Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 1 of 57
`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 1 of 57
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`EXHIBIT C
`EXHIBIT C
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`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 1 of 57
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`EXHIBIT C
`EXHIBIT C
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`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 2 of 57
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`Thomas H. Bienert, Jr. (admitted pro hac vice)
` tbienert@bmkattorneys.com
`Whitney Z. Bernstein (admitted pro hac vice)
` wbernstein@bmkattorneys.com
`BIENERT KATZMAN LITTRELL WILLIAMS LLP
`903 Calle Amanecer, Suite 350
`San Clemente, CA 92673
`Telephone: (949) 369-3700
`Facsimile: (949) 369-3701
`
`Attorneys for Defendant James Larkin
`
`Paul J. Cambria, Jr. (admitted pro hac vice)
` pcambria@lglaw.com
`Erin McCampbell (admitted pro hac vice)
` emccampbell@lglaw.com
`LIPSITZ GREEN SCIME CAMBRIA LLP
`42 Delaware Avenue, Suite 120
`Buffalo, New York 14202
`Telephone: (716) 849-1333
`Facsimile: (716) 855-1580
`
`Attorneys for Defendant Michael Lacey
`
`[Additional counsel listed on next page]
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF ARIZONA
`
` CASE NO. 2:18-cr-00422-PHX-SMB
`
`PROPOSED VERDICT FORM
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`Assigned to Hon. Susan M. Brnovich,
`Courtroom 506
`
`Trial Date:
`
`United States of America,
`
`Plaintiff,
`
`vs.
`
`Michael Lacey, et al.,
`
`Defendants.
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`
`
`
`September 2, 2021
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`3739464.5
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`PROPOSED VERDICT FORM
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`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 3 of 57
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`Gary S. Lincenberg (admitted pro hac vice)
` glincenberg@birdmarella.com
`Ariel A. Neuman (admitted pro hac vice)
` aneuman@birdmarella.com
`Gopi K. Panchapakesan (admitted pro hac vice)
` gpanchapakesan@birdmarella.com
`BIRD, MARELLA, BOXER, WOLPERT, NESSIM,
`DROOKS, LINCENBERG & RHOW, P.C.
`1875 Century Park East, 23rd Floor
`Los Angeles, California 90067-2561
`Telephone: (310) 201-2100
`Facsimile: (310) 201-2110
`
`Attorneys for Defendant John Brunst
`
`Bruce Feder (AZ Bar No. 004832)
` bf@federlawpa.com
`FEDER LAW OFFICE, P.A.
`2930 E. Camelback Road, Suite 160
`Phoenix, Arizona 85016
`Telephone: (602) 257-0135
`
`Attorney for Defendant Scott Spear
`
`David Eisenberg (AZ Bar No. 017218)
` david@deisenbergplc.com
`DAVID EISENBERG PLC
`3550 N. Central Ave., Suite 1155
`Phoenix, Arizona 85012
`Telephone: (602) 237-5076
`Facsimile: (602) 314-6273
`
`Attorney for Defendant Andrew Padilla
`
`Joy Malby Bertrand (AZ Bar No. 024181)
` joy.bertrand@gmail.com
`JOY BERTRAND ESQ LLC
`P.O. Box 2734
`Scottsdale, Arizona 85252
`Telephone: (602)374-5321
`Facsimile: (480)361-4694
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`Attorney for Defendant Joye Vaught
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`3739464.5
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`2
`PROPOSED VERDICT FORM
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`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 4 of 57
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`We, the Jury, find the Defendants, Michael Lacey, James Larkin, Scott Spear, John
`“Jed” Brunst, Andrew Padilla, and Joye Vaught, as to the charges of the Indictment:
`
`CONSPIRACY
`18 U.S.C. § 371
`COUNT 1
`________ GUILTY
`________ GUILTY
`________ GUILTY
`________ GUILTY
`________ GUILTY
`________ GUILTY
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`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
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`Michael Lacey
`James Larkin
`Scott Spear
`John “Jed” Brunst
`Andrew Padilla
`Joye Vaught
`
`Q.2
`Q.3
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`Travel Act – Facilitate Prostitution
`18 U.S.C. § 1952(a)(3)(A)
`COUNTS 2-51
`Count 2:
`Concerning an ad published on Sept. 10, 2013
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
`
`Q.4
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`3739464.5
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`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`Scott Spear
`________ GUILTY
`John Brunst
`________ GUILTY
`Andrew Padilla
`________ GUILTY
`Joye Vaught
`________ GUILTY
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`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
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`Q.2
`Q.3
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`Count 3:
`Concerning an ad published on Jan. 27, 2014
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
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`Q.4
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`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
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`3739464.5
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`4
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`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 6 of 57
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`Scott Spear
`John Brunst
`Andrew Padilla
`Joye Vaught
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`________ GUILTY
`________ GUILTY
`________ GUILTY
`________ GUILTY
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`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
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`Q.2
`Q.3
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`Count 4:
`Concerning an ad published on Jan. 29, 2014
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
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`Q.4
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`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`Scott Spear
`________ GUILTY
`John Brunst
`________ GUILTY
`Andrew Padilla
`________ GUILTY
`Joye Vaught
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
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`3739464.5
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`PROPOSED VERDICT FORM
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`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 7 of 57
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`Q.2
`Q.3
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`Count 5:
`Concerning an ad published on Jan. 31, 2014
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
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`Q.4
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`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`Scott Spear
`________ GUILTY
`John Brunst
`________ GUILTY
`Andrew Padilla
`________ GUILTY
`Joye Vaught
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
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`Count 6:
`Concerning an ad published on Feb. 6, 2014
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`
`Q.2
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`3739464.5
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`6
`PROPOSED VERDICT FORM
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`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 8 of 57
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`Q.3
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`Q.4
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`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
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`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`Scott Spear
`________ GUILTY
`John Brunst
`________ GUILTY
`Andrew Padilla
`________ GUILTY
`Joye Vaught
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
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`Count 7:
`Concerning an ad published on Apr. 20, 2014
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`
`Q.2
`Q.3
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`3739464.5
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`PROPOSED VERDICT FORM
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`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 9 of 57
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`Q.4
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`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
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`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`Scott Spear
`________ GUILTY
`John Brunst
`________ GUILTY
`Andrew Padilla
`________ GUILTY
`Joye Vaught
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
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`Q.2
`Q.3
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`Count 8:
`Concerning an ad published on May 7, 2014
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
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`Q.4
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`3739464.5
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`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 10 of 57
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`Scott Spear
`John Brunst
`Andrew Padilla
`Joye Vaught
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`________ YES
`________ YES
`________ YES
`________ YES
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`_________ NO
`_________ NO
`_________ NO
`_________ NO
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`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`Scott Spear
`________ GUILTY
`John Brunst
`________ GUILTY
`Andrew Padilla
`________ GUILTY
`Joye Vaught
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
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`Q.2
`Q.3
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`Count 9:
`Concerning an ad published on May 31, 2014
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
`
`Q.4
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`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`Scott Spear
`________ GUILTY
`John Brunst
`________ GUILTY
`Andrew Padilla
`________ GUILTY
`Joye Vaught
`________ GUILTY
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`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
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`Q.2
`Q.3
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`Count 10: Concerning an ad published on July 1, 2014
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
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`Q.4
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`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
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`3739464.5
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`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 12 of 57
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`Scott Spear
`John Brunst
`Andrew Padilla
`Joye Vaught
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`________ GUILTY
`________ GUILTY
`________ GUILTY
`________ GUILTY
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`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
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`Q.2
`Q.3
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`Count 11: Concerning an ad published on Aug. 19, 2014
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
`
`Q.4
`
`
`
`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`Scott Spear
`________ GUILTY
`John Brunst
`________ GUILTY
`Andrew Padilla
`________ GUILTY
`Joye Vaught
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`
`
`3739464.5
`
`
`
`11
`PROPOSED VERDICT FORM
`
`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
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`17
`18
`19
`20
`21
`22
`23
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`28
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`
`
`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 13 of 57
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`1
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`22
`23
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`27
`28
`
`
`Q.2
`Q.3
`
`Count 12: Concerning an ad published on Nov. 23, 2014
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
`
`Q.4
`
`
`
`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`Scott Spear
`________ GUILTY
`John Brunst
`________ GUILTY
`Andrew Padilla
`________ GUILTY
`Joye Vaught
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`
`
`
`
`Count 13: Concerning an ad published on Jan. 29, 2015
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`
`Q.2
`
`3739464.5
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`
`
`12
`PROPOSED VERDICT FORM
`
`
`
`
`
`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 14 of 57
`
`
`
`
`
`Q.3
`
`Q.4
`
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
`
`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`Scott Spear
`________ GUILTY
`John Brunst
`________ GUILTY
`Andrew Padilla
`________ GUILTY
`Joye Vaught
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`
`
`
`
`Count 14: Concerning an ad published on Jan. 31, 2015
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`
`Q.2
`Q.3
`
`3739464.5
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`
`
`13
`PROPOSED VERDICT FORM
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`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`
`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 15 of 57
`
`
`
`
`
`Q.4
`
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
`
`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`Scott Spear
`________ GUILTY
`John Brunst
`________ GUILTY
`Andrew Padilla
`________ GUILTY
`Joye Vaught
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`
`Q.2
`Q.3
`
`
`
`
`Count 15: Concerning an ad published on Jan. 31, 2015
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`
`Q.4
`
`3739464.5
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`
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`14
`PROPOSED VERDICT FORM
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`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
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`
`
`
`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 16 of 57
`
`
`
`
`
`Scott Spear
`John Brunst
`Andrew Padilla
`Joye Vaught
`
`________ YES
`________ YES
`________ YES
`________ YES
`
`_________ NO
`_________ NO
`_________ NO
`_________ NO
`
`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`Scott Spear
`________ GUILTY
`John Brunst
`________ GUILTY
`Andrew Padilla
`________ GUILTY
`Joye Vaught
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`
`Q.2
`Q.3
`
`
`
`
`Count 16: Concerning an ad published on Feb. 4, 2015
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
`
`Q.4
`
`
`3739464.5
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`15
`PROPOSED VERDICT FORM
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`28
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`
`
`
`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 17 of 57
`
`
`
`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`Scott Spear
`________ GUILTY
`John Brunst
`________ GUILTY
`Andrew Padilla
`________ GUILTY
`Joye Vaught
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`
`Q.2
`Q.3
`
`
`
`
`Count 17: Concerning an ad published on Feb. 18, 2015
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
`
`Q.4
`
`
`
`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
`
`3739464.5
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`16
`PROPOSED VERDICT FORM
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`
`1
`2
`3
`4
`5
`6
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`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`
`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 18 of 57
`
`
`
`Scott Spear
`John Brunst
`Andrew Padilla
`Joye Vaught
`
`________ GUILTY
`________ GUILTY
`________ GUILTY
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`
`Q.2
`Q.3
`
`
`
`
`Count 18: Concerning an ad published on Feb. 26, 2015
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
`
`Q.4
`
`
`
`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`Scott Spear
`________ GUILTY
`John Brunst
`________ GUILTY
`Andrew Padilla
`________ GUILTY
`Joye Vaught
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`
`
`3739464.5
`
`
`
`17
`PROPOSED VERDICT FORM
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`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`
`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 19 of 57
`
`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`Q.2
`Q.3
`
`Count 19: Concerning an ad published on May 18, 2015
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`If you identify a business enterprise in response to Q.2, do you find that the
`business enterprise was engaged in prostitution offenses in violation of the
`laws of _____:
`YES ___ NO ___
`If you answer “YES” to Q.3, do you find that each defendant knew of this
`business enterprise, knew that it was engaged in prostitution, and specifically
`intended to facilitate its prostitution activities?
`Michael Lacey
`________ YES
`_________ NO
`James Larkin
`________ YES
`_________ NO
`Scott Spear
`________ YES
`_________ NO
`John Brunst
`________ YES
`_________ NO
`Andrew Padilla
`________ YES
`_________ NO
`Joye Vaught
`________ YES
`_________ NO
`
`Q.4
`
`
`
`Only if you answer “YES” to Q.1, identify a business enterprise in response to Q.2,
`answer “YES” to Q.3, and “YES” as to the defendant in Q.4 may you proceed to
`answer the following questions:
`Michael Lacey
`________ GUILTY
`James Larkin
`________ GUILTY
`Scott Spear
`________ GUILTY
`John Brunst
`________ GUILTY
`Andrew Padilla
`________ GUILTY
`Joye Vaught
`________ GUILTY
`
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`_________ NOT GUILTY
`
`
`
`
`Count 20: Concerning an ad published on May 19, 2015
`Q.1 Does the advertisement refer to a particular business enterprise?
`YES ___ NO ___
`If so, please identify the business enterprise: ___________
`
`Q.2
`
`3739464.5
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`
`
`18
`PROPOSED VERDICT FORM
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`
`
`
`
`Case 2:18-cr-00422-SMB Document 1222-3 Filed 08/18/21 Page 20 of 57
`
`
`
`
`
`Q.3
`
`Q.4
`
`If you identify a business enterprise in response to Q.2, do you find that the
`business enter
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