Exhibit 5

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 1 of 92
LAW ENFORCEMENT SENSITIVE

BACKPAGE 

INVESTIGATION

ASSET TRACING MASTER DOCUMENT DRAFT

Updated

11/4/2021

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FINANCIAL ACCOUNT TRACING

A. TRACING FOR PROSPERITY BANK ACCOUNT ‘7188 (1) 

1. On February 15, 2017, Posting Solutions LLC, located 

at 13601 Preston Rd., Ste. 801E, Dallas, Texas 75240, opened 

Prosperity Bank account number ‘7188. “M.G.”, the President, 

Chief Executive Officer, Treasurer and Secretary of Posting 

Solutions LLC is the sole signatory on the account. Posting 

Solutions LLC is a company owned by and controlled by Backpage. 

2. Posting Solutions’ application for the USPS Dallas, 

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

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

Application were the names of several Backpage Operators, 

including FERRER. 

3. Records of wire transfers from countries outside the 

United States deposited into the Prosperity Account ‘7188 for 

the period of August 1 through September 1, 2017, shows this 

account received over $2,781,750 in wire transfers from outside 

the United States. For example: 

a. On or about August 16, 2017, a company called 

"Binary Trading SG PTE LTD" ("Binary Trading") wired $535,500 

from an account in Singapore into Prosperity Account ‘7188. 

Binary Trading is a company used by GoCoin. 

b. On or about August 17, 2017, Binary Trading wired 

another $528,500 from a Singapore account into Prosperity 

Account ‘7188. 

c. On or about August 30, 2017, a company named 

Trilix PTE LTD (“Trilex”), listing the same Singapore address as 

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Binary Trading and GoCoin, in four wires ranging from $385,450 

to $492,250, sent approximately $1,717,750 from a Singapore 

account into Prosperity Account ‘7188. Memo lines from these 

wires list "GC" or "GC FOR INTERNET SERVICES." The government

understands "GC" to mean GoCoin.

4. A substantial percentage of outgoing payments from 

Prosperity Account ‘7188 are payments for the operation of 

Backpage.com. For example, between July and October, 2017, 

Prosperity Account ‘7188 wired $572,027 to pay for the 

following:

a. Between July and October 2017, Prosperity Account 

‘7188 wired $570,530 to Verizon Digital Media Services in Los 

Angeles for a service for the Backpage.com website.

b. On August 18, 2017, Prosperity Account ‘7188 

wired $1,497 to “Backupify,” a company that provided data backup 

for Backpage.

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B. TRACING FOR COMPASS BANK ACCOUNT ‘3873 (2A) 

5. Compass Bank account ‘3873 is owned by Cereus 

Properties LLC, identifying SPEAR as the sole signatory. This 

account was funded with transfers from Prosperity Account ‘7188. 

It is used as a funnel account to pay Backpage Operators with 

funds from the SUA. On average, during each month of 2017, 

Prosperity Account ‘7188 transferred several hundred thousand 

dollars into Compass Bank account ‘3873. For example: 

a. On August 31, 2017, Prosperity Account ‘7188 sent 

a wire transfer totaling $487,491.45 to Compass Bank account 

‘3873. 

b. On September 15, 2017, Prosperity Account ‘7188 

sent a wire transfer totaling $91,672.67 to Compass Bank account 

‘3873. 

c. On October 2, 2017, Prosperity Account ‘7188 sent 

a wire transfer totaling $471,766 to Compass Bank account ‘3873. 

 

1. Diagram Compass Bank ‘3873 (account 2A)

 

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C. TRACING FOR COMPASS BANK ACCOUNT ‘3825 (2B)

6. Compass Bank Account number ‘3825 is held in the name 

of Brunst. This account was funded with transfers from Compass 

Bank Account ‘3873.

7. On February 2, 2018, Cereus Properties Compass Bank 

account ‘3873 wired transferred $135,956.59 into Seized Account 

2B. 

 

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D. TRACING FOR NATIONAL BANK OF ARIZONA ACCOUNTS ‘0178 

(3A), ‘0151 (3B), and ‘3645 (3C)

8. National Bank of Arizona accounts '0178, ‘0151, and 

‘3645 are held in the name of SPEAR. In furtherance of their 

money laundering scheme, and in an attempt to further conceal 

the true nature of the money, Backpage Operators used these 

accounts as go-betweens to funnel money from one account to 

another.

9. The tracing involved numerous accounts including: 

Branch Banking & Trust account number ‘2008, belonging to 

Website Technologies; Arizona Bank & Trust account number ‘6211 

belonging to Cereus Properties, and a GoCoin account in 

Slovakia.

a. Between December 14, 2015, and January 15, 2016, 

in approximately 26 wires, a GoCoin account in Slovakia 

transferred over $2.5 million to Branch Banking & Trust account 

number ‘2008 in the United States. 

b. On January 15, 2016, Branch Banking & Trust 

account number ‘2008 wired $189,571 to Verizon in Los Angeles, 

California, in payment for Backpage internet services. 

c. Between January 21, 2016, and August 31, 2016, in 

approximately 27 wires, Branch Banking & Trust account number 

‘2008 transferred approximately $48 million to Arizona Bank & 

Trust account number ‘6211.

d. Between March 1, 2016, and July 1, 2016, Arizona 

Bank & Trust account number ‘6211 wired $892,426 into National 

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Bank of Arizona account '0178. 

e. On September 14, 2017, Compass Bank account ‘3873 

wired $50,162.05 into National Bank of Arizona account '0178. 

f. On October 12, 2017, National Bank of Arizona 

account '0178 wired approximately $21,500 into National Bank of 

Arizona account ‘0151.

g. On January 5, 2018, National Bank of Arizona 

account '0178 wired approximately $600,000 into National Bank of 

Arizona account ‘3645.

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E. *TRACING FOR LIVE OAK BANK ACCOUNT ‘6910 (4)

10. The Live Oak Bank account ‘6910 is held in the name of 

SPEAR.

11. On or about March 16, 2016, National Bank of Arizona 

account ‘0178 transferred $250,000 into Live Oak Bank ‘6910 in 

the name of Scott Spear as an opening deposit. On March 20, 

2018, Live Oak Bank confirmed that these funds have remained in 

Live Oak Bank account ‘6910 since the account was opened. 

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F. *TRACING FOR ASCENSUS BROKER SERVICES ‘4301 (5A) and 

‘8001 (5B) 

12. Ascensus Broker Services ‘4301 (5A) and ‘8001 (5B) are 

held in the name of Natasha Spear, Scott Spear’s adult daughter. 

a. On February 23, 2017, National Bank of Arizona 

account ‘0178 wired approximately $50,000 into Ascensus Broker 

Services account ‘4301. 

b. On the February 23, 2017, National Bank of 

Arizona account ‘0178 wired $50,000 into Ascensus Broker 

Services account ‘8001. 

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G. TRACING FOR FIRST FEDERAL SAVINGS & LOAN OF SAN RAFAEL 

ACCOUNT ‘3620 (6)

13. First Federal Savings & Loan of San Rafael account 

‘3620 is held in the name of Michael LACEY. In furtherance of 

their money laundering scheme, and in an attempt to further 

conceal the true nature of the money, Backpage Operators used 

this account as a go-between1 funneling money from one account to 

another.

a. On October 2, 2017, Compass Bank account ‘3825 

owned by Cereus Properties, wired approximately $297,795 into 

First Federal Savings & Loan of San Rafael account ‘3620.

1 A go-between is an account set up for the main purpose of 

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

other bank accounts. Commonly used as a means of concealing the 

original source of the funds.

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H. TRACING FOR REPUBLIC BANK OF ARIZONA ACCOUNTS ‘1889 

(7A), ‘2592 (7B), ‘1938 (7E), ‘2485 (16A), ‘1897 

(16B), ‘3126 (16C), ‘8103 (16G), ‘8162 (16H), ‘8189 

(16I), ‘8316 (16D), ‘8324 (16E), AND‘8332 (16F), 

1. Republic Bank of Arizona ‘1889 AND ‘2592

14. Republic Bank of Arizona account ‘1889 is held in the 

name of LARKIN. In furtherance of their money laundering scheme, 

and in an attempt to further conceal the true nature of the 

money, Backpage Operators used this account as a go-between 

funneling money from one account to another. Republic Bank of 

Arizona account ‘2592 is held in the name of James LARKIN

a. On July 6, 2017, Compass Bank account ‘3873 wired 

$971,651.51 into Republic Bank of Arizona account ‘1889. 

b. On July 28, 2017, Republic Bank of Arizona 

account ‘1889 wired $400,000 into Republic Bank of Arizona 

account ‘2592. 

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2. Republic Bank of Arizona ‘1938

15. Republic Bank of Arizona account ‘8103 is a CDARS held 

in the name of James LARKIN, Value: $500,000.00. Republic Bank 

of Arizona account ‘8162 is a CDARS held in the name of James 

LARKIN, Value: $250,000.00. Republic Bank of Arizona account 

‘8189 is a CDARS held in the name of James LARKIN, Value: 

$250,000.00. 

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3. Republic Bank of Arizona ‘2485, ‘1897, and ‘3126

16. Republic Bank of Arizona account ‘2485 is held in the 

name of LACEY. In furtherance of their money laundering scheme, 

and in an attempt to further conceal the true nature of the 

money, Backpage Operators used this account as a go-between 

funneling money from one account to another. Republic Bank of 

Arizona account ‘3126 is held in the name of LACEY. Republic 

Bank of Arizona account ‘1897 is held in the name of LACEY. In 

furtherance of their money laundering scheme, and in an attempt 

to further conceal the true nature of the money, Backpage 

Operators used these account as a go-between funneling money 

from one account to another. 

a. On December 2, 2016, the Foreign Account in the 

Netherlands wired $324,055.85 to Compass Bank account ‘3873. 

b. On December 8, 2016, the Netherland Account wired 

$499,970.00 to Compass Bank account ‘3873. 

c. On December 27, 2016, the Foreign Account wired 

$199,970.00 to Compass Bank account ‘3873. 

d. From March through December 2017, Compass Bank 

account ‘3873 paid over $9,000 to "Cox Communications," an 

internet services company that Backpage uses to facilitate its 

internet presence and promote its sale of prostitution 

advertising. 

e. On May 31, 2017, Compass Bank account ‘3873 wired 

approximately $676,808.04 into Republic Bank of Arizona account 

‘2485. 

f. On June 30, 2017 Republic Bank of Arizona account 

‘2485 transferred $600,000 to Republic Bank of Arizona account 

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‘1897.

g. On April 16, 2018, LACEY personally went into the 

Republic Bank of Arizona, withdrew $500,000 from Republic Bank 

of Arizona account ‘2485 and opened Republic Bank of Arizona 

account ‘3126 with an initial deposit of the $500,000 he had 

just withdrawn from Republic Bank of Arizona account ‘2485.

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4. Republic Bank of Arizona ‘8103, ‘8162, ‘8189

17. Republic Bank of Arizona account ‘8103 is a CDARS held 

in the name of James LARKIN, Value: $500,000.00. Republic Bank 

of Arizona account ‘8162 is a CDARS held in the name of James 

LARKIN, Value: $250,000.00. Republic Bank of Arizona account 

‘8189 is a CDARS held in the name of James LARKIN, Value: 

$250,000.00. 

a. On July 28, 2017, Republic Bank of Arizona 

account ‘1889 wired $400,000 into Republic Bank of Arizona 

account ‘2592. 

b. On or about February 8, 2018, LARKIN wrote a 

check from $1 million drawn from Republic Bank of Arizona 

account ‘2592. This check was paid to Republic Bank of Arizona 

and was used to fund LARKIN’s CDARS accounts; Republic Bank of 

Arizona account ‘8103 (which received $500,000), Republic Bank 

of Arizona account ‘8162 (which received $250,000), and Republic 

Bank of Arizona account ‘8189 (which received $250,000). 

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5. Republic Bank of Arizona ‘8316, ‘8324, ‘8332

18. Republic Bank of Arizona account ‘8316 is a 

Certificate of Deposit Account Registry Service (“CDARS”) and is 

held in the name of LACEY. Republic Bank of Arizona account 

‘8324 is a Certificate of Deposit Account Registry Service 

(“CDARS”) and is held in the name of LACEY. Republic Bank of 

Arizona account ‘8332 is a Certificate of Deposit Account 

Registry Service (“CDARS”) and is held in the name of LACEY. In 

furtherance of their money laundering scheme, and in an attempt 

to further conceal the true nature of the money, Backpage 

Operators used this account as a go-between funneling money from 

one account to another. 

a. On October 2, 2017 Cereus Properties at Compass 

Bank account ‘3873 wired two wires to LACEY controlled accounts: 

i. $694,856.25 was wired to LACEY’s San 

Francisco Fire Credit Union account ‘2523 

ii. 297,795.54 was wired to LACEY’s First 

Federal Savings & Loan of San Rafael account ‘3620. 

b. On or about February 15, 2018, LACEY drafted two 

checks totaling $1.2 million, which he split between three of 

his “CDARS” accounts at Republic Bank of Arizona: ‘8316, ‘8324 

and ‘8332. The first check was drawn from First Federal Savings 

& Loan of San Rafael account ‘3620 in the amount of $600,000. 

The second check was drawn from San Francisco Fire Credit Union 

account ‘2523, also in the amount of $600,000. The combination 

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of these two checks totaling $1.2 million. Republic Bank of 

Arizona account ‘8316 received $600,000.

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I. *TRACING FOR BANK OF AMERICA ACCOUNT ‘8225 

(8A), ‘7054 (8B), ‘9342 (8C), ‘0071 (8D)

19. The Bank of America account ‘8225 is held in the name 

of Troy Larkin.

a. On February 2, 2018, Compass Bank account ‘3873 

wired $28,337 into Bank of America account ‘8225.

20. The Bank of America account ‘7054 is held in the name 

of Ramon Larkin.

a. On February 2, 2018, Compass Bank account ‘3873 

wired $28,337 into Bank of America account ‘7054. 

21. The Bank of America account ‘9342 is held in the name 

of Daniel Hyer and Melissa Deeann Row-Hyer.

a. On August 2 and August 8, 2017, Prosperity 

Account bank ‘7188 wired $33,700 and $44,000, respectively, to 

S&W Payroll, a company Backpage uses to pay its employees. 

b. Between August 11, 2017, and December 1, 2017, 

S&W Payroll wired a total of $207,125.81 into Bank of America 

account ‘9342. 

22. The Bank of America account ‘9342 is held in the name 

of Daniel Hyer.

a. Between November 3, 2017, and December 8, 2017, 

Bank of America account ‘9342 wired $57,500 into Bank of America 

account ‘0071. 

Account 8A, 8B, 8C, and 8D

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J. *TRACING OF SAN FRANCISCO FIRE CREDIT UNION 

‘2523 (9)

23. The San Francisco Fire Credit Union account ‘2523 was 

held in the name of Michael LACEY and Jean K. Warren.

a. On February 2, 2018, Compass Bank account ‘3873 

wired $734,603.70 into San Francisco Fire Credit Union account 

‘2523. 

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K. *TRACING FOR GREEN BANK ACCOUNT ‘4832 (12A) and 

‘4293 (12B) 

24. The Green Bank accounts ‘4831 and ‘4293 were 

held in the name of FERRER.

a. On August 8, 2017, Prosperity Account bank 

‘7188 wired $62,000 into Green Bank account ‘4832. 

b. On December 8, 2017, Seized Account 12A 

wired $20,000 into Green Bank account ‘4293. 

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L. TRACING FOR PERKINS COIE TRUST COMPANY ACCOUNT ‘0012

(14)

25. Perkins Coie Trust Company account number ‘0012 held 

in the name of Margaret LARKIN, LARKIN’S spouse. In furtherance 

of their money laundering scheme, and in an attempt to further 

conceal the true nature of the money, Backpage Operators used 

this account in a series of transfer between payments made for 

the SUA and other accounts.

26. The different accounts involved in this tracing 

include: Branch Banking & Trust account number ‘2008, belonging 

to Website Technologies; Arizona Bank & Trust account number 

‘6211 belonging to Cereus Properties, Charles Schwab account 

number ‘4693 in the name of LARKIN; Northern Trust Company 

account number ‘9562 under the name “Ocotillo Family Trust,” 

belonging to James LARKIN”; and Morgan Stanley account number 

‘1673 belonging to James LARKIN and his wife, Margaret LARKIN; 

and GoCoin transactions related to certain ads posted on 

Backpage, specifically including ads that related to child 

victims A.C., S.F., T.S., S.L., K.O., and R.W.

a. On September 6, 2015, a bitcoin account 

associated with the owner of the email address who trafficked 

A.C. and S.F. paid Backpage about $4 worth of bitcoin in order 

to post an ad promoting the trafficking of those victims in Palm 

Springs, California.

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

email address owner indicated a payment to Backpage of about $8 

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worth of bitcoin in order to "Fund Account"2 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 T.S., S.L., 

K.O., and R.W. paid Backpage about $1 worth of bitcoin in order 

to post an ad promoting the trafficking of those 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.

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. 

g. During the period of September 4, 2015, and 

November 23, 2015, Backpage advertisers used bitcoin to purchase 

about 1,000,000 "adult" ads from Backpage. Backpage then sold 

that bitcoin to GoCoin for approximately $8.6 million. Included 

among the bitcoin sold to GoCoin during this period were the six 

payments the pimps made to Backpage to purchase ads to promote 

child prostitution.

h. During the period of December 14, 2015, through 

December 29, 2015, a GoCoin account held in Slovakia wired over 

2 The email address owner provided bitcoin to Backpage as 

payment for credit to be used at a later time to pay for 

Backpage ads.

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$1.25 million to Branch Banking & Trust account ‘2008 in the 

United States. The $1.25 million represented GoCoin's partial 

payment to Backpage for the bitcoin Backpage sold to GoCoin 

during the period of September 4, 2015, through November 23, 

2015. 

i. On December 31, 2015, Branch Banking & Trust 

account ‘2008 wired $811,424 to Arizona Bank & Trust account 

‘6211.

j. On January 11, 2016, Arizona Bank & Trust account 

‘6211 wired approximately $1.3 million to Charles Schwab account 

‘4693.

k. On January 14, 2016, Charles Schwab account ‘4693 

wired approximately $13.5 million to the Northern Trust Account.

l. In July 21, 2017, Northern Trust Company account 

‘9562 wired $6.014 million to Morgan Stanley account ‘1673.

m. In or about November 2017, Morgan Stanley elected 

to terminate its business relationship with LARKIN. 

n. Following this, on November 30, 2017, LARKIN 

wired all the funds then held Morgan Stanley account ‘1673, 

about $10 million dollars, to Perkins Coie Trust Company account 

number ‘0012.

o. Some of the funds in Perkins Coie Trust Company 

account number ‘0012 were used, among other things, to purchase 

bonds and/or securities, which assets remain held in Perkins 

Coie Trust Company account number ‘0012.

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M. TRACING FOR ALLIANCE BERNSTEIN ACCOUNTS ‘6878 (15A),

‘4954 (15B), ‘7892 (15D), ‘7889 (15E), ‘7888 (15F)

‘0582, AND ‘6485 (15G)

27. Alliance Bernstein accounts ‘6878, ‘4954, ‘7892, 

‘7889, ‘7888 ‘0582, and ‘6485 are held in the name of the 

“BRUNST Family Trust.” BRUNST and his wife, Mary BRUNST, are 

the sole trustees for these accounts. In furtherance of their 

money laundering scheme, and in an attempt to further conceal 

the true nature of the money, Backpage Operators used this 

account as a go-between funneling money from one account to 

another.

a. During the period between September 4, 2015, and 

November 23, 2015, Backpage advertisers used bitcoin to purchase 

about 1,000,000 “adult” ads from Backpage. Backpage then sold 

that bitcoin to GoCoin for approximately $8.6 million. Included 

among the bitcoin sold to GoCoin during this period were the six 

payments the pimps made to Backpage to purchase ads to promote 

child prostitution.

b. During the period of December 14, 2015, through 

December 29, 2015, a GoCoin account held in Slovakia wired over 

$1.25 million to Branch Banking & Trust account ‘2008 Account 

belonging to Website Technologies in the United States which 

represented GoCoin’s partial payment to Backpage for the bitcoin 

Backpage sold to GoCoin during the period of September 4, 2015, 

through November 23, 2015. 

c. On December 31, 2015, the Branch Banking & Trust 

account ‘2008 wired $811,424 to Arizona Bank & Trust account 

‘6211 belonging to Cereus Properties.

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d. On December 6, 2016, Arizona Bank & Trust account 

‘6211 wired $161,459 to Wells Fargo Bank account ‘4891, 

belonging to BRUNST.

e. On January 4, 2017, Arizona Bank & Trust account 

‘6211 wired another $258,841 to Wells Fargo Bank account ‘4891.

f. On January 5, 2017, Wells Fargo Bank account 

‘4891 transferred $300,000 to Wells Fargo Bank account ‘7474 

belonging to the BRUNST Family Trust.

g. On May 19, 2017, Wells Fargo Bank account ‘7474 

wired about $1.5 million into Alliance Bernstein account ‘6878.

h. On May 23, 2017, Alliance Bernstein account ‘6878 

transferred about $350,000 to Alliance Bernstein account ‘6878.

i. On June 7, 2017, Alliance Bernstein account ‘6878 

transferred about $1.34 million to Alliance Bernstein account 

‘6878.

j. On September 13, 2017, Alliance Bernstein account 

‘6878 transferred about $581,000 to Alliance Bernstein account 

‘7892.

k. On September 13, 2017, Alliance Bernstein account 

‘6878 transferred about $250,000 to Alliance Bernstein account 

‘7889.

l. On September 13, 2017, Alliance Bernstein account 

‘6878 transferred about $250,000 to Alliance Bernstein account 

‘7888.

m. On September 15, 2017, Alliance Bernstein account 

‘6878 transferred about $500,000 to Alliance Bernstein account 

‘6485.

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Seized Accounts 15A through 15G

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N. TRACING FOR K&H BANK ACCOUNT ‘1210 (17)

28. K&H Bank account ‘1210 is located in Hungary, and held 

in the name of Primus Trust Company (“Binghampton Trust”) for 

the benefit of LACEY. In furtherance of their money laundering 

scheme, and in an attempt to further conceal the true nature of 

the money, Backpage Operators used this account as a go-between 

funneling money from one account to another.

29. The tracing of this account involves numerous banks 

and bank accounts both foreign and domestic. The accounts 

include: Branch Banking & Trust account ‘2008, belonging to 

Website Technologies; Arizona Bank & Trust account ‘6211 

belonging to Cereus Properties; 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, 

in approximately 26 wires, a GoCoin account in Slovakia 

transferred over $2.5 million to Branch Banking & Trust account 

‘2008 in the United States. 

b. On January 15, 2016, Branch Banking & Trust 

account ‘2008 wired $189,571 to Verizon in Los Angeles, 

California, in payment for Backpage internet services. 

c. Between January 21, 2016, and August 31, 2016, in 

approximately 27 wires, Branch Banking & Trust account ‘2008 

transferred approximately $48 million to Arizona Bank & Trust 

account ‘6211.

d. Between April 1, through October 6, 2016, in 

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approximately 12 transactions, Arizona Bank & Trust account 

‘6211 transferred over $18 million to the AZBT Annuity Trust 

Accounts.

e. On December 29, 2016, LACEY's AZBT Annuity Trusts 

Accounts sent five wires totaling $16.5 million to Johnson 

Financial account ‘9992.

f. On January 3, 2017, Johnson Financial account 

‘9992 wired the $16.5 million to K&H Bank account ‘1210 in 

Hungary.

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O. TRACING FOR FIO BANK ACCOUNTS ‘5803 (18A), ‘5801 

(18B), AND‘5805 (18C)

30. Fio Bank accounts ‘5803, ‘5801, and ‘5805 are located 

in the Czech Republic, and held in the name of Ad Tech BV, with 

FERRER as the ultimate beneficial owner. According to FERRER, all 

funds in these accounts are the criminally derived proceeds of 

ads promoting prostitution.

31. Fio Bank accounts ‘5803, ‘5801, and ‘5805 are accounts 

receivable accounts. As such, Payment processors and merchant 

processors would take credit card payments, and payments such as 

bitcoin payments from Backpage customers for prostitution and 

other ads, and would transfer these funds to accounts such as 

Fio Bank accounts ‘5803, ‘5801, and ‘5805. 

i. On May 8, 2018, within the Stipulation for 

Preliminary Order of Forfeiture, CR18-465-PHX-SPL, FERRER as CEO 

of Backpage.com, stipulated that any and all bank funds, 

securities, or other assets on deposit or seized from these 

accounts are forfeitable property. 

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P. TRACING FOR FIO BANK ACCOUNTS ‘2226 (18D), ‘2231 

(18E), and ‘2230 (18F)

32. Fio Bank accounts ‘2226,‘2231, ‘2230 are located in 

the Czech Republic, and held in the name of Gold Leaf SRO. All 

funds and securities in these accounts are held for Backpage.com 

by a third party, Gold Leaf SRO. According to FERRER and the 

Service Level Agreement ("SLA") between Ad Tech BV, a Backpage 

owned company and Gold Leaf SRO, the funds and/or securities in 

these accounts are the criminally derived proceeds of Backpage 

ads, including ads promoting prostitution. 

33. The SLAs state that 99.5% of the net proceeds are to 

be paid to Ad Tech BV, which is owned by Backpage. According to 

FERRER, the arrangement between Gold Leaf, SRO, and Backpage was 

put into place to evade what he called a "blockade by credit 

card companies." FERRER explained that beginning around 2015, 

U.S. credit card companies such as MasterCard and Visa refused 

to process credit card payments for Backpage due to the negative 

press surrounding sex trafficking and prostitution content on 

Backpage. 

34. As one of the ways around this "blockade," Backpage 

Operators set up agreements with foreign persons and partners to 

"franchise" websites for the sole purpose of accepting credit 

card payments. 

35. According to FERRER, this use of foreign third-parties 

and foreign accounts allowed Backpage to continue to accept 

credit card payments for prostitution ads while concealing from 

the credit card companies that the payments were for Backpage 

ads. 

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32

36. FERRER said that Gold Leaf SRO existed for the sole 

purpose of funneling to Backpage accounts otherwise prohibited 

credit card payments for Backpage ads. FERRER explained that 

these accounts are owned by Backpage and are not co-mingled with 

other funds, and are therefore subject to seizure and forfeiture 

to the United States.

i. On May 8, 2018, within the Stipulation for 

Preliminary Order of Forfeiture, CR18-465-PHX-SPL, FERRER as CEO 

of Backpage.com, stipulated that any and all bank funds, 

securities, or other assets on deposit or seized from these 

accounts are forfeitable property.

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Q. TRACING FOR FIO BANK ACCOUNTS ‘4194 (18G), ‘4196 

(18H), AND ‘4198 (18I)

37. Fio Bank accounts ‘4194, ‘4196 and ‘4198 are located 

in the Czech Republic, and held in the name of Protecctio SRO. 

All funds and securities in these accounts are held for 

Backpage.com by a third party, Protecctio SRO. According to 

FERRER and the Service Level Agreement ("SLA") between 

Protecctio, a Backpage owned company and Protecctio SRO, the 

funds and/or securities in these accounts are the criminally 

derived proceeds of Backpage ads, including ads promoting 

prostitution. 

38. The SLAs state that 99.5% of the net proceeds are to 

be paid to Ad Tech BV, which is owned by Backpage. According to 

FERRER, the arrangement between Protecctio SRO, and Backpage was 

put into place to evade what he called a "blockade by credit 

card companies." FERRER explained that beginning around 2015, 

U.S. credit card companies such as MasterCard and Visa refused 

to process credit card payments for Backpage due to the negative 

press surrounding sex trafficking and prostitution content on 

Backpage. 

39. As one of the ways around this "blockade," Backpage 

Operators set up agreements with foreign persons and partners to 

"franchise" websites for the sole purpose of accepting credit 

card payments. 

40. According to FERRER, this use of foreign third-parties 

and foreign accounts allowed Backpage to continue to accept 

credit card payments for prostitution ads while concealing from 

the credit card companies that the payments were for Backpage 

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 35 of 92
34

ads. 

41. FERRER said that Protecctio SRO existed for the sole 

purpose of allowing purchasers of prostitution ads to purchase 

ads on Backpage websites while evading the credit card company 

blockade. FERRER explained that these accounts are owned by 

Backpage and are not co-mingled with other funds, and are 

therefore subject to seizure and forfeiture to the United 

States.

i. On May 8, 2018, within the Stipulation for 

Preliminary Order of Forfeiture, CR18-465-PHX-SPL, FERRER as CEO 

of Backpage.com, stipulated that any and all bank funds, 

securities, or other assets on deposit or seized from these 

accounts is forfeitable property.

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R. TRACING FOR FIO BANK ACCOUNT ‘8083 (18J), ‘8086 (18K), 

AND ‘8080 (18L)

42. Fio Bank accounts ‘8083, ‘8086, and ‘8080 are located 

in the Czech Republic, and held in the name of Varicok Company 

SRO. All funds and securities in these accounts are held for 

Backpage.com by a third party, Varicok Company SRO. According to 

FERRER and the Service Level Agreement ("SLA") between Varicok 

Company SRO, a Backpage owned company and Varicok Company SRO, 

the funds and/or securities in these accounts are the criminally 

derived proceeds of Backpage ads, including ads promoting 

prostitution. 

43. The SLAs state that 99.5% of the net proceeds are to 

be paid to Ad Tech BV, which is owned by Backpage. According to 

FERRER, the arrangement between Varicok Company SRO, and 

Backpage was put into place to evade what he called a "blockade 

by credit card companies." FERRER explained that beginning 

around 2015, U.S. credit card companies such as MasterCard and 

Visa refused to process credit card payments for Backpage due to 

the negative press surrounding sex trafficking and prostitution 

content on Backpage. 

44. As one of the ways around this "blockade," Backpage 

Operators set up agreements with foreign persons and partners to 

"franchise" websites for the sole purpose of accepting credit 

card payments. 

45. According to FERRER, this use of foreign third-parties 

and foreign accounts allowed Backpage to continue to accept 

credit card payments for prostitution ads while concealing from 

the credit card companies that the payments were for Backpage 

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ads. 

46. FERRER said that Varicok Company SRO existed for the 

sole purpose of allowing purchasers of prostitution ads to 

purchase ads on Backpage websites while evading the credit card 

company blockade. FERRER explained that these accounts are 

owned by Backpage and are not co-mingled with other funds, and 

are therefore subject to seizure and forfeiture to the United 

States.

i. On May 8, 2018, within the Stipulation for 

Preliminary Order of Forfeiture, CR18-465-PHX-SPL, FERRER as CEO 

of Backpage.com, stipulated that any and all bank funds, 

securities, or other assets on deposit or seized from these 

accounts is forfeitable property.

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S. TRACING FOR BANK FRICK ACCOUNTS ‘K000 K (19A), ‘K000

U (19B), ‘K000 E (19C), AND ‘K001 E (19D) 

47. Bank Frick accounts ‘K000 K, ‘K000 U, ‘K000 E, and 

‘K001 E are located in Principality of Liechtenstein, and held 

in the name of Ad Tech BV, and FERRER is the ultimate beneficial 

owner. According to FERRER these are accounts receivable 

banking accounts. 

48. Payment processors and merchant processors would take 

credit card payments, and payments such as bitcoin payments from 

Backpage customers for prostitution and other ads, and would 

transfer these funds to Bank Frick accounts ‘K000 K, ‘K000 U, 

‘K000 E, and ‘K001 E. 

49. These accounts contain funds and/or securities that 

are criminally derived and are subject to forfeiture. FERRER 

and Backpage has agreed to surrender these funds and/or 

securities as they are criminally derived. 

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T. TRACING FOR KNAB BANK ACCOUNT ‘7664 (20)

50. Knab Bank account ‘2452 is located in Kingdom of the 

Netherlands, and held in the name of Procop Services BV. All 

funds and securities in this account are held for Backpage.com 

by Procop Services BV. According to FERRER and the Service Level 

Agreement ("SLA") between Procop Services BV, a Backpage owned 

company and Procop Services BV, the funds and/or securities in 

these accounts are the criminally derived proceeds of Backpage 

ads, including ads promoting prostitution. 

51. The SLAs state that 99.5% of the net proceeds are to 

be paid to Ad Tech BV, which is owned by Backpage. According to 

FERRER, the arrangement between Procop Services BV, and Backpage 

was put into place to evade what he called a "blockade by credit 

card companies." FERRER explained that beginning around 2015, 

U.S. credit card companies such as MasterCard and Visa refused 

to process credit card payments for Backpage due to the negative 

press surrounding sex trafficking and prostitution content on 

Backpage. 

52. As one of the ways around this "blockade," Backpage 

Operators set up agreements with foreign persons and partners to 

"franchise" websites for the sole purpose of accepting credit 

card payments. 

53. According to FERRER, this use of foreign third-parties 

and foreign accounts allowed Backpage to continue to accept 

credit card payments for prostitution ads while concealing from 

the credit card companies that the payments were for Backpage 

ads. 

54. FERRER said that Procop Services BV existed for the 

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 40 of 92
39

sole purpose of allowing purchasers of prostitution ads to 

purchase ads on Backpage websites while evading the credit card 

company blockade. FERRER explained that these accounts are 

owned by Backpage and are not co-mingled with other funds, and 

are therefore subject to seizure and forfeiture to the United 

States.

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U. TRACING FOR RABO BANK ACCOUNT ‘2452 (21A) and 

‘4721(21B)

55. According to FERRER and business agreements, Rabo Bank 

Account ‘2452 is an account in the Netherlands held in the name of 

Gulietta Group BV. The funds and/or securities in this account are 

derived from selling advertisements online, most of which are for 

prostitution advertisements. The SLAs state that 99.5% of the net 

proceeds are to be paid to Ad Tech BV which is owned by Backpage.

56. According to FERRER, the arrangement between Guilietta 

Group BV, and Backpage was put into place to evade what he called 

a "blockade by credit card companies." FERRER explained that 

beginning around 2015, U.S. credit card companies such as 

MasterCard and Visa refused to process credit card payments for 

Backpage due to the negative press surrounding sex trafficking 

and prostitution content on Backpage.

57. As one of the ways around this "blockade," Backpage 

Operators set up agreements with foreign persons and partners to 

"franchise" websites for the sole purpose of accepting credit 

card payments.

58. This use of foreign third-parties and foreign accounts 

allowed Backpage to continue to accept credit card payments for 

prostitution ads while concealing from the credit card companies 

that the payments were for Backpage ads.

59. Rabo Bank account ‘4721 is an account in the 

Netherlands held in the name of UnivsersAds BV. According to 

Ferrer and the SLA between the companies, the funds and/or 

securities in this account are derived from selling 

advertisements online, most of which are for prostitution 

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 42 of 92
41

advertisements. The Service Level Agreements state that 99.5% 

of the net proceeds are to be paid to Ad Tech BV which is owned 

by Backpage.

60. According to Ferrer, the arrangement between 

UniversAds BV and Ad Tech BV or Backpage was put into place to 

evade the same credit card blockade described above. Ferrer 

explained that these accounts are owned by Backpage and are not 

co-mingled with other funds and/or securities, and are therefore 

subject to seizure and forfeiture to the United States.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 43 of 92
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V. TRACING FOR ACACIA CONSERVATION FUND ‘0112 (22)

61. Acacia Conservation Fund LP account‘0112 are 

investment funds held in the name of Ocotillo Family Trust. 

Ocotillo Family Trust is owned by JAMES and Margaret LARKIN. In 

furtherance of their money laundering scheme, and in an attempt 

to further conceal the true nature of the money, Backpage

Operators used these accounts as go-betweens to funnel money 

from one account to another.

a. The tracing involved numerous accounts including: 

Branch Banking & Trust account number ‘2008, held in the name of 

Website Technologies; Arizona Bank & Trust account number ‘6211 

held in the name of Cereus Properties; Charles Schwab account 

number ‘4693 held in the name of JAMES LARKIN; and Pershing, LLC 

Account number ‘1121 held in the name of Acacia Conservation 

Fund; and GoCoin transactions related to certain ads posted on 

Backpage, specifically including ads that related to child 

victims A.C., S.F., T.S., S.L., K.O., and R.W.

b. On September 6, 2015, a bitcoin account 

associated with the owner of the email address who trafficked 

A.C. and S.F. paid Backpage about $4 worth of bitcoin in order 

to post an ad promoting the trafficking of those victims in Palm 

Springs, California.

c. On September 15, 2015, an email from the same 

email address owner indicated a payment to Backpage of about $8 

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 44 of 92
43

worth of bitcoin in order to "Fund Account"3 for 

palmsprings.backpage.com. 

d. On October 6, 2015, the same email address owner 

paid Backpage about $1 worth of bitcoin to "Fund Account" on 

palmsprings.backpage.com. 

e. On October 30, 2015, a bitcoin account associated 

with the owner of the email address who trafficked T.S., S.L., 

K.O., and R.W. paid Backpage about $1 worth of bitcoin in order 

to post an ad promoting the trafficking of those victims in 

Columbus, Ohio.

f. 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.

g. 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. 

h. During the period of September 4, 2015, and 

November 23, 2015, Backpage advertisers used bitcoin to purchase 

about 1,000,000 "adult" ads from Backpage. Backpage then sold 

that bitcoin to GoCoin for approximately $8.6 million. Included 

among the bitcoin sold to GoCoin during this period were the six 

payments the pimps made to Backpage to purchase ads to promote 

child prostitution.

i. During the period of March 23, 2016, through 

March 31, 2016, in three transactions, Branch Banking and Trust 

3 The email address owner provided bitcoin to Backpage as 

payment for credit to be used at a later time to pay for 

Backpage ads.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 45 of 92
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Bank account ‘2008 wired $3,694,813.60 to the Arizona Bank and 

Trust Account ‘6211.

j. During the period of April 1, 2016, through July 

1, 2016, in five transactions, the Arizona Bank and Trust 

Account ‘6211 wired $5,750,294 to LARKIN’s Charles Schwab 

account ‘4693. 

k. On July 1, 2016, the Charles Schwab account ‘4693 

wired $15 million to the Acacia Conservation Fund, LP account 

‘0112.

l. During the period of August 2, 2016, through 

October 6, 2016, in six transactions, the Arizona Bank and Trust 

Account ‘6211 wired $9,550,315 to LARKIN’s Charles Schwab 

account ‘4693. 

m. On January 3, 2017, the Charles Schwab account 

‘4693 wired $2.5 million to the Acacia Conservation Fund, LP 

account ‘0112.

n. On January 4, 2017, the Charles Schwab account 

‘4693 wired $2.5 million to the Acacia Conservation Fund, LP 

account ‘0112.

ACCOUNT 22

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Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 47 of 92
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W. TRACING FOR SAXO PAYMENTS ACCOUNT ‘1262 (23)

62. Saxo Payments account number 00011262 is a United 

Kingdom-based account held in the name of Cashflows Europe 

Limited (“Cashflows”). Cashflows is holding these funds for the 

benefit of Gulietta Group B.V., Universads B.V, Procop Services 

B.V., and Proteccio SRO, each of which company is a Backpage 

owned or controlled entity. United Kingdom law enforcement 

officials have restrained the funds held by these four companies 

and consolidated them into this Saxo Payments account. 

63. On April 5, 2018, pursuant to a plea agreement in the 

District of Arizona, FERRER plead guilty to a single-count 

information charging him with a violation of 18 U.S.C. § 371, 

conspiracy to violate 18 U.S.C. §§ 1952 (the Travel Act) and 

1956 (money laundering). As part of his plea agreement, FERRER 

agreed to "take all steps within his power to forfeit to the 

United States all corporate assets and other property owned or 

controlled by Website Technologies, LLC, which own and operates 

the Backpage website, as well as corporate assets and other 

property owned or controlled by Backpage.com, LLC, Posting 

Solutions LLC, Amstel River Holdings, LLC, Ad Tech BV, and UGC 

Tech Group CV." That same day, also in the District of Arizona, 

Backpage.com, LLC and related entities plead guilty to 18 U.S.C. 

§ 1956(h) (money laundering conspiracy). 

64. Saxo Payments account ‘1262 contains funds from (1) 

Gulieta Group B.V.; (2) Procop Services B.V.; (3) Universads 

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 48 of 92
47

B.V.; and (4) Protecctio SRO, (collectively referred to as, the 

"Entities"):

65. According to FERRER and the four separate SLAs between 

(1) Ad Tech BV, a Backpage owned company, and Guilietta Group 

B.V.; (2) Backpage and Procop Services B.V.; (3) Backpage and 

Universe Ads B.V.; and (4) Backpage and Protecctio SRO, the 

funds and/or securities held by these entities are the 

criminally derived proceeds of Backpage ads, including ads 

promoting prostitution. All four SLAs state that 99.5% of the 

net proceeds are to be paid to Ad Tech BV, which is owned by 

Backpage. According to FERRER, the arrangements between these 

Entities, and Backpage were put into place to avoid what FERRER 

described as, "a blockade [of Backpage] by credit card 

companies." FERRER explained that beginning around 2015, U.S. 

credit card companies such as MasterCard and Visa refused to 

process credit card payments for Backpage due to the negative 

press surrounding sex trafficking and prostitution content on 

Backpage. As a way around this "blockade," Backpage Operators 

set up agreements with foreign persons and partners to 

"franchise" websites for the sole purpose of accepting credit 

card payments. According to FERRER, this use of foreign thirdparties and foreign accounts allowed Backpage to continue to 

accept credit card payments for prostitution ads while 

concealing from the credit card companies that the payments were 

for Backpage ads. FERRER said that the Entities existed for the 

sole purpose of funneling to Backpage accounts otherwise 

prohibited credit card payments for Backpage ads. FERRER 

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 49 of 92
48

explained that these funds are owned by Backpage and are not comingled with other funds, and the funds held in Saxo Payments 

account ‘1262 are therefore subject to seizure and forfeiture to 

the United States.

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X. *TRACING FOR AS LHV PANK ACCOUNT ‘4431 (24)

66. Restrained Account 24 is an account maintained 

in the Republic of Estonia, held in the name of Olist 

OU. The funds and/or securities in this account are 

derived from selling advertisements online, most of 

which ads are for prostitution advertisements. The 

SLAs state that 99.5% of the net proceeds are to be 

paid to Ad Tech BV, which is owned by Backpage. The 

arrangement between Olist OU and Ad Tech BV (Backpage) 

was put into place to avoid the same credit card 

“blockade” described in relation to Saxo Payments 

account ‘1262. These accounts are owned by Backpage 

and are not co-mingled with other funds and/or 

securities.

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Y. *TRACING COMPASS BANK ACCOUNT ‘4862 (25)

67. The Compass Bank account was opened in the name 

of Cereus Properties:

a. On December 2, 2016, the Foreign Account in the 

Liechtenstein wired $324,055.85 to Compass Bank account ‘3873.

b. On December 8, 2016, the Foreign Account wired 

$499,970.00 to Compass Bank account ‘3873.

c. On December 27, 2016, the Foreign Account wired 

$199,970.00 to Compass Bank account ‘3873.

d. On September 19, 2017, Compass Bank account ‘3873 

wired $83,063 to Wells Fargo Bank account ‘9863.

e. Between September 20, 2017, and December 8, 2017, 

in a total of seven wire transfers, Wells Fargo Bank account -

9863 sent a combined total of $944,729.25 to Compass Bank 

account ‘4862.

f. On December 13, 2017, Compass Bank account ‘4862 

wired $406,211.10 to Republic Bank of Arizona account 1938.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 52 of 92
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Z. *TRACING OF MIDFIRST BANK ACCOUNT ‘4139 (26)

68. The Midfirst Bank account was held in the name 

of John Becker’s IOLTA for MICHAEL LACEY

a. On January 4, 2017, GoCoin’s Singapore 

account wired $489,500 into Account -1462, and on 

January 20, 2017, GoCoin’s Singapore account directed 

two additional wires, for $358,150 and $470,150, 

respectively, into Account -1462 (totaling $1,317,800 

wired from GoCoin’s Singapore account into Account -

1462).

b. On or about February 23, 2017, Account -

1462 sent two payments, a wire of $443,014 and a check 

for $27,887.41 to Compass Bank account ‘3873.

c. Between March 30, 2017, and September 14, 

2017, Compass Bank account ‘3873 sent five wires 

totaling $4,058.063.65 to Midfirst Bank account ‘4139.

d. In July 2018, Midfirst Bank account ‘4139 

was closed and a cashier’s check totaling $2,412,785.47 

was issued to Michael Lacey’s Annuity Fund held by his 

attorney. As of the date of this affidavit, this check 

has not been negotiated.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 53 of 92
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AA. ASCIO/WMB INC WEBSITES 

69. Backpage, until recently, controlled numerous domain 

names that have since been seized by the government pursuant to 

a seizure warrant issued in this district.4 

70. The Seized Domains are registered by “ASCIO 

TECHNOLOGIES INC” DBA “NETNAMES,” a domain registrar that 

manages the reservation 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. 

71. 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 Prosperity 

Bank account ‘7188, and the Seized Domains were the mechanism 

Backpage used to promote the prostitution and sex trafficking 

activity. 

72. The following domains constitute and are derived from 

proceeds traceable to one or more violations of 18 U.S.C. 

§ 156(g), 18 U.S.C. § 156(a)(2), and 18 U.S.C. § 1957: 

73. atlantabackpage.com 

74. backpage.be 

75. backpage.com 

76. backpage.com.br 

77. backpage.cz 

78. backpage.dk 

4 18-MJ-00711

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 54 of 92
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79. backpage.ee

80. backpage.es

81. backpage.fi

82. backpage.fr

83. backpage.gr

84. backpage.hu

85. backpage.ie

86. backpage.it

87. backpage.lt

88. backpage.mx

89. backpage.net

90. backpage.no

91. backpage.pl

92. backpage.pt

93. backpage.ro

94. backpage.si

95. backpage.sk

96. backpage.us

97. backpage-insider.com

98. bestofbackpage.com

99. bestofbigcity.com

100. bigcity.com

101. chicagobackpage.com

102. denverbackpage.com

103. newyorkbackpage.com

104. phoenixbackpage.com

105. sandiegobackpage.com

106. seattlebackpage.com

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 55 of 92
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107. tampabackpage.com

ASCIO/NETNAMES

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 56 of 92
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REAL PROPERTY TRACING

A. 2043 Pleasant Hill Rd, Sebastopol, CA 95472

108. Michael LACEY knowingly engaged and attempted to 

engage in a monetary transaction in criminally derived property 

of a value greater than $10,000 and is derived from SUA activity 

in violation of 18 U.S.C. § 1957. 

109. As set forth below, financial transactions involving 

illicit proceeds were deposited in GoCoin (Singapore) which were 

then moved through the Posting Solutions Prosperity Bank 

account, then moved through the Cereus Properties Compass Bank 

account, then moved to the San Francisco Fire Credit Union 

account ‘2523 controlled by Michael LACEY. 

110. Additional financial transactions involving illicit 

proceeds were deposited in Ad Tech BV Bank Frick account (XXXX) 

which were then moved through the Cereus Properties Compass Bank 

account, then moved to the San Francisco Fire Credit Union 

account ‘2523 controlled by Michael LACEY. LACEY issued a check 

from his San Francisco Fire Credit Union account ‘2523 to the 

Sonoma County Tax Collector. 

Date(s) Approximate Amount of Wire Transfers from GoCoin and 

Ad Tech BV

Debits from San Francisco 

Fire Credit Union Account 

‘2523

From To Amount Amount To

8/1/2017 – 

9/1/2017

GoCoin Posting 

Solutions

$2.7 Million

7/25/2017 – 

10/2/2017

Posting 

Solutions

Cereus 

Properties

$1.67 Million

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 57 of 92
56

12/2/2016 –

12/30/2016

Ad Tech BV Cereus 

Properties

$1,023,995.95

10/2/2017 Cereus 

Properties

San Francisco 

Fire Credit 

Union ‘2523 $694,856.25

10/10/2017 $12,956.25

Sonoma 

County Tax 

Collector

111. As noted above, on October 10, 2017, LACEY issued a 

check for $12,956.25 to Sonoma County Tax Collector. The 

notation on this wire was “2043 Pleasant Hill Dr Sebastopol”. 

112. Finca Manzana for Sebastopol, LLC, a Delaware limited 

liability company, which was the entity used to take title to 

SEBASTOPOL, CALIFORNIA PROPERTY, is owned by Michael LACEY. On 

February 11, 2016, Deborah Chalsty transferred by grant deed, as 

instrument number 2016010019 of the Sonoma County official 

records, SEBASTOPOL, CALIFORNIA PROPERTY to Michael LACEY, an 

unmarried man. On April 24, 2017, Michael LACEY, for no 

consideration, transferred by grant deed, as instrument number 

2017031052 of the Sonoma County official records, SEBASTOPOL, 

CALIFORNIA PROPERTY to Finca Manzana for 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 change in the method of holding title and 

in which proportional ownership inters in the realty 

remain the same. . .”

113. LACEY used funds that had been moved through GoCoin 

and Ad Tech BV, through Posting Solution and Cereus Properties 

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 58 of 92
57

accounts, to an account controlled by himself, to acquire or 

maintain the real property known as 2043 Pleasant Hill Rd.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 59 of 92
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B. 343 Presidio Ave, San Francisco, CA 94115 

114. Michael LACEY knowingly engaged and attempted to 

engage in a monetary transaction in criminally derived property 

of a value greater than $10,000 and is derived from SUA activity 

in violation of 18 U.S.C. § 1957. 

115. As set forth below, financial transactions involving 

illicit proceeds were deposited in GoCoin (Singapore) which were 

then moved through the Posting Solutions Prosperity Bank 

account, then moved through the Cereus Properties Compass Bank 

account, then moved to the San Francisco Fire Credit Union 

account ‘2523 controlled by Michael LACEY. 

116. Additional financial transactions involving illicit 

proceeds were deposited in Ad Tech BV Bank Frick account (XXXX) 

which were then moved through the Cereus Properties Compass Bank 

account, then moved to the San Francisco Fire Credit Union 

account ‘2523 controlled by Michael LACEY. Lacey issued a check 

from his San Francisco Fire Credit Union account to pay the San 

Francisco Tax Collector. 

Date(s) Approximate Amount of Wire Transfers from GoCoin and 

Ad Tech BV

Debits from San Francisco 

Fire Credit Union Account 

‘2523

From To Amount Amount To

8/1/2017 – 

9/1/2017

GoCoin Posting 

Solutions 

$2.7 Million

7/25/2017 – 

10/2/2017

Posting 

Solutions

Cereus 

Properties

$1.67 Million

12/2/2016 – Ad Tech BV Cereus $1,023,995.95

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 60 of 92
59

12/30/2016 Properties

10/2/2017 Cereus 

Properties

San Francisco 

Fire Credit 

Union ‘2523 $694,856.25

10/10/2017 $15,053.08

San 

Francisco 

Tax 

Collector

117. As noted above, on October 10, 2017, LACEY issued a 

check for $15,053.08 to San Francisco Tax Collector. The 

notation on this wire was “343 Presidio”. 

118. On May 18, 2016, David H. Berg, Trustee and Geraldine 

B Berg, Trustee of The Berg Family Trust, dated August 15, 2005 

transferred by grant deed, as instrument number 2016-K245482-00 

of the San Francisco County official records, 343 Presidio Ave, 

to Michael G. LACEY, a single man and Alyson Talley, a single 

woman, as joint tenants with right of survivorship. 

119. LACEY used funds that had been moved through GoCoin

and Ad Tech BV, through Cereus Properties accounts, to accounts 

controlled by himself, to acquire or maintain the real property 

known as SAN 

120. FRANCISCO, CALIFORNIA PROPERTY 1.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 61 of 92
60

C. 2755 Fillmore St, San Francisco, CA 94123

121. Michael LACEY knowingly engaged and attempted to 

engage in a monetary transaction in criminally derived property 

of a value greater than $10,000 and is derived from SUA activity 

in violation of 18 U.S.C. § 1957.

122. As set forth below, financial transactions involving 

illicit proceeds were deposited in GoCoin (Slovakia) which was 

then moved through the Website Technologies Branch Banking & 

Trust account, then moved through Cereus Properties Arizona Bank 

& Trust account, then moved through multiple Annuity trust 

accounts controlled by LACEY, then moved to Arizona Bank & Trust 

account ‘1793 controlled by LACEY. Funds from LACEY’s Arizona 

Bank & Trust account ‘1793 were then wire transferred to 

Fidelity National Title Company. 

123. As noted above, on June 27, 2016, LACEY wired, or 

caused to be wired, $397,500.00 to Fidelity National Title 

Company. The notation on this wire was “XXX(Earnest 

Money)XXXXXX”. On July 20, 2016, LACEY wired, or caused to be 

wired, $12,859,152.57 to Fidelity National Title Company. The 

notation on this wire was “XX(Balance of Property)XXXXX”.

124. Casa Bahia for San Francisco, LLC, a Delaware limited 

liability company, which was the entity used to take title to 

SAN FRANCISCO, CALIFORNIA PROPERTY 2, is owned by Michael LACEY 

(“XXX”). On July 21, 2016, Hui Li and Ying Lan Li transferred 

by grant deed, as instrument number 2016-K291371-00 of the San 

Francisco County official records, 2755 Fillmore St to Michael 

G. LACEY, an unmarried man. On June 21, 2017, Michael G. LACEY, 

for no consideration, transferred by grant deed, as instrument 

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 62 of 92
61

number 2017-K466276099 of the San Francisco County official 

records, SAN FRANCISCO, CALIFORNIA PROPERTY 2 to Casa Bahai for 

San Francisco, LLC, a Delaware limited liability company. 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. . .”

125. LACEY used funds that had been moved through GoCoin, 

Website Technologies and Cereus Properties accounts, as well as 

annuity accounts controlled by himself, to acquire the real 

property known as 2755 Fillmore St.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 63 of 92
62

Date(s) Approximate Amount of Wire Transfers into Arizona 

Bank & Trust

Debits from Arizona Bank & 

Trust Acct. ‘1793

From To Amount Amount To

12/14/2015-

1/29/2016 (39 

transfers)

GoCoin Website 

Technologies

$3,959,557.78

12/14/2015-

9/1/2016

GoCoin Website 

Technologies

$35 million

12/14/2015-

12/29/2015

GoCoin Website 

Technologies

$1.25 million

3/23/2016-

3/31/2016 (3 

transfers)

Website 

Technologies

Cereus 

Properties

$3,694,813.60

12/31/2015-

8/31/2016

Website 

Technologies

Cereus 

Properties

$39.2 million

12/31/2015-

10/28/2016

Website 

Technologies

Cereus 

Properties

$48 million

4/1/2016-

5/2/2016

Cereus 

Properties

Annuity Account 

‘1967

$832,916.00

4/1/206-

5/2/2016

Cereus 

Properties

Annuity Account 

‘1972

$832,916.00

4/1/206-

5/2/2016

Cereus 

Properties

Annuity Account 

‘1986

$832,916.00

4/1/206-

5/2/2016

Cereus 

Properties

Annuity Account 

‘1991

$832,916.00

4/1/206-

5/2/2016

Cereus 

Properties

Annuity Account 

‘2014

$832,916.00

5/5/2016 Annuity 

Account ‘1967

Arizona Bank & 

Trust ‘1793 $4,701,840.00

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 64 of 92
63

6/21/2016 Annuity 

Account ‘1967

Arizona Bank & 

Trust ‘1793 $750,761.45

5/5/2016 Annuity 

Account ‘1972

Arizona Bank & 

Trust ‘1793 $4,701,840.00

6/21/2016 Annuity 

Account ‘1972

Arizona Bank & 

Trust ‘1793 $750,761.45

5/5/2016 Annuity 

Account ‘1986

Arizona Bank & 

Trust ‘1793 $4,701,840.00

6/21/2016 Annuity 

Account ‘1986

Arizona Bank & 

Trust ‘1793 $750,761.45

5/5/2016 Annuity 

Account ‘1991

Arizona Bank & 

Trust ‘1793 $4,701,840.00

6/21/2016 Annuity 

Account ‘1991

Arizona Bank & 

Trust ‘1793 $750,761.45

5/5/2016 Annuity 

Account ‘2014

Arizona Bank & 

Trust ‘1793 $4,701,840.00

6/21/2016 Annuity 

Account ‘2014

Arizona Bank & 

Trust ‘1793 $750,761.45

6/27/2016 $397,500.00 Fidelity 

National 

Title 

Company 

Earnest 

Money for 

Fillmore

7/20/2016 $12,859,152.57 Fidelity 

National 

Title 

Company 

Balance for 

Fillmore 

property

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 65 of 92
64

D. 1100 Union St. #700, San Francisco, CA 94109

126. Michael LACEY, knowingly engaged and attempted to 

engage in a monetary transaction in criminally derived property 

of a value greater than $10,000 and is derived from SUA activity 

in violation of 18 U.S.C. § 1957.

127. As set forth below, funds originating from Backpage’s 

U.S. Bank account ‘1165 was moved through the Camarillo Holdings 

LLC, BMO Harris Bank account, then moved to LACEY’s BMO Harris 

account ‘5263. LACEY’s BMO Harris account ‘5263 paid a check to 

a contractor for repairs to the 1100 Union St. #700. In detail:

a. Between February 4, 2013 and February 11, 2013, 

over a series of wire transfers, Backpage.com U.S. Bank account 

wired about $3.2 million to Camarillo Holdings LLC BMO Harris 

Bank account ‘7172.

b. On February 15, 2013, Camarillo Holdings LLC BMO 

Harris Bank account ‘7172 wire transferred $395,513.85 to 

LACEY’s BMO Harris Bank account ‘5263.

c. On May 12, 2015, LACEY using funds from his BMO 

Harris Bank account ‘5263, paid an $11,027.37 check to a 

contractor for water damage repair for 1100 Union St. #700.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 66 of 92
65

E. 493 Zinfandel Lane, Saint Helena, CA 94574 

128. James LARKIN, knowingly engaged and attempted to 

engage in a monetary transaction in criminally derived property 

of a value greater than $10,000 and is derived from SUA activity 

in violation of 18 U.S.C. § 1957. 

129. As set forth below, financial transactions involving 

illicit proceeds were deposited in from Backpage’s U.S. Bank 

account ‘1165, then moved to the Camarillo Holdings LLC BMO 

Harris Bank account 7172, then moved to JAMES LARKIN’s BMO 

Harris Bank account ‘3110. These illicit funds were then used 

to pay for appraisal for 493 Zinfandel Lane: 

a. From February 4, 2013 through June 6, 2013, a 

foreign account wire transferred $41.5 million Camarillo 

Holdings LLC, BMO Harris Bank account ‘7172. 

b. On October 2, 2013, BMO Harris Bank account ‘7172 

wired $26,130.64 to JAMES LARKIN’s BMO Harris Bank account 

‘3110. 

c. On November 3, 2016, LARKIN paid a check to an 

appraiser company. Annotated on the memo line: “Zinfandel 

Appraisal 2015” 

 

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 67 of 92
66

F. 1308 E. 56th Street, 2, Chicago, IL 60637

130. James LARKIN, knowingly engaged and attempted to 

engage in a monetary transaction in criminally derived property 

of a value greater than $10,000 and is derived from SUA activity 

in violation of 18 U.S.C. § 1957.

131. As set forth below, funds originating from Backpage’s 

U.S. Bank account ‘1165, was moved through the Camarillo 

Holdings LLC, BMO Harris Bank account, then moved to LARKIN’s 

BMO Harris account ‘3110. Funds from LARKIN’s BMO Harris 

account ‘3110 were then wire transferred to Chicago Title for 

1308 E. 56th Street, 2. Specifically:

a. Between February 4, 2013 and June 6, 2013, over a 

series of wire transfers, Backpage.com U.S. Bank account wired 

about $41.5 million to Camarillo Holdings LLC BMO Harris Bank 

account ‘7172.

b. On October 2, 2013, Camarillo Holdings LLC BMO 

Harris Bank account ‘7172 wire transferred $26,130.64 to 

LARKIN’s BMO Harris Bank account ‘3110.

c. On October 2, 2015, LARKIN’s BMO Harris Bank 

account ‘3110 wired $138,000 to Chicago Title and Trust Company 

as payment for the purchase of 1308 E. 56th Street, 2. 

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 68 of 92
67

G. 10647 N. State Route 89A, Sedona, AZ 86336

132. Michael LACEY knowingly engaged and attempted to 

engage in a monetary transaction through a place outside the 

United States to a place in the United States with the intent to 

promote the carrying on of a specified unlawful activity in 

violation of 18 U.S.C. § 1956(a)(2)(A).

133. As set forth below, financial transactions involving 

illicit proceeds were deposited into Cereus Properties Compass 

Bank, which was then moved through Michael LACEY’s First Federal 

Savings and Loan of San Rafael account ‘3620. Funds from 

LACEY’s Arizona Bank & Trust account ‘1793 were then paid to the 

Coconino County Treasurer for tax obligations for 10647 N. State 

Route 89A. In detail:

a. Between December 2, 2016 and December 30, 2016, a 

foreign account wire transferred $1,023,995.95 into Cereus 

Properties Compass Bank account ‘3873.

b. Between March 3, 2017 and June 9, 2017, Cereus 

Properties Compass Bank account ‘3873 paid about $4,000 of these 

funds to “Cox Communications,” an internet services company that 

provides voice-over-internet phone and cable services.

c. On October 2, 2017, Compass Bank account ‘3825 

owned by Cereus Properties, wired approximately $297,795 into 

First Federal Savings & Loan of San Rafael account ‘3620.

d. On November 13, 2018, LACEY issued a check from 

First Federal Savings & Loan of San Rafael account ‘3620 to the 

Coconino County Treasurer for tax obligations for 10647 N. State 

Route 89A.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 69 of 92
68

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 70 of 92
69

H. 5555 North Casa Blanca Drive, Paradise Valley, AZ 

85253

134. James LARKIN, knowingly engaged and attempted to 

engage in a monetary transaction in criminally derived property 

of a value greater than $10,000 and is derived from SUA activity 

in violation of 18 U.S.C. § 1957.

135. As set forth below, funds originating from Backpage’s 

U.S. Bank account ‘1165 was moved through the Camarillo Holdings 

LLC, BMO Harris Bank account, then moved to LARKIN’s BMO Harris 

account ‘3110. Funds from LARKIN’s BMO Harris account ‘3110 

were then paid to a landscape and gardening service. In detail:

a. Between February 4, 2013 and June 6, 2013, over a 

series of wire transfers, Backpage.com U.S. Bank account wired 

about $41.5 million to Camarillo Holdings LLC BMO Harris Bank 

account ‘7172.

b. On October 2, 2013, Camarillo Holdings LLC BMO 

Harris Bank account ‘7172 wire transferred $26,130.64 to 

LARKIN’s BMO Harris Bank account ‘3110.

c. On December 11, 2014, LARKIN issued a $46,987.28 

check from the BMO Harris Bank account ‘3110 to a lawn and 

garden service company for landscape service for 5555 North Casa 

Blanca Drive. 

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 71 of 92
70

I. LACEY PURCHASES THE PARADISE VALLEY, ARIZONA PROPERTY 

2 USING PROCEEDS TRANSACTIONAL MONEY LAUNDERING 

136. Michael LACEY knowingly engaged and attempted to 

engage in a monetary transaction in criminally derived property 

of a value greater than $10,000 and is derived from SUA activity 

in violation of 18 U.S.C. § 1957. 

As set forth below, financial transactions involving 

illicit proceeds were deposited 

(TRACING TO BE COMPLETED ON MONDAY) 

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 72 of 92
71

J. 3304 E. Stella Lane, Paradise Valley, AZ 85253

137. Michael LACEY, knowingly engaged and attempted to 

engage in a monetary transaction in criminally derived property 

of a value greater than $10,000 and is derived from SUA activity 

in violation of 18 U.S.C. § 1957.

138. As set forth below, funds originating from Backpage’s 

U.S. Bank account ‘1165 was moved through the Camarillo Holdings 

LLC, BMO Harris Bank account, then moved to LACEY’s BMO Harris 

account ‘5263. Funds from LACEY’s BMO Harris account ‘5263 were 

then used to purchase 3304 E. Stella Lane. In detail:

a. Between February 4, 2013 and June 6, 2013, over a 

series of wire transfers, Backpage.com U.S. Bank account wired 

about $41.5 million to Camarillo Holdings LLC BMO Harris Bank 

account ‘7172.

b. Between March 15, 2014 and September 18, 2014, 

Camarillo Holdings LLC BMO Harris Bank account ‘7172 wire 

transferred $11,489,258.12 to LACEY’s BMO Harris Bank account 

‘5263.

c. On March 11, 2015, LACEY wire transferred $50,000 

from his BMO Harris Bank account ‘5263 to Clear Title Agency as 

earnest money deposit for the purchase of the 3304 E. Stella 

Lane.

d. On March 30, 2015, LACEY wire transferred 

$774,379.46 from his BMO Harris Bank account ‘5263 to Clear 

Title Agency to complete the purchase of 3304 E. Stella Lane.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 73 of 92
72

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 74 of 92
73

K. 6300 N. 33rd Street, Paradise Valley, AZ 85253, 6314 

N. 33rd Street, Paradise Valley, AZ 85253, 3308 E. 

Stella Lane, Paradise Valley, AZ 85253, 3311 E. Stella 

Lane, Paradise Valley, AZ 85253

139. Michael LACEY, knowingly engaged and attempted to 

engage in a monetary transaction in criminally derived property 

of a value greater than $10,000 and is derived from SUA activity 

in violation of 18 U.S.C. § 1957.

140. As set forth below, funds originating from Backpage’s 

U.S. Bank account ‘1165 was moved through the Camarillo Holdings 

LLC, BMO Harris Bank account, then moved to LACEY’s BMO Harris 

account ‘5263. Funds from LACEY’s BMO Harris account ‘5263 were 

then wire transferred to an Interest on Lawyers Trust Account 

(“IOLTA”) for his attorney who further wired funds to purchase 

6300 N. 33rd Street, 6314 N. 33rd Street, 3308 E. Stella Lane, 

and 3311 E. Stella Lane. In detail:

a. Between February 4, 2013 and February 11, 2013, 

over a series of wire transfers, Backpage.com U.S. Bank account 

‘1165, wired about $3.2 million to Camarillo Holdings LLC BMO 

Harris Bank account ‘7172.

b. On February 15, 2013, Camarillo Holdings LLC BMO 

Harris Bank account ‘7172 wire transferred $395,513.85 to 

LACEY’s BMO Harris Bank account ‘5263.

c. On May 12, 2015, LACEY wire transferred or caused 

a wire transfer from his BMO Harris Bank account ‘5263, 

$3,350,000 to a his attorney’s IOLTA account.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 75 of 92
74

d. On May 12, 2015, the IOLTA paid $100,000 to 

“Thomas Title & Escrow” for the purchase of 6300 N. 33rd Street, 

6314 N. 33rd Street, 3308 E. Stella Lane, and 3311 E. Stella 

Lane.

e. On May 26, 2015, the IOLTA paid $3,143,132.25 to 

“Thomas Title & Escrow” for the payoff of the PRADISE VALLEY 

PROPERTIES 4, 5, 6, and 7.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 76 of 92
75

L. 7006 San Mateo Blvd Apt 214, Dallas, TX 75223 

141. Daniel HYER knowingly engaged and attempted to engage 

in a monetary transaction with funds derived from violations of 

18 U.S.C. § 1952. 

142. As set forth below, funds originating from Backpage 

controlled Website Technologies payroll account. The payroll 

service company then deposited the funds into DANIEL HYER’s Bank 

of America account ‘9342. These funds were then used to pay the 

mortgage on HYER’s property, 7006 San Mateo Blvd Apt 214. For 

example: 

a. On February 14, 2014, Website Technologies, a 

Backpage controlled entity, through their payroll company 

deposited $5,379.09 to DANIEL HYER’s Bank of America account 

‘9342. 

b. On February 28, 2014, Website Technologies, a 

Backpage controlled entity, through their payroll company 

deposited $5,798.88 to DANIEL HYER’s Bank of America account 

‘9342. 

c. On March 3, 2014, HYER paid the mortgage for the 

DALLAS PROPERTY with funds from the Bank of America account 

‘9342. 

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 77 of 92
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M. 14, rue Saint Guillaurme, Paris, France 75007

143. JAMES LARKIN knowingly engaged and attempted to engage 

in a monetary transaction in criminally derived property of a 

value greater than $10,000 and is derived from SUA activity in 

violation of 18 U.S.C. § 1957.

144. As set forth below, funds originating from Website 

Technologies (Backpage) Branch Banking and Trust account ‘2008 

was moved through Cereus Properties Arizona Bank & Trust account 

‘6211, which them moved through JAMES LARKIN’s Charles Schwab 

account ‘4693, then Northern Trust Account ‘9562, held by the 

Ocotillo Family Trust which is owned by LARKIN. These funds 

were then used to purchase and upgrade 14, rue Saint Guillaurme.

a. On December 31, 2015, Website Technologies’ 

Branch Banking & Trust account ‘2008 wired $811,424 to Arizona 

Bank & Trust account ‘6211.

b. On January 11, 2016, Arizona Bank & Trust account 

‘6211 wired approximately $1.3 million to Charles Schwab account 

‘4693.

c. On January 14, 2016, Charles Schwab account ‘4693 

wired approximately $13.5 million to the Northern Trust account 

‘9562.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 78 of 92
77

d. On February 9 2016, LARKIN wire transferred or 

caused a wire transfer of $3,357,878.91 from his Charles Schwab 

account ‘4693 to SCP Bonnart a real estate company in Paris, 

France.

e. On February 16, 2016, LARKIN wire transferred or 

caused a wire transfer of $36,752 from his Charles Schwab 

account ‘4693 to A+B Kasha Designs, a real estate design company 

in Paris, France. The wire annotations for this wire referenced 

an invoice for the renovation of 14, rue Saint Guillaurme.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 79 of 92
78

N. 3353 Red Robin Road, Pinetop, AZ 85935

145. John BRUNST knowingly engaged and attempted to engage 

in a monetary transaction through a place outside the United 

States to a place in the United States with the intent to 

promote the carrying on of a specified unlawful activity in 

violation of 18 U.S.C. § 1956(a)(2)(A).

146. As set forth below, financial transactions involving 

illicit proceeds were deposited in GoCoin (Slovakia) which was 

then moved through the Website Technologies Branch Banking & 

Trust account ‘2008. These international funds were used to 

promote the SUA, then moved through Cereus Properties Arizona 

Bank & Trust account ‘6211, then moved through John BRUNST’s 

Wells Fargo Bank account ‘4891. Funds from John BRUNST’s Wells 

Fargo Bank account ‘4891 was used to pay the County Treasurer 

for tax obligations for 3353 Red Robin Road. In detail:

a. National Bank of Arizona accounts '0178, ‘0151, 

and ‘3645 are held in the name of SPEAR. In furtherance of 

their money laundering scheme, and in an attempt to further 

conceal the true nature of the money, Backpage Operators used 

these accounts as go-betweens to funnel money from one account 

to another.

147. The tracing involved numerous accounts including: 

Branch Banking & Trust account number ‘2008, belonging to 

Website Technologies; Arizona Bank & Trust account number ‘6211 

belonging to Cereus Properties, and a GoCoin account in 

Slovakia.

a. Between December 14, 2015, and January 15, 2016, 

in approximately 26 wires, a GoCoin account in Slovakia 

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 80 of 92
79

transferred $2,523,475.60 to Branch Banking & Trust account 

number ‘2008 in the United States. 

b. On January 15, 2016, Branch Banking & Trust 

account number ‘2008 wired $189,571 to Verizon in Los Angeles, 

California, in payment for Backpage internet services. 

c. Between March 23, 2016 and March 31, 2016, in 

three wire transfers, Branch Banking & Trust account number 

‘2008 transferred approximately $3,694,813.60 to Arizona Bank & 

Trust account number ‘6211.

d. On January 4, 2017 Arizona Bank & Trust account 

‘6211 wired $298,941 to JOHN BRUNST’s Wells Fargo Bank account 

‘4891.

e. On January 31, 2017, BRUNST, using funds from his 

Wells Fargo Bank account ‘4891 paid $3,773.25 to the Navajo 

County Treasurer for tax obligations for the PINETOP PROPERTY.

f. On October 3, 2017, BRUNST, using funds from his 

Wells Fargo Bank account ‘4891 paid $4,125.92 to the Navajo 

County Treasurer for tax obligations for 3353 Red Robin Road.

g. On February 12, 2017, BRUNST, using funds from 

his Wells Fargo Bank account ‘4891 paid $4,125.92 to the Navajo 

County Treasurer for tax obligations for 3353 Red Robin Road.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 81 of 92
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81

O. 2416 N. Foote Dr., Phoenix, AZ 85008

148. Michael LACEY, knowingly engaged and attempted to 

engage in a monetary transaction in criminally derived property 

of a value greater than $10,000 and is derived from SUA activity 

in violation of 18 U.S.C. § 1957.

149. As set forth below, financial transactions involving 

illicit proceeds were deposited in GoCoin (Singapore) which were 

then moved through the Posting Solutions Veritex Bank account 

‘1462, then moved through the Cereus Properties Compass Bank 

account ‘3873, then moved to his attorney’s IOLTA account at 

MidFirst Bank account ‘4139. Funds from MidFirst Bank account 

‘4139 was used to purchase the PHOENIX PROPERTY 1.

a. Between January 13, 2017 and January 20, 2017, 

GoCoin (Singapore) wired $1,318,800 to Posting Solutions Veritex 

Bank account ‘1462, 

b. On or about February 23, 2017, Veritex Bank 

account ‘1462 sent two payments, a wire of $443,014 and a check 

for $27,887.41 to Cereus Properties Compass Bank account ‘3873.

c. Between March 30, 2017, and September 14, 2017, 

Cereus Properties Compass Bank account ‘3873 sent five wires 

totaling $4,058.063.65 to the attorney’s IOLTA for MICHAEL LACEY 

at MidFirst Bank account ‘4139.

d. On January 3, 2018, LACEY, through his attorney, 

used funds from the MidFirst Bank IOLTA account ‘4139 to 

purchase 2416 N. Foote Dr.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 83 of 92
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83

P. 4931 E. White Gates Drive, Phoenix, AZ 85018

150. John BRUNST knowingly engaged and attempted to engage 

in a monetary transaction in criminally derived property of a 

value greater than $10,000 and is derived from SUA activity in 

violation of 18 U.S.C. § 1957.

151. As set forth below, financial transactions involving 

illicit proceeds from a Backpage controlled Ad Tech BV foreign 

account, were deposited into Cereus Properties Compass Bank 

‘3873, which was then moved through BRUNST’s Compass Bank 

Account ‘3825. Funds from BRUNST’s Compass Bank Account ‘3825 

were then paid to Equity Title Agency Inc. for the purchase of 

4931 E. White Gates Drive.

a. Between December 2, 2016 and December 30, 2016, a 

foreign account wire transferred $1,023,995.95 into Cereus 

Properties Compass Bank account ‘3873.

b. On November 3, 2017, Cereus Properties Compass 

Bank account ‘3873 transferred $73,648.03 to BRUNST’s Compass 

Bank Account ‘3825.

c. On December 22, 2017, BRUNST wire transferred or 

caused a wire transfer of $1.6 million from his Compass Bank 

account ‘3825 to Equity Title Agency Inc. for the purchase of 

4931 E. White Gates Drive. 

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85

Q. 5830 E. Calle Del Medio, Phoenix, AZ 85018

152. JOHN BRUNST knowingly engaged and attempted to engage 

in a monetary transaction through a place outside the United 

States to a place in the United States with the intent to 

promote the carrying on of a specified unlawful activity in 

violation of 18 U.S.C. § 1956(a)(2)(A).

153. As set forth below, financial transactions involving 

illicit proceeds were deposited in GoCoin (Slovakia) which was 

then moved through the Website Technologies Branch Banking & 

Trust account ‘2008, then moved through Cereus Properties 

Arizona Bank & Trust account ‘6211, which is a funnel account. 

These funds were then then used to promote pay tax obligations, 

then moved through John BRUNST’s Wells Fargo Bank account ‘4891. 

Funds from John BRUNST’s Wells Fargo Bank account ‘4891 was used 

to pay the Maricopa County Treasurer for tax obligations for

5830 E. Calle Del Media (Medio):

a. The tracing involved numerous accounts including: 

Branch Banking & Trust account number ‘2008, belonging to 

Website Technologies; Arizona Bank & Trust account number ‘6211 

belonging to Cereus Properties, and a GoCoin account in 

Slovakia.

b. Between December 14, 2015, and December 29, 2015, 

in approximately 13 wire transfers, a GoCoin account in Slovakia 

transferred $1,251,179.97 to Branch Banking & Trust account 

number ‘2008 in the United States. 

c. On December 31, 2015, Branch Banking & Trust 

account number ‘2008 transferred approximately $811,424.07 to 

Arizona Bank & Trust account number ‘6211.

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d. On January 21, 2016, LACEY promoted his business 

by paying $43,013.76 to the Internal Revenue Service for 

business tax obligations.

e. Between January 26, 2016 and January 28, 2016, 

Arizona Bank & Trust account ‘6211 wired $166,367.10 to JOHN 

BRUNST’s Wells Fargo Bank account ‘4891.

f. On September 23, 2016, BRUNST, using funds from 

his Wells Fargo Bank account ‘4891 paid $5,959.42 to the 

Maricopa County Treasurer for tax obligations for 5830 E. Calle 

Del Media (Medio).

g. On January 31, 2017, BRUNST, using funds from his 

Wells Fargo Bank account ‘4891 paid $5,959.42 to the Maricopa 

County Treasurer for tax obligations for 5830 E. Calle Del Media 

(Medio).

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R. 5751 N. 77th Place, Scottsdale, AZ 85250

154. SCOTT SPEAR knowingly engaged and attempted to engage 

in a monetary transaction in criminally derived property of a 

value greater than $10,000 and is derived from SUA activity in 

violation of 18 U.S.C. § 1957.

155. As set forth below, financial transactions involving 

illicit proceeds from a Backpage controlled Ad Tech BV foreign 

account, were deposited into Cereus Properties Compass Bank 

‘3873, which was then moved through SPEAR’s National Bank of 

Arizona account ‘0178, then to SPEAR’s National Bank of Arizona 

account ‘0151. Funds from SPEAR’s National Bank of Arizona 

account were used to pay for upgrades to 5751 N. 77th Place, 

Scottsdale, AZ 85250.

a. Between December 2, 2016 and December 30, 2016, a 

foreign account wire transferred $1,023,995.95 into Cereus 

Properties Compass Bank account ‘3873.

b. On September 14, 2017, Cereus Properties Compass 

Bank account ‘3873 transferred $50,162.05 to SPEAR’s National 

Bank of Arizona account ‘0178.

c. On October 12, 2017, Cereus Properties Compass 

Bank account ‘3873 transferred $50,162.05 to SPEAR’s National 

Bank of Arizona account ‘0178.

d. On December 3, 2017 SPEAR paid $11,925 to a wine 

cellar installation company for the installation of a wine 

cellar into 5751 N. 77th Place.

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Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 90 of 92
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S. 8604 E. San Ardo Dr., Scottsdale, AZ 85258

156. SCOTT SPEAR knowingly engaged and attempted to engage 

in a monetary transaction in criminally derived property of a 

value greater than $10,000 and is derived from SUA activity in 

violation of 18 U.S.C. § 1957.

157. As set forth below, financial transactions involving 

illicit proceeds were deposited in GoCoin (Slovakia) which was 

then moved through the Website Technologies Branch Banking & 

Trust account ‘2008, then moved through Cereus Properties 

Arizona Bank & Trust account ‘6211, which then moved through 

SPEAR’s National Bank of Arizona account ‘0178, and ‘8441. 

Funds from SPEAR’s National Bank of Arizona account ‘8441 was 

used to purchase 8604 E. San Ardo Dr:

a. Between December 14, 2015, and January 29, 2016, 

in approximately 39 wire transfers, a GoCoin account in Slovakia 

transferred $3,959,557.78 to a Backpage controlled Branch 

Banking & Trust account number ‘2008 in the United States. 

b. Between February 2, 2016 and February 29, 2016, 

in five wire transfers, Branch Banking & Trust account number 

‘2008 transferred approximately $6,622,954.08 to Arizona Bank & 

Trust account number ‘6211.

c. On January 4, 2017 Arizona Bank & Trust account 

‘6211 wired $313,168.00 to SPEAR’s National Bank of Arizona 

account ‘0178.

d. On April 18, 2016 SPEAR, transferred 283,332.93 

from his National Bank of Arizona account ‘0178 to his National 

Bank of Arizona account ‘8441.

e. On April 19, 2016, SPEAR wire transferred or 

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90

caused a wire transfer of $283,332.93 from his National Bank of 

Arizona account ‘8441 to Security Title Escrow to purchase 8604 

E. San Ardo Dr.

Case 2:18-cr-00422-DJH Document 1966-4 Filed 11/13/23 Page 92 of 92