Exhibit G 

Case 2:18-cr-00422-DJH Document 643-8 Filed 06/19/19 Page 1 of 3
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Whitney Bernstein

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

Sent: Wednesday, April 10, 2019 4:54 PM

To: Whitney Bernstein

Subject: RE: US v. Lacey et al., 18-CR-0422-PHX-SMB

Attachments: Response to W. Bernstein's 2.26.19 letter.pdf

Hi Whitney: 

I’ve been out of the office today on work‐related travel.  I spoke with FBI personnel in Pocatello, Idaho today 

and unfortunately we are unable to meet with you this Thursday.  The FBI datacenter in Pocatello is required 

to run background checks on all non‐FBI personnel who enter the building and thus require 48‐72 hour notice 

before non‐FBI personnel can enter the building.    That being said, we are available to meet with you to 

inspect the Backpage server data next Wednesday April 17, 2018 at 1pm in Pocatello.  The nine servers seized 

from Amsterdam and three of the five servers seized from Dallas are located in Pocatello.  The 37 servers 

seized from Tucson and two of the five servers seized from Dallas are now available for your review at an FBI 

facility in Phoenix, Arizona.  Since you will be in Phoenix later this month and indicated you plan to pick‐up 

Defendant Larkin’s personal devices from FBI Phoenix during your visit, we are happy to facilitate your 

inspection of the servers located in Phoenix on April 23rd or April 24th.    As I articulated in my March 7, 2019 

email to you (email is attached) per Federal Rule of Criminal Procedure Rule 16, the Backpage server data 

located in Pocatello and Phoenix is available for you to inspect and copy.   

If next Wednesday April 17, 2019, still works for you to travel to Pocatello, please provide me the name, date 

of birth, and social security number of everyone who will be traveling to the datacenter so FBI can start 

conducting the necessary background investigation.   

Also, I’m currently on work‐related travel, but will plan to send you the chain of custody for all servers when 

I’m back in the office on Friday.  The chain of custody will provide a list of all servers in the government’s 

possession.  As we indicated to you previously, there is no master list that describes what data is on each 

server, but as you know, we’ve imaged several servers and have spoken with the former Backpage employee 

who managed the server data and described to you in the attached March 7 letter the data contained on the 

servers currently in our possession.  We were informed by this same former Backpage employee that the 

payment processing data is located on the remaining servers in Amsterdam.  As per your request (and as we 

indicated in our March 7 letter to you), we will make that data as well as any other data contained on those 

remaining servers available to you when it is received via the MLAT process. 

Backpage operated as a classified website for more than 14 years so we’re sure your client, as owner of the 

company, is aware of the data that was hosted on the website.  So, if there is specific data other than ads, 

images, emails, and payment processing data that you believe is material to your defense, please let us know 

and we will attempt to locate that data for you.   

We’ve worked diligently to image and make available to you server data currently in our possession that you 

might find relevant to the case and have even agreed to provide you with exhibits of any server data we might 

utilize at trial to assist you in focusing your efforts and attention.    

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Again, in accordance with the Federal Rules of Criminal Procedure, all Backpage server data in the 

government’s possession is available for your inspection; however, we believe it would be most efficient for all 

parties if you could consult with Defendants and provide the government specific server data other than the 

ad, image, and email data we’ve imaged and made available to you (and payment processing data we will 

make available to you when we receive it), that you believe is material to your defense.   

Please send me the names, dates of birth, and social security numbers for next Wednesday as soon as 

possible, and I will get you the chain of custody documents by the end of the week. 

Best,  

Reggie  

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