 2017, Account 3 transferred $406,211.10 to 

Account 15.

179. Account 16, 17, and 18 are CDARS Accounts held in the name 

11 On January 13, 2020, pursuant to a stipulation, this Court 

entered a consent judgment returning approximately $206,163.88 to 

James Larkin (see ECF No. 65, 2:18-cv-8420-RGK-PJW). As a result, 

those funds are not included in this Amended Consolidated Complaint.

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of Larkin.

a. On July 28, 2017, Account 13 transferred $400,000 into 

Account 14; and

b. On or about February 8, 2018, $1 million in funds from 

Account 14 was used to fund Account 16 (which received $500,000), 

Account 17 (which received $250,000), and Account 18 (which received 

$250,000).

O. Accounts 19 AND 20 (PCTC ACCOUNT ‘0012 FUNDS, PERKINS COIE 

‘0012)

180. Account 19 is held in the name of Larkin’s spouse, M.

Larkin, and was funded with proceeds traceable to SUA, involved in 

money laundering, or both. 

a. On December 31, 2015, Website Tech Account ‘2008 

transferred $811,424 to the Slovakia Account; 

b. On January 11, 2016, the Slovakia Account transferred 

approximately $1,300,000 to Charles Schwab account ‘4693, held in the 

name of Larkin (“Charles Schwab Account ‘4693”);

c. On January 14, 2016, Charles Schwab Account ‘4693 

transferred approximately $13,500,000 to Northern Trust Company 

account ‘9562 (under the name “Ocotillo Family Trust,” owned and 

controlled by Larkin and Margaret Larkin);

d. In July 21, 2017, Account ‘9562 transferred $6,014,000 to 

Morgan Stanley account ‘1673 (held in the name of Larkin and Margaret 

Larkin);

e. In or about November 2017, Morgan Stanley elected to 

terminate its business relationship with Larkin; 

f. On November 30, 2017, all the funds then held in Morgan 

Stanley account ‘1673 (about $10,000,000) were transferred to Account 

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19; and

g. Some of the funds in Account 19 were used to purchase bonds 

and/or securities, which were held in Account 20. 

P. Account 21 (ACF ‘2020) 

181. Account 21 contains securities and investment vehicles held 

in the name of Ocotillo Family Trust, which is owned and controlled

by Larkin and his spouse, and was funded with proceeds traceable to 

SUA, involved in money laundering, or both.

a. During the period of March 23 through March 31, 2016, 

Website Tech Account ‘2008 sent three wire transfers totaling 

$3,694,813.60 to Arizona Bank & Trust account number ‘6211, belonging 

to Cereus Properties (“Account ‘6211”);

b. During the period of April 1, 2016, through July 1, 2016, 

Account ‘6211 sent five wire transfers totaling $5,750,294 to Charles

Schwab Account ‘4693;

c. On July 1, 2016, Charles Schwab Account ‘4693 transferred 

$15,000,000 to Account 21;

d. During the period of August 2, 2016, through October 6, 

2016, Account ‘6211 sent six wire transfers totaling $9,550,315 to 

Charles Schwab Account ‘4693;

e. On January 3, 2017, Charles Schwab Account ‘4693 

transferred $2,500,000 to Account 21; and

f. On January 4, 2017, Charles Schwab Account ‘4693 

transferred $2,500,000 Account 21.

Q. Accounts 22 And 23 (BA ‘8225 and ‘7054)

182. Account 22 is held in the name of one of Larkin’s children,

T. Larkin, and was used in furtherance of the money laundering scheme

described herein, and in an attempt to further conceal or disguise 

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the nature, location, source, ownership or control of the criminal

proceeds.

183. On February 2, 2018, Account 2 wire transferred $28,337 

into Account 22.

184. Account 23 is held in the name of R. Larkin. On February 

2, 2018, Account 2 wire transferred $28,337 into Account 23. 

R. Saint Helena Property

185. The Saint Helena Property was purchased and maintained, in 

whole or in part, using funds traceable to SUA, involved in money 

laundering, or both.

186. Between February 4 and June 6, 2013, approximately 

$41,500,000 in illicit funds were transferred to Camarillo Holdings 

LLC, BMO Harris Bank account ‘7172. On October 2, 2013, BMO Harris 

Bank account ‘7172 wired $26,130.64 to Larkin’s BMO Harris Bank 

account ‘3110. Thereafter, on November 3, 2016, over $10,000 of 

funds from BMO Harris Bank account ‘7172 were used to purchase or 

maintain the Saint Helena Property. 

S. Chicago Property 

187. The Chicago Property was purchased and maintained, in whole 

or in part, using funds traceable to SUA, involved in money 

laundering, or both.

188. Illicit funds originating from Backpage’s U.S. Bank account 

‘1165 were passed-through accounts owned or controlled by Backpage or 

Backpage Operators, and ended up in BMO Harris Bank account ‘3110. 

Thereafter, on October 2, 2015, BMO Harris Bank account ‘3110 

transferred $138,000 to Chicago Title and Trust Company as payment 

towards the purchase of the Chicago Property. 

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T. Paradise Valley Property 1 

189. Paradise Valley Property 1 was purchased and maintained, in 

whole or in part, using funds traceable to SUA, involved in money 

laundering, or both.

190. Approximately $41.5 million in illicit funds from 

Backpage’s U.S. Bank account ‘1165 passed through various Backpage or 

Backpage Operators’ accounts. Following these various transfers, 

eventually, on October 2, 2013, a total of approximately $26,130.64 

was transferred into BMO Harris account ‘3110, owned or controlled by 

Larkin. Thereafter, on December 11, 2014, BMO Harris Bank account 

‘3110 paid $46,957.28 to maintain the Paradise Valley property 1.

U. Paradise Valley Property 2

191. Paradise Valley Property 2 was purchased and maintained, in 

whole or in part, using funds traceable to SUA, involved in money 

laundering, or both.

192. Illicit funds originating from Backpage’s U.S. Bank account 

‘1165 were passed-through accounts owned or controlled by Backpage or 

Backpage Operators, and ended up in BMO Harris Bank account ‘3110, 

from which account over $10,000 was paid to maintain Paradise Valley 

Property 2.

JOHN BRUNST ASSETS

V. Account 24 (COMPASS BANK ‘3825)

193. Account 24 is held in the name of Brunst, and was used in 

furtherance of the money laundering scheme described herein, and in

an attempt to further conceal or disguise the nature, location, 

source, ownership or control of the proceeds of SUA. 

194. On February 2, 2018, Account 2 wire transferred $135,956.59 

into Account 24. 

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W. Account 25, 26, 27, 28, 29, 30 (AB ‘6878, ‘4954, ‘7892, 

‘7889, ‘7888 AND ‘6485)

195. Accounts 25, 26, 27, 28, 29, and 30 are held in the name of 

the “Brunst Family Trust.” Brunst and his wife are the sole trustees 

for these accounts, which were funded with proceeds traceable to SUA, 

involved in money laundering, or both.

a. On December 31, 2015, Website Tech Account ‘2008

transferred $811,424 to Account ‘6211;

b. On December 6, 2016, Account ‘6211 transferred $161,459 to 

Wells Fargo Bank account ‘4891, belonging to Brunst (“Account 

‘4891”);

c. On January 4, 2017, Account ‘6211 transferred another 

$298,841 to Account ‘4891;

d. On January 5, 2017, Account ‘4891 transferred $300,000 to 

Wells Fargo Bank account ‘7474, belonging to the Brunst Family Trust

(“Account ‘7474”).

e. On May 19, 2017, Account ‘7474 transferred approximately

$1,500,000 into Account 25;

f. On May 23, 2017, Account 25 transferred approximately 

$350,000 to Account 26;

g. On June 7, 2017, Account 25 transferred approximately 

$1,340,000 to Account ‘0582;

h. On September 13, 2017, Account ‘0582 transferred 

approximately $581,000 to Account 27;

i. On September 13, 2017, Account ‘0582 transferred 

approximately $250,000 to Account 28;

j. On September 13, 2017, Account ‘0582 transferred 

approximately $250,000 to Account 29; and

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k. On September 15, 2017, Account ‘0582 transferred 

approximately $500,000 to Account 30.

SCOTT SPEAR ASSETS

X. Accounts 31, 32, AND 33 (NBA ‘0178, ‘0151, and’3645)

196. Accounts 31 and 32 are held in the name of Spear, which 

accounts were funded with proceeds traceable to SUA, involved in 

money laundering, or both. Account 33 is held in trust for the 

benefit of Spear and certain of his family members, which account was 

funded with proceeds traceable to SUA, involved in money laundering, 

or both. In furtherance of the money laundering scheme, and in an 

attempt to further conceal the true nature of the criminal proceeds, 

go-between accounts served to funnel money from one account to 

another.

a. Between January 21 and August 31, 2016, Website Tech 

Account ‘2008 sent approximately 27 wire transfers totaling 

approximately $48,000,000 to Account ‘6211;

b. Between March 1, 2016, and July 1, 2016, Account ‘6211 

transferred $892,426 into Account 31;

c. On September 14, 2017, Account 2 wire transferred 

$50,162.05 into Account 31; 

d. On October 12, 2017, Account 31 transferred approximately

$21,500 into Account 32; and

e. On January 5, 2018, Account 31 transferred approximately 

$600,000 into Account 33.

Y. Account 34 (Live Oak Bank Account ‘6910)

197. Account 34 is held in the name of Spear, and was funded 

with proceeds traceable to SUA, involved in money laundering, or 

both.

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198. On or about March 16, 2016, as an opening deposit, Account 

31 transferred $250,000 into Account 34. 

Z. Account 35 and 36 (Ascensus Broker Services ‘4301 and’8001) 

199. Accounts 35 and 36 are held in the name of N. Spear, 

Spear’s adult daughter, and were funded with proceeds traceable to 

SUA, involved in money laundering, or both.

a. On February 23, 2017, Account 31 transferred approximately 

$50,000 into Account 35; and

b. On the February 23, 2017, Account 31 transferred $50,000 

into Account 36.

PRIMUS TRUST ASSETS

AA. Account 37 (K&H Bank Account ‘1210)

200. Account 37 is located in Hungary, and held in the name of 

Primus Trust Company for the benefit of Lacey. In furtherance of the 

money laundering scheme, Account 37 was funded with proceeds 

traceable to SUA, involved in money laundering, or both.

201. The tracing of this account involves numerous banks and 

bank accounts, both foreign and domestic. The accounts include: 

Website Tech Account ‘2008; Account ‘6211; Arizona Bank & Trust 

annuity trust account numbers ‘1967, ‘1972, ‘1986, ‘1991, and ‘2014, 

all held in Lacey’s name (“AZBT Annuity Accounts”); and Johnson 

Financial account ‘9992, held in an IOLTA, with Lacey as the sole 

beneficiary.

a. Between December 14, 2015, and January 15, 2016, the

Slovakia Account sent approximately 26 wire transfers totaling over 

$2,500,000 to Website Tech Account ‘2008 in the United States; 

b. On January 15, 2016, Website Tech Account ‘2008 transferred 

$189,571 to Verizon in Los Angeles, California, in payment for 

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Backpage internet services, which served, in whole or in part, to 

promote sex trafficking and illegal prostitution; 

c. Between January 21 and August 31, 2016, Website Tech 

Account ‘2008 sent approximately 27 wire transfers totaling 

approximately $48,000,000 to Account ‘6211;

d. Between April 1 and October 6, 2016, in approximately 12 

wires, Account ‘6211 sent over $18,000,000 to the AZBT Annuity Trust 

Accounts;

e. On December 29, 2016, in five wires, the AZBT Annuity 

Trusts Accounts sent approximately $16,500,000 to Johnson Financial 

account ‘9992; and

f. On January 3, 2017, Johnson Financial account ‘9992 

transferred $16,500,000 to Account 37.

AD TECH BV ASSETS

BB. Accounts 56, 57, and 58 (Fio Bank ‘5803, ‘5801, and ‘5805)

202. Accounts 56, 57, and 58 are located in the Czech Republic 

and held in the name of Ad Tech BV, identifying Ferrer as the 

ultimate beneficial owner, which accounts were funded with proceeds 

traceable to SUA, involved in money laundering, or both.

203. Account 56, 57, and 58 were set up and maintained to 

receive payments for Backpage ads, that is, for “accounts 

receivable.” Merchant processors would accept credit card payments 

and Bitcoin from Backpage advertisers as credit to place ads for 

prostitution and other services. The merchant processors would then 

transfer these funds to accounts set up to receive such payments, 

specifically including Accounts 56, 57, and 58. All funds contained 

within Accounts 56, 57, and 58 are traceable to SUA and involved in 

money laundering.

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CC. Accounts 47, 48, 49 and 50 (BF Accounts ‘000K, ‘000U, ‘000 

, and ‘001K)

204. Accounts 47, 48, 49, and 50 are located in Principality of 

Liechtenstein, and held for the benefit of Ferrer, which accounts 

were funded with proceeds traceable to SUA, involved in money 

laundering, or both.

205. Accounts 47, 48, 49, and 50 were set up and maintained to 

receive payments for Backpage ads, that is, for “accounts 

receivable.” Merchant processors would accept credit card payments 

and Bitcoin from Backpage advertisers as credit to place ads for 

prostitution and other services. The merchant processors would then 

transfer these funds to accounts set up to receive such payments, 

specifically including Accounts 47, 48, 49, and 50. All funds 

contained within Accounts 47, 48, 49, and 50 are traceable to SUA and 

involved in money laundering.

GOLD LEAF SRO FUNDS HELD AT FIO BANK

DD. Account 38, 39, and 40 (Fio Bank ‘2226, ‘2231, and ‘2230)

206. Accounts 38, 39, and 40 are located in the Czech Republic, 

and held for the benefit of Backpage by a third party entity named, 

“Gold Leaf SRO.” Accounts 38, 39, and 40 were funded with proceeds 

traceable to SUA, involved in money laundering, or both. 

207. Accounts 38, 39, and 40 were created outside the United 

States with the intention of avoiding the “blockade” of Backpage set 

up by U.S. credit card companies that refused to process Backpage 

receipts following negative press associated with Backpage. 

Approximately 99.5% of the payments into these accounts were to be 

transferred to accounts held by Ad Tech BV, a Backpage controlled 

company located in the Netherlands, after which transfer, the funds 

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could be directed for the benefit of Backpage or Backpage Operators 

in the U.S. or abroad. All funds contained within Accounts 38, 39, 

and 40 are traceable to SUA and involved in money laundering.

PROTECCTIO SRO FUNDS HELD AT FIO BANK

EE. Accounts 41, 42, and 43 (Fio Bank ‘4194, ‘4196, and ‘4198)

208. Accounts 41, 42, and 43 are located in the Czech Republic, 

and held for the benefit of Backpage by a third party entity named, 

“Protecctio SRO.” Accounts 41, 42, and 43 were funded with proceeds 

traceable to SUA, involved in money laundering, or both. 

209. Accounts 41, 42, and 43 were created outside the United 

States with the intention of avoiding the “blockade” of Backpage set 

up by U.S. credit card companies that refused to process Backpage 

receipts following negative press associated with Backpage. 

Approximately 99.5% of the payments into these accounts were to be 

transferred to accounts held by Ad Tech BV, a Backpage controlled 

company located in the Netherlands, after which transfer the funds 

could be directed for the benefit of Backpage or Backpage Operators 

in the U.S. or abroad. All funds contained within Accounts 41, 42, 

and 43 are traceable to SUA and involved in money laundering.

VARICOK SRO FUNDS HELD AT FIO BANK

FF. Accounts 44, 45, and 46 (Fio Bank ‘8083, ‘8086, and ‘8080)

210. Accounts 44, 45, and 46 are located in the Czech Republic, 

and held in the name of Varicok Company SRO. Accounts 44, 45, and 46 

were funded with proceeds traceable to SUA, involved in money 

laundering, or both. 

211. Accounts 44, 45, and 46 were created outside the United 

States with the intention of avoiding the “blockade” of Backpage set 

up by U.S. credit card companies that refused to process Backpage 

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receipts following negative press associated with Backpage. 

Approximately 99.5% of the payments into these accounts were to be 

transferred to accounts held by Ad Tech BV, a Backpage controlled 

company located in the Netherlands, after which transfer, the funds 

could be directed for the benefit of Backpage or Backpage Operators 

in the U.S. or abroad. All funds contained within Accounts 44, 45, 

and 46 are traceable to SUA and involved in money laundering.

PROCOP SERVICES BV FUNDS HELD AT KNAB BANK

GG. Account 51 (KB ‘7664)

212. Account 51 is located in the Kingdom of the Netherlands, 

and held for the benefit of Backpage by a third party entity named, 

“Procop Services BV.” Account 51 was funded with proceeds traceable 

to SUA, involved in money laundering, or both.

213. Account 51 was created outside the United States with the 

intention of avoiding the “blockade” of Backpage set up by U.S. 

credit card companies that refused to process Backpage receipts 

following negative press associated with Backpage. Approximately 

99.5% of the payments into Accounts 51 was to be transferred to 

accounts held by Ad Tech BV, a Backpage controlled company located in 

the Netherlands, after which transfer, the funds could be directed 

for the benefit of Backpage or Backpage Operators in the U.S. or 

abroad. All funds contained within Account 51 are traceable to SUA 

and involved in money laundering.

GULIETTA GROUP BV FUNDS HELD AT RABO BANK

HH. Accounts 52 and 53 (RB ‘2452 and ‘4721)

214. Accounts 52 and 53 are located in the Kingdom of the 

Netherlands and held for the benefit of Backpage by a third party 

entity named, “Gulietta Group BV.” Accounts 52 and 53 were funded 

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with proceeds traceable to SUA, involved in money laundering, or 

both.

215. Accounts 52 and 53 were created outside the United States 

with the intention of avoiding the “blockade” of Backpage set up by 

U.S. credit card companies that refused to process Backpage receipts 

following negative press associated with Backpage. Approximately 

99.5% of the payments into these accounts were to be transferred to 

accounts held by Ad Tech BV, a Backpage controlled company located in 

the Netherlands, after which transfer, the funds could be directed 

for the benefit of Backpage or Backpage Operators in the U.S. or 

abroad. All funds contained within Accounts 52 and 53 are traceable 

to SUA and involved in money laundering.

CASHFLOWS EUROPE LTD FUNDS HELD FOR GULIETTA GROUP B.V., UNIVERSADS 

B.V., PROCOPSERVICES B.V. and PROTECCIO SRO

II. Account 55 (SP ‘1262)

216. Account 55 is located in the United Kingdom and held by a 

third party entity, “Cashflows Europe Limited” (“Cashflows”). 

Although Backpage is the ultimate beneficiary of Account 55, 

Cashflows acts first as an entity holding this account for the 

benefit of Gulietta Group B.V., Universads B.V., Procop Services 

B.V., and Proteccio SRO, each of which company is owned or controlled 

by Backpage. Account 55 was funded with proceeds traceable to SUA, 

involved in money laundering, or both.

217. Account 55 was created outside the United States with the 

intention of avoiding the “blockade” of Backpage set up by U.S. 

credit card companies that refused to process Backpage receipts 

following negative press associated with Backpage. Approximately 

99.5% of the payments into Accounts 55 was to be transferred to 

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accounts held by Ad Tech BV, a Backpage controlled company located in 

the Netherlands, after which transfer, the funds could be directed 

for the benefit of Backpage or Backpage Operators in the U.S. or 

abroad. All funds contained within Account 55 are traceable to SUA 

and involved in money laundering. 

JJ. Account 54 (LHVP ‘4431)

218. Account 54 is an account maintained in the Republic of 

Estonia, held in the name of Olist OU for the benefit of Backpage. 

Account 54 was funded with proceeds traceable to SUA, involved in 

money laundering, or both.

219. Account 54 was created outside the United States with the 

intention of avoiding the “blockade” of Backpage set up by U.S. 

credit card companies that refused to process Backpage receipts 

following negative press associated with Backpage. Approximately 

99.5% of the payments into Accounts 54 was to be transferred to 

accounts held by Ad Tech BV, a Backpage controlled company located in 

the Netherlands, after which transfer, the funds could be directed 

for the benefit of Backpage or Backpage Operators in the U.S. or 

abroad. All funds contained within Account 54 are traceable to SUA 

and involved in money laundering.

BACKPAGE-CONTROLLED DOMAIN NAMES

KK. ASCIO/WMB Inc Domain Names

220. Until recently, Backpage controlled numerous domain names,

which have since been seized by the government pursuant to a seizure 

warrant issued in this district (the “Seized Domains”).12

221. The Seized Domains are registered by “ASCIO TECHNOLOGIES 

INC” DBA “NETNAMES,” a domain registrar that manages the reservation 

12 18-MJ-00711

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of internet domain names. A domain registrar serves to ensure that a 

registered domain name, like each of the Seized Domains, is not 

double sold.

222. Additionally, a domain registration will allow the owner of 

the domain to direct internet traffic to a company’s webserver. The 

Seized Domains were found to have been acquired and maintained with 

funds traceable to the money laundering scheme described herein, 

specifically with funds from Account 1, and the Seized Domains were 

the mechanism Backpage used to promote the prostitution and sex 

trafficking activity.

223. The following domains constitute and are derived from 

proceeds traceable to SUA, involved in money laundering, or both:

a. atlantabackpage.com

b. backpage.be

c. backpage.com

d. backpage.com.br

e. backpage.cz

f. backpage.dk

g. backpage.ee

h. backpage.es

i. backpage.fi

j. backpage.fr

k. backpage.gr

l. backpage.hu

m. backpage.ie

n. backpage.it

o. backpage.lt

p. backpage.mx

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q. backpage.net

r. backpage.no

s. backpage.pl

t. backpage.pt

u. backpage.ro

v. backpage.si

w. backpage.sk

x. backpage.us

y. backpage-insider.com

z. bestofbackpage.com

aa. bestofbigcity.com

bb. bigcity.com

cc. chicagobackpage.com

dd. denverbackpage.com

ee. newyorkbackpage.com

ff. phoenixbackpage.com

gg. sandiegobackpage.com

hh. seattlebackpage.com

ii. tampabackpage.com

LL. SURRENDERED DOMAIN NAMES

224. Until recently, Backpage also controlled numerous domain 

names that Backpage has since surrendered (pursuant to its guilty 

plea on April 5, 2018, in the District of Arizona). 

225. The following websites were purchased and/or maintained, in 

whole or in part, with proceeds traceable to SUA, involved in money 

laundering, or both:

a. admoderation.com (Versio)

b. admoderators.com (Versio)

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c. adnet.ws (NetNames)

d. adplace24.com (Versio)

e. adplaces24.com (Versio)

f. adpost24.com (Versio) 

g. adpost24.cz (GoDaddy)

h. adquick365.com (Versio)

i. adreputation.com (NetNames)

j. ads-posted-mp.com (Versio)

k. adsplace24.com (Versio)

l. adspot24.com (Versio)

m. adspots24.com (Versio)

n. adsspot24.com (Versio)

o. adtechbv.co.nl (NetNames)

p. adtechbv.com (NetNames)

q. adtechbv.nl (NetNames)

r. advert-ep.com (Versio)

s. adverts-mp.com (Versio)

t. axme.com (GoDaddy)

u. back0age.com (NetNames)

v. backpa.ge (NetNames)

w. backpaee.com (NetNames)

x. backpage-insider.com (NetNames)

y. backpage.adult (NetNames)

z. backpage.ae (NetNames)

aa. backpage.at (NetNames)

bb. backpage.ax (NetNames)

cc. backpage.be (NetNames)

dd. backpage.bg (European domains)

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ee. backpage.bg (NetNames)

ff. backpage.ca (NetNames)

gg. backpage.cl (NetNames)

hh. backpage.cn (European domains)

ii. backpage.cn (NetNames)

jj. backpage.co.id (NetNames)

kk. backpage.co.nl (European domains)

ll. backpage.co.nl (NetNames)

mm. backpage.co.nz (NetNames)

nn. backpage.co.uk (NetNames)

oo. backpage.co.ve (NetNames)

pp. backpage.co.za (NetNames)

qq. backpage.com (NetNames)

rr. backpage.com.ar (NetNames)

ss. backpage.com.au (NetNames)

tt. backpage.com.ph (NetNames)

uu. backpage.cz (NetNames)

vv. backpage.dk (NetNames)

ww. backpage.ec (NetNames)

xx. backpage.ee (European domains)

yy. backpage.ee (NetNames)

zz. backpage.es (NetNames)

aaa. backpage.fi (European domains)

bbb. backpage.fi (NetNames)

ccc. backpage.fr (European domains)

ddd. backpage.fr (NetNames)

eee. backpage.gr (European domains)

fff. backpage.gr (NetNames)

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ggg. backpage.hk (European domains)

hhh. backpage.hk (NetNames)

iii. backpage.hu (European domains)

jjj. backpage.hu (NetNames)

kkk. backpage.ie (NetNames)

lll. backpage.in (NetNames)

mmm. backpage.it (NetNames)

nnn. backpage.jp (NetNames)

ooo. backpage.kr (NetNames)

ppp. backpage.lt (NetNames)

qqq. backpage.lv (European domains)

rrr. backpage.lv (NetNames)

sss. backpage.me (NetNames)

ttt. backpage.mx (NetNames)

uuu. backpage.my (NetNames)

vvv. backpage.net (NetNames)

www. backpage.nl (NetNames)

xxx. backpage.no (European domains)

yyy. backpage.no (NetNames)

zzz. backpage.nz (NetNames)

aaaa. backpage.pe (NetNames)

bbbb. backpage.ph (NetNames)

cccc. backpage.pk (NetNames)

dddd. backpage.pl (NetNames)

eeee. backpage.porn (NetNames)

ffff. backpage.pt (NetNames)

gggg. backpage.ro (European domains)

hhhh. backpage.ro (NetNames)

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iiii. backpage.se (NetNames)

jjjj. backpage.sex (NetNames)

kkkk. backpage.sg (NetNames)

llll. backpage.si (European domains)

mmmm. backpage.si (NetNames)

nnnn. backpage.sk (European domains)

oooo. backpage.sk (NetNames)

pppp. backpage.sucks (NetNames)

qqqq. backpage.tw (NetNames)

rrrr. backpage.uk (NetNames)

ssss. backpage.uk.com (NetNames)

tttt. backpage.us (NetNames)

uuuu. backpage.vn (NetNames)

vvvv. backpage.xxx (NetNames)

wwww. backpage.xyz (NetNames)

xxxx. backpagecompimp.com (NetNames)

yyyy. backpagecompimps.com (NetNames)

zzzz. backpagepimp.com (NetNames)

aaaaa. backpagepimps.com (NetNames)

bbbbb. backpagg.com (NetNames)

ccccc. backpagm.com (NetNames)

ddddd. backpagu.com (NetNames)

eeeee. backpaoe.com (NetNames)

fffff. backpawe.com (NetNames)

ggggg. backqage.com (NetNames)

hhhhh. backrage.com (NetNames)

iiiii. backxage.com (NetNames)

jjjjj. bakkpage.com (NetNames)

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kkkkk. bcklistings.com (NetNames)

lllll. bestofbackpage.com (NetNames)

mmmmm. bestofbigcity.com (NetNames)

nnnnn. bickpage.com (NetNames)

ooooo. bigcity.com (NetNames)

ppppp. bpclassified.com (NetNames)

qqqqq. bpclassifieds.com (NetNames)

rrrrr. carlferrer.com (NetNames)

sssss. clasificadosymas.com (NetNames)

ttttt. clasificadosymas.net (NetNames)

uuuuu. clasificadosymas.org (NetNames)

vvvvv. classifiedsolutions.co.uk (NetNames)

wwwww. classifiedsolutions.net (NetNames)

xxxxx. classyadultads.com (Versio)

yyyyy. columbusbackpage.com (NetNames)

zzzzz. connecticutbackpage.com (NetNames)

aaaaaa. cracker.co.id (NetNames)

bbbbbb. cracker.com (NetNames)

cccccc. cracker.com.au (NetNames)

dddddd. cracker.id (NetNames)

eeeeee. cracker.net.au (NetNames)

ffffff. crackers.com.au (NetNames)

gggggg. crackers.net.au (NetNames)

hhhhhh. ctbackpage.com (NetNames)

iiiiii. dallasbackpage.com (NetNames)

jjjjjj. denverbackpage.com (NetNames)

kkkkkk. easypost123.com (Versio)

llllll. easyposts123.com (Versio)

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mmmmmm. emais.com.pt (NetNames)

nnnnnn. evilempire.com (NetNames)

oooooo. ezpost123.com (Versio)

pppppp. fackpage.com (NetNames)

qqqqqq. fastadboard.com (Versio)

rrrrrr. guliettagroup.nl (Versio)

ssssss. htpp.org (NetNames)

tttttt. ichold.com (NetNames)

uuuuuu. internetspeechfoundation.com (nameisp)

vvvvvv. internetspeechfoundation.org (nameisp)

wwwwww. loads2drive.com (NetNames)

xxxxxx. loadstodrive.com (NetNames)

yyyyyy. loadtodrive.com (NetNames)

zzzzzz. losangelesbackpage.com (NetNames)

aaaaaaa. mediafilecloud.com (NetNames)

bbbbbbb. miamibackpage.com (NetNames)

ccccccc. minneapolisbackpage.com (NetNames)

ddddddd. mobileposting.com (Versio)

eeeeeee. mobilepostings.com (Versio)

fffffff. mobilepostlist.com (Versio)

ggggggg. mobilposting.com (Versio)

hhhhhhh. naked.city (NetNames)

iiiiiii. nakedcity.com (NetNames)

jjjjjjj. newyorkbackpage.com (NetNames)

kkkkkkk. paidbyhour.com (NetNames)

lllllll. petseekr.com (NetNames)

mmmmmmm. petsfindr.com (NetNames)

nnnnnnn. phoenixbackpage.com (NetNames)

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ooooooo. posteasy123.com (Versio)

ppppppp. postfaster.com (NetNames)

qqqqqqq. postfastly.com (NetNames)

rrrrrrr. postfastr.com (NetNames)

sssssss. postonlinewith.com (Versio)

ttttttt. postonlinewith.me (Versio)

uuuuuuu. postseasy123.com (Versio)

vvvvvvv. postsol.com (GoDaddy)

wwwwwww. postszone24.com (Versio)

xxxxxxx. postzone24.com (Versio)

yyyyyyy. postzones24.com (Versio)

zzzzzzz. rentseekr.com (NetNames)

aaaaaaaa. results911.com (NetNames)

bbbbbbbb. sandiegobackpage.com (NetNames)

cccccccc. sanfranciscobackpage.com (NetNames)

dddddddd. seattlebackpage.com (NetNames)

eeeeeeee. sellyostuffonline.com (Versio)

ffffffff. sfbackpage.com (NetNames)

gggggggg. simplepost24.com (Versio)

hhhhhhhh. simpleposts24.com (Versio)

iiiiiiii. svc.ws (NetNames)

jjjjjjjj. truckrjobs.com (NetNames)

kkkkkkkk. ugctechgroup.com (NetNames)

llllllll. universads.nl (Versio)

mmmmmmmm. villagevoicepimps.com (GoDaddy)

nnnnnnnn. websitetechnologies.co.uk (NetNames)

oooooooo. websitetechnologies.com (NetNames)

pppppppp. websitetechnologies.net (NetNames)

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qqqqqqqq. websitetechnologies.nl (NetNames)

rrrrrrrr. websitetechnologies.org (NetNames)

ssssssss. weprocessmoney.com (GoDaddy)

tttttttt. wst.ws (NetNames)

uuuuuuuu. xn--yms-fla.com (NetNames)

vvvvvvvv. ymas.ar.com (European domains)

wwwwwwww. ymas.br.com (European domains)

xxxxxxxx. ymas.br.com (NetNames)

yyyyyyyy. ymas.bz (European domains)

zzzzzzzz. ymas.bz (NetNames)

aaaaaaaaa. ymas.cl (European domains)

bbbbbbbbb. ymas.cl (NetNames)

ccccccccc. ymas.co.bz (European domains)

ddddddddd. ymas.co.bz (NetNames)

eeeeeeeee. ymas.co.cr (European domains)

fffffffff. ymas.co.cr (NetNames)

ggggggggg. ymas.co.ni (European domains)

hhhhhhhhh. ymas.co.ni (NetNames)

iiiiiiiii. ymas.co.ve (European domains)

jjjjjjjjj. ymas.co.ve (NetNames)

kkkkkkkkk. ymas.com (NetNames)

lllllllll. ymas.com.br (European domains)

mmmmmmmmm. ymas.com.br (NetNames)

nnnnnnnnn. ymas.com.bz (European domains)

ooooooooo. ymas.com.bz (NetNames)

ppppppppp. ymas.com.co (European domains)

qqqqqqqqq. ymas.com.co (NetNames)

rrrrrrrrr. ymas.com.do (European domains)

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sssssssss. ymas.com.do (NetNames)

ttttttttt. ymas.com.ec (European domains)

uuuuuuuuu. ymas.com.ec (NetNames)

vvvvvvvvv. ymas.com.es (European domains)

wwwwwwwww. ymas.com.es (NetNames)

xxxxxxxxx. ymas.com.gt (European domains)

yyyyyyyyy. ymas.com.gt (NetNames)

zzzzzzzzz. ymas.com.hn (European domains)

aaaaaaaaaa. ymas.com.hn (NetNames)

bbbbbbbbbb. ymas.com.mx (NetNames)

cccccccccc. ymas.com.ni (European domains)

dddddddddd. ymas.com.ni (NetNames)

eeeeeeeeee. ymas.com.pe (European domains)

ffffffffff. ymas.com.pe (NetNames)

gggggggggg. ymas.com.pr (European domains)

hhhhhhhhhh. ymas.com.pr (NetNames)

iiiiiiiiii. ymas.com.pt (NetNames)

jjjjjjjjjj. ymas.com.uy (European domains)

kkkkkkkkkk. ymas.com.uy (NetNames)

llllllllll. ymas.com.ve (European domains)

mmmmmmmmmm. ymas.com.ve (NetNames)

nnnnnnnnnn. ymas.cr (European domains)

oooooooooo. ymas.cr (NetNames)

pppppppppp. ymas.do (European domains)

qqqqqqqqqq. ymas.do (NetNames)

rrrrrrrrrr. ymas.ec (European domains)

ssssssssss. ymas.ec (NetNames)

tttttttttt. ymas.es (European domains)

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uuuuuuuuuu. ymas.es (NetNames)

vvvvvvvvvv. ymas.org (NetNames)

wwwwwwwwww. ymas.pe (European domains)

xxxxxxxxxx. ymas.pe (NetNames)

yyyyyyyyyy. ymas.pt (NetNames)

zzzzzzzzzz. ymas.us (European domains)

aaaaaaaaaaa. ymas.us (NetNames)

bbbbbbbbbbb. ymas.uy (European domains)

ccccccccccc. ymas.uy (NetNames)

ddddddddddd. ymas.uy.com (European domains)

BACKPAGE SURRENDERED ASSETS

MM. ASSETS BACKPAGE SURRENDERED TO THE GOVERNMENT 

226. On or about May 8, 2018, all of the funds, digital 

currencies, and other property listed in this subsection were

transferred into the United States Postal Inspection Service 

(“USPIS”) holding bank account, Bitcoin wallet, Bitcoin Cash wallet, 

Litecoin wallet, and Bitcoin Gold wallet. These Surrendered Assets 

constitute and are derived from proceeds traceable to SUA, involved 

in money laundering, or both.

227. On May 8, 2018, within the Stipulation for Preliminary 

Order of Forfeiture, CR18-465-PHX-SPL, Ferrer, in his capacity as CEO 

of Backpage, stipulated that the following bank funds, securities, or 

other assets were criminally derived proceeds of Backpage’s illegal 

activity, involved in money laundering transactions, or both, and as 

such, were forfeitable property:

a. $699,940.00 wire transferred from ING Bank account ‘7684, 

held in the name of Payment Solutions BV;

b. $106,988.41 wire transferred from ING Bank account ‘2071, 

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held in the name of Payment Solutions BV;

c. $499,910.01 wire transferred from US Bank account ‘0239, 

held in the name of Affordable Bail Bonds LLC;

d. $50,000.00 wire transferred from Enterprise Bank and Trust 

account ‘7177, held in the name of Global Trading Solutions LLC;

e. $1,876.36 wire transferred from ING Bank account ‘2071, 

held in the name of Payment Solutions BV;

f. $699,940.00 wire transferred from ING Bank account ‘7684, 

held in the name of Payment Solutions BV;

g. $248,970.00 wire transferred from Citibank NA, account 

‘0457, held in the name of Paul Hastings LLP;

h. $52,500.00 wire transferred from Enterprise Bank and Trust

account ‘7177, held in the name of Global Trading Solutions LLC;

i. $65,000.00 wire transferred from Enterprise Bank and Trust 

account ‘7177, held in the name of Global Trading Solutions LLC;

j. $5,534.54 wire transferred from Enterprise Bank and Trust 

account ‘7177, held in the name of Global Trading Solutions LLC; and

k. $40,000.00 wire transferred from Crypto Capital;

l. 6 Bitcoin transferred from a Backpage controlled wallet;

m. 199.99995716 Bitcoin transferred from a Backpage controlled 

wallet;

n. 404.99984122 Bitcoin transferred from a Backpage controlled 

wallet;

o. 173.97319 Bitcoin transferred from a Backpage controlled 

wallet;

p. 411.00019 Bitcoin transferred from a Backpage controlled 

wallet;

q. 2.00069333 Bitcoin transferred from a Backpage controlled 

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wallet;

r. 136.6544695 Bitcoin transferred from a Backpage controlled 

wallet;

s. 2,673.59306905 Bitcoin Cash transferred from a Backpage 

controlled wallet;

t. 55.5 Bitcoin Cash transferred from a Backpage controlled 

wallet;

u. 73.62522241 Bitcoin Cash transferred from a Backpage 

controlled wallet;

v. 16,310.79413202 Litecoin transferred from a Backpage 

controlled wallet;

w. 783.9735116 Litecoin transferred from a Backpage controlled 

wallet; and

x. 509.81904619 Bitcoin Gold transferred from a Backpage 

controlled wallet.

228. Backpage surrendered to a USPIS holding bank account the 

following assets that constitute and are derived from proceeds 

traceable to SUA, involved in money laundering, or both: 

a. On or about October 30, 2018, approximately $182,182.50 

previously held in the name of ‘Ad Tech BV’ at Amro Bank N.V. Account 

‘6352 (“Amro ‘6352 Funds” or “Account 63”); 

b. On or about December 11, 2018, approximately $518,172.92 

previously held in the name of ‘Cardquiry’ at Wells Fargo Bank 

Account ‘4455 (“WF ‘4455 Funds” or “Account 66”); and

c. On or about January 8, 2019, approximately $11,802.76 

previously held for the benefit of Backpage and related entities by 

the law firm ‘Schiff Hardin LLP’ at Citibank Account ‘6937 (“Citibank 

‘6973 Funds” or “Account 65”).

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NN. BACKPAGE ASSETS SURRENDERED TO THE GOVERNMENT BY OTHERS

229. On or about November 13, 2018, the holder of Plains Capital 

Account ‘3921 agreed to and did wire $23,175 to the USPIS holding 

account. The holder of Plains Capital Account ‘3921 agreed to wire, 

and did wire, these funds to the government in lieu of the government 

executing a seizure warrant on these funds, which funds constitute 

and are derived from proceeds traceable to SUA, involved in money 

laundering, or both. 

230. On or about June 11, 2019, Ferrer agreed to and did 

transfer to USPIS cryptocurrency holding wallets the following 

cryptocurrency, previously held in Bitstamp Account Number ‘0831, 

which cryptocurrency Ferrer stipulated was the criminally derived 

proceeds of Backpage’s illegal activity, involved in money laundering 

transactions, or both, and as such, are forfeitable property:

a. Approximately 2.70447488 Bitcoin, previously held in the 

name of Carl Ferrer and Postfastr, LLC; and

b. Approximately 3.54986007 Bitcoin Cash, previously held in 

the name of Carl Ferrer and Postfastr, LLC. 

OO. BACKPAGE FUNDS PREVIOUSLY HELD AT DAVIS WRIGHT TREMAINE

231. On August 13, 2018, Davis Wright Tremaine initiated a wire 

transfer of $3,713,121.03 from Bank of America account ‘3414, held in 

the name of Davis Wright Tremaine, LLP into the government holding 

account. 

a. Between January 13 and January 20, 2017, a GoCoin account 

wire transferred $1,318,800 to the Veritex Account;

b. On June 22, 2017, the Veritex Account wire transferred 

$1,000,000 into Account 27;

c. On April 27, 2017, the Netherlands Account wire transferred

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$2,500,000 to Account 27;

d. On April 28, 2017, the Netherlands Account wire transferred 

$2,500,000 to Account 27;

e. On May 24, 2017, Account 1 wire transferred $500,000 into 

Account 27;

f. On September 13, 2017, Account 1 wire transferred 

$1,000,000 into Account 27;

g. On September 27, 2017, the Netherlands Account wire

transferred about $778,802.96 into Account 27; and

h. On October 20, 2017, Account 1 wire transferred $500,000

into Account 27.

FUNDS HELD AT USAA SAVINGS BANK FOR THE BENEFIT OF MICHAEL LACEY

PP. Accounts 59, 60, 61, and 62 (USAA ‘2155, ‘2058, ‘2171, and, 

1507)

232. Accounts 59, 60, 60, and 62, are all held in the name of

Anne Hawkins, a sister-in-law to Larkin, and were funded with 

proceeds alleged to have been traceable to SUA, involved in money 

laundering, or both.

233. Between December 14, 2015, and February 9, 2017, a company 

doing business for GoCoin initiated approximately 39 wire transfers 

totaling approximately $3,959,557.78 in criminal proceeds from the 

Slovakia Account to Website Tech Account ‘2008, in the United States.

234. Between January 21, 2016, and August 31, 2016, Website Tech 

Account ‘2008 initiated approximately 27 wire transfers totaling 

approximately $48 million to Arizona Bank & Trust account number 

‘6211 (“AZBT ‘6211”), belonging to Cereus Properties LLC, which is 

owned or controlled by Spear, Backpage, and or other Backpage 

Operators.

235. On January 4, 2017, AZBT ‘6211 initiated four wires:

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a. $33,591.34 to Charles Schwab account ‘6039, held in the 

name of Oaxaca Living Trust with Kathleen D. Larkin as the sole 

beneficiary (“Schwab ‘6039”);

b. $33,591.34 to Charles Schwab account ‘9083, held in the 

name of Puebla Living trust with Rose L. Larkin as the sole 

beneficiary (Schwab ‘9083”);

c. $33,591.34 to Charles Schwab account ‘7249, held in the 

name of Cuernavaca Living Trust with Quinn M. Larkin as the sole 

beneficiary (“Schwab ‘8628”); and

d. $33,591.34 to Charles Schwab account ‘8628, held in the 

name of Chiapas Living trust with John C. Larkin as the sole 

beneficiary (“Schwab ‘8628”).

236. Several days after the wire transfers from AZBT ‘6211 to 

the four Charles Schwab accounts, funds were wire transferred to four 

AZBT accounts. 

a. On January 10, 2017, Schwab ‘6039 wired $840,692.69 to 

Arizona Bank & Trust account ‘3835, held in the name of Oaxaca Living 

Trust UTA with Lacey and Hawkins as the Trustees and Kathleen 

Dewhurst Larkin as the beneficiary (“AZBT ‘3835”);

b. On January 11, 2017, Schwab ‘9083 wired $840,672.72 to 

Arizona Bank & Trust account ‘3864 held in the name of Puebla Living 

Trust UTA with Lacey and Hawkins as the Trustees and Rose Lyons 

Larkin as the beneficiary (“AZBT ‘3864”);

c. On January 12, 2017, Schwab ‘7249 wired $840,672.70 to 

Arizona Bank & Trust account ‘3859 held in the name of Cuernavaca 

Living Trust UTA with Lacey and Hawkins as the Trustees and Quinn

McCarthy Larkin as the beneficiary (“AZBT ‘3859”); and

d. On January 10, 2017, Schwab ‘8628 wired $840,672.70 to 

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Arizona Bank & Trust account ‘3840 held in the name of Chiapas Living 

Trust UTA with Lacey and Hawkins as the Trustees and John Carey 

Larkin as the beneficiary (“AZBT ‘3840”).

237. On January 11, 2018, and in addition to the previous wire 

transfers, AZBT ‘6211 transferred $33,591.34 to each of the Living 

Trust accounts, AZBT ‘3835, AZBT ‘3864, AZBT ‘3859, and AZBT ‘3840.

238. On February 9, 2017, the four Oaxaca Living Trust accounts, 

AZBT ‘3835, AZBT ‘3864, AZBT ‘3859, and AZBT ‘3840, wire transferred 

approximately $874,330 to Accounts 59, 60, 61, and 62. More 

specifically:

a. On February 9, 2017, AZBT ‘3835 wired $874,334.26 to 

Account 59;

b. On February 9, 2017, AZBT ‘3864 wired $874,332.68 to 

Account 60;

c. On February 9, 2017, AZBT ‘3835 wired $874,331.01 to 

Account 61; and

d. On February 9, 2017, AZBT ‘3835 wired $874,334.27 to 

Account 62.

FIRST CLAIM FOR RELIEF

(18 U.S.C. § 981(a)(1)(C))

239. Based on the facts set out above, Plaintiff alleges that 

the Defendant Assets constitute, and are derived from, proceeds 

traceable to one or more violations of Title 18, United States Code, 

Sections 1591 (Sex Trafficking of Children) and 1952 (Interstate and 

Foreign Travel in Aid of Racketeering Enterprise), each of which is a 

specified unlawful activity under 18 U.S.C. §§ 1956(c)(7)(A), 

1956(c)(7)(B)(iv) and 1956(c)(7)(D), and a conspiracy to commit such 

offenses. The Defendant Assets are therefore subject to forfeiture 

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to the United States pursuant to 18 U.S.C. § 981(a)(1)(C).

SECOND CLAIM FOR RELIEF

(18 U.S.C. § 981(a)(1)(A))

240. Based on the facts set out above, Plaintiff alleges that 

the Defendant Assets were involved in, and are traceable to, property 

involved in one or more transactions or attempted transactions in 

violation of section 18 U.S.C. § 1957, and a conspiracy to commit 

such offenses, in violation of section 18 U.S.C. § 1956(h). 

Specifically, the Defendant Assets were involved in and are traceable 

to property involved in one or more financial transactions, attempted 

transactions, and a conspiracy to conduct or attempt to conduct such 

transactions in criminally derived property of a value greater than 

$10,000 that was derived from specified unlawful activities, to wit, 

violations of Title 18, United States Code, Sections 1591 (Sex 

Trafficking of Children) and 1952 (Interstate and Foreign Travel in 

Aid of Racketeering Enterprise), each of which is a specified 

unlawful activity under 18 U.S.C. §§ 1956(c)(7)(A), 1956(c)(7)(B)(iv)

and 1956(c)(7)(D), and a conspiracy to commit such offenses. The 

Defendant Assets are therefore subject to forfeiture to the United 

States pursuant to 18 U.S.C. § 981(a)(1)(A). 

THIRD CLAIM FOR RELIEF

(18 U.S.C. § 981(a)(1)(A))

241. Based on the facts set out above, Plaintiff alleges that 

the Defendant Assets were involved in, and are traceable to property 

involved in, one or more transactions or attempted transactions in 

violation of section 18 U.S.C. § 1956(a)(1)(B)(i) (Concealment Money 

Laundering), (a)(2) (International Money Laundering), and a 

conspiracy to commit such offenses, in violation of section 18 U.S.C. 

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§ 1956(h). Specifically, the Defendant Assets were involved in and 

are traceable to property involved in one or more financial 

transactions, attempted transactions, and a conspiracy to conduct or 

attempt to conduct such transactions involving the proceeds of 

specified unlawful activity, to wit, violations of Title 18, United 

States Code, Sections 1591 (Sex Trafficking of Children) and 1952 

(Interstate and Foreign Travel in Aid of Racketeering Enterprise), 

each of which is a specified unlawful activity under 18 U.S.C. 

§§ 1956(c)(7)(A), 1956(c)(7)(B)(iv) and 1956(c)(7)(D), and a 

conspiracy to commit such offenses. The Defendant Assets are 

therefore subject to forfeiture to the United States pursuant to 18 

U.S.C. § 981(a)(1)(A). 

///

///

///

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WHEREFORE, plaintiff United States of America prays:

(a) That due process issue to enforce the forfeiture of the 

Defendant Assets;

(b) That due notice be given to all interested parties to 

appear and show cause why forfeiture should not be decreed;

(c) That this Court decree forfeiture of the Defendant Assets

to the United States of America for disposition according to law; and

(d) For such other and further relief as this Court may deem 

just and proper, together with the costs and disbursements of this 

action.

Dated: June 1, 2020 NICOLA T. HANNA

United States Attorney

BRANDON D. FOX

Assistant United States Attorney

Chief, Criminal Division

STEVEN R. WELK

Assistant United States Attorney

Chief, Asset Forfeiture Section

____/s/Dan G. Boyle________

JOHN J. KUCERA

DANIEL G. BOYLE

Assistant United States Attorneys

Attorneys for Plaintiff

UNITED STATES OF AMERICA

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VERIFICATION

I, Lyndon A Versoza, hereby declare that:

1. I am a United States Postal Inspector with the United 

States Postal Inspection Service. I am the case agent for the civil 

forfeiture action entitled United States of America v. $1,546,076.35 

in Bank Funds Seized From Republic Bank of Arizona Account ‘1889, et 

al. 

2. The Consolidated Master Verified Complaint encompasses all 

of the previously filed member complaints and assets into the lead 

complaint.

3. I have read the above Consolidated Master Verified 

Complaint for Forfeiture and know its contents, which is based upon 

my own personal knowledge and reports provided to me by other agents.

4. Everything contained in the Complaint is true and correct, 

to the best of my knowledge and belief.

I declare under penalty of perjury that the foregoing is true 

and correct.

Executed on June 1, 2020, in Los Angeles, California.

_________________________

LYNDON A VERSOZA

U.S. Postal Inspector

United States Postal Inspection 

Service

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