Case Document 230 Filed 07/25/18 (gage 1 of 92

 
  

 
   
  
 

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA

United States of America,
Plaintiff,
V.

1. Michael Lacey
(Countsl- -70, 81, 83100)

.. 2. James Larkin

(Counts 1?68, 80, and 87)

3. Scott Spear
(Counts 1?68, 71-78, 85, and 93)

4. John ?Jed? Brunst
(Counts 1-70, 78?84, and 86-93) 

5. 9 Dan Hyer
(Counts 1-68)

6. Andrew Padilla

(Counts 1-51)

9 7. Joye Vaught

(Counts 1? 51)
Defendants.

 

 

 

No. CR (BSB)

SUPERSEDING
INDICTMENT .

V10: 18 US C. 371
(Conspiracy)
Count 1

18 U. S. ?1952(a)(3)(A)
(Travel Acthac1l1tate Prostitution)
Counts 2 51 .

18 C. ?1956(h)

(Cons iracy to Commit Money
Laun er1ng)

Count 52

18 U. S. C. 1956(a)(1)(B)(i)
(Concealment Money Laundering)
Counts 53(International Promotional Money

Laundering)
Counts 63- 68

'18 U. S. C. 1957(a)
(Transactional Money Laundering)
Counts 691956(a)(2)(B)(i)
(International Concealment Money
Laundering)

Count 100

 

 



i?t, 0

Case Document 230 Filed 07/25/18 Page 982(a)(1) 6% 9f. 
$85309); 28 U. S. C. ?2461(c)
o1fe1ture Allegations)

 

 

 

THE GRAND JURY 
A. Introduction I
1. The website (?Backpage?) was, until being shut down

by federal law enforcement authorities in April 2018, notorious for being the internet?s
leading source of prostitution advertisements. Backpage derived the overwhelming
majority of its revenue from such ads. These practices enabled Baclcpage to earn over $5 00
million in prostitution- r?elated revenue during its fourteen years of existence.

2. Backpage was created in 2004 by defendant MICHAEL LACEY
defendant JAMES LARKIN and a third individual, C.F. From
2004?15, LACEY and LARKIN oversaw the website?s policies and strategic direction.
Additionally, LACEY and LARKIN retained significant over the website (and
continued receiving tens of millions of dollars of Backpage?related distributions) after
purportedly selling their interests in Backpage in 2015. i A i

3. Defendant SCOTT SPEAR served as the Executive Vice President of one of
Backpage?s parent companies and held, at times, an ownership interest in Backpage of
approximately A i

4 Defendant JOHN BRUNST served as the Chief

Financial Officer of Backpage and several of. Backpage? parent companies and held, at

times, an ownership interest in Backpage of approximately 

5. Defendant DAN HYER joined Baclcpage?s marketing department
in or around 2006 and served as Backpage?s Sales and Marketing Director.

6. Defendant PADILLA served as Backpage?s 

Operations Manager.

 

 

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Case Document 230 Filed 07/25/18 Page 3 of 92

7. Defendant JOYE VAUGHT served as Backpage?s assistant
Operations Manager. i

8..) The defendants identi?ed above are referred to at times in this Superseding
Indictment as the I

9. AS explained in detail below, the BACKPAGE DEFENDANTS were aware
that the vast majority of the ?adult? and ?escort? ads appearing on Backpage were actually I
ads for prostitution and took steps to intentionally facilitate that illegal activity. For
example, during Backpage?s early years. of operation, the. company?s employees were
aetually trained to?and paid bonuses for?identifyingprostitutes who were postingads
on rival websites, creating free ads'on Backpage for them, and using the resulting Ba'bkpage
ads (which would only remain free for a trial period) in an attempt to secure the prostitutes? .
future business. These affirmative content?creation efforts, which were described
internally as ?content aggregation? or the ?Dallas Plan,? were vital to Backpage?s early
growth and success. 

10. . Backpage also employed other business strategies that were speci?cally
intended to promote and facilitate prostitution. For example, for several years, Backpage
had a reciprocal link agreement with The Erotic Review a website that permitted 
customers to post explicit ?reviews? of their encounters with prostitutes, including
descriptions of prices charged for particular seX acts. Backpage paid tens of thousands of
dollars to TER in return for assistance in getting customer base to start using
Backpage. 

11. In addition to affirmatively creating prostitutionurelated content and .

intentionally soliciting prostitution-related business, Backpage also utilized a variety of

strategies to conceal the true nature of the ads being posted on its website. Most notably, I

Backpage periodically used computerized, ?lters and human ?moderators? to edit the
wording of (or block) ads that explicitly offered sexual services in return for money. The
BACKPAGE DEFENDANTS admitted?in internal company documents and during

private meetings?that, despite these editing practices, they knew the overwhelming



 

 




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Case Document 230 Filed 07/25/18 Page 4 of 92

majority of the website?s ads prostitution. In one internal document, LACEY
actually bragged about the company?s contributions to the prostitution industry:
?Backpage is part of the solution; Eliminating adult advertising will in no way eliminate
or even reduce the incidence of prostitution in this country. . . . For the veryifirst time, the
oldest profession in the world has transparency, record keeping and safeguards.?

12. Notwithstanding these private admissions, the BACKPAGE
DEFENDANTS took pains to mislead the public, regulators, and law enforcement officials
concerning the supposed sincerity of Backpage?s efforts to prevent the publication of
prostitution?related ads. For example, after reviewing written description of
Backpage?s contributions to the prostitution industry and editing practices, LARKIN
instructed CF. to prevent ?any of the information in this being made public.? PADILLA,
who helped supervise Backpage?s moderators, threatened to fire any employee who
acknowledged in writing that the ?escorts? depicted in the website?s ads were actually
prostitutes: ?Leaving notes . . . implying that we?re aware of prostitution . . . is enough to
lese your job over.? And in one internal document, Backpage?s media strategy was
described simply as ?Do not acknowledge the prostitution.?

13. Many of the ads published on Backpage depicted children who were victims
of sex trafficking. Once again, although Backpage sought to create the perception that it
Was diligently attempting to prevent the publication of such ads, the reality is that Backpage
allowed such ads to be published while declining?for ?nancial reasonsmto take necessary 
steps to address the problem. For example, for several years, Backpage?s official policy,
when presented with an ad featuring the prostitution of a child, was to delete the particular
words in 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 featured the prostitution of a child?

it only created a veneer of deniability and helped Backpage?s customers (113., pimps

traf?cking children) evade detection. Similarly, in April 2011, several BACKPAGE
DEFENDANTS were warned that the term ?New In Town? was a coded phrase used by

?pimps who shuttle children to locations where they do not know anyone and cannot get



 

 






 

Case Document 230 Filed 07/25/18 Page 5 of 92

help.? Nevertheless, Backpage continued for the next seven years to permit ads using the
phrase ?New In Town? to be published on its website.

14. Backpage also contributed to the proliferation of ads featuring the
prostitution of children in other ways. For example, an anti-sex trafficking organization

once suggested that Backpage provide an automatic warning message whenever a customer

searched for particular terms indicative of the prostitution of a child. In response, C.F.

acknowledged the proposal was a good one but declined to adopt it because Backpage
would not derive any public-relations benefit from doing so: ?This is a good idea but it is
not visible to AGs [state attorneys general] so it has little PR value. It is a low priority.?
Backpage also claimed it did everything in its power to alert the National Center for
Missing and Exploited Children whenever it became aware that a child was
being advertised on its website. However, the BACKPAGE DEFENDANTS implemented
policies to arti?cially limit such referrals. In one training document, moderators were
instructed not-to send emergency aleits to NCMEC in response to complaints filed by the
grandparents and other extended family members of children being advertised on the
website: ?Neice [sic],nephew, grandchild, cousin, etc. doesn?t count.? 

15. Virtually every dollar ?owing into Backpage?s coffers represented the
proceeds of illegal activity. In fact, by 2015, the major credit card companies stopped
processing payments for Backpage and some banks closed Backpage?s accounts out of
concern they were being used for illegal purposes. In response, the BACKPAGE
DEFENDANTS pursued an array of money laundering strategies. These strategies
included instructing customers to send checks-and money orders to a particular Post
Office box, depositing those payments in bank accounts held in the name of entities with
no apparent connection to Backpage, and then giving customers a corresponding ?credit?
on Backpage to purchase new ads, wiring the proceeds of Backpage?s business to bank
accounts held in foreign countries and then redistributing the funds to certain BACKPAGE
DEFENDANTS (as compensation) or redepositing the funds in bank accounts held in the

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



 

 






 

Case Document 230 Filed 07/25/18 Page 6 of 92

operations), and converting customer payments, and the proceeds of Backpage?s
business, into 

16. The BACKPAGE DEFENDANTS also engaged in other financial
transactions designed to conceal their misconduct and evade seizure by law enforcement.
For example, in July 2016, LACEY wrote an email seeking assistance in ?put[ting] some
assets in place[s] where . . . government parties . . . can not access my accounts.? A few
months later, LACEY asked employees of an Arizona-based bank for advice on how to
move his assets ?offshore? to protect them from seizure by the government. Soon
afterward, $16.5 million in Backpage-derived cash was wired from bank .-
accounts in the United States to an overseas bank account in Hungary. At the time of the
Hungarian transfer, LACEY was facing criminal charges in California state court and was
aware of the federal grand jury investigation in this matter.

17. For all of these reasons, the BACKPAGE DEFENDANTS are charged in this
superseding indictment with the crimes of facilitating prostitution (18 U.S.C. 1952),
concealment, transactional, international promotional, and international concealment
money laundering (18 U.S.C. 1956 and 1957), and/or conspiracy to commit these
offenses (18 U.S.C 371' and 1956).

B. Baekpage?s Origins, Ownership, and Control

18. LACEY and LARKIN are the founders of the Phoenix New Times, an
alternative newspaper based in Arizona. . Over time, LACEY and LARKIN acquired
several other alternative newspapers, which they came to operate through entities called
New Times Media and Village Voice Media Holdings (referred to collectively for ease of
reference as Additionally, SPEAR served as Executive Vice
President and BRUNST served as Chief Financial Officer.

19. The publications within the VVMH newspaper chain routinely featured
illegal prostitution ads. In fact, more than 30 years ago, a federal court affirmed the
conviction of the operator of a prostitution business (which masqueraded as a massage

parlor) for publishing ads in the classified section of the Village Voice. See United States



 

 

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Case Document 230 Filed 07/25/18 Page 7 of 92

v. Sigalow, 812 F.2d 783 (2d Cir. 1987). The conviction was for violating 18 U.S.C.
1952, one of the same crimes charged in this Superseding Indictment.

20. By 2000, the rise of the internet?and, in particular, the website
(?Craigslist?), which offered free classified. ads?began to
significantly disrupt business model, which depended on classified advertising
revenue for survival.

21. LACEY and LARKIN, with assistance from C.F., sought to address this
threat by creating Backpage. Their decision to create Backpage was later described in an
internal company document as follows: ?In 2004, in response to the Craigslist threat that
was decimating daily newspapers, WM launched its own online classified site,
Backpagecom, named after the back page of print publication.?

22. During its first few years of operation, Backpage accounted for only a
fraction of overall revenue. In January 2006, for example, VVMH estimated that
Backpage supplied only 1% of its overall advertising revenue but also noted that Backpage
had ?tremendous upside potential.?

23. This prediction proved prophetic. By 2008, Backpage was generating over
$5 million in annual profit. This annual profit figure increased to over $10 million in 2009.

24. In 2010, Craiglist 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, made an aggressive push for Backpage to capture Craiglist?s share
of this market. In one internal document, LARKIN commented: ?Craigslist has folded
. . . . It is possible that this will mean a deluge of adult content ads for backpagecom . . . .
We have with the Village Voice probably the longest run of adult content advertising in
the US and it is, like it or not, in our 

25. This push was successful. In internal documents, Backpage stated that it
experienced ?explosive growth? by ?capitalizing on displaced Craigslist ad volume.?
Backpage?s annual profits grew to over $26 million in 2010, over $52 million in 2011, and

over $78 million in 2012.

 



1Case Document 230 Filed 07/25/18 Page 8 of 92

26. These ?gures dwarfed the profits that print publications were
generating. In fact, Backpage became so pro?table that the BACKPAGE DEFENDANTS
decided to get rid of publishing business so they could focus on Backpage?s
further development and expansion. Accordingly, in or around November 2012, the
BACKPAGE DEFENDANTS spun off print publications and began utilizing
several new corporate entities, including Medalist Holdings, Inc. (?Medalist?), Dartmoor
Holdings LLC (?Dartmoor?), and Camarillo Holdings, LLC (?Camarillo?), to serve as
Backpage?s parent companies.

27. Following these transactions, LACEY held an ownership interest in Medalist
(and, therefore, in Backpage) of approximately 45%, LARKIN held an ownership interest
of approximately 43%, BRUNST held an ownership interest of approximately and
SPEAR held an ownership interest of approximately 

28. Backpage?s annual profits continued to skyrocket during and after these
changes. They grew to over $112 million in 2013 and over- $134 million in 2014.

29. In or around April 2015, LACEY, LARKIN, SPEAR, and BRUNST
purported to sell their ownership interests in Backpage and several related'entities for
around $600 million to various Dutch entities. These Dutch entities included Atlantische
Bedrijven, C.V., which agreed to purchase Backpage?s U.S. operations for around $526
million, and. UGC Tech Group C.V., which agreed to purchase Backpage?s overseas
operations for around $77 million. 

30. In fact, these Dutch entities were controlled by C.F., who simply ?borrowed?
most of the $600 million from entities controlled by the sellers to finance the purchase.
Due to this financial arrangement, LACEY, LARKIN, SPEAR, and BRUNST retained a
significant financial interest in Backpage after the transactions were completed.

31. LACEY, LARKIN, SPEAR, and BRUNST also retained significant

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

- 2015 loan agreement required CF. to sign a six-year employment agreement, required C.F. 

to provide the lenders with full access to Backpage?s books and records, required CF. to



 

 






 

Case Document 230 Filed 07/25/18 Page 9 of 92

provide the lenders with an annual listing of all of personal assets, and prohibited
C.F. from opening new bank accounts on Backpage?s behalf without the lenders? consent.

32. LARKIN and others also met regularly with CF. following the April 2015
transaction to discuss and direct the operation of Backpage?s business, often taking steps
(such as avoiding the use of email and holding the meetings in the presence of attorneys)
intended to conceal their continued involvement in, and control over, the company.
Through these mechanisms, LARKIN and others exerted post?April 2015 control over
Backpage?s banking relationships, the migration of some of Backpage?s operations to the
Philippines, the management of Backpage?s counsel, Backpage?s acceptance of gift cards,
Backpage?s response to a Senate investigation, and Backpage?s licensing agreements.
Additionally, LARKIN and others took steps in 2018 to attempt to sell the company to a
new buyer. 1
C. Knowledge And Facilitation Of Prostitution

33. Prostitutionis illegal in 49 states and in most of Nevada. Advertisements for
prostitution services in those locations are, therefore, not protected by the First
Amendment.

34. As explained below, the BACKPAGE DEFENDANTS were aware that the
overwhelming majority of the website?s ?adult? and ?escort? ads were actually ads for
prostitution and took a variety of steps to intentionally facilitate that illegal activity. These

steps evolved over time and included, but were not limited to, creating free ads for

prostitutes in an attempt to secure future advertising revenues from them ?content

aggregation?), entering into formal business arrangements with known prostitution
services and websites in an attempt to increase the volume of prostitution advertisements
being posted on Backpage (116., reciprocal link and affiliate programs), and sanitizing ads
by editing them?specifically, removing terms and pictures that were particularly
indicative of prostitution and then publishing a revised version of the ad 

?moderation?).

 

 

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Case Document 230 Filed 07/25/18 Page 10 of 92

i. Aggregation
35. On or about April 10, 2007, SPEAR sent an email to HYER and CF.

concerning aggregation efforts in Dallas. SPEAR encouraged HYER and CF. to
create a ?blueprint? for ?moving that process to other cities.?

36. Included as an attachment to this email was a document entitled ?Dallas
success in other markets.? This document described Backpage?s aggregation process in
extensive detail. Among other things, it explained how Backpage employees would
?secure content? by running Google searches to identify prostitutes advertising on other
websites, then ?Call clients. Ask them if they have tried backpagecom. If not, post a free
ad with an auto repost for free for six weeks.? The document further stated: ?Dan Hyer to
direct and manage this process for all the cities. to consult and supervise.?

37. Also included, as another attachment to this email, was a document entitled
?Class Director Steps to grow Backpagecom visits and revenue.? Under the heading
?Aggregating Content,? it explained: ?For the past 6 months we'have uploaded 25 adult
. . . leads each week. Leads come from Adult websites, the Gay publication here in Dallas,
and the daily paper.? 7 

38. On or about June 15, 2007, several Backpage principals, including SPEAR,
HYER, and C.F., met in Oregon to discuss various Backpage-related developments. The
agenda for this meeting stated that HYER would be presenting on the topic ?How Dallas

grew to per month? and that this revenue growth was driven in part by creating

?adult content online for free? by posting ?20 free adult ads per week for prospects on other
sites with a 6 week auto repost for free.?

39. On July 18, 2007, HY ER sent an email that, among other things, summarized
Backpage?s ?Aggregation? efforts. It stated that Backpage?s employees were responsible
for ?Aggregat[ing] new adult content from other sites.?

40. On or about July, 20, 2007, several Backpage principals, including LARKTN,
SPEAR, and CF, met to discuss various Backpage-related developments. The agenda for

this meeting included a ?Dallas aggregation update.?

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Case Document 230 Filed 07/25/18 Page 11 of 92

41. On or about August 20, 2007, SPEAR sent an email to LARKIN, C.F., and
another Backpage principal. Enclosed with that email was an agenda for a meeting to be
held later that day. The agenda provided for another ?Dallas aggregation update? and
stated that Backpage employees were ?Wrapping up [aggregation] in SF, Nashvilleabout December 18, 2007, C.F. provided a document entitled
?Backpage strategic plan? to LARKIN, SPEAR, and BRUNST. Among other things, it
stated that Backpage intended to expand the Dallas aggregation efforts to other cities:
?Create additional Dallas adult revenue models in LA and This document also
contained a detailed summary of how the aggregation process worked (?Here?s the detail
on what the backpage staff does to create Dallas like results?), which included ?Set up free
user posting (250 to 500 postings per market)?

43. In November 2008, an internal company email was sent to LARKIN, C.F.,
and others stating that Backpage had just experienced its ?best month ever? in terms of
revenue. In response, C.F. sent a series of emails explaining that nearly all of the revenue
growth was due to aggregation efforts in Dallas: ?btw: the revenue wasngt [sic]
that great except for dallas. . . . Dallas sure gave us a nice bump. Hyer?s done an awesome
job with his marketing crew.? 

44. On or about October 25, 2013, C.F. sent an email to SPEAR summarizing
his ?to do list? for Backpage. It included a plan to - hire ?Content creators? in the
Netherlands to create free ads on Backpage for potential customers who were posting on
?competing sites.?

ii. Reciprocal Link And Affiliate Programs

45. On July 2, 2007, C.F. sent an email to SPEAR entitled ?The erotic review.?
In this email, C.F. explained that Backpage received ?2 million page views, 150,000 visits
from the erotic review per month. They bring in more referrals than the Village Voice.?
C.F.. also sought permission from SPEAR to initiate a business arrangement with TER

under which the two companies would post reciprocal ads on each other?s website.

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Case Document 230 Filed 07/25/18 Page 12 of 92

46. On July 16, 2007, HYER sent an email to SPEAR and CF. summarizing
various criticisms of a particular Backpage employee. Among other thing, the email chain
stated that the employee was deleting adult ads too quickly, which ?kills the sites see
[search engine optimization] as in no traffic from TheEroticReview.com. . . . Why care?
Without TheEroticReview traffic you might as well kiss any growth in [that city] good
bye.? On August 31, 2007, OF. sent a follow-up email to HYER concerning this employee
that explained: ?We have a deal with the TER. It?s a reciprocal link program where we
get an additional million page views from TER. . . . The TER deal is very big for us. The
internet makes strange bed fellows.?

47. On or about July 20, 2007, several Backpage principals, including LARKIN,
SPEAR, and C.F., met to discuss various Backpage-related developments. The agenda for
this meeting stated that Backpage intended to ?Trade with in order to ?increase traffic
in adult.?

48. On or about August 20, 2007, several Backpage principals, including
LARKIN, SPEAR, and CF, met to discuss various Backpage-related developments. The
agenda for this meeting provided an update on the previous efforts to create a business
partnership with The Erotic Review, stating: ?Trade with TER - complete.?

- 49. On ?or about December 18, 2007, CF. provided a document entitled
?Backpage strategic plan? to LARKIN, SPEAR, and BRUNST. Among other things, it
stated that Backpage intended to ?look for more relationships like TER to drive traffic?
and to ?Expand relationship with The document also stated, that, when seeking to
expand Backpage?s business in particular cities, Backpage employees would ?Set up 100
fresh TER reciprocal links to the specific city? and that a key to Backpage?s growth was
?Drive traffic via reciprocal links . . . . Example of PR [public relations] is the posting in
the forums in TER talking about us.?

50. On or about December 20, 2007, CF. provided a document entitled ?2008
Budget and Business Plan for Backpagecom? to LARKIN, SPEAR, and potentially others.

Among other things, it explained: ?In terms of marketing, we struck a deal with



 

 








 

Document 230 Filed 07/25/18 Page 13 of 92

TheEroticReview (TER) with reciprocal links. It created huge brand awareness in this
niche industry and increased page Views from 120,000 per day.?

51. On or about December 14, 2008, CF. provided SPEAR with a document
discussing Backpage?s budget. Among other things, it noted that Backpage was paying
$4,000 per month nearly $50,000 per year) to place advertisements on The Erotic

- Review banner ad on ter?). The document further noted that ?We have made a special

buy with TER in terms of high quality referrals.?

52. On or about December 17, 2008, OF. distributed, to other Backpage
principals, a document entitled ?How We Are Going To Get There In 2009.? Among other
things, this document identified Backpage?s top marketing strategy as high page 1
view per referral? and stated ?We have made a special buy with TER in terms of high
qualify referrals.? 

53. On May 7, 2009, HYER and CF. exchanged emails concerning how to
improve Backpage?s business relationship with TER, with CF. commenting: think we
need to move some staff on this project and make one more play to get to 40,000 referrals
per day.?

54. On May ll, 2009, LARKIN forwarded a news article to OF.
that described a recent ?prostitution bust? in Phoenix in which 43 people were ?indicted on
charges of having roles in a prostitution syndicate.? The article further noted that some of
the defendants had provided reviews on TER, which was described in the article as a
?prostitution website.? In the subject line of the email, LARKIN summarized the article?s
contents as follows: ?johns accused of favorably rating escorts on Erotic Review in
exchange for discounts.?

55. Between around June 10, 2009, and June 19, 2009, HYER and CF.
exchanged additional emails concerning how to improve Backpage?s business relationship
with TER. In one email, C.F. stated: need help creating a wish list to discuss with the
TER peoplereferrals by 2010.?

56. on or about November 1, 2011,. CF. met with LARKIN and SPEAR to

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Case Document 230 Filed 07/25/18 Page 14 of 92

discuss Backpage?related developments. The agenda for this meeting noted that Backpage
was still obtaining ?very strong referral traf?c? based on its ?Reciprocal link relationships?
and stated that Backpage was considering a ?move offshore? because such a move would
?Minimize restrictions? and ?Allow more skin.?

57. The BACKPAGE DEF ENDANTS were routinely forwarded and/or briefed
about ?Google Analytics? reports, which provided a snapshot of which other
websites were referring users to Baokpage. For example, on July 27, 2012, LARKIN sent
an email to SPEAR, BRUNST, and CF. stating: Jed, and Scott: These are the
topics I would like to cover in our discussion 10:00 am Wednesday in Phoenix. . .

[A]nalytics . . . On December 19, 2012, CF. sent an email to LARKIN, SPEAR, and

BRUNST that included, as attachments, various Google Analytics reports. And on March

4, 2014, LARKIN, SPEAR, BRUNST, HYER, and CF. received an email from another
executive stating: have attached 2 items. A An agenda for tomorrow and an excerpt from
Google Analytics to show a comparison of January and February.?

58. These Google Analytics reports confirmed that TER was playing a crucial
role in driving traffic to the Backpage website. For example, the report for January
2009 stated that TER was the #1 outside source of referrals and was responsible for over .
half a million visits that month. The daily report for March 22, 2010 showed that TER was
responsible for referring more than 40,000 daily visits to Backpage?more than six times
as many as the next-biggest referral source. The daily report for February 1, 2012, again
showed that TER was responsible for referring more than 40,000 daily visits to

Backpage~?more than three times as many as the next-biggest referral source. The

report for August 2013 showed that TER was responsible for nearly 1 million

visits each month. And the report for November 2014 showed that, once again,
TER was the #1 source of non-search engine referrals.

59. In addition to pursuing a formal partnership with TER, Backpage also formed
?affiliate? partnerships with other organizations and individuals who were knoWn to be

involved in the prostitution industry. One such individual, known as ?Dollar Bill,? earned

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Case Document 230 Filed 07/25/18 Page 15 of 92

fees in return for arranging for prostitutes and pimps to post ads on Backpage.

60. On March 5, 2010, PADILLA received an email from a co?worker that
described Dollar Bill as a ?super affiliate? and sought assistance in restoring
two of Dollar Bill?s ads that had been deleted Backpage. In response, PADILLA
stated ?i?m working . . . on it now? and forwarded the email chain to CF.

61. On or around March 18, 2010, Backpage deleted over 4,000 ads that had been
presented by Dollar Bill. After Dollar Bill called to complain, PADILLA sent an email to
Backpage?s computer programmers stating that ?4200 ads need to be restored? and
explaining that ?[t]his is one of our largest adult accounts and the restoration of these ads
is a high priority for us.? I

62. On April 15, 2010, Dollar Bill sent an email to CF. proposing the creation
of a new website called ?Dollar Bills Escort Roundup? that would ?discuss[] issues in the .
escort business and give[] insider info from an Editor who knows the biz from both sides
via my unique relationship with the girls.? The email further stated that the proposed new
website ?could sell ads in local areas just like best gfe does.?

63. On OctOber 24, 2010, Dollar Bill sent an email to CF. requesting a reduction 
in the rates that Backpage was him charging for ads. Dollar Bill argued he was entitled to
such a reduction because ?I?ve championed Backpage in print and with the girls in the past?

and because don?t feel there Should be a statute of limitations on residual benefits

Backpage gives me for my previous contributions which by your own admission were

consideration. . . . [W]hy would you want to raise my rate when I was so instrumental in
building New York, where you?re making a bloody fortune??

64. On October 25, 2010, Dollar Bill sent an email to CF. complaining about
Backpage?s decision to refuse one of his ads even though NEVER SAID and
noting that other, even more obvious prostitution ads had been published despite ?saying


65. On December 29, 2010, HYER sent an email to SPEAR and CF. entitled
?Sales Marketing 2011 Working Agenda.? One of the agenda items was ?[Dollar] Bill

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Case Document 230 Filed 07/25/18 Page 16 of 92

. . . rate increase.?

66. On February26, 2011, Dollar Bill wrote an email to CF. complaining that
the nude pictures had been stripped out of one of his ads (which was entitled ?real?crazy-
In response, OF. advised Dollar Bill that ?[t]his user sneaking in
nudes may need to be set for forced moderation? and then forwarded the email chain to
adjusted Backpage?s filter accordingly.

67. On December 21, 2011, Dollar Bill wrote an email to CF. discussing
whether Backpage would publish 15 ads depicting a particular ?girl? who ?makes about 10
grand a week. . . owns 4 apartments . . . and a Store! . . . millionaire several times over
at age 28. And all from being an escort!? In response, C.F. stated that the-enclosed picture
was ?a little too nude for us? and provided advice to Dollar Bill on how to wordsmith ads
so they wouldn?t be rejected by Backpage?s moderators.

Moderation And Notice

68. In April 2008, CF. 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 and
result in ?lost pageviews and revenue.? Thus, he 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.

69. On February 26, 2009, OF. received an email asking why Backpage?s terms

'of service purported to prevent customers from ?suggest[ing] an exchange of sexual favors

for money? in light of the fact that ?[c]learly everyone on the entire backpage network
breaks the rules.? In response, CF. didn?t dispute the author?s characterization and
explained that Backpage had simply added the terms of service at the behest of ?our
attorney in in an attempt to avoid liability in civil lawsuits.

70. On May 25, 2009, SPEAR received an email summarizing a plan to begin
?remov[ing] sex act pics and coded terms? from Backpage ads. Later that day, C.F.

forwarded this email to HYER with the explanatory note that ?We do not intend to be a

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Case Document 230 Filed 07/25/18 Page 17 of 92

craig[slist] here, just get out the most egregious stuf 

71. On March 8, 2010, OF . testi?ed in federal court (the United States District
Court for the Southern District of Florida) in the criminal trial of a pimp who had used
Backpage to post prostitution ads. During his testimony, C.F. acknowledged the defendant
had used the email address ?Youngpimpin86? when posting the ads. CF. also
acknowledged that the ads described one so-called escort as ?five~foot-three, with a small
waist and amazing ass you?ll have to see to believe. XL, XL, XL, Lollipop? and described
a different so?called escort as ?discrete, sincere and extremely naughty. I am the type of
girl who absolutely adores a man who understands the many desires of a young beautiful
woman and how to accommodate a variety of fantasies.? This episode provided notice to
Backpage that it was implausible to pretend such ads were merely offering lawful escort
services. .

72. On September 1, 2010, PADILLA sent an email to HYER and CF. stating
that customers who engaged in ?extreme and repeat? violations of Backpage?s posting rules
would have their ads deleted and be banned from the website. However, PADILLA also
stated the bans would only be temporary and that ?we?ll do everything we can to affect
only the worst apples.?

73. On September 1, 2010, SPEAR received an email acknowledging that
Backpage?s moderators were being instructed to ?Remove any sex act pics in escorts [ads]?
and"?Remove any illegal text in escorts [ads] to include any code words for sex act for
money.?

74. On September 21, 2010, a group of state attorneys general wrote a letter to
Backpage. This letter observed that ?ads for prostitution?including ads trafficking
children?are rampant on the site? and argued that ?[b]ecause Backpage cannot, or will 
not, adequately screen these ads, it should stop accepting them altogether.? The letter
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

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Case Document 230 Filed 07/25/18 Page 18 of 92

to be victimized, in the marketplace provided by backpage.?

75. On September 25, 2010, C.F. 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. Thus, C.F. announced that Backpage would ?go back to having our
moderators remove bad content in a post . . . 

76. On September 30, 2010, C.F. testified in federal court (the United States
District Court for the District of Minnesota) in the criminal trial of a pimp who had used
Backpage to post prostitution ads. During his testimony, C.F. acknowledged that
Backpage?s servers are located in Arizona and that the ads posted by the Minnesota-based
defendant had therefore ?traveled across state lines.?

77. On October 8, 2010, PADILLA sent an email (on which VAUGHT was odd)
threatening to fire any Backpage employee who acknowledged, in writing, that a customer
was a prostitute: ?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.?

78. On October 16, 2010, PADILLA sent an email to a large group of Backpage
employees (including HYER and VAUGHT). The email had two attachments that
provided 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. PADILLA concluded the email by stating:
the language in ads that?s really killing us with the Attorneys General. Images are

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Case Document 230 Filed 07/25/18 Page 19 of 92

almost an afterthought to them.?

79. On October 16, 2010, PADILLA sent a separate internal email (which also
included HYER and VAUGHT as recipients). In this email, PADILLA explained that ?I?d
like to still avoid Deleting ads when possible,? that ?we?re still allowing phrases with
nuance,? and that the case of lesser violations, editing should be sufficient.?

80. On October 21, 2010, OF. sent an email to PADILLA stating: ?Maybe

lighten up on the images moderation. Spear tells me it?s the text that is the problem.? In 

response, PADILLA wrote: the training i?ve given the staf 

81. On October 25, 2010, CF. sent an email to SPEAR, HYER, and PADILLA
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 pics are removed,? the ?ad text may stay.?

82. On October 26, 2010, HYER and PADILLA reCeived an email explaining:
?We will not remove ads with vaginas or penis showing, just the images unless they are a
frequent offender. We will not remove ads with rates under an hour, just the text with the
minimum rates. Users need time to react to this change.?

83. On October 27, 2010, PADILLA sent an email to the head of a group of
contractors from India who had been hired to moderate Backpage?s adult ads. In this email,
PADILLA criticized the contractors for deleting too many ads, stated that this approach
was bad for business, and instructed the contractors to simply edit the ads to remove the
more-obvious language: ?As long as your crew is editing and not removing the ad entirely,
we shouldn?t upset too many users. Your crew has permission to edit out text Violations
and images and then approve the ad.?

84. On November 4, 2010, OF. sent an email to Backpage?s India-based
moderators (on which PADILLA was cc?d) explaining that any of the ads need to have
15 minute and 30 minute pricing removed? and that ?I?m being evaluated by lawyers 
state attorneys general] later this week so cleaning up old stuff is important.?

85. On November 17, 2010, HYER and PADILLA received an email

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Case Document 230 Filed 07/25/18 Page 20 of 92

acknowledging that the term Lolita is ?code for under aged girl? but explaining that this
term could simply be stripped out from ads (as opposed to refusing to publish the ad). The
email also explained that customers should be allowed to include their identi?cation
numbers from The Erotic Review: ?[A]llow users to put in TER IDS (just no live links).?

86. On November 30, 2010, LARKIN, SPEAR, and other Backpage
representatives participated in a conference call with representatives from NCMEC.
During this call, the Backpage representatives were advised that a large portion of the ads
on Backpage were blatant prostitution ads, that many of those ads featured children, and
that the posting of such ads" was illegal in every state.

87. In December 2010, HYER, and others exchanged a series of
emails entitled ?Deep cleaning strip out?" These emails identified a list of terms
that were indicative of prostitution and discussed plans for removing the terms from the
old ads in Backpage?s archives. During this exchange, CF. stated that Backpage wasn?t
willing to delete the old prostitution ads because ?our users love? having access them,
best to do deep cleaning and not kill a valuable feature.? C.F. later encouraged
Backpage?s staff to complete the project quickly to avoid scrutiny: ?This task is urgent
since CNN is runing [sic] a report soon.?

88. On January 13, 2011, HYER and PADILLA received an email summarizing
instructions that had been provided to members of Backpage?s techniCal staff. It explained
that the technical staff had been instructed ?not to display the moderation log? in a.
particular section of Backpage?s database ?since we this page for subpoenas. I would 
rather not testify'in court as to why my staff ?approved? . . . postings.?

89. In January 2011, LARKIN and LACEY met with a representative from
NCMEC. During this meeting, LACEY asked which types of seX ads would be acceptable
from 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.?

90. On January 31, 2011, and February 1, 2011, OF. engaged in an email

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Case Document 230 Filed 07/25/18 Page 21 of 92

exchange concerning Whether to remove links to other prostitution websites (such as TER)
from expired Backpage ads. C.F. stated that, although SPEAR and his ?internet safety I
guy? were recommending that such ads be removed, he thought this would ?be a stupid
move? because it would hurt Backpage financially (by reducing the number of referrals
from other sites). C.F. added that ?this overly zealous focus on moderation at the expense
of other development is a lot of bullshit . . . 

91. On February 3, 2011, a Backpage customer who went by the namel?Licks

- Alot? wrote an email to Backpage complaining that all of the pictures in one of her ads 0

(entitled ?Athletic SWF Guaranteed Low Mileage had been deleted. OF.
responded to ?Licks Alot? by explaining that one of her photos had been removed because
?[o]ur crazy internet safety experts do not want any genitalia showing up around the
thong.? However, C.F. proceeded to apologize to ?Licks Alot? over the removal of her
remaining photos, allowed her ad (which was obviously for prostitution) 'to remain On the
website, and offered her a free upgrade.

92. On February 8, 2011, OF. testified in federal court (the United States District
Court for the Middle District of Florida) in the criminal trial of a pimp who had used
Backpage to post prostitution ads. During his testimony, OF. authenticated one of the ads
the defendant had placed on Backpage, whose title was ?Extra horny sexy newbie,?
con?rmed that Backpage had allowed this ad to be posted multiple times in various East
Coast cities, and acknowledged that Backpage published ?a lot? of similar ads. This
episode provided further notice to Backpage that it was implausible to pretend such ads
were merely Offering lawful escort services.

93. On February 16,- 2011, PADILLA sent an email to Backpage?s India-based
moderators (on which VAUGHT was cc?d) explaining that Backpage was adopting a
?more lenient policy? and that he was instructing his Phoenix-based employees to ?go easy
on some types of violations.? PADILLA acknowledged this approach would ?likely? result
in more ?violations? but emphasized that ?moderators should err on the side of the user.?

94. On February 16, 2011, PADILLA sent a separate email discussing whether

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Case Document 230 Filed 07/25/18 Page 22 of 92

several terms should remain on Backpage?s ?filtered terms? list. During this discussion,
PADILLA acknowledged?by placing quote marks around the term ?companionship??
that he didn?t actually believe the women being advertised on Backpage were providing
lawful escort services: ?[The term] implies some exchange of bodily ?uids which kills our
?companionship? argument, but i don?t think we?ve ever really gotten in trouble forit.?
95. On February 22, 2011, PADILLA received an email requesting Backpage?s
?list of banned, stripped out adult terms.? In response, PADILLA sent an Excel
spreadsheet entitled ?Phrase List 0221 which PADILLA described as ?the latest greatest
version of the list.? The enclosed spreadsheet identi?ed, over 660 words or phrases that are
indicative of prostitution, including an array of terms that are suggestive of child

99 

prostitution ?lolita,? ?fresh,? ?high school,? ?tight, young?). The spreadsheet
explained that most such terms were simply to be ?filtered? from the 'ads in which they
appeared.

96. On February 23, 2011, PADILLA received an email concerning a particular
ad that had been edited by Backpage?s India-based moderators. The ad was obviously for
prostitution?its title was ?new?new?new-put me in your favorite position? and the poster
had attempted to include two photographs that violated Backpage?s posting rules. In
reSponse, the India-based moderators had deleted both of those photos, as well as a third
photo that depicted the prostitute?s face, and then allowed the ad to be published. The
email received by PADILLA did not criticize themoderators for allowing an obvious
prostitution ad to be published after editing. To the contrary, it emphasized that the ad
should remain on Backpage and criticized the moderators for removing the third photo,
threatening to fire them if they did it again: ?2 out of 3 pics should have been removed.
But [the] moderator deleted all three pics. This is plain wrong . . . . 1 would ?re a moderator
in Phoenix if they did this.? I i

97. In March 2011, LARKIN, LACEY, SPEAR, and other Backpage
representatives met with representatives from NCMEC. During this meeting, the Backpage

representatives were again advised that a large portion of the ads on Backpage were blatant

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Case Document 230 Filed 07/25/18 Page 23 of 92

prostitution ads. The Backpage representatives also were advised they could be criminally

prosecuted under federal law for their conduct.

98. On or about March 9, 2011, CF. distributed, to other Backpage principals, a
document entitled ?Backpage Growth Agenda.? Among other things, this document stated
that the company intended to renew its focus on ?growth and efficiency? by ?adjust[ing]
content rules to be more ?exible? and to permit more coded terms: ?Allow 30 minutes,
naughty, etc. Nipples.? This document also discussed plans to expand to certain countries
in Europe, where Backpage would explicitly ?Allow nudity and sex for money text.?

99. On April 5, 2011, PADILLA sent an email whose recipients included
VAUGHT and the supervisor of Backpage?s Indian moderation team. The email was
entitled ?relaxed image standards? and included, as an attachment, a document that
displayed a series of 30 nude and partially-nude photographs. Next to each picture was an
instruction as to whether it should be approved or disapproved by a moderator. One picture
showed a woman sitting on a bed, wearing only a bra and panties, with her legs spread
open and her hand partially covering her crotch. The caption provided in part: ?okay 
but barely.?

100. On April 27, 2011, LARKIN, SPEAR, CF, and others received an email
from a firm that Backpage had hired to assist with ?internet safety? issues. Enclosed with
the email was a list of recommended ?action items? for the company to pursue. One such
item, listed in the category of ?Finding Illegal Ads,? warned that ??New In Town? 
terminology is often used by pimps who shuttle children to different locations where they
do not know anyone and cannot get help.? Another item, also listed in the category of 
?Finding Illegal Ads,? recommended that Backpage should ?[dletermine if there is a way
to figure out if a [credit] card being used is prepaid; this could be one indicator (of many)

. . . as a potential trafficking ad.? And yet another recommendation, under the category of

?Finding Illegal Ads,? was to ?[c]reate a way to ?gure out if one phone number is being

used on numerous different ads . . . [because] this could indicate a prostitution situation or

a human traf?cking situation.?

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inCase Document 230 Filed 07/25/18 Page 24 of 92

101. Backpage disregarded all of these recommendations. After April 2011, the
company continued publishing ads using the phrase ?New In Town,? continued accepting
prepaid credit cards (in fact, such cards supplied a large portion of the company?s
revenues), and continued allowing a person with a single phone number to post
advertisements for multiple ?escorts.? - i

102. Between April 2011 and March 2012, PADILLA, CF, and others
participated in an email exchange acknowledging that Backpage was deleting thousands of
pictures from customer ads each week and seeking assistance in collecting all of the deleted
pictures so they could be used for ?entertainment? or to generate user ?traffic for other
projects.? The email explained that the deleted pictures could be made available to the
public on a new website called ?nakedpics.backpage.com? or ?badpics.backpage.com.?i?

103. On April 19, 2011, LARKIN and SPEAR received an email seeking
permission to terminate the contract of a third?party vendor that had been receiving $17,000
per month to ?remov[e] any nude pics? from the expired ads in Backpage?s database.
LARKIN responded: ?do it!?

104. On June 7, 2011, OF. received an inquiry from a law enforcement official
about a particular ad that included the term ?amber alert.? In response, OF. acknowledged
this might be ?some kind of bizarre new code word for an under aged person.? OF. then
forwarded this exchange to PADILLA and stated that he had instructed HYER to add
?amber alert? to Backpage?s ?strip out? list. In other words, HYER, PADILLA, and CF.
did not require all future ads involving this particular coded term for the prostitution of a
child to be blocked from Backpage?they merely required such ads to be edited before
publication.

105. On June 30, 2011, several Backpage representatives met with representatives
from the office of the Washington State Attorney General. During this meeting, the
Backpage representatives initially attempted to claim that no prostitution ads appeared on
their website. In response, a representative from the Attorney General?s office stated:

?You mean to tell me that if someone responded to an advertisement, the woman they

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Case Document 230 Filed 07/25/18 Page 25 of 92

called for services would be offering to go out for coffee?? A Backpage representative
responded to this question by looking at C.F., laughing, and acknowledging that Backpage
couldn?t ?deny the undeniable.? .

106. On July 27, 2011, CF. sent an email to HYER and PADILLA, and a nearly-
identical email to LARKIN and LACEY, concerning the possibility of using age?
verification software. In this email, C.F. acknowledged the software might be bene?cial
(?This might be our solution?) but recommended against its wholesale adoption because it
would cost ?79 to 99 cents per query? and would thus cut into Backpage?s pro?ts.

107. On July 28, 2011, LACEY sent LARKIN a draft editorial entitled ?BackPage
understood.? In this document, LACEY bragged about Backpage?s contributions to the
prostitution industry: ?Backpage is part of the solution. Eliminating our adult advertising
will in no way eliminate or even reduce the incidence of prostitution in this country. . . .
For the very ?rst time, the oldest profession in the world has transparency, record keeping
and safeguards.? LACEY also acknowledged that Backpage used an automatic filter to
remove particular phrases from ads that were indicative of prostitution but still published
the ads after editing them. i 

108. Soon afterward, LARKIN forwarded the editorial to OE, With a cover note
cautioning against some of statements ?being made public? because ?we need
to stay away from the very idea of ?editing? the posts, as you know.? C.F., in turn, revised
the editorial to take out the paragraph landing Backpage?s contributions to the prostitution
industry.

109. On August 5, 2011, Backpage received a letter from the mayor of Seattle.
This letter warned that ?Seattle Police have identi?ed an alarming number of juvenile
prostitutes advertised on Backpagecom 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
sexi ads? and ?your services are a direct vehicle for prostitution.? The letter also

recommended that Backpage require age veri?cation for all of the ?escorts?

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Case Document 230 Filed 07/25/18 Page 26 of 92

depicted in its ads. Afterward, Backpage declined to adopt these recommendations.
110. On August 15, 2011, PADILLA received an email containing an updated
version of Backpage?s moderation guidelines. This six-page document provided the

following instructions concerning photographs: ?Nude rear shots are okay as long the

model is not exposing her anus er genitalia,? ?Transparent wet panties okay should not be

able to see personal private part,? and ?cherry, Ice-cream keeping in mouth [is okay] The
document also explained that ?Bikini, lingerie, g?string, thong, and hands covering nipples
are all allowed,? ?Hourly rates are and ?Sessions are okay. E. $50 session.?

?111. On August 31, 2011, Backpage receiVed a letter from the National
Association of Attorneys General. This letter characterized Backpage as ?a hu for
human trafficking, identified ?more than 50 instances, in 22 states over three years, of
charges filed against those traf?cking or attempting to traffic minors on Backpagecom,?
and noted that ?[n]early naked persons in provocative positions are pictured in nearly every
adult services advertisement on'Backpagecom and the site requires advertisements for
escorts, and other similar ?services,? to include hourly rates. It does not require forensic
training to understand that these advertisements are for prostitution.?

112. In or around September 2011, certain BACKPAGE DEFENDANTS assisted
in the creation of a Powerpoint presentation, entitled ?Management Presentation,? that was
intended to describe Backpage?s business model to potential buyers. This presentation
acknowledged that the non-adult sections of the Backpage website were simply intended

993

to ?allow[] ?plausible deniability, to make the website more palatable to ?regulatory and
law enforcement? of?cials, and to otherwise make Backpage?s adult section more
?defensible.?

113. On October 6, 2011, CF. sent an email discussing various proposals for
addressing ?the under aged issue.? With respect to one particular proposal, C.F.
acknowledged it was a good one but recommended against adopting it because Backpage

would not derive any public?relations benefit from doing so: ?This is a good idea but it is

not visible to [state attorneys general] so it has little PR value. It is a low priority.?



 

 






 

Case Document 230 Filed 07/25/18 Page 27 of 92

114. In the fall of 201 1, Backpage sought the assistance of a public relations firm
based in Washington, DC. On October 12, 2011, OF. received a written copy of the ?rm?s
presentation. Later, some of the BACKPAGE DEFENDANTS attended a meeting at

which the presentation was discussed in more detail. The presentation warned that

Backpage?s' buSiness practices would inevitably result in legal trouble (?One day the
proverbial is going to hit the fan?) and characterized Backpage?s ?media strategy? as ?Do
not acknowledge the prostitution.? The presentation also noted that the ?ads on the
backpage.com site? generally fall into three categories, one of which is ?Pimps and Men
Looking for Kids.?

115. On October 21, 2011, LARKIN received an email discussing whether the
Backpage website should include a warning message concerning the prostitution of
children. This email contained the following joke: ?Andrew thinks it to[o]
heavy handed and thinks our web site name will be entrapmentcom (Hilarious).?

I 116. On November 16, 2011, HYER and PADILLA received an email asking for

?urgent? assistance in eliminating the word ?teen? from the ads appearing on Backpage?s

website: ?Remove ads with teens or remove the text teen from . . . ads.? The following

day, PADILLA wrote back with an update that he had foimd ?76 pages of results? and that
he had simply ?edited? all of the ads posted within the last two months (116.. allowed those
ads to remain on the website after sanitizing them).

117. Between around January and March 2012, many of Backpage?s moderators
(who were supervised in part by PADILLA and VAUGHT) underwent performance
appraisals. These appraisals revealed that many of the moderators did ?not report-young
looking escorts.? Nevertheless, these moderators were allowed to keep their jobs, and
sometimes were given strong overall performance ratings. 

118. On February 23, 2012, CF. was forwarded a legal notice claiming that
several of Backpage?s ads copyrighted content from two competing websites
called RubMaps.com and EroticMP.com. C.F. also received copies of the underlying ads

from the competing websites, which clearly involved prostitution. In one of the ads, a.

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Case Document 230 Filed 07/25/18 Page 28 of 92

customer stated that, in return for $45 and a $5 tip, he had received a ?Blow Job . . . w/
condom? from a woman who ?had nice breasts.? In a different ad, a customer stated that,
in return for $60, he had oral and vaginal sex with a prostitute. And in a different ad, a
customer stated: ?Her bj was slow and erotic, and she was happy to go with whatever
position I wanted.? When CF. forwarded these materials to Backpage?s staff, he was asked
whether the corresponding ads appearing on Backpage?s website should be removed
immediately. C.F. replied that they should be allowed to remain on Backpage for another
few weeks withOut any modi?cation.

119. 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 merely ?strip out? the names of the competing
prostitution websites: ?Copyright infringement issue. We need to strip out every
appearance of rubmapscom and eroticmpcom.? When a staff member sought more
guidance, HYER interjected: ?We don?t need to delete ads or users.?

120. On April 7, 2012, PADILLA was informed that a woman had contacted I
Backpage to rep01t that one of the ?escorts? depicted on the site was only 17 years old.
The woman provided the juvenile?s full name and birth year and further stated that the
juvenile had been attempting to recruit the complaining party?s daughter (who was 15). In
response, PADILLA instructed his staff to refuse to remove the'ad because ?she?s isn?t
claiming her own daughter is in the ad.?

121. On April 8, 2012, LACEY sent an email emphasizing that ?jim 
and I believe in legalized prostitution? and stating that Backpage?s efforts to prevent the
prostitution of children on the site were ?not perfect, by any means.?

122. On April 25, 2012, a Backpage representative spoke at a meeting of the New
York City Council?s Women?s Issues Committee. During this meeting, the representative
stated it was better to have ads for sex work appear on Backpage than have them move to
other places on the internet. The representative further stated: don?t deny that Backpage

is part of the problem, but the problem is the internet.?

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Case Document 230 Filed 07/25/18 Page 29 of 92

123. On April 27, 2012, a woman wrote an email to Backpage?s support
department stating that her underage daughter had been kidnapped, drugged, and was being.
advertised as a prostitute against her will. The email identified the speci?c phone number
associated with the ads stated that the ads appeared on a website called
BackpagePics.corn, and asked that the ads be removed immediately: ?This is a drugged
and held against her will child who had photos taken under threat and duress . . . . Please
remove.? This email was forwarded to PADILLA by a subordinate, who asked ?should
we respond?? PADILLA replied by explaining that, because the website 
BackpagePics.com wasn?t owned by Backpage, there was no need to respond to the
mother.

4 124. On April 30, 2012 (three days later), the same woman wrote another email
to Backpage?s support department. In this email, the woman stated that have contacted
backpage on several occassions [sic] to remove these pictures which were posted against
her will and while she was drugged and held captive. I have yet to receive a reply.? This
time, the . woman provided a? link to her daughter?s ad on Backpage (not
BackpagePics.com), which included the same phone number that had been
included in the other ad. . I

125. On May 1, 2012 (the next day), the same woman wrote a third email to
Backpage?s support department. In this email, the woman included a link to another ad on
Backpage depicting her underage daughter and stated: also found 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-department stating: ?The post is con?rmed removed.?

126. Some of these emails were forwarded to LACEY and LARKIN. In response,
LARKIN applauded Backpage?s ?good solid response? to the woman and remarked: ?this
whole rigarnarole seems a little odd to me.?

127. On May 10, 2012, the television news station CNN ran an expose on
Backpage that emphasized ?how young some of these girls look? and deemed the website

?a hub for the sex trade.?

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Case Document 230 Filed 07/25/18 Page 30 of 92

128. On May 11, 2012, PADILLA sent an email to VAUGHT and other Backpage
employees entitled ?forbidden planet.? Enclosed with the email was an Excel spreadsheet
that identi?ed over 600 words and phrases that are indicative of prostitution. The
spreadsheet also specified, for each word and . phrase, whether an ad containing the
offending language should be banned or whether Backpage should simply ?strip term from
ad? and then publish it after the revision.

129. On July 12, 2012, PADILLA sent an email (which was also shared with
VAUGHT) to the head of Backpage?s Indian moderation team. In this email, 
criticized the moderators for deleting too many ads and provided the following instruction:
?1 agree that ?over cautiousness? is as big of a problem as moderators that miss a lot of
violations.?

130. Between June 2012 and August 2012, a Backpage representative, E.M.,

4 engaged in correspondence with a vendor about potentially acquiring software ?that could

help Backpage screen for minors.? In one email, sent on August 16, 2012, the vendor
stated that he understood, from his discussions with EHM, that ?Backpage has a problem
with pimps phoning in false accusations that another advertiser?s women are underage. Do
we know if there is any public DB [database] that they might affordably access to solve
this?? and further stated that the vendor could not assist with this ?problem.? In response,
E.M. thanked the vendor for the information, sought additional information about the cost
of the software, and forwarded the email chain to OF.

131. In or around November 2012, a researcher at Arizona State" University
published a study concluding that most of the ads on Backpage?s Phoenix page involved
prostitution and that many of the ads depicted juvenile trafficking victims. On December
19, 2012, LACEY was forwarded a copy?of the studyfs results. The researcher responsible
for the study also met with a Backpage representative to propose various mechanisms for
reducing or eliminating the prostitution of children on the website. Backpage declined to
adopt these proposals. I

132. Between around September 2010 and October 2012, OF. became aware that

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a particular Backpage customer, P.R., was posting prostitution ads. Rather than bar this
customer from posting future ads, OF. repeatedly restored her posting privileges and gave
her advice on how to conform to Backpage?s publication standards. The communications
involving this woman?s ads included the following: 7

- On September 26, 2010, OF. received an email from a woman who was
obviously posting prostitution ads on Backpage. The woman, whose email address
included the phrase ?provider4u,? wrote to complain that her escort ad (?50 Red Roses

special Dont Miss out Ell?) had been removed even though ?[o]ther women have more

explicit ads than me and they are up!? The woman continued: can not afford to have

this ad removed. This is the only way all the time I will not i
be able to pay my bills . . . . My fiance is in jail and he'is not able to help me at this
point.? In response, OF. arranged for the woman to be allowed to continue posting ads.

On October 6, 2010, OF. received another email from the same woman. In
this email, she complained that her most recent ad had been removed because it included
an explicit picture of her body. She provided a cepy of the picture to CF. and stated: ?If
the person [who removed the ad] is such a prude well maybe they should check out the
other women?s ads in that [escorts] section.? On November 15, 2010, OF. wrote back to
the woman to encourage her to edit the ad so it could be ire-posted: ?Oh, please try editing
the ad now.? After this exchange, the woman was permitted to resume posting ads on
Backpage.

- On June 6, 2011, OF received another email from the same woman. It
stated: would really appreciate it if you would please take the block off my ad for editing
. . . . I wont post any more objectionable pics, 0k?? In response, C.F. arranged for the

woman?s editing and posting privileged to be restored: ?You should be able to edit

now. Please let us know if you are still having any trouble.? After this exchange, the

woman resumed posting ads on Backpage.
- On July 14, 2012, OF. received another email from the same woman. It

stated: ?would you please take the edit block off my ad. I need to change some info on it

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Case Document 230 Filed 07/25/18 Page 32 of 92

and update it. . I promise i wont put no more nude pics in it, you have my word. . [M]y
ad says: 50. red roses special dont miss out.? After this exchange, the woman was allowed
to continue posting ads on Backpage.

On September 17, 2012, CF. received another email from the same
woman. This time, she complained that Backpage was editing her ads (whose title
continued to feature the obvious prostitution term ?50 Red roses special?) to remove the
most explicit pictures. She stated: would like to know why my ad in the escort section

of backpage keeps getting messed with. . . . [S]omeone keeps erasing the link to my pics

- on the ad. that is so wrong. I am being deprived of income that I sorely need . . . . There

are other woman posting pics on their ads that Show more nudity . . . After this exchange,
the woman was permitted to continue posting ads on Backpage.

On October 16, 2012, the woman wrote another email to Backpage. In this
email, she again complained about how Backpage was editing her ads to remove the most
explicit pictures. She stated: ?It is very hard for me to make any income from this ad as
they continually go into my ad and remove the link from the ad that goes to my
pictures. They wontallow me to post my pics on the ad yet other women with other ads
Show more nudity thanmy pictures ever did.? I

- This email was forwarded to VAUGHT and to PADILLA, who asked
another Backpage employee to ?dig into this one alittle.? On October 17, 2012, PADILLA
receiVed a follow-up email from his co?worker stating that the woman?s ad 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 (which had been stripped by Backpage) were
?topless shots.?

- Following these exchanges, between October 2012 and November 2015, the
same customer was allowed to post over a dozen new ads on Backpage, many of which
utilized the same identifying information, coded prostitution terms, and contact phone
number as before.

133. On January 7, 2013, VAUGHT was informed by a moderator that Backpage

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Case Document 230 Filed 07/25/18 Page 33' of 92

wasn?t diligently pursuing reports of child exploitation: ?We?ve supposedly been checking
them, but some seem to be ignored. They get ?marked as read?, but nothing gets done with
them. It?s aggravating and irresponsible.? 

134. On June 6, 2013, Backpage received a letter from NCMEC recommending

the adoption of several specific security measures to prevent the trafficking of children.

The recommended security measures included verifying the age and identity of users

who Submitted adult ads, verifying the age and identity of individuals depicted in
photographs within adult ads, (0) prohibiting the use of anonymous payment sources such
as prepaid credit cards, and requiring users to utilize veri?ed email addresses and
telephone numbers. Backpage declined to follow any of these recommendations.

135. On August 30, 2013, LARKIN, SPEAR, BRUNST, HYER, and CF.
received an email notifying them that ?Chase [Bank] was no longer accepting transactions
from Backpagecom, due to their involvement in human trafficking.? In response, OF.
informed the group that he intended to begin ?giv[ing] users free ads if they complain while
we wait on directly transactions to another processor.?

.136. On September 11, 2013, a Backpage representative made a presentation to
the Arizona Governor?s Task Force on Human Trafficking. Following this presentation
(which took place in Phoenix), the representative was asked whether there would be any
?cons? to requiring verifiable identification of all escorts being advertised on Backpage?s
website. In response, the representative did not identify any financial or logistical hurdles
to the adoption of such a requirement. Instead, the representative stated that such a
requirement would simply cause Backpage to lose business to other prostitution websites
like myRedBookcom or to overseas prostitution websites. During this meeting, members
of the task force also provided the representative with evidence showing that Backpage?s
moderation efforts were ineffective at preventing the publication of prostitution ads.

137. On April 3, 2014, PADILLA and VAUGHT were forwarded an email that
had been sent to Backpage by a credit card processing company in Canada. The email

stated that have multiple user accounts that are paying for your services for what I

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Case Document 230 Filed 07/25/18 Page 34'of 92

understand to be prostitution advertisements? and sought information about ?how you are
processing these transactions.? 

138. On April 14, 2014, LARKIN and BRUNST received an email from or.
discussing why Backpage had experienced ?past high growth? and identifying various
ideas for achieving ??iture growth.? This email stated that Backpage had been the
bene?ciary of ?[m]igration of content from other . . . marketplaces to the internet? and
identified one particular marketplace as a key source of Backpage?s customers: ?[N]et loss
for brick and mortar marketplaces: Strip clubs, hotels, and gathering spots displaced by the
internet.? In other words, the email acknowledged that the supposed ?escorts? advertising
on Backpage were actually prostitutes (lawful escorts did not congregate at strip clubs,
hotels, and other brick-and?mortar ?gathering spots? during the pre?internet age). This
email also attributed Backpage?s success in part to its adoption of policies that allowed
customers to post ads without leaving any meaningful identifying information?in a list of
Backpage?s advantageous policies, it identified ?Anonymous,? ?Prepaid card friendly,?
?User can post paid ads without a valid email address,? and ?bitcoin.?

139. On April 24, 2014, VAUGHT sent an email to Backpage?s moderators (while

'cc?ing PADILLA). In this email, 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 terms but ?don?t bother removing it from the current ad.?

140. On September 4, 2014, Backpage was served with a brief that had been filed
by NCMEC in a lawsuit in Washington state court. In this brief, NCMEC criticized the
sincerity of Backpage?s efforts to prevent child sex trafficking: ?Backpage has repeatedly
claimed in public statements and court filings that it is working to reduce child sex
trafficking on its website. The unpleasant reality is that Backpage publicizes carefully
selected operational processes as a subterfuge to avoid increased scrutiny, while providing
traf?ckers with easy access to an online venue to sell children for sex. In practice,
Backpage?s stated interest in doing something meaningful to stop child sex trafficking ads

on its site is apparently overridden by the enormous revenue it generates from its escort

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lCase Document 230 Filed 07/25/18 Page 35 of 92

ads, including ads selling children for sex.?

141. On March 17, 2015, a law enforcement of?cer with the California
Department of Justice spoke with a Backpage representative concerning the prevalence of
blatant prostitution ads on Backpage. In response, the representative did not dispute the
of?cer?s characterization and said the internet and prostitution were not going away.

142. On or about July 19, 2015, LACEY and LARKIN received a ?Thank You
Letter? from the Sex Worker?s Outreach Project This letter lauded Backpage?s
contributions to the prostitution industry (?Backpage has made quite a difference for many
of us . . . thanked Backpage for continuing to permit sex workers ?to advertise in the
?Adnlt? area,? expressed gratitude for Backpage?s willingneSs to accept alternative
payment methods ?as a way to pay for ads when MasterCard and Visa abruptly halted 
processing our credit card payments,? and stated that Backpage had. provided ?our
community an opportunity to learn how to use alternative payment methods, like Bitcoin.?

143. On July 30, 2015, a document entitled ?trainingJuly2015? was distributed to
Backpage? moderators. This training manual specifically told moderators that, if they saw
a photograph depicting ?a person [who] looks young/minor,? they shOuld ?approve dont
delete the ad unless it has a banned term.? The training manual also identified, under the
heading ARE ALL a long list of terms that are indicative of prostitution,
such as ?99% CUM BACK FOR ?car service,? and ?lollipop special.?

144. In or around August 2015, as part of a lawsuit in Illinois, Backpage was
served with an affidavit from a detective employed by the Seattle Police Department. In
this affidavit, the detective avowed that 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? and that ?every time the Seattle Police Department?s 

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.? During the same lawsuit in .

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Case Document 230 Filed 07/25/18 Page 36 of 92

Illinois, Backpage was served with a different affidavit from a detective employed by the
Boston Police Department. In this af?davit, the detective avowed that ?Backpagecom is
the number. one site in Boston for prostitution and sex trafficking,? that his unit had ?[s]ince
2010 . . . arrested oVer 100 buyers of sex of both adults and minors through Backpagecom
ads,? and that ?nearly all the cases we find associated with it [Backpage] involve pimp .
controlled prostitution.? . i

145. On October 7, 2015, PADILLA received an email from another Backpage
employee (which was later forwarded to VAUGHT) disclosing that there were ?massive
numbers of live ads with banned terms and pictures out on the site.? 

146. On December 9, 2015, Backpage received an email from a reporter stating
that the 359 sex traf?cking incidents Toronto Police have been involved in since

3

2013, every single girl that was rescued was advertised on Backpage.? The email also
asked: ?Why hasn?t Backpage closed down the adult escort ads portion of - its site like
Craigslist when it?s known that underage girls are being exploited via Backpage??

147. In or around January 2016, Company A was retained to serve as a payment
processor for some of Backpage?s websites. On April 29, 2016, Company A informed C.F.
that it had conducted ?a review of your website, and unfortunately we had to suspend your
account . . . [because] advertising of illegal activities is strictly forbidden.?

148. Beginning in or around January 2016, Backpage?s moderators were
instructed to stop removing ads that contained the phrase For example, on January
28, 2016, VAUGHT was sent an email from a Backpage moderator explaining that ?As far
as I am aware we are no longer removing ads for Similarly, on March 9, 2016, a
Backpage moderator sent an email to his coworkers explaining that ?Andrew 
and I talked about the GFE thing, going forward we will not be removing ads for 
and clarifying ?this includes even gfe with price.? And again, on March 25, 2016, an email
was Sent to Backpage?s moderation staff stating that ?We are no longer removing ads for
or 

149. In fact, the BACKPAGE DEFENDANTS repeatedly acknowledged that the



 

 






 

Case Document 230 Filed 07/25/18 Page 37 of 92

term (girlfriend experience) is a coded term for prostitution. For example:

On October 26, 2010, SPEAR, HYER, and received an email
from OR that explained: ?No coded sex act for money: GFE, PSE, DATY, etc.?

- On May 4, 2011, HYER sent an email to PADILLA and others identifying
GFE as a ?code word? that should be forbidden.

On August 31, 2011, PADILLA and CF. exchanged emails in which they
discussed a list of 100 ?solid sex for money terms.? The list included 2 girlfriend
experience.?

On November 2, 2011, PADILLA and VAUGHT received an email from a
co?worker identifying GFE in a list of ?sex phrases and coded terms? that are ?not
allowed.?

150. HYER, PADILLA, and other BACKPAGE DEFENDANTS periodically
received a ?Google alert? when articles discussing Backpage appeared in the news. Many
of the news articles identi?ed in these alerts discussed instances in which prostitutes who
had been advertised on Backpage were kidnapped, raped, or murdered.

151. In January 2017, after conducting a investigation, the Senate
Subcommittee on Permanent Investigations (?Subcommittee?) issued a 50?page report
entitled ?Backpage.com?s Knowing Facilitation of Online Sex Traf?cking.? This report
concluded, among other things, that virtually all of Backpage?s ?adult? ads were 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 traf?cking . . . . Those practices served 'to sanitize the
content of innumerable advertisements for illegal transactions?even as Backpage
represented to the public and the courts that it merely hosted content others had created.?

152. In response to the Subcommittee?s report, Backpage purported to shut down
the ?adult? section of its website. However, the prostitution ads simply migrated to other
sections of the website, where they remained until the website was shut down by federal

law enforcement authorities in April 2018.

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Case Document 230 Filed 07/25/18 Page 38 of 92

D. International Operations

153. In addition to facilitating prostitution through its US. website, Backpage also
facilitated prostitution through its websites in foreign countries. In this context, Backpage
(as it did through its domestic ?aggregation? efforts and the Dallas Plan) often af?rmatively
created the content of the prostitution ads being published.

154. Around 2013 or 2014, Backpage hired a Philippines-based company
(Company B) in an attempt to increase the profitability of Backpage?s international
operations. Company B?s employees were instructed to (1) visit rival prostitution websites
in other countries, (2) obtain the email addresses of prostitutes who were posting ads on
those websites (often by falsely posing as prospective customers), (3) use the information
from the other website to create a competing prostitution ad on Backpage (a process

referred to internally as ?preboarding?), and then (4) transmit the new ad to the prostitute,

- often using the previously-harvested email account information, in an attempt to persuade

the prostitute to become a Backpage customer. Company B?s employees were paid
bonuses based on the amount of ad revenue they generated for Backpage using these
techniques.

155. Backpage?s executives were fully aware of the plan to use Company to
create prostitution ads outside the United States. For example, on or around November 6,
2013, CF. made a presentation to LARKIN, SPEAR, and BRUNST. Amongother things,
this presentation Summarized Backpage?s plans for ?International Planning and
Expansion.? One of the plans was to use the Philippines as a ?test? market and hire Filipino
contractors to ?contact by email leads, secure email address, add ad and email address in
[computer system] and assign to American staff. American staff makes contact.?

156. On August 7, 2014, HYER sent an email stating that Company was ?an
ef?cient and cost effective way for us to bring new users to backpage.? This email also
contained the following summary of how Company would operate: ?Process after hiring
company offering BPO services: 1. Backpage provides BPO with sites, categories 

countries to target. Backpage also provides sample ?scripts? and examples of phone

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Case Document 230 Filed 07/25/18 Page 39 of 92

calls. 2. BPO contacts users via phone from sites backpage provided, obtains user email
address permission to preboard ad. 3. BPO preboards ad as public user. 4. After ad is
preboarded,? users receive verification link to verify the ad.? This email also stated that
Backpage would offer a ?bonus per veri?ed authenticated ad.? 

157. On April 10, 2015, a ?five-year business plan? was emailed to LARKIN,

SPEAR, and CF. One of the goals for 2015 was ?Off shore marketing staff in

the Philippines to grow to 166 and main task is international market content acquisition.?
This email also included a separate attachment stating that HYER should be considered for
promotion because ?his are strong marketing and revenue growth skills? and he
had been ?heavily involved in the user experience development? and that VAUGHT should
be considered for a promotion because ?[h]er include six years of experience
managing moderators.? I

158. On May 15, 2015, a Company employee posing as a Backpage employee
sent an email to an apparent prostitute. The subject line was ?Offering Free Advertisement
from Backpagecom? and the text of the email sought to persuade the prostitute to ?upgrade
your ad with sponsor placement or automatic repost.? In response, the prostitute wrote
back that she had ?managed to activate my ad and could buy credits as well. thanks for
your help. I?m traveling today to [London] how can I change my location.? This email
exchange was later forwarded by HYER to OE With a cover note stating: ?[I]deal scenario
for [Company agent user activates ad, user purchases credit.?

159. On December 14, 2015, OF. was part of an email exchange concerning an
ad that had an IP address assOciated with Company B. This email contained the following
description of Company B?s process for creating and selling prostitution ads on Backpage:
(1) ?Staff found lead in assigned area.? (2) ?Staff entered all relevant into [database]
(3) ?Staff called lead to discuss creation of free ad? (4) ?Staff created
free ad for lead (verification email sent)? (5) ?Staff followed under with an email

reminding lead of phone conversation and detailing verification of ad.?

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Case Document 230 Filed 07/25/18 Page 40 of 92

E. Select Victim Summaries

160. Between in or around 2009 and 2013, Victim was sold for sex, through the
use of Backpage ads, in 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

1?s trafficker took all of the money that was earned through her acts of prostitution.

161. Between in or around 2009 and 2011, Victim 2 was sold for sex, through the
use of Backpage ads, in Arizona, Georgia, North Carolina, Texas, New York, New Jersey,
and Louisiana. Victim 2?s trafficker drafted her Backpage ads and Victim 2 initially did
not know she was being offered on Backpage. The ads contained wordsand phrases to
make customers believe Victim 2 was ?barely legal? and also contained words and phrases
indicative of prostitution, such as ?roses? (money).

162. Between in or around 2009 and 2012, Victim 3 was. sold for sex, through the
use of Backpage ads, in Colorado and North Dakota. Victim 3?s pimp instructed her to
review existing prostitution ads on Backpage to learn how to draft her own ads. During a
p01tion of this period, Victim 3 was required by her pimp to make week-long trips to North
Dakota to work as a prostitute. During these trips, which would generate as much as $2,000
in prostitution-derived revenue each day, Victim 3 was forced to leave her children at home


163. In or around 2010, Victim 4 was sold for sex, through the use of Backpage
ads, in Washington. During this period, Victim 4 was a juvenile (15 years old). Victim
4?s pimp drafted the ads that were placed on Backpage. The wording of these ads was
edited by Backpage before publication. The ads contained words and phrases such as
and WONT TAKE LONG AT 
and included pictures of Victim 4 in provocative positions showing her breasts and

buttocks.

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Case Document 230 Filed 07/25/18 Page 41 of 92

164. Between in or around 2011 and 2016, Victim 5 was sold for sex, through the
use of Backpage ads, in Massachusetts and Rhode Island. During much of this period,
Victim 5 was a juvenile (14?19 years old). Victim 5?s female pimp instructed Victim 5
that Backpage was the safest place to advertise because it did not require age veri?cation. -
On one occasion, Backpage declined to accept a proposed ad that indicated Victim5 was
only 17 years old. In response, the ad ?was simply resubmitted with a new (false) age of
19. On other occasions, Backpage removed provocative pictures of Victim 5 from ads and
then allowed edited versions of the ads to be published. Victim 5?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 Victim 5 ?s Backpage ads forced

Victim 5 to perform sexual acts at gun point, choked her to the point of having seizures,

and gang-raped her.

165. In. or around June 2012,7Victim 6 was sold for sex, through the use of
Backpage ads, in Arizona. Her traf?ckers utilized Backpage ads that did not offer a
specific person but instead generally offered a woman with a particular type of hair color
and build. On June 22, 2012, Victim 6 was dispatched to a customer who had respOnded
to a Backpage ad featuring ?Nadia,? who was described as a slender brunette woman.
Upon her arrival at the location, Victim 6 was stabbed to death.

. 166. Between in or around 2012 and 2015, Victim 7 was sold for sex, through the
use of Backpage ads, in Washington and Oregon. Victim 7?s pimp drafted the ads that
were placed on Backpage. The wording of these ads was edited by Backpage before
publication. The ads contained provocative nude pictures of Victim 7.

167. Between in or around 2013 and 2014, Victim 8 was sold for sex, through the
use of Backpage ads, in Maine, Connecticut, and Massachusetts. During this period,
Victim 8 was a juvenile (15 years old). Victim 8?s uncle, as well as his friends, placed the
ads on Backpage, which included words and phrases that were indicative of prostitution,
such as ?roses? (money), ?fetish friendly,? and 150 for 1/2 hour, 200 for full hour.

Through these ads, Victim 8 was forced to do ?in?calls?- (where she was raped in hotels) as

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Case Document 230 Filed 07/25/18 Page 42 of 92

well as ?out?calls? (where she was raped at other locations chosen by the men paying for
her).

168. In or around 2013, Victim 9 was sold for sex, through the use of Backpage
ads, in Florida. Victim 9?s pimp taught her how to use code words in her Backpage ads to
indicate how much she was charging for certain sex acts. Victim 9 was brutally attacked
by her trafficker, causing bruises and a fractured cheek bone.

169. Between in or around 2014 and 2015, Victim 10 was sold for sex, through

the use of Backpage ads, in California and Arizona: During some of this period, Victim

10 was a juvenile (17 years old). An associate of Victim 10?s pimp took pictures of her

and drafted the ads that were placed on Backpage. The Backpage ads contained words and
phrases such as IN ?sexy sweet,? and ?sweet like honey but super hot like
fire? and included pictures of Victim 10 in provocative positions showing her legs,
stomach, shoulder,- and buttocks.

170. Between in or around 2014 and 2015, Victim 11 was sold for sex, through
the use of Backpage ads, in Arizona, Colorado, Minnesota, Oregon, California, Montana,
Nevada, New Mexico, and Utah. The Backpage ads contained words and phrases
indicative of prostitution and included pictures of Victim 11 in provocative positions. On
some occasions, Backpage wouldremove certain explicit photos from the ads but publish
the remaining text and other photos. Victim 11?s trafficker gave her drugs, took her
identi?cation documents, sexually assaulted her with a ?rearm, and forced her to work full-
time as a prostitute.

171. In or around 2015, Victim 12 was sold for sex, through the use of Backpage
ads, in California and Arizona. Victim 12 was first advertised on Backpage in San
Bernardino, California, but moved to the Phoenix metro area because the Super Bowl was
being held there. Victim 12?s advertisements on Backpage contained 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 legs, stomach, shoulders and buttocks.

172. In or around 2015, Victirn 13 was sold for sex, through the use of Backpage



 

 






 

Case Document 230 Filed 07/25/18 Page 43 of 92

ads, in California. During this period, Victim? 13 was a juvenile (15 years old). Victim 13
and her traf?cker both posted the Backpage ads, which falsely represented that Victim 13
was 19 years old and showed pictures of her face and body. On at least one occasion, a
Backpage representative contacted Victim 13 with instructions could be published. 

173. In or around June 2015, Victim 14 was sold for sex, through the use of a
Backpage ad, in Texas. This ad contained words and phrases such as ?fun, young, exotic,?
?Ready to be your fantasy girl,? CALLS and BLACK and
included pictures of Victim 14?s stomach, breasts, shoulders, and buttocks. On or around
June 20, 2015, Victim 14 was murdered by a customer. AfterWard, the customer attempted
to destroy Victim 14?s corpse by lighting it on fire. Victim 14?s father later contacted
Backpage to request that the ads showing his deceased daughter be removed. Backpage
did not immediately comply with this request. 

174. In or around June 2015, Victim 15 was 'sold for sex, through the use of
Backpage ads, in Texas and Louisiana. These ads contained words and phrases such as
?Thick Glass of Chocolate Milk Looking for a GoodTiine! and ?sexy certified freak?
and contained pictures showing Victim 15?s legs, shoulders and buttocks. On June 10,
2015, Victim 15 was forced into a vehicle with her trafficker, who was attempting to take
her to Texas against her will. In an attempt to escape, Victim 15 jumped out of the vehicle
onto Interstate 10 and Was killed after being hit by several vehicles at high speeds.

175. In or around July and August 2015, Victim 16 was sold for sex, through the
use of Baekpage ads, in Michigan. These ads contained words and phrases such as
?Juicy Caramel Lady On Duty,? ?Sexy, Erotic Caramel Dream,?
and ?No Thugs, Pimps Or Weirdos? and contained pictures showing Victim 16?s breasts,
legs, lips, buttocks, and face. On August 15, 2015, Victim 16 was murdered by a customer.
Afterward, the customer dumped her corpse in a park.

176. Between in or around 2015 and 2016, Victim 17 was sold for sex, through

the use of Backpage ads, in Arizona and California. Victim 17 averaged ten customers a

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\om?qu?I-mehCase Document 230 Filed 07/25/18 Page 44 of 92

day during this time and turned over all of her prostitution earnings (approximately 1 ,5 00
per day) to her pimp. An associate of Victim 17?s pimp took pictures of her and drafted
the ads that were placed on Backpage. The Backpage ads contained words and phrases
such as ?I?m here to make your wildest fantasies come true!? and
?Sorry, but NO BLACK and included pictures of Victim 17?s buttocks and face.
F. Money Laundering Activities

177. Backpage?s customers overwhelmingly used the proceeds of criminal
activity money earned from! pimping and prostitution) when purchasing ads on
Backpage. In addition, because Backpage?s publication of such ads was an independent
crime violation of 18 U.S.C. 1952), the fees it collected from customers posting
prostitution ads?estimated at more than $500 million?constituted the proceeds of
unlawful activity.

178. For these and other reasons, banks and financial institutions repeatedly
refused to do business with Backpage. In response, the BACKPAGE DEFENDANTS
pursued a variety of money laundering strategies. For example, on August 27, 2013, CF.
was forwarded an array of emails from Backpage customers who were complaining that
their credit card companies had refused to process Backpage?related transactions. One
customer wrote: ?Have you resolved the issue of Chase Bank not honoring payment for
you for ethical reasons?? C.F. forwarded these complaint emails to LARKIN, SPEAR, and
BRUNST and proposed, as a ?solution? to the problem, that Backpage reconfigure its
website to fool credit card companies into believing the charges were being incurred on a
different website.

179. During a November 2013 presentation by GP. to LARKIN, SPEAR, and
BRUNST, CF. again discussed strategies for fooling credit card companies into believing
that Backpage?associated charges were being incurred on different websites, including a
proposal to set up shell companies without any apparent connection to Backpage (?create
new companies with new principals?) and use their bank accounts to accept payment.

Another ?solution? was to ?allow users to fund an account thru several other sites? that

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Case Document 230 Filed 07/25/18 Page 45 of 92

?have no adult or images.?
180. On NOVember 6, 2013, LARKIN, SPEAR, and BRUNST received an email

entitled ?Options for the future of Backpage.? This email discussed various strategies for

creating new entities to process Backpage-related payments ?without ever disclosing ties

to Backpage.? 

181. On April 1, 2015, BRUNST and CF. were informed that Mastercard was
?snooping around? Backpage and might stop processing payments for Backpage. In
response, OF. offered several suggestions for setting up new payment channels that would
conceal Backpage?s involvement. One such proposal was to begin routing Backpage?
related 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 content??

182.. Notwithstanding these strategies, the three major credit card companies
stopped doing business with Backpage. On or about April 30, 2015, Backpage learned that
American Express would no longer allow its cards to be used for any purchases in
Backpage?s adult section. In or around July 2015, Backpage learned that Mastercard would

no longer allow its cards to be used for Backpage-related transactions. When discussing

this decision, MasterCard stated that it ?has rules that prohibit our cards from being used

. for illegal activities.? Around the same time, Backpage learned that Visa would no longer

allow its cards to be used for Backpage-related transactions. When discussing this
decision, Visa stated that its ?rules prohibit our network from being used for illegal
activity.?

183. . Similarly, some banks closed accounts that were held by Backpage (or
Backpage-related entities) out of concern the accounts were being used for illegal purposes.
For example, on April 2, 2014, BRUNST received a letter from US. Bank that was
addressed to ?Backpagecom.? The letter explained: ?Dear Jed . . . please be advised that
we have elected to close your Account with us.?

184. Backpage responded to these developments in several ways. One was to

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Case Document 230 Filed 07/25/18 Page 46 of 92

encourage customers to send checks and money orders to a Post Of?ce box held in the
name of a seemingly?unrelated entity called Posting Solutions LLC (?Posting Solutions?)
and give such customers a corresponding credit on Backpage. For example, on July 31,
2015, CF. exchanged email correspondence with a representative from a payment
processing company. In this email, CF. identi?ed himself as the CEO of Posting
Solutions, described Backpage as a ?brand? operated by Posting Solutions, and explained
he was seeking to ?find a way to position payments under another company.?

185. The following episode provides an example of how the Posting Solutions
payment process worked. On October 16, 2015, Backpage received an email from a
customer complaining about her inability to pay for ads using a credit card. In response, a
Backpage representative explained?in an email exchange later forwarded to 
that you would like to pay for upgrades or buy credits, we suggest posting with

alternative payment methods such as Bitcoin. If you are in the United States, you can also

pay by check or money order. Please make payable to ?Posting Solutions.? WE CAN I

ONLY ACCEPT CHECKS OR MONEY ORDERS MADE OUT TO 
Posting Solutions. Attn: Accounts. PO. Box 192307. Dallas, TX 75219.
Please send through the United States Postal Service. FedEx, UPS, or other mail delivery
alternatives cannot deliver to a PO. Box. When sending your payment please be sure to
include your email address. Please do not make your payments out to backpagecom as We
will no longer be able to accept them.?

186. Between around September 2015 and June 2016, over $7.1 million of checks
and money orders sent by Backpage customers were deposited in bank accounts held by
Posting Solutions.

187. Backpage also utilized a different entity, called Website Technologies, LLC
(?Website Technologies?), to process Backpage-related funds and took steps to make it
appear that Backpage and Website Technologies were independent entities. For example,
on March 10, 2014, BRUNST, SPEAR, and others participated in an email exchange with

the subject line ?Website Technologies vs Backpage (Vendors, audits, risk assessments,

_46_

 

 

\0'Case Document 230 Filed 07/25/18 Page 47 of 92

email)? During this exchange, one person stated and I were just discussing
company names and the possibility of updating our email addresses to
websitetechnologiescom.? In response, BRUNST cautioned: ?We need to think this thru
or all the work to separate it from BP will be lost.? Similarly, on April 3, 2014, BRUNST
sent an email to SPEAR and others explaining that Mayll we will have to be out of
US Bank. We will move all banking under Website Technologies at [a different bank,
BMO Harris].? 

188. In many instances, Backpage?related money that was initially deposited into
accounts held by Posting Solutions was later transmitted to accounts held by Website
Technologies. For example:

- On October 27, 2015, OF. received an email entitled ?Two packages coming
your way! (Money Orders)? The email stated that two UPS packages filled with money
orders were being sent?one containing $47,647.25 of money orders made out to Backpage
and the other containing $52,251.48 of money orders made out to Posting Solutions.

Similarly, on November 16, 2015, CF. received an email entitled ?Three
packages sent today $441,408.69.? The email stated that three packages filled with money
orders were being sent?one containing $129,193.61 of money orders made out to
Backpage, another containing $244,353 .63 of money orders made out to Posting Solutions,
and the last containing an additional $67,861.75 of money orders made out to Posting
Solutions.

- And again, on January 29, 2016, a Posting Solutions account wired $2.4
million to a Website Technologies account. PADILLA and CF. were both authorized
signers on the recipient account. I

189?. In addition to receiving millions of dollars from Posting Solutions, the 9
Website Technologies accounts also served as the repository for millions of dollars of wires
from international bank accounts controlled by Backpage-associated entities. For example,
between January 2015 and December 2016, Website Technologies accounts received over

$45.4 million in wire transfers from Backpage-associated-bank accounts in Liechtenstein,

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Case Document 230 Filed 07/25/18 Page 48 of 92

over $30.1 million in wire transfers from Backpage?associated bankaccounts in Iceland,
and. over $3.9 million in wire transfers from Backpage-associated bank accounts in the
Netherlands.

190. In many instances, the next stage of the money?laundering process was for
money to be wired from Website Technologies accounts to bank accounts held by a
different entity called Cereus Properties LLC (?Cereus Properties?). The authorized
signers on the Cereus Properties accounts included SPEAR and BRUNST. Between
around December 2015 and October 2016, Website Technologies accounts sent wire
transfers totaling over $47 million to accounts held by Cereus Properties.

191. Accounts held by Cereus Properties also received money directly from
internatiOnal bank accounts controlled by Backpage-associated entities. For example, 
between around August 2016 and November 2016, Cereus Properties accounts received
over $11.3 million in deposits and wire transfers from Backpage-associated accounts in the
Netherlands.

192. After money reached Cereus Properties, large portions of?it were funneled
back to Backpage or to certain BACKPAGE DEFENDANTS. For example, between
January 2016 and January 2017, LACEY (and family members) received
distributions totaling over $30.3 million and LARKIN separately received distributions
totaling. over $21 million.

193. Backpage also furthered its money laundering efforts through the use of

bitcoin processing companies. Over time, Backpage utilized companies such as CoinBase,

GoCoin, PaXful, Kraken, and Capital to receive payments from customers and/or
route money through the accounts of related companies.
194. Backpage also furthered its money laundering efforts by developing ways for

customers to purchase ads using gift cards issued by third-party vendors. This process was

described in a July 23, 2015, email exchange between various Backpage employees on

which HYER and others were copied. This exchange included the following: ?[W]hat if

we used a customers [sic] payment method, say visa prepaid card, to buy [bitcoin] from

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Case Document 230 Filed 07/25/18 Page 49 of 92

our seller account . . . giving said bitcoin to our catch-all wallet elsewhere (instead of to
user), simultaneously adding credits/purchasing paid ad. or upsells? From the user?s
perspective they just input their prepaid card and get their credits or purchase.?
Mm 
(Conspiracy)

195. The factual allegations in Paragraphs 1-194 are incorporated by reference
and reualleged as though fully set forth herein.

196. Beginning in or around 2004, and continuing through April 2018, in the
District of Arizona and elsewhere, defendants LACEY, LARKIN, SPEAR, BRUNST,
HYER, PADILLA, and VAUGHT, and others known and unknown to the grand jury,
knowingly and intentionally agreed, confederated, and conspired with each other, and with
others known and unknown to the grand jury, to commit the following offenses against the
United States:

a. 18 U.S.C. l952(a)(3)(A) (Travel Act?Facilitate Prostitution).
OBJECT OF THE CONSPIRACY
197. The object of the conspiracy was to obtain money.
MANNER AND MEANS OF THE CONSPIRACY

198. The manner and means of the conspiracy are described in paragraphs 1-194

above, incorporated by reference and re-alleged as though fully set forth herein.
OVERT ACTS

199. Overt acts were committed in furtherance of the conspiracy, including but
not limited to those described in paragraphs 1-194 above, incorporated by reference and
re?alleged as though fully set forth herein.

In violation of 18 U.S.C. 371.

COUNTS 2?51
(Travel Act?Facilitate Prostitution)
200. The factual allegations in Paragraphs 1?199 are incorporated by reference

and re-alleged as though fully set forth herein.

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Case Document 230 Filed 07/25/18 Page 50 of 92

201. On or about the dates set forth below, each instance constituting a separate
count of this Superseding Indictment, in the District of Arizona and elsewhere, defendants
LACEY, LARKIN, SPEAR, BRUNST, HYER, PADILLA, and VAUGHT, and others
known and unknown to the grand jury,,used the mail and any facility in interstate and
foreign commerce with intent to otherwise promote, manage, establish, carry on, and
facilitate the promotion, management, establishment, and carrying on of an unlawful
activity, to wit: prostitution offenses in violation of the laws of the State in which they are
committed and of the United States, including but not limited to Title 13, Arizona Revised
Statutes, Section 13-3214, and thereafter performed and attempted to perform an act that

did promote, manage, establish, carry on, and facilitate the promotion, management,

 

establishment, and carrying on of the unlawful activity, as follows:

 

Count Date Description
2. Sept, 10, 2013 Publish ad depicting Victim 5 entitled ?Get freaky Tuesday .

. Come spend ur day With us 19,? with accompanying text

?Doin inoalls and outcalls?

 

 

3. Jan. 27, 2014 Publish ad involving entitled ?50 Red 
DONT MISS 
4. Jan. 29, 2014 Publish ad depicting Victim 8 entitled ?Puerto Rican mami in

walpole area ?19? after deleting one picture from
the originally?submitted ad

 

5. Jan. 31, 2014 Publish ad depicting Victim 8 entitled ?Exotic latina, south
p01tland area, ready to play, INCALLS, 30 min 

19? after deleting one picture from originally-submitted ad

 

 

6. Feb. 6, 2014 Publish ad involving P.R. entitled ?75 Red 
DONT MISS 
7. Apr. 20,2014 Publish ad involving PR. entitled ?50 Red 

 

 

 

 

 

- DONT MISS 

 



 

 




Case Document 230 Filed 07/25/18 Page 51 of 92

 

May 7, 2014

Publish ad involving entitled ?50 Red 
DONT MISS 

 

Dday31,2014

Publish ad involving P.R. entitled ?50 Red 
- DONT MISS 

 

10.?

h?y1,2014

Publish adinvolving P.R. entitled ?50 Red 
DONT MISS 

 

11.

Aug. 19, 2014

Publish ad involving P.R. entitled ?50 Red 
- DONT MISS 

 

?12.

Nov. 23, 2014

Publish ad depicting Victim 10 entitled ?New in Town Super
Hot Skinny Mixed Cuban Girl With Long Black Hair l8?

afterdeleting picture from originallyusubmitted ad

 

13.

Jan.29,2015

Publish ad depicting Victim 12 entitled. ?New in Town Sexy
Dark Asain Bombshell with a Nice Tight {Booty} 23?

after deleting one picture from the originally?submitted ad

 

14.

Jan. 31, 2015

Publish ad depicting Victim 10 entitled IN TOWN

sexy sweet European mixed Cuban California girl 21?

 

15.

Jan. 31, 2015

Publish ad depicting Victim 12 entitled ?New in Town Sexy
Dark Asian mixed Bombshell 23? after deleting one picture

from the originally-submitted ad

 

16.

Feb. 4, 2015

Publish ad depicting Victim 1 1 entitled ?Upscale Independent
BRUNETTE BOMBSHELL 5?Star Fantasy 26,? after

deleting pictures from originally?submitted ad

 

17.

Feb. 18, 2015

Publish ad depicting Victim 11 entitled ?Alexis Foxx the
HOTTEST in 26,? after deleting six, pictures from

the originally?submitted ad

 

 

18.

 

Feb. 26, 2015

 

Publish ad involving P.R. entitled ?50 Red 
DONT MISS 

 

 

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Case Document 230 Filed 07/25/18 Page 52 of 92

 

19.

May 18, 2015

Publish ad depicting Victim 15 entitled ebony
PLAYMATE Perfect Curves. . .Skills to make ur TOES
CURL 19,? after removing one picture of originally-
submitted ad, with accompanying text ?you agree . . . you are
not af?liated with any law enforcement agency? and ?Incalls

Outcall! 

 

20.

May 19, 2015

Publish ad depicting Victim 15 entitled ?Hot Driping
Submissive Ebony Playmates 20,? after removing one
picture of originally-submitted ad, with accompanying text
?you agree . . . you are not af?liated with any law enfOrcement
agency? and ?We?re ready to please and accommodate all of
your needs and wants!! With a mouth that?ll ROCK your 

and a [picture of cat] that?ll leave you purring for more?

 

21.

July 1,2015

Publish ad depicting Victim 17 entitled ?AbSoLuTeLy
AmAziNg CoMe WiTh Me #1 MOST WaNtEd 
PlAymate 20,? with accompanying text ?By
contacting me you agree that you are not af?liated with any
form of law enforcement,? PERFECT Will satisfy your
every need,? and 

 

22.

July 2, 2015

Publish ad depicting Victim 17 entitled ?SeXyll Exotic
playmate Call me! the girl you NEED to See! 20,? with

accompanying text DO NOT OFFER 40$, 50$, 60$

and CALLS 

 

 

23.

 

Aug. 13, 2015

 

Publish ad depicting Victim 13 entitled ?Young SEXY
PUERTO RICAN 19,? which accompanying text do half

hour sessions that vary in donation prices, 80 for head, 120

i for hooking up without head and 150 for hooking up with

head?

 

 

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Case Document 230 Filed 07/25/18 Page 53 of 92

 

24.

Aug. 15, 2015

Publish ad depicting Victim 16 entitled ?Outcalls Now
Freaky Curvy Caramel Lady OUTCALLS NOW 23?

 

25.

Sept. 13, 2015

Publish ad involving P.R. entitled ?50 Red 
DONT MISS ournm? 

 

26.

Nov. 28, 2015

Publish ad involving P.R. entitled ?50 Red 
DONT MISS -

 

27.

Apr. 21, 2016

Publish ad entitled ?Finally! PSE GFE Kimber Rae and
MIA Marie Together BOOK 

 

28.

NOV. 3, 2016

Publish ad entitled New l8?

 

29.

Nov.11, 2016

Publish ad entitled ?Mind blowing Tiffany. lncall in Taunton -
37,? with accompanying text ?Soft GFE . . . lm real and

reviewed?

 

30.

Nov. 14, 2016

Publish ad entitled ?Top Model 2016 Special 5Best Looking
Young Asian? . . . 22,? with accompanying text ?Sexy Asian

Girl Incall Service? and-?GFE? 

 

31.

Nov. 14, 2016

Publish ad entitled ?Sometimes It?s All About. The Journey,
And The Destination. . .;.Erectile Dysfunctional 
Provider 44,? with accompanying test ?You can find a few
current reviews at T3R and have been EROS

authenticated?

 

 

32.

 

Nov. 19, 2016

 

Publish ad entitled ?The True (G)irl (F)riend (Experience. ..
Visiting November 27th? Sunday PRE-BOOKING
SPECIAL 100,? with accompanying text ?Let?s blur
restrictions between ?nancial transaction Romantic

Connection?

 

 

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Case Document 230 Filed 07/25/18 Page 54 of 92

 

33.

Nov. 24, 2016

Publish ad entitled ?Top Asian Grand Opening 100% Young
100% Sexy . . . 23,? with accompanying text 
INCALL IN and 

 

34.]

Nov. 26, 2016

Publish ad entitled LOVE I?m a GFE. OutCall and

Incall with exceptiOn on the 42?

 

35.

Dec. 20, 2016

Publish ad entitled Sexy Sensual 36DD-24-36
Stacked College Coed With The Best Mouth Ever! BOOK
with accompanying text do ALL the things
YOU Wish Your Wife Did! and 30 min/$180?

 

36.-

Jan. 15,2017

Publish ad entitled ?Real Reviewed Girlfriend
Theonesweetweeblycom 30,? with accompanying text

?250 

 

37.

Apr. 4, 2017

Publish ad entitled GFE KOREAN GIRLS 
20?

 

38.

Apr. 11, 2017

Publish ad entitled ?Pettit Sexy #Corey# 4407239339 39,?

with accompanying text ?complete GFE experience?

 

39.

July 3, 2017

Publish ad entitled HANG OUT NOW UpScale
New In Town! Call ME now for an unforgettable Visit 20,?

with accompanying text ?100% GFE with 100% no Pimps?

 

40.

July 15,2017

Publish ad entitled ?Ready for some fun daddy? This is your
chance too have a amazing time - 21,? with accompanying

text ?Slim body, nice tits, freaky, 

 



July 15, 2017

Publish ad entitled ?New in town BiGBubble Booty
HOT BODY 24,? with in

accompanying text

 

 

42.

 

July 21, 2017

 

Publish ad entitled ?Pettit Sexy #Corey# 4407239339 30,?

with accompanying text ?complete GFE experience?

 

 

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Case Document 230 Filed 07/25/18 Page 55 of 92

 

 

 

 

 

 

 

 

 

 

 

 

43. July 23, 2017 Publish ad entitled GODDESS young 20,? with
accompanying text?100% Discreet seivice? and 

44. Jan. 26, 2018 Publish ad entitled Service Available! Private

Encounters w/ Pampering Beauty?
45. Jan. 30, 2018 Publish ad entitled ?241 white plans area Carfun Perfect
1 Treat Available No Rush,? with ?Sweet Sexy in
accompanying text

46. Jan. 30, 2018 Publish ad entitled REAL HOT Sweet DREAM
AMAZING BEST 

47. Jan. 30, 2018 Publish ad entitled ?Tall, Slim Sexy Luxe Goddess 
NARCISA Sensual Body Rub Fetish Sessions,? with
accompanying text ?gfe Hh: $160 H: $220?

48. Jan. 31, 2018 Publish ad entitled ?Exotic Asian Beauty,? with
accompanying text am an independent GFE with excellent
massage skills? A 7

49. Feb. 1, 2018 Publish ad entitled ?Nuiu (Best GFE ever) incall only?

50. Feb. 6, 2018 Publish ad entitled ?Tuesday with Ashleigh. Available now,?
with in accompanying text

51. Feb. 6, 2018 . Publish ad entitled Kisskisspop 100% Real Photo
Choice 9Asian girl Nurunude?

 

 

In violation of 18 U.S.C. 1952(a)(3)(A).

2%

(Conspiracy To Commit Money Laundering)

202. The factual allegations in Paragraphs 1?201 are incorporated by reference

and re?alleged as though fully set forth herein.

203. Beginning in or around 2004, and continuing through April 2018, in the
District of Arizona and elsewhere, defendants LACEY, LARKIN, SPEAR, BRUNST, and

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Case Document 230 Filed 07/25/18 Page 56 of 92

HYER, and others known and unknown to the grand jury, knowingly and intentionally
agreed, confederated, and conspired with each other, and with others known and unknown
to the grand jury, to commit the following offenses against the United States:
I a. 18 U.S.C. 1956(a)(1)(A)(i) (Promotional Money Laundering)
b. 18 U.S.C. 1956(a)(1)(B)(i) (Concealment Money Laundering)
18 U.S.C. 1956(a)(2)(A) (Int?l Promotional Money Laundering)
d. 18 U.S.C. 1956(a)(2)(B)(i) (Int?l Concealment Money Laundering)
e. 18 U.S.C. 1957(a) (Transactional Money Laundering)
In violation of?18 U.S.C. 1956(h).
I 
(Concealment Money Laundering)

204. The factual allegations in Paragraphs 1~203 are incorporated by reference
and re-alleged as though fully set forth herein.

205. On or about the dates set forth below, each instance constituting a separate
count of this Superseding Indictment, in the District of Arizona and elsewhere, defendants
LACEY, LARKIN, SPEAR, BRUNST, and Others known and unknown to the
grand jury, knowing that the property involved in a financial transaction represented the
proceeds of some form?of unlawful activity, conducted and attempted to conduct such a
?nancial transaction whichin fact involved the proceeds of specified unlawful activity
knowing that the transaction was designed in whole and in part to conceal and disguise the
nature, the location, the source, the ownership, and the control of the proceeds of the

specified unlawful activity, as follows:

 

Count Date Amount Description

 

53. May18, 2016 $1,476,505.00 Website Technologies (X2008) to Cereus
Properties (X621 1)

 

54. May 18, 2016 $264,438.00 Website Technologies (X2008) to Cereus
Properties (X6211)

 

 

 

 

 

 

,56_

 

 






Case Document 230 Filed 07/25/18 Page 57 of 92

 

 

 

 

 

 

 

 

 

 

 

 

Properties (X621 1)

55. May 31, 2016 $3,171,675.80 Website Technologies (X2008) to Cereus
Properties (X6211)
56. May 31, 2016 $432,961.87 Website Technologies (X2008) to Cereus
Properties (X6211)
57. . June 20, 2016 $842,878.00 Website Technologies (X2008) to Cereus
Properties (X6211) I
58. June 30, 2016 $3,076,147.75 Website Technologies (X2008) to Cereus
Properties (X6211)
59. July 27, 2016 $3,252,681.62 Website Technologies (X2008) to 'Cereus
I Properties (X6211)
60. July 27,2016 843 8,818.86 Website Technologies (x2008) to Cereus
Properties (X6211)
61. Aug. 16, 2016 $804,250.00 Website Technologies (X2008) to Cereus
Properties (X6211)
62. Aug. 31, 2016 $3,171,264.42 Website Technologies (X2008) to Cereus

 

 

In Violation of 18 U.S.C. 


(International Promotional Money Laundering)

and re?alleged as though fully set forth herein.

206. The factual allegations in Paragraphs l-205 are incorporated by reference

207. On or about the dates set forth below, each instance constituting a separate

count of this Superseding Indictment, in the District of Arizona and elsewhere, defendants

LACEY, LARKIN, SPEAR, BRUNST, and HYER, and others known and unknown to the

grand jury, transported, transmitted, and transferred, and attempted to transport, transmit,

and transfer, a monetary instrument and funds from a place in the United States to and

through a place outside the United States, and to a place in the United States from and

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Case Document 230 Filed 07/25/18 Page 58 of 92 -

through a place outside the United States, with the intent to promote the carrying on of

specified unlawful activity, as follows:

 

 

 

 

 

 

 

Amount Description
63. Mar. 4, 2014 $6,450.00 US Bank (X1165) to SB. (web developer
in India)
1 64. Aug. 5, 2016 $5,005,732.86 Ad Tech B.V. (Netherlands) to Cereus
. Properties (X6211)
65. Sept, 22, 2016 $2,916,955.00 Ad Tech B.V. (Netherlands) to Cereus
Properties (X6211)
66. Oct. 3, 2016 $354,050.84 Ad Tech B.V. (Netherlands) to Cereus
Properties (X6211)
67. Nov. 2,2016 $2,726,170.00 Ad Tech B.V. (Netherlands) to Cereus
Properties (X6211)
68. Nov. 15, 2016 $351,403.54 Ad Tech B.V. (Netherlands) to Cereus I

 

 

 

 

 

Properties (X621 1)

 

 

1n violation of 18 U.S.C. 1956(a)(2)(A).
COUNTS 69?99
(Transactional Money Laundering)

208. The factual allegations in Paragraphs 1-207 are incorporated by reference

and re?alleged as though fully set forth herein.

209. On or about the dates set forth below, each instance constituting a separate

count of this Superseding Indictment, in the United States and in the District of Arizona

and elsewhere, the specified defendant, and others known and unknown to the grand jury,

knowingly engaged and attempted to engage in a monetary transaction in criminally

derived property of a value greater than $10,000 and is derived from specified unlawful

activity, as follows:

_58_

 

 






Case Document 230 Filed 07/25/18 Page 59 of 92

 

 

 

 

 

 

 

 

 

 

 

 

 

Count Defendant Date Amount Description
69. LACEY, Aug. 21, $30,000.00 Bank of America (X1793) to
BRUNST 2013 Stewart Title (partial payment
for Sedona property)
70. LACEY, Sept. 13, $62,491.47 BMO Harris to Stewart Title
BRUNST 2013 (partial payment for Sedona
preperty)
71. SPEUXR. June11,2014 iNa?onal IBank of Amazona
(X0178) to Spear'Family Trust
72. SPEAQK June20,2014- l?a?onal iBank of Eudzona
(X0178) to TD Ameritrade
73. SPEAR Nov. 4, 2014 $1,000,000.00 National Bank of Arizona 
(X0178) to UBS Financial
74. SPEAR May 14, 2015 $250,000.00 National Bank of Arizona
(X0178) to Linooh1 lJa?onal
L?e
75. SPEAR May 26, 2015 $50,000.00 National Bank of Arizona
Indu?r?? Iaopeny

76. SPEAR Nov. 3, 2015 $300,000.00 National Bank of Arizona
(X0178) to Ally Bank
77. SPEAR Dec. 1, 2015 $200,000.00 National Bank of Arizona
(X0178)toVVeHsI%Igo
78. SPEAR, Jan. 11, 2016 $133,045.00 Cereus Propeities (X6211) to
BRUNST National Bank of Arizona
(X0178)

 

 

 

 

 

 

-59_

 

 

 



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ooquA-hwwr?aomooqmm-hmmr?so

Case Document 230 Filed 07/25/18 Page 60 of 92

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

79. BRUNST Jan. 26, 2016 $101,974.00 Cereus Properties (X6211) to
Wells Fargo (X4891)
80. LARKTN, Feb. 3, 2016 $1,507.944.00 Cereus Properties (X6211) to
BRUNST Charles Schwab
81. LACEY, Mar. 1, 2016 $1,692,020.00 Cereus Properties (X6211) to
BRUNST Bank of America (X5554)
82. BRUNST Apr. 1, 2016 $220,944.00 Cereus Properties (X6211) to
Wells Fargo (X4891)
83. LACEY, June 27,2016 $397,9500.00 Arizona Bank Trust (X1793)
I BRUNST to Fidelity Title (partial payment
for San Francisco property)
84. LACEY, July 20, 2016 $12,859,152.57 Arizona Bank Trust (X1793)
BRUNST to Fidelity Title (partial payment
for San Francisco property)
85. SPEAR July 22, 2016 $50,000.00 National Bank of Arizona
I (X0178) to Strategic Storage
Trust '11
8'6. LACEY, Aug. 2, 2016 $16,243.00 Cereus Properties (X6211) to
BRUNST Wells Fargo (X0495)
87. LARKIN, Oct. 6, 2016 $1,206,356.00 Cereus Properties (X6211) to
BRUNST - Charles Schwab (X4693)
88. LACEY, Oct. 6, 2016 $268,016.00 Cereus Properties (X6211) to
BRUNST Arizona Bank Trust (X1967)
89. LACEY, Oct. 6, 2016 $268,016.00 Cereus Properties (X6211) to
BRUNST Arizona Bank Trust (X1972)
90. LACEY, Oct. 6, 2016 $268,016.00 Cereus Properties (X6211) to
BRUNST Arizona Bank Trust (X1986)

 

 

-60_

 

 

 



RIM 1?11.43 r?A (3

Case Document 230 Filed 07/25/18 Page 61 of 92

 

 

 

 



 

 

 

 

 

 

91. LACEY, Oct. 6, 2016 $268,016.00 Cereus Properties (X6211) to
BRUNST Arizona Bank Trust (X1991)
92. LACEY, Oct. 6, 2016 $268,016.00 Cereus Properties (X6211) to
BRUNST Arizona Bank Trust (X2014)
93. SPEAR, Oct. 6, 2016 $141,444.00 Cereus Properties (X6211) to
BRUNST National Bank of Arizona
(X0178)
94. LACEY Dec. 29, 2016 $3,300,000.00 Arizona Bank Trust/Dubuque
Bank Trust to Johnson Bank
(x9992) 
95. LACEY Dec. 29, 2016 $3,300,000.00 Arizona Bank Trust/Dubuque
Bank Trust to Johnson Bank
(X9992)
96. LACEY Dec. 29,2016 $3,300,000.00 Arizona Bank Trust/Dubuque -
Bank Trust to Johnson Bank
(X9992)
97. LACEY Dec. 29, 2016 $3,300,000.00 Arizona Bank Trust/Dubuque
Bank Trust to Johnson Bank
(X9992)
98. LACEY Dec. 29, 2016 $3,300,000.00 Arizona Bank Trust/Duhuque
Bank Trust to Johnson Bank
(X9992)
99. LACEY Jan. 3, 2017 $16,500,000.00 Johnson Bank (X9992) to
. Primus Tiust Bank
(Hungary)

 

 

 

 

 

 

In Violation of 18 U.S.C. 1957(3).

-61_

 

 

 



txCase Document 230 Filed 07/25/18 Page 62 of 92

COUNT 100
(International Concealment Money Laundering)

210. The factual allegations in Paragraphs 1-209 are incorporated by reference
and ire-alleged as though fully set forth herein.

211. On or about the date set forth below, in the United States and in the District
of Arizona and elsewhere, the speci?ed defendant, and others known and unknown to the
grand jury, transported, transmitted, and transferred, and attempted to transport, transmit,
and transfer, a monetary instrument and funds from a place in the United States to and
through a' place outside the United States, and to a place in the United States from and
through a place outside the United States, knowing that the monetary instrument and funds
involved in the transportation, transmission, and transfer represented the proceeds 'of some
form of unlawful activity and knowing that such transportation, transmission, and transfer
was designed in whole and in part to conceal and disguise the nature, the location, the
source, the ownership, and the control of the proceeds of specified unlawful activity, as

follows:

 

Count Defendant Date Amount Description

 

 

100. LACEY Jan. 3, 2017 $16,500,000.00 Johnson Bank (X9992) to 
Primus Trust Bank

 

 

 

 

 

 

(Hungary)

 

In violation of 18 U.SV.C. 



 

 




l-d



 

Case Document 230 Filed 07/25/18 Page 63 of 92

FORFEITURE ALLEGATION ONE
{18 U.S.C. 981(a)(1)(C) and 28 U.S.C. 2461(c)]

1. The factual allegations in Paragraphs 1-211 are incorporated by reference
and re-alleged as though fully set forth herein. I

2. Pursuant to Rule 32.2 of the Federal Rules of Criminal Procedure, notice is
hereby given that the United States will seek forfeiture as part of any sentence, pursuant to
Title 18, United States Code, Section 981(a)(l)(C) and Title 28, United States Code,
Section 2461(0), in the event of any defendant?s conviction under Counts 1 through 51 of
this Superseding Indictment. Each defendant so convicted shall forfeit to the United States
the following:

a. All right, title, and interest in any and all property, real or personal,
constituting, or derived from, any proceeds obtained, directly or indirectly, as a result of
the offense. Such property includes, but is not limited to,ithe real property located at the
following addresses:

1. 10647 N. State Route 89A, Sedona, AZ 86336

2. - 1100 Union St. #700, San Francisco, CA 94109
3. 1308 E. 56th Street, 2, Chicago,-IL 60637

4. 14, rue Saint Guillaume, Paris, France 75007

5. 2043 Pleasant Hill Rd, Sebastopol, 
6. 2416 N. Foote Dr., Phoenix, AZ 85008

7. 2531 Tumbleweed Way, Frisco, TX 75034

8. 2755 Fillmore St, San Francisco, CA 94123

9. 3300 E. Stella Lane, Paradise Valley, AZ 85253
10. 3304 E. Stella Lane, Paradise Valley, AZ 85253
11. 3308 E. Stella Lane, Paradise Valley, AZ 85253
12. 3311 E. Stella Lane, Paradise Valley, AZ 85253
13. 3353 Red Robin Road, Pinetop, AZ 85935

14.

343 Presidio Ave, San Francisco, CA 94115

-63_

 

 



Document 230 Filed 07/25/18 Page 64 of 92

15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.

3516 Estacado Lane, Plano, TX 75025-4432 (Rental)
493 Zinfandel Lane, Saint Helena, CA 94574

4931 E. White Gates Drive, Phoenix, AZ 85018

5245 Evening Sun Dr, Frisco, TX 75034

5555 North Casa Blanca Drive, Paradise Valley, AZ 85253
5751 N. 77th Place, Scottsdale, AZ 85250

5830 E. Calle Del Media (Medic), Phoenix, AZ 85018
6300 N. 33rd Street, Paradise Valley, AZ 85253

6314 N. 33rd Street, Paradise Valley, AZ 85253

7409 Kingsbarns, The Colony, TX 75056

8604 E. San Ardo Dr., Scottsdale, AZ 85258

948 Carlsbad Dr., Plano, TX 75023

Such property also includes, but is not limited to, all funds, securities, and/or other assets

held in the following bank accounts:

1.

59.009.050.439!?

1?l1?a1?k1?Ar?t


Prosperity Bank account number 
Compass Bank Account number 
Compass Bank Account number 825 
National Bank of Arizona Account number 
National Bank of Arizona Account number 151

- National Bank of Arizona Account number 645

Live Oak Bank Account Number x6910

Ascensus Broker Dealer Services Account Number 
Ascensus Broker Dealer Services account Number 
First Federal Savings Loan of San Rafael account number 620
Republic Bank of Arizona account number 

Republic Bank of Arizona account number 

Republic Bank of Arizona account number 00

Republic Bank of Arizona account number 

-64?

 

 

\OOqum-bUJNhCase Document 230 Filed 07/25/18 Page 65 of 92

15. Bank of America Account number 

16. Bank of America Account number 

17. Bank of America Account number 42

18. Bank of America Account number 

19. San Francisco Fire Credit Union Account Number 
20. Ally Bank Account Number 92

21. Branch Banking and Trust Bank account number 
22. Green Bank Account number 

23. Green Bank Account number 

24. Perkins Coie Brokerage Account number 

25. Perkins Coie Liquid Assets 

26. Alliance Bernstein Brokerage Account number 

27. Alliance Bernstein Brokerage Account number 

28. Alliance Bernstein Brokerage Account number 

29. Alliance Bernstein Brokerage Account number 

30. Alliance Bernstein Brokerage Account number 

31. Republic Bank of Arizona Brokerage Account number 

32. Republic Bank of Arizona Brokerage Account number 

33. Republic Bank of Arizona Brokerage Account number 

34. Republic Bank of Arizona Certificate of Deposit 

35. Republic Bank of Arizona Certi?cate of Deposit 
36. Republic Bank of Arizona Certificate of Deposit 
37. Republic Bank of Arizona Certi?cate of Deposit 
38. Republic Bank of Arizona Certificate of Deposit 
39. Republic Bank of AriZona Certi?cate of Deposit 
40. Paul Hastings LLP Account number 

41. Global Trading Solutions 

42. Bank Account number 

-65_

 

 



Nib.) l?A 1?4 r?m 1?4


 

Case Document 230 Filed 07/25/18 Page 66 of 92

43.
44.
45.
46.
47.
?48.
49.
50.
51.
52.
53.
54.
55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
65.
66;
67.
68.
69.
70.

Pic Bank Account number 803

Fio Bank Account number 801

Fio Bank Account number 

Fio Bank Account number 

Fio Bank Account number 

Fio Bank Account number 

Fio Bank Account number 

Fio Bank Account number 

to Bank Account number 

io Bank Account number 

Fio Bank Account number 

Fio Bank Account number 
Bank Prick Account numb er L109 OX
Bank Prick Account number L13 00X
Bank Prick Account number LI740X
Bank Prick Account number L1900X
Knab Bank Account number 

Rabo Bank Account number 

Rabo Bank Account number 

Acacia Conservation Fund Brokerage Account number X2020
Saxo Payments Account number X1262

AS LHV Pank Account number 
Bitcoin Wallet in the amount of 6 BTC

Bitcoin Wallet ~6Lix5 in the amount of 199.99995716 BTC
Bitcoin Wallet ~6Lix5 in the amount of 404.99 84122 BTC

JP Morgan Chase Bank account number 5 in the amount of $699,940
JP Morgan Chase Bank account number in the amount of $106,988.41

JP Morgan Chase Bank account number in the amount of $499,910

-66_

 

 






 

Case Document 230 Filed 07/25/18 Page Morgan Chase Bank account number in the amount of $50,000
Bitcoin Cash Wallet ?t8V7e in the amount of 3,673.593 06905 BCH

Litecoin Wallet ?goaeV in the amount of 16,310.79413202 LTC

Bitcoin Wallet in the amount of 173.97319 BTC

Bitcoin Cash Wallet ~t8v7e in the amount of 55.5 BCH

Bitcoin Wallet in the amount of411.00019 BTC

Bitcoin Wallet in the amount of 2.00069333 BTC

Bitcoin Wallet in the amount of 136.6544695 BTC

'Bitcoin Cash Wallet ?t8V7e in the amount of 73.62522241 BCH

Litecoin Wallet ?goaeV in the amount of 783 .97351 16 LTC

Bitcoin Gold Wallet in the amount of 50981904619 BTG

Capital account number X1124

Capital account number X1933

Any and all bank funds, securities, or other assets on deposit or
seized from an account held at Kraken in the name of Ad Tech BV.

JP Morgan Chase Bank account number 5 in the amount of $42,500
Alliance Bernstein Brokerage account X7889

Alliance Bernstein Brokerage account X0582

Mid?rst Bank account X4139

Capital account number X6886

Such property further includes, but is not limited to, the following domain namesadmoderation.com (Versio)

admoderatorscom (Versio)

*adnetws (NetNames)

adplace24.com (Versio)
adplaces24.com (Versio)
adpost24.com (Versio)
adpost24.cz (GoDaddy)

-67m

 

 

MD 00 Ch 4). DJ 1?




 

Case Document 230 Filed 07/25/18 Page 29.

30.

31.

32.

33.

34.

35.

adquick365 .oom (Versio)
adreputationoom (NetNames)
(Versio)
adsplaer4.com (Versio)
adspot24.oom (Versio)
adspot524.com (Vorsio)
adsspot24.com (Vorsio)
adteohbv.oo.n1 (N etNames)
adtechbv.com (N etNaInes)
(N etNames)
advert?epoom (Versio)
adverts-mpoom (Versio) 7
axme.oom (GoDaddy)
backOage.oom (NetN?ames)
backpage (NetNames)
backpaee.com (N etNames)
backpage-insider.oom (NetNames)
backpage.adult (N etNames)
backpageae (NetNames)
backpageat (NetNamos)
backpageax (N etNames)
backpagebe (NetNames)

. backpagebg (European domains)

backpagebg (N etNames)
baokpage.ca- (NetNamos)
backpage.ol (N etNames)
backpage.on (European domains)

backpage.cn (N etNarnes)



 

 



F4 run-I runU.) 

 

Case Document 230 Filed 07/25/18 Page 69 of 92 

36.
37.
38.
39.
40.
41.
42.
43.
44.
45.
46.
4754.
55.
56.
57.
58.
59.
60.
61.
62.
63.

backpage.co.id (NetNames)
baokpage.co.n1 (European domains)
backpage.co.n1 (NetNames)
backpage.co.nz (NetNames)
backpage.eo.uk (N etNameS)
backpage.oo.ve (NetNames)
backpage.eo.za (N etNames)
backpag'eeom (N etNames)
backpage.oom.ar (NetNames)
backpage.oom.au (N etNames)
backpageeomph(NetNames) 
backpage.oz (NetNames)
backpagedk (NetNames)
backpageeo (NetNames)
(European domains)
(N etNames)
backpagees (N etNames)

backpage? (N etNames)
backpageir(Eur0pean6knnanm)
backpageiE(IJe?NaInes)
backpagegr (European domains)
backpagegr (NetNames)

backpagehk (N etNames)
backpagehu (European domains)
backpagelnl??e??anmm)
backpageie (NetNames)

?69?

 

 






 

Case Document 230 Filed 07/25/18 Page 70 of 92

64.
65.
66.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
81.
82.
83.
84.
85.
86.
87.
88.
89.
90.
91.

backpagein (NetNames)
backpageit (NetNames)
backpagejp (NetNames)
backpagekr (NetNames)
backpagelt (N etNames)
backpagelv (European domains)
backpage.1v (NetNames)
backpageme (N etNames)
backpagemx (NetNaInes)
backpagemy (NetNames)
backpagenet (N etNames)
backpagenl (NetNames) i
backpageno (European domainS)
backpageno (N etNames)
backpagenz (NetNames)
backpagepe (NetNames)
backpageph (N etNames)

backpagepk (NetNames)

backpagepl (N etNames)
backpageporn (NetNames)
backpagept (N etNames)

'baokpagexo (European domains)

backpagexo (N etNames)
backpagese (NetNames)
backpagesex (NetNames)

. backpagesg (NetNames)

backpagesi (European domains)

backp agesi (N etNames)

-70?

 

 






 

Case Document 230 Filed 07/25/18 Page 71 of 92

92.
93.

94. 

95.
96.
97.
98.
99.

100.
I 101.
102.
103.
104.
105.
106.
107.
108.
109.
110.
111.
112.
113.
114.
115.
116.
117.
118.
119.

backpage.sk (European domains)
backpage.sk (N etNames)
backpage.sucks (N etNames)
backpage.tw (NetNames)
backpage.uk (NetNames)
backpage.uk.com (NetNames)
backpage.us (NetNames)
backpage.vn (NetNames)
(NetNames)
backpafgexyz (NetNames)
backpagecompimp.com (N etNames)
backpagecompimps.com (NetNames)
backpagepimp.com (NetNames)
backpagepimps.com (NetNames)
backpagg.com (NetNames)
backpagm.com (NetNames)
backpagu.com (NetNames)
backpaoe.com (NetNames)
backpaWe.com (NetNames)
backqage.com (NetNames)
backrage.com (N etNames)
backxage.com (N etNames)
bakkpage.com (NetNames)
bcklistings.com (NetNames)
(NetNames)
bestofbigcity.com (NetNames)
bickpagacom (NetNames) 
bigcity.com (NetNames)

-71m

 

 



Case Document 230 Filed 07/25/18 Page 72 of 92

120.
121.
122.
123.
124.
125.
126.
127.
128.
129.
.130.
131.
132.
133.
134.
135.
136.
137.
138.
139.
140.
141.
142.
143.
144.
145.
146.
147.

bpclassi?ed.com (NetNames)
bpclassi?eds.com (NetNames)
carlferrer.com (N etNames)
clasificadosymas.com (NetNames)
clasificadosymasnet (NetNames)
clasificadosymasnrg (NetNames)
classi?edsolutions.co.u1< (N etNames)
classi?edsolutions .net (NetNames)
classyadultads.com (Versio)
columbusbackpage.com (NetNames)
connecticutbackpage.com (NetNames)
cracker.co.1d (NetNames)
cracker.com (NetNames)
cracker.com.au (NetNames)
cracker.id (N etNames)
crackernetau (N etNames)
crackers.com.au (NetNames)
crackersnetau (NetNames)
ctbackpage.com (NetNames)

dallasb ackpage.com (NetNames)
denverbackpage.com (NetNames)
easypost123 .com (Versio)
easypostsl23 .com (Versio)
emais.com.pt (NetNames)
evilempire.com (NetNames)
ezpost123 .com (Versio)
fackpage.com (N etNames)

fastadboard.com (Versio)



 

 



Case Document 230 Filed 07/25/18 Page 73 of 92

148.
149.
150.
151.
152.
153.
154.
155.
156.
157.
158.
159.
160.
161..
162.
163.
164.
165.
166.
167.
168.
169.
170.
171.
172.
173.
174.
175.

guliettagroupnl (Versio)

htpp.01?g (NetNames)

ichold.com (NetNames)
internetspeechfoundation.com (nameisp)
intemetspeechfoundation.org (nameisp)
10ads2drive.com (N etNames)
10adstodrive.com (NetNames)
loadtodrivecom (NetNames)
losangelesbackpage.com (NetNames)
media?lecloud.com (N etNameS)
miamibaC1<page.com (NetNames)
minneapolisbackpage.com (NetNames)
mobileposting.com (Versio)
mobilepostings.com (Versio)
mobilepostlist.com (Versio)
mobilposting.com (Versio)

nakedcity (NetNames)

nakedcity.com (NetNames)
newyorkbackpage.cbm (NetNames)
paidbyhour.com (NetNames)
petseeklzcom (N etNames)
petsfindr.com (NetNames)
phoenixbackpage.com (NetNames)
posteasy123 .com (Versio)
postfaster.com (NetNames)
postfastly.com (N etNames)
postfastr.com (N etNames)

postonlinewith.com (Versio)

-732

 

 






 

Case Document 230 Filed 07/25/18 Page 74 of 92

176.
. 177.
178.
179.
180.
181.
182.
183..
184.
185.
186.
1 187.
188.
189.
190.
191.
192.
193.
194.
195.
196.
197.
198.
199.
200.
201.
202.
203.

postonlinewithme (VerSio)
postseasy123 .Com (Versio)
postsol.com (GoDaddy)
(Versi'o)
postzon624.com (Versio)
post20116824.com (Versio)
rentseekr.com (N etNames)

results91 1.00m (N etNames)
sandiegobackpage.com (NetNames)
sanfranciscobackpage.com (NetNames)
seattlebackpage.com (NetNames)
sellyostuffonline.00m (Versio)

ackpage.com (N etNames)
simplepost24.00m (Versio)
simplepostsZ4.com (Versio)

SVC.WS (NetNames)

truckrj 0bs.com (N etNames)
ugctechgroup.com (NetNames)
universadsnl (Versio)
Villagevoicepimps.com (GoDaddy)
websitefechnologies.co.uk CN?tNames)
websitetechnologies.com (NetNames)
websitetechnologiesnet (NetNames)
websitetechnologiesnl (NetNames)
Websitetechnologiesorg (NetNames)
weprocessmoney.c0m (GoDaddy)
wst.ws (NetNames)

xn??yms??a.com (NetNames)

-742

 

 






 

Case Document 230 Filed 07/25/18 Page 75 of 92

204.
205.
206.
207.
208.
209.
210.
211.
212.
213.
214.
215.
216.
217.
218.
219.
220.
221.
222.
223.
224.
225.
226.
227.
228.
229.
230.
231.

ymas.ar.oom (European domains)

ymas.br.com (European domains)

. ymas.br.com (N etNames)

ymasbz (European domains)
ymasbz (NetNames)

ymas.o1 (European domains)
ymas.ol (NetNames)

ymas.co.bz (European domains)
ymas.co.bz (NetNames)
ymas.co.or (European domains)
ymas.co.cr (NetNames)
ymas.oo.ni (European domains)
ymas.co.ni (NetNames)
ymas.oo.ve (European domains)
ymas.co.ve (NetNames)
ymas.oom (NetNames)
ymas.oom.br (European domains)
ymas.com.br (N etNames)
ymas.com.bz (European domainS)
ymas.oom.bz (NetNames)
ymas.oom.oo (European domains)
ymas.oom.co (NetNames)
ymas.oom.do (European domains)
ymas.com.do (NetNames)
ymas.com.ec (European domains)
ymas.oom.ec (NetNames)
ymas.com.es (European domains)

ymas.com.es (NetNames)

-75m

 

 



r3?4 

 

Case Document 230 Filed 07/25/18 Page 76 of 92

232.
233.
234.
235.
236.
237.
238.
239.
- 240.
241.
242.
243.
244.
245.
246.
247.
248.
249.
250.
251.
4252.
253.
254.
255.
256.
257.
258.
259.

ymas.oom.gt (European domains)
ymas.com.gt (N etNames)
ymas.com.hn (European domains)
ymas.oom.hn (N etNames)
ymas.com.mx (N etNarnes)
ymas.com.ni (European domains)
ymas.oom.ni (N etNames) 
ymas.com.pe (European domains)
ymas.oom.pe (NetNames)
ymas.oom.pr (European domains)
ymas.com.pr (NetNames)
ymas.com.pt (NetNames)
ymas.com.uy (European domains)
ymas.com.uy (N etNames)
ymas.com.ve (European domains)

ymas.com.ve (N etNames)

ymas.cr (European domains)

ymas.or (NetNames)

ymasdo (European domains)

lymasdo (NetNames)

ymaseo (European domains)
ymasec (NetNames)
ymases (European domains)
ymases (NetNames)
ymas.org (NetNames)
ymaspe (European domains)
ymaspe (NetNames)
ymaspt (NetNames)

-76?

 

 



Case Document 230 Filed 07/25/18 Page 77 of 92

260. ymas.us (European domains)
261. ymas.us (NetNames)
262. ymas.uy (European domains)
263. ymasuy (NetNames)
264. ymas.uy.corn (European domains)
265. atlantabackpagecom (NetNames)
266. backpagecombr (NetNames)
267. chicagobackpagecom (NetNames)
268. tampabackpagecom (NetNames)

b. To the extent such property is not available for forfeiture, a sum of money
equal to the total value of the property described in subparagraph 

3. Pursuant to Title 21, United States Code, Section 853(p), as incorporated by
Title 28, United States Code, Section 2461(0), the defendant shall forfeit substitute
property, up to the total value of the property described in the preceding paragraph if, as
the result of any act or omission of the defendant, the property described in the preceding
paragraph, or any portion thereof: cannot be located upon the exercise of due diligence;
has been transferred, sold to or deposited with a third party; (0) has been placed beyond
the jurisdiction of the court; has been sub stantially, diminished in value; or has been
commingled with other property that cannot be divided without dif?culty. 

FORFEITURE ALLEGATION TWO
[18 U.S.C. 982(a)(1)]

l. The factual allegations in Paragraphs 1?211 are incorporated by reference
and re-alleged as though fully set forth herein. 

2. Pursuant to Rule 32.2 of the Federal Rules of Criminal Procedure, notice is
hereby given that thelUnited States will seek forfeiture as part of any sentence, pursuant
Title 18, United States Code, Section 982(a)(1), in the event of any defendant?s conviction
under Counts 52 through 100 of this Superseding Indictment. Each defendant so convicted
shall forfeit to the United States the following: i

_77_

 

 






 

Case Document 230 Filed 07/25/18 Page 78 of 92

a. All right, title, and interest in any and all property, real or personal, involved
in or traceable to any transaction set forth in Counts 52 through 100 of this Superseding
Indictment. Such property includes, but is not limited to, the real property located at the

following addresses:

1. 10647 N. State Route 89A, Sedona, AZ 86336

2. 1100 Union St. #700, San Francisco, CA 94109

1308 E. 56th Street, 2, Chicago, IL 60637

4. 14, rue Saint Guillaume, Paris, France 75007

5. 2043 Pleasant Hill Rd, Sebastopol, CA 95472

6. 2416 N. Foote Dr., Phoenix, AZ 85008

7. 2531 Tumbleweed Way, Frisco, TX 75034

8. 2755 Fillmore St, San Francisco, CA 94123 

9. 3300 E. Stella Lane, Paradise Valley, AZ 85253

10. 3304 E. Stella Lane, Paradise Valley, AZ 85253

11. 3308 E. Stella Lane, Paradise Valley, AZ 85253

12. 3311 E. Stella Lane, Paradise Valley, AZ 85253

13. 3353 Red Robin Road, Pinetop, AZ 85935

14. 343 Presidio Ave, San Francisco, 15

15. 3516 Estacado Lane, Plano, TX 75 025?4432 (Rental)
16. 493 Zinfandel Lane, Saint Helena, CA 94574 A

17. 4931 E. White Gates Drive, Phoenix, 

18. 5245 Evening Sun Dr., Frisco, TX 75034

19. 5555 North Casa Blanca'Drive, Paradise Valley, AZ 85253
.20. 5751 N. 77th Place, Scottsdale, AZ 85250

21. 5830 E. Calle Del Media (Medio), Phoenix, AZ 85018
22. 6300 N. 33rd Street, Paradise Valley, AZ 85253

23. 6314 N.'33rd Street, Paradise Valley, AZ 85253

24. 7409 Kingsbarns, The Colony, TX 75056

-78_

 

 



Case Document 230 Filed 07/25/18 Page 79 of 92

25.
26.

8604 E. San Ardo D11, Scottsdale, AZ 85258
948 Carlsbad Dr., Plano, TX 75023

Such property also includes, but is not limited to, all funds, securities, and/or other assets

held in the following bank accounts:

1.

wwagwaww




Prosperity Bank account number 
Compass Bank Account number 873
Compass Bank Account number 825

National Bank of Arizona Account number 

National Bank of Arizona Account number 1 51

National Bank of Arizona Account number 645

Live Oak Bank Account Number X6910

Ascensus Broker Dealer Services Account Number 
Ascensus Broker Dealer Services account Number 
First Federal Savings Loan of San Rafael account number 620
Republic Bank of Arizona account number 

Republic Bank of Arizona account number 

Republic Bank of Arizona account number 

Republic Bank of Arizona account number 

Bank of America Account number 

Bank of America Account number 

Bank of America Account number 

Bank of America Account number 

San Francisco Fire Credit Union Account Number 
Ally Bank Account Number 

Branch Banking and Trust Bank account number 
Green Bank Account number 

Green Bank Account number 

Perkins Coie Brokerage Account number 

-79_

 

 



i?A r?a a?t 


 

Case Document 230 Filed 07/25/18 Page 34.
35.
36.
37.
38.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
50. 
51.
52.

Perkins Coie Liquid Assets 

Alliance Bernstein Brokerage Account number 
Alliance Bernstein Brokerage Account number 
Alliance Bernstein Brokerage Account number 892
Alliance Bernstein Brokerage Account number 
Alliance Bernstein Brokerage Account number 
Republic Bank of Arizona Brokerage Account number 
Republic Bank of Arizona Brokerage Account number 897

Republic Bank of Arizona Brokerage Account number 

I Republic Bank of Arizona Certi?cate of Deposit 

Republic Bank of Arizona Certificate of Deposit 
Republic Bank of Arizona Certi?cate of Deposit 
Republic Bank of Arizona Certificate ?of Deposit 
Republic Bank of Arizona Certi?cate of Deposit 
Republic Bank of Arizona Certi?cate of Deposit 
Paul Hastings LLP Account number 

Global Trading Solutions 

Bank Account number 

Fio Bank Account number 803

Fio Bank Account number 801
Fio Bank Account number 
Fio Bank Account number 
Fio Bank Account number 
Fio Bank Account number 
Fio Bank Account number 
Fio Bank Account number 
Fio Bank Account number 

Fio Bank Account number 

-80~

 

 

om?mm-b-UJNl?d




 

Case Document 230 Filed 07/25/18 Page 81 of 92

53.
54.
55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
.65.
66.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.

Fio Bank Account number 

io Bank Account number 

Bank rick Account number L1090X

Bank Frick Account number L13 00X

Bank Frick Account number Ll740x

Bank Prick Account number LI900X

Knab Bank Account number 

Rabo Bank Account number 

Rabo Bank Account number 21

Acacia Conservation Fund Brokerage Account number x2020

Saxo Payments Account number X1262

AS LHV Pank Account number 

Bitcoin Wallet -6Lix5 in the amount of 6 BTC

Bitcoin Wallet in the amount of 19999995716 BTC

Bitcoin Wallet ?6Lix5 in the amount of 404.9984122 BTC

JP Morgan Chase Bank account number in the amount of $699,940
JP Morgan Chase Bank account number 5 in the amount of $106,988.41
JP Morgan Chase Bank account number in the amount of $499,910

Morgan Chase Bank account number in the amount of $50,000

Bitcoin Cash Wallet ?t8V7e in the amount of 3,673.59306905 BCH
Litecoin Wallet -goaeV in the amount of 16,310.79413202 LTC
Bitcoin Wallet -6Lix5 in the amount of 173.97319 BTC

Bitcoin Cash Wallet ?t8V7e in the amount of 55.5 BCH

Bitcoin Wallet ?6Lix5 in the amount 01?41 1.00019 BTC

Bitcoin Wallet ?6Lix5 in the amount of 2.00069333 BTC

Bitcoin Wallet -6Lix5 in the amount of 136.6544695 BTC

Bitcoin Cash Wallet ?t8V7e in the amount of 73.62522241 BCH
Litecoin Wallet wgoaeV in the amount of 783 .97351 16 LTC

-81_

 

 



r?t r?t r?a rm i?A 




 

Case Document 230 Filed 07/25/18 Page 82 of 92

. 81. Bitcoin Gold Wallet in the amount of 50981904619 BTG

82. Capital account number x1124

83. Capital account number X1933

84. Any and all bank funds, securities, or other assets on deposit or
seized from an account held at Kraken in the name of Ad Tech BV.

85. JP Morgan Chase Bank account number 5 in the amount of $42,500

86. Alliance Bernstein Brokerage account x7889 

87. Alliance Bernstein Brokerage account X0582-

88. Mid?rst Bank account X4139

89. Capital account number X6886

Such property further includes, but is not limited to, the following domain names:

1. admoderationcom (Versio)
2. admoderatorscorn (Versio)
3. adnet.ws (NetNames)

- 4. adplace24.eorn (Versio)
5. adplace324.com (Versio)
6. adpost24.corn (Versio)
7. adpost24.cz (GoDaddy)
8. adquick365.com (Versio)
9. adreputationcom (NetNames)
1'0. ads-posted-mp.com (Versio)
11. adsplace24.com (Versio)
12. adspot24.corn (Versio)
13. adspots24.com (Versio)
14. adsspot24.com (Versio)
15. adtecth.co.nl (N etNarnes)
16. CNetNaInes)
17. (NetNarnes)

-822.

 

 





 

Case Document 230 Filed 07/25/18 Page 83 of 92

18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
3.8.
39.
40.
41.
42.
43.
44.
45.

advert?epcom (Versio)
adverts-mpcom (Versio)
axme.com (GoDaddy)
b?aCkOageeom (N etNames)
backpage (NetNames)
backpaee.oom (N etNames)
backpage-insider.com (NetN'ames)
backpageadult (N etNames)
(NetNameS)
backpageet (NetNames)
backpageex (NetNames)
backpagebe (NetNames)
backpagebg (European domains)
backpagebg (N etNames)
backpage.ea (NetNames)

backpage.cl (N etNames)

backpage.en (European domains)
backpage.cn (N etNames)
backpage.co.id (NetNaInes)
backpage.oo.nl (European domains)
backpage.oo.nl (N etNemes)
backpage.co.nz (NetNames)
backpage.oo.uk (N etNames)
backpage.oo.ve (NetNames)
backpage.oo.Za (NetNames)
backpage.oom (N etNames)
backpageeoiner (N etNames)

backpagecomau (NetNames)

-83_

 

 






 

Case Document 230 Filed 07/25/18 Page 84 of 92

46.
47.
48.
49.
50.
51.
52.
53.
54.
55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
65.
66.
67.
68.
69.
70.
71.
72.
73.

backpage.com.ph (NetNames)
backpage.oz (NetNames)
backpagedk (N etNames)
backpageec (NetNames)
(European domains)
(NetNames)
backpagees (NetNames)
backpage.fi (European domains)
backpage? (NetNames)
backpagefr (European domains)
backpage.fr (N etNames)
backpage. gr (European domains)
backpagegr (N etNarnes)
backpagehk (European domains)
backpagehk (N etName s)
backpagehu (European domains)
backpagehu (N etNarnes)
backpageie (NetNames)
backpagein (N etNames)
backpageit (N etNames)
backpagejp (N eiNames)
backpagekr (N etNames)
backpage1t (NetNarnes)
backpagelv (European domains)
backpagelv (NetNarnes)
backpage.me (N etN-ames)
backpagemx (N etNames)
backpage.my (N etNames)

-84_

 

 






 

Case Document 230 Filed 07/25/18 Page 85 of 92

74.
75.
76.
77.
78.
79.
80.
81.
82.
83.
84.
85.
86.
87.
88.
89.
90.
91.
92.

93. 

94.

95. 

96.
97.
98.
99.

100.
101.

backpagenet (NetNames)
backpagenl (N etNames)
backpageno (European domains)
backpageno (N etNames)
bac'kpagenz (N etNames)
backpagepe (N etNames)
backpageph (N etNames)
backpagepk (N etNames)
backpagepl (NetNames)
backpageporn (N etNames)

,baekpagept (N etNames)

backpagexo (European domains)
backpage.ro (N etNames)
backpage.se (N etNames)
backpage.sex (NetNames)
backpage.sg (N etNames)
backpage.si (European domains)
backpage.si (N etNames)
backpage.sk (European domains)
backpage.sk (N etNames)
backpage.sucks (N etNames)
backpage.tw (NetNames)
backpagenk (N etNames)
backpagenkcom (NetNames) I
backpagens (NetNames)
backpage.vn (NetNames)
(N etNames)
backpage.xyz (NetNames)

-85_

 

 

\DOON?lChUl-hmwr?t

[9 1?4 1?9 1?1 1?


 

Case Document 230 Filed 07/25/18 Page 86 of 92

102.
103.
104.
105.
106.
107.
108.
109.
110.
111.
112.
113.
114.
115.
116.
117.
118.
119.
120.
121.
122.
123.
124.
125.
126.
127.
128.
129.

backpagecompimp.com (NetNames)
backpagecompimps.com (NetNames)
backpagepimp.com (N etNames)
backpagepimps.com (NetNames)
backpagg.com (NetNames)
bacl<pagm.com (NetNames)
backpagu.com (N etNames)
backpaoecom CNetNames)
backpawe.com (N etNames)
backqage.com (N etNames)
ba-ckrage?om (NetNames)
backxagccom (NetNames)
bakkpage.com (NetNames)
bcklistings.com (NetNames)
bestofbackpage.com (NetNames)
bestofbigcity.com (NetNames)
biCkpage.com (N etNames)
bigcity.com (NetNames)
bpclassi?ed.com (NetNames)
bpclassifieds.com (NetNames)
carlferrer.com (NetNames)
clasi?cadosymas.com (NetNames)
clasi?cadosymasnet (NetNames)
clasi?cadosymas.org (NetNames)
classifiedsolutions.co.uk (N etNames)
classi?edsolutionsnet (NetNames)


columbusbackpage.com (NetNames)



 

 






 

Case Document 230 Filed 07/25/18 Page 87 of 92

130.
131.
132.
133.
134.
135.
136.
137.
138.
139.
140.
141.
142.
143.
144.
145.
146.
147.
148.
- 149.
150.
151.
152.
153.
154.
155.
156.
157.

connectiCutbackpage.com (NetNames)
cracker.c0.id (NetNames)

cracker.com (NetNames)
cracker.com.au (NetNames)

crackerid (N etNames)

cracker.net.au (NetNames) I

c1*ackers.com.au (NetNames)

crackersnetau (N etNames)
ctbackpage.com (N etNames)

dallasb ackpage.com (NetNames)
denverbackpage.com (NetNames)
easypost123 .com (Versio)
easypost3123 .com (Versio)
emais.com.pt (NetNames)
evilempire.com(NetNames)

ezpost123 .com (Versio)

fackpage.com (N etName's)
fastadboard.com (Versio)
guliettagroupnl (Versio)

htpp.0rg (NetNames) 

icholdcon? (N etNames)
intemetspeechfoundation.com (nameisp)
int?rnetspeechfoundation.org (nameisp)
10adderive.com (NetNames)
loadstodrive.com (NetNames)
loadtodrive.com (NetNames)
losangelesbackpage.com (NetNames)

mediafilecloud.com (NetNames)

-87_

 

 






 

Case Document 230 Filed 07/25/18 Page 88 of 92

158.
159.
160.
161.
162.
163.
164.
165.
166.
167.
168.
169.
170.
171.
172.
173.
174.
175.
176.
177.
178.
179.
180.
181.
182.
183.
184.
185.

miamibackpage.com (NetNames)
minneapolisbackpage.com (N etNames)
mobileposting.com (Versio)
mobilepostings.com (Versio)
mobilepostlist.com (Versio)
mobilposting.com (Versio)

nakedcity (NetNames)

nakedcity.com (N etNames)

newyorkbackpage.com (N ?tNames)
paidbyhour.com (NetNames)
petseekrcom (NetNames)
petsfindr.com (N etNames)
phoenixbackpage.com (NetNames)
posteasy123 .6011}. (Versio)
postfaster.com (N etNames)
postfastly.com (N etNames)
postfastr.com (NetNames)
p03t0n1inewith.com (Versio)
postonlinewith.me (Versio)
postseasy123.com (Versio) 

postsol.com (GoDaddy)

-postszone24.com (Versio)

postzone24.com (Versio)
postzon6824.com (Versio)

l?entseekrcom (N etNames)

Iresults91 1.00m (NetNames)

sandiegobackpagesom (N etNames)

sanfranciscobackpage.com (NetNames)

-88..

 

 



anus amt inCase Document 230 Filed 07/25/18 \Page 89 of 92

186.
187.
188.
189.
190.
191.
192.
193.
194.
195.
196.
197.
198.
199.
200.
201.
202.
203.
204.'
205.
206.
207.
208.
209.
210.
211.
212.
213.

seattlebackpage.oom (NetNames)
sellyostuffonline.oorn (Versio)
sfbaokpage.oom(NetNames)
simplepost24.oom (Versio)
simplepost324.corn (Versio)

svc.ws (NetNames)

truckrj obsoom (N etNarnes)
ugotechgroupeorn (NetNames) -
universadsnl (Versio)
Villagevoicepimps.com (GoDaddy)
web sitetechnologies . co .uk (N etNames)
websitetechnologies.com (NetNames)
websitetechnologies.net (N etNarnes)
websiteteohnologiesnl (NetNaInes)
websiteteohnologiesorg (N etName?s)
weprocessmoneyeom (GoDaddy)
wst.ws (NetNames)
(N etNames)
ymas.ar.oorn (European domains)
ymas.br.com (European domains)
ymas.br.com (N etNames)

ymasbz (European domains)
ymasbz (NetNames)

yrnascl (European domains)
ymas.ol (NetNames)

ymas.oo.bz (European domains)
ymas.oo.bz (NetNames)

ymas.oo.or (European domains)

-89_

 

 






 

Case Document 230 Filed 07/25/18 Page 90 of 92

214.
215.
216.
217.
218.
219.
220.
221.
222.
223.
224.,
225.
226.
227.
228.
229.
230.
231.
232.
233.
234.
235.
236.
237.
238.
239.
240.
241. 1

ymas.co.cr (NetNames)
ymas.oo.ni (European domains)
ymas.co.ni CNetNames)
ymas.co.ve (European domains)
ymas.oo.ve (N etNames)
ymas.com (NetNames)
ymas.com.br (European domains)
ymas.com.br (NetNames)
ymas.oom.bz (European domains)
ymas.com.bz (N etNames)
ymas.oom.co (European domains)
ymas.oom.co (NetNames)
ymas.oom.do (European domains)
ymas.corn.do (NetNames)
ymas.oom.ec (European domains)
ymas.com.e'c (NetNames)
ymas.com.es (European domains)
ymas.oom.es (NetNames)
ymas.oom.gt (European domains)
ymas.com. gt (NetNames)
ymas.com.hn (European domains)
ymas.com.hn (NetNames) I
ymas.oom.mx (N etNames)
ymas.com.ni (European domains)
ymas.oom.ni (NetNames)
ymas.oom.pe (European domains)
ymas.oom.pe (N etNames)

ymas.com.pr (European domains)

-90_

 

 

uncommon?boom)?

3?4 v?t pun 1?4 s?a r?t p?L p?i


 

Case Document 230 Filed 07/25/18 Page 91 of 92

242.
243.
244.
245.
246.
247.
248.
249.
250.
251.
252.
253.
254.
255.
256.
257.
258.
259.
260.
261.
262.
263.
264.
265.
266.
267.
268.

ymas.oom.pr (NetNames)
ymas.oom.pt (N etNames)
ymas.oom.uy (European domains)
ymas.oom.uy (NetNames)
ymas.eom.ve (European domains)
ymas.com.ve (NetNames)
ymas.or (European domains)
ymas.er (N etNames)
ymasdo (European domains)
ymas.do (N etNames)
ymasec (European domains)
ymaseo (NetNames)
ymases (European domains)
ymases (NetNames)
ymasorg (NetNames)
ymaspe (European domains)
ymaspe (N etNames)
ymaspt (NetNames) 
ymasns (European domains)
ymas.us (NetNames)
ymasny (European domains)
ymasny (NetNames)

ymas.uy.com (European domains)

-at1antabaekpage.oom (N etNames)

backpage.com.br (N etNames)
ohioagobackpage.com (NetNames)
tampabaokpageoom (NetNames)

b. To the extent such property is. not available for forfeiture, a sum of money

-91_

 

 






 

Case Document 230 Filed 07/25/18 Page 92 of 92

equal to the total value of such property. 

3. Pursuant to Title 21, United States Code, Section 853(p), as incorporated by
Title 18, United States Code, Section 982(b), eachldefendant convicted under Counts 52
through 100 of this Superseding Indictment shall forfeit substitute property, if, by any act
or omission of that defendant, the property described in the preceding paragraph, or any
portion thereof, cannot be located upon the exercise of due diligence; has been transferred,
sold to, or deposited with a third party; has been placed beyond the jurisdiction of the court;
has been substantially diminished in value; or has been commingled with other property

that cannot be divided Without dif?culty.

A TRUE BILL


FOREPERSON OF THE GRAND JURY
Date: July 25,2018

ELIZABETH A. STRANGE
First Assistant United States Attorney
District of Arizona

BRIAN BENCZKOWSKI Assistant Attorney General A
Criminal Division, US. Department of Justice

8/

KEVIN M. RAPP
MARGARET PERLMETER
PETER KOZINETS 
ANDREW STONE
Assistant US. Attorneys

JOHN J. KUCERA 
Specral US. Attorney

REGINALD E. JONES

Senior Trial Attorne

US. Department of Instice, Criminal Division
Child Exploitation and Obscenity Section

g92__