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GARY M. RESTAINO

United States Attorney

District of Arizona

KEVIN M. RAPP (Ariz. Bar No. 014249, kevin.rapp@usdoj.gov)

MARGARET PERLMETER (Ariz. Bar No. 024805, margaret.perlmeter@usdoj.gov)

PETER S. KOZINETS (Ariz. Bar No. 019856, peter.kozinets@usdoj.gov) 

ANDREW C. STONE (Ariz. Bar No. 026543, andrew.stone@usdoj.gov)

Assistant U.S. Attorneys

40 N. Central Avenue, Suite 1800

Phoenix, Arizona 85004-4408

Telephone (602) 514-7500

DAN G. BOYLE (N.Y. Bar No. 5216825, daniel.boyle2@usdoj.gov) 

Special Assistant U.S. Attorney

312 N. Spring Street, Suite 1400

Los Angeles, CA 90012

Telephone (213) 894-2426

NICOLE M. ARGENTIERI

Acting Assistant Attorney General 

Criminal Division, U.S. Department of Justice

AUSTIN M. BERRY (Texas Bar No. 24062615, austin.berry2@usdoj.gov)

U.S. Department of Justice

Child Exploitation and Obscenity Section

1301 New York Avenue, NW, 11th Floor

Washington, D.C. 20005

Telephone (202) 412-4136

Attorneys for Plaintiff

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

United States of America,

Plaintiff, 

v. 

Michael Lacey, et al.,

Defendants.

No. CR-18-422-PHX-SMB

UNITED STATES PROPOSED 

SPECIAL VERDICT FORM FOR 

FORFEITURE

Case 2:18-cr-00422-DJH Document 1936 Filed 11/01/23 Page 1 of 23
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The United States submits the attached Proposed Special Verdict Form for Forfeiture, 

to be used in the event of any defendant’s conviction on a count in the Superseding Indictment 

which has an associated forfeiture allegation. The United States reserves the right to conform 

this proposed verdict form to any counts of conviction, including by adding or removing any 

property identified in the forfeiture allegations of the Superseding Indictment and related Bills 

of Particular.

Respectfully submitted this 1st day of November, 2023.

GARY M. RESTAINO

United States Attorney

District of Arizona

NICOLE M. ARGENTIERI

Acting Assistant Attorney General 

Criminal Division, U.S. Department of Justice

/s/

KEVIN M. RAPP

MARGARET PERLMETER

PETER KOZINETS

ANDREW STONE

DAN G. BOYLE

Assistant U.S. Attorneys

AUSTIN M. BERRY

Trial Attorney

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CERTIFICATE OF SERVICE

I hereby certify that on November 1, 2023, I electronically transmitted the attached 

document to the Clerk’s Office using the CM/ECF System for filing and transmittal of a 

Notice of Electronic Filing to the CM/ECF registrants who have entered their appearance 

as counsel of record.

s/ Dan G. Boyle

Dan G. Boyle

U.S. Attorney’s Office

Case 2:18-cr-00422-DJH Document 1936 Filed 11/01/23 Page 3 of 23
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SPECIAL FORFEITURE VERDICT FORM

Count 1: Conspiracy to Violate the Travel Act

Defendant LACEY

We, the jury, return the following Special Verdict, as to Defendant Michael Lacey

regarding the property described below.

We, the jury, unanimously find by a preponderance of the evidence that they are 

proceeds of a Conspiracy to Violate the Travel Act, or property traceable to such property, 

for which the Defendant was found guilty:

1. Real Property Located at 2755 Fillmore Street, San Francisco, CA 94123; 

[ ] Yes [ ] No

2. Real Property Located at 3300 E. Stella Lane, Paradise Valley, AZ 85253; 

[ ] Yes [ ] No

3. Real Property Located at 3304 E. Stella Lane, Paradise Valley, AZ 85253; 

[ ] Yes [ ] No

4. Real Property Located at 3308 E. Stella Lane, Paradise Valley, AZ 85253; 

[ ] Yes [ ] No

5. Real Property Located at 6300 N. 33rd Street, Paradise Valley, AZ 85253; 

[ ] Yes [ ] No

6. Real Property Located at 6314 N. 33rd Street, Paradise Valley, AZ 85253; 

[ ] Yes [ ] No

7. Real Property Located at 2416 N. Foote Dr., Phoenix, AZ 85008; 

[ ] Yes [ ] No

8. $16,500,000.00 seized from or restrained in K&H account number ending

1210 held in the name of Primus Trust and any proceeds thereof; 

[ ] Yes [ ] No

9. $2,412,785.47 seized from or restrained in Midfirst Bank account number 

ending 4139, held for the benefit of Lacey, and any proceeds thereof; 

[ ] Yes [ ] No

Case 2:18-cr-00422-DJH Document 1936 Filed 11/01/23 Page 4 of 23
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10. $302,177.57 seized from or restrained in Republic Bank of Arizona CDARS 

account number ending 8324 and any proceeds thereof; 

[ ] Yes [ ] No

11. $305,127.89 seized from or restrained in Republic Bank of Arizona CDARS 

account number ending 8332 and any proceeds thereof; 

[ ] Yes [ ] No

12. $484,745.72 seized from or restrained in SF Fire Credit Union account 

number ending 2523 and any proceeds thereof; 

[ ] Yes [ ] No

13. $500,000.00 seized from or restrained in Republic Bank of Arizona account 

number ending 3126 and any proceeds thereof; 

[ ] Yes [ ] No

14. $140,711.61 seized from or restrained in Republic Bank of Arizona account 

number ending 2485 and any proceeds thereof; 

[ ] Yes [ ] No

15. $601,827.10 seized from or restrained in Republic Bank of Arizona 

Certificate of Deposit number ending 8316 and any proceeds thereof; 

[ ] Yes [ ] No

16. $689,884.48 seized from or restrained in First Federal Savings & Loan of 

San Rafael account number ending 3620 and any proceeds thereof; 

[ ] Yes [ ] No

17. $5,462,027.17 seized from or restrained in Compass Bank account number 

ending 3873 held in the name of Cereus Properties and any proceeds 

thereof;

[ ] Yes [ ] No

18. $182,1 82.50 seized from or restrained in Amro Bank, N.V. account number 

ending 6352 held in the name of Ad Tech BV with Stichting Zencotrust; 

[ ] Yes [ ] No

Case 2:18-cr-00422-DJH Document 1936 Filed 11/01/23 Page 5 of 23
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19. $191,246.00 seized from or restrained in Western Alliance Bank account 

number ending 6979 held in the name of Mitchell Stein Carey Chapman PC. 

and any proceeds thereof;

[ ] Yes [ ] No

20. $518,172.92 seized from or restrained in Wells Fargo Bank account number 

ending 4455 in the name of Cardquiry and any proceeds thereof;

[ ] Yes [ ] No

21. 747,664.15 GBP seized from or restrained in SAXO Payments (UK) account

number ending 1262 held in the name of the Cashflows Europe Limited and 

any proceeds thereof;

[ ] Yes [ ] No

22. $499,910.01 seized from or restrained in US Bank account number ending 

0239 held in the name of Affordable Bail Bonds LLC and any proceeds 

thereof;

[ ] Yes [ ] No

23. $1,600,705.61 seized from or restrained LHV Pank account number ending 

4431 held in the name of Olist OU and any proceeds thereof. 

[ ] Yes [ ] No

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Count 52: Money Laundering Conspiracy

Defendant LACEY

We, the jury, return the following Special Verdict, as to Defendant Michael Lacey

regarding the property described below.

We, the jury, unanimously find by a preponderance of the evidence that they are 

property involved in a Money Laundering Conspiracy, or property traceable to such 

property, for which the Defendant was found guilty:

1. Real Property Located at 2755 Fillmore St, San Francisco, CA 94123; 

[ ] Yes [ ] No

2. Real Property Located at 3300 E. Stella Lane, Paradise Valley, AZ 85253; 

[ ] Yes [ ] No

3. Real Property Located at 3304 E. Stella Lane, Paradise Valley, AZ 85253; 

[ ] Yes [ ] No

4. Real Property Located at 3308 E. Stella Lane, Paradise Valley, AZ 85253; 

[ ] Yes [ ] No

5. Real Property Located at 6300 N. 33rd Street, Paradise Valley, AZ 85253; 

[ ] Yes [ ] No

6. Real Property Located at 6314 N. 33rd Street, Paradise Valley, AZ 85253; 

[ ] Yes [ ] No

7. Real Property Located at 2416 N. Foote Dr., Phoenix, AZ 85008; 

[ ] Yes [ ] No

8. $16,500,000.00 seized from or restrained in K&H account number ending

1210 held in the name of Primus Trust and any proceeds thereof; 

[ ] Yes [ ] No

9. $2,412,785.47 seized from or restrained in Midfirst Bank account number 

ending 4139, held for the benefit of Lacey, and any proceeds thereof; 

[ ] Yes [ ] No

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10. $302,177.57 seized from or restrained in Republic Bank of Arizona CDARS 

account number ending 8324 and any proceeds thereof; 

[ ] Yes [ ] No

11. $305,127.89 seized from or restrained in Republic Bank of Arizona CDARS 

account number ending 8332 and any proceeds thereof; 

[ ] Yes [ ] No

12. $484,745.72 seized from or restrained in SF Fire Credit Union account 

number ending 2523 and any proceeds thereof; 

[ ] Yes [ ] No

13. $500,000.00 seized from or restrained in Republic Bank of Arizona account 

number ending 3126 and any proceeds thereof; 

[ ] Yes [ ] No

14. $140,711.61 seized from or restrained in Republic Bank of Arizona account 

number ending 2485 and any proceeds thereof; 

[ ] Yes [ ] No

15. $601,827.10 seized from or restrained in Republic Bank of Arizona 

Certificate of Deposit number ending 8316 and any proceeds thereof; 

[ ] Yes [ ] No

16. $689,884.48 seized from or restrained in First Federal Savings & Loan of 

San Rafael account number ending 3620 and any proceeds thereof; 

[ ] Yes [ ] No

17. $5,462,027.17 seized from or restrained in Compass Bank account number 

ending 3873 held in the name of Cereus Properties and any proceeds 

thereof;

[ ] Yes [ ] No

18. $182,182.50 seized from or restrained in Amro Bank, N.V. account number 

ending 6352 held in the name of Ad Tech BV with Stichting Zencotrust; 

[ ] Yes [ ] No

19. $191,246.00 seized from or restrained in Western Alliance Bank account 

number ending 6979 held in the name of Mitchell Stein Carey Chapman PC. 

and any proceeds thereof;

Case 2:18-cr-00422-DJH Document 1936 Filed 11/01/23 Page 8 of 23
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[ ] Yes [ ] No

20. $518,172.92 seized from or restrained in Wells Fargo Bank account number 

ending 4455 in the name of Cardquiry and any proceeds thereof;

[ ] Yes [ ] No

21. 747,664.15 GBP seized from or restrained in SAXO Payments (UK) account 

number ending 1262 held in the name of the Cashflows Europe Limited and 

any proceeds thereof;

[ ] Yes [ ] No

22. $499,910.01 seized from or restrained in US Bank account number ending 

0239 held in the name of Affordable Bail Bonds LLC and any proceeds 

thereof;

[ ] Yes [ ] No

23. $1,600,705.61 seized from or restrained LHV Pank account number ending 

4431 held in the name of Olist OU and any proceeds thereof. 

[ ] Yes [ ] No

Case 2:18-cr-00422-DJH Document 1936 Filed 11/01/23 Page 9 of 23
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Count 69

Defendant LACEY

We, the jury, return the following Special Verdict, as to Defendant Michael Lacey

regarding the property described below.

We, the jury, unanimously find by a preponderance of the evidence that they are 

property involved in Transactional Money Laundering, or property traceable to such 

property, for which the Defendant was found guilty:

1. Real Property Located at 10647 N. State Route 89A, Sedona, AZ 86336

 [ ] Yes [ ] No

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Count 70

Defendant LACEY

We, the jury, return the following Special Verdict, as to Defendant Michael Lacey

regarding the property described below.

We, the jury, unanimously find by a preponderance of the evidence that they are 

property involved in Transactional Money Laundering, or property traceable to such 

property, for which the Defendant was found guilty:

1. Real Property Located at 10647 N. State Route 89A, Sedona, AZ 86336

 [ ] Yes [ ] No

Case 2:18-cr-00422-DJH Document 1936 Filed 11/01/23 Page 11 of 23
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Count 83

Defendant LACEY

We, the jury, return the following Special Verdict, as to Defendant Michael Lacey

regarding the property described below.

We, the jury, unanimously find by a preponderance of the evidence that they are 

property involved in Transactional Money Laundering, or property traceable to such 

property, for which the Defendant was found guilty:

1. Real Property Located at 2755 Fillmore St, San Francisco, CA 94123; 

 [ ] Yes [ ] No

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Count 84

Defendant LACEY

We, the jury, return the following Special Verdict, as to Defendant Michael Lacey

regarding the property described below.

We, the jury, unanimously find by a preponderance of the evidence that they are 

property involved in Transactional Money Laundering, or property traceable to such 

property, for which the Defendant was found guilty:

1. Real Property Located at 2755 Fillmore St, San Francisco, CA 94123; 

 [ ] Yes [ ] No

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Count 99

Defendant LACEY

We, the jury, return the following Special Verdict, as to Defendant Michael Lacey

regarding the property described below.

We, the jury, unanimously find by a preponderance of the evidence that they are 

property involved in Transactional Money Laundering, or property traceable to such 

property, for which the Defendant was found guilty:

1. $16,500,000.00 seized from or restrained in K&H account number ending

1210 held in the name of Primus Trust and any proceeds thereof:

[ ] Yes [ ] No

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Count 100: International Concealment Money Laundering

Defendant LACEY

We, the jury, return the following Special Verdict, as to Defendant Michael Lacey

regarding the property described below.

We, the jury, unanimously find by a preponderance of the evidence that they are 

property involved in International Concealment Money Laundering, or property traceable 

to such property, for which the Defendant was found guilty:

1. $16,500,000.00 seized from or restrained in K&H account number ending

1210 held in the name of Primus Trust and any proceeds thereof: 

[ ] Yes [ ] No

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Count 1: Conspiracy to Violate the Travel Act

Defendant SPEAR

We, the jury, return the following Special Verdict, as to Defendant Scott Spear

regarding the property described below.

We, the jury, unanimously find by a preponderance of the evidence that they are 

proceeds of a Conspiracy to Violate the Travel Act, or property traceable to such property, 

for which the Defendant was found guilty:

1. $613,573.28 seized from or restrained in National Bank of Arizona account 

number ending 3645 and any proceeds thereof; 

 [ ] Yes [ ] No

2. $404,374.12 seized from or restrained in National Bank of Arizona account 

number ending 0178 and any proceeds thereof; 

[ ] Yes [ ] No

3. $260,283.40 seized from or restrained in Live Oak Bank account number 

ending 6910 and any proceeds thereof; 

[ ] Yes [ ] No

4. $56,902.99 seized from or restrained in Ascensus Broker Services account 

number ending 8001 and any proceeds thereof; 

[ ] Yes [ ] No

5. $64,552.82 seized from or restrained in Ascensus Broker Services account 

number ending 4301 and any proceeds thereof; 

[ ] Yes [ ] No

6. $1,925.80 seized from or restrained in National Bank of Arizona account 

number ending 0151 and any proceeds thereof; 

[ ] Yes [ ] No

7. $5,462,027.17 seized from or restrained in Compass Bank account number 

ending 3873 held in the name of Cereus Properties and any proceeds 

thereof; 

[ ] Yes [ ] No

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8. $182,182.50 seized from or restrained in Amro Bank, N.V. account number 

ending 6352 held in the name of Ad Tech BV with Stichting Zencotrust; 

[ ] Yes [ ] No

9. $191,246.00 seized from or restrained in Western Alliance Bank account 

number ending 6979 held in the name of Mitchell Stein Carey Chapman PC. 

and any proceeds thereof; 

[ ] Yes [ ] No

10. $518,172.92 seized from or restrained in Wells Fargo Bank account number 

ending 4455 in the name of Cardquiry and any proceeds thereof; 

[ ] Yes [ ] No

11. $747,664.15 GBP seized from or restrained in SAXO Payments (UK) 

account number ending 1262 held in the name of the Cashflows Europe 

Limited and any proceeds thereof; 

[ ] Yes [ ] No

12. $499,910.01 seized from or restrained in US Bank account number ending 

0239 held in the name of Affordable Bail Bonds LLC and any proceeds 

thereof; 

[ ] Yes [ ] No

13. $1,600,705.61 seized from or restrained LHV Pank account number ending 

4431 held in the name of Olist OU and any proceeds thereof. 

[ ] Yes [ ] No

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Count 52: Money Laundering Conspiracy

Defendant SPEAR

We, the jury, return the following Special Verdict, as to Defendant Scott Spear

regarding the property described below.

We, the jury, unanimously find by a preponderance of the evidence that they are 

property involved in a Money Laundering Conspiracy, or property traceable to such 

property, for which the Defendant was found guilty:

2. $613,573.28 seized from or restrained in National Bank of Arizona account 

number ending 3645 and any proceeds thereof; 

 [ ] Yes [ ] No

3. $404,374.12 seized from or restrained in National Bank of Arizona account 

number ending 0178 and any proceeds thereof; 

[ ] Yes [ ] No

4. $260,283.40 seized from or restrained in Live Oak Bank account number 

ending 6910 and any proceeds thereof; 

[ ] Yes [ ] No

5. $56,902.99 seized from or restrained in Ascensus Broker Services account 

number ending 8001 and any proceeds thereof; 

[ ] Yes [ ] No

6. $64,552.82 seized from or restrained in Ascensus Broker Services account 

number ending 4301 and any proceeds thereof; 

[ ] Yes [ ] No

7. $1,925.80 seized from or restrained in National Bank of Arizona account 

number ending 0151 and any proceeds thereof; 

[ ] Yes [ ] No

8. $5,462,027.17 seized from or restrained in Compass Bank account number 

ending 3873 held in the name of Cereus Properties and any proceeds 

thereof; 

[ ] Yes [ ] No

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9. $182,182.50 seized from or restrained in Amro Bank, N.V. account number 

ending 6352 held in the name of Ad Tech BV with Stichting Zencotrust; 

[ ] Yes [ ] No

10. $191,246.00 seized from or restrained in Western Alliance Bank account 

number ending 6979 held in the name of Mitchell Stein Carey Chapman PC. 

and any proceeds thereof; 

[ ] Yes [ ] No

11. $518,172.92 seized from or restrained in Wells Fargo Bank account number 

ending 4455 in the name of Cardquiry and any proceeds thereof; 

[ ] Yes [ ] No

12. $747,664.15 GBP seized from or restrained in SAXO Payments (UK) 

account number ending 1262 held in the name of the Cashflows Europe 

Limited and any proceeds thereof; 

[ ] Yes [ ] No

13. $499,910.01 seized from or restrained in US Bank account number ending 

0239 held in the name of Affordable Bail Bonds LLC and any proceeds 

thereof; 

[ ] Yes [ ] No

14. $1,600,705.61 seized from or restrained LHV Pank account number ending 

4431 held in the name of Olist OU and any proceeds thereof. 

[ ] Yes [ ] No

Case 2:18-cr-00422-DJH Document 1936 Filed 11/01/23 Page 19 of 23
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Count 1: Conspiracy to Violate the Travel Act

Defendant BRUNST

We, the jury, return the following Special Verdict, as to Defendant John “Jed” 

Brunst regarding the property described below.

We, the jury, unanimously find by a preponderance of the evidence that they are 

proceeds of a Conspiracy to Violate the Travel Act, or property traceable to such property, 

for which the Defendant was found guilty:

1. $5,848,729.00 seized from or restrained in Alliance Bernstein account 

number ending 6878 and any proceeds thereof;

[ ] Yes [ ] No

2. $527,624.00 seized from or restrained in Alliance Bernstein account 

number ending 6485 and any proceeds thereof;

[ ] Yes [ ] No

3. $342,596.00 seized from or restrained in Alliance Bernstein account 

number ending 7982 and any proceeds thereof;

[ ] Yes [ ] No

4. $306,277.00 seized from or restrained in Alliance Bernstein account 

number ending 7889 and any proceeds thereof;

[ ] Yes [ ] No

5. $275,328.00 seized from or restrained in Alliance Bernstein account 

number ending 7888 and any proceeds thereof;

[ ] Yes [ ] No

6. $372,878.00 seized from or restrained in Alliance Bernstein account 

number ending 4954 and any proceeds thereof;

[ ] Yes [ ] No

7. $359,527.06 seized from or restrained in Compass Bank account number 

ending 3825 and any proceeds thereof; 

 [ ] Yes [ ] No

Case 2:18-cr-00422-DJH Document 1936 Filed 11/01/23 Page 20 of 23
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8. $5,462,027.17 seized from or restrained in Compass Bank account number 

ending 3873 held in the name of Cereus Properties and any proceeds 

thereof; 

[ ] Yes [ ] No

9. $182,182.50 seized from or restrained in Amro Bank, N.V. account number 

ending 6352 held in the name of Ad Tech BV with Stichting Zencotrust; 

[ ] Yes [ ] No

10. $191,246.00 seized from or restrained in Western Alliance Bank account 

number ending 6979 held in the name of Mitchell Stein Carey Chapman PC. 

and any proceeds thereof; 

[ ] Yes [ ] No

11. $518,172.92 seized from or restrained in Wells Fargo Bank account number 

ending 4455 in the name of Cardquiry and any proceeds thereof; 

[ ] Yes [ ] No

12. $747,664.15 GBP seized from or restrained in SAXO Payments (UK) 

account number ending 1262 held in the name of the Cashflows Europe 

Limited and any proceeds thereof; 

[ ] Yes [ ] No

13. $499,910.01 seized from or restrained in US Bank account number ending

0239 held in the name of Affordable Bail Bonds LLC and any proceeds 

thereof; 

[ ] Yes [ ] No

14. $1,600,705.61 seized from or restrained LHV Pank account number ending 

4431 held in the name of Olist OU and any proceeds thereof. 

[ ] Yes [ ] No

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Count 52: Money Laundering Conspiracy

Defendant BRUNST

We, the jury, return the following Special Verdict, as to Defendant John “Jed” 

Brunst regarding the property described below.

We, the jury, unanimously find by a preponderance of the evidence that they are 

property involved in a Money Laundering Conspiracy, or property traceable to such 

property, for which the Defendant was found guilty:

1. $5,848,729.00 seized from or restrained in Alliance Bernstein account 

number ending 6878 and any proceeds thereof;

[ ] Yes [ ] No

2. $527,624.00 seized from or restrained in Alliance Bernstein account 

number ending 6485 and any proceeds thereof;

[ ] Yes [ ] No

3. $342,596.00 seized from or restrained in Alliance Bernstein account 

number ending 7982 and any proceeds thereof;

[ ] Yes [ ] No

4. $306,277.00 seized from or restrained in Alliance Bernstein account 

number ending 7889 and any proceeds thereof;

[ ] Yes [ ] No

5. $275,328.00 seized from or restrained in Alliance Bernstein account 

number ending 7888 and any proceeds thereof;

[ ] Yes [ ] No

6. $372,878.00 seized from or restrained in Alliance Bernstein account 

number ending 4954 and any proceeds thereof;

[ ] Yes [ ] No

7. $359,527.06 seized from or restrained in Compass Bank account number 

ending 3825 and any proceeds thereof; 

 [ ] Yes [ ] No

8. $5,462,027.17 seized from or restrained in Compass Bank account number 

ending 3873 held in the name of Cereus Properties and any proceeds 

thereof; 

[ ] Yes [ ] No

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9. $182,182.50 seized from or restrained in Amro Bank, N.V. account number 

ending 6352 held in the name of Ad Tech BV with Stichting Zencotrust; 

[ ] Yes [ ] No

10. $191,246.00 seized from or restrained in Western Alliance Bank account 

number ending 6979 held in the name of Mitchell Stein Carey Chapman PC. 

and any proceeds thereof; 

[ ] Yes [ ] No

11. $518,172.92 seized from or restrained in Wells Fargo Bank account number 

ending 4455 in the name of Cardquiry and any proceeds thereof; 

[ ] Yes [ ] No

12. $747,664.15 GBP seized from or restrained in SAXO Payments (UK) 

account number ending 1262 held in the name of the Cashflows Europe 

Limited and any proceeds thereof; 

[ ] Yes [ ] No

13. $499,910.01 seized from or restrained in US Bank account number ending 

0239 held in the name of Affordable Bail Bonds LLC and any proceeds 

thereof; 

[ ] Yes [ ] No

14. $1,600,705.61 seized from or restrained LHV Pank account number ending 

4431 held in the name of Olist OU and any proceeds thereof. 

[ ] Yes [ ] No

This _____ day of November, 2023.

__________________________________

Foreperson

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