Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 1 of 10
`
`EXHIBIT INDEX TO DEFENDANTS’ RESPONSE TO GOVERNMENT’S
`MOTION TO PRECLUDE DEFENSE FROM REFERENCING CRAIGSLIST
`MEETINGS WITH ATTORNEYS GENERAL
`
`United State of America v. Michael Lacey, et al.
`2:18-cr-00422-PHX-DJH
`
`
`Exhibit Description
`Def. Trial Ex. 5054
`A
`B
`Gov’t Trial Ex. 17
`
`
`
`

`

`Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 2 of 10
`Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 2 of 10
`
`EXHIBIT A
`EXHIBIT A
`
`

`

`Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 3 of 10
`
`for Missing and Exploited
`listed below, and the National Center
`the Attorneys General
`craigslist,
`Children ("NCMEC"),
`announce new measures
`that craigslist
`is taking to help combat unlawful activity
`and improve public safety on its web site.
`
`This agreement culminates a series of discussions and in person meetings between Jim Buckmaster,
`CEO ofcraigslist, Richard Blumenthal, Attorney General ofthe State of Connecticut,
`and NCMEC.
`
`craigslist
`all communication
`
`service that provides the public with many benefits. Like
`internet classifieds
`is a popular
`tools,
`it can unfortunately be misused to facilitate unlawful activity.
`
`to prevent misuse of its web site, assisting
`craigslist has a long record of implementing measures
`law enforcement
`investigations,
`and of improving safety for craigslist users. Law enforcement
`personnel
`have called craigslist's
`attention to misuse of craigslist's
`"erotic services" category to facilitate unlawful
`activity. This problem requires new safeguards
`for craigslist and new ways of working together with law
`enforcement.
`Further
`innovation and collaboration
`in addressing these issues will be beneficial
`for the
`safety of craigslist
`users and the general public. Accordingly,
`craigslist,
`the Attorneys General,
`and
`NCMEC,
`announce the following measures
`for combating unlawful activity and improving public safety
`on craigslist:
`
`•
`
`•
`
`•
`
`•
`
`•
`
`•
`
`•
`
`program which allows users to "flag" a
`self-policing
`a community
`has implemented
`craigslist
`posting the user believes violates the terms of use,
`including the prohibition against pornography.
`The objectionable
`posting is eliminated automatically
`if it receives above a threshold number of
`flags.
`
`screening to block certain advertisements
`uses electronic
`craigslist
`violate its Terms of Use before they are posted.
`
`that craigslist
`
`believes will
`
`craigslist digitally tags adult sections of the site using industry standard PICS rating headers
`facilitate the effectiveness of PC-based parental screening software.
`
`to
`
`section of the
`craigslist has implemented a telephone verification system for the "erotic services"
`site requiring any person seeking to post an advertisement
`to provide a working telephone number.
`
`to permanently
`enables craigslist
`verification
`Telephone
`posting unlawful or inappropriate advertisements.
`
`block the phone number of any person
`
`craigslist
`category.
`credit card.
`
`services"
`its "erotic
`for
`and fee to post
`credit card verification
`to implement
`plans
`Persons wishing to post ads in this category will be required to pay a fee using a valid
`
`Credit card verification and fee to post will reduce ad volume significantly,
`responsible usage.
`
`and encourage more
`
`

`

`Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 4 of 10
`
`Credit Card verification provides additional identifying information that will enable craigslist to
`block the accounts of persons who violate craigslist's terms of use.
`
`credit card information would be available to law enforcement agencies through a subpoena
`process.
`
`craigslist plans to contribute 100% of the net revenues from these advertisements to charity. A
`public accounting firm will verify the net revenue amounts.
`
`is facilitated by companies providing spamming, posting, and/or flagging
`Misuse of craigslist
`services.
`These businesses seek financial profit by providing services and/or software that
`circumvent craigslist's terms of use and defense mechanisms or facilitate circumvention by other
`persons.
`
`craigslist has initiated (or will soon initiate) lawsuits against a number of these companies that
`violate craigslist's terms of use (or facilitate the violation ofcraigslist's terms of use by others).
`
`craigslist will provide evidence of unlawful activity by these operators to the Attorneys General for
`potential prosecution.
`
`craigslist has developed search capabilities that enhance its ability to assist NCMEC and law
`enforcement agencies to locate missing persons, and identify exploited minors and victims of
`human trafficking.
`
`craigslist is continuing its development efforts in this area to further enhance its ability to assist law
`enforcement NCMEC and even social welfare agencies in their efforts to protect children from this
`type of victimization.
`
`craigslist is visited by more than 40 million Americans each month, generating more than 12 billion
`monthly page views.
`Information presented by craigslist can help raise awareness among
`Americans regarding the enormous suffering caused by human trafficking and the exploitation of
`minors in this country.
`
`craigslist, the Attorneys General, and NCMEC will work together to further refine and improve
`educational materials that are currently available on craigslist.
`
`craigslist and the Attorneys General will meet on a regular basis to discuss design and functionality
`improvements to combat unlawful activity and improve safety on its web site.
`
`•
`
`•
`
`•
`
`•
`
`•
`
`•
`
`•
`
`•
`
`•
`
`•
`
`•
`
`

`

`Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 5 of 10
`
`•
`
`•
`
`craigslist will explore the implementation
`to violate its terms of use.
`
`and use of technology that prevents
`
`image uploads likely
`
`craigslist will work with the Attorneys General
`language used in craigslist postings.
`
`to develop more robust electronic
`
`screening
`
`of
`
`/~';p!
`
`Jim Buckmaster
`President and Chief Executive Officer
`craigslist,
`Inc.
`
`P/I4P
`
`Richard Blumenthal
`Attorney General of Connecticut
`
`#~
`
`Dustin B. McDaniel
`Attorney General of Arkansas
`
`Af:t~
`
`Richard S. Gebelein
`Acting Attorney General of Delaware
`
`~[%~
`
`Thurbert E. Baker
`Attorney General of Georgia
`
`~t~
`
`w~
`
`Mark J. Bennett
`Attorney General of Hawaii
`
`Lisa Madigan
`Attorney General of Illinois
`
`~
`
`Ernie Allen
`President and Chief Executive Officer
`National Center for Missing and Exploited
`Children
`
`---
`
`~~e.r-~
`
`Terry Goddard
`Attorney General of Arizona
`
`r:;t-w.~
`
`John W. Suthers
`Attorney General of Colorado
`
`~l;:;:-,
`P~ter J.1'l1ickles
`Attorney General ofthe District of Columbia
`
`d k{ tlu~" Ii
`
`"'-h<~<.L'.v
`
`Alicia G. Limtiaco
`Attorney General of Guam
`
`c=sf~~
`
`Lawrence G. Wasden
`Attorney General of Idaho
`
`~~
`
`Stephen Carter
`Attorney General of Indiana
`
`

`

`Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 6 of 10
`
`.~~
`Tom Miller
`Attorney General of Iowa
`
`?t?!{{..
`
`Jac:conway"O
`Attorney General of Kentucky
`
`~~~
`
`Steven Rowe
`Attorney General of Maine
`
`~~~
`
`Jim Hood
`Attorney General of Mississippi
`
`V<X--IJ~
`
`Jon Bruning
`Attorney General of Nebraska
`
`j(4a~
`~0
`
`Kelly A. Ayotte
`Attorney General of New Hampshire
`
`Gary King
`Attorney General of New Mexico
`
`U(iti~
`
`Steve Six
`Attorney General of Kansas
`
`~-g
`15~
`~/~
`
`James D. "Buddy" Caldwell
`Attorney General of Louisiana
`
`Douglas F. Gansler
`Attorney General of Maryland
`
`4/(t,~
`
`Mike McGrath
`Attorney General of Montana
`
`~&tJ1~
`
`Catherine Cortez Masto
`Attorney General of Nevada
`
`~
`Anne Milgram
`Attorney General of New Jersey
`
`~~
`Roy Cooper
`Attorney General of North Carolina
`
`f/thn~~~
`
`Wayne Stenehjem
`Attorney General of North Dakota
`
`Nancy H. Rogers
`Attorney General of Ohio
`
`

`

`Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 7 of 10
`
`~
`Drew Edmondson
`Attorney General of Oklahoma
`
`7::-t~
`
`Tom Corbett
`Attorney General of Pennsylvania
`
`j4/J/ #~It1~
`
`Henry McMaster
`Attorney General of South Carolina
`
`tf£~·r
`
`/~
`
`Hardy Myers
`Attorney General of Oregon
`
`~~
`Patrick C. Lynch
`Attorney General of Rhode Island
`
`~~
`Attorney General of South Dakota
`
`42l~
`
`Robert E. Cooper, Jr.
`Attorney General of Tennessee
`
`Mark L. Shurtleff
`Attorney General of Utah
`
`~~
`Vincent F. Frazer
`Attorney General of the Virgin Islands
`
`~M*~~-
`
`Rob McKenna
`Attorney General of Washington
`
`~~~
`J. B. Van Hollen
`Attorney General of Wisconsin
`
`~
`William H. Sorrell
`Attorney General of Vermont
`
`Robert F. McDonnell
`Attorney General of Virginia
`
`jL~~J
`;U/io
`
`Darrell V. McGraw, Jr.
`Attorney General of West Virginia
`
`Bruce A. Salzburg
`Attorney General of Wyoming
`
`

`

`Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 8 of 10
`Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 8 of 10
`
`EXHIBIT B
`EXHIBIT B
`
`

`

`Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 9 of 10
`
`From:
`Sent:
`To:
`Subject:
`
`Carl Ferrer [carl.ferrer@backpage.com] on behalf of Carl Ferrer
`Saturday, November 22, 2008 4:01 PM
`carlferrer1 S@gmail.com
`Fwd: Re: Fwd: Re: Backpage.com November Revenue Report
`
`Date: Sat, 22 Nov 2008 09:00:36 -0700
`From: "Dan Hyer" <Dan.Hyer@dallasobserver.com>
`To: "Carl Ferrer" <Carl.Ferrer@backpage.com>
`Subject: Re: Fwd: Re: Backpage.com November Revenue Report
`
`Wow - thanks for the nod!
`
`I'd
`I notice we were having a really good month. Did we let someone back in who was out?
`love to attribute that to Christina's aggregation efforts, but the ads she posted were free,
`so we haven't likely reaped the reward of her efforts.
`
`Thomas trained Bailey on Friday to do MBS aggregation, so she's an under the radar aggregator
`that will eventually become a bp.com employee.
`I think the females will have better success
`with MBS - if a male calls, they first think it's a client and are on guard.
`
`>>> Carl Ferrer 11/21/08 11:28 PM>>>
`fyi. ...
`
`I think in LA, we need to find the agencies and get them started with 25 posting credits.
`
`btw: the revenue wasn;t the great except for dallas. Most of the sites with banner ads are
`down or flat.
`
`earl
`
`>>> Carl Ferrer 11/21/2008 5:35 PM>>>
`Dallas sure gave us a nice bump. Hyer's done an awesome job with his marketing crew.
`
`Now, it's about building LA. It starts with improved content and Dan's on it.
`I want a strong west coast market.
`
`Carl
`
`>>> Jim Larkin <Jim.Larkin@VillageVoiceMedia.com> 11/21/2008 4:46 PM>>>
`Carl:
`
`Congratulations!!!!!!!!
`Another great month, you're leading the way for the whole WM enterprise onto the web!
`
`Larkin
`
`On Nov 21, 2008, at 3:51 PM, Jess Adams wrote:
`
`> Hello everyone - here is November's report.
`>
`> Highlights:
`>
`
`CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER-ATTORNEYS' EYES ONLY
`
`BACKPAGE00033590
`DOJ-BP-0004602604
`
`

`

`Case 2:18-cr-00422-DJH Document 1611-1 Filed 06/15/23 Page 10 of 10
`
`> Total Revenue $540K - record 4 week month Web Revenue - record 4 week
`> month, best month ever in terms of weekly/ 7 day average National
`> Revenue - record 4 week month Total ads 1,161,140 - record 4 week
`> month, best month ever in terms of weekly/ 7 day average Visits
`> 13,437,390 - record 4 week month, best month ever in terms of weekly/
`> 7 day average PageViews 221,405,718 - record 4 week month, best month
`> ever in terms of weekly/ 7 day average
`>
`> We had a 10.2 million page view day this past week (best day ever),
`> and we jumped 3.5 million page views per week across the network in
`> November over October.
`>
`> You are probably aware that Craigslist has begun charging for adult
`> postings in conjunction with a settlement reached with 40 state
`> attorney generals. This represents validation of our adult business
`> model (screening out underage posters, financial data for law
`> enforcement subpoenas, etc) and represents a tremendous growth
`> opportunity for Backpage.com -> when Craig was free, users were still
`> paying to post with us. Now the free competitor is gone ...
`>
`> Thank you,
`>
`>
`> Jess Adams
`> Accountant
`> Backpage.com
`> (602) 440-1125
`> <Backpage - November 2008 Revenue Report.xls>
`
`2
`
`CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER-ATTORNEYS' EYES ONLY
`
`BACKPAGE00033591
`DOJ-BP-0004602605
`
`