Exhibit 3 – Part A

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United States District Court 

CENTRAL DISTRICT OF CALIFORNIA -------------------- -------------------------- In the Matter of the Seizure of 

(Address or Brief description of property or premises to be seized) 

UP TO AND INCLUDING $5,279,173.07 

HELD IN BANK OF THE WEST 

ACCOUNT #035-171363 

I, LYNDON A. VERSOZA, being duly sworn, depose and say: 

AMENDED 

APPLICATION AND AFFIDAVIT 

FOR SEIZURE WARRANT 

CASE NUMBER: 2:18-MJ-2872 

I am a United States Postal Inspector with the United States Postal Inspection Service, and I have reason to believe that 

in the Central District of CALIFORNIA 

there is now concealed a certain person or property' namely (describe the person or property to be seized) 

Up to and including $5,279,173.07 held in Bank of the West Account #035-171363 

which is (state one or more bases for seizure under United States Code) 

subject to seizure and forfeiture under 18 U.S.C. § 981 (a)(l)(A) and (C) 

concerning a violations of Title ...IB_ United States Code, Sections 1952(a)(3)(A) and (b) 1956 and 1957. 

The facts to support a finding of Probable Cause for issuance of a Seizure Warrant are as follows: 

Continued on the attached sheet and made a part hereof. X Yes No 

Sworn to before me, and subscribed in my presence 

10/31/18 

Date 

ISi 

Signature of Affiant 

Los Angeles, California 

City and State 

Hon. ROZELLA A. OLIVER, U.S. Magistrate Judge 

Name and Title of Judicial Officer 

• 

~ ~ ·°',--- • ., _Q_(l_, , _ Signature of Judicial Officer 

John Kucera: smb 

DOJ-BP-0004 719085 

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AFFIDAVIT IN SUPPORT OF SEIZURE WARRANT 

I, Lyndon A. Versoza, being duly sworn, hereby depose and state 

as follows: 

I. TRAINING AND EXPERIENCE 

1. I am a United States Postal Inspector employed by the 

United States Postal Inspection Service ("USPIS"), Los Angeles 

Division, in Los Angeles, California, where I have served since 

June 2005. Currently, I am responsible for investigating 

criminal violations of money laundering and structuring laws, 

such as when United States Postal Service ("USPS") Money Orders 

or the United States Mail are used as a means to launder or 

structure funds. During my career as a Postal Inspector, I have 

participated in or investigated financial violations including 

money laundering, darknet investigations, digital currency 

investigations, structuring, bank, wire and mail fraud, and 

identity theft. In addition, I have received both formal and 

informal training from USPIS and other agencies regarding money 

laundering and financial crimes. For approximately five years 

prior to investigating money laundering, I was assigned to 

investigate child exploitation and sex trafficking. In that 

assignment, I worked both independently and in a task force 

where I led and participated in investigations related to crimes 

involving the exploitation of children and sex trafficking. 

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DOJ-BP-0004 719086 

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2. Prior to my service as a U.S. Postal Inspector, I 

attended the University of Southern California in Los Angeles, 

where, in 2001, I received a bachelor's degree. While in 

college, I was the website administrator for a non-profit media 

company in Los Angeles where, among other things, I learned 

about domain names, domain name servers, and remote hosting. 

Following college, from 2002 to 2005, I served as a law 

enforcement officer with the U.S. Immigration and Naturalization 

Service, which later became U.S. Customs and Border Protection. 

There, among other things, I worked on cases involving human 

smuggling and international sex trafficking. 

3. I am familiar with the facts and circumstances 

described herein. This affidavit is based upon my personal 

involvement in this investigation, my training and experience, 

and information obtained from various law enforcement personnel 

and witnesses, including information that has been reported to 

me either directly or indirectly. This affidavit does not 

purport to set forth my complete knowledge or understanding of 

the facts related to this investigation. Unless specifically 

indicated otherwise, all conversations and statements described 

in this affidavit are related in substance and part only. All 

figures, times, and calculations set forth herein are 

approximate. 

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DOJ-BP-0004 719087 

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II. SUMMARY AND PURPOSE OF AFFIDAVIT 

4. This affidavit is made in support of applications for 

warrants to seize all funds held in certain SUBJECT ACCOUNTS 1 

(identified specifically below at paragraph 10), all owned, 

controlled, or held for the benefit of "Backpage.com" (referred 

to herein as "Backpage"), associated entities, and their owners 

and operators. 

A. Background 

5. This case is being investigated by the USPIS, the 

Federal Bureau of Investigation and the Internal Revenue 

Service-Criminal Investigation, with assistance from the Los 

Angeles Joint Regional Intelligence Center. 

6. The focus of the investigation has been on violations 

by Backpage, its associated entities, and their owners and 

operators, of Title 18, United States Code, Sections 1591(a), 

1952 (a) (3) (A) and (b) (i) (1) (Interstate and Foreign Travel in 

Aid of Racketeering Enterprise); and Title 18 U.S.C. §§ 1956 and 

1957, (Money Laundering) . 

7. From speaking with other agents in this investigation, 

1 The numbering of the SUBJECT ACCOUNTS picks up from prior 

warrant applications for different accounts, the contents of 

which have already been seized or restrained following seizure 

warrants issued in this District. See 18-MJ-711; 18-MJ-712; 18-

MJ-713; 18-MJ-715; 18-MJ-716; 18-MJ-178; 18-MJ-720; 18-MJ-721; 

18-MJ-722; 18-MJ-723; 18-MJ-724; 18-MJ-751; 18-MJ-752; 18-MJ797; 18-MJ-798; 18-MJ-996; 18-MJ-1863; and 18-MJ-1864. 

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DOJ-BP-0004 719088 

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and reviewing emails, internal documents, and other records 

related to this investigation, I know the following: 

a. Backpage.com, LLC, incorporated in Delaware in 

2004, is an internet-based company that allows customers to post 

on-line classified advertisements. These advertisements include 

sections dedicated to a variety of matters, including adult, 

automotive, community, dating, jobs, local places, musicians, 

rentals and services. Backpage receives between 75 million to 

100 million unique internet visitors per month. 

b. Backpage realizes profits in the tens of millions 

of dollars per year from adult advertisement. Historically, 

adult ads, where Backpage advertisers post sex trafficking ads, 

constitute less than ten percent of all advertisements posted on 

the website. However, the adult ads generate over 90 percent of 

Backpage's revenue. In short, Backpage derives almost all its 

revenue and profits from adult service ads, including 

advertising for sex trafficking. 2 

2 According to Backpage accounting records, for the period May 1 

to May 31, 2014, over 90% of Backpage's revenues derived from 

what they characterized as "adult entertainment." Backpage's 

internal documents suggest that this 90% figure has been 

consistent since its 2004 inception. 

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DOJ-BP-0004 719089 

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c. In or about 2004, operators Michael Lacey 

("Lacey"), James Larkin ("Larkin"), and Carl Ferrer ("Ferrer") 

created Backpage. There were also two minority owners; John 

Brunst ("Brunst"), who owned 5.67 percent; and Scott Spear 

("Spear"), who owned 4.09 percent. From 2004 until 2015, Lacey 

and Larkin oversaw the website's policies and strategic 

direction. In 2015, Lacy and Larkin purportedly sold all or 

substantially all of their interests in Backpage to Ferrer. 3 

However Lacey and Larkin retained significant control over the 

website, and both Lacey and Larkin continue to receive tens of 

millions of dollars of annual distributions of Backpage revenue. 

d. While not an original owner, Ferrer was one of 

the original officers of Backpage, having initially served as 

Backpage's vice-president, and later as CEO. Ferrer is also the 

CEO of several Backpage related entities in the Netherlands, 

including "Website Technologies," "Amstel River Holdings," and 

For example, between October 6, 2014, and May 31, 2015, 

Backpage grossed almost $105 million from advertising "adult 

entertainment." During this same period, Backpage grossed only 

$1.6 million from all other advertisements combined. Assuming 

that Backpage has accurately estimated that 90% of its revenues 

are generated from "adult" and "escort" ads, Backpage has 

generated as much as $500 million in prostitution-related 

revenue since 2004. 

3 From my review of financial records related to Ferrer's 2015 

agreement to purchase Backpage, it appears that, through a 

series of loans from other Backpage Operators to be repaid by 

Ferrer, Ferrer agreed to purchase Backpage for approximately 

$400 million. 

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DOJ-BP-0004 719090 

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"Ad Tech BV." 

e. Michael Thomas Gage ("Gage") has no formal 

position at Backpage, but is the President, Chief Executive 

Officer, Treasurer, and Secretary of another Backpage controlled 

entity, "Posting Solutions," a wholly owned subsidiary of 

Backpage that receives payments from Backpage advertisers. 

According to his social media profile, Gage is also the Chief 

Financial Officer of Website Technologies. Based on emails he 

has sent and wire transfer information, Gage appears to control 

much of the international and domestic financial transactions of 

Backpage and its related entities. 

f. Daniel Hyer ("Hyer") at one time was the Sales 

and Marketing Director of Backpage. He remains an account 

signatory for Backpage controlled entities, including Website 

Technologies. 

8. Throughout this affidavit, the individuals identified 

in paragraphs 7(c) through (f), along with others not named in 

this affidavit, are collectively referred to as the "Backpage 

Operators." 

9. Based on a review of publicly available materials 

obtained in the course of the investigation, and my review of 

the Backpage website, I have learned the following: 

a. The majority of the paid advertisements on the 

Backpage website relate to prostitution activities in violation 

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DOJ-BP-0004 719091 

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of 18 U.S.C. §§ 1591 and 1952. 

b. As further described below, Backpage itself, as 

well as its operators, who are in control of the SUBJECT 

ACCOUNTS (as defined below), is in the business of promoting the 

trafficking of children and adults for sex. Sex trafficking of 

adults is a violation of 18 U.S.C. § 1952, and sex trafficking 

of children is a violation of 18 U.S.C. 1591, each of which 

statutes is a Specified Unlawful activity ("SUA'') within the 

meaning of federal law. (see 18 U.S.C. § 1956(c) (7) (A), 

identifying as an SUA certain "racketeering activity" as defined 

in 18 U.S.C. § 1961(a)). 

c. The SUBJECT ACCOUNTS are located both inside and 

outside the United States. The domestic accounts have received 

wire transfers from places outside of the United States or have 

received funds traceable to wire transfers from places outside 

of the United States, which funds Backpage has used to promote 

sex trafficking, in violation of 18 U.S.C. § 1956(a) (2) (A) 

(International Money Laundering). Some of the SUBJECT ACCOUNTS 

have received transfers or deposits in excess of $10,000 

traceable to the SUA, in violation of 18 U.S.C. § 1957 (Money 

Laundering Spending Statute). 

d. Backpage, until recently, controlled numerous 

domain names that have since been seized by the government 

pursuant to a seizure warrant issued in this district in case 

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DOJ-BP-0004 719092 

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no. CR. Misc. 2:18-MJ-00711. 4 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. 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 an account seized pursuant to a 

separate seizure warrant in case no. CR. Misc. 2:18-MJ-00721, 

and the Seized Domains were the mechanism Backpage used to 

promote the prostitution and sex trafficking activity described 

below. 

4 On March 28, 2018, the Honorable Patrick J. Walsh, United 

States Magistrate Judge for the Central District of California, 

issued seizure warrants for certain Backpage owned or controlled 

domain names (see 18-MJ-00711). On April 6, 2018, pursuant to 

that warrant, Backpage.com was seized and ceased operations. 

The domain names seized pursuant to that warrant are referred to 

herein as the "seized domains." 

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DOJ-BP-0004 719093 

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B. SUBJECT ACCOUNTS 5 

10. This affidavit is offered in support of applications 

for warrants to seize funds and securities held in the following 

U.S. bank accounts (hereinafter referred to as the "SUBJECT 

ACCOUNTS"). SUBJECT ACCOUNTS 28 through 42 are "Interest on 

Lawyers Trust Accounts" ("IOLTAs"), ostensibly holding funds for 

possible future legal services Backpage might need. According 

to Ferrer, in anticipation of future legal services and in the 

event of government seizure of Backpage-held bank accounts, 

Backpage provided retainer funds for law firms to access when 

legal services would arise. Ferrer has stated that the funds in 

these accounts were obtained from Backpage ad sales, most of 

which was for prostitution. I have confirmed through my own 

review of Backpage internal banking records that the funds 

originated from Backpage. As described below in paragraph 35, 

as part of Backpage and Ferrer's plea agreement, they have 

agreed to surrender all Backpage assets. According to Backpage 

and Ferrer, the assets held in these IOLTAs are proceeds of 

criminal activity and should be forfeited to the government. 

5 Following the initial seizure warrant of March 28, 2018, 

additional seizures have been issued in this District. In order 

to maintain consistency with prior numbered related seized 

subject accounts, the SUBJECT ACCOUNTS described herein begin at 

SUBJECT ACCOUNT 28. For a complete description of the related 

seizure warrants, including date of issue, account number and 

the issuing Magistrate Judge, please see Attachment A. 

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DOJ-BP-0004 719094 

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a. SUBJECT ACCOUNT 28: Bank of the West account 

035-171363 is an IOLTA held in the name of Rusing Lopez & 

Lizardi PLLC. Based on my conversations with Ferrer and my 

review of banking records, I believe that Backpage or Backpagecontrolled entities are the beneficiaries of this account. As 

further described and traced in this affidavit, $5,279,173.07 of 

funds from this account are criminally derived proceeds from 

Backpage. 

b. SUBJECT ACCOUNT 29: Wells Fargo account 

2000608102052 is an IOLTA held in the name of Copeland, Franco, 

Screws & Gill, PA Trust Account. Based on my conversations with 

Ferrer and my review of banking records, I believe that Backpage 

or Backpage-controlled entities are the beneficiaries of this 

account. As further described and traced in this affidavit, 

$100,000 of funds from this account are criminally derived 

proceeds from Backpage. 

c. SUBJECT ACCOUNT 30: SunTrust Bank account 

1000144637906 is an IOLTA held in the name of David B. Smith, 

PLLC IOLTA Account. Based on my conversations with Ferrer and 

my review of banking records, I believe that Backpage or 

Backpage-controlled entities are the beneficiaries of this 

account. As further described and traced in this affidavit, 

$10,000 of funds from this account are criminally derived 

proceeds from Backpage. 

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DOJ-BP-0004 719095 

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d. SUBJECT ACCOUNT 31: Citibank account 205027287 is 

an IOLTA held in the name of Keker Van Nest & Peters. Based on 

my conversations with Ferrer and my review of banking records, I 

believe that Backpage or Backpage-controlled entities are the 

beneficiaries of this account. As further described and traced 

in this affidavit, $500,000 of funds from this account are 

criminally derived proceeds from Backpage. 

e. SUBJECT ACCOUNT 32: Citibank account 30525705 is 

an IOLTA held in the name of McDermott Will and Emery LLP. 

Based on my conversations with Ferrer and my review of banking 

records, I believe that Backpage or Backpage-controlled entities 

are the beneficiaries of this account. As further described and 

traced in this affidavit, $100,000 of funds from this account 

are criminally derived proceeds from Backpage. 

f. SUBJECT ACCOUNT 33: Citibank account 1255464039 

is an IOLTA held in the name of Prince Lobel Tye, LLP. Based on 

my conversations with Ferrer and my review of banking records, I 

believe that Backpage or Backpage-controlled entities are the 

beneficiaries of this account. As further described and traced 

in this affidavit, $100,000 of funds from this account are 

criminally derived proceeds from Backpage. 

g. SUBJECT ACCOUNT 34: US Bank account 153555921235 

is an IOLTA held in the name of Perkins Coie LLP. Based on my 

conversations with Ferrer and my review of banking records, I 

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DOJ-BP-0004 719096 

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believe that Backpage or Backpage-controlled entities are the 

beneficiaries of this account. As further described and traced 

in this affidavit, $2,167,704.86 of funds from this account are 

criminally derived proceeds from Backpage. 

h. SUBJECT ACCOUNT 35: US Bank account 100-06-06952 

is an IOLTA held in the name of Thompson Coburn. Based on my 

conversations with Ferrer and my review of banking records, I 

believe that Backpage or Backpage-controlled entities are the 

beneficiaries of this account. As further described and traced 

in this affidavit, $100,000 of funds from this account are 

criminally derived proceeds from Backpage. 

i. SUBJECT ACCOUNT 36A: JP Morgan Chase bank account 

211909285 is an IOLTA held in the name of Piccarreta Davis 

Keenan Fidel PC. Based on my conversations with Ferrer and my 

review of banking records, I believe that Backpage or Backpagecontrolled entities are the beneficiaries of this account. As 

further described and traced in this affidavit, $10,000 of funds 

from this account are criminally derived proceeds from Backpage. 

j. SUBJECT ACCOUNT 36B: Grand Point bank account 

2503985 is an IOLTA held in the name of Piccarreta Davis Keenan 

Fidel PC. Based on my conversations with Ferrer and my review 

of banking records, I believe that Backpage or Backpagecontrolled entities are the beneficiaries of this account. As 

further described and traced in this affidavit, $740,000 of 

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DOJ-BP-0004 719097 

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funds from this account are criminally derived proceeds from 

Backpage. 

k. SUBJECT ACCOUNT 37: JP Morgan Chase bank account 

851844381 is an IOLTA held in the name of Lawrence G Walters, 

P.A. Based on my conversations with Ferrer and my review of 

banking records, I believe that Backpage or Backpage-controlled 

entities are the beneficiaries of this account. As further 

described and traced in this affidavit, $100,000 of funds from 

this account are criminally derived proceeds from Backpage. 

1. SUBJECT ACCOUNT 38: JP Morgan Chase bank account 

100079698 is an IOLTA held in the name of Akin Gump Strauss 

Hauer & Feld, LLP. Based on my conversations with Ferrer and my 

review of banking records, I believe that Backpage or Backpagecontrolled entities are the beneficiaries of this account. As 

further described and traced in this affidavit, $250,000 of 

funds from this account are criminally derived proceeds from 

Backpage. 

m. SUBJECT ACCOUNT 39: Plains Capital bank account 

3100033921 is an IOLTA held in the name of Scheef & Stone, LLP. 

Based on my conversations with Ferrer and my review of banking 

records, I believe that Backpage or Backpage-controlled entities 

are the beneficiaries of this account. As further described and 

traced in this affidavit, $25,000 of funds from this account are 

criminally derived proceeds from Backpage. 

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DOJ-BP-0004 719098 

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n. SUBJECT ACCOUNT 40: JP Morgan Chase bank account 

616275397 is an IOLTA held in the name of Wayne B. Giampietro, 

LLC. Based on my conversations with Ferrer and my review of 

banking records, I believe that Backpage or Backpage-controlled 

entities are the beneficiaries of this account. As further 

described and traced in this affidavit, $100,000 of funds from 

this account are criminally derived proceeds from Backpage. 

o. SUBJECT ACCOUNT 41A: Alliance Bank of Arizona 

account 8010597402 is an IOLTA held in the name of Mitchell 

Stein Carey, PC. Based on my conversations with Ferrer and my 

review of banking records, I believe that Backpage or Backpagecontrolled entities are the beneficiaries of this account. As 

further described and traced in this affidavit, $100,000 of 

funds from this account are criminally derived proceeds from 

Backpage. 

p. SUBJECT ACCOUNT 41B: Alliance Bank of Arizona 

account 8010596206 is an IOLTA held in the name of Mitchell 

Stein Carey, PC. Based on my conversations with Ferrer and my 

review of banking records, I believe that Backpage or Backpagecontrolled entities are the beneficiaries of this account. As 

further described and traced in this affidavit, $100,000 of 

funds from this account are criminally derived proceeds from 

Backpage. 

q. SUBJECT ACCOUNT 42: Western Alliance Bank account 

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DOJ-BP-0004 719099 

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8011386979 is an IOLTA held in the name of Karp & Weiss, P.C. 

Based on my conversations with Ferrer and my review of banking 

records, I believe that Backpage or Backpage-controlled entities 

are the beneficiaries of this account. As further described and 

traced in this affidavit, $250,000 of funds from this account 

are criminally derived proceeds from Backpage. 

r. SUBJECT ACCOUNT 43A: USAA Savings Bank account 

0213582155 is an account held in the name of Oaxaca Trust. The 

trustee of this account is a family member of LARKIN. Funds in 

this account originated from money earned from Backpage Ad sales 

and flowed through several layers of LARKIN-owned accounts. 

s. SUBJECT ACCOUNT 43B: USAA Savings Bank account 

0213582058 is an account held in the name of Oaxaca Trust. The 

trustee of this account is a family member of LARKIN. Funds in 

this account originated from money earned from Backpage Ad sales 

and flowed through several layers of LARKIN-owned accounts. 

t. SUBJECT ACCOUNT 43C: USAA Savings Bank account 

0213582171 is an account held in the name of Oaxaca Trust. The 

trustee of this account is a family member of LARKIN. Funds in 

this account originated from money earned from Backpage Ad sales 

and flowed through several layers of LARKIN-owned accounts. 

u. SUBJECT ACCOUNT 43D: USAA Savings Bank account 

0213581507 is an account held in the name of Oaxaca Trust. The 

trustee of this account is a family member of LARKIN. Funds in 

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DOJ-BP-0004 719100 

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this account originated from money earned from Backpage Ad sales 

and flowed through several layers of LARKIN-owned accounts. 

v. SUBJECT ACCOUNT 44: Texas Bank and Trust account 

596620 is an account held in the name of Bristol Staffing, LLC. 

Based on my conversations with Ferrer, attorneys representing 

Bristol Staffing, and my review of banking records, as further 

described and traced in this affidavit, $745,111.89 of funds 

from this account are criminally derived proceeds from Backpage. 

III. APPLICABLE LAW 

11. There is probable cause to believe that funds and/or 

securities on deposit in the SUBJECT ACCOUNTS are subject to 

seizure and forfeiture by the United States under the following 

provisions: 

w. 18 U.S.C. § 981(a) (1) (A), because the funds and/or 

securities are involved in, and traceable to, one or more 

transactions or attempted transactions in violation of 18 U.S.C. 

§ 1956 (h) (Conspiracy to Launder Money), 18 U.S.C. § 1956 (a) (2) 

(International Money Laundering for Promotion), and 18 U.S.C. § 

1957 (Financial Transactions Involving Illicit Proceeds). 

Pursuant to 18 U.S.C. § 981(a) (1) (A), any property involved in a 

transaction, or attempted transaction, in violation of 18 U.S.C. 

§§ 1956 or 1957, or any property traceable to such property, is 

subject to forfeiture to the United States; and 

x. 18 U.S.C. § 981 (a) (1) (C), because the funds and/or 

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DOJ-BP-0004719101 

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securities constitute and are derived from proceeds traceable to 

one or more violations of 18 U.S.C. § 1956(h), 18 U.S.C. § 

19 5 6 (a) ( 2 ) , and 18 U. S . C . § 19 5 7 . 

12. A protective order under 21 U.S.C. § 853(e) may not be 

sufficient to assure the availability of the property for 

forfeiture because there is reason to believe that the property 

is under the control of the targets of this investigation, who 

cannot reasonably be relied upon to abide by an order to 

maintain the property in substantially the same condition as it 

is at the present time in order to ensure that it will be 

available for forfeiture. Specifically, illicit funds are 

routinely moved among several related accounts and certain 

individuals who maintain control of the accounts are able to 

move funds among other bank accounts within their control. 

Thus, I request a seizure warrant issued pursuant to 21 U.S.C. § 

853(f) (as incorporated by 18 U.S.C. § 982(b) and 28 U.S.C. § 

2461 (c)). 

13. Title 18 U.S.C. § 1956 prohibits, among other things, 

financial transactions involving the proceeds of SUAs 

committed or attempted (1) with the intent to promote further 

predicate offenses; (2) with the intent to evade taxation; (3) 

knowing the transaction is designed to conceal the source, 

location, ownership or control of the proceeds; or (4) knowing 

the transaction is designed to avoid anti-laundering financial 

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reporting requirements. 18 U.S.C. § 1956(h) prohibits two or 

more parties agreeing to accomplish the unlawful purpose of 

money laundering. 

14. Title 18 U.S.C. § 1957 prohibits a party from 

knowingly engaging in a monetary transaction in excess of 

$10,000 with property that is criminally derived from some SUA. 

15. Title 18 U.S.C. § 1956(a) (2) (International Money 

Laundering for Promotion) makes it a crime to transport, 

transmit, or transfer, or attempt to transport, transmit, or 

transfer, monetary instruments or funds (including funds that 

are not criminal proceeds) from the United States to or through 

a place outside the United States, or to the United States from 

or through a place outside the United States, with the intent to 

promote some SUA, as that term is defined in 18 U.S.C. § 

1956 (c) (7). 

16. The "Travel Act," 18 U.S.C. § 1952(a), an SUA, 

prohibits, in part, the use of the mail or any facility in 

interstate or foreign commerce with the intent to otherwise 

promote, manage, establish, carry on, or facilitate the 

promotion, management, establishment, or carrying on of any 

unlawful activity, by any person who thereafter performs or 

attempts to perform an act to promote, manage, establish, carry 

on, or facilitate the promotion, management, establishment and 

carrying on of such unlawful activity. "Unlawful Activity," as 

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defined in 18 U.S.C. § 1952(b), includes prostitution offenses 

in violation of the laws of the state in which such acts are 

committed or in violation of the laws of the United States. 

Prostitution is illegal in the State of California. (Seer e.g., 

Cal. Penal Code§ 647(b) .) 

17. Sex trafficking of juveniles or any person by means of 

force, fraud or coercion, is a violation of 18 U.S.C. § 1591, an 

SUA. 

IV. DIGITAL CURRENCY/BITCOIN 

18. Digital currency (also known as crypto-currency) is 

generally defined as an electronic-sourced unit of value that 

can be used as a substitute for fiat currency (i.e., currency 

created and regulated by a sovereign government). It exists 

entirely on the Internet and is not stored in any physical form. 

It is not issued by any government, bank, or company, but is 

instead generated and controlled through computer software 

operating on a decentralized peer-to-peer network. Digital 

currency is not illegal in the United States and may be used for 

legitimate financial transactions. However, it is often used to 

conduct illegal transactions, such as the sale of controlled 

substance, or as in this investigation, to purchase ads to 

promote prostitution. 

19. Bitcoin is a type of digital currency accepted by 

Backpage. Bitcoin payments are recorded on a public ledger that 

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is maintained by peer-to-peer verification, and is thus not 

maintained by a single administrator or entity. Individuals can 

acquire Bitcoin either by "mining" them or purchasing Bitcoin 

from other individuals. An individual can "mine" Bitcoin by 

allowing his/her computing power to verify and record the 

Bitcoin payments into a public ledger. Individuals are rewarded 

for this by being given newly created Bitcoin. Bitcoin can be 

bought and sold in fractions. 

20. Backpage also accepts other digital currencies, 

including Litecoin, Bitcoin Cash, and Ether. Sometimes called 

"alt-coins," because they are alternatives to Bitcoin, these 

digital currencies were created after Bitcoin to address 

perceived weaknesses or problems with Bitcoin technology. Based 

on my review of Backpage transactions, the majority of 

Backpage's digital currency transactions are in Bitcoin. 

21. An individual can send and receive Bitcoin through 

peer-to-peer digital transactions or by using a third-party 

broker. Such transactions can be done on any type of computer, 

including laptop computers and smart phones. 

22. Digital currency is generally stored in digital 

"wallets," which essentially store the access codes that allows 

individuals to conduct digital currency transactions on the 

public ledger. To access digital currency on the public ledger, 

an individual must use a public address (or "public key") and a 

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private address (or "private key"). The public address can be 

analogized to a bank account number, while the private key is 

like a password used to access an online account. 

23. Even though the public addresses of those engaging in 

Bitcoin transactions are recorded on the public ledger, the true 

identities of the individuals or entities behind the public 

addresses are not. If, however, an individual or entity is 

linked to a public address, it would be possible to determine 

what transactions were conducted by that individual or entity. 

For these reasons, digital currency transactions are described 

as "pseudonymous," meaning they are partially anonymous. 

V. STATEMENT OF PROBABLE CAUSE 

C. Buying a Backpage Ad 

24. In February 2018, I visited Backpage.com and, posing 

as an advertising purchaser, engaged in the regular process of 

posting an ad in the Backpage "Dating" section, which is one of 

the places on Backpage.com where prostitution ads are commonly 

found. Through this process, I learned the following: 

a. A person looking to post an advertisement on 

Backpage (an "advertiser") must first create an account. Once 

an account is created, the advertiser clicks on a link called 

"Post an ad," which will then toggle certain categories 

regarding where the ad should be posted (e.g., "Los Angeles," 

"Riverside," etc.) and under what category the ad should appear 

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(e.g., "Dating," "Adult," etc.). The advertiser also has the 

option to post pictures and videos. In the adult sections, 

opting to post in more than one geographical area, or opting to 

post more frequently occurring ads will increase the 

advertisement price. Currently, Backpage.com charges $5 per ad 

posted in the adult sections. In some of the non-adult and nondating sections I checked, there was no charge at all to post an 

ad. 

b. Once an advertiser selects the desired options, 

he or she is required to enter a phone number, a link to a 

social media page (such as Facebook), and an email address. The 

Backpage website claims to verify the advertiser's phone number 

before he or she can continue on to actually purchasing an ad. 

c. In order to pay for Backpage ads, an advertiser 

must first buy "credits." Backpage offers several ways for an 

advertiser to acquire credits: 

i. A Backpage advertiser may mail gift cards, 

checks, and money orders to "Posting Solutions" at a P.O. Box in 

Dallas, Texas (as further described below, this P.O. Box is 

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associated with Posting Solutions and Seized Account 1) 6 

ii. Backpage directly accepts credit card 

payment through a third-party credit card payment processor. 

iii. Backpage also accepts several types of 

digital currency (specifically, Backpage accepts Bitcoin, 

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

selects this option, Backpage provides a digital currency wallet 

address where the advertiser can send the electronic transfer of 

the digital currency. 

iv. Backpage also accepts cash, but only through 

third party payment processors. Based on information gathered 

during this investigation, I believe that once the third-party 

payment processor receives cash, it converts the cash into 

digital currency and then electronically transfers that digital 

currency to a Backpage digital currency wallet. 

25. Digital Currency is processed through the subject 

accounts in the following way: 

6 I have reviewed the cash purchase of USPS money orders 

subsequently directed to this P.O. Box. Between September 2014 

and June 2016, several millions of dollars in money orders were 

purchased in what appears to have been structured transactions 

(i.e., transactions carried out in a manner intended to avoid 

certain reporting requirements that USPS maintains for money 

order purchases greater than $3000). Based on my review, 

hundreds of these money orders include email addresses with 

words consistent with prostitution, such as "sex" or "sexy." 

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y. When Backpage receives digital currency, it will 

aggregate the digital currency and then transfer it to a thirdparty exchanger like GoCoin. 7 

z. In exchange for the digital currency, the exchanger 

transfers U.S. dollars from its foreign bank accounts into 

Backpage operating accounts, such as Seized Account 1. The 

exchanger, if it so elects, may then sell its Bitcoin on various 

Bitcoin markets. 

2 6. I reviewed records obtained from GoCoin. From this 

review, I estimate that between 5 to 10 percent of the ads posted 

on Backpage.com are ads within the Central District of California 

(including Los Angeles and Orange Counties). For example, between 

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

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

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

approximately 500,000 ads, approximately 28,400 were posted only 

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

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

SanGabrielValley.Backpage.com. These specific ads generated 

7 GoCoin is a digital currency exchanger that converts Bitcoin, 

Litecoin and another digital currency into fiat currency, like 

the U.S. Dollar or the Euro. GoCoin is owned by Manx 

Broadcasting Corporation, based in the Isle of Man. GoCoin has 

offices in Singapore and Santa Monica, California and appears to 

hold bank accounts in several countries outside the United 

States. 

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approximately $184,479 in revenue. 

D. Backpage Promotion of Prostitution and Sex Trafficking 

27. I have reviewed several Backpage ads that were used to 

sell minors for sex and forcibly traffic adult women for sex. I 

have also reviewed the criminal records of certain of the pimps 

and sex traffickers, most of whom were convicted after having used 

Backpage to advertise their victims. From this review, I learned 

the following: 

a. Between 2014 and 2015, a pimp sold S.F., a minor 

girl, for sex. The pimp advertised S.F. on Backpage's "Escort" 

section in the Los Angeles area of California and in Arizona. The 

ad contained phrases such as "New In Town" and "Sexy Dark Asian 

Bombshell with a Nice & Tight {Booty}." The ad selling S.F. on 

Backpage included multiple pictures showing her legs, stomach, 

shoulders and buttocks. Later, the pimp was arrested and 

convicted on state sex trafficking charges, and sentenced to 196 

years imprisonment. 

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

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

first sold for sex through a Backpage ad using phrases such as 

"NEW IN TOWN," "sexy sweet," and "sweet like honey but super hot 

like fire." The Backpage ad selling A.C. included pictures of her 

showing her legs, stomach, shoulder, and buttocks, and posed her 

in sexually provocative positions. 

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c. Between November 2015 and December 2015, in a 

different incident, a pimp drove two women and four minor girls 

(T.S., S.L., K.O., and R.W.) from Columbus, Ohio to a hotel in St. 

Charles, Missouri. The next day, the pimp told the girls to post 

ads on Backpage.com. Some of the girls took calls and engaged in 

paid sex acts with Backpage customers who responded to the ads. 

The ads the girls posted included pictures of them sitting on the 

bed showing their buttocks. Another image I saw was of a naked 

girl's body pressed against a mirror. Other pictures appeared 

more mundane, such as images of girls posing clothed in front of a 

mirror. However, these ads used phrases like "I'm sweet as a 

treat maybe even sweeter" and "not a lot need to be said. my pie 

are 100% real." In 2017, this pimp was convicted on sex 

trafficking charges and a federal court sentenced him to 300 

months in prison. 

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

girl, was sold for sex through the use of Backpage ads. J. s.' s 

pimp drafted the ads that were placed on Backpage ad containing 

words and phrases such as, "W'E'L'L_W'O'R'T'H I'T***/\***150HR" and 

"IT WONT TAKE LONG AT ALL." The ads also included pictures of 

J.S. in provocative positions showing her breasts and buttocks. 

On March 29, 2011, the pimp who sold J.S. for sex was sentenced to 

over 26 years imprisonment on charges related to sex trafficking. 

e. Between in or around 2011 and 2016, a female 

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victim, D.O., who was between the ages of 14 and 19 during those 

years, was sold for sex through Backpage ads. D.O.'s female pimp 

instructed D.O. that Backpage was the safest place to advertise 

because Backpage did not require age verification. D.O.'s 

Backpage ads included words and phrases that were indicative of 

prostitution, such as "roses" (money) and "back door" (anal sex) 

Some of the customers who responded to D.O.'s Backpage ads forced 

D.O. to perform sexual acts at gunpoint, choked her to the point 

of having seizures, and gang-raped her. 8 

28. I have reviewed documents and reports from multiple 

state and government agencies and authorities regarding Backpage's 

promotion of sex trafficking and prostitution. From these 

8 Using these examples, I also reviewed financial transactions 

for some of these ads. Using email addresses and other 

identifiers associated with the Backpage ads, I reviewed GoCoin 

records for some of these transactions. From these records, I 

found bitcoin payments associated with the email addresses used 

to post the ads, which transactions were processed by GoCoin. 

For example, in the case involving victims S.F. and A.C. 

(described in paragraphs 27(a) and (b) of this affidavit) 

prosecuted in Arizona, the bitcoin payments for these ads were 

made in November and October 2015. In the case involving T.S., 

S.L., K.O., and R.W. (described in paragraph 27(c) of this 

affidavit) prosecuted in Missouri, the bitcoin payments were 

made in October and November 2015. As described in paragraph 45 

of the incorporated affidavit, between December 2015 and June 

2016, over 130 wires from Slovakia from GoCoin, totaling over 

$16.8 million was sent to a Website Technologies account at 

Branch Bank & Trust Company account number 1440001712008. 

Between December 2015 and October 2016, 32 wires totaling $48 

million were sent from the BBT Account to a Cereus Properties 

Account 9361116211 at Arizona Bank and Trust, which made its way 

into 11 accounts named in prior seizure warrants. 

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reports, and from my review of internal Backpage correspondence 

following Backpage management receiving these reports, I am aware 

that all levels of Backpage management are aware of Backpage's 

role in promoting criminal activity. For example: 

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

general wrote a letter to Backpage observing that "ads for 

prostitution-including ads trafficking children-are rampant on the 

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

adequately screen these ads, it should stop accepting them 

altogether." The state AGs acknowledged that this step would 

cause Backpage to, "lose the considerable revenue generated by the 

adult services ads," but stated that "no amount of money can 

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

women and children who will continue to be victimized in the 

marketplace provided by backpage." 

b. Following this letter, on September 25, 2010, 

Ferrer wrote an email explaining that Backpage was unwilling to 

delete ads that included terms indicative of prostitution because 

doing so would "piss[] off a lot of users who will migrate 

elsewhere" and force Backpage to refund those customers' fees. 

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

Permanent Investigations ("Subcommittee") conducted a lengthy 

investigation into sex trafficking and Backpage. I have reviewed 

the Subcommittee's 50-page report entitled "Backpage.com's Knowing 

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Facilitation of Online Sex Trafficking." This report concluded, 

among other things, that virtually all of Backpage's "adult" ads 

are actually solicitations for illegal prostitution services and 

that "Backpage has maintained a practice of altering ads before 

publication by deleting words, phrases, and images indicative of 

criminality, including child sex trafficking. Those 

practices served to sanitize the content of innumerable 

advertisements for illegal transactions-even as Backpage 

represented to the public and the courts that it merely hosted 

content others had created." In response to the Subcommittee's 

report, Backpage purported to shut down the "adult" section of its 

website. However, based on my review of several thousands of 

Backpage ads, I believe that the prostitution ads simply migrated 

to other sections of the website, where they remain to this day. 

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

the mayor of Seattle. This letter warned, "Seattle Police have 

identified an alarming number of juvenile prostitutes advertised 

on Backpage.com since January 2010," and explained that Backpage 

was dissimilar from other companies whose products and services 

are "occasionally or incidentally" utilized by criminals because 

"[y]our company is in the business of selling sex ads" and "your 

services are a direct vehicle for prostitution." The letter also 

recommended that Backpage require in-person age verification for 

all of the "escorts" depicted in its ads. Based on knowledge 

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gained through this investigation, I do not believe that Backpage 

has ever instituted an in-person age verification. 

29. I have reviewed internal documents, emails, and 

correspondence among Backpage employees and management. From 

those emails I have learned that Backpage has instituted policies 

and procedures designed to maintain its promotion of sex 

trafficking and prostitution, but which "sanitize" some of the 

language Backpage customers use to advertise in order to make the 

advertising of sex trafficking less overt. From my review of 

Backpage documents, I know that Backpage refers to this practice 

as "moderation." For example: 

a. In April 2008, Ferrer wrote an email explaining 

that, although he was "under pressure to clean up phoenix's adult 

content," he was unwilling to delete prostitution ads because 

doing so "would put us in a very uncompetitive position with 

craig[slist]" 9 and result in "lost pageviews and revenue." Thus, 

Ferrer instructed Backpage's technical staff to edit the wording 

of such ads by removing particular terms that were indicative of 

prostitution, and then allow the remainder of the ad to be 

featured on Backpage's website. 

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

9 Craigslist is a competing internet based advertising company 

that features classified ads. 

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email threatening to fire any Backpage employee who acknowledged, 

in writing, that a customer was advertising prostitution: 

"Leaving notes on our site that imply that we're aware of 

prostitution, or in any position to define it, is enough to lose 

your job over. This isn't open for discussion. If you don't 

agree with what I'm saying completely, you need to find another 

job." 

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

again sent an email to a large group of Backpage employees that 

contained two attachments providing guidance on how to "moderate" 

ads. The first was a PowerPoint presentation that displayed a 

series of 38 nude and partially-nude photographs, some of which 

depicted graphic sex acts. Next to each picture was an 

instruction as to whether it should be approved or disapproved by 

a Backpage moderator. These instructions included "Approve. Nude 

rear shots are okay as long the model is not exposing her anus or 

genitalia." and "Approve. Rear shot okay. Transparent wet 

panties okay." The second was an Excel spreadsheet identifying 50 

terms (all of which were indicative of prostitution) that should 

be "stripped" from ads before publication. The Backpage manager 

concluded the email by stating, "[I]t's the language in ads that's 

really killing us with the Attorneys General. Images are almost 

an afterthought to them." 

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

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a separate internal email explaining, "I'd like to still avoid 

Deleting ads when possible," that "we're still allowing phrases 

with nuance," and that "[i]n the case of lesser violations, 

editing should be sufficient." 

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

acknowledging that the "[i]llegal content removed" through 

Backpage's moderation processes was "usually money for sex act." 

This email also explained that, after the "sex act pies are 

removed," the "ad text may stay." 

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

sent an internal email stating that Backpage was "editing 70 to 

80%" of the ads it received from customers. 

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

law enforcement official about a particular ad that included the 

term "amber alert." In response, Ferrer acknowledged this might 

be "some kind of bizarre new code word for an under aged person." 

Ferrer then forwarded this exchange to a Backpage manager and 

instructed that the term "amber alert" be added to Backpage's 

"strip out" list. I believe that this email indicates that 

Backpage did not require all future ads involving this particular 

coded term for the prostitution of a child to be blocked from 

Backpage, but merely required that such ads be edited before 

publication. 

h. On August 31, 2011, Backpage managers exchanged 

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emails in which they discussed a list of 100 "solid sex for money 

terms." Later emails indicate that this list of terms would 

change but, in general, the list prohibited use of certain terms 

that Backpage management and employees too closely identified with 

the obvious promotion of sex trafficking and prostitution. 

i. Based on knowledge gained during this investigation 

and my training and experience, I believe that this manager 

acknowledged that a large proportion of the ads originally 

submitted by Backpage's customers contained text and pictures that 

were indicative of sex trafficking. Nevertheless, Backpage would 

still publish those ads after editing them to appear less obvious 

in promoting illegal activity. Using the words the Backpage 

manager used in the email described in paragraph 28(d) above, I 

believe that Backpage sex trafficking ads have adapted to 

Backpage's moderation policy by using "phrases with nuance" when 

promoting sex trafficking. Also, based on knowledge gained during 

this investigation, and my training and experience, I believe 

that, following the implementation of "moderation," Backpage's 

list of prohibited terms needed to change and evolve to adjust to 

the reality of Backpage advertisers' use of new code words to 

promote prostitution. That is, once a coded word or phrase not 

previously associated with sex-for-money would become too familiar 

and associated with certain sex trafficking activities in the 

Backpage community of advertisers, Backpage's "moderation" policy 

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would need to adapt by adding such words or phrases to the 

"blocked" list or risk being too obvious in its promotion. 

30. Based on my review of several thousand Backpage ads and 

internal Backpage documents and correspondence, I believe that 

Backpage's policy of "moderation" only caused ads explicitly 

promoting sex trafficking to become more coded and implicit in the 

ads' purpose. I have reviewed several thousand Backpage ads 

posted in the various "adult" categories of Backpage (including 

"massage," "dating," "escort" and others). From this review, I 

learned the following: 

a. Well over half of the Backpage classified ads in 

these categories use terms and phrases that, in my training and 

experience, I believe to be consistent with sex trafficking and 

prostitution. These terms and phrases include, "roses" (money, 

e.g., "150 roses/half hour"), "in-call" (where the customer goes 

to the prostitute's location), "outcall" (where the prostitute 

goes to the customer's location), "GFE" (girlfriend experience), 

and "PSE" (porn star experience). 

b. Other Backpage ads use language that can be mostly 

free of coded language, but that include sexually provocative 

pictures. In my training and experience, the sexually suggestive 

images included in these ads are typical of ads for prostitution. 

For example, one such ad posted in Backpage's Los Angeles dating 

section depicted images of a woman on a bed with her buttocks 

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

woman's cleavage; others included pictures of women posing in 

sexual positions wearing lingerie and pictures of a woman bending 

over revealing her naked buttocks. 

c. Based on knowledge gained through this 

investigation, and my training and experience, I believe that 

Backpage's policy of moderation has had its intended effect. 

Moderation has caused and allowed otherwise neutral or innocuous 

terms to be understood within the Backpage community as coded 

language for sex trafficking and prostitution. Because of this 

evolving use of coded terms, a reader of such ads who is familiar 

with the particular vocabulary used in Backpage "adult" ads may 

readily identify coded terms and images indicating an ad for 

prostitution, while an uninitiated reader may not understand these 

terms at all, or at least not as being associated with sex-formoney. 

31. Notwithstanding many Backpage advertisements' use of 

seemingly innocuous language in promoting prostitution, based on 

my conversations with law enforcement officers around the country 

and from my review of law enforcement officers' statements and 

reports regarding Backpage, I believe that the majority of 

Backpage ads that appear in the traditionally "adult" categories 

(such as "escort," "massage," or "body rubs") are actually 

advertisements promoting sex trafficking or prostitution. For 

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example, in August 2015, the Detective-Sergeant in charge of the 

Seattle Police Department's Vice/High Risk Victims Unit and Human 

Trafficking Task Force made a sworn statement that provided, in 

pertinent part, 

Since 2014, the Seattle Police Department has made arrests 

that include hundreds of related charges, such as charges 

for patronizing a prostitute/sexual exploitation, hundreds 

of charges for prostitution, dozens of charges [of] 

Promoting Prostitution, up to 100 charges for Commercial 

Sexual Abuse against a Minor and have investigated dozens 

of rape reports involving victims who are prostitutes and 

one murder of a prostitute. As a result of hundreds of 

investigations, the Seattle Police Department Vice/High 

Risk Victims Unit has found that Backpage.com has become 

the primary web site in Seattle/Washington State for those 

looking to solicit a prostitute, post prostitution ads or 

traffic prostitutes and minors. 

Vice/High Risk Victims Unit Detectives also make use of 

this site to respond to ads posted under the 'escorts' and 

'body rubs' categories posing as male customers and 

successfully arrest females and males who charge 

undercover operatives money in exchange for sex. To date, 

no Detective within the Seattle Police Department's 

Vice/High Risk Victims Unit has ever found a legitimate 

'escort', (person who charges simply for companionship 

with no offer of sex) or 'masseuse', (person offering 

legitimate and licensed massage therapy rather than sex) 

while responding to ads placed in these categories on 

Backpage.com. 

As stated previously, every time the Seattle Police 

Department Vice/High Risk Victims Unit has responded to an 

ad in the adult section of Backpage.com, we have found 

that the ad was a posting for illegal activity. The 

Seattle Police Department Vice/High Risk Victims Unit has 

not once found that the individual posting or responding 

to one of our decoy ads in the adult section of 

Backpage.com was in fact seeking any type of innocent, 

legal activity. In my professional experience, the adult 

section of Backpage.com not only contains ads for illegal 

activity, including prostitution, solicitation and 

trafficking, but it is a primary source for such ads and 

- 36 -

DOJ-BP-0004 719121 

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is well known for that purpose in the sex trafficking 

industry in the city of Seattle and State of Washington. 

Additionally, in August 2015, the Sergeant Detective who is 

Commander of the Human Trafficking Unit ("HTU") for the Boston, 

Massachusetts Police Department made a sworn statement that 

provided, in pertinent part, 

Since 2009, the [HTU] has made numerous arrests that 

include enticement of a minor into prostitution, sex 

trafficking of a minor, sex trafficking of an adult, 

forcible rape . and sex for a fee for soliciting a 

prostitute. 

As a result of investigations, the HTU has found that 

Backpage.com is the go-to Web site in Boston for those 

looking to solicit a prostitute, post prostitution ads, 

and recruit and traffic young women and minors. The 

detectives have been able to identify numerous would-be 

exploiters by setting up decoy ads and responding to ads 

on the site. The have arrested pimps, traffickers and 

buyers who facilitate prostitution and fuel the harmful 

and violent sex trade. Backpage.com is the number one 

site that detectives go to in order to look for underage 

girls who are on the run and are being commercially 

sexually exploited by pimps. 

Since 2010, the HTU has arrested over 100 buyers of sex of 

both adults and minors through Backpage.com ads 

exclusively in hotel stings. 

Since 2013, 12 individuals have been charged in federal 

court for sex trafficking of both minors and adults. In 

all these aforementioned cases, Backpage.com played a 

pivotal role in facilitating these crimes. 

Detectives of the HTU often get tips about illegal 

activity concerning ads posted on the escort, adult and 

massage sections of Backpage.com. In almost every case 

detectives have found that in fact there was illegal 

activity which resulted in fines, arrests, or further 

investigations of sex trafficking. 

Therefore, in my professional experience as a law 

- 37 -

DOJ-BP-0004 719122 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 39 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 39 of 

136 Page ID #:463 

enforcement officer for over thirty years, the adult 

section of Backpage.com not only contains ads for illegal 

activity, including prostitution, solicitation and 

trafficking, but it is also the primary source for such 

ads and well known for that purpose in the sex trafficking 

industry in Boston, Massachusetts. Backpage.com's adult 

section provides a vehicle and anonymity for its users who 

exploit and traffic young women and girls. . It is my 

humble opinion that the adult section of Backpage.com 

serves no legitimate service and nearly all the cases we 

find associated with it involve pimp controlled 

prostitution. 

32. Almost all "adult"-type Backpage ads list phone numbers 

or emails for a potential customer to use to make contact with the 

advertiser. I have compared a sample of phone numbers and emails 

found within Backpage ads with phone numbers and emails that 

frequently are included in the memo section of some of the checks 

that Backpage advertisers use to pay Backpage for those ads. From 

my review, I have found that very often the same number and/or 

email appears in multiple Backpage ads as the contact information 

to make an appointment. For example: 

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

in Duarte, California, made payable to "Posting Solutions PO BOX 

802426, Dallas, TX," and thereafter deposited into a Seized 

Account, included writing on the money order listing a phone 

number and the words "Dulce Latina." From a search of Backpage 

ads, I found almost 800 advertisements listing the same phone 

number found on the $25 USPS Money Order. 

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

- 38 -

DOJ-BP-0004 719123 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 40 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 40 of 

136 Page ID #:464 

California, and later deposited into a Seized Account, included 

writing listing a phone number and the words "love my lips." From 

a search of Backpage ads, I found almost 1300 advertisements 

listing the same phone number found on the $20 USPS Money Order. 

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

Arizona, and made payable to "Posting Solutions," included an 

email and the words, "red hot stuff". From an internet search of 

the email address listed on this $150 money order, I found 

advertisements on several female escort websites that directed 

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

then searched Backpage.com records for this phone number and found 

approximately 760 ads that included this same phone number. My 

review of these Backpage ads revealed images indicative of 

prostitution. For example, one such ad posted on Backpage's 

"massage" section included sexual images such as a woman lying on 

a bed wearing lingerie and a woman laying naked on her stomach. 

One of the ads describes, "Pampering provider I Body Rub Massage 

Body Shampoo I Body Scrub I 4 hands I Walk ins or appointment." 

From my training and experience, I know that legal massage 

advertisements do not typically depict sexual images. This 

advertisement depicted sexual images and included terms like "4 

hands," which I know to be coded language describing a massage 

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

indicative of prostitution. 

- 39 -

DOJ-BP-0004 719124 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 41 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 41 of 

136 Page ID #:465 

33. Despite the fact that several thousand Backpage ads 

shared the exact same phone number or email address to contact the 

advertiser, these same ads included sexually suggestive images of 

hundreds of different women. Based on my training and experience, 

multiple different women do not share the same email address or 

phone number when posting ads for dating. Rather, in my training 

and experience, such ads are consistent with ads posted by pimps 

or prostitution agencies that are using the same phone number or 

email to advertise several different women (or girls) to 

prospective prostitution clients. 

34. On March 28, 2018, in the District of Arizona, a grand 

jury returned a 93 count indictment charging certain Backpage 

Operators with criminal violations of 18 U.S.C. § 371 

(Conspiracy), § 1952 (Travel Act-Facilitation of Prostitution), § 

1956 (Money Laundering), § 1957 (Financial Transactions Involving 

Illicit Proceeds), and including Forfeiture Allegations pursuant 

to 18 U.S.C. §§ 981 and 982 (seeking criminal forfeiture of, among 

other assets, the Seized Accounts and the Seized Domains). 

35. On July 25, 2018, also in the District of Arizona, a 

grand jury returned a 100 count "First Superseding Indictment" 

charging certain Backpage Operators with additional criminal 

violations of 18 U.S.C. § 371 (Conspiracy), § 1952 (Travel ActFacilitation of Prostitution), § 1956 (Money Laundering), § 1957 

(Financial Transactions Involving Illicit Proceeds), and including 

- 40 -

DOJ-BP-0004 719125 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 42 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 42 of 

136 Page ID #:466 

Forfeiture Allegations pursuant to 18 U.S.C. §§ 981 and 982 

(seeking criminal forfeiture of, among other assets, the Seized 

Accounts and the Seized Domains). Additionally, the grand jury 

made specific findings of probable cause for forfeitability of all 

the Seized and Restrained Accounts 10 listed in previously 

submitted warrant affidavits. A copy of the "First Superseding 

Indictment" is attached hereto (as Attachment C) and incorporated 

herein as though fully set forth. 

E. THE SEIZED ACCOUNTS AND SUBJECT ACCOUNTS 

1. SUBJECT ACCOUNT 28 

36. 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 owns and operates 

the Backpage website, as well as corporate assets and other 

10 Because of the extensive movement of money by the Backpage 

operators, attached and incorporated as Attachment Bis a copy 

of the most recently previously obtained warrant application 

(referred to as Seized Accounts 1 through 17, 22 and 25 through 

27; or Restrained Accounts 18 through 21B, 23 and 24), herein 

collectively referred to as the "Seized Accounts." 

- 41 -

DOJ-BP-0004 719126 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 43 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 43 of 

136 Page ID #:467 

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) . 

37. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 28 is an IOLTA account 

held in the name of the law firm Rusing Lopez and Lizardi PLLC. 

Based on my conversations with Ferrer, I believe that Backpage 

or Backpage-controlled entities are the beneficiaries of this 

account. This account has received $5,279,173.07 in criminal 

proceeds for prepayment of future legal services. These funds 

are owned by Backpage, but held by RLL and are subject to 

forfeiture. 

38. Based upon my review of the financial records relating 

to SUBJECT ACCOUNT 28, Seized Account 1, and the Foreign 

Account, I learned that in total, SUBJECT ACCOUNT 28 received 

$5,279,173.07 in Backpage funds: 

a. On May 5, 2017, SUBJECT ACCOUNT 28 received a 

$499,970 wire from the Foreign Account. 

b. On June 2, 2017, SUBJECT ACCOUNT 28 received a $1 

million wire from the Foreign Account. 

c. On September 18, 2017, SUBJECT ACCOUNT 28 

received a $1 million wire from the Foreign Account. 

- 42 -

DOJ-BP-0004 719127 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 44 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 44 of 

136 Page ID #:468 

d. On October 3, 2017, SUBJECT ACCOUNT 28 received a 

$779,203.07 wire from the Foreign Account. 

e. On November 6, 2017, SUBJECT ACCOUNT 28 received 

a $500,000 wire from Seized Account 1. 

f. On January 9, 2018, SUBJECT ACCOUNT 28 received a 

$750,000 wire from Seized Account 1. 

g. On January 19, 2018, SUBJECT ACCOUNT 28 received 

a $750,000 wire from Seized Account 1. 

39. An analysis of the banking statements and the wire 

transfers for SUBJECT ACCOUNT 28 show that the funds have 

remained in this IOLTA since they were transferred. 

Ad Tech BV 

(FOREIGN ACCOUNT)"--..._ 

5/5/2017 - $499,970 

6/2/2017 - $1,000,000 

9/18/2017 - $1,000,000 

10/3/2017 - $779,203.07 

8/1/2017 - 9/1/2017 11/6/2017 - $500,000 ~ Cli ---~·$2.7 MILLION::.:.:__ ___ IP..~ ----1/9/2018 - $750,000-----+ ~ 

GOCOIN 

(SINGAPORE) 

POSTING SOLUTIONS 

'7188 

PROSPERITY BANK 

(SEIZED ACCOUNT 1) 

1/19/2018 - $750,000 

DIAGRAM FOR SUBJECT ACCOUNT 28 

2. SUBJECT ACCOUNT 29 

RUSING LOPEZ & LIZARDI PLLC 

IOLTA 

'1363 

BANK OF THE WEST 

(SUBJECT ACCOUNT 28) 

40. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 29 is an IOLTA account 

held in the name of the law firm Copeland, Franco, Screws & Gill. 

- 43 -

DOJ-BP-0004 719128 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 45 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 45 of 

136 Page ID #:469 

41. Based on my conversations with Ferrer and review of 

bank records, I believe that Backpage or Backpage-controlled 

entities are the beneficiaries of this account. This account 

has received $100,000 in criminal proceeds for prepayment of 

future legal services. These funds are owned by Backpage, but 

held by Copeland, Franco, Screws & Gill, and are subject to 

forfeiture. 

42. Based upon my review of the financial records from 

Backpage, and Veritex Account ending in -1462, held in the name 

of Posting Solutions ("Veritex Account -1462"), I learned the 

following: 

a. On March 28, 2017, Backpage wired $25,000 from 

their Veritex Account -1462 to SUBJECT ACCOUNT 29. 

b. On May 9, 2017, Backpage wired $75,000 from their 

Veritex Account -1462 to SUBJECT ACCOUNT 29. 

_____ 3/28/2017 - $25,000 ____ ~ , 

5/9/2017 - $75,000 

POSTING SOLUTIONS 

30021462 

VERITEX BANK 

COPELAND FRANCO SCREWS GILL PA 

2000608102052 

WELlS FARGO BANK NA 

SUBJECT ACCOUNT 29 

DIAGRAM FROM SUBJECT ACCOUNT 29 

3. SUBJECT ACCOUNT 30 

43. From speaking with Ferrer and reviewing financial 

- 44 -

DOJ-BP-0004 719129 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 46 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 46 of 

136 Page ID #:470 

records, I learned that SUBJECT ACCOUNT 30 is an IOLTA account 

held in the name of the law firm, David B. Smith, PLLC. Based on 

my conversations with Ferrer, I believe that Backpage or Backpagecontrolled entities are the beneficiaries of this account. This 

account has received $10,000 in criminal proceeds as prepayment of 

future legal services. These funds are owned by Backpage but held 

by David B. Smith, PLLC, and are subject to forfeiture. 

44. Based upon my review of the financial records from 

Backpage and Veritex Account -1462, held in the name of Posting 

Solutions, I learned the following: 

a. On March 28, 2017, Backpage wired $10,000 from 

their Veritex Account -1462 to SUBJECT ACCOUNT 30. 

----3/28/2017 - $10,000 

POSTING SOLUTIONS 

30021462 

VERITEX BANK 

DAVID B. SMITH, PLLC 

IOL TA ACCOUNT 

1000144637906 

SUNTRUST BANK 

SUBJECT ACCOUNT 30 

DIAGRAM FOR SUBJECT ACCOUNT 30 

4. SUBJECT ACCOUNT 31 

45. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 31 is an IOLTA account 

- 45 -

DOJ-BP-0004 719130 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 47 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 47 of 

136 Page ID #:471 

held in the name of the law firm Keker, Van Nest & Peters. Based 

on my conversations with Ferrer, I believe that Backpage or 

Backpage-controlled entities are the beneficiaries of this 

account. This account has received $500,000 in criminal proceeds 

as prepayment of future legal services. These funds are owned by 

Backpage, but held by Keker, Van Nest & Peters, and are subject to 

forfeiture. 

46. Based upon my review of the financial records from 

Backpage, and Seized Account 1, I learned the following: 

a. On September 14, 2017, Backpage wired $500,000 

from Seized Account 1 to SUBJECT ACCOUNT 31. 

~-

POSTING SOLUTIONS 

'7188 

PROSPERITY BANK 

Seized Account 1 

KEKER VAN NESS & PETERS 

'7287 

DIAGRAM FOR SUBJECT ACCOUNT 31 

5. SUBJECT ACCOUNT 32 

CITIBANK 

SUBJECT ACCOUNT 31 

47. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 32 is an IOLTA account 

held in the name of the law firm McDermott Will & Emery. Based on 

my conversations with Ferrer, I believe that Backpage or Backpagecontrolled entities are the beneficiaries of this account. This 

account has received $100,000 of criminal proceeds for prepayment 

- 46 -

DOJ-BP-0004 719131 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 48 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 48 of 

136 Page ID #:472 

of future legal services. These funds are owned by Backpage, but 

held by McDermott Will & Emery, and are subject to forfeiture. 

48. Based upon my review of the financial records from 

Backpage and Veritex Account -1462, held in the name of Posting 

Solutions, I learned the following: 

a. On May 9, 2017, Backpage wired $100,000 from 

their Veritex Account -1462 to SUBJECT ACCOUNT 32. 

--------<:;/9/2017 - $100,000-------+-i 

POSTING SOLUTIONS 

30021462 

VERITEX BANK 

MCDERMOTT 1⁄2'ILL AND EMERY LLP 

30525705 

CITIBANK NA 

DIAGRAM FOR SUBJECT ACCOUNT 32 

6. SUBJECT ACCOUNT 33 

49. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 33 is an IOLTA account 

held in the name of the law firm Prince Lobel Tye, LLP. Based on 

my conversations with Ferrer, I believe that Backpage or Backpagecontrolled entities are the beneficiaries of this account. This 

account has received $100,000 of criminal proceeds as prepayment 

of future legal services. These funds are owned by Backpage, but 

held by Prince Lobel Tye, LLP, and are subject to forfeiture. 

50. Based upon my review of the financial records from 

Backpage and Veritex Account -1462, held in the name of Posting 

Solutions, I learned the following: 

- 47 -

DOJ-BP-0004 719132 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 49 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 49 of 

136 Page ID #:473 

a. On June 22, 2017, Backpage wired $100,000 from 

their Veritex Account -1462 to SUBJECT ACCOUNT 33. 

~ -

POSTING SOLUTIONS 

30021462 

VERITEX BANK 

6/22/2017 - $100,000---->-

PRINCE LOBEL TYE LLP 

1255464039 

CITIBANK NA 

SUBJECT ACCOUNT 33 

DIAGRAM FOR SUBJECT ACCOUNT 33 

7. SUBJECT ACCOUNT 34 

51. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 34 is an IOLTA account 

held in the name of the law firm Perkins Coie, LLP. Based on my 

conversations with Ferrer, I believe that Backpage or Backpagecontrolled entities are the beneficiaries of this account. This 

account has received $2,167,704.86 in criminal proceeds as 

prepayment of future legal services. These funds are owned by 

Backpage, but held by Perkins Coie, LLP, and are subject to 

forfeiture. 

52. Based upon my review of the financial records from 

Backpage, Seized Account 1, and the Foreign Account, I learned 

that SUBJECT ACCOUNT 34 has received $3,250,000 from Backpage. 

- 48 -

DOJ-BP-0004 719133 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 50 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 50 of 

136 Page ID #:474 

Specifically, SUBJECT ACCOUNT 34 received the following 

transactions: 

a. On May 9, 2017, Backpage wired $500,000 from one 

of their foreign-held accounts, held in the name of Ad Tech BV, 

to SUBJECT ACCOUNT 34. 

b. On June 1, 2017, Backpage wired $500,000 from one 

of their foreign-held accounts, held in the name of Ad Tech BV, 

to SUBJECT ACCOUNT 34. 

c. On July 7, 2017, Backpage wired $1,500,000 from 

one of their foreign-held accounts, held in the name of Ad Tech 

BV, to SUBJECT ACCOUNT 34. 

d. On August 23, 2017, Backpage wired $750,000 

through one of their foreign-held accounts to SUBJECT ACCOUNT 

34. 

53. Based on Backpage internal accounting that I have 

reviewed, $1,082,295.14 of these funds have been spent. 

$2,167,704.86 in proceeds remain in this account and is subject 

to forfeiture. 

- 49 -

DOJ-BP-0004 719134 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 51 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 51 of 

136 Page ID #:4 75 

POSTING SOLUTIONS 

216887188 

PROSPERITY BANK 

8/23/2017 - $750,000 

i 

5/9/2017 - $500,000---------------KINS COIE LLP 

6/1/2017 - $500,000 153555921235 

-------July 7, 2017 - $1,500,000 US BANK 

------ SUBJECT ACCOUNT 34 

AD TECH B V 

Foreign Account 

DIAGRAM FOR SUBJECT ACCOUNT 34 

8. SUBJECT ACCOUNT 35 

54. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 35 is an IOLTA account 

held in the name of the law firm Thompson Coburn, LLP. Based on 

my conversations with Ferrer, I believe that Backpage or Backpagecontrolled entities are the beneficiaries of this account. This 

account has received $100,000 in criminal proceeds as prepayment 

for future legal services. These funds are owned by Backpage, but 

held by Thompson Coburn, LLP, and are subject to forfeiture. 

55. Based upon my review of the financial records from 

Backpage and Seized Account 1, I learned that SUBJECT ACCOUNT 35 

has been funded via the following transactions: 

a. On December 14, 2017, Backpage wired $100,000 

from Seized Account 1 to SUBJECT ACCOUNT 35. 

- 50 -

DOJ-BP-0004 719135 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 52 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 52 of 

136 Page ID #:4 76 

--12/14/2017 - $100,000----'>•• ~ -

POSTING SOLUTIONS 

216887188 

PROSPERITY BANK 

THOMPSON COBURN LLP 

100-06-06952 

US BANK 

SUBJECT ACCOUNT 35 

DIAGRAM FOR SUBJECT ACCOUNT 35 

9. SUBJECT ACCOUNT 36A 

56. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 36A is an IOLTA account 

held in the name of the law firm Piccarreta Davis Keenan Fidel, PC 

at JP Morgan Chase Bank. Based on my conversations with Ferrer, 

I believe that Backpage or Backpage-controlled entities are the 

beneficiaries of this account. This account has received $10,000 

in criminal proceeds as prepayment of future legal services. These 

funds are owned by Backpage, but held by Piccarreta Davis Keenan 

Fidel, PC, and are subject to forfeiture. 

57. Based upon my review of the financial records from 

Backpage and Veritex Account -1462, I learned that SUBJECT 

ACCOUNT 36A has received the following funds from Backpage: 

- 51 -

DOJ-BP-0004 719136 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 53 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 53 of 

136 Page ID #:477 

a. On March 8, 2017, Backpage wired $10,000 from 

their Veritex Account -1462 to SUBJECT ACCOUNT 36A. 

POSTING SOLlffIONS 

30021462 

VERITEXMNK 

PiCCARRETA DAVIS KEENAN FIDEL PC 

211909285 

JP MORGAN CHASE BANK NA 

SUBJECT .ACCOUNT 36A 

DIAGRAM FOR SUBJECT ACCOUNT 36A 

10. SUBJECT ACCOUNT 3 6B 

58. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 3 6A is another IOLTA 

account held in the name of the law firm Piccarreta Davis Keenan 

Fidel, PC at Grand Point Bank. Based on my conversations with 

Ferrer, I believe that Backpage or Backpage-controlled entities 

are the beneficiaries of this account. This account has received 

$740,000 in criminal proceeds as prepayment of future legal 

services. These funds are owned by Backpage, but held by 

Piccarreta Davis Keenan Fidel, PC, and are subject to forfeiture. 

59. Based upon my review of the financial records from 

Backpage and Seized Account 1, I learned that SUBJECT ACCOUNT 

36B has received the following funds from Backpage: 

a. On April 3, 2017, Backpage wired $250,000 from 

Seized Account 1 to SUBJECT ACCOUNT 36B. 

- 52 -

DOJ-BP-0004 719137 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 54 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 54 of 

136 Page ID #:478 

b. On May 2, 2017, Backpage wired $490,000 from 

Seized Account 1 to SUBJECT ACCOUNT 36B. 

POSTING SOLUTIONS 

216887188 

PROSPERITY BANK 

PICCARRETA DAVIS KEENAN FIDEL PC 

250-398-5 

GRANDPOINT BANK 

SUBJECT ACCOUNT 368 

DIAGRAM FOR SUBJECT ACCOUNT 36B 

11. SUBJECT ACCOUNT 37 

60. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 3 7 is an IOLTA account 

held in the name of the law firm Lawrence G. Walters, P.A., at JP 

Morgan Chase Bank. Based on my conversations with Ferrer, and 

employees at JP Morgan Chase Bank, I believe that Backpage or 

Backpage-controlled entities are the beneficiaries of this 

account. This account has received $100,000 in criminal proceeds 

as prepayment of future legal services. These funds are owned by 

Backpage, but held by Lawrence G. Walters, P.A., and are subject 

to forfeiture. 

61. Based upon my review of the financial records from 

Backpage and Veritex Account -1462, I learned that SUBJECT 

ACCOUNT 37 has received the following funds from Backpage: 

- 53 -

DOJ-BP-0004 719138 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 55 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 55 of 

136 Page ID #:479 

a. On March 7, 2017, Backpage wired $10,000 from 

their Veritex Account -1462 to SUBJECT ACCOUNT 37. 

b. On May 9, 2017, Backpage wired $90,000 from their 

Veritex Account -1462 to SUBJECT ACCOUNT 37. 

_____ 3/7/2017-$10,000 

5/9/2017 - $90,000-----+I 

POSTING SOLUTIONS 

30021462 

VERITEX BANK 

LAWRENCE G WALTERS PA IOLTA TRUST 

851844381 

JP MORGAN CHASE BANK NA 

SUBJECT ACCOUNT 37 

DIAGRAM FOR SUBJECT ACCOUNT 37 

12. SUBJECT ACCOUNT 38 

62. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 3 8 is an IOLTA account 

held in the name of the law firm Akin Gump Strauss Hauer & Feld, 

LLP, at JP Morgan Chase Bank. Based on my conversations with 

Ferrer, and employees at JP Morgan Chase Bank, I believe that 

Backpage or Backpage-controlled entities are the beneficiaries of 

this account. This account has received $250,000 in criminal 

proceeds as prepayment of future legal services. These funds are 

owned by Backpage, but held by Akin Gump Strauss Hauer & Feld, 

LLP, and are subject to forfeiture. 

63. Based upon my review of the financial records from 

Backpage, Veritex Account -1462, and Seized Account 1, I learned 

- 54 -

DOJ-BP-0004 719139 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 56 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 56 of 

136 Page ID #:480 

that SUBJECT ACCOUNT 38 has received the following funds from 

Backpage: 

a. On March 29, 2017, Backpage wired $150,000 from 

Seized Account 1 to SUBJECT ACCOUNT 38. 

b. On April 25, 2017, Backpage wired $50,000 from 

their Veritex Account -1462 to SUBJECT ACCOUNT 38. 

c. On May 9, 2017, Backpage wired $50,000 from their 

Veritex Account -1462 to SUBJECT ACCOUNT 38. 

POSTING SOLUTIONS -----

30021462 -----· 

VERITEX BANK 3/29/2017 - $150,[:mD 

~ 

4/25/2017 - $5U,IJOD____-?" 

. ·. ___ 5/9/2011 - $5o,mm ----- Akin Gump Strauss ~ -•••'.II., Hauer & Field, LLP 

100079698 POSTING SOLUTIONS 

216887188 

PROSPERITY BANK 

JP Morgan Chase Bank 

SUBJECT ACCOUNT 38 

DIAGRAM FOR SUBJECT ACCOUNT 38 

13. SUBJECT ACCOUNT 39 

64. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 3 9 is an IOLTA account 

held in the name of the law firm Scheef & Stone, LLP, at Plains 

Capital Bank. Based on my conversations with Ferrer, and Plains 

- 55 -

DOJ-BP-0004 719140 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 57 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 57 of 

136 Page ID #:481 

Capital Bank employees, I believe that Backpage or Backpagecontrolled entities are the beneficiaries of this account. This 

account has received $25,000 in criminal proceeds as prepayment of 

future legal services. These funds are owned by Backpage, but 

held by Scheef & Stone, LLP, and are subject to forfeiture. 

65. Based upon my review of the financial records from 

Backpage and Seized Account 1, I learned that SUBJECT ACCOUNT 39 

has received the following funds from Backpage: 

a. On November 9, 2017, Backpage wired $25,000 from 

Seized Account 1 to SUBJECT ACCOUNT 39. 

-11/09/2017 - $25,000 

POSTING SOLUTIONS 

216887188 

PROSPERITY BANK 

Scheef & Stone LLP 

3100033921 

Plains Capital Bank 

SUBJECT ACCOUNT 39 

DIAGRAM FOR SUBJECT ACCOUNT 39 

14. SUBJECT ACCOUNT 40 

66. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 40 is an IOLTA account 

held in the name of the law firm Wayne B. Giampietro, LLC, at JP 

Morgan Chase Bank. Based on my conversations with Ferrer and JP 

Morgan Chase Bank employees, I believe that Backpage or Backpage-

- 56 -

DOJ-BP-0004 719141 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 58 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 58 of 

136 Page ID #:482 

controlled entities are the beneficiaries of this account. This 

account has received $100,000 in criminal proceeds as prepayment 

of future legal services. These funds are owned by Backpage, but 

held by Wayne B. Giampietro, LLC, and are subject to forfeiture. 

67. Based upon my review of the financial records from 

Backpage and Seized Account 1, I learned that SUBJECT ACCOUNT 40 

has received the following funds from Backpage: 

a. On December 19, 2017, Backpage wired $100,000 

from Seized Account 1 to SUBJECT ACCOUNT 40. 

~ - "C:a- ---12/ 19/ 2017 - $100,000---)1•· · 

POSTING SOl UTIONS 

216887188 

PROSPERITY BANK 

WAYNED B GIAMPIETRO LLC 

616275397 

JP Morgan Chase Bank 

SU BJ ECT ACCOUNT 40 

DIAGRAM FOR SUBJECT ACCOUNT 40 

15. SUBJECT ACCOUNT 41A 

68. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 41A is an IOLTA account 

held in the name of the law firm Mitchell Stein Carey, PC, at 

Alliance Bank of Arizona, account number ending in -97402. Based 

on my conversations with Ferrer and employees of Alliance Bank of 

Arizona, I believe that Backpage or Backpage-controlled entities 

are the beneficiaries of this account. This account has received 

- 57 -

DOJ-BP-0004 719142 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 59 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 59 of 

136 Page ID #:483 

$100,000 in criminal proceeds as prepayment of future legal 

services. These funds are owned by Backpage, but held by Mitchell 

Stein Carey, PC, and are subject to forfeiture. 

69. Based upon my review of the financial records from 

Backpage and Veritex Account -1462, I learned that SUBJECT 

ACCOUNT 41A has received the following funds from Backpage: 

a. On May 3, 2017, Backpage wired $100,000 from 

Veritex Account -1462 to SUBJECT ACCOUNT 41A. 

----S/ 3/ 2017 - $100,000---....;>• · 1 

POSTING SOLUTIONS 

30021462 

VERITEX BANK 

MITCHELL STEIN CAREY, PC 

XXXXX97402 

ALLIANCE BANK OF ARIZONA 

SUBJECT ACCOUNT 41A 

DIAGRAM FOR SUBJECT ACCOUNT 41A 

16. SUBJECT ACCOUNT 4 lB 

70. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 4 lB is another IOLTA 

account held in the name of the law firm Mitchell Stein Carey, PC, 

at Alliance Bank of Arizona, account number ending in -96206. 

Based on my conversations with Ferrer and employees of Alliance 

Bank of Arizona, I believe that Backpage or Backpage-controlled 

entities are the beneficiaries of this account. This account has 

received $100,000 in criminal proceeds as prepayment of future 

- 58 -

DOJ-BP-0004 719143 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 60 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 60 of 

136 Page ID #:484 

legal services. These funds are owned by Backpage, but held by 

Mitchell Stein Carey, PC, and are subject to forfeiture. 

71. Based upon my review of the financial records from 

Backpage and Seized Account 1, I learned that SUBJECT ACCOUNT 

41B has received the following funds from Backpage: 

a. December 14, 2017, Backpage wired $100,000 from 

Seized Account 1 to SUBJECT ACCOUNT 41B. 

----12/14/20 17 - $100,000---- • 

POSTING SOLUTIONS 

216887188 

PROSPERITY BANK 

MITCHIELL STEIN CAREY, PC 

8010596206 

ALLIANCE BANK OF ARIZONA 

SU BJECf ACCOUNT 41B 

DIAGRAM FOR SUBJECT ACCOUNT 41A 

1 7. SUBJECT ACCOUNT 42 

72. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 42 is an IOLTA account 

held in the name of the law firm Karp & Weiss, PC, at Western 

Alliance Bank. Based on my conversations with Ferrer and Western 

Alliance Bank employees, I believe that Backpage or Backpagecontrolled entities are the beneficiaries of this account. This 

account has received $250,000 in criminal proceeds as prepayment 

of future legal services. These funds are owned by Backpage, but 

held by Karp & Weiss, PC, and are subject to forfeiture. 

- 59 -

DOJ-BP-0004 719144 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 61 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 61 of 

136 Page ID #:485 

73. Based upon my review of the financial records from 

Backpage and Seized Account 1, I learned that SUBJECT ACCOUNT 42 

has received the following funds from Backpage: 

a. On March 29, 2017, Backpage wired $250,000 from 

Seized Account 1 to SUBJECT ACCOUNT 42. 

----3/29/2017 - $250,000---:)-. i 

POSTING SOLUTIONS 

216887188 

:PROSPERITY BANK 

Karp & Weiss, P.C. 

8011386979 

Western Alliance Bank 

SUBJECT ACCOUNT 42 

DIAGRAM FOR SUBJECT ACCOUNT 42 

18. SUBJECT ACCOUNTS 43A, 43B, 43C, and 43D 

74. I have reviewed records for SUBJECT ACCOUNTS 43A, 43B, 

43C, and 43D, as well as the following accounts: Branch Banking 

& Trust account number 1440001712008, belonging to Website 

Technologies (as detailed above, a Backpage-controlled entity), 

held in Arizona ("BB&T Account"); and Arizona Bank & Trust 

account number 9361116211 belonging to Cereus Properties, held 

in Arizona ("AZBT -6211"). I also reviewed Charles Schwab 

accounts 8524-6039 ("Schwab -6039"), 3698-9083 ("Schwab -9083"), 

4821-7249 ("Schwab -7249"), and 6971-8623 ("Schwab -8623"), all 

at Citibank, and all held in the name of Oaxaca Living Trust, 

- 60 -

DOJ-BP-0004 719145 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 62 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 62 of 

136 Page ID #:486 

with LARKIN as the grantor, and LACEY and a LARKIN relative as 

the trustees, and LARKIN's daughter as the beneficiary. I also 

reviewed Arizona Bank and Trust Accounts 9361153835 ("AZBT -

3835"), 9361153864 ("AZBT -3864"), 9361153859 ("AZBT -3859"), 

and 9361153840 ("AZBT -3840"), all held in the name of Oaxaca 

Living Trust with LACEY and a LARKIN relative as the trustees, 

and LARKIN's family as the beneficiaries. From my review, I 

learned the following: 

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

in approximately 39 wires, a company doing business for GoCoin 

transferred about $3,959,557.78 in criminal proceeds (see 

paragraphs supra) from an account held in Slovakia to the 

BBT Account in the United States. 

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

approximately 27 wires, the BBT Account transferred 

approximately $48 million to AZBT -6211. 

c. On January 4, 2017, AZBT -6211 initiated four 

wires: 

i. $33,591.34 to Schwab -6039; 

ii. $33,591.34 to Schwab -9083; 

iii. $33,591.34 to Schwab -7249; and 

iv. $33,591.34 to Schwab -8628. 

d. A few days later, these funds were moved to AZBT 

Accounts: 

- 61 -

DOJ-BP-0004 719146 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 63 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 63 of 

136 Page ID #:487 

i. On January 10, 2017 Schwab -6039 wired 

$840,692.69 to AZBT -3835; 

ii. On January 10, 2017 Schwab -8628 wired 

$840,672.70 to AZBT -3840; 

iii. On January 11, 2017 Schwab -9083 wired 

$840,692.72 to AZBT -3864; 

iv. And On January 12, 2017 Schwab -7249 wired 

$840,692.70 to AZBT -3859; 

e. Additionally, on January 11, 2017, the AZBT -6211 

transferred $33,591.34 to each of the four Oaxaca Living Trust 

accounts, AZBT -3835, AZBT -3840, AZBT -3864, and AZBT -3859. 

f. Less than one month later, on February 9, 2017, 

the four Oaxaca Living Trust accounts, AZBT -3835, AZBT -3840, 

AZBT -3864, and AZBT -3859 wired approximately $874,330 to the 

SUBJECT ACCOUNTS 43A, 43B, 43C, and 43D. More specifically: 

i. On February 9, 2017, AZBT -3835 wired $874,334.26 

to SUBJECT ACCOUNT 43A. 

ii. On February 9, 2017, AZBT -3864 wired $874,332.68 

to SUBJECT ACCOUNT 43B. 

iii. On February 9, 2017, AZBT -3835 wired $874,331.01 

to SUBJECT ACCOUNT 43C. 

iv. On February 9, 2017, AZBT -3835 wired $874,334.27 

to SUBJECT ACCOUNT 43D. 

- 62 -

DOJ-BP-0004 71914 7 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 64 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* 

136 Page ID #:488 

Filed 10/31/18 Page 64 of 

5ErW llY JAMES LAAKIN 1/201G 

GR/INTORS: )hi'CSLARKIN & MARGARrT I hRKIN 

TRUSTEES: M!QlAELLACEY &ANNE HAWKINS 

.. Qa::oica I lvlnq Tmst mo K;ithle,en D. I ttrkln 

Charlt"S Sdlwab account at Citibank 

1)5,4-(;(139 

Pu~bI lu Li~fr1,Q rrusl HK> f\ose l. l.d1ki11 

O,ar1es Sdlwab ,;iccnunt .-.it Otlhimk 

3698 9083 

Cu@rnaVi'H;"il 

/ UvlnQ Tms.t . 

HlO ()utnn M. l i!rkln 

01u1les Sdtnvdl, uccoonl ut Qlib1.mk 

4an .7249 

.. LivillCl Trus.t FBO John C. 

' Sd1wdb ilCOOtml ill Ci -

6971·8628 

3 591 

1/10/2017 

$840,692.69 

TRUSTEES: MIQlAEL LACEY &ANNE HAWKINS 

~ 

A~EHAWKJNS 

021358215!> US/I/\ 

SUBJcCT ACCO UN I '13A 

--- 2/91 1/ ----➔ ,; $874.3. HR 

PUE!l.A LIVING TRUST UT A 3/11/20 !S 

I IN -1/ 6/1/,33 

(l!lO ROSE LYONS LARKIN) 

93611,3864 

ARIZONA Jl/lNK IHRUST 

MIIJr I1/\WKlNS 

02135820>8 

US/\/\ 

SUBJF( I ACCOUN I 43~ 

., ---,o2f.i/.3 :

7

01- 1 /11/20 ~ = 

~ 

SJ 3.591 CUO>IMVhC/\~:::il~~T/\J/11/2015 

(fllO QUINN MCCART! II' /LARKIN) 

1/11/2017 9361 !!i)ij'.,9 

~>33,591.3-1 ~BANK&TRUST 

ia.'-~------------,;£!:£~?_1!1 --------+---- SI.. 

Cercus Properties 

A1llo11 ,1 B,1nk 11.i I rnSl 

93611 1G211 BRUNST/9'EAR °""""" 12111201:, 

CHIAPASUl'ING TRUST UTA 3/11/2015 

IIN 47 6/0/041 

(mo JOHN CAREY LARKIN) 

93611,3840 

ARIZONA BANK & TRUST 

DIAGRAM FOR SUBJECT ACCOUNTS 43A, 43B, 43C, and 43D 

A~EHAWKJNS 

0213>82171 

USAA 

SlJBJcCT ACCO~T 43C 

A~[ll/\!MONS 

0213:,81~07 

USAA 

SUOJI C1 ~CCOUN I 4)D 

121. In summary, as described above and depicted in the 

diagram, funds which originated from Backpage and passed through 

several layers of funnel accounts were ultimately deposited into 

SUBJECT ACCOUNTS 43A, 43B, 43C and 43D. 

19. SUBJECT ACCOUNT 44 

75. 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, 

63 

DOJ-BP-0004 719148 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 65 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 65 of 

136 Page ID #:489 

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) . 

76. From speaking with Ferrer and reviewing financial 

records, I learned that SUBJECT ACCOUNT 44 is held in the name 

of Bristol Staffing, LLC. Based on my conversations with Ferrer, 

Bristol Staffing is a Human Resource company retained by 

Backpage for Human Resource Services for Backpage and their 

employees. According to an accounting report provided by 

Bristol Staffing attorneys, which I have reviewed, at the time 

Backpage was seized by the government, Bristol Staffing had 

$1,464,000 on deposit. The report stated, "In Late April, after 

having terminated all employees, Bristol paid the final payroll 

and severance to the now angry employees. The disbursements 

totaled $718,888 .11... leaving $745,111.89 to be applied as 

directed by the contract." 

- 64 -

DOJ-BP-0004 719149 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 66 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 66 of 

136 Page ID #:490 

VI. CONCLUSION 

77. For the reasons stated above, there is probable cause 

to believe that funds and/or securities on deposit in the 

SUBJECT ACCOUNTS are subject to seizure and forfeiture by the 

United States under the following provisions: 

a. 18 U.S.C. § 981(a) (1) (A), because the funds 

and/or securities are involved in, and traceable to, one or more 

transactions or attempted transactions in violation of 18 U.S.C. 

§ 1956 (h) (Conspiracy to Launder Money), 18 U.S.C. § 1956 (a) (2) 

(International Money Laundering for Promotion), and 18 U.S.C. § 

1957 (Financial Transactions Involving Illicit Proceeds). 

Pursuant to 18 U.S.C. § 981(a) (1) (A), any property involved in a 

transaction, or attempted transaction, in violation of 18 U.S.C. 

§§ 1956 or 1957, or any property traceable to such property, is 

subject to forfeiture to the United States; and 

b. 18 U.S.C. § 981 (a) (1) (C), because the funds 

and/or securities constitute and are derived from proceeds 

traceable to one or more violations of 18 U.S.C. § 1956(h), 18 

U.S.C. § 1956(a)(2), and 18 U.S.C. § 1957. 

78. Further, a protective order under 21 U.S.C. § 853(e) 

may not be sufficient to assure the availability of the property 

for forfeiture because there is reason to believe that the 

property is under the control of the targets of this 

- 65 -

DOJ-BP-0004 719150 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 67 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 67 of 

136 Page ID #:491 

investigation, who cannot reasonably be relied upon to abide by 

an order to maintain the property in substantially the same 

condition as it is at the present time in order to ensure that 

it will be available for forfeiture. Specifically, illicit 

funds are routinely moved among several related accounts and 

certain individuals who maintain control of the accounts are 

able to move funds among other bank accounts within their 

control. Thus, I request a seizure warrant issued pursuant to 

21 U.S.C. § 853(f) (as incorporated by 18 U.S.C. § 982(b) and 28 

U.S.C. § 2461(c)) for the following SUBJECT ACCOUNTS: 

a. Up to $5,279,173.07 in Bank of the West account 

035-171363; 

b. Up to $100,000 in Wells Fargo Bank account 

2000608102052; 

c. Up to $10,000 in SunTrust Bank account 

100144637906; 

d. Up to $500,000 in Citibank account 205027287; 

e. Up to $100,000 in Citibank account 30525705; 

f. Up to $100,000 in Citibank account 1255464039; 

g. Up to $2,167,704.86 in US Bank account 

153555921235; 

h. Up to $100,000 in US Bank account 100-06-06952; 

i. Up to $10,000 in JP Morgan Chase account 

211909285; 

- 66 -

DOJ-BP-0004 719151 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 68 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 68 of 

136 Page ID #:492 

j . Up to $740,000 in Grand Point Bank account 

2503985; 

k. Up to $100,000 in JP Morgan Chase account 

851844381; 

l. Up to $250,000 in JP Morgan Chase account 

100079698 

m. Up to $25,000 in Plains Capital account 

3100033921; 

n. Up to $100,000 in JP Morgan Chase account 

616275397; 

o. Up to $100,000 in alliance Bank of Arizona 

account 801059742; 

p. Up to $100,000 in alliance Bank of Arizona 

account 8010596206; 

q. Up to $250,000 in Western Alliance account 

8011386979; 

r. Any and All Funds in USAA Saving Bank account 

0213582188; 

s. Any and All Funds in USAA Saving Bank account 

0213582058; 

t. Any and All Funds in USAA Saving Bank account 

0213582171 

u. Any and All Funds in USAA Saving Bank account 

0213581508; and 

- 67 -

DOJ-BP-0004 719152 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 69 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10131118 Page 69 of 

136 Page ID #:493 

v. Up to $745,111.89 in Texas Bank account 

111923238. 

Subscribed to and sworn to me 

this 31 st day of October, 2018 

~l• fl...fA 0... QO ~ United States Magistrate Judge 

ISi 

Lyndon Versoza 

U.S. Postal Inspector 

- 68 -

DOJ-BP-0004 719153 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 70 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 70 of 

136 Page ID #:494 

BANKNAME WARRANT NUMBER ACCOUNTS 

JUDGE DATE SIGNED 

Ascio 18-MJ-711 Domains on Attachment A 

Judge Walsh 3/28/18 

Ascensus Broker Dealer Service, 18-MJ-712 367726943-01 

Inc. '5280-01 

Judge Walsh 3/28/18 

Prosperity Bank 216887188 

Judge Walsh 18-MJ-721 

3/28/18 

6738453873 

Compass Bank 18-MJ-715 6745023825 3/28/18 Judge Walsh 

1294879342 

18-MJ-713 488039130071 

Bank of America, N.A. 3/28/18 483072278225 

Judge Walsh 5091387054 

0045000151 

18-MJ-719 0045000178 

National Bank of Arizona 3/28/18 0046003645 

Judge Walsh SDB-005007224 

75600050642523 

San Francisco Fire Credit Union 18-MJ-723 

3/28/18 Judge Walsh 

66910 

Live Oak Bank 18-MJ-718 

3/28/18 Judge Walsh 

First Federal Savings & Loan of 18-MJ-716 51103620 

San Rafael 3/28/18 Judge Walsh 

5501801098 

18-MJ-720 

Plains Capital 3/28/18 

Judge Walsh 

Ally Bank 18-MJ-724 2153056292 

Judge Walsh 3/28/18 

Branch Banking and Trust 18-MJ-751 1440001710218 

Judge Walsh 3/28/18 

18-MJ-752 3094832 

Green Bank 3/28/18 5501194293 

Judge Walsh 

ATTACHMENT A 

DOJ-BP-0004 719154 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 71 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 71 of 

136 Page ID #:495 

BANKNAME WARRANT NUMBER ACCOUNTS 

JUDGE DATE SIGNED 

11101889 

18-MJ-722 11402592 

3/28/18 11101938 

Republic Bank of AZ 11002912 

Judge Walsh 11402500 

11402485 

11101897 

11003126 

18-MJ-996 1021078316 

4/26/18 1021078324 

1021078332 

1021078103 

Republic Bank of AZ 1021078162 

Judge McDermott 1021078189 

54000770012 

Perkins Coie 18-MJ-797 

4/9/18 Judge Walsh 

888-96878 

079-64954 

18-MJ-798 036-50582 

4/4/18 036-57892 

036-57889 

Alliance Bernstein 036-57888 

Judge Walsh 079-66485 

18-MJ-997 HU6310401093505267678576121 

K&H Bank (Hungary) 4/26/18 

0 

Judge McDermott 

CZ9020100000002300995803; 

CZ1220100000002000995801; 

CZ7l20100000002600995805; 

CZ7020100000002001002226; 

CZ7620100000002101002231; 

18-MJ-998 CZ8520100000002501002230; 

4/26/18 CZ4620100000002000914194; 

CZ2720100000002300914196; 

CZ0820100000002600914198; 

CZ4820100000002801118083; 

Fio Bank (Czech Republic) CZ2020100000002701118086; 

Judge McDermott CZ7620100000002901118080 

L/09 08811060 7717 K000K 

18-MJ-999 L/30 08811060 7717 K000 U 

Bank Frick (Liechtenstein) 4/26/18 L/74 0881 1060 7717 K000 E 

Judge McDermott L/90 08811060 7717 K00J E 

ATTACHMENT A 

DOJ-BP-0004 719155 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 72 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 72 of 

136 Page ID #:496 

BANKNAME WARRANT NUMBER ACCOUNTS 

JUDGE DATE SIGNED 

18-MJ-1000 NL15KNAB0255357664 

Knab Bank (Netherlands) 4/26/18 Judge McDermott 

18-MJ-1001 NL44RABO0307182452 

Rabo (Netherlands) NL64RABO0307 604721 

4/26/18 Judge McDermott 

'2020 

Acacia Conservation Funds 18-MJ-01427 

6/4/18 Judge Rosenbluth 

'1262 

Saxo Payments 18-MJ-01428 

6/4/18 Judge Rosenbluth 

EE417700771002634431 

LHVPank 18-MJ-1433 

6/4/18 Judge Rosenbluth 

6745314862 

BBVA Compass Bank 18-MJ-1863 

7/19/18 Judge Oliver 

Previously held at MidFirst bank 

18-MJ-2030 #8061024139 and used to 

MoneyGram 8/7/18 purchase un-negotiated 

Judge Choolijian MoneyGram cashier 's check 

#317503 

Bank of America IOLTA 18-MJ-2031 $8,778,802.96 from account 

Judge Choolijian 8/7/18 

#500331414 

ATTACHMENT A 

DOJ-BP-0004 719156 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 73 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 73 of 

136 Page ID #:497 

United States District Court ---- -=C=E.::...:NT-==RAL= _____ DISTRICT OF ____ -=C=AL=IF=-O=RN=IA=-=-------

In the Matter of the Seizure of 

(Addrcu or Brier tltstriptfon. of property or premises to be $ttttd) 

UP TO AND INCLUDING $8,778,802.96 HELD 

IN BANK OF AMERICA IOLTA ACCOUNT 

#50033414 

AMENDED 

SEIZURE WARRANT 

CASE NUMBER: 2: 18-MJ-02031 

TO: United States Postal Inspection Service <USPIS) and any Authorized Officer of the United States, Affidavit(s) having been 

made before me by POSTAL INSPECTOR LYNDON VERSOZA who has reason to believe that in the Central District of California 

and elsewhere there is now certain property which is subject to forfeiture to the United States, namely (describe the property to be seized) 

Up to and including $8,778,802.96 held in Bank of America IOLTA account #50033414 

,vhicb is {Jlat~ on.it Dr more buu for,mure \I.Ddc-r Unitfll Stuu Codt:) 

subject to seizure and forfeiture under 18 U.S.C. § 981(a}(l)(A) and (C) 

concerning a violation of Title _lL United States Code, Sections 1591. 1952, 1956, and 1957. 

I am satisfied that the affidavit(s) aud any recorded testimony establish probable cause to believe that the property so described is subject 

to seizure and that grounds exist for the issuance of this seizure warrant. 

Bank of America is ordered to deliver said funds immediately and forthwith upon presentation of this warrant to the law enforcement 

agent serving the warrant, in the form of a cashier's check made payable to the United States Marshal Service. 

YOU ARE HEREBY COMMANDED to seize within 14 d~ys the property specified, serving this warrant and making the seizure in the 

daytime - 6:00 A.M. to 10:00 PM., leaving a copy of this warrant and receipt for the property seized, and prepare a written inventory 

of the property seized and promptly return this warrant to the undersigned judicial officer as required l;,y law. 

Hon,, Jacqueline Chooljian. U.S. Magistrate Judge 

Namf,) and Title of Judicial Officer 

John Kucera/smb 

Los Angeles California 

City and State 

ATTACHMENT B 

DOJ-BP-0004719157 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 74 of 76
Case 2:18-mj-02872-DUTY,*SEALED* Document 3-1 *SEALED* 1 _1_36_ Paae IDJt'4~8 Case 2:18-mj-02031-DUl SEALE(J7! -oocumen15~1 SEALED, 

Filed 10/31/18 Page 7 4 of 

Filed 08/07/18 Page 1 of 

121 Page ID #:325 

United States District Court ____ ..;;;:;C=E.;;;..:N-=T=RAL='------DISTRICT OF ____ ....::C=AL=IF=O=RN=-:..:;:;IA;:..:;_ _____ _ 

In the Matter of the Seizure of 

(Address or Brief dcsc:liption or propc11y or prnmfo:cs to bo seb·.ed) 

UP TO AND JNCLUDING $8,778,802.96 

HELD IN BANK OF AMERlCA IOLTA 

ACCOUNT #50033414 

I, LYNDON VERSOZA. being duly sworn, depose and say: 

AMENDED 

APPLICATION AND AFFIDAVIT 

FOR SEIZURE WARRANT 

FILED 

cu:Rl(, U.S. DISTIUCTCOURT 

Aug 7, 2018 I 

CENI'RAL DISTRJCT OF CALtFORNlA 

BY: kh DEl'\TfV 

I am a United States Postal Inspector with the United States Postal Inspection Service, and l have reason to believe that 

in the CENTRAL district of CALIFORNIA and elsewhere there is now concealed a certain person or 

property, namely (d,mibc the person or piOperty to be ,,;,..d) 

Up to and including $8,778,802.96 held in Bank of America IOLTA account #50033414 

which is (slate ooe or more bases fo1· ,elmre undo< un;1cd Stal<> Code) 

subject to seizure and forfeiture under 18 U.S.C. § 98l(a)(l)(A) and (C) 

concerning a violations of Title ...ll.. United States Code, Sections 1591, 1952, 1956 and 1957. 

The facts to support a finding of Probable Cause for issuance of a Seizure Warrant are as follows: 

Continued on the attached sheet and made a part hereof. X Yes No 

Sworn to before me, and subscribed in my presence 

August 7, 2018 

Date 

Hon. Jacqueline Chooljian U.S. Magistrate Judge 

Name and Title of Judicial Officer 

John Kucera:smb 

Signature of Affiant 

Los Angeles, California 

City and State 

Isl 

Signature of Judicial Officer 

ATTACHMENT B 

DOJ-BP-0004 719158 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 75 of 76
Case 2:18-mj-02872-DUTY *SEALED* Document 3-1 *SEALED* Filed 10/31/18 Page 75 of 

. /' -136 Paae IDJt"4~9 - Case 2:18-mJ-02031-DUT\ ..>EALED'< Docurnen1 5-1 SEALED*· . :iled 08/07/18 Page 2 of 

121 Page ID #:326 

AFFIDAVIT IN SUPPORT OF SEIZURE WARRANT 

I , Lyndon A. Versoza , being dul y sworn , hereby depose and state 

as follows : 

I. TRAINING AND EXPERIENCE 

1. I am a United States Postal I nspector empl oyed by the 

United States Postal Inspection Service (" USPIS " ) , Los Angeles 

Di v i sion, in Los Ange l es, California , where I have served since 

June 2005 . Currently, I am responsible for investigating 

crimin al violations of money laundering and structuring laws, 

such as when United States Posta l Service ("USPS " ) Money Orders 

or the United States Mail are used as a means to launder or 

stru cture funds . During my career as a Postal Inspector, I have 

participated in or investigated financial violations including 

money laundering , darkn et i nvestigati ons, digital currency 

investigations, structuring, bank, wire and mail fraud, and 

identity theft . In addition, I have received both formal and 

i nformal t raining from USPIS and other agencies regardi ng money 

laundering and financial crimes . For approximately five years 

prior t o investigating money l aunde ring, I was assigned to 

investigate child exploitation and sex traffi cki ng . I n that 

assignment , I worked both independently and in a task force 

where I led and partici pated in i nvestigations related to crimes 

invol ving the expl oitation of children and sex trafficking . 

ATTACHMENT B 

DOJ-BP-0004 719159 

Case 2:18-cr-00422-DJH Document 1968-1 Filed 11/13/23 Page 76 of 76