Case 2:18-cr-00422-DJH Document 1591 Filed 06/08/23 Page 1 of 13
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`
`
`Timothy J. Eckstein, 018321
` teckstein@omlaw.com
`Joseph Roth, 025725
` jroth@omlaw.com
`Sarah P. Lawson, 036436
` slawson@omlaw.com
`OSBORN MALEDON, P.A.
`2929 North Central Avenue, 20th Floor
`Phoenix, AZ 85012-2793
`Telephone: (602) 640-9000
`Facsimile: (602) 640-9050
`
`Attorneys for Defendant James Larkin
`
`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)
` gkp@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
`
`[Additional counsel listed on next page]
`
`
`
`UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF ARIZONA
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`
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`United States of America,
`
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`Plaintiff,
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`vs.
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`Michael Lacey, et al.,
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`Defendants.
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` CASE NO. 2:18-cr-00422-004-PHX-DJH
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`MOTION IN LIMINE TO PRECLUDE
`REFERENCES TO ALLEGED
`FORMER “PROSTITUTION”
`MARKETING STRATEGIES
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`3870624.2
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`MOTION IN LIMINE TO PRECLUDE REFERENCES TO ALLEGED FORMER “PROSTITUTION”
`MARKETING STRATEGIES
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`Case 2:18-cr-00422-DJH Document 1591 Filed 06/08/23 Page 2 of 13
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`Paul J. Cambria, Jr. (admitted pro hac vice)
` pcambria@lglaw.com
`Erin McCampbell Paris (admitted pro hac vice)
` eparis@lglaw.com
`LIPSITZ GREEN SCIME CAMBRIA LLP
`42 Delaware Avenue, Suite 120
`Buffalo, New York 14202
`Telephone: (716) 849-1333
`Facsimile: (716) 855-1580
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`Attorneys for Defendant Michael Lacey
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`Eric W. Kessler, SBN 009158
`KESSLER LAW GROUP
`6720 N. Scottsdale Rd., Ste. 210
`Scottsdale, Arizona 85253
`(480) 644-0093 phone
`(480) 644-0095 fax
`Eric.KesslerLaw@gmail.com
`
`Attorney for Defendant Scott Spear
`
`David Eisenberg, 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, 024181
` joy.bertrand@gmail.com
`JOY BERTRAND ESQ LLC
`PO 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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`3870624.2
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`2
`MOTION IN LIMINE TO PRECLUDE REFERENCES TO ALLEGED FORMER “PROSTITUTION”
`MARKETING STRATEGIES
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`Case 2:18-cr-00422-DJH Document 1591 Filed 06/08/23 Page 3 of 13
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`I.
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`THE GOVERNMENT HAS IDENTIFIED WITNESSES AND EXHIBITS
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`BARRED BY THE COURT’S PRIOR ORDER.
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`In its May 4, 2020 Order denying Defendant John Brunst’s Motion to Dismiss
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`Indictment for Failure to Allege the Necessary Elements of the Travel Act, the Court held
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`that:
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`Defendants’ suggestion that the SI improperly indicts a ‘boundless
`conspiracy to facilitate prostitution in general,’ (Reply at 4), however,
`mischaracterizes the charges against them. Such a claim is simply untrue.
`They were not indicted for facilitating the amorphous notion of
`‘prostitution.’ They were indicted for facilitating (via publishing ads) on
`fifty distinct occasions where prostitutes, prostitution-related businesses, or
`other groups were involved in the business of prostitution. (SI ¶ 201.)
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`Dkt. 946 at 13 (emphasis added).
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`That is the law of the case. Dkt. 1524 at 4 n.2 (Order Setting Final Pretrial
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`Conference). This case is about whether Defendants facilitated business enterprises
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`engaged in prostitution in violation of state law when Backpage.com published one or
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`more of the fifty charged adult-oriented ads – not about the millions of other adult-oriented
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`ads that Backpage.com published over the years. Dkt. 946 at 13. Evidence is therefore
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`relevant only if it concerns one of the fifty charged ads. To avoid another mistrial,
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`Defendants seek an order to make clear that evidence of alleged strategies to increase
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`purported “prostitution” ads on the site not specific to these fifty ads is irrelevant, because
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`those alleged practices ended long before any of the fifty charged ads was posted.
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`Defendants anticipate the Government will attempt to introduce evidence unrelated
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`to the fifty charged ads involving (1) ad moderation (allowing moderators to modify the
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`wording of ads and then allowing the ads to run); (2) Backpage’s alleged “reciprocal”
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`advertising/link program with The Erotic Review (TER) (a different website with adult
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`content); and (3) content “aggregation,” alleged to be the provision of free ads “in an
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`attempt to secure future advertising revenues.” Dkt. 230 (Superseding Indictment) at
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`¶¶ 10-11, 34. Under the Court’s Order, such evidence is inadmissible because each of
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`those alleged practices ended well before September 10, 2013—the date that the first
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`3870624.2
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`MOTION IN LIMINE TO PRECLUDE REFERENCES TO ALLEGED FORMER “PROSTITUTION”
`MARKETING STRATEGIES
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`Case 2:18-cr-00422-DJH Document 1591 Filed 06/08/23 Page 4 of 13
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`charged ad was published. Dkt. 230 at 201 (Count 2).1
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`First, Backpage.com prohibited its moderators from modifying the wording of ads
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`by the fall of 2012 – roughly a year before the first charged ad was published – a fact
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`admitted by several former Backpage.com moderators interviewed by the Government.
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`Second, as to alleged reciprocal links with TER, Backpage had ended its relationship with
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`TER and banned any reference to TER in its ads (including any “review ID” numbers tied
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`to TER) by early 2011 – about two-and-a-half years before the first charged ad was
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`published. Exh. A (February 18, 2011 email from Defendant Andrew Padilla). Third, as
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`to aggregation, the indictment references a November 2008 internal Backpage email
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`regarding “aggregation efforts in Dallas”—nearly five years before the first charged ad
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`was published. Dkt. 230 at ¶ 43. Although the indictment makes a single reference to an
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`October 2013 email from Carl Ferrer (Backpage’s CEO) to Defendant Scott Spear
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`regarding a “plan to hire . . . Content creators” in the Netherlands (where prostitution is
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`legal), there is no allegation that this plan was ever executed or that it had anything to do
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`with ads published in the United States, let alone any of the fifty charged ads. Id. at ¶ 44.
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`Critically, the Government does not allege, and could not allege, that any of the
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`fifty charged ads were the product of content aggregation, a “reciprocal” advertising/link
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`program with TER, or had their wording modified by a Backpage.com moderator.
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`Therefore, no evidence of any of these alleged practices should be admitted.
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`The Government may claim that those discontinued practices are relevant to the
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`conspiracy charge. But as the Court has already held, that charge is not “boundless”; it is
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`wedded and limited to the fifty charged ads. Dkt. 946 at 13; see also Dkt. 1444 at 8
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`(implying that any conspiracy is logically bound by the dates of the fifty charged ads, from
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`2013 to 2018). Nor are those practices relevant background information regarding the
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`1 The first charged ad was published on September 10, 2013, ten of the charged ads were
`published in 2014, fourteen of the charged ads were published in 2015, nine of the charged
`ads were published in 2016, eight of the charged ads were published in 2017, and eight of
`the charged ads were published in 2018.
`3870624.2
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`MOTION IN LIMINE TO PRECLUDE REFERENCES TO ALLEGED FORMER “PROSTITUTION”
`MARKETING STRATEGIES
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`Case 2:18-cr-00422-DJH Document 1591 Filed 06/08/23 Page 5 of 13
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`Backpage.com website because, as this Court has held, “this case is not about Backpage . .
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`. . This case is about these individuals and whether they had specific knowledge of these
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`ads as facilitating illegal activity.” Exh. B (December 4, 2020 Hr’g. Tr. at 38).
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`In addition to being barred under Rule 401 as irrelevant, evidence about these
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`discontinued practices should be barred under Rule 403, as the prejudice and confusion
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`resulting from the presentation of evidence about those practices would lead jurors to
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`conclude that such evidence is connected to the fifty charged ads.
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`II.
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`THE COURT PREVIOUSLY DEALT WITH A RELATED ISSUE.
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`In denying the Government’s Motion in Limine to Admit Evidence as Non-Hearsay
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`Statements (Dkt. 1162), the Court previously ruled that the Government would need to
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`“establish the foundation” necessary to admit unspecified statements from William “Dollar
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`Bill” Mersey (an alleged “super affiliate” of Backpage) and David Elms (who ran TER).
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`Dkt. 230 at 60; Dkt. 929 at 7-10. The instant motion seeks to preclude the admission of a
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`broader set of evidence regarding earlier practices the Government alleges were intended
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`to promote “prostitution” ads on the Backpage.com website, an approach supported by the
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`Court’s prior ruling as to statements made by Mersey and Elms.
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`III. PROPOSED ORDER
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`Defendants seek an order that precludes the Government from introducing evidence
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`regarding or making reference to (1) ad moderation; (2) a “reciprocal” advertising/link
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`program with The Erotic Review; and (3) content aggregation, as these alleged practices
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`are untethered to the fifty charged ads.2
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`2 Undersigned counsel certifies that they have conferred with the Government in an
`effort to resolve the disputed evidentiary issues that are the subject of this motion.
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`3870624.2
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`MOTION IN LIMINE TO PRECLUDE REFERENCES TO ALLEGED FORMER “PROSTITUTION”
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`Case 2:18-cr-00422-DJH Document 1591 Filed 06/08/23 Page 6 of 13
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`Pursuant to the District’s Electronic Case Filing Administrative Policies and
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`Procedures Manual (May 2023) § II(C)(3), Gary S. Lincenberg hereby attests that all
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`other signatories listed, and on whose behalf this filing is submitted, concur in the filing’s
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`content and have authorized its filing.
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`DATED: June 8, 2023
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`Respectfully submitted,
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`Timothy J. Eckstein
`Joseph Roth
`Sarah P. Lawson
`Osborn Maledon, P.A.
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`By:
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`/s/ Timothy J. Eckstein
`Timothy J. Eckstein
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`Attorneys for Defendant James Larkin
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`Gary S. Lincenberg
`Ariel A. Neuman
`Gopi K. Panchapakesan
`Bird, Marella, Boxer, Wolpert, Nessim,
`Drooks, Lincenberg & Rhow, P.C.
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`By:
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`/s/ Gary S. Lincenberg
`Gary S. Lincenberg
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`Attorneys for Defendant John Brunst
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`Paul J. Cambria
`Erin McCampbell Paris
`Lipsitz Green Scime Cambria LLP
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`By:
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`/s/ Paul J. Cambria
`Paul J. Cambria
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`Attorneys for Defendant Michael Lacey
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`DATED: June 8, 2023
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`DATED: June 8, 2023
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`3870624.2
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`MOTION IN LIMINE TO PRECLUDE REFERENCES TO ALLEGED FORMER “PROSTITUTION”
`MARKETING STRATEGIES
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`Case 2:18-cr-00422-DJH Document 1591 Filed 06/08/23 Page 7 of 13
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`DATED: June 8, 2023
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`DATED: June 8, 2023
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`DATED: June 8, 2023
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`Kessler Law Office
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`By:
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`/s/ Eric W. Kessler
`Eric W. Kessler
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`Attorney for Defendant Scott Spear
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`The Law Office of David Eisenberg, PLC
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`By:
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`/s/ David Eisenberg
`David Eisenberg
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`Attorney for Defendant Andrew Padilla
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`Joy Bertrand Esq. LLC
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`By:
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`/s/ Joy Malby Bertrand
`Joy Malby Bertrand
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`Attorney for Defendant Joye Vaught
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`3870624.2
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`MOTION IN LIMINE TO PRECLUDE REFERENCES TO ALLEGED FORMER “PROSTITUTION”
`MARKETING STRATEGIES
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`Case 2:18-cr-00422-DJH Document 1591 Filed 06/08/23 Page 8 of 13
`Case 2:18-cr-00422-DJH Document 1591 Filed 06/08/23 Page 8 of 13
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`EXHIBIT A
`EXHIBIT A
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`Case 2:18-cr-00422-DJH Document 1591 Filed 06/08/23 Page 9 of 13
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`Andrew Padilla •••••••••••I on behalf of Andrew Padilla
`
`on behalf of Andrew Padilla
`
`Andrew Padilla
`Friday, February 18, 2011 10:16 Pivi
`Adam
`Alien
`Amanda
`Beveilie
`Brian
`Billie
` Dawn
`Donavon
`Devyn
`Jennifer
`Jessica
`Levi
` Maria
` Misty
` Sara
`
`
`Jason
`
`Jeff
`LaTamara
` Michael
`Roger
`Zeke
`
` Ray
`Tranica
`
`Michael
`Nick
`Tara
`Joye
`another term bites the dust
`bites the dust
`good.jpg; bad.jpg; bad (1).jpg; bad (2) .jpg ; bad (3).jpg
`good.jpg; bad.jpg; bad (1).jpg; bad (2).jpg; bad (3).jpg
`
`Andrew
`Bryan
`:an
`
`Angel
`Cathleen '
` James
`John
` Martina
` Monica
` Sean
`
`Angela
`Cody
`
`Jana
`
`Justin
`Matt
` Nathan
`Stefano
`
`Kolter
`
`
`
`From:
`From:
`Sent:
`Sent:
`To:
`To ;
`
`Cc:
`Cc:
`Subject:
`Subjecl :
`Attachments:
`Attachments :
`
`All:
`All:
`
`We've been fiitering out the terms "TER" and "The Erotic Review" aiong with iinks to theeroticreview.com since January
`We've been filtering out the terms "TER" and "The Erotic Review" along with links to theeroticreview.com since January
`of this year but our internet safety experts have suggested we take a more aggressive approach.
`of this year but our internet safety experts have suggested we take a more aggressive approach.
`
`Effective irrtrriediateiy, any variation of, or reference to, TER is banned. if you find ii in an ad, rernove H·1e pr·1rase
`Effective ifnrnedicHeiy , 8ny v8fi8tion of, Of fefefence 10, TER is ban ned. if yOu find it in £In 8d, fefnOve iI're phfase
`and update tiie ad but do not lock tiie ad from editing for tiiis violation alone. if ti1e review iD number is attached to tiie
`and update the ad but do not lock the ad from editing fOf this violation alone . If the review ID num ber is attached to the
`iefeience (TER #8075309) , iernove tt-1e ID numbei along with the TER iefeience.
`reference (TER :tSG75309}, remove the ID nurnber along with the TER reference.
`
`If you find a string of numbers without a direct reference to TER, it's allowed.
`If you find a string of numbers without a direct reference to TER , it's allowed .
`Examples:
`Examples:
`
`"#123456"
`"#123456"
`
`'Well Reviewed #666666"
`"\Nell Reviewed #666666"
`
`"Google my reviews #12011201"
`"Google my reviews #12011201~
`
`An easy way to weed out a good chunk of these references is to do a search for "TER" on the city page. You'll get some
`An easy way to weed out a good chun k of these references is to do a search for ~TER" on the city page. You'll get some
`false positives but it should point you in the right direction. ~~on-adult spammers vvill sometimes use hidden keyvvords
`false positi ves but it should point you in the right direction. Non-adult spammers v.ill sometimes use hidden key,vords
`like "blockbuster video .. and the search vvill see the tail-end of "buster". To avoid this, you can start your search after
`like "block bus ter video" and the sea rch w ill see the tail-end of "bus ter" . To avo id this. you can start your search after
`you've navigated to the Adult section of the city.
`you've novigated to the Adu lt section of the city.
`
`!'m attaching '1 examp!e screenshots of \Alhat is not a!!ov1ed {circled in red) and 1 example screenshot of '.·vhat is okay
`I'm anaching 1 example screens hots of what is not allowed (circled in red) and 1 example screenshot of what is okay
`(circled in green).
`(circled in green).
`
`If you have any questions, please ask me or Joye. Thanks.
`If you have any Questions, please ask me or Joye. Thanks.
`
`Andrew Padilla
`And rew P3dilla
`Operation.~ ~ ... fan ager
`Or"'3tic;ns 1'.('''''1<''
`Backoa1te.com I Vil lai:te Voice Media
`"red i.
`
`
`CONFiDENTiAL
`CONFiDENTiAL
`
`BP-PSi-0297 ·i 7
`8P-PSi-029717
`
`App.000260
`
`

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`Case 2:18-cr-00422-DJH Document 1591 Filed 06/08/23 Page 10 of 13
`Case 2:18-cr-00422-DJH Document 1591 Filed 06/08/23 Page 10 of 13
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`EXHIBIT B
`EXHIBIT B
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`Case 2:18-cr-00422-DJH Document 1591 Filed 06/08/23 Page 11 of 13
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`UNITED STATES DISTRICT COURT
`
` FOR THE DISTRICT OF ARIZONA
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` _________________
`
` vs.
`
`United States of America, )
` )
` Plaintiff, ) CR-18-0422-PHX-SMB
` )
` ) Phoenix, Arizona
` ) December 4, 2020
`Michael Lacey, ) 10:02 a.m.
`James Larkin, )
`Scott Spear, )
`John Brunst, )
`Andrew Padilla, )
`Joye Vaught,
` )
` )
` Defendants. )
`______________________________)
`
`
`BEFORE: THE HONORABLE SUSAN M. BRNOVICH, JUDGE
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`
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`REPORTER'S TRANSCRIPT OF PROCEEDINGS
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`TELEPHONIC MOTION HEARING
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`Official Court Reporter:
`Linda Schroeder, RDR, CRR
`Sandra Day O'Connor U.S. Courthouse, Suite 312
`401 West Washington Street, Spc. 32
`Phoenix, Arizona 85003-2151
`(602) 322-7249
`
`Proceedings Reported by Stenographic Court Reporter
`Transcript Prepared by Computer-Aided Transcription
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`

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`Case 2:18-cr-00422-DJH Document 1591 Filed 06/08/23 Page 12 of 13
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`And I think one of the key things in my reason for
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`denying the recusal is that this case is not about Backpage.
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`Backpage was prosecuted in a separate case, entered a plea in a
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`separate case.
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`This case is about these individual defendants and
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`whether they had specific knowledge of these ads as
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`facilitating illegal activity. And that is why any reference
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`to the fact that this type of activity occurs on Backpage and
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`other social media doesn't have the strength it would had my
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`husband said something particular about these defendants, which
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`he has not.
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`He has also not -- I think the defense motion says
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`that he's made public statements about the people, which he has
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`not. The entities, yes, he's commented that Backpage -- that
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`human trafficking has occurred on Backpage along with
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`Craigslist, Facebook, other social media. And you also
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`mentioned issues in this case. He has not commented on this
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`case or any of the issues in this case.
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`MR. LINCENBERG: Your Honor, this is Gary Lincenberg.
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`I do not want to interrupt, but I would like to correct one
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`thing that the Court may have mistakenly just stated.
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`THE COURT: What's that?
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`MR. LINCENBERG: I believe I heard the Court state
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`that we had this key Attorney General letter in discovery, and
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`that's not correct, I believe, to the best of my knowledge.
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`UNITED STATES DISTRICT COURT
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`Case 2:18-cr-00422-DJH Document 1591 Filed 06/08/23 Page 13 of 13
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` 50
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`C E R T I F I C A T E
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`I, LINDA SCHROEDER, do hereby certify that I am duly
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`appointed and qualified to act as Official Court Reporter for
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`the United States District Court for the District of Arizona.
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`I FURTHER CERTIFY that the foregoing pages constitute
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`a full, true, and accurate transcript of all of that portion of
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`the proceedings contained herein, had in the above-entitled
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`cause on the date specified therein, and that said transcript
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`was prepared under my direction and control.
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`DATED at Phoenix, Arizona, this 4th day of December,
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`2020.
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` s/Linda Schroeder
` Linda Schroeder, RDR, CRR
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`UNITED STATES DISTRICT COURT
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