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3895846.3

DEFENDANTS’ PROPOSED VERDICT FORM

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

United States of America,

Plaintiff,

vs.

Michael Lacey, et al.,

Defendants.

CASE NO. 2:18-cr-00422-PHX-DJH

DEFENDANTS’ PROPOSED 

VERDICT FORM

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 1 of 47
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3895846.3 2

DEFENDANTS’ PROPOSED VERDICT FORM

Conspiracy to Violate the Travel Act

18 U.S.C. § 371

COUNT 1

Count 1:

We, the Jury, unanimously find Defendant:

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of Conspiracy to violate the Travel Act, as charged in Count 1 of the Indictment.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 2 of 47
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3895846.3 3

DEFENDANTS’ PROPOSED VERDICT FORM

Travel Act 

18 U.S.C. § 1952(a)(3)(A)

COUNTS 2-51

Count 2:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

September 10, 2013, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 3:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

January 27, 2014, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 3 of 47
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3895846.3 4

DEFENDANTS’ PROPOSED VERDICT FORM

Count 4:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

January 29, 2014, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 5:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

January 31, 2014, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 4 of 47
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3895846.3 5

DEFENDANTS’ PROPOSED VERDICT FORM

Count 6:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

February 6, 2014, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 7:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

April 20, 2014, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 5 of 47
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3895846.3 6

DEFENDANTS’ PROPOSED VERDICT FORM

Count 8:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

May 7, 2014, by specifically intending to promote or facilitate the promotion of a business 

enterprise involved in prostitution offenses in violation of the laws of _______.

Count 9:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

May 31, 2014, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 6 of 47
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3895846.3 7

DEFENDANTS’ PROPOSED VERDICT FORM

Count 10:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

July 1, 2014, by specifically intending to promote or facilitate the promotion of a business 

enterprise involved in prostitution offenses in violation of the laws of _______.

Count 11:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

August 19, 2014, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 7 of 47
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3895846.3 8

DEFENDANTS’ PROPOSED VERDICT FORM

Count 12:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

November 23, 2014, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 13:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

January 29, 2015, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 8 of 47
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3895846.3 9

DEFENDANTS’ PROPOSED VERDICT FORM

Count 14:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

January 31, 2015, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 15:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

January 31, 2015, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 9 of 47
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3895846.3 10

DEFENDANTS’ PROPOSED VERDICT FORM

Count 16:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

February 4, 2015, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 17:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

February 18, 2015, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 10 of 47
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3895846.3 11

DEFENDANTS’ PROPOSED VERDICT FORM

Count 18:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

February 26, 2015, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 19:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

May 18, 2015, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 11 of 47
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3895846.3 12

DEFENDANTS’ PROPOSED VERDICT FORM

Count 20:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

May 19, 2015, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 21:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

July 1, 2015, by specifically intending to promote or facilitate the promotion of a business 

enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 12 of 47
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3895846.3 13

DEFENDANTS’ PROPOSED VERDICT FORM

Count 22: 

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

July 2, 2015, by specifically intending to promote or facilitate the promotion of a business 

enterprise involved in prostitution offenses in violation of the laws of _______.

Count 23:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

August 13, 2015, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 13 of 47
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3895846.3 14

DEFENDANTS’ PROPOSED VERDICT FORM

Count 24:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

August 15, 2015, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 25:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

September 13, 2015, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 14 of 47
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3895846.3 15

DEFENDANTS’ PROPOSED VERDICT FORM

Count 26:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

November 28, 2015, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 27:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

April 21, 2016, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 15 of 47
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3895846.3 16

DEFENDANTS’ PROPOSED VERDICT FORM

Count 28:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

November 3, 2016, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 29:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

November 11, 2016, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 16 of 47
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3895846.3 17

DEFENDANTS’ PROPOSED VERDICT FORM

Count 30:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

November 14, 2016, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 31: 

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

November 14, 2016, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 17 of 47
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3895846.3 18

DEFENDANTS’ PROPOSED VERDICT FORM

Count 32:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

November 19, 2016, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 33:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

November 24, 2016, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 18 of 47
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3895846.3 19

DEFENDANTS’ PROPOSED VERDICT FORM

Count 34:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

November 26, 2016, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 35:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

December 20, 2016, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 19 of 47
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3895846.3 20

DEFENDANTS’ PROPOSED VERDICT FORM

Count 36: 

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

January 15, 2017, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 37:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

April 4, 2017, by specifically intending to promote or facilitate the promotion of a business 

enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 20 of 47
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3895846.3 21

DEFENDANTS’ PROPOSED VERDICT FORM

Count 38:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

April 11, 2017, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 39:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

July 3, 2017, by specifically intending to promote or facilitate the promotion of a business 

enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 21 of 47
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3895846.3 22

DEFENDANTS’ PROPOSED VERDICT FORM

Count 40:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

July 15, 2017, by specifically intending to promote or facilitate the promotion of a business 

enterprise involved in prostitution offenses in violation of the laws of _______.

Count 41:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

July 15, 2017, by specifically intending to promote or facilitate the promotion of a business 

enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 22 of 47
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3895846.3 23

DEFENDANTS’ PROPOSED VERDICT FORM

Count 42:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

July 21, 2017, by specifically intending to promote or facilitate the promotion of a business 

enterprise involved in prostitution offenses in violation of the laws of _______.

Count 43:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

July 23, 2017, by specifically intending to promote or facilitate the promotion of a business 

enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 23 of 47
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3895846.3 24

DEFENDANTS’ PROPOSED VERDICT FORM

Count 44:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

January 26, 2018, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 45:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

January 30, 2018, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 24 of 47
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3895846.3 25

DEFENDANTS’ PROPOSED VERDICT FORM

Count 46:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

January 30, 2018, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 47:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

January 30, 2018, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 25 of 47
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2

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3895846.3 26

DEFENDANTS’ PROPOSED VERDICT FORM

Count 48:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

January 31, 2018, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 49:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

February 1, 2018, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 26 of 47
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2

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5

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18

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3895846.3 27

DEFENDANTS’ PROPOSED VERDICT FORM

Count 50:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

February 6, 2018, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Count 51:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

Andrew Padilla ______ NOT GUILTY ______ GUILTY

Joye Vaught ______ NOT GUILTY ______ GUILTY

of violating the Travel Act in connection with the advertisement found at Exhibit ___ on 

February 6, 2018, by specifically intending to promote or facilitate the promotion of

a business enterprise involved in prostitution offenses in violation of the laws of _______.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 27 of 47
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2

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4

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6

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3895846.3 28

DEFENDANTS’ PROPOSED VERDICT FORM

Conspiracy to Commit Money Laundering

18 U.S.C. § 1956(h)

COUNT 52

Count 52:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of Conspiracy to commit Money Laundering, as charged in Count 52 of the Indictment.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 28 of 47
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18

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20

21

22

23

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26

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3895846.3 29

DEFENDANTS’ PROPOSED VERDICT FORM

Concealment Money Laundering

18 U.S.C. § 1956(a)(1)(B)(i)

COUNTS 53-62

Count 53:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Concealment Money Laundering in connection with the May 18, 2016 

transfer of $1,476,505.00 from Website Technologies to Cereus Properties.

Count 54:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Concealment Money Laundering in connection with the May 18, 2016 

transfer of $264,438.00 from Website Technologies to Cereus Properties.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 29 of 47
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DEFENDANTS’ PROPOSED VERDICT FORM

Count 55:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Concealment Money Laundering in connection with the May 31, 2016 

transfer of $3,171,675.80 from Website Technologies to Cereus Properties.

Count 56:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Concealment Money Laundering in connection with the May 31, 2016 

transfer of $432,961.87 from Website Technologies to Cereus Properties.

Count 57:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Concealment Money Laundering in connection with the June 20, 2016 

transfer of $842,878.00 from Website Technologies to Cereus Properties.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 30 of 47
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3895846.3 31

DEFENDANTS’ PROPOSED VERDICT FORM

Count 58:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Concealment Money Laundering in connection with the June 30, 2016 

transfer of $3,076,147.75 from Website Technologies to Cereus Properties.

Count 59:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Concealment Money Laundering in connection with the July 27, 2016 

transfer of $3,252,681.62 from Website Technologies to Cereus Properties.

Count 60:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Concealment Money Laundering in connection with the July 27, 2016 

transfer of $438,818.86 from Website Technologies to Cereus Properties.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 31 of 47
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DEFENDANTS’ PROPOSED VERDICT FORM

Count 61:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Concealment Money Laundering in connection with the August 16, 2016

transfer of $804,250.00 from Website Technologies to Cereus Properties.

Count 62:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Concealment Money Laundering in connection with the August 31, 2016 

transfer of $3,171,264.42 from Website Technologies to Cereus Properties.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 32 of 47
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18

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3895846.3 33

DEFENDANTS’ PROPOSED VERDICT FORM

International Promotional Money Laundering

18 U.S.C. § 1956(a)(2)(A)

COUNTS 63-68

Count 63:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing International Promotional Money Laundering in connection with the 

March 4, 2014 transfer of $6,450.00 from U.S. Bank to S.B (India).

Count 64:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing International Promotional Money Laundering in connection with the 

August 5, 2016 transfer of $5,005,732.86 from Ad Tech B.V. to Cereus Properties.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 33 of 47
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3895846.3 34

DEFENDANTS’ PROPOSED VERDICT FORM

Count 65:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing International Promotional Money Laundering in connection with the 

September 22, 2016 transfer of $2,916,955.00 from Ad Tech B.V. to Cereus Properties.

Count 66:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing International Promotional Money Laundering in connection with the 

October 3, 2016 transfer of $354,050.84 from Ad Tech B.V. to Cereus Properties.

Count 67:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing International Promotional Money Laundering in connection with the 

November 2, 2016 transfer of $2,726,170.00 from Ad Tech B.V. to Cereus Properties.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 34 of 47
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DEFENDANTS’ PROPOSED VERDICT FORM

Count 68:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing International Promotional Money Laundering in connection with the 

November 15, 2016 transfer of $351,403.54 from Ad Tech B.V. to Cereus Properties.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 35 of 47
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2

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4

5

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18

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3895846.3 36

DEFENDANTS’ PROPOSED VERDICT FORM

Transactional Money Laundering

18 U.S.C. § 1957(a)

COUNTS 69-99

Count 69:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the August 21, 2013

transfer of $30,000.00 from Bank of America to Stewart Title.

Count 70:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the September 13, 

2013 transfer of $62,491.47 from BMO Harris to Stewart Title.

Count 71:

We, the Jury, unanimously find Defendant: 

Scott Spear ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the June 11, 2014

transfer of $300,000.00 from National Bank of Arizona to Spear Family Trust.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 36 of 47
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5

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DEFENDANTS’ PROPOSED VERDICT FORM

Count 72:

We, the Jury, unanimously find Defendant: 

Scott Spear ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the June 20, 2014

transfer of $200,000.00 from National Bank of Arizona to TD Ameritrade.

Count 73:

We, the Jury, unanimously find Defendant: 

Scott Spear ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the November 4, 2014

transfer of $1,000,000.00 from National Bank of Arizona to UBS Financial.

Count 74:

We, the Jury, unanimously find Defendant: 

Scott Spear ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the May 14, 2015

transfer of $250,000.00 from National Bank of Arizona to Lincoln National Life.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 37 of 47
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4

5

6

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18

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DEFENDANTS’ PROPOSED VERDICT FORM

Count 75:

We, the Jury, unanimously find Defendant: 

Scott Spear ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the May 26, 2015

transfer of $50,000.00 from National Bank of Arizona to Industrial Property Trust.

Count 76:

We, the Jury, unanimously find Defendant: 

Scott Spear ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the November 3, 2015

transfer of $300,000.00 from National Bank of Arizona to Ally Bank.

Count 77:

We, the Jury, unanimously find Defendant: 

Scott Spear ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the December 1, 2015

transfer of $200,000.00 from National Bank of Arizona to Wells Fargo.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 38 of 47
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4

5

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7

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18

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DEFENDANTS’ PROPOSED VERDICT FORM

Count 78:

We, the Jury, unanimously find Defendant: 

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the January 11, 2016

transfer of $133,045.00 from Cereus Properties to National Bank of Arizona.

Count 79:

We, the Jury, unanimously find Defendant: 

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the January 26, 2016

transfer of $101,974.00 from Cereus Properties to Wells Fargo.

Count 80:

We, the Jury, unanimously find Defendant: 

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the February 3, 2016

transfer of $1,507,944.00 from Cereus Properties to Charles Schwab.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 39 of 47
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2

3

4

5

6

7

8

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10

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16

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18

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DEFENDANTS’ PROPOSED VERDICT FORM

Count 81:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the March 1, 2016

transfer of $1,692,020.00 from Cereus Properties to Bank of America.

Count 82:

We, the Jury, unanimously find Defendant: 

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the April 1, 2016

transfer of $220,944.00 from Cereus Properties to Wells Fargo.

Count 83:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the June 27, 2016

transfer of $397,500.00 from Arizona Bank & Trust to Fidelity Title.

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 40 of 47
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2

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5

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18

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DEFENDANTS’ PROPOSED VERDICT FORM

Count 84:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the July 20, 2016

transfer of $12,859,152.57 from Arizona Bank & Trust to Fidelity Title.

Count 85:

We, the Jury, unanimously find Defendant: 

Scott Spear ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the July 22, 2016

transfer of $50,000.00 from National Bank of Arizona to Strategic Storage Trust II.

Count 86:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the August 2, 2016

transfer of $16,243.00 from Cereus Properties to Wells Fargo.

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DEFENDANTS’ PROPOSED VERDICT FORM

Count 87:

We, the Jury, unanimously find Defendant: 

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the October 6, 2016

transfer of $1,206,356.00 from Cereus Properties to Charles Schwab.

Count 88:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the October 6, 2016

transfer of $268,016.00 from Cereus Properties to Arizona Bank & Trust.

Count 89:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the October 6, 2016

transfer of $268,016.00 from Cereus Properties to Arizona Bank & Trust.

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Count 90:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the October 6, 2016

transfer of $268,016.00 from Cereus Properties to Arizona Bank & Trust.

Count 91:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the October 6, 2016

transfer of $268,016.00 from Cereus Properties to Arizona Bank & Trust.

Count 92:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the October 6, 2016

transfer of $268,016.00 from Cereus Properties to Arizona Bank & Trust.

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DEFENDANTS’ PROPOSED VERDICT FORM

Count 93:

We, the Jury, unanimously find Defendant: 

Scott Spear ______ NOT GUILTY ______ GUILTY

John Brunst ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the October 6, 2016

transfer of $141,444.00 from Cereus Properties to National Bank of Arizona.

Count 94:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the December 29, 

2016 transfer of $3,300,000.00 from Arizona Bank & Trust/Dubuque Bank & Trust to 

Johnson Bank.

Count 95:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the December 29, 

2016 transfer of $3,300,000.00 from Arizona Bank & Trust/Dubuque Bank & Trust to 

Johnson Bank.

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Count 96:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the December 29, 

2016 transfer of $3,300,000.00 from Arizona Bank & Trust/Dubuque Bank & Trust to 

Johnson Bank.

Count 97:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the December 29, 

2016 transfer of $3,300,000.00 from Arizona Bank & Trust/Dubuque Bank & Trust to 

Johnson Bank.

Count 98:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the December 29, 

2016 transfer of $3,300,000.00 from Arizona Bank & Trust/Dubuque Bank & Trust to 

Johnson Bank.

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Count 99:

We, the Jury, unanimously find Defendant: 

Michael Lacey ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the January 3, 2017

transfer of $16,500,000.00 from Johnson Bank to Primus Trust Co./K&H Bank.

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International Concealment Money Laundering

18 U.S.C. § 1956(a)(2)(B)(i)

COUNT 100

Count 100:

We, the Jury, unanimously find Defendant:

Michael Lacey ______ NOT GUILTY ______ GUILTY

of committing Transactional Money Laundering in connection with the January 3, 2017

transfer of $16,500,000.00 from Johnson Bank to Primus Trust Co./K&H Bank.

DATE: ____________________

FOREPERSON

Case 2:18-cr-00422-DJH Document 1877 Filed 10/19/23 Page 47 of 47