Case 2:18-cr-00422-DJH Document 1626-1 Filed 06/30/23 Page 1 of 3
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE DISTRICT OF ARIZONA
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`CR-18-422-PHX-DJH
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`PROPOSED STIPULATED JOINT
`STATEMENT OF THE CASE
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`United States of America,
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`Plaintiff,
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`v.
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`Michael Lacey, et al.,
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`Defendants.
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`United States’ Proposed Joint Statement of the Case
`Six individuals (Michael Lacey, James Larkin, Scott Spear, John “Jed” Brunst,
`Andrew Padilla, and Joye Vaught) (“Defendants”) have been charged with: (1) conspiracy
`to commit violations of the Travel Act by facilitating prostitution; and (2) violations of the
`Travel Act.
`Four of these Defendants, Michael Lacey, James Larkin, Scott Spear, John “Jed”
`Brunst, have also been charged with: (1) conspiracy to commit money laundering; (2)
`concealment money laundering; (3) intentional promotional money laundering; and (4)
`transactional money laundering.
`In addition, Defendant Michael Lacey has been charged with international
`concealment money laundering.
`The charges arise from the Defendants’ various roles in the creation, operation, and
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`Case 2:18-cr-00422-DJH Document 1626-1 Filed 06/30/23 Page 2 of 3
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`management of the website Backpage.com. Each Defendant has pleaded not guilty to the
`charges against him or her and are presumed innocent. The United States has the burden
`of proving an individual guilty beyond a reasonable doubt.
`Defendants’ Objections
`The government’s language inaccurately summarizes the alleged violation of the
`Travel Act. One cannot violate the Travel Act by generally “facilitating prostitution” (or
`conspiring to “facilitate prostitution”). Rather, someone must “travel in interstate or
`foreign commerce” or “use” a “facility interstate or foreign commerce, with intent to . . .
`promote, manage, establish, carry on, or facilitate the promotion, management,
`establishment, or carrying on, of a . . . business enterprise involving . . . prostitution
`offenses in violation of the laws of the State in which they are committed,” and “thereafter
`perform or attempt[] to perform” an act to “promote” or “facilitate.” 18 U.S.C.
`§ 1952(a)(3), (b)(i). Defendants’ proposed joint statement more accurately describes the
`charges and also provides some plain-english background to the case that may be helpful
`to prospective jurors.
`Defendants’ Proposed Joint Statement of the Case
`This is a criminal case brought by the United States government. Michael Lacey,
`James (Jim) Larkin, John (Jed) Brunst, Scott Spear, Andrew Padilla, and Joye Vaught are
`charged with various crimes related to their alleged roles in the creation, ownership,
`development, and management of the website Backpage.com. Each defendant has pleaded
`not guilty to all charges and is presumed innocent. The United States has the burden of
`proving an individual guilty beyond a reasonable doubt.
`Backpage.com was an online classified advertising website. The government
`alleges that the defendants, in their various roles related to the website, agreed to and did
`knowingly and intentionally facilitate specific business enterprises involving prostitution
`offenses. The defendants deny these allegations.
`The government alleges that defendants Lacey, Larkin, Brunst, and Spear also
`agreed to and did engage in various financial transactions designed to conceal or promote
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`Case 2:18-cr-00422-DJH Document 1626-1 Filed 06/30/23 Page 3 of 3
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`the conduct at Backpage.com that the government alleges was criminal. The defendants
`deny these allegations.
`Each defendant is charged in Count 1, Conspiracy to Violate the Travel Act and
`Counts 2-51, Violations of the Travel Act. Michael Lacey is charged in Counts 53-62,
`Concealment Money Laundering; Counts 63-68, International Promotional Money
`Laundering; Counts 69-70, 81, 83-84, 86, 88-92, and 94-99, Transactional Money
`Laundering; and Count 100, International Concealment Money Laundering. James Larkin
`is charged in Count 52, Conspiracy to Commit Money Laundering; Counts 53-62,
`Concealment Money Laundering; Counts 63-68, International Promotional Money
`Laundering; and Counts 80 and 87, Transactional Money Laundering.
`Scott Spear is charged in Count 52, Conspiracy to Commit Money Laundering;
`Counts 53-62, Concealment Money Laundering; Counts 63-68, International Promotional
`Money Laundering; and Counts 71-78, 85 and 93, Transactional Money Laundering.
`John “Jed” Brunst is charged in Count 52, Conspiracy to Commit Money
`Laundering; Counts 53-62, Concealment Money Laundering; Counts 63-68, International
`Promotional Money Laundering; and Counts 69-70, 78-84, and 86-93, Transactional
`Money Laundering.
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`United States’ Objections
`The United States wrote its proposed statement of the case so that it was consistent
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`with the joint statement in the proposed juror pre-screening questionnaire as requested by
`the Court. (Doc. 1524 at 5, n.3.) In addition to varying substantially from the joint
`statement in the proposed juror pre-screening questionnaire, Defendants’ statement is
`clunky and difficult to follow. Including all the Counts is unnecessary and will simply
`serve to confuse the jury. The United States’ proposed statement should be read.
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