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ELIZABETH A. STRANGE

First Assistant United States Attorney District of Arizona

KEVIN M. RAPP (Ariz. Bar No. 14249, kevin.rapp@usdoj.gov)

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

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

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

Assistant U.S. Attorneys

40 N. Central Avenue, Suite 1800

Phoenix, Arizona 85004-4408

Telephone (602) 514-7500

JOHN J. KUCERA (Cal. Bar No. 274184,john.kucera@usdoj.gov)

Special Assistant U.S. Attorney

312 N. Spring Street, Suite 1200

Los Angeles, CA 90012

Telephone (213) 894-3391

JOHN P. CRONAN

Acting Assistant Attorney General

Criminal Division, U.S. Department of Justice

REGINALD E. JONES (Miss. Bar No. 102806, reginald.jones4@usdoj.gov)

Senior Trial Attorney, U.S. Department of Justice

Child Exploitation and Obscenity Section 

950 Pennsylvania Ave N.W., Room 2116

Washington, D.C. 20530

Telephone (202) 616-2807 

Attorneys for Plaintiff

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

United States of America,

Plaintiff, 

v. 

Michael Lacey, et al.,

Defendants.

CR-18-422-PHX-SPL (BSB) 

UNITED STATES’ MOTION TO 

RESOLVE ATTORNEY-CLIENT 

PRIVILEGE ISSUES

INTRODUCTION AND SUMMARY OF ARGUMENT

During the investigation in this case, the United States obtained search warrants for 

several email accounts belonging to the defendants and other Backpage personnel. 

Because it was suspected those accounts might contain some communications with 

Backpage’s attorneys (i.e., communications potentially covered by Backpage’s corporate 

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attorney-client privilege), the United States utilized a “filter team” to conduct an initial 

review of the materials seized via the search warrants. During this process—which was 

expressly authorized by magistrate judges—the filter team identified certain 

communications that were suspected to be privileged and removed them from the subset 

of materials that was later turned over to the prosecution team. 

Ordinarily, the next step in the process would be for the filter team to individually 

analyze the withheld emails and litigate whether some or all of them may be turned over 

to the prosecution team. This process can be very time-consuming and resource-intensive 

(not only to the parties, but also to the Court) and, in this case, could significantly slow 

down the discovery process. Additionally, the defense recently voiced objections to the 

continued use of filter teams in this case.

The Court should find, for three reasons, that no additional filter review is necessary 

here. First, Carl Ferrer has executed a written waiver of the corporate attorney-client 

privilege possessed by Backpage and related entities. This waiver obviates the need for 

the continued segregation of the withheld communications—Ferrer was authorized to 

execute the waiver (he is Backpage’s 100% owner and CEO) and Ninth Circuit law makes 

clear that, once such a waiver has been executed, individual corporate employees (such as 

the defendants in this case) cannot contest the disclosure of their previously-privileged 

communications. Second, individual review is also unnecessary because Judge Campbell 

recently determined, during the course of now-unsealed litigation, that Backpage waived 

its corporate attorney-client privilege by voluntarily sharing privileged materials with third 

parties. Third, individual review is also unnecessary because a judge in Washington State 

previously ruled that Backpage waived its privilege by placing the content of privileged 

communications at issue while defending a lawsuit brought by a trafficking victim. 

For these reasons, the United States seeks an order confirming that (1) Backpage’s 

corporate attorney-client privilege has been waived and (2) the prosecution team may 

therefore gain access to the emails and other communications that were previously 

withheld by the filter team.

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FACTUAL AND PROCEDURAL HISTORY

A. The Activities Of The Filter Team In This Case

1. The Warrant For Ferrer’s Email Account

In July 2016, the United States obtained a warrant compelling Google to produce 

the contents of an email account held by Carl Ferrer. Afterward, the United States obtained 

a court order authorizing the use of a filter team to review the account’s contents. See

Exhibit A. The order provided that “the Filter Team will review Backpage CEO Carl 

Ferrer’s emails for potentially privileged and protected materials, and will keep all 

legitimately protected materials, as well as materials suspected to be protected, segregated 

from the Investigative Team unless the Court rules they can be disclosed.” Id.

2. The Warrant For Nine Additional Email Accounts

In April 2017, the United States obtained a warrant to search nine email accounts 

held by Backpage personnel (including accounts held by defendants Lacey, Larkin, Padilla, 

and Vaught). See Exhibit B at 2.

1

 The judge issuing this warrant also authorized the use 

of a filter team to review the accounts’ contents. Specifically, Attachment B to the warrant 

provided that “the Filter Team will review the documents for privilege or protection only 

and will disseminate non-privileged and non-protected documents to the Investigative 

Team. The Investigative Team will determine which documents constitute evidence of 

unlawful activity. Because the Filter Team will be properly walled off from the 

Investigative Team, it may review emails to and from Elizabeth McDougall [Backpage’s 

in-house counsel] or other Backpage attorneys to determine if they properly qualify for 

privilege or protections, in accordance with procedures set forth above. This will eliminate 

the risk that protected information from or to Ms. McDougall or other Backpage attorneys 

will reach the Investigative Team.” Id. at 3.

 

1 The April 2017 warrant was directed to the California Department of Justice, which 

had previously (and independently) obtained the contents of the email accounts.

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3. The Filter Team’s Activities To Date

The attorney responsible for coordinating the filter-team review in this case is not a 

member of the prosecution team—she works within the Criminal Division of the 

Department of Justice in Washington, D.C.

As part of the review process, the filter team created a list of the attorneys and law 

firms whose communications may have been covered by Backpage’s corporate attorneyclient privilege during the time periods in question. This list included (1) Elizabeth 

McDougall, an attorney who has served as Backpage’s general counsel since February 

2012, (2) Steve Suskin, an attorney who served as Backpage’s in-house counsel (via his 

work as counsel to Village Voice Media Holdings, which was, at the time, Backpage’s 

parent company) from 2010-12, (3) Hemanshu Nigam, an attorney whose consulting 

company (“SSP Blue”) served as outside counsel to Backpage between September 2010 

and December 2011, (4) Don Bennett Moon, an attorney who previously served as a board 

member of Village Voice Media Holdings and who represented Backpage during certain 

interactions with regulators, (5) the law firm of Davis Wright Tremaine (“DWT”), which 

has served as Backpage’s outside counsel in various matters since 2010, and (6) the law 

firm of Rusing Lopez & Lizardi, which has also served as Backpage’s outside counsel.

Using this list, the filter team identified 1,832 emails from the Ferrer email warrant, 

and an additional 8,901 emails from the subsequent email warrant, that might be privileged. 

These emails have not been provided to the prosecution team (and were not disclosed to 

the defense as part of the first wave of discovery that was produced in May 2018). 

The filter team has also started the process of individually reviewing the segregated 

emails (to determine whether they are, in fact, privileged). To date, approximately 6,500 

of the segregated emails have been reviewed. However, the filter team temporarily stopped 

conducting this review in May 2018, after the prosecution team received a letter from the 

defense attorneys in this case raising concerns about the propriety of filter-team review. In 

response to that letter, the prosecution team proposed that the parties seek a ruling from the 

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Court concerning the privilege issues in this case (i.e., this motion).2

B. The Written Waiver Of Backpage’s Corporate Attorney-Client Privilege

On April 5, 2018, Carl Ferrer executed a written waiver of the corporate attorneyclient privilege possessed by Backpage.com, LLC and various other Backpage-related 

entities. See Exhibit C.

The document begins by explaining that “I am authorized to waive each of the 

Companies’ attorney-client privilege and am doing so because I believe executing such 

waiver is in each of the Companies' best interest.” Id. at 1. As for the scope of the waiver, 

the document provides: “I hereby voluntarily waive all aspects of the attorney-client 

privilege, on behalf of the Companies, which otherwise may have applied to 

communications, documents and information that I or the Companies have provided to law 

enforcement or which law enforcement may already have in its possession from other 

sources, as follows:

a. All communications related to the “adult,” “escort,” “dating,” and “services” 

sections of the Companies’ websites, including but not limited to company policies, 

moderation practices, age verification practices, legality, content, and compliance 

with law enforcement.

b. All communications related to the Companies’ financial activity, including 

but not limited to the sale of Backpage.com in 2015, all loans and financing 

agreements related to the sale of that company in 2015, monetization of the 

Companies’ websites, payment processing, credit card processing, banking, and 

payment of loans.

c. All communications regarding the relationship between the Companies 

(including their current owner and employees) and their former owners and officers, 

including but not limited to, James Larkin, Michael Lacey, John (“Jed”) Brunst and 

 

2 To be clear, the filter-team did not limit its review to the materials gathered in 

response to the two email search warrants. In addition to the 10,733 emails discussed 

above, the filter team has also segregated 54 documents that were previously produced by 

Backpage pursuant to a subpoena and thousands of additional documents that were 

produced pursuant to various subpoenas. 

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Scott Spear, as well as communications between the Companies (including their 

current owner and employees) and Don Bennett Moon.”

Id.

The document also states that, “in addition to the foregoing waiver, I hereby 

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

which otherwise may have applied to the Companies’ relationship with any attorney 

(“previous attorneys”) who was retained to represent the Companies in connection with 

various matters related to the subjects listed above. This attorney-client privilege waiver is 

meant to apply to all communications between the Companies and any attorney 

representing them at any time; all acts undertaken by others acting on the Companies’ 

attorneys’ behalf taken in connection with representing the Companies related to the 

subjects listed above; and any and all documents generated through their representation of 

the Companies that belong to the Companies.” Id. at 1-2.

C. Judge Campbell’s Ruling That Backpage Waived The Privilege

1. The Initial Litigation Over The 108 Subpoena

In October 2016, during the pre-indictment stage of the investigation, the grand jury 

issued a subpoena (“the 108 subpoena”) to Ferrer and Backpage for an array of internal 

documents. This subpoena was the catalyst for extensive litigation—litigation that has now 

been unsealed and may be publicly disclosed.3

In February 2017, following expedited briefing and a lengthy oral argument, Judge 

Campbell rejected Ferrer’s and Backpage’s First Amendment-based objections to the 

subpoena and ordered them to comply. See Exhibit D (transcript of February 22, 2017 

hearing). In support of this ruling, Judge Campbell made factual findings that “this grand 

jury investigation . . . is a good faith investigation and not being undertaken for bad faith 

purposes” (id. at 65), that there was a reasonable basis to suspect “that Backpage has 

 

3 On May 17, 2018, Judge Campbell issued an order authorizing the United States to 

disclose, during the proceedings in this case, the materials enclosed as exhibits D-H to this 

pleading.

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knowingly been involved with the posting of illegal advertisements” (id. at 63), and that 

the subpoena was properly tailored “to determine whether or not Backpage and its 

personnel knew that advertisements posted on its website were for illegal activity . . . which 

is a key question in whether or not crimes have been committed” (id. at 66). Notably, 

Judge Campbell also confirmed that 18 U.S.C. § 1952—which is the statute underlying 

many of the charges in the current indictment—“criminalize[s] the knowing publication of 

an advertisement for illegal prostitution or other illegal activity” and noted that Backpage’s 

then-counsel (from the DWT firm) had conceded this point during oral argument. Id. at 

65. See also Exhibit D at 37 (DWT concession); Exhibit E (minute entry). 

In June 2017, following expedited briefing, the Ninth Circuit issued a unanimous 

unpublished decision affirming Judge Campbell’s decision. See Exhibit F.

2. The Litigation Over Backpage’s Waiver Of The Privilege

In September 2017, Backpage purported to comply with the subpoena, producing 

over 500,000 documents, but also withheld over 7,000 documents based on invocations of 

the attorney-client privilege. In December 2017, after reviewing Backpage’s privilege log, 

the United States filed a motion to compel Backpage to produce many of the withheld 

documents on the grounds that Backpage had voluntarily shared them with third-party 

public relations firms and investment banks—acts of dissemination that destroyed the 

privilege. See Exhibit G (transcript of February 9, 2018 hearing).

On April 2, 2018, following a hearing and several rounds of briefing, Judge 

Campbell issued a 14-page order concluding that Backpage had, in fact, waived its 

corporate attorney-client privilege by sharing hundreds of privileged documents with thirdparty public relations firms and investment banks. See Exhibit H (order).

3. The Documents Produced In Response To Judge Campbell’s Order

On or around April 16, 2018, Backpage produced to the United States the documents 

that were the subject of Judge Campbell’s April 2 waiver finding (i.e., the once-privileged 

documents that Backpage had shared with public relations firms and investment banks). 

One of the documents included in this production was an April 2011 email that 

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several Backpage principals (including Ferrer, Larkin, and Spear) had received from SSP 

Blue (the firm operated by attorney Hemanshu Nigam). See Exhibit I. The subject matter 

of the legal advice contained in this email was how to moderate and review ads submitted 

by customers. Among other things, the email advised the recipients (in Action Item 12 of 

the enclosed spreadsheet) that Backpage should prevent customers from publishing ads 

using the phrase “New In Town” because this phrase “is often used by pimps who shuttle 

children to locations where they do not know anyone and cannot get help.” Id. (emphasis 

added). The Court will note that the indictment alleges the defendants ignored this advice 

and continued allowing ads using the phrase “New In Town” to be published. See, e.g., 

Counts 12-15 of the indictment.

Another document included in this production was a January 2012 email whose 

recipients included several Backpage principals (including Lacey, Larkin, and Ferrer) and 

a Backpage attorney. See Exhibit J. The subject matter of the email concerned 

whether/how to acknowledge the prevalence of prostitution ads on the Backpage website. 

Among other things, the email advised that, if the recipients were ever confronted with 

such questions, they shouldn’t issue a denial but, instead, should attempt to change the 

subject and accuse the questioner of being a “prude.” Id.

D. The Washington Judge’s Ruling That Backpage Waived The Privilege

1. Background Concerning The J.S. Case

In July 2012, three minor girls who had been “bought and sold for sexual services 

online on Backpage.com” filed a civil lawsuit against Backpage in Washington state court. 

See J.S. v. Village Voice Media Holdings, Inc., 359 P.3d 714, 715-16 (Wash. 2015). 

Backpage moved to dismiss, arguing it was immune from civil liability under the 

Communications Decency Act (“CDA”), 47 U.S.C. § 230, because it merely provided a 

forum for the illicit ads created by the girls’ pimps. Id. The girls, in turn, argued the CDA 

should be deemed inapplicable because Backpage does “more than just provide a forum 

for illegal content” and affirmatively shapes the content of its users’ ads through “posting 

rules [that are] ‘designed to help pimps develop advertisements that can evade the 

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unwanted attention of law enforcement, while still conveying the illegal message.’” Id. 

In September 2015, the Washington Supreme Court ruled 6-1 in the girls’ favor and 

denied Backpage’s motion to dismiss. The court explained: “This case turns on whether 

Backpage merely hosted the advertisements that featured J.S., in which case Backpage is 

protected by CDA immunity, or whether Backpage also helped develop the content of those 

advertisements, in which case Backpage is not protected.” Id. at 717). The court concluded 

the girls should be permitted to conduct discovery “to ascertain whether in fact Backpage 

designed its posting rules to induce sex trafficking.” Id. at 718. 

2. The J.S. Waiver Ruling

Following remand from the Washington Supreme Court, the girls’ attorney 

propounded an array of discovery requests to Backpage seeking information about its 

moderation practices. In response, Backpage identified its in-house counsel, Elizabeth 

McDougall, as its 30(b) witness, allowed her to be deposed concerning Backpage’s 

moderation practices, and submitted a declaration from her in an attempt to obtain 

summary judgment. The plaintiffs, in turn, filed a motion asserting that Backpage had 

waived its corporate attorney-client privilege on an array of topics by attempting to rely on 

Ms. McDougall in this fashion.

In an order issued in August 2017, the trial court agreed with the plaintiffs and held 

Backpage had waived the privilege. See Exhibit K. Specifically, the court explained that, 

because Backpage had “put the assertions and representations of Ms. McDougall at issue 

in this litigation,” it would be unfair to deny the plaintiffs access to other material that 

might bear on the validity of her claims. Id. at 1-3. Thus, the court concluded Backpage 

had “waived the attorney-client privilege and work-product protection with respect to . . . 

[all of] the topics identified in Plaintiffs’ 30(b)(6) deposition notice.” Id. This notice, in 

turn, broadly encompasses a variety of topics, including (1) Backpage’s moderation 

practices, (2) Backpage’s policies and procedures for reviewing, screening, moderating, 

and/or editing ads submitted by customers, and (3) Backpage’s knowledge and awareness 

that sex trafficking was occurring on the website. See Exhibit K, Appendix B.

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ARGUMENT

A. Further Segregation Is Unnecessary In Light Of The Written Waiver

There is no reason to continue withholding, from the prosecution team, the emails 

that had been segregated by the filter team. Based on Mr. Ferrer’s execution of a written 

waiver of Backpage’s corporate attorney-client privilege, those emails are no longer 

privileged.

As an initial matter, Mr. Ferrer—as Backpage’s CEO and 100% owner since 2015—

had the authority to waive the corporation’s privilege. See generally Commodity Futures 

Trading Comm’n v. Weintraub, 471 U.S. 343, 349 (1985) (“[W]hen control of a 

corporation passes to new management, the authority to assert and waive the corporation’s 

attorney-client privilege passes as well. New managers . . . may waive the attorney-client 

privilege with respect to communications made by former officers and directors. Displaced 

managers may not assert the privilege over the wishes of current managers, even as to 

statements that the former might have made to counsel concerning matters within the scope 

of their corporate duties.”).

Furthermore, the Ninth Circuit makes clear that, once a corporate privilege waiver 

has been executed, individual corporate employees (such as the defendants in this case) 

cannot contest the disclosure of their previously-privileged communications. In United 

States v. Graf, 610 F.3d 1148 (9th Cir. 2010), the Ninth Circuit addressed this issue in 

detail, noting that “[o]ne of these special problems” that arises in the context of the 

corporate attorney-client privilege “is that corporate officers, directors, and employees who 

communicate with corporate counsel on behalf of the corporation may later attempt to 

claim a personal attorney-client privilege regarding those communications after the 

corporation has waived its own privilege.” Id. at 1156. The Graf court held that a 

corporation is ordinarily “free to obtain information from its officers, employees, and 

consultants about company matters and then control the attorney-client privilege, waiving 

it when necessary to serve corporate interests,” and that an employee may prevent such a 

disclosure only under limited circumstances. Id. at 1160-61 (emphasis added). 

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Specifically, once the corporate privilege has been waived, an individual employee may 

prevent disclosure only by establishing the following five factors: 

First, they must show they approached counsel for the purpose of seeking legal 

advice. Second, they must demonstrate that when they approached counsel they 

made it clear that they were seeking legal advice in their individual rather than in 

their representative capacities. Third, they must demonstrate that the counsel saw 

fit to communicate with them in their individual capacities, knowing that a possible 

conflict could arise. Fourth, they must prove that their conversations with counsel 

were confidential. And fifth, they must show that the substance of their 

conversations with counsel did not concern matters within the company or the 

general affairs of the company.

Id. at 1160 (citation omitted) (emphasis in original).

Here, the United States has not seen any evidence suggesting these five factors could 

be satisfied with respect to any of the withheld emails. Thus, unless a particular defendant 

produces evidence that he or she, while working at Backpage, had discussions with 

corporate counsel about purely personal matters unrelated to the general affairs of 

Backpage and made clear he or she was seeking legal advice in an individual capacity, the 

Court should hold that Mr. Ferrer’s privilege waiver is valid and authorize the filter team 

to produce the withheld materials to the prosecution team.

B. Further Segregation Is Unnecessary In Light Of Judge Campbell’s Ruling

Judge Campbell’s order of April 2, 2018, provides an independent basis for 

concluding that Backpage’s corporate attorney-client privilege has been waived and that 

the segregated emails may therefore be produced to the prosecution team.

It is black-letter law that “voluntarily disclosing privileged documents to third 

parties will generally destroy the [attorney-client] privilege.” In re Pac. Pictures Corp., 

679 F.3d 1121, 1126-27 (9th Cir. 2012). See generally Chevron Corp. v. Penzoil Co., 974 

F.2d 1156, 1162 (9th Cir. 1992) (agreeing that “Pennzoil had waived the attorney-client 

privilege by disclosing to an outside auditor documents which discussed” legal advice it 

had received, because “voluntary disclosure of a privileged attorney communication to a 

third party constitutes waiver of privilege”); United States v. Ruehle, 583 F.3d 600, 612 

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(9th Cir. 2009) (“[A]ny voluntary disclosure of information to a third party waives the 

attorney-client privilege, regardless of whether such disclosure later turns out to be 

harmful.”); Southern Union Co. v. Southwest Gas Corp., 205 F.R.D. 542, 548 (D. Ariz. 

2002) (“[I]f the documents containing confidential communications are disclosed to third 

parties, the privileged status of the communications within the documents is lost.”).

Here, Judge Campbell already has determined that Backpage waived its corporate 

attorney-client privilege by voluntarily sharing hundreds of privileged communications 

with third-party public relations firms and investment banks. Moreover, although the only 

remedy the United States sought during the previous proceeding (before Judge Campbell)

was the disclosure of those particular emails, the law in the Ninth Circuit is that “voluntary 

disclosure of the content of a privileged attorney communication constitutes waiver of the 

privilege as to all other such communications on the same subject.” Weil v. 

Investment/Indicators, Research & Mgmt., Inc., 647 F.2d 18, 24 (9th Cir. 1981). See also 

Hernandez v. Tanninen, 604 F.3d 1095, 1100 (9th Cir. 2010) (“Disclosing a privileged 

communication . . . results in waiver as to all other communications on the same subject.”).

The privileged emails that Backpage disclosed to third-party public relations firms 

and investment banks addressed an array of different “subjects,” including how to moderate 

and review ads submitted by customers and whether/how to acknowledge the prevalence 

of prostitution ads on the Backpage website. These are the same “subjects” addressed in 

the communications that have been segregated by the filter team. Accordingly, those 

communications have lost their privileged status and may be shared with the prosecution 

team.

C. Further Segregation Is Unnecessary In Light Of The J.S. Ruling

Finally, the ruling issued in the J.S. case in August 2017 provides yet another 

independent basis for concluding that Backpage’s corporate attorney-client privilege has 

been waived and that the segregated emails may therefore be produced to the prosecution 

team.

The Ninth Circuit has recognized that “[e]ven when a party does not explicitly 

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disclose the content of an attorney-client communication, he may waive the privilege 

implicitly. A person cannot always claim that he relied on counsel, while protecting what 

was said between them from disclosure.” United States v. Ortland, 109 F.3d 539, 543 (9th 

Cir. 1997). See also Chevron Corp., 974 F.2d at 1162 (“Where a party raises a claim which 

in fairness requires disclosure of the protected communication, the privilege may be 

implicitly waived.”); 2 Rice, Attorney-Client Privilege § 9:24 at 89 (“When the client 

makes the communications with counsel a substantive issue in the litigation, courts have 

consistently held that the attorney-client privilege protecting those communications is 

waived. Courts often refer to this type of waiver as an ‘at issue’ waiver or an implied 

waiver.”). This is exactly what occurred in the J.S. case, and the “subject matters” that the 

J.S. court determined to be encompassed by its waiver ruling (i.e., Backpage’s moderation 

practices, Backpage’s policies and procedures for reviewing, screening, moderating, and/or 

editing ads submitted by customers, and Backpage’s knowledge and awareness that sex 

trafficking was occurring on the website) are the same subjects addressed in the 

communications that have been segregated by the filter team. 

CONCLUSION

The Court should issue an order confirming that (1) Backpage’s corporate attorneyclient privilege has been waived, at least with respect to Elizabeth McDougall, Steve 

Suskin, Hemanshu Nigam, the consulting firm SSP Blue, Don Bennett Moon, the law firm 

of Davis Wright Tremaine, and the law firm of Rusing Lopez & Lizardi, and (2) the 

prosecution team may therefore gain access to the emails and other communications that 

were previously withheld by the filter team. 

Respectfully submitted this 14th day of June, 2018.

ELIZABETH A. STRANGE

First Assistant United States Attorney

District of Arizona

/s Kevin Rapp

KEVIN M. RAPP

MARGARET PERLMETER

PETER S. KOZINETS

ANDREW C. STONE

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Assistant U.S. Attorneys

JOHN J. KUCERA

Special Assistant U.S. Attorney

JOHN P. CRONAN

Acting Assistant Attorney General

Criminal Division, U.S. Department of Justice

REGINALD E. JONES

Senior Trial Attorney

U.S. Department of Justice, Criminal Division

Child Exploitation and Obscenity Section

Certificate of Service

I hereby certify that on this date, I electronically transmitted the attached document to the 

Clerk’s Office using the CM/ECF system for filing and transmittal of a Notice of Electronic 

Filing to the following CM/ECF registrants: Anne Chapman, Erin McCampbell, James 

Grant, Lee Stein, Paul Cambria, Robert Corn-Revere, Ronald London, Janey Henze Cook, 

John Littrell, Kenneth Miller, Thomas Bienart, Jr., Bruce Feder, Michael Kimerer, Rhonda 

Neff, KC Maxwell, David Wakukawa, Michael Piccarreta, Stephen Weiss. 

s/ Sally Hawley

U.S. Attorney’s Office

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