Exhibit 1

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United States District Court 

____ _.C=E=N .... T ..... RA=L""------ DISTRICT OF ------'C=A=L=I=F_.O"""RN'-="-IA=---------

In the Matter of the Seizure of 

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

Any and all funds held in Knab Battf,~eetlttftt----------,FOR SEIZURE WARRANT 

# NL15KNAB0255357664 FILED 

CLERK, U.S. DISTRICT COfflSE UMBER: 2: 18-MJ-01000 

I APR 26 2018 I 

CENTRAL DISTRICT OF CALIFORNIA 

I, LYNDON A. VERSOZA, being duly ~W:!!O!!_!rjjffb'._Y~cl~~~~!!:t==~D:EP~U~T'._'.Y~_J 

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

in the KINGDOM OF THE NETHERLANDS and elsewhere there is now concealed a certain 

person or property' namely (describe the person or property to be sei,:ed) 

Any and all funds held in Knab Bank Account# NL15KNAB0255357664 

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

subject to seizure and forfeiture underl8 U.S.C. § 98l(a)(l)(A) and (C) 

concerning a violations of Title ...IB_ United States Code, Sections 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 

Isl 

Signature of Affiant 

Sworn to before me, and subscribed in my presence 

April 26 2018 Los Angeles, CA 

Date 

Hon. JOHN E. MCDERMOTT, U.S. Magistrate Judge 

Name and Title of Judicial Officer 

ft~Nw-t--_ 

,._, ... e----------.-. _, ..., ... "------------- ................ _,_, ... 

John Kucera:drb 

DOJ-BP-0004598397 

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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. 

DOJ-BP-0004598398 

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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-0004598399 

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II. Sill-1MARY AND PURPOSE OF AFFIDAVIT 

4. This affidavit is made in support of applications for 

warrants to seize all funds held in certain SUBJECT ACCOUNTS, 

all owned or controlled by "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 ("FBI") and the Internal Revenue 

Service-Criminal Investigation ("IRS-CI"), 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 

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, 

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, 

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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. 1 

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 

1 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. 

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. 

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DOJ-BP-0004598401 

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("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. 2 

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 

"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 

2 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-0004598402 

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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 

of 18 U.S.C. §§ 1591 and 1252. 

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 

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

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

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 

no. CR. Misc. 2:18-MJ-00711. 3 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 

3 The domain names seized pursuant to that warrant are referred to 

herein as the "seized domains." 

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DOJ-BP-0004598404 

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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. 

B. SUBJECT ACCOUNTS 

10. This affidavit is offered in support of applications 

for warrants to seize all funds and securities held in the 

following U.S. and foreign bank accounts 4 (hereinafter referred 

to collectively as the "SUBJECT ACCOUNTS"): 

a. SUBJECT ACCOUNT 16A: 5 Republic Bank of Arizona 

4 Pursuant to 18 U.S.C. § 981(b) (3), this Court has authority to 

issue a seizure order for foreign accounts ("Notwithstanding the 

provisions of Rule 41(a) of the Federal Rules of Criminal 

Procedure, a seizure warrant may be issued . in any district 

in which a forfeiture action may be filed . . and may be 

transmitted to the central authority of any foreign state for 

service with any treaty or other international agreement"). 

5 The numbering of the subject accounts picks up from prior 

warrant applications for different accounts, the contents of 

which have already been seized. 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; and 18-MJ-798. 

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account number 11402485 is a money market account held in the 

name of Lacey. 

b. SUBJECT ACCOUNT 16B: Republic Bank of Arizona 

account number 11101897 is a checking account held in the name 

of Lacey. 

c. SUBJECT ACCOUNT 16C: Republic Bank of Arizona 

account number 11003126 is an account held in the name of Lacey. 

d. SUBJECT ACCOUNT 16D: Republic Bank of Arizona 

account number 1021078316 is a Certificate of Deposit Account 

Registry Service ("CDARS") account held in the name of Lacey. 

e. SUBJECT ACCOUNT 16E: Republic Bank of Arizona 

account number 1021078324 is a CDARS account held in the name of 

Lacey. 

f. SUBJECT ACCOUNT 16F: Republic Bank of Arizona 

account number 1021078332 is a CDARS account held in the name of 

Lacey. 

g. SUBJECT ACCOUNT 16G: Republic Bank of Arizona 

account number 1021078103 is a CDARS account held in the name of 

Larkin. 

h. SUBJECT ACCOUNT 16H: Republic Bank of Arizona 

account number 1021078162 is a CDARS account held in the name of 

Larkin. 

i. SUBJECT ACCOUNT 16I: Republic Bank of Arizona 

account number 1021078189 is a CDARS account held in the name of 

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Larkin. 

j. SUBJECT ACCOUNT 17: K&H Bank, located in Hungary, 

account number HU63104010935052676785761210, is an account held 

in the name of Primus Trust Company (Binghampton Trust) for the 

benefit of Lacey. 

k. SUBJECT ACCOUNT 18A: Fio Bank, located in the 

Czech Republic, account number CZ9020100000002300995803, is an 

account held in the name of Ad Tech BV, with Ferrer as the 

ultimate beneficial owner. 

1. SUBJECT ACCOUNT 18B: Fio Bank, in the Czech 

Republic, account number CZ1220100000002000995801, is an account 

held in the name of Ad Tech BV, with Ferrer as the ultimate 

beneficial owner. 

m. SUBJECT ACCOUNT 18C: Fio Bank, in the Czech 

Republic, account number CZ7120100000002600995805, is an account 

held in the name of Ad Tech BV, with Ferrer as the ultimate 

beneficial owner. 

n. SUBJECT ACCOUNT 18D: Fio Bank, in the Czech 

Republic, account number CZ7020100000002001002226, is an account 

held in the name of Gold Leaf SRO. All funds and securities in 

this account are held for Backpage.com by a third party, Gold 

Leaf SRO. 

o. SUBJECT ACCOUNT 18E: Fio Bank, in the Czech 

Republic, account number CZ7620100000002101002231, is an account 

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held in the name of Gold Leaf SRO. All funds and securities in 

this account are held for Backpage.com by a third party, Gold 

Leaf SRO. 

p. SUBJECT ACCOUNT 18F: Fio Bank, in the Czech 

Republic, account number CZ8520100000002501002230, is an account 

held in the name of Gold Leaf SRO. All funds and securities in 

this account are held for Backpage.com by a third party, Gold 

Leaf SRO. 

q. SUBJECT ACCOUNT 18G: Fio Bank, in the Czech 

Republic, account number CZ4620100000002000914194, is an account 

held in the name of Protecctio SRO. All funds and securities in 

this account are held for Backpage.com by a third party, 

Protecctio SRO. 

r. SUBJECT ACCOUNT 18H: Fio Bank, in the Czech 

Republic, account number CZ2720100000002300914196, is an account 

held in the name of Protecctio SRO. All funds and securities in 

this account are held for Backpage.com by a third party, 

Protecctio SRO. 

s. SUBJECT ACCOUNT 18I: Fio Bank, in the Czech 

Republic, account number CZ0820100000002600914198, is an account 

held in the name of Protecctio SRO. All funds and securities in 

this account are held for Backpage.com by a third party, 

Protecctio SRO. 

t. SUBJECT ACCOUNT 18J: Fio Bank, in the Czech 

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Republic, account number CZ4820100000002801118083, is an account 

held in the name of Varicok Company SRO. All funds and 

securities in this account are held for Backpage.com by a third 

party, Varicok Company SRO. 

u. SUBJECT ACCOUNT 18K: Fio Bank, in the Czech 

Republic, account number CZ2020100000002701118086, is an account 

held in the name of Varicok Company SRO. All funds and 

securities in this account are held for Backpage.com by a third 

party, Varicok Company SRO. 

v. SUBJECT ACCOUNT 18L: Fio Bank, in the Czech 

Republic, account number CZ7620100000002901118080, is an account 

held in the name of Varicok Company SRO. All funds and 

securities in this account are held for Backpage.com by a third 

party, Varicok Company SRO. 

w. SUBJECT ACCOUNT 19A: Bank Frick, located in 

Liechtenstein, account number LI09 0881 1060 7717 K000 K, is an 

account held in the name of Ad Tech BV, and Ferrer is the 

ultimate beneficial owner. 

x. SUBJECT ACCOUNT 19B: Bank Frick, in 

Liechtenstein, account number LI30 0881 1060 7717 K000 U, is an 

account held in the name of Ad Tech BV, and Ferrer is the 

ultimate beneficial owner. 

y. SUBJECT ACCOUNT 19C: Bank Frick, in 

Liechtenstein, account number LI74 0881 1060 7717 K000 E, is an 

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account held in the name of Ad Tech BV, and Ferrer is the 

ultimate beneficial owner. 

z. SUBJECT ACCOUNT 19D: Bank Frick, in 

Liechtenstein, account number LI90 0881 1060 7717 K00l E, is an 

account held in the name of Ad Tech BV, and Ferrer is the 

ultimate beneficial owner. 

aa. SUBJECT ACCOUNT 20: Knab Bank, located in the 

Netherlands, account number NL15KNAB0255357664, is an account 

held in the name of Procop Services BV. All funds and 

securities in this account are held for Backpage.com by Procop 

Services BV. 

bb. SUBJECT ACCOUNT 21A: Rabo Bank, in the 

Netherlands, account number NL44RABO0307182452, is an account 

held in the name of Gulietta Group BV. All funds and securities 

in this account are held for Backpage.com by Guilietta Group BV. 

cc. SUBJECT ACCOUNT 21B: Rabo Bank, in the 

Netherlands, account number NL64RABO0307604721, is an account 

held in the name of UniversAds BV. All funds and securities in 

this account are held for Backpage.com by UniversAds BV. 

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: 

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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. 

12. 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 

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

more parties agreeing to accomplish the unlawful purpose of 

money laundering. 

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13. 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. 

14. 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). 

15. 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 

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. 

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DOJ-BP-0004598412 

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

Cal. Penal Code§ 647(b) .) 

16. 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 

17. 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. 

18. Bitcoin is a type of digital currency accepted by 

Backpage. Bitcoin payments are recorded on a public ledger that 

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

maintained by a single administrator or entity. Individuals can 

acquire Bitcoins either by "mining" them or purchasing Bitcoins 

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from other individuals. An individual can "mine" Bitcoins 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 Bitcoins. Bitcoins can be 

bought and sold in fractions. 

19. Backpage also accepts other digital currencies, 

including Litecoin, Bitcoin Cash, and Ether. Sometimes called 

"alt-coins," because they are alternatives to Bitcoins, 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. 

20. An individual can send and receive Bitcoins 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. 

21. 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 

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. 

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22. 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 

A. Buying a Backpage Ad 

23. 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 

(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 

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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 

associated with Posting Solutions and SUBJECT ACCOUNT 1) . 6 

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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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. 

24. Digital Currency is processed through the subject 

accounts in the following way: 

a. When Backpage receives digital currency, it will 

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

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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b. In exchange for the digital currency, the exchanger 

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

Backpage operating accounts, such as SUBJECT ACCOUNT 1. The 

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

Bitcoin markets. 

25. 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 

approximately $184,479 in revenue. 

B. Backpage Promotion of Prostitution and Sex Trafficking 

26. 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: 

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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 Asain 

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. 

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 

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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 a Backpage that contained 

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 

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 

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of having seizures, and gang-raped her. 8 

27. 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 

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 

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 28(a) and (b)) 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 28(c)) prosecuted in Missouri, the 

bitcoin payments were made in October and November 2015. As 

described in paragraph 48 of this 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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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 

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 

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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 

gained through this investigation, I do not believe that Backpage 

has ever instituted an in-person age verification. 

28. 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 

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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 

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 

9 Craigslist is a competing internet based advertising company 

that features classified ads. 

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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 

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." 

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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 

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 

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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 

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

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

29. 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 

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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 

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 

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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. 

30. 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 

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 

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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 

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. 

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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 

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. 

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

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

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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, 

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 

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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. 

32. 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 

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prospective prostitution clients. 

33. On March 28, 2018, a grand jury returned a 93 count 

indictment charging certain Backpage Operators with 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 

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). A copy of that indictment is 

attached hereto (as Exhibit A) and incorporated herein as though 

fully set forth. 

C. THE SEIZED ACCOUNTS AND SUBJECT ACCOUNTS.!:.Q 

1. Seized Account 1 

i. Foreign Transfers Into SEIZED ACCOUNT 1 

34. While Backpage accepts payments for ads from thirdparties, for the purpose of this affidavit, I will focus on 

advertising payments made via the Posting Solutions' P.O. BOX 

using cash, money orders, or digital currency. 

35. From my review of Posting Solutions' application for the 

USPS Dallas, Texas P.O. BOX, I learned that it was registered to 

10 Because of the extensive movement of money by the Backpage 

operators, it is necessary to include here a discussion ofboth the 

accounts targeted in the prior warrant applications (referred to 

herein as Seized Accounts 1 through 15G, and the SUBJECT ACCOUNTS. 

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"Website Technologies, LLC/Backpage.com." Also listed on the P.O. 

BOX Application were the names of several Backpage Operators, 

including Ferrer. 

36. I have reviewed bank records for Seized Account 1.

Based on my review, I know the following: 

a. On February 15, 2017, Posting Solutions LLC,

located at 13601 Preston Rd., Ste. 801E, Dallas, Texas 75240, 

opened Prosperity Bank account number 216887188 (Seized Account 

1, which lists Gage as the sole signatory on the account). 

b. Gage is the President, Chief Executive Officer,

Treasurer and Secretary of Posting Solutions LLC. 

37. Based on my knowledge of this investigation, having

spoken to law enforcement personnel, and my review of the 

financial records, when an advertiser purchases an ad for 

prostitution using digital currency, the payments to Backpage (and 

certain subsequent expenditures) then proceed in the following 

manner: 

a. A "poster" of a prostitution ad on backpage.com

would pick a payment method, for example, through Bitcoin payments 

as previously described above. 

b. The poster would already have Bitcoin or Backpage

would direct the poster to a third-party exchanger in order to buy 

Bitcoin. 

c. Backpage would then provide the poster with a

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wallet address to send the specific amount of Bitcoin. 

d. The poster would receive credit to then post ads on 

Backpage. 

e. In batches, generally valued in hundreds of 

thousands of dollars, Backpage would sell the Bitcoin to a third 

party exchanger, frequently "GoCoin," in order to convert the 

Bitcoin into U.S. or foreign currency, which GoCoin generally 

holds in foreign bank accounts. 

f. GoCoin would wire funds from these foreign accounts 

to either 1) Backpage controlled foreign accounts, or 2) Backpage 

controlled domestic operating accounts. 

g. Backpage operators would hold these receiving 

accounts in the names of entities controlled by Backpage, such as 

Ad Tech BV, Posting Solutions (Seized Account 1 is held in the 

name of Posting Solutions), Website Technologies, or Cereus 

Properties (Seized Account 2A is held in the name of Cereus 

Properties) 

h. These funds that originated from foreign 

transactions would be used to pay for services, like Verizon in 

Los Angeles, or would be transferred to Backpage Operators' 

accounts and accounts held in their family members' names. 

38. I have reviewed records of wire transfers from countries 

outside the United States deposited into the Seized Account 1. 

Just for the period of August 1 through September 1, 2017, Seized 

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Account 1 received over $2.7 million in wire transfers from 

outside the United States. For example: 

a. On or about August 16, 2017, a company called 

"Binary Trading SG PTE LTD" ("Binary Trading") wired $535,500 from 

an account in Singapore into Seized Account 1. Based on my review 

of records related to this transaction, Binary Trading is a name 

used by GoCoin. 11 

b. On or about August 17, 2017, Binary Trading wired 

another $528,500 from a Singapore account into Seized Account 1. 

c. On or about August 30, 2017, a company named 

"TRILIX PTE LTD," listing the same Singapore address as Binary 

Trading and GoCoin, in four wires ranging from $385,450 to 

$492,250, sent approximately $1,717,750 from a Singapore account 

into Seized Account 1. Memo lines from these wires list "GC" or 

"GC FOR INTERNET SERVICES." I understand "GC" to mean GoCoin. 

ii. Seized Account 1 Payments for Backpage Operations 

39. I have reviewed outgoing payments from Seized Account 1 

and found that substantial percentages of these payments are for 

the operation of Backpage.com. For example, between July and 

October, 2017, Seized Account 1 wired over $1.1 million to pay for 

the following: 

11 Further, according to GoCoin's website, GoCoin maintains 

offices at the Singapore address listed on the $535,500 wire 

from "Binary Trading." 

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a. Between July and October 2017, Seized Account 1 

wired $570,530 to Verizon Digital Media Services in Los Angeles. 

b. On August 4, 2017, Seized Account 1 wired $4,137 to 

"Netnames," also known as ASCIO, to pay for the registration 

renewal of all the Seized Domains, including Backpage.com. 

c. In August 2017, Seized Account 1 sent numerous 

automated clearinghouse payments to "Netchex Tax Prep Clients" 

totaling over $437,000. From a review of their website, I learned 

Netchex is a human resources company that provides payroll and 

other such services to Backpage. 

d. Within a one-week period beginning on August 2, 

2017, Seized Account 1 wired approximately $77,800 to S&W Payroll 

Services. An online search of S&W Payroll indicated that S&W 

Payroll is owned by Netchex. As stated above, Netchex is a human 

resource service, and S&W Payroll appears to be Netchex's payroll 

division. 

e. On August 11, 2017, Seized Account 1 wired 

$5,319.79 to the Telesign Corporation, located in Marina del Ray, 

California. According to their website, Telesign is a 

communications platform that delivers security for websites. 

f. On August 18, 2017, Seized Account 1 wired $1,497 

and $6,984, respectively, to two separate data backup companies 

for Backpage's on-line data backup. 

40. Based on my review of bank records for Seized Account 1 

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throughout the existence of the account, these types of 

transactions and expenditures were typical. 

2. Seized Account 2A 

i. Transfers From Seized Account 1 

41. From my review of bank documents, I have learned that 

Seized Account 2A is a Compass Bank business bank account owned 

by "Cereus Properties LLC," identifying Spear as the sole 

signatory. My review revealed that this account was funded with 

transfers from Seized Account 1. On average, during each month 

of 2017, Seized Account 1 transferred several hundred thousand 

dollars into Seized Account 2A. For example: 

a. On July 25, 2017, Seized Account 1 sent two wire 

transfers totaling about $566,562.47 to Seized Account 2A. 

b. On August 8, 2017, Seized Account 1 sent a wire 

totaling $62,198.51 to Seized Account 2A. 

c. On August 31, 2017, Seized Account 1 sent a wire 

transfer totaling $487,491.45 to SU Seized Account 2A. 

d. On September 15, 2017, Seized Account 1 sent a wire 

transfer totaling $91,672.67 to Seized Account 2A. 

e. On October 2, 2017, Seized Account 1 sent a wire 

transfer totaling $471,766 to Seized Account 2A. 

ii. Foreign Transfers into Seized Account 2A 

42. I have reviewed financial records from a foreign bank 

in the Netherlands (the "Foreign Account") I have also 

- 42 -

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reviewed emails related to this account. From my review of 

these records, I learned the following: 

a. The Foreign Account was opened in March 2015 and 

is held in the name of Ad Tech BV, a Netherlands based company, 

and identifies Ferrer as the CEO and Gage as the CFO. 

b. From March 2015 through November 2017, the 

Foreign Account received millions of dollars from Binary Trading 

SG PTE, Limited, the same company GoCoin used to wire funds into 

Seized Account 1. In an April 4, 2017, email to employees of 

the bank that maintains the Foreign Account, Gage explained, 

Binary Capital is our trading partner, they hold money in 

trust for Go Coin [sic]. Rather than incurring 3 sets of 

wire fees which make our transactions unprofitable, they 

act as our agent and disburse payments directly from our 

trust account to our merchant. 

c. During this same period, the Foreign Account wire 

transferred several million dollars into Seized Account 2A. For 

example, an April 25, 2017, an email from Gage to individuals at 

the bank holding the Foreign Account directed the bank to wire 

"USD $2,337,048" to Seized Account 2A. Thereafter, I reviewed a 

wire record and confirmed that on April 25, 2017, the Foreign 

Account wired $2,337,048 into Seized Account 2A, as Gage 

directed in his email. In reviewing the records, I found the 

following additional wires sent to Seized Account 2A: 

i. In December 2016, the Foreign Account wired 

approximately $1 million dollars to Seized Account 2A. 

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ii. On February 28, 2017, the Foreign Account 

wired $2,324,390 into Seized Account 2A. 

iii. On March 30, 2017, the Foreign Account wired 

$2,247,858 into Seized Account 2A. 

iv. On May 31, 2017, the Foreign Account wired 

$2,335,076 to SUBJECT ACCOUNT 2A. 

v. On June 28, 2017, the Foreign Account wired 

$2,324,390 to Seized Account 2A. 

vi. July 27, 2017, the Foreign Account wired 

$10,928 to Seized Account 2A. 

iii. Seized Account 2A Payments for Backpage Operations 

43. I then reviewed Seized Account 2A records for payments 

to promote Backpage operations. From March through December 

2017, Seized Account 2A paid over $9,000 to "Cox 

Communications," an internet services company that provides 

voice-over-internet phone and cable services. I believe that 

Backpage uses Cox Communications to facilitate its internet 

presence and promote its sale of prostitution advertising. 

3. Seized Account 2B 

44. I reviewed records Seized Account 2A and Seized 

Account 2B. On February 2, 2018, Seized Account 2A wired 

transferred $135,956.59 into Seized Account 2B. I am aware of 

no other funding sources for Seized Account 2B. 

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4. Seized Account 3A, 3B, 3C 

45. I have reviewed records for Seized Account 3A 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 

("BBT Account"); Arizona Bank & Trust account number 9361116211 

belonging to Cereus Properties, held in Arizona ("AZBT 

Account") From this review, I learned the following: 

a. Between December 14, 2015, and January 15, 2016, 

in approximately 26 wires, a GoCoin account in Slovakia 

transferred over $2.5 million to the BBT Account in the United 

States. 

b. On January 15, 2016, the BBT account wired 

$189,571 to Verizon in Los Angeles, California, in payment for 

Backpage internet services. 

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

approximately 27 wires, the BBT Account transferred 

approximately $48 million to the AZBT Account. 

d. Between March 1, 2016, and July 1, 2016, the AZBT 

Account wired $892,426 into Seized Account 3A. 

46. According to records for Seized Account 3A, 3B, and 

3C: 

a. On September 14, 2017, Seized Account 2A wired 

$50,162.05 into Seized Account 3A. 

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b. On October 12, 2017, Seized Account 3A wired 

approximately $21,500 into SUBJ Seized Account 3B. 

c. On January 5, 2018, Seized Account 3A wired 

approximately $600,000 into Seized Account 3C. 

5. Seized Account 4 

47. From my review of the records for Seized Account 4 

(belonging to Spear), I learned that on or about March 16, 2016, 

Seized Account 3A transferred $250,000 into Seized Account 4 as 

an opening deposit. On March 20, 2018, Live Oak Bank confirmed 

that these funds have remained in Seized Account 4 since the 

account was opened. 

6. Seized Account 5A and 5B 

48. I have reviewed financial records related to Seized 

Accounts 5A and 5B, held in the name of Natasha Spear, Scott 

Spear's adult daughter. From this review, I learned the 

following: 

a. On February 23, 2017, Seized Account 3A wired 

approximately $50,000 into Seized Account 5A. 

b. On the February 23, 2017, Seized Account 3A wired 

$50,000 into Seized Account 5B. 

7. Seized Account 6 

49. From my review of financial records related to Seized 

Account 2A, 2B and 6, I learned the following: 

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a. On October 2, 2017, Seized Account 2A wired 

approximately $297,795 into Seized Account 6. 

l~ICHAEL Ll',CEV MlCHJ\EL LACEY 

51103620 SAFE DEPOSi:T BOX 

Flf!ST FEDERAL SA.',1NGS 

CEREUS PROPER::-ltS 

673845873 

COMPASS BANK 

(SUBJECT ACCOUNT 2) 

F[RST FEDERAL SJ\VlNGS 

& LON, OF SAN RAF.AEl 

(SUEUECT J\C COUNT 6) 

&. LOAN OF SA.N RAFAEL 

(SUtUECT SAFE DEPOSir BO:X 2) 

8. Seized Accounts 7A through 7E 

50. From my review of financial records of Seized Accounts 

2A and 2B, 7A through 7D, and 12A, I learned the following: 

a. On July 6, 2017, Seized Account 2A wired 

$971,651.51 into Seized Account 7A. 

b. On July 28, 2017, Seized Account 7A wired 

$400,000 into Seized Account 7B. 

51. From my review of financial records of Seized Account 

1 and 7C, and those concerning the Veritex Bank account ending 

in -1462, held in the name of Posting Solutions ("Account -

1462") , 12 I learned the following: 

12 Veritex Bank is a U.S. bank located in Dallas, Texas. 

Posting Solutions opened Veritex Bank account -1462 on or about 

January 5, 2017. 

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a. On January 13, 2017 and January 20, 2017, a GoCoin 

account in Singapore wired a total of approximately $1,318,800 

into Account -1462. 

b. In February 2017, Account -1462 wired a total of 

$5,395 to Verizon, in Los Angeles. 

c. On August 8, 2017, Seized Account 1 wired $62,000 into 

Seized Account 12A. 

d. On November 3, 2017, Seized Account 12A wired $100,000 

to SUBJE Seized Account 7D. 

9. Seized Account 8A, 8B, BC, and 8D 

52. From my review of the records for Seized Accounts 2A 

and 2B, 8A, and 8B, I learned the following: 

a. On February 2, 2018, Seized Account 2A wired 

$28,337 into Seized Account 8A. 

b. Also on February 2, 2018, Seized Account 2A wired 

$28,337 into Seized Account 8B. 

53. From my review of Seized Account 1, BC, and 8D, I 

learned the following: 

a. On August 2 and August 8, 2017, Seized Account 1 

wired $33,700 and $44,000, respectively, to S&W Payroll, a 

company Backpage uses to pay its employees. 

b. Between August 11, 2017, and December 1, 2017, 

S&W Payroll wired a total of $207,125.81 into Seized Account BC. 

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c. Between November 3, 2017, and December 8, 2017, 

Seized Account BC wired $57,500 into Seized Account 8D. 

10. Seized Account 9 

54. From my review of the records for Seized Account 2A 

2B, and 9, I learned that on February 2, 2018, Seized Account 2A 

wired $734,603.70 into Seized Account 9. 

11. Seized Account 10 

55. From my review of records for Seized Accounts 2A and 

10, I learned that on February 2, 2018, Seized Account 2A wired 

$94,154.89 into Seized Account 10. 

12. Seized Account 11 

56. From my review of Seized Accounts 1, BC, 8D, and 11, 

as well as Account -1462 (as described above, a Posting 

Solutions' Veritex Bank account), I learned the following: 

a. On January 4, 2017, GoCoin's Singapore account 

wired $489,500 into Account -1462, and on January 20, 2017, 

GoCoin's Singapore account directed two additional wires, for 

$358,150 and $470,150, respectively, into Account -1462 (for a 

total of $1,317,800 wired from GoCoin's Singapore account into 

Account -1462) 

b. On January 24, 2017, Account -1462 wired 

approximately $1.3 million into S&W Payroll. 

57. On January 27, 2017, an S&W Payroll account wired a 

total of $9,913.53 into Seized Account 11. 

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13. Seized Accounts 12A and 12B 

58. From my review of financial records for Seized Account 

1, 12A, and 12B, I learned the following: 

a. On August 8, 2017, Seized Account 1 wired $62,000 

into Seized Account 12A. 

59. On December 8, 2017, Seized Account 12A wired $20,000 

into Seized Account 12B. 

14. Seized Account 13 

60. From my review of financial records for Seized 

Accounts 1, 12A, and 13, I learned the following: 

a. In January 2017, eized Account 1 wired $62,000 

into Seized Account 12A. 

b. On August 16, 2017, Seized Account 12A wired 

$20,000 into Seized Account 13. 

15. Seized Account 14 

61. I have reviewed records for Seized Account 14 as well 

as the following accounts: the BBT Account; the AZBT Account; 

Charles Schwab account number 49074693 in the name of Larkin 

("Schwab Account"); Northern Trust Company account number 

2389562 under the name "Ocotillo Family Trust," belonging to 

James Larkin" ("Northern Trust Account"); and Morgan Stanley 

account number 237-061673 belonging to James Larkin and his 

wife, Margaret Larkin (the "Morgan Stanley Account"). 

Additionally, I have reviewed GoCoin transactions related to 

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certain ads posted on Backpage, specifically including ads that 

related to child victims A.C., S.F., T.S., S.L., K.O., and R.W. 

(previously described in paragraph 26, above) . 13 Finally, I 

reviewed emails associated with the email addresses used to post 

some of the ads promoting the trafficking of A.C., S.F., T.S., 

S.L., K.O., and R.W. From this review I observed the following: 

a. On September 6, 2015, a bitcoin account 

associated with the owner of the email address who trafficked 

A.C. and S.F. paid Backpage about $4 worth of bitcoin in order 

to post an ad promoting the trafficking of those victims in Palm 

Springs, California. 

b. On September 15, 2015, an email from the same 

email address owner indicated a payment to Backpage of about $8 

worth of bitcoin in order to "Fund Account" for 

palmsprings.backpage.com. Based on information I have learned 

through this investigation, I believe that to "Fund Account" 

means that the email address owner provided bitcoin to Backpage 

as payment for credit to be used at a later time to pay for 

Backpage ads. 

13 As previously described, the pimp who trafficked A.C. and 

S.F. was convicted and sentenced to 196 years imprisonment, and 

the pimp who trafficked T.S., S.L., K.O., and R.W. was convicted 

and sentenced to 300 months imprisonment. 

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c. On October 6, 2015, the same email address owner 

paid Backpage about $1 worth of bitcoin to "Fund Account" on 

palmsprings.backpage.com. 

d. On October 30, 2015, a bitcoin account associated 

with the owner of the email address who trafficked T.S., S.L., 

K.O., and R.W. paid Backpage about $1 worth of bitcoin in order 

to post an ad promoting the trafficking of those victims in 

Columbus, Ohio. 

e. On November 2, 2015, this same email address 

owner paid Backpage about $1 worth of bitcoin to "Move Ad to Top 

of Listings" in the Columbus, Ohio Backpage ads. 

f. On November 21, 2015, this same email address 

owner paid Backpage about $1 worth of bitcoin to Backpage for 

credit for that email owner's Backpage ad account. 

g. During the period of September 4, 2015, and 

November 23, 2015, Backpage advertisers used bitcoin to purchase 

about 1,000,000 "adult" ads from Backpage. Backpage then sold 

that bitcoin to GoCoin for approximately $8.6 million. Included 

among the bitcoin sold to GoCoin during this period were the six 

payments the pimps made to Backpage to purchase ads to promote 

child prostitution. 

h. During the period of December 14, 2015, through 

December 29, 2015, a GoCoin account held in Slovakia wired over 

$1.25 million to the BBT Account in the United States. Based on 

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my review of GoCoin's financial records and GoCoin's pattern of 

payments to Backpage for bitcoin sales, I believe that this 

$1.25 million represented GoCoin's partial payment to Backpage 

for the bitcoin Backpage sold to GoCoin during the period of 

September 4, 2015, through November 23, 2015. 

i. On December 31, 2015, the BBT Account wired 

$811,424 to the AZBT Account. 

j. On January 11, 2016 the AZBT Account wired 

approximately $1.3 million to the Schwab Account. 

k. On January 14, 2016, the Schwab Account wired 

approximately $13.5 million to the Northern Trust Account. 

1. In July 21, 2017, the Northern Trust Account 

wired $6.014 million to the Morgan Stanley Account. 

m. In or about November 2017, Morgan Stanley elected 

to terminate its business relationship with Larkin. 

n. Following this, on November 30, 2017, Larkin 

wired all the funds then held the Morgan Stanley Account, about 

$10 million dollars, to Seized Account 14. 

o. Some of the funds in Seized Account 14 were used, 

among other things, to purchase bonds and/or securities, which 

assets remain held in Seized Account 14. 

16. Seized Accounts 15A through 15G 

62. I have reviewed records for Seized Account 15 as well 

as the following accounts: the BBT; the AZBT Account; Wells 

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Fargo Bank Account number 6324184891, belonging to John Brunst 

("WFB Account -891"); and Wells Fargo Bank Account number 

00007910147474, belonging to the Brunst Family Trust ("WFB 

Account -474"). Additionally, I have reviewed GoCoin 

transactions related to certain ads posted on Backpage, 

specifically including ads that related to child victims A.C., 

S.F., T.S., S.L., K.O., and R.W. (previously described in 

paragraph 26, above.) Finally, I reviewed emails associated 

with the email addresses used to post some of the ads promoting 

the trafficking of A.C., S.F., T.S., S.L., K.O., and R.W. From 

this review I observed the following: 

a. On September 6, 2015, a bitcoin account 

associated with the owner of the email address who trafficked 

A.C. and S.F. paid Backpage about $4 worth of bitcoin in order 

to post an ad promoting the trafficking of those victims in Palm 

Springs, California. 

b. On September 15, 2015, an email from the same 

email address owner indicated a payment to Backpage of about $8 

worth of bitcoin in order to "Fund Account" for 

palmsprings.backpage.com. Based on information I have learned 

through this investigation, I believe that to "Fund Account" 

means that the email address owner provided bitcoin to Backpage 

as payment for credit to be used at a later time to pay for 

Backpage ads. 

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c. On October 6, 2015, the same email address owner 

paid Backpage about $1 worth of bitcoin to "Fund Account" on 

palmsprings.backpage.com. 

d. On October 30, 2015, a bitcoin account associated 

with the owner of the email address who trafficked T.S., S.L., 

K.O., and R.W. paid Backpage about $1 worth of bitcoin in order 

to post an ad promoting the trafficking of those victims in 

Columbus, Ohio. 

e. On November 2, 2015, this same email address 

owner paid Backpage about $1 worth of bitcoin to "Move Ad to Top 

of Listings" in the Columbus, Ohio Backpage ads. 

f. On November 21, 2015, this same email address 

owner paid Backpage about $1 worth of bitcoin to Backpage for 

credit for that email owner's Backpage ad account. 

g. During the period of September 4, 2015, and 

November 23, 2015, Backpage advertisers used bitcoin to purchase 

about 1,000,000 "adult" ads from Backpage. Backpage then sold 

that bitcoin to GoCoin for approximately $8.6 million. Included 

among the bitcoin sold to GoCoin during this period were the six 

payments the pimps made to Backpage to purchase ads to promote 

child prostitution. 

h. During the period of December 14, 2015, through 

December 29, 2015, a GoCoin account held in Slovakia wired over 

$1.25 million to the BBT Account in the United States. Based on 

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my review of GoCoin's financial records and GoCoin's pattern of 

payments to Backpage for bitcoin sales, I believe that this 

$1.25 million represented GoCoin's partial payment to Backpage 

for the bitcoin Backpage sold to GoCoin during the period of 

September 4, 2015, through November 23, 2015. 

i. On December 31, 2015, the BBT Account wired 

$811,424 to the AZBT Account. 

j. On December 6, 2016 the AZBT Account wired 

$161,459 to the WFB Account -891. 

k. On January 4, 2017, the AZBT Account wired 

another $258,841 to the WFB Account -891. 

1. On January 5, 2017, the WFB Account transferred 

$300,000 to WFB Account -474. 

m. On May 19, 2017 the WFB Account -474 wired about 

$1.5 million into Seized Account 15A. 

n. On May 23, 2017 Seized Account 15A transferred 

about $350,000 to Seized Account 15B. 

o. On June 7, 2017, Seized Account 15A transferred 

about $1.34 million to Seized Account 15C. 

p. On September 13, 2017, Seized Account 15C 

transferred about $581,000 to Seized Account 15D. 

q. On September 13, 2017, Seized Account 15C 

transferred about $250,000 to Seized Account 15E. 

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r. On September 13, 2017, Seized Account 15C 

transferred about $250,000 to Seized Account 15F. 

s. On September 15, 2017, Seized Account 15C 

transferred about $500,000 to Seized Account 15G. 

17. SUBJECT ACCOUNTS 16A, 16B, 16C, 16D, 16E, 16F, 16G, 

16H, and 16I 

63. From my review of financial records related to Seized 

Accounts 2A, 6, 7B, and 9, and Subject Accounts 16A, 16B, 16C, 

16D, 16E, 16F, 16G, 16H, and 16I, I learned the following: 

a. On June 8, 2017, Seized Account 2A wired 

approximately $297,795 into SUBJECT ACCOUNT 16A. 

b. On June 30, 2017 SUBJECT ACCOUNT 16A transferred 

$600,000 to SUBJECT ACCOUNT 16B. 

c. On April 16, 2018, Lacey personally went into the 

Republic Bank of Arizona, withdrew $500,000 from SUBJECT ACCOUNT 

16A and opened SUBJECT ACCOUNT 16C with an initial deposit of 

the $500,000 he had just withdrawn from SUBJECT ACCOUNT 16A. 

d. On or about February 15, 2018, Lacey drafted two 

checks totaling $1.2 million, which he used to fund his "CDARS" 

accounts at Republic Bank of Arizona. The first check was drawn 

from Seized Account 6 in the amount of $600,000 and deposited 

into SUBJECT ACCOUNT 16D. The second check also was drawn from 

Seized Account 9, also in the amount of $600,000, but was split 

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evenly into SUBJECT ACCOUNTS 16E (which received $300,000) and 

16F (which received $300,000). 

e. On or about February 8, 2018, Larkin drafted a $1 

million check drawn from Seized Account 7B and made payable to 

Republic Bank of Arizona in order to fund his "CDARS" accounts 

at that bank. SUBJECT ACCOUNT 16G received $500,000, SUBJECT 

ACCOUNT 16H received $250,000, and SUBJECT ACCOUNT 16I received 

$250,000. 

18. SUBJECT ACCOUNT 1 7 

64. I have reviewed records for SUBJECT ACCOUNT 17 as well 

as the following accounts: the BBT Account; the AZBT Account; 

Arizona Bank & Trust annuity trust account numbers 9361121967, 

9361121972, 9361121986, 9361121991, and 9361122014, all held in 

Lacey's name ("AZBT Annuity Accounts"); and Johnson Financial 

account number 1000879992 held in an IOLTA with Lacey as the 

sole beneficiary. From this review, I learned the following: 

a. Between December 14, 2015, and January 15, 2016, 

in approximately 26 wires, a GoCoin account in Slovakia 

transferred over $2.5 million to the BBT Account in the United 

States. 

b. On January 15, 2016, the BBT account wired 

$189,571 to Verizon in Los Angeles, California, in payment for 

Backpage internet services. 

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

approximately 27 wires, the BBT Account transferred 

approximately $48 million to the AZBT Account. 

d. Between April 1, 2016, through October 6, 2016, 

in approximately 12 transactions, the AZBT Account transferred 

over $18 million to the AZBT Annuity Trust Accounts. 

e. On December 29, 2016, Lacey's AZBT Annuity Trusts 

Accounts sent five wires totaling $16.5 million to the Johnson 

Financial Bank Account. 

f. On January 3, 2017, the Johnson Financial Account 

wired the $16.5 million to the SUBJECT ACCOUNT 17 in Hungary. 

19. SUBJECT ACCOUNTS 18A, 18B, 18C, 18D, 18E, 18F, 18G, 

18H, 18J, 18K, and 18L 

65. 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 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 

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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) . 

66. On April 17 and April 18, 2018, along with other law 

enforcement agents and prosecutors, I spoke with Ferrer and his 

attorneys in Phoenix, Arizona. Following this in-person 

interview, I also have spoken with Ferrer on the phone and 

communicated via email. From my review of Service Level 

Agreements, financial records related to SUBJECT ACCOUNTS 18, 

and records and statements provided by Ferrer, I know the 

following: 

a. SUBJECT ACCOUNTS 18A, 18B, 18C are accounts owned 

by Ad Tech BV and controlled by Backpage. According to Ferrer, 

all funds in this account are the criminally derived proceeds of 

ads promoting prostitution. According to Ferrer, SUBJECT 

ACCOUNTS 18A, 18B, and 18C are accounts receivable bank 

accounts. Payment processors and merchant processors would take 

credit card payments, and payments such as bitcoin payments from 

Backpage customers for prostitution and other ads, and would 

transfer these funds to accounts such as SUBJECT ACCOUNTS 18A, 

18B and 18C. Per his plea agreement and his cooperation, Ferrer 

has agreed to surrender these funds and/or securities to the 

United States. 

b. SUBJECT ACCOUNTS 18D, 18E, and 18F are accounts 

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held by a third party, Gold Leaf SRO. According to Ferrer and 

Service Level Agreements ("SLA") between Ad Tech BV, a Backpage 

owned company and Gold Leaf SRO, which I have reviewed, the 

funds and/or securities in these accounts are the criminally 

derived proceeds of Backpage ads, including ads promoting 

prostitution. The SLAs state that 99.5% of the net proceeds are 

to be paid to Ad Tech BV, which is owned by Backpage. According 

to Ferrer, the arrangement between Gold Leaf, SRO, and Backpage 

was put into place to evade what he called a "blockade by credit 

card companies." Ferrer explained that beginning around 2015, 

U.S. credit card companies such as MasterCard and Visa refused 

to process credit card payments for Backpage due to the negative 

press surrounding sex trafficking and prostitution content on 

Backpage. As one of the ways around this "blockade," Backpage 

Operators set up agreements with foreign persons and partners to 

"franchise" websites for the sole purpose of accepting credit 

card payments. According to Ferrer, this use of foreign thirdparties and foreign accounts allowed Backpage to continue to 

accept credit card payments for prostitution ads while 

concealing from the credit card companies that the payments were 

for Backpage ads. Ferrer said that Gold Leaf SRO existed for 

the sole purpose of funneling to Backpage accounts otherwise 

prohibited credit card payments for Backpage ads. Ferrer 

explained that these accounts are owned by Backpage and are not 

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co-mingled with other funds, and are therefore subject to 

seizure and forfeiture to the United States. 

c. SUBJECT ACCOUNTS 18G, 18H, and 18I are accounts 

held by a third party, Protecttio SRO. According to Ferrer and 

an agreement between Protecttio SRO and Ad Tech BV, which I have 

reviewed, the arrangements between these entities are 

essentially the same as the Gold Leaf SRO arrangement. This 

business arrangement existed for the sole purpose of allowing 

purchasers of prostitution ads to purchase ads on Backpage 

websites while evading the credit card company blockade. Ferrer 

explained that these accounts are owned by Backpage and are not 

co-mingled with other funds and/or securities, and are therefore 

subject to seizure and forfeiture to the United States. 

d. SUBJECT ACCOUNTS 18J, 18K, 18L are accounts held 

by a third party, Varicok SRO. According to Ferrer and an 

agreement between Varicok SRO and Ad Tech BV, which I have 

reviewed, the arrangement is essentially the same as the Gold 

Leaf SRO, and Protecttio SRO. This business arrangement existed 

for the sole purpose of allowing purchasers of prostitution ads 

to purchase ads on Backpage websites while evading the credit 

card company blockade. Ferrer explained that these accounts are 

owned by Backpage and are not co-mingled with other funds and/or 

securities, and are therefore subject to seizure and forfeiture 

to the United States. 

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20. SUBJECT ACCOUNTS 19A, 19B, 19C, and 19D 

67. From speaking with Ferrer and reviewing financial 

records, I learned the following: 

a. SUBJECT ACCOUNTS 19A, 19B, 19C, and 19D, are 

owned by Ad Tech BV, with Ferrer as the ultimate beneficial 

owner. According to Ferrer, SUBJECT ACCOUNTS 19A, 19B, 19C and 

19D are accounts receivable banking accounts. Payment 

processors and merchant processors would take credit card 

payments, and payments such as bitcoin payments from Backpage 

customers for prostitution and other ads, and would transfer 

these funds to accounts such as SUBJECT ACCOUNTS 19A, 19B, 19C, 

and 19D. These accounts contain funds and/or securities that 

are criminally derived and are subject to forfeiture. Ferrer 

and Backpage has agreed to surrender these funds and/or 

securities as they are criminally derived. 

21. SUBJECT ACCOUNT 2 0 

68. From speaking with Ferrer and reviewing financial 

records, I learned the following: 

a. SUBJECT ACCOUNT 20 at Knab Bank in the 

Netherlands is an account held by a third party, Procop Services 

BV. According to Ferrer the arrangement is essentially the same 

as the Gold Leaf SRO and Protecttio SRO, as described with 

respect to SUBJECT ACCOUNTS 19. This business arrangement 

existed for the sole purpose of allowing purchasers of 

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prostitution ads to purchase ads on Backpage websites while 

evading the credit card company blockade. Ferrer explained that 

these accounts are owned by Backpage and are not co-mingled with 

other funds and/or securities, and are therefore subject to 

seizure and forfeiture to the United States. 

22. SUBJECT ACCOUNT 21A and 22B 

69. From speaking with Ferrer and reviewing financial 

records and business agreements, I learned the following: 

a. SUBJECT ACCOUNT 21A is an account in the 

Netherlands held in the name of Gulietta Group BV. According to 

Ferrer and the SLA, the funds and/or securities in this account 

are derived from selling advertisements online, most of which 

are for prostitution advertisements. The SLAs state that 99.5% 

of the net proceeds are to be paid to Ad Tech BV which is owned 

by Backpage. According to Ferrer, the arrangement between 

Guilietta Group BV and Ad Tech BV (Backpage) was put into place 

to evade the same credit card "blockade" described in with 

regard to SUBJECT ACCOUNTS 18D, 18E, and 18F. Ferrer explained 

that these accounts are owned by Backpage and are not co-mingled 

with other funds and/or securities, and are therefore subject to 

seizure and forfeiture to the United States. 

b. SUBJECT ACCOUNT 21B is an account in the 

Netherlands held in the name of UnivsersAds BV. According to 

Ferrer and the SLA between the companies, the funds and/or 

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securities in this account are derived from selling 

advertisements online, most of which are for prostitution 

advertisements. The Service Level Agreements state that 99.5% 

of the net proceeds are to be paid to Ad Tech BV which is owned 

by Backpage. According to Ferrer, the arrangement between 

UniversAds BV and Ad Tech BV or Backpage was put into place to 

evade the same credit card blockade described above. Ferrer 

explained that these accounts are owned by Backpage and are not 

co-mingled with other funds and/or securities, and are therefore 

subject to seizure and forfeiture to the United States. 

VI. CONCLUSION 

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

to believe that the 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 in each of the SUBJECT ACCOUNTS 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); and 

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

and/or securities in the SUBJECT ACCOUNTS constitute and are 

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derived from proceeds traceable to one or more violations of 18 

U.S.C. § 1952, and 18 U.S.C. § 1591). 

Isl 

Lyndon Versoza 

U.S. Postal Inspector 

Subscribed to and sworn to me 

t~his 26~-~pr~~-

~ c__ il\o \J 

v e 

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128 Page ID #:208 

Filed 04/26/18-1:?il'Q~ 

HECEMW COPY 

2 

3 

4 

s 

6 

7 

8 

9 

10 

11 

12 

13 

14 

!.5 

16 

]7 

18 

19 

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21 

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MAR 2 8 2018 

C!.e'.fiK U S Of$1'R!CT COURT 

OISTRIC OF AFUZONA 

SY M aePuTY 

SEALED 

IN THE UNITED STATES DISTRICT COURT 

FOR. THE DISTRICT OF i\RlZ()NA 

United States of America, 

Plaintiff~ 

V. 

l. tv1ichae1 Lacov 

Counts 1-70, 81, '83-84, 86, 88-92 

2. Jarncs Larkin 

Counts ]-681 80, 87 

3. Scott Spear 

Counts 1-68, 71-78, 85, 93 

4. John "Jed" Bnmsi 

Counts 52-70, 78-84, 86-93 

5. Dan Jlyer 

Counts 1-68 

6. Andrew Padilla 

Counts J-51 

7. Joye Vaught 

Counts 1-51 

Dcfe:ndants.. 

----···························································----< 

THE GRAND JURY CHAR.GES: 

A. Introduction 

CR-18-00422-PHX-SPL (BSE3) 

lNDlCTMENT 

VIO: 18 llS.C § 371 

(Conspiracy) 

Count 1 

1,?, U.S.C. § 19.J2(a)(3)(1\) . . ( r raveI Act-······l"'ac1htatc Prostttutwn) 

Counts 2-5 J • 

18 lLS.C. § 1956(h) 

(~onst;!:~~; to Commit Money I.,,1u.nd,...-1mt;) 

Count 52 

l.8 U.S,C. & l 956(a)(I)(B)(i) 

(p)nc~aJ~11~:f Money Laundering) Lormt.., 53~.>"' . 

18 U.S.(. § l956(a)(~)(A) 

(International Pmmot1cma.! Money 

Laundenng} 

Counts 63-68 

18, l T (1 C' J;;. ·1 (IS"7( •• , \, .,), .... ';f .I .J~. , aJ 

(!ransac!:io_!tal !\1foney Laundering) 

Counts 69-93 

1. The website wvvw.backpage.corn CBackpage") is notorious for being the 

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2 

3 

4 

intcrnct's leading source of prostitution advertisements. Backpage derives the 

overwhelming majority of its revenue from such ads, These practices have enabled 

Backpage to earn over $500 m.illion in prnstitntion-rdated revenue since its inccpti.m.1, 

2. Backpage was created in 2004 by defondant !VHCHAEL LACEY 

5 ('"LACEY'')~ defendant JAM.ES LARKIN ("LARKIN"), and a thfrd individual~ C.F. From 

6 2004~:! 5, LACEY and LARKIN oversaw the website's policies and strategic direction. 

7 i\dditionally~ LACEY and LARKIN have retained significant control over the \.Vehsite (and 

8 have continued receiving tens of miUions of dollars of Backpage-related distributions) 

9 since purportedly selling thdr interests in Backpagc in 2015. 

3, Defendant SCOTT SPEAR served as the Executive Vice President of one of 

11 Backpage's. parent cornpanics and. held, at times, an ovvnership interest fo Ba:ckpage of 

l2 approximately 4'%. 

l3 4, Defendant JOI-IN "JEIY' BRJJNST ("BRlJNST") served as the Chief 

14 Financial Officer of Backpagc and several of Backpage' s parent con:ipanies and hdd, at 

15 times, an O\•vncrship interest in Ba.ckpage of approximately 6'%, 

16 

17 

18 

19 

20 

21 

22 

Defendant DAN BYER ("UYER") joined Backpages marketing department 

in or around 2006 and served as Backpage's Saks and Marketing Director, 

Defendant ANDltEW PADILLA CPADJLLA") served as Backpage's 

Operations Manager. 

Defendant JOYE VAUGHT ('"VAUGl-1T') served as Backpagc's assistant 

Operations Manager. 

8, The defendants identified above are referred to at times in this indictment as 

23 the "BACKPAGE DEFENDANTS.'' 

24 9, As explained in detail below~ the.B/\CKP/\GE DEFENDANTS have utilized 

25 a variety of strategics tu make it appear that the prostitution ads appearing on Back.page 

26 are actually ads for "esc.orf' services, ''adult" companionship, dating, or other la 1,vful 

27 activities, For example, Backpage purports to bar customers from offering illegal services 

28 

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1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

and has pcrlodicaHy used cmnputerizcd filters and hnman "moderators" to edit the wording 

of (or block) ads that explicitly offer sexual services in return for money, 

These strategies arc a fiction designed to conceal the true nature of 

Backpagi,/s ads and customers. Indeed, the BACK.PAGE DEFENDi\NTS have 

admitted--in internal cornpa11y documents aml during p1:ivate meetings ---~that they know 

the overv1hr.hning rnajority of the website's ads involve prostitution, ln one intema1 

document, LACEY aetu.aHy bragged <1bout the company's contributions to the prostitution 

indtrntry: "Back.page is part of the solution. Eliminating adult advertising wiH in no y.,.,ay 

eliminate or even reduce the incidence of prostitution in this country, , .. For the very first 

time, the oldest profession .in the world has transparency, record keeping and safoguards." 

11. ·Notwithstanding these private admissions, BACKPAGE 

P DEFENDANT'S have takcnpains to mfokad the public, regulators, and Jaw enforcement 

13 officials co11ccrning the snr:poscd sincerity ofBackpage~s efforts to prevent the publication 

14 of p1~ostitution-relatcd ads, For example, after reviewing LACE Y's written description of 

1:5 Back.page's contributions to the prostitution industry and editing practicei'l'.,, LARKJN 

16 instructed C.F. to prevent "any of the information in this being made public." P/\.DIU.,_A, 

17 who helped supervise Backpagc's moderators, threatened to fire any employee vvho 

18 acknowledged in writing that the ''escorts" depicted in the \.Vcbsite's ads were actually 

19 prostitutes: '"Leaving notes . , . implying that we're aware of prostitution ... is enough to 

20 lose your job over," And in one internal document_ B.aekpagc's media strategy was 

21 described sirnply as ''Do not admow-ledge the prostitution." 

22 Many of the ads published on Backpagr. depicted children who \Vere victims 

23 of sex trafficking. Once again, although Backpage has sought to create the percept.ion that 

24 it diligently atte.mpts to prevent the publication o:f such ads, the reality is that Backpage has 

25 allowed such ads to he published vvhile declining---- for financial reasons------to take .necessary 

26 steps to address the problem. For example, for several years, Backpage's official pohcy, 

27 when presented with an ad featuring the prostitution of a chi id, was to delete the particular 

28 

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words 111 the ad denoting the child's age and then publish a revised version of the ad. Such 

editing, of course, did nothing to change the fact the ad foatured the prostitution of a chHd-······ 

it only· created a veneer of dcniahihty and helpr.d Backpagc's customers (i,e., pirnps 

trafficking children) evade detection. 

13. Backpage has also coniribnt.cd to the prohforatfrm of ads featuring the 

6 prostitution of children in other ways. For exarnple, an anti-sex trafficking organization 

· 7 once suggested t:hat Backpage provide an autornatic warning message whenever a customer 

8 scan:hed for particular terms indicative of tfo.i prostHufa.ni of a child, f.n response\ C.F, 

9 acknowledged the proposal \Vas a good one hut declined to adopt it because Backpagc 

IO would not derive any public-relations benefit from doh1g so: "This is a good idea but it is 

I 1 not visible to A Gs [state attorneys general] so it has httle PR value. lt. is a I.ow prioTity. n 

J 2 Backpagc has also daiincd it does everything in its pc)'-..ver to alert the National Center for 

13 Missing and Exploited Children ("'NCMEC'°) whenever it becomes aware that a child is 

14 being advertised on its website. However, the BACKP/\(IE DEFENDANTS implemented 

15 policies to ar!:ificbL!y limit such referrals, In one crnafl, PADILLA. instructed VAUGHT 

16 that "if we don't want to blow· past 500 [referrals to Nl\tlCECJ this month, v,,,re shouldn't be 

17 doing rnore than 16 pe:r day." In another training document, nmderntors were instructed 

18 not to send emergency akrts to NCMEC in response to complaints filed by the 

19 grandparents and other t\XJended family mernbern of chfldren being advertised on the 

20 website: «Neice [sic], nephew, grandchi1rk cousin, etc.doesn't count>; 

21 

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l.4, Virtually every do11ar flowing into Backpage's coffers represents the 

proceeds of ilkgal activity. fo fact, by 2015, the n1c1jor credit card companies stopped 

processing payrnents for Baekpage and some banks dosed Backpage's accounts out of 

concern they \Vere being nsed for illegal purposes. Jn response, the BACKPAGE 

DEFENDANTS have pursued an array of money !am.u-Jcring strategies. These strategics 

have included (a) instructing customers to send checks and money orders to particular Post 

Office box, depositing those payments in hank accounts held in the name of entities with 

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1 no apparent comwcti(m to Backpagc1 and then giving customers a corresponding "credit" 

2 on B-ackpagc to pun:.-hase new ads, (h) wiring the proceeds ofBackpagc's business to hank 

3 accounts held in fr)rcign countries and then redistributing the funds to 1.x.~rta.i11 BACKPAGE 

4 DEFENDANTS (as compensatkm) or redepositing the funds in bank accounts held in th0 

5 United States (to conceal the nature of those funds and promote Backpage's ongoing 

6 operations), and (c) converting customer payments, and. the proceeds of Backpage's 

7 business, into and out of cryptocurrency, 

8 15. The BACK.PAGE DEFENDANTS have also engaged in other financial 

9 transactions designed to conceal their misconduct and evade seizure by law enforeemenL 

IO For example, in November 201.6, LAC'.EY asked ern.p1oyees of an Arizona-based bank for 

l l. advice on how to move his assets "offshore" to protect thern from seizure by the 

12 government. Soon ai:krwanL $16,5 miHion in Backpage-derived cas:b was wired from 

J 3 LACEY's bank accounts in the United States to an overseas bank account in Hungary. 

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l.6. For al! of these reasons, the BACKPAGE DEFENDANTS are charged in this 

_indictment ,::vith the crimes of facilitating prostitution (18 U.S.C. § 1952\ eoncealrnent, 

transactional 1 and international promotional money laundering (18 U,S.C. §§ 1956 and 

1957), and/or conspiracy to commit thes(~ offenses (18 lJ.S,C § 371 and 1956). 

B. Back:r.age 1

s Origins, Ownership, and Control 

l.7. LACEY and LARKIN are the founders of the Phoenix Ne1,v Time5\ an 

alternative newspaper based in /\rizona. Over time, L/\.CEY and LARKIN acquired 

several other alternative newspapers, which they came to operate through an entity called 

Village Voice Media J-Joldings ("VVMlT'). Additionally, SPEAR served as VVMH's 

Executive Vice President and BRUNS:1' served as vvrvnrs Chief Financial Officer. 

The publications within the VVMH newgpapcr chain routinely featured 

illegal prostitution ads, 1n foct, more than 30 years ago, a federal court affirmed the 

conviction of the operator of a prostitution business (\:vhich masqueraded as a massage 

parlor) ,for publishing ads in the classified section of the Village Voice. /-,'ee (hilted States 

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v. SigaloH', 812 F.2d 783 (2d Cir, 1.987), The conviction \-vas for violating 18 "U.S.C 

§ l. 952, one of the same crim.es charged in this indictment 

_By 2000, the rise of the intcmct----.,and, m particuJar, the \Vcbsitc 

www.craigs1istcom C'Craigslist''), which offered free classified ads ----began to 

significantly disrupt VV!vl!Ts business model, which depended on classified advertising 

revenue for survival 

20. LACEY and LARKIN, with assistance fr·om CF,, sought to address fois 

8 threat by creating Backpagc. Their decision to create Hackpage was later described in an 

9 internal company document as follows: "In 2004, in response to the Craigslist threat that 

10 was decimating daily ne\vspapcrs, VV.tvl launched Jts own online classified site, 

11 Backpage.com, named afterthe back page of VVM's print publication.'' 

12 2L During its first few years of operation, Backpage accmmted fclr only a 

IJ fraction ofVVMlJ's overall revenue, In January 2006, for example, VVMH estirnated that 

14 Backpage supplied only 11}'a of its overall advertising revenue but al.so noted that Back page 

15 had •'trerncndous upside potentiaL" 

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22, This prediction proved prophetic. By 2008, Backpage was generating over 

$5 rnillion in annual profit. 'This annual profit figure increased to over $1.0 million in 2009. 

ln 20 l 0~ Craig List chose to shut down its "adult" section due to the prevalence 

of ads for prostitution and other illegal services. The BACKPAGE DEFENDANTS, 

sensing an opportunity, rnadc a.n aggressive push for Backpage to capture Craiglisf s share 

of this markeL fa one internal document~ LARKIN commented: "Craigslist has fo1ded, . 

. , H is possible that this will rnean a deluge of adult content ads for hackpage,com . , , . 

We Irnvti wjth the Village Voice prnbabiy the longest nm of adult content adve1iising in 

the l.JS and it is, hke it or not, in our DNA.!' 

24, This push was successful Jn internal documents, Backpage stated that it 

26 experienced "explosive gro\.vth" by "'capitalizing on displaced CraigsHst ad vo]mnc." 

27 Backpage's amrn.al profits grew to over $26 m.fflion in 20 I.O, over $52 1nil1ion in 20 l l, and 

28 

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1 over $78 rni!lion in 2012. 

2 'fhcse figures dwarfed the profits that VVMH's print publications were 

3 generating. ln fact, Backpage became so profitable that the BACKPAGE DEFEND/\.NTS 

4 decided to get ·rid of VVl\/1Tl's publishing business so they conkl focus on Backpage's 

5 further ckvdoprncnt and expansion. Accordingly, in or around November 2012, the 

6 BACKPAGE DEFENDANTS spun off VVMlrs print publications and began utilizing 

7 several new corporate entities; including Medalist lfoldings, Inc, ("Medalist''), Dartrnoor 

8 HOidings LLC CDartmoor"), and Camarillo Holdings, LLC ("Camarillo"), to serve as 

9 Backpage's parent companies. 

1.0 

I.I 

i3 

!4 

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16 

26. Following these transactions, LACEY held an mvncrship interest in Medalist 

(and, thcrefr)re, in Backpage) of approximately 45%, L/\R.KIN held an ownership interest 

of approximately 43°Ai, BRUNST held an ownership interest of approximately 6%), and 

SPEAR held an ownership interest of approximately 4iy.;, 

27. Backpage 's annual profits continued to 1.,kyrocket during and after these 

changes. They grev,1 to over $ l l 2 million in 2013 and over $134 million in 20 14, 

28, ln or around April 2015, L,\CIIY, LARKIN~ SP.EA.R; and BRUNST 

1 7 purported to sell their ownership interests in Backpage a.nd several rdated entities for 

18 around $600 mH1ion to various: Dutch entities. 'These Dutch entities included Atlantische 

19 Bodrijven, C.V., which agreed to purchase Backpage's U.S. operations for around $526 

20 n1fllion1 and UG·C Tech G-roup C.V ., \vhich agreed to purchase Backpa.gc's overseas. 

21 operations for around $77 million, 

22 29, In fact, these Dutch entities ,,vcre controlled by C.F., Vlho bo1Towed most of 

23 the $600 million from entities eontrnl!ed by d1e sellers to finance the purchase, l)uc to this 

24 financial a.rrnngement 1 LACEY, LARlCIN, SPEAR, and BRlJNST retained a significant 

25 financial interest in Backpage after the transactions were completed. 

26 

27 

28 

30, Additionally, LACEY, LJ\RKTN, SPEAR, and BRUNST retained significant. 

operational control over Backpagc following these transactions. For example, the April 

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J 2015 loan agreement requ.ired C.F. to sign a six-year employment agreement, required CJ< 

2 to provide the lenders \Vith foH access to Backpage's books and records~ required C.F, to 

J provide the lenders with an annual listing of all of C,F. 's personal assets, and prohihitcd 

4 CJ< from opening any new bank accounts on Back:page's behalf '>Vithout the lenders' 

5 consent 

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JL By 2008, if not earlier, the BACKPAGE DEFENDANTS \Vere aware that 

the overwhelming m,1jority of the website's "adult" ads involved prostitution, 

Nevertheless, the JJACKP AGE DEFENDANTS rnad.e a financial. decision to continue 

displaying those ads, 

The BACKPAGE DEFENDANTS also sought to sanitize the ads by editing 

them------that is~ by removing terms and pictures that were particula1'ly indicative uf 

prostitution and then pub1ishi11g a revised version of the ad. This process \Vas s(m1etimcs 

referred to as ''moderation,,; 

33. For example, in April 2008, C.F. wrote a-n email explaining that, although he 

was "'under pressure to clean up phoenix's adult content," he was unwilling to delete 

prostitution ads because <lofog so "would put us in a very uncompetitiv,1 position \vith 

craig[slistr and resu11 in ""lost pagevicws and revenue." Thus, he instn1cfod Backpage's 

technical staff to edit the word.ing of such ads, by removing particular terms that were 

indicative of prostitution, a-nd. then allow the remainder of the ad to be featured on 

Backpage's website. 

34. On February 26, 2009, C.F. received an einaH from the classified-ads 

manager of a newspaper within the vvrvn-1 chain asking why Backpagc's tcrrns of service 

purpoii:ed to prevent customers froro ''suggcst[ing:J an exchange of sexual favors for 

money" in light of the frwt that "[c]lca.dy everyone on tho entire backpage network breaks 

tho rules." In response, C.F. didn't dispute the author's characterization and. explained that 

Backpage had sirnply added the terms of service at the behest of"our attorney in SF" in an 

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att,:1npt to avoid liability in civil lawsuits, 

2 35. On l\4ay 25, 2009, SPEAR received an ernail summarizing a plan to begin 

3 "rcmovf.ingJ sex act pies and cotk:d terms" from Backpage ads. Later that day, C.F, 

4 fonvarded this email to HYER with the explanatory nole that ''Vv'e do not intend to be a 

5 craig[s1ist] here, just get out the most egregious stuff" 

6 

7 

8 

9 

36. On March 8, 2010, C.F, testified in federal court (the united States District 

Court for the Southern District of Florida) in the crhni-nal trial of a pimp who had used 

Backpage to post prostitution ads . .During his tcstinHm)', CF. acknowledged the defendant 

had used the email address '"Y mmgpilnpin86" \,vhen posting the ads. C.F, also 

l.0 acknowledged that the ads described one so-calkd escort as ''five-liiot-thret\ with a small 

l. l wafat and an1azing ass you1U have to see to believe. XL, XL, XL, Lollipopn and described 

1.2 a different so-called escort as "discrete, sincere and extremely naughty. I am. the type of 

1.3 girl \Vho ahsolutd.y adores a man who understands the rnany desires of a young beautiful 

!.4 woman and how to acco1:nn1odate a variety of fantasies." This episode provided notice to 

l 5 Backpage that it was implausible to pretend such ads were merely offering law fol escort 

16 services. 

17 37, On Septcrnber l, 2010, PADILLA sent an email to HYER and C.F. stating 

18 that customers who engaged in "extreme and repeat" violations ofBackpage 1s posting rules 

19 would have their ads deleted and be bam1ed from the website. However, PADILLA also 

20 stated the bans would only be temporary a:nd that '\veH do everything we can to affect 

21 only the \,vorst apples." 

38, On Septernber 1, 2010, SPEAR received an email ackno1vvkdging that 

23 Backpage's 111ocfora.tors \VCW being instructed to "Remove any sex act pies in escorts [ads]" 

2A and. "Remove any illegal text in escorts [ ads] to include any code words for sex act for 

25 money," 

26 39. On September 21, 2010, a group of state attorneys genera] wrote a letter to 

2.7 Backpage. This letter observed that "ads for prostitution------including ads trafficking 

28 

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chfldren······are rampant on the site" and argued that '"[b ]ecausc Backpage cannot, or 1-vill 

2 not, adequately screen these ads, it should stop accepting them altogether," The ktter 

3 acknmvlcdgcd that this step \Vonid cause Backpagc to "lose the considerable revenue 

4 generated by the adult services ads" but stated that "''no amount of money can justify the 

5 scourge ofiUcga1 prostitution, and the rnisery of the women and children who 1-vi11 continue 

6 to be victimized, in the rnarketp1ace provided by backpagc," 

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40, On September 25, 2010, C.F. wrote an email explaining that Backpagc was 

unwilling to delete ads that .included tcr.rns indicative of prostitution because doing so 

would "pissU off a Jot of users \.vho wm migrate clscwJiere" and force Backpage to refund 

those customers' !:ees. 'fhus, CF. a1111ounced thatBackpagc wonld "go back to having our 

moderators remove bad content in a post ... , " 

4L On September JO, 20! 0, C,F. testified in federal court (the United States 

Distdct Court for the District of Minnesota) in the criminal trial of a pimp who had used 

Backpagc to post prostitution ads, During his testimony, CF. ackno;,x.dedged that 

Ba.ckpagc's servers arc located .in Arizona and that the ads posted by the Mim1csota-based 

defm1dant had therefore ''traveled across state lines.'' 

42. On October 8, 2010, PADILLA sent an email (on which VAUGHT vvas cc'd) 

18 threatening to fire any Backpage em.ployee who ackno,.vlcdgcd, in writing, that a customer 

19 was a prostitute: '"Leaving notes on our site that irnply that we're a\v,u·e of prostitution, or 

20 in any position to define it, is enough to los.e your job over. , . . This isn't open for 

21 discussim1. If you don't agree 1-vith what Pm saying completely, you need to find another 

22 job." 

23 43. On October J 6, 20] 0, PADILLA sent an email to a large group of Backpage 

24 employees (including HYER and VAUGHT), The email had two attachments that 

25 provided guidance on ho-,.,.v to "moderate" ads, The first vvas a Povverpoint presentat1{n1 that 

26 displayed a series of 38 nude and partia.Hy~nude photographs~ some of which depicted 

27 graphic sex acts, Next to each picture was an instruct.ion as to whether it should he 

28 

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approved or disapproved by a Backpage moderator. These instructions induded "Approve. 

2 Nude rear shots are okay as long the model is not exposing her anus or genitalia." and 

3 "Approve, Rear shot okay. Transparent wet panties okay," The second wus an Excel 

4 spreadsheet identifying 50 terms (all of \Vhich were indicative of prostitution) that should 

5 he '"stripped" from ads befr)re publicatim.1. PADILLA concluded the email by stating: 

6 ""[f!t's the language in ads that's rcal1y killing us with the Attorneys General. h:nages arc 

7 almost an aftcii.houg:ht to them." 

8 ... 

9 

10 

n 

12 

44 . On October 16, 20 U\ PADILLA sent a separate internal email (\vhic.h also 

included I-IYER anJ VAUGHT as .recipients). In this email, PADILLA c-xplained that ''l'd 

like lo stiH avoid Deleting ads \Vhcn possible," that "we 're still a!lcn,ving phrases Vlith 

nuance," and that '"[ijn the case of lesser violations~ editing should be sufficient." 

45. On October 25, 2010, C.F. sent an email to SPEAR, llYER, and PADILLA 

13 ack:no\~'kdging that the "[i]Hcgal content removed" through Back.page's m.oderation 

14 processes was '"usually money for sex act'' This email also explafo.ed that, af:ler the "sex 

15 act pies are removed/ the ''ad text m.ay stay." 

16 

17 

18 

19 

20 

46. On October 26, 20 H\ HYER and PADILLA received an email explaining: 

"\Ve \Vill nut remove ads vvith vaginas or penis showing, jnst: the images unless they are a 

frequent offender. We will not remove ads \-Vith rates under an hour, just the text with the 

m1ninn.1m rates. Users nt:cd time to react to this change," 

47. On October 27, 2010, PA.DILL/\ sent an email to the head of a group of 

2 l. contractors from lndia who had been hired to mod,ffatc Backpage' s adult ads, In this email, 

22 PADILLA criticized the contractors for deleting too rnany ads, stated that this approach 

23 was bad for hn:-ducss, and instructed the contractors to simply edit the ads to remove the 

24 more-obvious 1anguagc: "As Jong as your crew fa editing and not removing the ad entirdy, 

25 we shouldn't upset too many users. Your crnv has permission to edit i:)ut text ·violations 

26 and images and then approve the ad. 1' 

27 

28 

48, On October 27, 20 l0, I-IYER sent a.n .internal. emai1 stating that Backpagc 

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was "editing 70 to 80~•1<->'' of the ads it received frrnn customers, In other wonb, JJYER 

acknowledged that a large proportion of the ads originally submitted by Baekpage's 

customers contained text and pictures that vvcrc imhcative of _prostitution and. that 

Back.page was still choosing to publish those ads after editing them. 

49. On Novernber 4, 2010, C.F. sent an email to Backpa.ge's India-based 

moderators (on which PADILLA \Vas cc' d) explaining that "[m]any of the ads need to have 

15 mfoute and 30 minute: pricing removed'' and that 'Tm being evaluated by lawyers [i.e., 

state attorneys general! later this week so cleaning up old stuff is irnportant.'' 

On November 17, 2010, HYER. and PADILLA received an cma.i1 

10 acknowledging that the term Lolita is "code for under aged girl" but explaining that this 

1 ! term could simply be stripped ont frorn ads (as opposed to refusing to publish the ad). The 

12 email also explained that customers should ho allowed to include their identification 

13 mimbers from a notorious prostitution •,,vchsitc~ The Erotic Review: "[ AJHow users to put 

14 in TER IDs (just no live links)." 

15 5L On November 30, 20! {\ LARKIN, SPEAR., and other Backpage 

16 representatives participated in a conference call with representatives from NCM.EC. 

17 During this caU, the Backpage representatives were advised that a large portion of the ads 

18 on Backpage \Vere blatant prostitution ads, that many of those ads featured children, and 

19 that the posting ofs.uch ads was illegal in every state. 

20 52. In Deccrnhcr 20 l 01 HYER, PADiLLi\, and other8 exchanged a series of 

21 emails entitk'.d "Deep deaning strip out." These emails identified a lengthy Est of tcnn.s 

22 that \Vere indicative of proi~titution and discussed plans for removing the terms from the 

23 old ads in Backpage's archives, During this exchange, C.F. stated that .Backpago wasn't 

24 willing to delete the old prostitution ads because "our users love" having access them, 

25 ''[sjo, best to do deep cleaning and not kill a valuable feature." C.F, later encouraged 

26 Backpage~s staff to complete t.he project quickly to avoid scrutiny: ''This task is urgent 

27 since CNN is nming [sic] a report soon." 

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53. On January l. 3~ 20 !. 1, H.YE1{ and PADfLLA received an oma:il swnmarizing 

instrn.ctions that had been provided to members ofBackpage's tedmfoal staff. lt explained 

that the technical staff had been instructed "not to display the moderation log" in a 

particular section of Backpago~ s database "since we pdf this page for subpoenas, I would 

rather not testify in corut as to why my staJf \.ippruvcd' ... postings." 

54, ln January 20 I. L LARKIN and LACEY met with a representative from 

NCJvfEC. During this mooting, LACEY asked which types of sex ads would be acceptable 

from NCMEC's perspective. When the NCMEC representative declined to say that any 

such ads would be acceptable, LACEY made a statement to the effect of'"adult prostitution 

is none of your business." 

On January 31, 201 J, and February 1 ~ 20"! I., CF. engaged in an ernail 

12 exchange conc01.·n1ng \vhether to n.unove links to othe.r prostitution websites (such as The 

I 3 Erotic Review) from expired Backpagc ads. C. F, stated thati although SPEAR and his 

14 "internet safety guy" \Vere n.:cornmendfog that such ads be removed, he thought this vvould 

15 "be a stupid move" because it \vould hmt Backpagc financially (by reducing the number 

16 of referrals from other sites).. C.F .. added that '"this overly zealous focus on moderation at 

17 the expense of other devcloprnent is a lot of hull.shit .... " 

18 

19 

20 

21 

22 

23 

24 

56. On February 2, 201 l, C.F. sent an email acknowledging that •'[t]hc strip out 

affects almost every adult ad." In other words, C. F. acknowledged that "almost every adult 

ad°' on Backpage was a prostitution ad that had been edited to remove the xnost damning 

text and pictures. 

57. On February 3, 20 l l, a Baekpage customer who \~'cnt by the name "Licks 

Alof' wrote an email to Uackpage complaining that aH of the pictures in one of her ads 

(entitled "Athletic SWF (Juanmteed Lovv Mileage Boys!!!") had been deleted. CF. 

25 responded to "'Licks Alot" by cxpl.aini-ng that 0110 of her photos had been removed because 

26 "[o]ur crazy internet safoty experts do not want any genitalia shovving up around the 

27 thong.p lfowevcr, C.F. proceeded to apologize to «ucks Alot" over the removal. of her 

28 

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rernaining photos, aHowed ber ad (which was obviously for prostitution} to remain on tho 

website, and offered her a free upgrade. 

58. On February 81 20 I l, CF. testified in federal court (the United States District 

4 Conrt fen- the Middle District of Florida) in tho criminal trial of a pimp who had used 

5 Backpage to post prostitution ads. During his testimony, C.F., authenticated. one of the ads 

6 the defondant had placed on Backpage, whose titk was •'Extra horny sexy newbie," 

7 confirmed that Bad,.page had allowed this ad to be posted rnu1tiple times in various East 

8 Coast cities, and acknowledged that Backpage published "a loC' of similar ads. This 

9 episode provided further notice to Backpage that it was irnplausible to pretend snch ads 

IO \Vere 1nerely offering lawful escort services. 

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12 

n 

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59. On February l.6, 2011, PADILLA s.cnt an ern.ail to Backpagc's 1n<lia-based 

moderators (on which VAIJGl-IT \Vas cc'd) explaining that Backpagc was adopting a 

"more lenient policy'' and fhat he \Vas instructing his. Phoenix-based employees to '"go easy 

on some types of violations." PADILLA ackm.nvlcdged this approach would "likely" result 

in rnore "violatkrns" but emphasized that "moderators should err on the side of the user!' 

60. On February 1.6, 20 l.l, PADILLA sent a separate email. discussing \Vhether 

several terrns: should remain on Backpage's "filtered terms" list During this discussion, 

PADILLA. acknmvledged---by placing quote marks around the term '"companionship"---

that he didn't actually believe the worncn being advertised on Backpage were :providing 

hnvfo.l escort services: "!_The tenn] implies sorne exchange ofbodi1y fluids which ki!Js our 

'companionship' argument, but i don't thi-nk \Ve~ve ever really gotten in tronhk for iL" 

61. On February 22, 2011, PADILLA received an email requesting Backpage's 

"Est of banned~ stripped out adult terms," In response, PADILLA sent an Excd 

spreadsheet entitl.cd '"Phrase List 02211," which PADILLA described as '"the latest greatest 

version of the list'' The enclosed spn.iadsheet identified over 660 words or phn=rnes that are 

.indicative of prostitution, including an array of terms that are suggestive of child 

prostitution (e.g., "'lolitat "fresh/' "high schoo1:' "'tightt "yonntl The spreadsheet 

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cxpiained that most such terms were sirnpl.:l to be "filtered" from the ads 111 \vhkh they 

appeared. 

62. On February 23,201 l, PADILLA received an email concerning a particular 

4 ad that had recently been (.xlited by Backpage's India-based moderators. The ad was 

5 obviously :for prostitution-·····its title was «nev/-nevv~ncw-put me in your favodte position" 

6 and the poster had attempted to include two photographs that violated Backpage's post.lng 

7 rules, In response, the India-ba~{ed moderators had deleted both of those photos, as weU as 

8 a third photo that depicted the prostitute's face, and then all.owed the ad to be published. 

9 The email received by PADILLA did not criticize the rnoderatorn for aHm-ving an obvious 

IO prostitution ad to be published after editing. To the contra.ry, it en1phasized that the ad 

1.1 should remain on Backpage and criticized the moderators i<)r removing the third photo, 

l2 threatening to fire them. ff they did it again: "2 out of 3 pies should have been rcrnoved. 

l 3 But [theJ moderator deleted all three plcs, This is plain wrong, , , , I would fire a moderator 

l4 in Phoenix if they did this." 

63. In Ma.rch 20 I!, LARKIN, LACEY, S.PEAR., and other Backpagc 

16 representatives 1net with representatives from NCMEC. During this meeting, the Backpage 

17 representatives \vere again advised that a large portion orthe ads on Ba.ckpage '>Vere blatant 

! 8 prostitutkm ads. The Backpage rcpres,~ntatives also were advised they could be criminally 

! 9 prosecuted under federal law for their conduct. 

20 

21 

22 

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64. On April 5, 2011, PADlLL/\. sent an email whose recipients included 

VAUCffJT and the supervisor of Backpage's Indian moderation team. The em.ail \Vas 

entitled "relaxed image standards" and 1nduded, as an attachment, a doc11ment that 

displayed a series of 30 nude and partially-nude photographs, Next to each picture was an 

instrud1on as to whether it should be approved or disapproved by a moderator. One picture 

sho\ved a woman sitting on a bed, wearing only a bra and pantks, with her legs spread 

open and her hand partially covering her crotch, The caption provided in part: "'okay -

but barely.'' 

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l 65. Betvveen April 2011 and JVIarch 2012, PADILLA, C.F,, and others 

2 participated in an email exchange acknowledging that Backpage was dC!eting thousands of 

3 pictures from customer ads each week a:nd seeking assistance in collecting all of the deleted 

4 pictures so they could he used for "entertainment" or to generate user «traffic for other 

5 projects,'' The crnail explained that the deleted pictures could be made available to the 

6 public on a new \,vcbsjtc called "11<:tkedpics,backpage,com" or "badpics.hackpage,com." 

7 

8 

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lO 

u 

66. On April 19, 2011., LARKIN and SPEAR received an email seeking 

permission io tenninate the contract of a foird-party vendor that had been receiving $17 ~000 

per month to "remov[c] any nude pies" from the expired ads in Backpage's database. 

LARKIN responded: ''do it!" 

67. On Jnne 7, 200, C.F, received an inqu.iry from a law· cnforcernent officfa1 

12 about a particular ad. that included. the term "arnber alert." In response, C.F. acknowledged 

13 this might be "some kind of bizarre new code word for an under aged penmn.'' C.F, then 

14 forwarded this exchange to PADILLA and stated that he had instructed !TYER to add 

15 "amber alert" to Backpagc's "strip out" list ln other words, HYER, PADlLLA, and CF. 

16 did not require all future ads involving this particular coded term for the prostitution of a 

! 7 child to be blocked fn:nn Backpage~----they merely required such ads to be edited hef<)re 

18 publication. 

!9 68. On June 30, 201 I., several Backpagc representatives met with representatives 

20 frorn the office of the Washington State Attorney GencraL During this meeting, the 

21 Backpagc representatives initially attempted to daim that no prostitution ads appeared on 

22 their i.;vebs.ite. fn response, a repre~entative from the Attorney Ckncral's office stated: 

23 "·y uu mean to tell. .me that if someone responded to an advertisement, the woman they 

24 caHed for services would be offering to go out for coffee?" A Backpage representative 

25 responded to this question by looking at C.F., laughing, and acknowledging that Backpage 

26 couldn't '"deny the undeniable." 

27 69. On July 27, 2011, C.F. sent an email to HYER and Pl\DfLLA~ and a nearly28 

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identical ernai! to LARK.IN and LACEY, concernmg the possibility of using a.gevcrificatkrn software. Jn this email, C.F. acknowledged the soflwaro 111ight be beneficiaJ 

("This might he our solution") but recommended against its wholesale adoption because it 

would cost "79 to 99 cents per query" and \Vonld thus cu.t foto Backpage 's profits. 

70. On July 28,201 J, LACEY sent LARKIN a drafl editorial entitled "BackPage 

6 lffH..krstood.'' In this docum.ent, LACEY bragged about Backpage's contributions to the 

7 prostitution industry; "Backpagc is pali. of the solution. Eliminating our adult advertising 

8 will fo -no Vi!ay eliminate or even reduce the incidence of prostitution in this country .... 

9 For the very first time, the oldest profession in the ,,,vurld has transparency, record keeping 

l O and safeguards." LACEY also acknov./ledgcd tfo1t Backpage used an automatic filter to 

11 rernovc particular phrases fmm ads that were indicative of prostitution but still published 

12 the ads after editing them. 

71. Soon afte1ward, LARl(TN fo1warded the editorial to C.F ., with a cover note 

14 cautioning against some of LACEY's statements ''being made public" because "we need 

15 to stay ;:nvay from. the very idea of 'editing1 the posts, ~ts you know." C.F .. 1 in turn, revised 

16 the editorial to take out the paragraph lauding Backpagt/ s contrihutions to the prostitution 

17 industry. 

72. On August 5, 2011, Backpagc received a letter from the mayor of Seattle. 

19 This letter warned that "Seattle Police have identified an ala.nning number of juvenile 

20 prostitutes advertised 011 Back.page.com since January 201 O" and explained that Backpage 

21 was dissimilar from othe,r companie& whose products and services are '"occasionally or 

22 incidentally" utilized by crirnina1s because '"[y]our company is in the business of selling 

23 

24 

25 

26 

27 

28 

sex ads" and "your services arc a direct vehldc for prostitution." The letter also 

rccmmnended that Backpa.ge require in-person age vcr:ificaticm for all of the "escorts" 

depicted in its ads, A!:lerwan1, Backpagc declined to adopt these recommendations. 

73. On 1\ugust 15, 201 l, PADILLA received an email containing an updated 

version of Backpage's moderation gniddines. This. six-page document provided the 

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foHowing instructions concerning photographs: "Nude rear shots are okay as long the 

mode! is not cxpot-frng her anus or genitalia," "'fransparent vvet panties okay should not be 

able to see personal private part., Hand "cherry, lcc-crcmn keeping i.n mouth [is okay],,; The 

document a.1so explained that ''Bikini, lingerie, g-string, thong, and hands covering nipples 

arc all allowed/' ".f-lourly rates are OK/' and "Sessions a.re okay. E.g $50 session_;, 

74. On August 3li 2011, Backpage received a letter from the National 

7 Association of Attorneys (knernL This letter characterized Backpage as "a hull' for 

8 human trafficking, identified '"more than 50 instances, in 22 states over three years~ of 

9 cfotrges filed against those trafficking or attempting to traffic minors on Backpage.corn," 

IO and noted that "'[n]carly naked. persons in provocative poifrti.ons are pictured in nearly every 

l I adult services advertisement on Backpagc.c0111 and the site requires advertisements for 

12 escorts, and other similar 'services,' to include hourly rates, .ft does not require forensic 

13 training to understand that these advertisements arc for prostitution, H 

14 

15 

75. On October 6, 20 l 1, C.F. sent an email discussing various proposals for 

addressing "the under aged. issue!' \IVHh respect to one particular proposal, C.F. 

16 acknowledged it was a good one but recon1mended against adopting it bt~cause Baekpage 

17 • would not derive any pubhc-relations benefit from doing so: "This is a good idea but it is 

18 not visible to AG;s [state attorneys general] so it has little Pll value, It is a low priority." 

19 76, In the fall of 2011, Backpage sought the assistance of a public relations finn 

20 based in Washington~ D,C. On October 12,2011; CF, received a written copy of the firm's 

2] presentation. Later, some of the B/\.CKPA.CiE DEFENDANTS attended a meeting at 

22 which the presentation vvas discussed in more detaiL The presentation ;,varned that 

23 Backpage~s business practices would .inevitably result in k~ga! trouble ("One day the 

24 proverbial is. going to hit the fan") and characterized .Backpage's ''media strategy'1 as "Do 

25 not acknowledge the prostitution. 1' The presentation also noted that the "ads on the 

26 backpage.com sit,~" generally fall into three categories, one of which fa "Pimps and M.en 

27 Looking for Kids," 

28 

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77. On October 21., 2011, LARKIN received an emaH discussing whether the 

2 Backpage \Vchsite should include a warning message concerning the prostitution of 

3 children. This email contained the foHovYing joke: "'Andrc\v [PADILLA] thinks it to[o"j • 

4 heavy handed and thinks our web ~dte mmw '>Vill he entmpm.cntcom (J-Iilariotrn):: 

5 78. On Nove1nber 16, 2011, HYER and PADILLA. received an ema.1 I asking for 

6 ''urgent" assistance in diminati-ng the word '"teen" from the ads appearing on Backpagc's 

7 website: "Rem.ove ads with teens or remove the text teen from . , , ads!' 'The following 

8 day~ .PADILLA wrote back with an update that he had found "76 pages of results" and that 

9 he ha.d simply "edile{f' all of the ads posted within the last two 1nonths (i.e., allo\.ved those 

10 ads to remain on the website after sanitizing them). 

H 

12 

13 

14 

15 

16 

79, Between around January and March 201.2, many of Backpage's moderators 

(\.vho were supervised in part by PADILLA and VAUGHT) nndervvent performance 

appraisals. These appraisals revealed that many of the moderators did "not report young 

looking escorts." Nevertheless, these moderators were ailowed to keep their jobs, and 

sometimes were given strong overall performance ratings, 

On February 16~ 20 l.2, PADILLA. sent an email to VAU(iHT stating that 

17 Backpa.ge should limit the number of child-exploitation -referrals it was making to 

18 NCMEC: "lf we don't want to blow past 500 this month, we shouldn't he doing more than 

J 9 l.6 a day." 

20 81. On February 23~ 201.2, CF. waH forvvarded a legal notice claiming that 

21 several of Backpage's ads included copyrighted content from two competing websites 

22 called Rub.tvlaps.com and Erotic.MP .com. C.F. also received copies of the underlying ads 

23 from the competing websites, which dearly involved prostitution. ln one of the ads., a 

24 customer stated that, in return for $45 and a $5 tip, he had received a "Bh)\V Job . , . w/ 

25 condon/' from a woman who "had nice breasts." In a different ad, a customer stated that 

26 in retnm for $60, he had oral and vaginal sex with a prostitute. And in a different ad, a 

27 cus.torner stated: 'Tier bj \Vas slo\'\'' and erotic, and she was happy to go with whatever 

28 

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position I \Vanted." When CF. forwarded these materials to Backpagc's stan: 1w \Vas asked 

\Vhether the corresponding ads appearing on Backpage 's \vebsite should be removed 

immediately, C.F, replied that they should be all<nved to remain on .Backpag~ for another 

fov,,1 weeks without any modification, 

82. On March 15, 2012, HYER received an email concerning the ads with the 

copyrighted materiaL This email stated that the ads shouldn;t be deleted and that 

Backpage's technical staff should ffierdy "strip ouC the names of the competing 

prostitution vvt.~bsitcs: '"Copyright infringement issue. We need to strip out every 

appearance of rubrnaps.com and eroticmp.com." Vi/hen a staff member sought rnore 

guidance, J-IYER fote1:jected: "We don't need to delete ads or users." 

83. On .April 7; 2012; .PADILLA vvas infrmned that a \Vom.an had contacted 

12 Backpagc to rcpuii that one of the "escorts" depicted on ihe site was only l? years ol.d, 

13 The woman provided the juvenile's full name and hirlh year and fu1ther stated that the 

!4 juvcnilt'. had been attempting to recruit tho complaining party 7s daughter {who \Vas 15), In 

15 response, PADILLA. instructed his staff to refuse to ren10vc the ad because "she~s isn't 

16 claiming her own daughter is in the ad,'' 

17 

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84. On /\.pril 8, 2012, LACEY sent an email emphasizing that '~iim [LARKIN] 

and I believe in legalized prostitution" and stating that Hackps.ge\., efforts to prevent tho 

prostitution of children on the site were "not perfect, by any means." 

85. On ApriJ 251 2012, a Backpagc representative spoke at a meeting of the Nc\-v 

York City Council's Women's Issues Cornrnittce. During this meeting, the representative 

stated it \-Vas better to have ads for sex \Vork appear on Backpagc than have them rnovc to 

other places on the internet The representative further stated: "I don't deny that Backpago 

is part of the problem, but the problem is the internet," 

86. On April 27, 201.2, a \Vot:nan wrote an email to Backpagc's support 

departrnent stating that her underage daughter had been kidnapped, drugget\ and \~'as being 

advertised as a prostitute against hor will. 'fhe ernail identified the specific phone munber 

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associated vvith the ads (754-229-xxxx\ stated that the ads appeared on a website ca11ed 

BackpagoPics.com, and asked that the ads be removed immediately: "l'his fa a drugged 

a.nd held against her will child ;,>ii·ho had photos taken under threat and duress . . . . Please 

remove." This email was forwarded to PADILLA by a subordinate\ vvho asked '"should 

,ve respond?" PADILLA replied by explaining that, because the website 

6 BackpagePic:-tcom wasn't owned by· Backpage, there \<\'as no need to respond to the 

7 .mother. 

8 87, On April 30, 2012 (t!m.::c days later), the same woman wrote another em.ail 

9 to Backpage\; support depa1tmenL 1n this e1nai1, the woman stated that "l have contacted 

10 hackpage on scvend occassions [sic] to remove these pictures which were posted against 

1 J her wm and \Vhile she was drugged and held captive. I have yet to receive a reply." This 

12 time, lhe woman provided a frnk to her <laughtm· 1

s ad on Backpage (not 

J 3 BackpagePics.corn), which included tho sarno phone munbcr (754-229-xxxx) that had boon 

14 included in the other ad. 

15 

16 

17 

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19 

20 

21 

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88.. On May I, 2012 (the next day), the same woman \.Vrotc a third email to 

Backpage's support department In this email, the 'Nonum included a Hnk to another ad on 

Backpage depicting her underage daughter and stated: "I also fr,und a pix of my daughter 

within this url both girls are in protective custody." Later that day, the woman received an 

email from Backpage's support depa.rtnient stating: "The post fa confinnod removed." 

89. Som.e of these emai !s were forwarded to LA.CEY and LARKI.N. In response, 

LARKIN applauded Backpage's ••good solid response'~ to the woman and remarked: "this 

whole rigamarolc seems a little odd to me.,; 

90. On M:ay 10, 2012, !'he tdcvision news station CNN ran an expose on 

24 Backpagc that emphasized «hcn.v young S(JJ:ne of these girls look'' and deemed the webs.it,~ 

25 "a huh for the sex trade.'' 

26 9L On l'Vlay 1 I, 2012, PADil,LA sent an email to VAUGHT and other Backpagt1 

27 mnployees entitled "forbidden pbneL" Enclosed with the email was an Excel spreadsheet 

28 

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1 that identified over 600 words and phrases that arc indicative of prnstitutio11. The 

2 spreadsheet also specified, for each \VOrd and phrast\ whether an ad containing the 

3 offending language should be banned or whether Ba.ckpagc 1:-1hould simply ""strip term fr()m 

4 ad" and then publish it after the revision. 

5 

6 

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ll. 

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92. On July 12, 2012, PADILLA sent an ernail (which was also shared with 

VAUGHT) to the head of Backpage's Indian 1:nodtTation team. in this email, PADILLA 

criticized the moderators for ddeting too many ads and provided the !<)Umving instruction: 

'"l agree that 'over cautiousness' is as big of a problem as moderators that mbs a fot of 

violations. '

1 

93. In or around November 2012, a researcher at Arizona State University 

published. a study concluding that rnosi of the ads on Backpage's Phoenix page involved 

prostitution and that many of the ads depicted juvenile trafficking victims. On December 

! 9, 2012, LACEY vnis fon.varded a copy of the stndy's results. The researcher responsible 

for the study also met with a Backpage 1.cpresentativc to propose various rnedwnisms for 

reducing or eliminating the prostitution of children on the website. Backpage tfodined to 

adopt these proposals. 

94. Between around September 20 lO and October 2012, C.F. becarne a\varc that 

18 a particular Backpagc nrntomer, P.R., was posting prostitution ads. Rather than bar th.is 

i.9 customer !iom posting future ads, C.F. repeatedly restored. her posting privileges and gave 

20 her advice on h(nv to conform to Backpage's publication standards, The communications 

21 involving this woman's ads included the f(.1Hovving: 

22 

23 

24 

25 

26 

27 

28 

.. On September 26: 2010, C.F. received an email from a woman ·who was 

obviously posting prostitution ads on Backpagc, Tho \Votmn1, whose email address 

inch.1ded the phrase "'provider4u," wrote to complain that her escort ad ("'50 Red Roses 

special ---- Dont .t-.tliss out ! ! !") had bce.n removed cvon though "'[o]ther women have more 

explicit ads than me and they are up!" The \Voman continued: "I can not afford to have 

this ad removed. This is the only way I can got by and if its not on a.11 the tirnc I will not 

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! be able tu pay my bills .... !vly fianc6 is in jail and he is not able to help rne at this 

2 point." In responSt'\ CF. arranged for the \V<m1an tu be allowed to continue posting ads. 

3 On October 6, 2010, CF, received another ernail frorn the same woman. In 

4 this email, she complained that her most recent ad had been removed because it induded 

5 an explicit picture of her body, She provided a copy of the picture to C.F, and stated: "ff 

6 the person [ who removed the adJ is such a p1Ti.de well rnaybe they should check out the 

7 other women's ads in that [escorts] section." On November 15, 2010, C.F. \Vrote back to 

8 foe woman to encourage her to t~dit the ad so it could be re-posted: "Ole please try editing 

9 the ad now:~ After this exchange, the woman was permitted to resume posting ads on 

lO Backpagc. 

" On June 6, 201 I, C.F. received another email !iom the same woman. It 

l2 stated: •·1 would rea!ly appreciate it if you \.vould please take the block off my ad for editing 

l3 ... , l wont post any rnore objectionable pies, ok?'" In response\ CF, arranged for the 

14 1-voman 's editing and posting privileged to he restored: "You should be able to edit 

15 no\v. Please let us know if you arc still having any trouble." After this cxc.hange, the 

16 1-voman resumed posting ads on Baekpagc. 

I7 On July 14, 2012, C.F. received another email from the same v10.man. It 

18 stated: '\vould you please take the ed.it block off my ad, l need to change sorne info cm it 

19 and update it l prornise i \.vont put no more nude pies in it, yon have my wont . . . [M1y 

20 a.d says: 50 red roses special···· dont miss out." Atkr this exchange, the woman was allowed 

21 to continue posting ads rm Bac.kpa.gc. 

22 ,. On Sept.ember 17, 2012, CF, rccd.ved another email from the same 

23 vvoman. T'his time, she complained that Backpagc ,vas editing her ads (whose title 

24 continued to feature the obvious prostitution tenn <•50 lfed roses special") to remove the 

25 most explicit pictures., She stated: "'l would Hke to k110w why my ad in the escort section 

26 of backpage keeps getting messed with ... , [SJomcone keeps erasing the !ink to rny pies 

27 on the ad. that fa so wrong. l am being deprived of income that I sorely need . . . . There 

28 

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are other woman posting pies on their ads that show more nudity, , , , " After this exchange, 

tho woman \Vas pennitted to continue posting ads on JJackpagc, 

On October I 6, 2012, the woman wrote another email to Backpagc. In this 

4 ernaiJ: she again corn.plained about how Backpage was editing her ads to remove the most 

5 explicit pictures, She stated: "lt is very hard for me to make any income fn)ffl this ad as: 

6 they continually go into my ad and remove the !ink from the ad. that goes to my 

7 pictures. They wont allow me to post my pies on the ad yet othtT women with other ads 

8 shrnv more nudity than my pict11rcs ever did." 

9 

:10 

H 

12 

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15 

This email was forwarded to VAUGHT and to PADII.,LA~ who asked 

another Bac.kpage employee to "dig into this one a htlle: 1 On October 17 ~ 2012, PADILLA 

received a follow-up email from his co-\vorkcr stating that the ·wonmn 'sad had been posted 

on September 27, was still on the Backpage website, and that the pictures the woman had 

originally attempted to include in the ad (\vhich had been stripped by Backpage) were 

"topless shots.'' 

Following these exchanges, between October 2012 amiNovemher 2015, the 

16 same customer \Vas allowed to post over a dozen new ads on Backpagc, many of \Vhich 

17 utilized the same identifying infonn.ation.1 coded prostitution terms, and contact phone 

18 number as before, 

19 95. On January 7, 2013, VAJJGHT ·was infiJrn1ed by a moderator that Backpage 

20 wasn't diligently pursuing rcporh; of child exploitation: "We 'vc supposedly been checking 

21 then1, but some seem to be ignored. 'J'hey get "rnarkcd as read', hut nothing gets done with 

22 them, It's aggravating and irresponsible," 

23 

24 

25 

26 

28 

96. On June 6, 2013, Backpage received a letter from NC.MEC recommending 

the adoption of several specific security rneasurei~ to prevent the trafficking of children, 

The recommended security measures included (a) verifying the age and identity of users 

who submitted adult ads, (b) verifying the age and identity of individuals depicted in 

photographs \vithin adult ads, (c) prohibiting the use of anonymous payment sources such 

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as prepaid credit cards, and ( d) reqn.iring users to utilize verified email addresses and 

telephone mnnhen;, 

recommend.ati ons. 

Afterward> Backpage declined to :fi)lluw any of these 

97. On August 30, 2013, LARKIN, SPEAR, BRUNSJ\ JTYER, apd C.F. 

5 received an cm.ail notifying them that ;'Chase [Bank] was no longer ae(x~pting transactions 

6 from Backpage,com, due to their involvernent in human trafficking," In response, C.F. 

7 informed the group that he intended to begin "giv[ing] users free ads if they complain while 

8 we ,vait 011 directly transactions to another processor." 

9 

l.O 

I.I 

1.2 

1.3 

1.4 

1.5 

l.7 

18 

19 

20 

21 

22 

23 

24 

98. On September ] I, 201 \ a Backpage representative made a presentatim.1 to 

the Arizona Governor's Task Foree on Human Trafficking. Following this presentation 

(,,vhich took place in Phoenix), foe representative was asked whether there would. he any 

'·cons" to requiring verifiable identification of all escorts being advertised on Hackpage's 

website. In response, the representative did not identif\1 any financial or logistical hurdles 

to the adoption of such a requirement, Instead, the representative stated that such a 

requirement would simply cause Backpagc to lose business to other prostitution websites 

like myRedifookcom or to overseas prostitufom websites. During this rncctiug, mem.hers 

of the task force also provided the representative with evidence sho\ving that Backpagc 's 

moderation efforts were ineffective at preventing the publication of prostitution ads. 

99. On Aprfl 3, 2014, PADJLLA and \/AUGHT were forwarded an email that 

had been sent to Backpage by a credit card processing company in Canada. The email 

stated that "r w]e have rnultipl.e user accounts that are paying for your services for what 1 

understand to be prostitution adverfo.,ements." and sought information c1hout "lmvv you arc 

processing these transactions." 

100, On April 14, 2014~ LARKIN and BRUNST received an email from CF. 

25 discussing why Backpagc had experienced "past high growth" and identifying various 

26 ideas for achieving 1'foture growth." This emai! stated that Backpage had been the 

27 beneficiary of "[mJigration of content :from other ... marketplaces to the internet" and 

28 

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identified one particular marketplace as a key source of Backpage's custorncrs: "[N]ct loss 

2 for brick and mortar marketplaces: Strip dubs, !.1otcfo., and gathering spots disp!at:ed by the 

3 internet." In other 1-vords1 the crnail acknowledged that the supposed "escorts" advertising 

4 on :Backpage were actually prostitutes (lawful escorts did not congregate at strip dubs, 

5 hotels, and other hrick-and-rnortar '"gathering spots" during the pre-_internet age). This. 

6 email also attributed Backpage's success in part to its adoption of policies that allowed 

7 customers to post ads \:vithout leaving any meaningful identifying infi:mnation-·····ju a list of 

8 Backpage's advantageous policies, it identified '"Ancmymous/' ''"Prepaid card friendly/' 

9 "User can post paid ads withont a valid email address/' and "b1tcofo.'' 

IO 

I] 

12 

13 

14 

l 01. On A.pd! 24, 2014, VALJGHT sent an email to Backpage's moderators (while 

cc'ing PADILLA). In this ernail, VAUGHT explained that if a moderator came across an 

ad containing a link to a ''sex for money'' website, the moderator should add the link to a 

list of banned tem1s but "don't bother removing it from the current ad." 

102. On September 4, 2014, Backpagc was served with a brief that had been filed 

15 by NCMEC in a !awsl11t in Washington state court Tn this brief: NCMEC critidzed the 

16 sincerity of .Backpage' s efforts to prevent child sex trafficking: ''Backpage has. repeatedly 

17 claimed in public statements and court filings that it is v,,iorking to reduce child sex 

18 trafficking on its V-/l+,sitc. The unpleasant reality is that Backpagc publicizes can.'.foi!y 

19 selected operational processes as a subterfuge to avoid increased scrutiny, while providing 

20 traffickers with easy access to an nniinc venue to sell children for sex, 1n practice, 

21 Backpage's stated interest in doing son1cthing meaningful to stop child s.cx trafficking ads 

22 on its site is apparently overridden hy the enorrnous revenue H generates. from its escort 

23 ads., including ads sc11ing children for sex:i 

24 

25 

26 

27 

28 

103, On March 17, 2015, a law enforcement officer with the Ca1ffornia 

Depart1nent of Justice spoke with a Backpagc representative concerning the prevalence of 

blatant prostitution ads on Backpage, ln response, the representative did not dispute tJ1c 

ofl:iccr's characterizatfon and said the internet and. prostitution weTe not going away, 

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1 

2 

3 

4 

5 

6 

7 

104. On July 30~ 2015, a document entitled "trainingJuly2015" was distributed to 

Backpagc 's moderators. This training manual specifically told moderators that, if they saw 

a photograph depicting "a person [whoJ looks young/minor," they should "approve dont 

delete the ad unless it has a banned term." The training manual also identified, under the 

heading "THESE ARE .ALL OK.A Y," a Jong list of terms that are indicative of prostitution, 

such as '"99% CUM B.ACK. FOR JvlORE/' '"car service," and "loHipop speciaL' 1 

105, In or around August 2015, as part of a l.awsuit in 1HimJis} Backpagc was 

8 served \Vith an affidavit from a detective employed by the Seattle Police De:partmcnt. In 

9 this affidavit, d1c detective avowed that '"[t]o date, no Detective withjn the Seattle Police 

10 Depari.mcnt's Vice/High Risk Victims Unit has ever found a legitimate 'escort' (person 

11 who charges simply for companionship with no offer of sex) or "rnasseuse' (person offering 

12 legitimate and licensed massage therapy rather than sex) while responding to ads placed in 

l3 these categories on Backpage,com" and that "'every tim.e the Seattle Pol-ice Depm:tmenfs 

14 Vice/High Risk Victims lJnit has responded to an ad in the adult section of Backpage,com1 

15 we have found that the ad was a posting for iHegal activity," 

16 l 06, In or around August 2015.1 during the same hn-vsuit in JUinois, Backpage was 

17 st~rvcd \vith a different affidavit from a detective employed by the Boston Police 

18 Depa.rtment. In this affidavit, the detective avmved that "Backpage.com is the number one 

19 site in Boston for prostitution and sex trafficking," that his unit had "'[s]focc 2010 ... 

20 arrested over l 00 buyers of sex of both adults and minors through Backpago,com ads,'; and 

21 that "nearly aH the cases we find ass()ciatcd with it [Backpage] involve pim.p controlkid 

22 prostitution." 

23 

24 

25 

26 

27 

28 

107. On October 7, 2015, PADILLA received an email from another .Backpage 

employee (which was later fonvarded. to VAlJGlIT) disclosing that there \Vero '"n1assivc 

mJmbcrn of live ads with banned tcnns and pictures out on the site.'' 

108. On Deccn1ber 9, 2015, Backpagc received an email from a reporter stating 

that "[o]f the 359 sex trafficking incidents Toronto Police have been involved in since 

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1 

2 

3 

4 

5 

6 

7 

8 

2013, every single girl that was rescued 1-vas advertised on Backpagc,H The email also 

asked: ''Why has.n"t Backpagc closed down the adUlt escort ads portion of its site Wm 

Craigslist when it's known that nnderage girls are being exploited via Backpage?" 

109. ln or around January 2016, Cornpany A was retained to serve as a payment 

processor for som.e of Backpage's \vebsitcs, On April 29, 2016, Company A informed C.F. 

that it had conducted "a review of your \<\'cbsite, <'Ind unfortunately we had to suspend your 

account ... [because] advertising of illegal activities is strictly forbidden." 

110, Beginning in or around January 20 U\ Bm..:kpage)s moderatocrs were 

9 instructed to stop removing ads that contained the phrase "(}FE." For cxmnph.\ cm January 

IO 28, 2016, VAUGHT was sent an email from a Baekpage moderator explaining that '"As far 

l l as lam aware we arc no longer rcrnoving ads for GFE," Similarly, on M<.'trch 9, 2016, a 

1.2 Backpagc rnodcrntor sent an email to his coworkers explaining that '"Andrew [PADILLA] 

1.3 and I talked about the GFE thing, going forwa.rd ,ve will not be removing ads for GFE'' 

14 and clarifying "this includes even gfo \.-vith price.'~ A.nd again, on March 25, 20 l 6, an email 

1.5 was sent to Backpage's 1:no(ku-ation staff stating that ''\Ve are no longer rernoving ads for 

1.6 'GFE' or 'PSE. '" 

1.7 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

I:! L In fad, the BACKPA.GE DEFENDAN'fS repeatedly ackmAvledged that the 

term ''(1FE" (girlfriend experience) is a coded term for prostitution, For example: 

.. On October 26, 2010, SPEAR., l-lYER, and PADILLA received an email 

from C.F, that explained: "No coded sex act for money: GFE,, PSE, BBBJ, DATY, etc,~' 

" On May 4, 2011, HYER sent an email to PADILLA and others identifying 

GFE as a "code word' 1 that should be forbidden, 

" On August 31, 2011, PADILLA and CF. excha11ged emails in ,vhich they 

discussed a Iist of 100 •'solid sex for money terms.'' The list included "GFE "" girlfriend 

experience." 

" On November 2, 201 l., P/\DTLLA and. VAUG·FIT received a.n email from a 

co-vvorker idcntif)'ing GFE in a list of "sex phrases and coded terms" that arc ''not 

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1 

2 

3 

4 

5 

6 

112. HYER, PA_DJLLA, and other BACKPAGE DEFEND/\_NTS pcTiodically 

received a "Gong1e alert" when articles discussing Back:page appeared in the news.. :tvlany 

of the ne\vs articles identified in these alerts discuss instances in which prostitutes who had 

been advertised on Backpagc were kidnapped, raped, or mu-n:.forcd, 

113. fn January 2017, after conducting a. lengthy invcstigation1 the Senate 

7 SubcornmiHcc on Pennancnt Investigations ("Subcmnrnittee") issued a 50-page report 

8 entitled '"Backpagc.com's Knowing Facilitation of Online Sex Trafficking." This report 

9 concluded, arnong other things, that viii.uaily al! of Backpagc's "adulC ads arc actually 

10 solicitations for illegal prostitution services and that "'Back page has maintained a practice 

11 of altering ads bcfoTe publication by deleting \Von.ls,, phrases, and i1nages indicative of 

12 criminality, including child sex trafficking . . . . Those practices served to sanitize the 

13 content of inm.m.1ernbk advciiisements for 1!1egal transactions------cvcn as Backpage 

14 represented to tho public and the courts that it merely hosted content others had created." 

15 l l.4. ln response to the Subcommittee's: report, Backpage purported to shut dcrwn 

16 the '"adult" section of its \:Vcbsite. However, the prostitution ads simply migrated to other 

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

18 

19 

20 

D. ~ptcrn.ationa1 Operations 

115. ln addition to facihtating prostitution through its U.S. website, Backpage has 

also facilitated prostitution through .its websites in foreign countries, 1n this context, 

21 Backpagc o:fkn al:Iirmatively creates the content of the ilkga1 prostitution ads being 

22 published. 

23 116. Around 2013 or 2014, Backpage hired a Philippines-based comp,my 

24 (Company B) in an attempt to increase the p.mfitability of Backpage's i:ntcrnationa.l 

25 operations. Company B's cn1p!oyecs vverc instructed to (I.) visit rival prostitution ;,vcbsites 

26 in other countries., (2) obtain l11c email. addresses of prostitutes who \Vere posting ads on 

27 • those websites (often by falsely posing as prospective customers), (3) use tho information 

28 

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• l from the other website to create a competing prostitution ad on Backpage (a process 

2 referred to internally as "preboarding")1 and then (4) transmit the nc\v ad to the prostitute, 

3 often using the previously-harvested email account infonnation, in an atternpt to persuade 

4 the prostitute to becon1e a Backpage customer. Company B's employees were paid 

5 bonuses based on the amount of ad revenue tbey generated for Backpagc using these 

6 techniques, 

7 117, Backpage's executives. were folly aware of the phm to use Conrpany B to 

8 create prostitution ads outside the United States. For example, on or around November 6, 

9 201.3~ C.F. made a presentation to LARKIN, SPEAR) and BRJJ.NST, Among other things, 

IO this presentation smmnarized Backpage's plans for <•International Planning and 

I 1 Ex.pans.ion,'' One of the plans was to use the Philippines as a "test'; market and hire Filipino 

12 contractors to '\.::ontact hy email leads, secure email address, add ad and email address in 

13 [cornputcr system] and assign to American staff An1erican sta:ff rnakcs contact" 

14 l.18. On August 7, 2014; HYER sent an email stating that Cornpany B was "an 

15 ef1J.d.ent and cost effective \Vay fr.ir us to bring new users to back.page." This email. al.so 

i 6 contained the following smnrnary of how Company B would operate: ''Process after hiring 

t7 company offering BPO services: l. Backpagc provides BPO \-vith sites, categories & 

18 countries to target. Backpage also provides sample 'scripts' and exarnplcs of phone 

I 9 calls, 2. BPO contacts users via phone from sites backpage provided, obtains user email 

20 address & permission to preboard ad. 3, BPO prcboards ad as pnblic user. 4, After ad is 

21 proboarded, usorn receive verification link to verify the ad!' This email also stated that 

22 Hackpagc would of:fi:r a ''bonus per verified authenticated ad." 

23 119. On April 10, 2015, a "five-year business plan" \Vas emailed to LARKIN, 

24 BRUNST, SPEAR, and CF. One of the goals for 2015 \Vas ·'Off shore marketing staff in 

25 the Philippines to grow to 166 and main task is international rmtrkct content acquisition." 

26 Thi::; email also included a separate attachment stating that H''{ER should he considered for 

27 prmnotion because "hfa strengths arc strong marketing and revenue growth skills" and he 

28 

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I had been "heavfly involved in the user experience dcveloprnenf' and that VAlJGI-lT should 

2 . ht~ cornridered for a promotion because "[h]cr strengths .include six years of experience 

3 rnanaging moderators." 

4 120. On JVlay 15 1 201.5, a Co:mpany B employee posing as a Backpagc ernployee 

5 sent an email to an apparent prostitute. The subject line was "Offering ·Free Advertiserncnt 

6 from Backpage.corn" and the text of1he crna.11 sought to persuade the prostitute to "upgrade 

7 your ad with sponsor placement or automatic repost." ln response, the prostitute wrote 

8 back that she had "managed to activate rny ad and could bny credits as wdL thanks fcff 

9 your help. I'm traveling today to fLondon] how can I change my location.n This email 

:l O exchange \.Vas later forvvankd by HYER to C. F. with a cover note stating: ''1.I"Jdcal scenario 

1 l. fnr [Company B] agent --- user activates ad, user purchases credit." 

l.21., On December 14, 20 ! 5, C.F. was part of an email exchange concerning an 

13 ad that had an IP address associated with Coxnpany B. This em.ail contained the following 

:l 4 descriptfo-n of Company B's process for creating and selling prostitution ads on Backpagc: 

15 (1) "Staff found lead in assigned area.'' (2) "Staff entered all relevant into [database] 

:l 6 (phone/e1nai1/ctc. )" (3) «staff called lead to discuss creation of free ad" (4) Staff created 

:! 7 free ad for .k:ad (verification email sent), (5) Staff1:b1lm-ved under with an email reminding 

J 8 lead of phone conversation and detailing verification of ad.,; 

19 

20 

2l 

22 

23 

24 

25 

26 

27 

28 

Select Victim Surmnaries 

122. Between in or ztrm:md 2009 and 2013, Victirn ] was sold for sex, through the 

use of Backpage ads., i-n Ohio~ Indiana, and Georgia. Victim l's Backpage ads often 

included words and phrases that were indicative of prostitution, such as ''roses" (money), 

On at least one occasion, Victim I. contacted Backpage after a proposed ad had been 

rejected because it contained banned words and phrases. In response, a. Backpage 

representative coached Victim l m.1 how to re-write the ad using different words, Victim 

l's trafficker took an of the money that \Vas earned through bcr acts of prostitution. 

123, Bet\vecn in or around 2009 and 20 l 1 i Victim 2 was sold for sex, through the 

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l 

2 

3 

4 

5 

6 

use of Backpage ads, in Arizona, Georgia, North Carolina1 Texas, New York~ New Jersey, 

and Louisiana. Victim 2's trafficker draHed her Backpage ads and Victim 2 initially did 

not know she was being nfiered on Backpage, The ads contained ,i.lords and phrases to 

make customers believe Victirn 2 was "baxely legal"' and also contained words and phrases 

indicative of prostitution, such as "roses" (money), 

124, Behveen in or around 2009 and 2012, Victim 3 was sold for sex, through the 

7 use of Backpage ads, in Colorado and North Dakota. Victim 3's pimp instn.icted her to 

8 reviev•/ existing prostitution ads on Ba.ckpage to learn how to draft her o,..vn ads. During a 

9 pmtion of this period, Victim 3 was required by her pimp to make \vcck-long trips to North 

IO Dakota to work as a prostitute. During these trips, \vhlch would ge:ncrate as much as $2 ,()00 

I 1 in prostitutfotHfori vcd revenue each day, Victim 3 was fon:x.id to leave her children at home 

] 2 in the care of her pimp. 

]3 125. Tn or around 2010, Vict1m 4 \Vas sold for sex~ through the use of Backpage 

14 ads, in Washington. During this period, Victim 4 was. a juvenile ( 15 years old), Victim 

15 4's pimp drafted the ads that were pl.aced on Backpage. The wording of these ads was 

I 6 edited by Backpage before publication. The ads contained words: and phrases such as 

17 ''\V'E'L'L W'(YR'T'U I'T***1\***150lTR'; and "IT WONT TAKE LONG AT ALL'' -.- ... , 

I 8 and includ~.xi pictures of Victim 4 in provocati vc positions showing her breasts and 

I 9 but.tocks. 

20 126. Between in or around 201 I and 20 ! 6, Victim 5 was sold for sex, through the 

21 use of Backpage ads~ in l\tlassaclR1setts and .Rhode Island. During much of this period, 

22 Victim 5 was a juvenile (14-19 years old), Victhn S's female pimp instructed Victim 5 

23 that Backpage \Vas the safest place to advertise because it did not require age verification. 

24 On one occasion, Backpage declined. to accept a proposed ad that indicated Victim 5 \Vas 

25 only 17 years old. ln response, the ad was simply resubmitted with a new- (false) age of 

26 19. On other oec.asim1s~ Backpage removt~d provocative pictures of Victim 5 fro:m ads and 

27 then allowed edited versions of the ads to be published. Victim. S's Backpage ads included 

28 

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words and phrases that were indicative of prostitution, such as "ro5c$" (money) and "back 

2 door" (anal sex} Some of the customers who responded Victim 5 's Backpage ads fi)rced 

3 Victim 5 to perfonn scxua1 acts at gun point, choked her to the point of having seiz11rcs1 

4 and gang-raped her. 

5 127. ln or a.round June 201.2, Victim 6 was sold for sex, through the use of 

6 Backpagc ads, in 1\rizona, H.er traffickers utilized Backpage ads that did not offer a 

7 specific pt'.n;on hut instead generally offered a woman ,;,.vith a particular type of hair color 

8 and build. On J unc 22, 201.2, Victim 6 was d.ispatched to a customer who had responded 

9 to a Back.page ad foat:nring «Nadia;' who was described as a slender bnmctte woman. 

10 Upon her arrival at the location, Victirn 6 was stabbed to death. 

]] 

12 

13 

14 

15 

128. Between .in or around2012 and 2015, Victim 7 was sold. for sex, through the 

use of Backpagc ads, in \Vas.hington and Oregon. Victim Ts pirnp drafted the ads that 

were placed on Backpage. The wording of these ads was edited by Back.page before 

pubhcatiun. The ads contained provocative nude pictures. of Victirn 7. 

129, Between .in or around 2013 and 2014, Victim 8 was sold for sex, through tho 

16 use of Backpagc ads, in Maine, Connecticut, and .Massachusetts. During this period, 

l 7 Victin1 8 \Vas a j uvenilc (15 years o[d). Victim 8' s uncle, as wdl as his friends, placed the 

18 ads on Backpagc, which indmlcd wo_rds and phrases that were indicative of pmstitution, 

l. 9 such as "roses" (money), "fetish friendly/' and 150 for 1/2 hour, 200 for foH hour. 

20 Through these ads., Victim 8 \Vas forced to do '"in-catls" ( vvhcrc she 'was raped in hotels) as 

21 wen as "out-caHs" (viihere she 1,vas raped at other locations chosen by the ,men paying for 

22 her). 

23 130. Jn or around 2013, Victim 9 was sold for sex, through the use of Backpagc 

24 ads, in Fl.or.i<la, Victim 9's pimp taught her how to use codti words in her Backpage ads to 

25 indicate how much she \Vas charging f<1r certain sex ads. Victim 9 \.Vas brutally attacked 

26 by her trafficker1 causing bruises and a fractured cheek bone. 

27 

28 

13 L Between in or around 2014 and 2015, Victirn 10 \Vas sold for sex, through 

- 33 -

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2 

3 

4 

5 

6 

7 

9 

the use of Backpage ads, in Calif{}rnia and Arizona. During some of this period, Victim 

10 \Vas a j uveni1e (17 years old), An associate of Victim 10' s pimp took pictures of 111:.ir 

and drafted. the ads that were placed on Backpagc. The Backpage ads contained words and 

phrases such as "'NEvV rN TO\VN," ''sexy sweet," and '•s,.,vcet like honey but super hot like 

fin/' and. included pidurcs of \lictim 10 in provocative posit.ions shov-.ring her legs, 

stomach, shoulder, a.nd buttocks. 

132. Bet.ween in or anmnd 2014 and 2015, Victim U. ,vas sold for sex, through 

the use of Back page ads, in Arizona, Colorado, l'vhnnesota, Oregon, California, Montana, 

Nevada, New Jvicxico, and Utah. Thi:.i Backpage ads contained words and phrases 

10 fodicativc uf prostitution and included pictures of Victim 1 I in provocative positions. On 

11 smne occasions, Backpage \<\'OUld remove certa.in explicit photos from t11e ads but publish 

l.2 the rernaining text and other photos. Victim J l's trafficker gave her drugs, took her 

l.3 identification docu.ments, sexuaHy assaulted her with a fireann, and forced her to work fulll. 4 time as a prostitute. 

l.5 

l.6 

l.7 

l.8 

l.9 

20 

21 

22 

24 

25 

26 

27 

28 

133. In or around 20 ! 5, Victim l 2 was sold for sex, through the use of Backpage 

ads, in California and Arizona, Victim 12 -..vas first adve1tiscd on Backpage in San 

Bernardino, California, but rnoved to the Phoenix metro area becaust~ the Su.per Bowl. was 

being held there. Victim 12's advertisements on Backpage contairwd words and phrases 

such as "New In Town" and "Sexy Dark Asian Bombshell with a Nice & Tight {Booty}" 

and included pictures showing Victim 12 's kgs1 stomach, shoulders and buttocks. 

134. In or around 2015, Victirn l.3 \Vas sold for sex, through the nsc of Backpagc 

ads, in Cafrfi?rnia. During this period1 Vi dim l. 3 was a ju venifo ( l. 5 years old). Victim 1 J 

and her trafficker both posted the Backpagc ads, '-NhkJ1 fa1sdy represented that Victim. 13 

V'hlS 19 years old and sho1,ved pictures of her face and body, On at least one occasion, a 

Backpage representative contacted Victim 13 with instructions on how to fix an ad so it 

could he published. 

:U5. 1n or around June 2015, Victim 14 was sold for sex, through the use of a 

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l Backpagc ad, in Texas. This ad contained \Vords and phrases such as "fon1 young, exotic1" 

2 "Ready to be your fantasy girL" "OUT CALLS ONLY," and "NO BLACK MEN" and 

3 included piclures of Victirn l4js stomach, breasts, shoulders, and buttocks, On or around 

4 June 201 2015, Victim 14 was nmrdercd by a customer. Aftenvard, the customer attempted 

5 to destroy Victim l.4's corpse by lighting it on fire. Victim M's hither Iater contacted 

6 Backpagc tu request that the ads shovving his deceased daughter be removed. Ba.ckpagc 

7 did not irnmcdiatcly comply with this request 

8 136. Jn or around June 20 l 5, Victim 15 was sold for sex, through tlw use of 

9 Backpage ads, in Texas and Louisiana. 'fhcse ads contained \Vords ~md phrases such as 

l. 0 "Thick Glass of Chocolate fvhlk Looking for a CloodTim.e ! ! !" and ''"sexy certified freak" 

11 and contained pictures showing Victirn l5's legs, shoulders and buttocks. On June 10, 

1.2 201\ Victim 15 was forced into a vehicle with her trafficker, who \Vas attempting to take 

l. 3 her to Texas against her \vilL In an attempt to escape, Victim 15 jumped out of thr;.i vehicle 

l.4 onto 1ntcrstate l 0 and ,vas kiL!cd after being hit by several vehicles at high speeds, 

15 

16 

17 

18 

19 

20 

21 

137, In or around July and August 2015, Vkti.m 16 was sold for sr;.~x, through the 

use of Hackpagc ads, in Michigan., These ads contained \Vords and phrases such as 

"'OUT CALLS ONLY,'' "Juicy Caramel Lady On Duty/' "'Sexy, Erotic Canund Dream," 

and "No Thugs, Pimps Or Wcirdos'1 and contained pictures showing Victim I 6's breasts, 

legs~ lips, buttocks, and face, On August l.5, 20 ! 5, Victim 1.6 was murdered by a customer. 

A.!lenvard, the customer dumped her corpse in a park 

13 8. Between in or around 2 O! 5 and 20 16, Victim ] 7 was so Id for sex, through 

22 the use of Backpage ads 1 in Arizona and CalH<)mia, Victim l 7 averaged ten customers a 

23 day during this thne and turned over all of her prostitution earnings (approximately $1,500 

24 per day) to her pimp. An associate of Victim I Ts pimp took pictures of her and drafted 

25 the ads that were placed on Hackpage. The Backpage ads contained ;,vord.s and phrases 

26 such as ""IN/CALLS ONLY," '"'r'm here to make your \Vil<lest frmtasies come true!"' and 

27 «sorry, but NO BLACK MEN'' a.nd indudcd pictures of Victim 17's buttocks and face. 

28 

DOJ-BP-0004598498 

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1 

2 

3 

F. Money Laurnkring_Activitics 

139. Hackpagc's custon1ers have ovcnvhehningty used the proceeds of criminal 

activity (i.e., money earned fron1 pimping and prostitution) when purchasing ads on 

4 Backpagc. In addition, because Backpage's publication of such ads is an independent 

5 crime (e.g:., violation of 18 U -8.C. § 1952t the fees it collects fmm nrntomcrs posting 

6 prostitl1tlnn ads·······CSt1mated at more than $500 million since 2004 ····Constitute the proceeds 

7 ofunlawful activity. 

8 140. For these and other reasons, banks and financial institutions have repeatcdl.y 

9 refused to do business with Bar..kpage. In response 1 the BAC.KPAGE DEFENDANTS have 

l.O pursued a variety of money laundering strategies, For exampk, on August 27s 2013~ C.F, 

l.1 was for\.varded an array of emails from Backpagc customers w·ho were complaining that 

l.2 their credit card companies had refosed to process Backpage-rdatcd transactions. One 

13 customer wmte: "}lave you resolved. the issue of Chase Bank not honoring payment for 

l.4 you for ethical reasons?'' C.F, forwarded these co1nplaint emails to LARK.IN, SPEAR, and 

15 BRUNST and proposed, as a "solution" to the problem, that Backpage reconfigure its 

16 website to fool credit ca.rd companies into believing the charges \.Vere being incurred on a 

17 different website. 

18 14 L During a November 20 :13 presentation by C.F. to LARK.IN, SPEAR, and 

19 B.RUNST, CF, again discussed strategics for fooling credit card companies into bdicving 

20 that Backpagc-associated charges were being incurred on different websites, inchtding a 

21 • proposal to set up shell companies without any apparent com1cctio11 to Backpagc C"creatc 

22 new co111.panics with new principals") and use their ba.nk accounts to accept payment 

23 Another "solution" -,.vas to "allow users io fund an account thru several other sites" that 

24 ''have no adult or images." 

25 

26 

27 

28 

142, On November 6, 2013, LARKIN, SPEAR, and BRUNST received an email 

entitled '\)pt.ions for the future of Backpage." This email discussed various strategies for 

creating new entities to process Backpage-rdated payrnents "without ever disclosing ties 

DOJ-BP-0004598499 

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l 

2 

3 

4 

5 

6 

7 

8 

9 

to Backpagc.'' 

143. On April L 2015, BRUNST and C,F, were infon:ned that Mastercard \Vas 

"snooping around'' Backpage and might stop processing payrncnts for Backpagc, .fn 

n.~sponse, C.F, offered several suggestions for setting up ne\v payment channels that \vouM 

concea.1 Backpuge' s involvernent. One such proposal was to begin routing Backpagerclatcd transactions through banks located in the country of ·Mauritius. In response, 

BRUNST stated: "Didnt we go down the Mauritius path once and the banks had the same 

issue with our contcnt't' 

144, Notwithstanding these strategies, the three major credit card com.panics 

l. 0 stopped doing business with Backpage. On or about April 30, 2015, Backpagc learned that 

l. l American Express wou]d no longer all.ow its cards to be -used for any purchases in 

!.2 Backpage 's adult section. In or around July 2015, .Backpage learned that Mastercard \-vould 

13 no 1ongcr allow its cards to be nsed for Backpagc-rdated. transactions. vVhen discussing 

14 this decision, MasterCard stated that it '•has rules that prohibit our cards from being ui:;t~d 

I. 5 for illegal activities." Around the same time, Backpagc learned that Visa would no longer 

1.6 

1.7 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

allow its cards to be used for Backpagc-rclated transactions, When discussing this 

decision, Visa stated. that its "rules prohibit our -network from being used for iHegal 

activity." 

145, Simi!ady, some banks closed accounts that were held by Backpage (or 

Backpagc-related entities) out of concern the accounts were being used for iUegal purposes. 

For cxanipk, on Ap-ril 2, 20! 4, BRlJNST received a letter from U.S. Bank that \Vas 

addressed to "Bac-kpage.com." The letter explained; •'Dear fod .. , please be advised that 

we have elected to close your Account with us," 

146, Baekpagc responded to these developments in several ways. One ,vas to 

encourage customers to send checks and money orders to a .Post Of:fke box held in the 

mune of a seemingly-unrelated entity ca1k<l Posting Solutions LLC (""Posting Solutions1') 

and give sud1 customers a corresponding credit on Backpagc, For example, on July 31, 

- 37 -

DOJ-BP-0004598500 

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3 

4 

5 

2015, C.F. exchanged email correspondence with a representative from a payment 

processing company. In this ernai1, C. F, identified hirnsdf as the CEO of Posting 

Solutions, described Ba.ckpagc as a "brand" operated hy Posting Solutions, and explained 

he was seeking to "find a way to posit.ion payn1ents under another company,'' 

14 7. The foHov-/ing episode provides an example of how the Posting Solutions 

6 :payment process Viiorked. On October 16, 2015, Backpage received an email fro111 a 

7 customer complaining ab<-iut her .inability to pay for ads using a credit canL b.1 response 1 a 

8 Backpage representative expia.ined------in an email exchange later fi)rwan:led to VAUGHT-----

9 that "[i]f you would like to pay for upgrades or buy credits, we &mggest posting with 

10 alternative payment rnethods such as Bitcoin. If you are in the United States, you can also 

ll pay by check or 1noney order. Please make payable to 'Posting Solutions.' WE CAN 

12 ONLY ACCEPT ClJECKS OR MONEY ORDERS MADE OUT TO 'POSTING 

13 SOLUTIONS.' Posting Solutions. Attn: A.ccounts. P.O. Box 192307. Dallas, TX 75219, 

14 Please send through the United States Postal Service. FedEx, UPS, or other mailddivery 

15 alternatives cannot deliver to a. .P.O. Box. When sending your payinent please be sure to 

16 include your email address, Pl.ease do not make your payments out to hackpagc.com as \VC 

17 wiH no longer be able to accept them_,, 

18 148. Behvecn around September 2015 and Jmw 2016, over $7.1 million of checks 

l 9 and money orders sent by Backpagc customers '1Nere deposited .in bank accounts held by 

20 Posting Solutions. 

21 

22 

23 

24 

25 

26 

27 

28 

149. Backpagc also utilized a d.iffercnt entity, caHed Website Technologies, LLC 

("Website Technologies"), to process Backpage-rdatcd funds a.nd took steps to 1nakc it 

appear that Back.page and Vlebsite Technologies were independent entities. For example, 

on March 10, 2014~ BRUNST, SPEAR, and others participated in an email exchange Vi/1th 

the subject Linc "Website Technologies vs Baekpagc (Vendors, audits, risk assessrnents, 

ernai1)." During this exchange~ one person stated "!C.F.] and l were just discusi'>ing 

company mnnes and the possibility of updating our email addresses to 

DOJ-BP-0004598501 

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vvchsitotcdmo1ogics,com. '' ln response, BRUN ST cautioned: ''W' e need to think this thrn 

2 or aH the work to separate it from BP will be lost'' Similarly, on April 3, 2014, BRUNST 

3 sent an email to SPE/\.R and others explaining that "[b]y rvtay I. we wiU have to be out of 

4 US Bank. \~Tc w1U move all hanking under Vv'ebsite Technologies at [a different bank, 

5 HMO flan-is]!' 

6 150. ln .many instances, Backpage-related money that vvas initially deposited into 

7 accounts hc!d hy Posting Solutions was later transmitted to accounts held by \V cbsite 

8 'fed1nologies. For example: 

9 

]0 

]l 

12 

.. On October 27, 2015, C\F. received an email entitled "'Two packages corning 

your vvay1 (MOney Orders)." 'fhe entail stated that two UPS packages filled \.Vith m.oney 

orders \Vere being scnt ...... one containing $47,647.25 ofn:1oney orders made out to Backpagc 

and tho other containing $52,251.48 of money orders made out to Posting Solutions. 

.. Similarly, on November 16, 2015, C.F. received an email entitled "'Three 

14 packages sent today $441,408.69.'' The email stated that three packages filled with 1noney 

l5 orders were being scnt--.. --one containing $129, I. 93.61 of money orders made out to 

16 Backpagc, another containing $244,353.63 of money orders made out to Posting Solutions, 

17 and the hrnt containing an additional $67,86:! .75 of money orders made out to Posting 

18 Solution:,;, 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

And again, on January 29, 2016, a Posting Soh1tiuns account wired $2,4 

million to a \Vebsite Technologies account. PADILLA and C.F. vvere both authorized 

signers on the recipient account. 

151. fo addition to receiving mi111{ms. of dollars from Posting Solutions, the 

W cbsite Tcdmologim, accounts also served as. the repository for rnillions of dollars of wires 

from international bank accounts controHcd by Backpagc-associated entities. For example, 

betvvcen January 2015 and December 201.6, \Vebsitc Tcdmo1ogics accounts received over 

$45,4 n1iHion in \Vire transfers from Backpage-associatcd bank accounts in Licchtt.'.nstein, 

over $30. I. 1nfrlion in Vv'frc transfers from Backpage-assoc.iated bank accounts. in Iceland, 

- 39 -

DOJ-BP-0004598502 

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3 

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6 

and over $3.9 m.illion in wire tnnwfors from Backpagc-associated bank accounts in the 

Netherlands. 

152. In many instances, the next stage of the money~l.aundering: process was for 

money to be Vi"ired from \Vebsite Technologies accounts to hank accounts held by a 

different entity caHed Cercus Properties LLC ("Cereus Prope1iks)'). The authorized 

signers on the Cereus Properties accounts included SPEAR and BRUNS'I'. Bet,veen 

7 around December 2015 and October 2016, Website Technologies accounts sent wire 

8 transfers totaling over $47 million to accounts held by Cereus Properties. 

9 

IO 

11 

12 

13 

14 

153. Accounts held by Cereus Properties also received money d.ircct1y frorn 

international bank accounts controlled by Backpage-associated entities, For example, 

bchveen around August 2016 and Novernhcr 2016, Cercus Properties accounts received 

over $11.3 rnillfon in deposits and \Vire transfers from Backpage-associated acconnts in the 

Netherlands. 

154. Afr.er money reached Cereus Properties, large portions of it were funneled 

15 back to Backpagc or to certain BACKP.AGE DEFENDANTS. For example~ between 

16 Janua.ry 201.6 and January 20171 LACEY (and LACEY's fami1y n1ernbers) received 

17 distributions totaling over $30,3 million and LARKIN separately received distributions 

I 8 totaling over $21 million. 

19 

20 

2! 

22 

23 

24 

25 

26 

27 

28 

! 55. Backpage also fo.rthercd its money laundering efforts through the use of 

bitcoin processing companies. Over time, Backpage utilized companies such as CoinBase, 

GoCoin, Paxful, Krakcn, and Crypto Capital to receive payments from customers and/or 

route money through the accounts of rnlated companies. 

I 56, Backpage also furthered its rnnncy laundering efforts by developing ways frw 

custornern to purchase ads using gift cards issued by third-party vendors. This process was 

described in a July 23, 2015, ernail exchange between various Backpage employees on 

which HYER and others ,vere copied. This exchange included the foHo\ving: "!_W]ha1 if 

we used a customers ["sieJ payment method, say visa prepaid ca.rd, to buy [bitcoin] from 

-40-

DOJ-BP-0004598503 

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our selkr account . , . giving said bitcoin to our catch-aH walkit dse\.vhere (instead of to 

2 user), sinm1tancous1y adding credits/purchasing paid ad or upsells? From the user's 

3 perspective they just input their prepaid card and get their credits or purchase.~' 

4 COUNTJ 

5 (Conspiracy} 

6 1.57. The fodual allegations 111 Paragraphs 1-156 are incorporated by reference 

7 and re-alleged as though fully set forth herein. 

l 58. Beginning in or around 2004, and continuing through the present, in the 

9 District of Arizona and elsewhere, defendants LACEY, L/\RKIN1 SPliAR, HYER. 

10 PADILLA, and VAUGHT~ and others kno\vn and ur1kno<vvn to the grand jury, knowingly 

11 and intentionally agreed, cnnfoderated, and conspired \v1th each other, and \Vith others 

12 k11cnvn and unknown to the grand jury, to comrnit the following offenses against the United 

13 Stales: 

14 

15 

16 

17 

18 

18 O,S.C: § l.952(a)(3)(A) (Travel Act······Facilitate Prostitution). 

OBJECT OF 'l'IIE CONSPIRACY 

159. The object of the conspiracy was to obtain rnoney. 

MANNER AND M·E1\NS OJ<' THE CONSPIRACY 

160. The .manner and means of the conspiracy are described. in paragraphs 1-156 

19 above, incorporated by reference and re-alleged as though fuHy set forth herein. 

20 OVER'f ACTS 

21 16 l. Overt acts were cmnmiited in furtherance of the conspiracy, includfog but 

22 not limited to those described in paragraphs 1-156 above, incorporated by reference and 

23 re-alk:ged as though fully set forth herein. 

24 h1 violation of :!8 U.S.C. § 371. 

25 

26 

27 

28 

DOJ-BP-0004598504 

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2 

3 

4 

5 

COUNTS 2-5_1 

(Travd Ad-Facilitate Prostitution) 

162, The factual allegations in ft;;i.ragraphs 1 ~ l. 6 l are incorporated by reference 

and re-alleged as though fully sot forth herein. 

163. On or about the dates set forth below, each instance constituting a separate 

6 count of this l:mHctment, in the District of Arizona and elsewhere, defendants LACEY, 

7 LARKJN, SPEAR, HYER, PADILLA, and VAUGHT, a.nd others known and unknown to 

8 the grand jury, used the mail and any facility in interstate and foreign commerce \.vith intent 

9 to otherwise promote, manage, establish, carry on~ and facilitate the promotion, 

l.O 1nanagernent, establishment, and carrying on of an unlavvful activity, to wit: prostitution 

l.1 offenses in violation of the laws of the State .in \Vhich they arc coimnitted and of the United 

12 States, including but not limited to Title 13~ Arizona Revised Statutes, Section L3-32l4, 

l. 3 and thereafter performed and attempted to perform an act that did promote, manage, 

14 establish, cm:ry on, and facilitate the promot.ion1 management, cstablishrncnt, and can:ying 

15 on of the unfavvful activity, as fo!luws: 

l.6 

17 

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28 

~--···························--- --- ----····························----

Count Q!!!£ Description -----'-···························· 

2. 

---·······························---

Sept 10, 2013 Publish ad depicting Victim 5 entitled "Get freaky Tuesday . 

, Come spend ur day ,vith us -- 19," with accompanying text 

"Doin 1ncaHs and out.calls'' ··························---

Jan.27,2014 

---·······························-------- ----··················· 

Publish ad involving P.R. entitled ''50 Red R*O*S*E*S 

S*P*E*C*l*A*L - DONT MJSS OOT!n!!" ---································--- ---·····························----- __ ____, 

Jan.29,2014 Publish ad depicting Victim 8 entitled "Puerto Rican marni in 

walpolc area INCALLS --·-19" after deleting une pkturn from 

··-···················· ····--- ----+---t·_!1_c origi.nal.~_y~~.~~~:!!!}.~.tcd ad -----························· 

5, Ja.n. 31, 20 14 Publish ad depicting Victim 8 entitled '"Exotic 1atina, south 

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~-···--··························-- ---------.-.-.-.-.-·---························-------~·-·----······················ 

19'' after deleting one picture from the original1y-s.ubm1tted 

ad ............__ ........ ··················-- --~~~--------···························------·----.-.-.-.-.-.---.---················-----------·· 

6. Feb.6,2014 PnhHsh ad involving PJC entitled "75 Red R*O*S*E*S 

S*P*E*C*I*A>"L - DONT !vUSS OUT!!l!!'' --···························----------~------······················---··~--·······--·································· 

Apr. 20, 2014 Publish ad involving PJt entitled ""50 Red R*O*S*E*S 

S*P*E*C*I*A*L - DON'T MJSS OUT!t!!!" ~--············ ············--------·---~.-.-.-.-.--•························---

8, J'Vfoy 7, 2014 Publish ad involving P.K entitled ·'50 Red R*O*S*E*S 

S*P*E*C*I*A*L - DONTMJSS OU'Tltl!l" -------------· ..................... -1-----------·························---···--···---------························· 

9, May 31, 2014 Publish ad involving P.R. cntitl.ed "50 Red R*O*S*E*S 

S*P*E*C*I*A*L - DONT rvnss OUT!!!!!" !-----•••••••••••••••• •••••---v~--••+---••••••••••••••••••••••••--- •--~ --····················-------·---

!O, Publish ad involving P.R. entitled "50 Red R *O*S*E*S 

S*P*E*C*T*A*L - DONT MISS OUT!!!!!" •~- -1----•••••••••••••••••••--+----v--•-•••---••••••••••••••••••••••--- ~--~•---•••••••••••••••••••••••••----< 

I.L Aug. J9, 2014 Publish ad involving P.R. entitled ''50 Red R.*O*S*E*S 

S*P*E*C*l*A*L - DONT MTSS OOTl!l!ln 

····················--1-- --+--·······················-----~--···--······················-- ·--

12, Nov, 23, 2014 Publish ad depicting Victim 10 entitled '"Ncvv in To\vn Super 

Hot Skinny M.ixcd Cuban (hr! W'ith Long Black lfalr - 1 W' 

---4--••·················---

after deleting.picture frnrn origirutl1y-suhmitted .. ad·····--

13. Jan. 29, 2015 Publish ad depicting Victim. 12 entitled ''Nevv in Town Sexy 

Dark Asain Bomhshefl \vith a. Nice & Tight {Booty} ···· 23" 

--···--·········· .?i:!c,r ddetir1.~ one .P~.ctnrc }!·:~?:::~ .. ~~!e originally-subi!1itt.ed a.~1 .......... . 

14. Publish ad depicting Victim 10 entitled ''NE\\7 IN TOWN 

•·---···•·················--- ~-+-scx.y sweet.European mix?:1Cuban California.girl.··· 21i,_ 

15. Jan. 3 l., 20! 5 Publish ad depicting Victim l.2 entitled. "Ne\.v in Town Sexy 

Dark Asian mixed Bombshell --23" after deleting one picture 

----+-···------··········· .. from the orig1nally-suhmitted .. al_i ___ ----·---··············· 

16. Fcb.4~2015 Publish ad depicting Victim l l. entitled "Upscale Independent 

BRUNETTE BOrvlBSHELL 5-Sta.r Fantasy 26," after ,____······················--·-----~ ····························---·--~--- ·····································-----

DOJ-BP-0004598506 

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, ....... ,. .. _ ___,_····----····· .. deleting pictwcsfrom originally-submitted. a~l----······················-

17. 

] 8, 

Feb. 18, 2015 P1Jblish ad depicting Victim 11 entitled '"Alexis Foxx the 

HOTTEST in town!!! 1 ! ··- 26,'' after deleting six pictures from 

th? originaHy-subrnittcd. ~ ··--······················- ........ ·-~-------

Feb. 26,201.5 Publish ad . .involving P,R. entitled. ""'50 Red R*O*S*E*S 

S*P*E*C*I*A *L - DONT rvuss OUT!! 1 ! !" 

---·-+---··--··········· ·········--------·~------- ---·····················-----------·----···-•~----······················· 

19. May 18, 2015 Publish ad depicting Victim l 5 entitled ''GORCiEOUS ebony 

PLAY.MATE Pt::-rfoct Cmves ... Skills to make ur TOES 

CURL ···- l.9," after ren1oving one picture of originallysubrnittod ad, with accompanying text "you agree ... you arc 

not affiliated 1-vith any law enforcement agency" and "Incalls 

&. Outcalll !!') ····················--···--·- ······················---··~-··--······················ 

20. 

2L 

May F), 2015 Publish ad depicting Victim 15 entitled "Hot & Driping 

Submissive Ebony Playrnatcs ·--· 20,1' after removing one 

picture of originaUy-subn1ittcd ad, with accompanying text 

"you agree, , , you aro not affiliated vvith any la;,v enforcement 

agency" and '"We're ready to pl.case and accommodate aH of 

your needs and wants!! With a mouth that' 11 ROCK your Ll 

······················--

July 1; 201.5 

aml '.~. [pictu~~: .. ~?.!..~:,itJ that'.U ka:? you Pl.~~(}~~.!f.Jbr more.'.~'--·, 

Publish ad depicting Victim 17 entitled. "'AbSoLuTeLy 

AmAziNg CoMe PLaY Wffh Me #1 .!VfoST W'aNtEd SwEeT 

SEXii PlAymate ···· 20t with accompanying text "By 

contacting me you agree that you arc not affiliated vvith any 

form of law enforcem_ent" PER.FEC'f & wrn satisfy your 

___ ------·············· __eycry neeJ;'arrd_ '"IN/q,t.\:~:~s ••• ONL_Y_·"~ ---························ 

22. July 2, 201s Publish ad depicting Victim 17 c.ntitlod "SoXy! ! ·Exotic 

--·· _____ playmatc.can .. me! thegirl.you NEED .. to .. See! -~ 20," wi~h 

DOJ-BP-0004598507 

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28 

---····················· ·-········--·····---·························--···~·--····-································--

accompanying text "I DO NOT OFFER 40$, 50$; 60$ 

SPECIALS" and '"IN/CALLS···· ONLY" ................ ----------~-- ···-························--- --···-·-·--······················--···---····---

23. 

24. 

25, 

Aug. 13, 2015 .Publish ad depictfag Vktim 13 entitled "Young SEXY 

.PUERTO RJC/\N ··· 19," \vhich accompanying text "l do half 

hour sessions that vary in donation prices, 80 for head, 120 

fur hooking up without head and 150 for hooking up v,dth 

head"' 

--I--••·····················~---- -------.----·····••·························-------·-·--·······---·····················---

Aug. 15, 2015 .Publis.h ad depicting Victim ! 6 entitled. '"OutcaUs Now 

.. :!~~:~~~~.:Y.S;urv:y .. Caramc_l Lady (?!_!.!.~:::~\J.LS ·~ow --~23" 

Sept 13, 2015 Publish ad involving PJt entitled "50 Red R*O*S*E*S 

S*P*E*C*l*A.*L - DONT MISS OUT!!tl!" •••---••••••••••••••••••••••••-- ••-~••••--•••••••••••••••••••••••----•v--•••--•••••••••••••••••••---

Nov. 28, 2015 Publish ad involving P.R .. entitled "50 Red R*O*S*E*S 

S*P*E*C*I*A*L - DONT MISS OUT!l!l !" --+···~·~~····--····················--····--· ----······················--··· 

28. 

Apr, 21 0 20 l 6 Publish ad entitled "FinaHy! ! PSE & GFE - Kimber Rae and 

MIA Marie Tog-ether BOOK NOW" ~.-----···················";:... ______ -_~.-----····················--- --~~~------

Nov. 3~ 20 l.6 Publish ad entitled "GFEE New ··· 18" -~-.-.-.•--·············· ······--------···---···················-- ---························ 

Nov, 11, 20 16 Publish ad entitled "M-ind blowing Tiffany. lncaH in Taunton 

···· 37/" with accompanying text "Son GFE .. , Tm real and 

reviewed" ·····················---···--··· -······················--···--··--······················-------·---.~.-.-.-. 

30, Nov, l. 4, 20 I. 6 Publish ad entitled "Top M.odel 2016 Special < Best Looking 

·young Asian' ... ···· 22/} 1.vith accompanying text "Sexy Asian 

Girl lncaU Service" and '\}FE" -....-.-+---- --·······················-------·----~-------··················--···-- ---························· 

3L Nov. 14, 2016 Publish ad entitled "Sometimes Ifs All About The Journey, 

And The Destination ..... Erectile Dysfunctional G F E 

Provider··· 44_," with accompanying test "Yon can find a fow 

current reviews at T'3R xxxxxx#'' and "l have been EROS 

auth(mticatcd'' ·······················--·····--· ·······················--··••-'~·~·--···························--

DOJ-BP-0004598508 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 113 of 129
Case 2: 8-mj-01000-DUTY *SEALED* Document 3-1 *SEALED* Filed 04/26/18 Page 113 of 

128 Page ID #:253 

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33. 

-----·························---------~------ ---•••••••••••••••••••••••-•--••--~w-.•• ••••••••••••••••---

Nov. 19, 2016 Publish ad entitled ''The True (G)irl (F)ri.end (E)xpcricnce ... 

\/isiting November 27th Sunday ,-., PRE-BOOKING 

SPECIAL .. ,, - l 00;' with accompanying text "Let's blur 

restrictions behvccn financial transaction & Romantic 

Connectio11" ····························---- ·-----·····················----

Nov. 241 2016 Publish ad entitled "Top Asian Grand Opening l 001l-'[i Young 

IO(VYo Sexy ... ···· 23," with accmnpanying text "BEST 

1NCALL IN TO Vv'Nr' and '\}FE" -----!--····························-1---··~·--·--·····---····························-- ·--

34. 

35. 

36. 

37. 

Nov. 26, 2016 Publish ad entitled .. J LOVE MEN!l rm a GFE. OutCaU and 

Incall with exception un the JncalU ! ···· 42" ·---························· ···- ••••• ·························---

Dec, 20, 2016 Publish ad entitled ''OMG Sexy Sensual 36DD-24-36 

Stacked Cu!!cge Coed With The Best Mouth Ever! BOOK 

NOW! -24," with accompanying text "I do ALL the things 

Jan. 15,201.7 

YOU Wish 'f..?.~.~!..~.~.~~ Did!!" and "(G).:(F),(E) }~(!.::!!.:/~ .. ~ .. ~.9" 

Publish ad entitled '"Real. & R.eviev11ed Girlfriend 

Thconeswect.1,vceh!y.com ···· JOt with accompanying text 

"250 G FE" ---························--- ---· ----·························---

Apr. 4, 2017 Publish ad entitled "KISSING & GFE KOREAN GIRLS.~ 

---····························----·"--····---······································ ··························---

38, 

39. 

Apr. l l, 20 I. 7 Publish ad entitled "Pettit Sexy #Corey# 4407239339 - 39," 

+----························· .. with ac~~~rnpanying text ".~'.\'.::!P..~.?..~e GFE experience'' 

July 3, 2017 Publish ad entitled "WANNA UANG OUT NO\V UpScale 

Ne\V In Townl c:all ME now for an 1mfcirgettabk visit -- 20t 

·················--1--- ·---· with .. <1~~~?.~:?.Jt~!1Ying te~.! "1 OO?i GFE ,vit!~ ... ~.gQ.:~~ .. ~~~?.}~Jmps" 

40. July ! 5, 2017 Publish ad entitkd "Ready for some fun daddy? This: is your 

chance too have a amazing time - 21 ," with accompanying 

··---·-------·•······················ .. · .. text "Shrn .bDD)\nice tits,. freaky ,_(}FE" 

DOJ-BP-0004598509 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 114 of 129
Case 2: 8-mj-01000-DUTY *SEALED* Document 3-1 *SEALED* Filed 04/26/18 Page 114 of 

128 Page ID #:254 

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----·········· ···············- ·······················-----·---

4L July 15, 2017 Publish ad entitled ··New m town BiGBubhle lfooty 

SWEETLiPS FIOT BODY 24/' with ''GFE'' m 

....................... ___ _ __ ---J... __ accornpanying .text····-----· ,------·························-·---

42, July 21~2017 Publish ad entitled "Pettit Sexy #Corey# 4407239339 ···· JOt 

43. July 23, 2017 Publish ad entitled "_ASIAN GODDESS young - 20;' with 

44. 

45, 

acc(m!P..~\!~.X~Y.W.t.cxt "lfHY'.~o D1sc.r?ct ser~/~:~:~~.?!.1.~l "#GFE" __ _ 

Ja.n. 26~ 20 I. 8 Publish ad entitled "GFE Service Available! Private 

---························ .. Encounters w/ Pa.mpering. Beauty'~--------------------

Jan.30,20]8 Publish ad entitled ''24-! & \Vhite plans area Carf11n Perfoct 

Treat Available No Rush," with "Sweet Sexy GFE'~ in 

accompanying text ................. __._ ________ ~----~---- ---······················----

46, Jmi- 30, 2018 Pubhsh ad entitled ''GFE _REAL HOT Sweet DREAM 

/\M_AZING BEST RELAX" 

---+·······························------- ---··························--- --- ----······························ 

47. 

48. 

Jan. 301 2018 Publish ad entitled "Tall, Slim & Sexy Luxe Goddess * 

NARCISA * Sensual Body Ruh + Fetish Sessions," \vith 

-----l ... ~:~:~:~!.!~:~P..~::nying te:xt '"gfo ~!:_I_h: $16~ ... L~.: .... ~?2_0_" _____ _ 

Jan, 31, 2018 Publish ad entitled "Exotic Asian Bcautyt with 

r~eeumpanying text '"J am an independent GFE with excellent 

----······························- ---··························---

4·_ f:_)._-1-I-~eb. 1, 20_1_8_---1J~~.!?.Y~!:.?~l entitl~d '"Nurn (Best GFE.ever) incaH on1-y~"--

Feb. 6, 2018 Publish ad entitled '"Tuesday \Vith Ashleigh. A vai!abfo now,'' 

•f------·· ···················---

with "G_FE" i.n ?.?.?.~?_~?:Jlanying __ t~-'~x_t __ ---····························-

51. .Publish ad entitled "GFE Kisskisspop 100%i Real Photo 

---·· 5?~:.?~YY . .?Asian girl Nunmude 1'······························---

ln violation of 18 U.S.C. § 1952(a)(3)(A) and (b)(I)(i). 

- 47 -

DOJ-BP-0004598510 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 115 of 129
Case 2: 8-mj-01000-DUTY *SEALED* Document 3-1 *SEALED* Filed 04/26/18 Page 115 of 

128 Page ID #:255 

COUNT52 

2 {Conspiracy To Commit :Money l,aundedng) 

3 1.64. The factual allegations in Paragraphs !-163 are i:ncmvoratcd by reference 

4 and re-alleged as though fully set forth herein. 

5 165, Beginning in or around 2004, a.nd continuing through the present, in the 

6 District of Arizona and c1scwhcre, defendants LACEY, LARKIN, SPE/\.R, BRJJNST, and 

7 HYER, and others known and unknown to the grand jnry, knowingly and intentfonally 

8 agreed, confederated, and conspired with each other, and with others known and unknown 

9 to the grand jury, to con unit the following ofl:enses against the United States: 

10 

11 

12 

13 

14 

15 

16 

17 

18 

a. 

(t 

C. 

!8 U..S.C. § l956(a)(I)(A)(i) (Promotional Money Laundering) 

! 8 U.S.C. § L956(a)(l)(B)(i) (ConctialnH.mt l'vfoney Laundering) 

! 8 U.S.C. § L956(a)(2)(A) (Inn Prornotiona] Money Laundering) 

! 8 U.S.C. § L956(a)(2)(B)(i) (Int'I Concealment Money Laundering) 

18 U.S.C. § !597 (Transactional Money Laundering) 

In violation nt' 18 lLS.C. § 1956(h). 

COUNTS 53-62 

(Concealment. Money Laundering) 

I 66. The factual allegations in Paragraphs 1-165 a.re incorporated by reference 

J 9 and re-alleged as though fully set forth herein. 

20 I 67. On or about the dates set hnth bekn,v, each instance constituting a separate 

21 count of this Indictment, in the District of Arizona and elsewhere, defendants LACEY, 

22 .LARKIN, SPEAI{~ BRUNST, and HYER, and others knmvn and unknovm. to the grand 

23 jury, knowing that the property involved in a financial transaction represented the proceeds 

24 of some fi)rm of unlawful activity, conducted and attempted to conduct such a financial 

25 transacfam which in fact involved the proceeds of specified unlawful activity lmo\ving that 

26 the transaction was designed. in whole and in part to conceal and disguise the nature, the 

27 location: the source, the ownership, and the control of the proceeds of the specified 

28 

DOJ-BP-0004598511 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 116 of 129
Case 2: 8-mj-01000-DUTY *SEALED* Document 3-1 *SEALED* Filed 04/26/18 Page 116 of 

128 Page ID #:256 

unlav1ful. acti vity,.as foUov.?,: --······ .---·--······················---

2 ... <:_"o_un_t. Date .. ····----... ~.~~~.?.~.,~.t ..... _ _J_.=O=e~sc=i=·i5,pt=:.i=m=:! ___ ..................... ___ _ 

3 

4 

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9 

10 

1 l 

12 

13 

14 

J5 

16 

17 

18 

19 

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28 

53. May 18, 2016 $1,476,505.00 Website Technologies (x2008) to Ccrcus 

Prope1iics (x62 I l) ---····························· ···---···--········································· 

54. May 18~ 2016 $264,438.00 Website Technologies (x2008) to Ccreus 

I---······-·;............-.. -~ -- ---·········· ··················--- .. l~roperties (x62 !. D_··················-- ······-······-•---------------1 

55. 1v1ay3l,20I6 $3,171,675.80 V-/ebsitc Technologies (x2008) to Ccreus 

·1--------••························--·~-----+-- ---··········· .. Properties (x621 I) ····-··---·······································-

56. May 31, 2016 $432,96L87 Website Technologies (x2008) to Cereus 

~-----~~-- --············ ·············--- Propert_ies (x621)) .............. __ _ 

57. June 20, 2016 $842,878.00 WCbsite Technologies (x2008) to Cereus 

1-----················ ------- ---··································--

58. June 30, 20 I 6 $3,076,147.75 Website Technologies (x2008) to Ccreus 

-···--- .. . ........................ ·---·~·----+-P·1:operties J:~.~~?.}}). ___ ___ _ 

59. July 27, 2016 $3,252,681.62 Website 'fcdmologies (x2008) to Cereus 

---+---·························· Properties (x6~__1_1.::....) --······························----

60. July 27, 20! 6 $438,818.86 Website Technologies (x2008) to Cerew; 

-1----··························--+--- Properties .. (x62.1_1.c.....) __ --~ 

6L Aug. I 6, 2016 $804,250.00 Website Technologies (x2008) to Cercus 

-+--···························--+--l-)r_op~rtics (x621 l) ·································---

62. Aug. 3I,2016 $3,171,264.42 Website Technologies (x2008) to Ccreus 

. ......L...---···························-~-- ---··---"_f:_:~r_o:.;__p_ertics .. (x621--'-1'--) __ 

1n violation of I 81J.S.C § l 956(a)(1 )(B)(i). 

DOJ-BP-0004598512 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 117 of 129
Case 2: 8-mj-01000-DUTY *SEALED* Document 3-1 *SEALED* Filed 04/26/18 Page 117 of 

128 Page ID #:257 

2 (International . .Promotional l\toney Laundt~.ring) 

3 168, The factual allcgatimrn 111 Paragraphs 1-167 arc incorporated by reference 

4 and re-alleged as though fully set forth herein, 

5 I 69, On or about the dates set forth below, each instance constituting a separate 

6 count of this Indictment, in the District of Arizona and elsewhere, de fondants LACEY, 

7 LARKIN, SPEAR, BRUNST, and .HYER, and others known and unknmvn to the grand 

8 jury, transported, transmitted, and trnnsforred, and attempted to tnms.port, transmit, and. 

9 transfer, a monetary hrntrument and funds. fron1 a place in the United States to and through 

l O a place ontside the United States, and to a place in the United States. from and through a 

l 1 place outside the United States, with the intent to promote the can:ying on of specified. 

12 unlawful activity~ as follows: 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

24 

25 

26 

27 

28 

··············•·"" ···························-~-

Count Date_····················•---l---=~<\=-1:-::::n=o=u=n=t- ----1-±D:-:::e-:-:-::'S:::::c:-:::.d~p:::::t-::-:-:io=n.=---- ___ . ---····························· 

63. Mar. 4, 2014 

64. Aug, 5, 2016 

$6,450.00 LLS. Bank (xl165) to S,B. (web <levc!oper 

in India) --~·······················--- ----. 

$5,005J32.86 Ad Tech RV. (Netherlands) to Cercus 

Properties (x6211) -·--+--························--·· ·--····· ---··· .................... ··-- ---·························· 

65, $2,916,955.00 Ad Tech B,V. (Netherlands) to Cereus 

l--·-····"'+··-------- ---··········· ··········--- ~--+-------P!.operties ... (~.?.?..~ ... 1 .. 2 ___ ·----------

66. Oct. 3, 2016 $354,050.84 Ad Tech B.V. (Netherlands) to Ccretrn 

---1······················-- ---········ .Y~:~?p_erties ( x 6211) ··---···························•--------1 

67. Nov. 2, 2016 $2,726,170.00 Ad 'fech B.V. (Netherlands) to Cerew; 

,___ __ ---+-- ---......... ············~---------= Propcrtie~~ .. ~::.~'.~?.1.-.. 1_) ___ -~~- ----I 

68. Nov, 15, 2016 $351,403,54 Ad Tech B,V. (Netherlamls) to Cercus 

---~···············-···--- _ ____,_____ --·············· .. ?.~opcrtics (x621 .1) ___ ····························-------' 

ln violation of 18 U.S.C § l 956(a)(2)(A). 

DOJ-BP-0004598513 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 118 of 129
Case 2: 8-mj-01000-DUTY *SEALED* Document 3-1 *SEALED* Filed 04/26/18 Page 118 of 

128 Page ID #:258 

1 

2 

3 

COUNTS 69-.93 

('l'rnnsactional l\'foncy l,aundering) 

l. 70. The fiwtuaJ allegations in Paragraphs l-169 are incorporated by reference 

4 and re-alleged as though folly set forth herein. 

5 I. Ti. On or about the dates set forth below, each instance constituting a soparntc 

6 count of this Indictment, in the United States and in the Dist1>ict of Arizona and elscwhert\ 

7 the specified defendant, and others known and unkno\vn to the grnnd jury, knowingly 

8 engaged and attempted to engage in a 1nonctary transaction in criminaHy derived property 

9 ~:i~y~!Y~ .. weater than $10,000 an(~.f~.~~~~}Y.°.d from spccified.ynlawfi!}.?~~!.:"ity: as follt).~'S: ·~~ 

12 

]3 

l4 

15 

16 

17 

rn 

19 

20 

2] 

22 

23 

24 

25 

27 

28 

Count Defendant Date 

69, LACEY1 

BRUNST 2013 

Amount 

21., $30,000.00 

•······················ ··························---

70. LACEY, Sept.. 

HRUNST 2013 

~.------1--•···················-l----- -- .......... 

71. SPEAR June l.l,201.4 $300/lOO,O 0 

-l----·----<---·······················+---

72, SPEAR Juno 20, 2014 $200/JOO.O () 

·--1--·························---+-- ... 

73. SPEAR Nov, 4, 2014 $1,000,000 .00 

·················---+-- ---·1 --······················· ··--···----

74. S.PEAR Kifay 14, 2015 $250,000.0 0 

·---+--························--+-------~---····~.--••. 

75. May 26, 2015 $50,000.00 

•••••••••••••••••------·-----.A---••••••••••••••••••••••--···--~· 

..... Des ............. 

Ba.t 1k of America (x 1793) to 

wart Title (pmthl payrnent 

Sedona .. prope_r_ty_') __ 

Ste 

for 

BM 0 Harris tu Stc1,,vmt Tit1o 

(pa rtial payment for Sedona 

pro1 Jcrty) ---···························· 

Nat ional fJank of Arizona 

(xO: ! 78) to Spear Family Trust 

Nat 

(xO 

.......................... 

ional Bank of ,Arizona 

l 78) to TD Am.critrade ·~ ----.-.-.-- ............................ . 

Nat 

(xO 

Nat 

(xO 

io1tal Bank of Arizona 

178) to UBS Financial --~ 

ional Rmk of Arizona 

178) to Lincoln National 

Life --·····---··-······················ ---~ 

Nat ional Bank of Arizona 

(xO 1.78) to Industrial :Prupcrty 

DOJ-BP-0004598514 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 119 of 129
Case 2: 8-mj-01000-DUTY *SEALED* Document 3-1 *SEALED* Filed 04/26/18 Page 119 of 

128 Page ID #:259 

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3 

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12 

13 

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1.7 

1.9 

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21 

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23 

24 

25 

26 

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28 

76. 

78. 

SPEAR 

SPEAR 

SPEAR, 

BRl.JNST 

,._._._._._._..-.~-----+--··················· 

Trust 

····················--+--·••-'--···-···· ·············----~····-~•························ 

Dec, l, 2015 $200,000.00 

Jan. ll.; 2016 $133,045.00 

National Bank of Arizona 

(xO 178).to.Aily Bar_1k_ .. ________ _ 

National Bank of Arizona 

Ccreus Properties (x62ll) to 

National Bank uf Arizona 

_(x0178)_···········--- _____ _ 

79. BlUJNST Jan, 26, 2016 $Hll ,974.00 Cereus Properties (x621 l) to 

__ .. .. -----············ .. \V dls J!arg(} (x489 l ) .................. . 

80. LARKIN, Feb. 3, 2016 $1,507.944.00 Cercus Properties (x621 l) to 

BRUNST 

=··---4-·················--

8L LACEY, 

BRUNST 

Charles Schwab --····················----·-·· 

:tvlar. 1, 2016 $1,692/120.00 Cereus Prope.rtics (x62l1) to 

Bank of America { x:5554) -------1····--···-----l···················--·••-' --················- - • . ... --•-···:· ................ _·' --

BRUNST Apr. l., 2016 $220,944.00 Cereus Propert1cR (x62 l ! ) to 

WClls Fargo (x489l) 

1----·················---

83. LACEY, 

BR.UNST 

··················--·· ···--

June 27, 2016 $397,9500.00 Arizona Bank & Trust (x1793) 

to Fidelity Title (partial payrnent 

,......_ .... ~....-+--------············· ··········--· ---~····_,___ ................... ___ for San Francisco. propertYL ... -.·-

84. 

85. 

LACEY, 

BRlJNST 

SPEAR 

July 20, 2016 $12,859,152.57 Arizona Bank & Trust (xl793) 

to Fidelity Title (partial payment 

________ ___, .. for. San Vrar1cisco propm:~Yt ............ . 

July 22, 2016 $5{\000.00 National Bank of Arizona 

{xO 178) to Strategic Storage 

l'rust II r---------~".------------~-- --·····················--··~· ·--················---

LACEY, Aug. 2, 2016 $16,243.00 Cercus Properties (x62 ! 1) to 

BRUNST' -·······················-····· -~-----··············· -··--···· .. \Vells FargoJx049?) .................... . 

- 52 -

DOJ-BP-0004598515 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 120 of 129
Case 2: 8-mj-01000-DUTY *SEALED* Document 3-1 *SEALED* Filed 04/26/18 Page 120 of 

128 Page ID #:260 

1 

2 

3 88. 

LARKIN, Oct, 6, 2016 $1.,206,356.00 Cereus Properties (x6211) to 

BRUNST 

LACEY~ Oct 6, 2016 $268,016.00 

Chad~:~ .sc.hwab .. (x4693_) __ 

4 BRUNST 

Cereus Properties (x62 l.1) to 

Arizona Bank&. 'fnrnt (x l. 967) 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

--·············· ...... ~ ........................ . 

89. LACEY, Oct. 6, 2016 $268,016.00 Cercus Properties (x621 I) to 

,---···· .. :~.!.~\l!'J_· S_'T_. . _____ .... --··· ........................ --.. -- t'\ri~~1na Bai:.~ ... ~~ .. :Tmst (xl ~~?_~) 

90, 

91.. 

LACEY, 

BRUNST 

Oct. 6, 2016 $268,016.00 

-----·········· ............... __ .... .........+--

LACEY, Oct 6~ 20 l. 6 $268,016.00 

Cereus Properties (x62] I) to 

Cemus Properties (x62 l]) tu 

BRUNST Arizona Bank & Trust (x 1991) f----····· ···········-··----~· ·-----··-····· ·····················----,...j,.........-.• -•--······················· 

92. 

93. 

LACEY~ 

BRUNST 

Oct 6, 2016 $268/ll6.00 Cereus Properties (x6211) to 

---················ .. Arizon.i:! Ban1~ .. & TmstJ.~~.?.~?._l__~L._ --······················--

SPEAR~ 

BR-UNS'f 

Oct. 6, 20Hi $141,444.00 Cereus Properties (x62l 1) to 

National Bank of Arizona 

······················---... ---.--.---······················-'------- (x0'!78)········-- ~~ 

In violation of 18 ll,S.C. § 1957. 

- 53 -

DOJ-BP-0004598516 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 121 of 129
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128 Page ID #:261 

2 

3 L 

FORFEITURE Al,.LEGA.'HON ONE 

!

. ·1 ° ·1· 1· c c' 00 1 , )( 1) ·c··,·) . i T. u· s (., § ')4 ✓-. i , • )·1 .· 0 _ .,:i. _., ;,o ta . ( ., am . ..:..8 .. ,, , "" o, lL: J 

Pursuant to Rule 32.2 of the Federal Rules of Criminal Procedure, notice is 

4 hereby given that the United States will seek forfeiture as part of any scntencZ:\ pursuant to 

5 Title 18- United States Code, Section 98l(a)(l.)(C) .md Title 28, United States Cude, 

6 Section 246l(c), in the event of any defendant's conviction under Counts I through 51 of 

7 this indictment Each defendant so convicted shaH foTfdt to the United States the 

8 follo\ving: 

9 a, id! right, title, and interest in any and aU propc1i.y, real or personal, 

! 0 constituting, or derived from, any proceeds obtained, directly or indirectly~ as a result of 

! I the offense. Such property indudcs, hut is not limited to, the real property located at the 

! 2 following addresses: 

!3 

!4 

15 

16 

17 

18 

19 

20 

21 

1. 1 WO UNION SI' #0700 SAN FRANClSCO CA 94109-2019 

11. 2043 PLEAS/\.NT BlLL RD SEBAS'fOPOL CA. 95472-4947 

111. 343 PRESfDH) A VE, SAN FRANCISCO, CA 941.15 

iv. 2755 FILLMORE ST, SAN FRANCISCO, CA 94:l 23 

v. 5300 STELLA. LANE, PARADISE VALLEY, AZ 85253 

VL 16901 COLEGROVE DR., DALLAS, TX 75248 

v1L 10647 NORTH STATE ROUTE 89/\, SEDONA~ AZ 

viiL 493 ZlNFANDEL LN. ST l:LELENA, CA 94574 

ix. 5555 N. CASA BLANCA DR, PARADISE VALLEY, AZ 85253 

x. 1308 E. 56TH ST UNIT 2i Cl-HCJ\GO, IL 6063 7 

23 Such prnpmty also includes, but is not hmited to, fonds held m the fi)llowing bank 

24 accounts: 

25 L Prosperity Bank account mnnber XXXXX7 l. 88 

26 11. Corripass Bank A.ccou11t nnrnber XXXXXX3873 

27 iii, Compass Bank Account nnmher XXXXXX3825 

28 

DOJ-BP-0004598517 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 122 of 129
Case 2: 8-mj-01000-DUTY *SEALED* Document 3-1 *SEALED* Filed 04/26/18 Page 122 of 

128 Page ID #:262 

1 iv, National Bank of Arizona Account number XXXXO 178 

2 v, National Bank of Arizona Account number XXXXOI 51 

3 vi, National Bank of Arizona Account number XXXX3645 

4 v11, Live Oak Bank /\ccount Number XXXXXXXXXX2523 

5 vm. Ascensns Broker Dea1er Services Account Number XXXXX6943-0 I. 

6 ix, Ascensns Broker Dealer Services account Nut:nber XXXXX5280-01 

7 x. First Federal Savings & Loan of San .Rafa-tel account number XXXX3620 

8 xi. Republic Bank of Arizona account 11:m:nbe.r XXXXl 889 

9 xu. Repuhhc Bank of Arizona account number XXXX2592 

l.O xiii. Repuhl.ic Bank of Arizona account number XXXX2912 

l.1 x1v. Republic Bank of 1\Tizuna account number XXXX2500 

12 xv. Republic Bank of Arizona account number XXXXl 938 

13 xvL Bank of America A.ccount number XXXXXXXXXXXX8225 

14 xvii. Bank of America Account number XXXXXXXXXXXX7054 

15 xvHL Bank ofAmerica ,1-\ccount number XXXXXXXXXXXX9342 

16 xn<, Bank of America Account number XXXXXXXXXXXX007 l. 

17 xx, San Francisco Fire Credit lJnion Account Number XXXXXXXXXX2523 

18 xxL Ally Bank Account Number XXXXXX6292 

19 xxiL Branch Banking and Trust Bank account number XXXXXXXXX02 l 8 

20 xxHi, Green Bank Account number XXX4832 

2 l xxiv, Green Bank Ac,(X)tmt number XXXXXX4293 

22 xxv. Plains Capital Bm1k account number XXXXXX l. 098 

Such property further includes, hut is not limited to, the following dornain names: 

24 

25 

26 

27 

28 

L atlantabackpage.com 

1.L backpage.be 

nL backpagc.com 

iv. backpagc.com.br 

DOJ-BP-0004598518 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 123 of 129
Case 2: 8-mj-01000-DUTY *SEALED* Document 3-1 *SEALED* Filed 04/26/18 Page 123 of 

128 Page ID #:263 

_l V. backpage.cz 

2 V!, bac~kpage.dk 

., 

~) Vll. backpage.cc 

4 VllL backpage.cs 

5 IX. backpage.fi 

6 x. backpage.fr 

7 XL backpage.gr 

8 xii. backpageJrn 

9 XUL backpage.ie 

l.O XlV. backpage,it 

l1 xv. backpageJt 

l.2 XVL backpage,mx 

l.3 XV1L backpage,net 

l.4 XVlU. backpage,no 

15 XlX. backpage.pl 

16 xx. backpage.pt 

17 XXL backpage.rn 

18 xxii. backpage.si 

19 xx iii. backpage.sk 

20 xx1v. backpage.us 

21 xxv. backpag:e-insi<lcr.com 

22 XX'./1. bestofoackpagi:.'..corn 

23 xxvii. bestofoigcity,corn 

24 xxvii.i. higcfry.corn 

25 XX1X. chicagobackpage,com 

26 XXX. denverbackpagc.corn 

27 xxxi. new yorkbackpage.com 

28 

- 56 -

DOJ-BP-0004598519 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 124 of 129
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128 Page ID #:264 

1 xxx11, phocnixbackpage.com 

2 xxxiii. sandicgohackpage.com 

3 xxx1v, scatt!cbackpage.com 

4 xxxv, tampabackpage.eom 

5 To the extent such property is not av:.tilahle f<)r for!:citnre, a sum of 

6 money equal to the tuta.1 value of the property described in subparagraph (a). 

Pursuant to Title 21, United Stales Code, Section 85J(p ), as incorporated by 

8 Title 28, United State~{ Code, Section 2461(c), the dcfondant shall forfeit substitute 

9 property, up to the total value of the property described in the preceding paragraph i( as 

10 tho result of any act or omission of the defendant, the property described in the preceding 

I l paragraph, or any portion thereof: (a) cannot be located upon the exercise of due di1ige11cc; 

12 (b) has been transferred~ sold to or deposited \Vith a third party; (c) has been placed beyond 

13 the jurisdiction of the court; (d) has been substantially diminished in value; or (e) has been 

14 commingled with other property foat cannot be divided without difficulty, 

15 FORF.RITURE ALLEGATION TWO 

16 [ 18 -l-! .-, -, g o,:r1( -)(. i,] . ,.:-:,.(,.. t· .70.;.. a i.) 

17 

18 

19 

20 

21 

23 

24 

25 

26 

27 

28 

L Pursuant to Rnie 32.2 of t]ie Federal Rules of Criminal Procedure, notice is 

hereby given that the United States will seek forfeiture as part of any sentence, pursuant 

Title 18~ United States Code, Section 982(a)(J ), in the event of any ddendant's conviction 

under Counts 52 through 93 of this Indictment. Each defendant so convicted shall forfeit 

to the United States the foHowing: 

a, All right, title, and interest in any and aU propc1iy, real or personal, 

involved in or traceable to any transaction set forth in Counts 52 through 93 of this 

Jndictrncnt. Such propciiy indudes, but is not lin1ited to, the real property located at the 

foHowing addresses: 

1. 1100 UNION ST' #0700 SAN FRANCISCO CA 94Hl9-201.9 

n. 2043 PLEASANT I-ULL RD SEBASTOPOL CA 95472-494 7 

DOJ-BP-0004598520 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 125 of 129
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128 Page ID #:265 

2 

3 

4 

5 

6 

7 

8 

9 

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1:1 

12 

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21 

22 

23 

24 

25 

26 

27 

28 

m. 343 PRESIDIO AVE\ SAN FRANClSCO, C'.A 94115 

1v. 2755 FILLMORE ST, SAN FRANCISCO, CA 941.23 

v. 5300 STELJ,A LANE, PARADISE VALLEY, AZ 85253 

vL 1690 I COLEGROVE DR., DALLAS~ TX 75248 

vn. 10647 NORTil STATE ROU'fE 89A, SEDONA, AZ 

vHL 493 ZINFANDEL LN, ST lJELENA, CA 94574 

1x. 5555 N. CASA BLANCA DR, PARADIS.E VALLEY, AZ 85253 

x. 1308 E. 56TH ST UNIT 2, CHICAGO, l:L 6063 7 

Such property also includes, but is not limited to, funds hdd in the fo!low·ing bank 

accounts: 

1. Prosperity Bank account nmnbc:r XXXXX7188 

11. Compass Bank Account nnrnbcr XXX:XXX3873 

111. Compass Bank Account mn:nbcr XXXXXX3825 

1v. National Bank nf Arizona Account number XXXX0 178 

v. National Bank of Arizona Account number XXXX0:151 

vi. National Bank of Arizona Account number XXXX3645 

vn. Live Oak Bank Account Number XXXXXXXX.XX2523 

v1u. Ascensus Broker Dealer Services Account Number XXXXX6943-01 

1x. /\sccnsus B.mker Dealer Services ac.eount Number XXXXX5280-01 

x, First Federal. Savings & Loan of San Rafael account number XXXX3620 

XL Republic Bank of Arizona account number XXXXJ 889 

xii, 1lcpublic Bank of Arizona account number XXXX2592 

xiii. Republic Bank of Arizona account nurnber XXXX2912 

xiv, 1fopnblic Bank of Arizona account number XXXX2500 

xv. Republic B,ink of Arizona account munber XXXXJ938 

XVL Bank of America A.ccount number XXXXXXXXXXXX8225 

DOJ-BP-0004598521 

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128 Page ID #:266 

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12 

13 

14 

15 

16 

17 

l8 

]9 

20 

21 

22 

23 

24 

25 

26 

27 

28 

xvii. Bank of Arnerica Account number XXXXXXXXXXXX7054 

xviii, Bank of America. Account number XXXXXXXXXXXX9342 

x1x. Bank of America /\ccount number XXXXXXXXXXXX007 l 

xx, San Francisco Vire Credit Union Accmmi Number XXXXXXXXXX2523 

xxi. Ally Bank Aeun.mt Number XXXXXX6292 

xxii. Branch Banking and Trnst Bank account number XXXXXXXXX0218 

xx 111. Green Bank Account nurnher XXX4832 

xxiv, Green Bauk Aeeount number XXXXXX4293 

xxv. Plains Capita! B-ank aceount number XXXXXXl 098 

Such property further includes, hut fa not limited to, the follo\ving dnmain names: 

L atlantabackpage,corn 

u. backpagc.be 

.iii. backpage.com 

1v. backpagc.com.br 

v. backpage,cz 

v1. backpagc.dk 

vii. backpage,ee 

viii backpagc'.es 

1x. backpage,fi 

x. backpagc.fr 

x1. backpage.gr 

xu. hackpagc.hu 

X!U. backpage.ie 

xiv. hackpage.it 

xv. backpfH!,eJt ' ,_ 

xv1. backpage.rnx 

DOJ-BP-0004598522 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 127 of 129
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128 Page ID #:267 

2 

4 

5 

6 

7 

8 

9 

10 

l l. 

12 

13 

14 

!5 

]9 

20 

2!. 

22 

23 

XV!L backpagc.nct 

x vm. backpageJ10 

XIX. baekpage.pl 

xx. back.page.pt 

xx1. baekpage.ro 

xx1.L backpagc.si 

xxiii. backpage.sk 

xxiv. backpagc.ns 

xxv, backpage-insider.com 

xxvL bestotbackpagc.com 

xxv11. bestofhigcity.com 

xxvrn. 

xxix. 

XXX. 

xxxil. 

XXX11L 

XXX1V. 

XXXV. 

bigcity.corn 

chicagobaCkpagc.com 

denvr.Jbackpagc.com 

ncwyorkbackpagc,com 

phor.nixbackpage.corn 

sandicgobackpagc.cmn 

scattlebackpagc.corn 

tampabackpage.corn 

h. To the cxte11t such property is not available fi)r for!:citure, a sum of 

money equal to the total va]uc of such property. 

2, Pursuant to Title 21, United States Code, Section 853(p\ as incorporated by 

24 T1tlc 18, United States Code, Section 982(b ), each defendant convicted under Counts 52 

25 through 93 of this Indictment shall forfeit substitute property~ ff, hy any act or omission of 

26 that defendant, the propc1i.y described in the preceding paragraph, or any portion thereof, 

~ry i 

L I cannot he located upon tho exorcise of due diligence; has been transferred, sok to, or 

28 

DOJ-BP-0004598523 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 128 of 129
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128 Page ID #:268 

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deposited with a third party; has he.en placed beyond tho Jurisdiction of the court; has been 

substantially dfrninfahcd in value; or has been commingled with other properly that cannot 

be divided \vithout difficulty. 

A TRUE BILL 

i.{ I 

toREPERSON OF THE GRAND °JURY 

Date: March 28, 2018 

ELIZABET.FI A. STRANGE 

First Assistant United States Attorncv 

District of Arizona -

JOHN P. CRONAN 

Acting A.ssistant Attorncv General 

Criminal Division, U ,S. Depart.m,nit of Justice 

KE\llN .iv1. RAPP 

DOMINIC Li\NZA 

MARGA1tET PERLMlT"fER 

JOFIN J. KUCERA 

Assistant LLS. Altorrwys 

REGJNALD E, JONES 

Se1?ior Trial Attom~ry . , . . , . , U.S, Department ot Jnst1ee; CTmHnal Ihv1mon 

Child Exploitation and Obscenity Section 

DOJ-BP-0004598524 

Case 2:18-cr-00422-DJH Document 1966-1 Filed 11/13/23 Page 129 of 129