Exhibit C 

Case 2:18-cr-00422-DJH Document 195-3 Filed 06/14/18 Page 1 of 3
WAIVER OF ATTORNEY CLIENT PRIVILEGE 

I, Carl Ferrer, state the following in my capacity as sole owner and manager of Dartmoor 

Holdings LLC, which wholly owns and operates Backpage.com LLC ( of which I am Chief 

Executive Officer), Website Technologies LLC, IC Holdings LLC, Posting Solutions LLC, and 

Postfaster LLC, hereafter referred to as "the Companies." I am authorized to waive each of the 

Companies' attorney-client privilege and am doing so because I believe executing such waiver is 

in each of the Companies' best interest. 

I further state that, being represented by counsel and being fully advised as to this matter, 

I hereby voluntarily waive all aspects of the attorney-client privilege, on behalf of the Companies, 

which otherwise may have applied to communications, documents and information that I or the 

Companies have provided to law enforcement or which law enforcement may already have in its 

possession from other sources, as follows: 

a. All communications related to the "adult," "escort," "dating," and "services" sections 

of the Companies' websites, including but not limited to company policies, moderation practices, 

age verification practices, legality, content, and compliance with law enforcement. 

b. All communications related to the Companies' financial activity, including but not 

limited to the sale of Backpage.com in 2015, all loans and financing agreements related to the sale 

of that company in 2015, monetization of the Companies' websites, payment processing, credit 

card processing, banking, and payment of loans. 

c. All communications regarding the relationship between the Companies (including their 

current owner and employees) and their former owners and officers, including but not limited to, 

James Larkin, Michael Lacey, John ("Jed") Brunst and Scott Spear, as well as communications 

between the Companies (including their current owner and employees) and Don Bennett Moon. 

I further state that, in addition to the foregoing waiver, I hereby voluntarily waive, on 

behalf of the Companies, all aspects of the attorney-client privilege which otherwise may have 

applied to the Companies' relationship with any attorney ("previous attorneys") who was 

retained to represent the Companies in connection with various matters related to the subjects 

listed above. This attorney-client privilege waiver is meant to apply to all communications 

between the Companies and any attorney representing them at any time; all acts undertaken by 

others acting on the Companies' attorneys' behalf taken in connection with representing the 

Case 2:18-cr-00422-DJH Document 195-3 Filed 06/14/18 Page 2 of 3
Companies related to the subjects listed above; and any and all documents generated through 

their representation of the Companies that belong to the Companies. 

I further state that this waiver does not apply in any respect to any aspect of the 

Companies' representation by David Botsford of Botsford & Roark LLP, or to any aspect of my 

personal attorney-client relationship with attorneys who have represented me in the past or who 

currently represent me in an individual capacity, including, but not limited to, Nanci Clarence, 

Jonathan Baum and Shaneeda Jaffer of Clarence, Dyer & Cohen, and the Law Offices of E.G. 

Morris. 

DATE / Carl Ferrer 

Case 2:18-cr-00422-DJH Document 195-3 Filed 06/14/18 Page 3 of 3