1 APPEARANCES 3 FOR THE PLAINTIFFS: 4 JASON PAUL AMALA, ESQUIRE 5 VINCENT THOMAS NAPPO, ESQUIRE 6 PFAU COCHRAN VERTETIS AMALA, P.L.L.C.

Transcription

1 EXHIBIT 51

2 IN THE DISTRICT COURT DALLAS COUNTY, TEXAS 162ND JUDICIAL DISTRICT J.S., S.L., L.C. vs. Plaintiffs, VILLAGE VOICE MEDIA HOLDINGS, L.L.C., D/B/A BACKPAGE.COM; CAUSE NO. DC BACKPAGE.COM, L.L.C.; NEW TIMES MEDIA, L.L.C., D/B/A BACKPAGE.COM; AND BARUTI HOPSON Defendants. ATTORNEYS' EYES ONLY DEPOSITION OF ANDREW PADILLA TAKEN ON TUESDAY, DECEMBER 6, :25 P.M. PERKINS COIE 500 NORTH AKARD STREET, SUITE 3300 DALLAS, TEXAS Page 1 1 APPEARANCES CONTINUED 2 3 FOR THE DEFENDANTS: 4 HARRY H. SCHNEIDER, JR., ESQUIRE 5 PERKINS COIE, L.L.P THIRD AVENUE, SUITE SEATTLE, WASHINGTON (206) (206) Fax 10 HSCHNEIDER@PERKINSCOIE.COM; ELIZABETH L. MCDOUGALL, ESQUIRE 13 GENERAL COUNSEL 14 VILLAGE VOICE MEDIA HOLDINGS, L.L.C. 15 BACKPAGE.COM, L.L.C NE 65TH STREET, SUITE SEATTLE, WASHINGTON (214) LMCDOUGALL@Backpage.COM; Page 3 1 APPEARANCES 2 3 FOR THE PLAINTIFFS: 4 JASON PAUL AMALA, ESQUIRE 5 VINCENT THOMAS NAPPO, ESQUIRE 6 PFAU COCHRAN VERTETIS AMALA, P.L.L.C COLUMBIA STREET, SUITE SEATTLE, WASHINGTON (206) (206) (206) Fax 12 JASON@PCVALAW.COM; VNAPPO@PCVALAW.COM FOR THE PLAINTIFFS: 15 ERIK LOUIS BAUER, ESQUIRE 16 THE LAW OFFICE OF ERIK L. BAUER TACOMA AVE SOUTH 18 TACOMA, WASHINGTON (253) (253) Fax 21 ERIK@ERIKBAUERLAW.COM APPEARANCES CONTINUED 2 Page 2 3 FOR THE WITNESS: 4 SAM CROCKETT NEEL, ESQUIRE 5 MCDERMOTT WILL & EMERY 6 THE MCDERMOTT BUILDING NORTH CAPITOL STREET, NORTHWEST 8 WASHINGTON, DC (202) (202) Fax 11 SNEEL@MWE.COM Page 4 1 (Pages 1 to 4)

3 1 INDEX 2 Page 3 4 EXAMINATION BY MR. AMALA ATTORNEYS' EYES ONLY 2 DEPOSITION OF 3 ANDREW PADILLA 4 TAKEN ON 5 TUESDAY, DECEMBER 6, :25 P.M. 7 Page 5 8 THE VIDEOGRAPHER: We are on the record. 9 The time is 3: This is the beginning of the deposition of 11 Andrew Padilla. 12 Will Counsel introduce yourselves and 13 state whom you represent? 14 MR. NEEL: Sam Neel from the law firm of 15 McDermott Will & Emery, representing the witness, 16 Mr. Andrew Padilla. 17 MS. MCDOUGALL: Liz McDougall, general 18 Counsel for Backpage.com. 19 MR. SCHNEIDER: Harry Schneider on behalf 20 of the Backpage defendants. 21 MR. AMALA: Jason Amala on behalf of 22 plaintiffs. 23 MR. BAUER: Erik Bauer on behalf of 24 plaintiffs. 25 MR. NAPPO: Vincent Nappo on behalf of Page 7 1 EXHIBITS 2 Exhibit Page TASHA TEXT ME BACKPAGE.COM COURT PAPERS Page 6 1 plaintiffs. 2 THE VIDEOGRAPHER: The court reporter will 3 now swear in the witness. 4 THE REPORTER: Raise your right hand. 5 Do you solemnly swear to tell the truth, 6 the whole truth, and nothing but the truth, so help 7 you God? 8 THE WITNESS: Yes. 9 THE REPORTER: Thank you. 10 MR. ANDREW PADILLA, having been first duly sworn, 11 testified as follows: 12 EXAMINATION 13 Q. Could you please state and spell your full 14 name for the record? 15 A. Andrew Padilla; A-N-D-R-E-W, P-A-D-I-L-L Q. What city do you currently reside in? 18 A.. 19 Q. 20 A. Yeah. 21 Q. We reached an agreement before the 22 deposition that I wouldn't ask for your actual 23 address on the record today with the understanding 24 that if we ever need that, we'll be able to get that 25 from your Counsel. Page 8 2 (Pages 5 to 8)

4 1 MR. AMALA: Is that everyone's agreement? 2 MR. NEEL: Yes. 3 Q. (BY MR. AMALA) Do you have any plans to be 4 out of the country in May of next year? 5 A. No. 6 Q. What's your date of birth? 7 A. 8 Q. Are you currently employed? 9 A. On advice of Counsel, I decline to answer 10 the question and invoke my Fifth Amendment rights. 11 Q. Who is your current employer? 12 A. On advice of Counsel, I decline to answer 13 the question and invoke my Fifth Amendment rights. 14 Q. You currently work on a website called 15 Backpage.com, correct? 16 A. On advice of Counsel, I decline to answer 17 the question and invoke my Fifth Amendment rights. 18 Q. You are currently employed by 19 Backpage.com, correct? 20 A. On advice of Counsel, I decline to answer 21 the question and invoke my Fifth Amendment rights. 22 Q. Do you have any health conditions that 23 affect your memory? 24 A. No. 25 Q. Are you on any medications that affect 1 Q. How much is Mr. Neel being paid to 2 represent you? Page 9 3 A. On advice of Counsel, I decline to answer 4 the question and invoke my Fifth Amendment rights. 5 Q. Backpage.com is paying for Mr. Neel's 6 legal fees, correct? 7 A. On advice of Counsel, I decline to answer 8 the question and invoke my Fifth Amendment rights. 9 Q. Why is Backpage.com paying for Mr. Neel's 10 legal fees? 11 A. On advice of Counsel, I decline to answer 12 the question and invoke my Fifth Amendment rights. 13 Q. Do you have an agreement with anyone else 14 regarding the payment of Mr. Neel's legal fees? 15 A. On advice of Counsel, I decline to answer 16 the question and invoke my Fifth Amendment rights. 17 Q. Have you communicated with anyone other 18 than Mr. Neel about today's deposition? 19 A. On advice of Counsel, I decline to answer 20 the question and invoke my Fifth Amendment rights. 21 Q. Did you speak with legal Counsel for 22 Backpage.com, Liz McDougall, in order to prepare for 23 today's deposition? 24 A. On advice of Counsel, I decline to answer 25 the question and invoke my Fifth Amendment rights. 1 your memory? 2 A. No. 3 Q. Have you ever been arrested? 4 A. Yes. 5 Q. When were you arrested? 6 A. Not sure. 7 Q. When approximately do you believe you were 8 arrested? 9 A Q. Why were you arrested? 11 A. DUI. 12 Q. Any other arrests? 13 A. No. 14 Q. Are you represented -- are you represented 15 by legal Counsel at today's deposition? 16 A. Yes. 17 Q. Who is your attorney? 18 A. Sam Neel. 19 Q. When did you retain Mr. Neel? 20 A. On advice of Counsel, I decline to answer 21 the question and invoke my Fifth Amendment rights. 22 Q. Do you have an retainer agreement with Mr. 23 Neel? 24 A. On advice of Counsel, I decline to answer 25 the question and invoke my Fifth Amendment rights. 1 Q. Did you speak with Carl Ferrer in order to 2 prepare for today's deposition? Page 10 3 A. On advice of Counsel, I decline to answer 4 the question and invoke my Fifth Amendment rights. 5 Q. You spoke with Mr. Ferrer to prepare for 6 today's deposition, correct? 7 A. On advice of Counsel, I decline to answer 8 the question and invoke my Fifth Amendment rights. 9 Q. You and Mr. Ferrer discussed the testimony 10 that you anticipate giving at today's deposition, 11 correct? 12 A. On advice of Counsel, I decline to answer 13 the question and invoke my Fifth Amendment rights. 14 Q. Where were you born? 15 A. 16 Q. Where did you grow up? 17 A. 18 Q. Did you go to high school? 19 A. Yes. 20 Q. Where did you go to high school? 21 A. 22 Q. Did you graduate? 23 A. No. 24 Q. No? 25 A. (Shakes head negatively). Page 11 Page 12 3 (Pages 9 to 12)

5 1 Q. Can you give me a thumbnail sketch of your 2 employment history? 3 A. I worked construction for 13 years. 4 Q. After leaving high school? 5 A. Yeah. 6 Q. All right. What's your date of birth? 7 MR. SCHNEIDER: 8 A.. MR. SCHNEIDER:? 9 THE WITNESS: Yeah. 10 MR. SCHNEIDER: Thanks. 11 MR. AMALA: You don't know how happy that 12 makes me that he got that wrong. 13 MR. SCHNEIDER: I was just testing the 14 witness. 15 Q. (BY MR. AMALA) What did you do for work 16 after the 13 years that you spent doing construction 17 work? 18 A. On advice of Counsel, I decline to answer 19 the question and invoke my Fifth Amendment rights. 20 Q. Ever get a chance to get your GED? 21 MR. NEEL: Object to form of the question. 22 Q. (BY MR. AMALA) Go ahead. 23 A. Yeah, I got a chance. 24 Q. Did you ever get your GED? 25 A. No. Page 13 1 Q. Who issued your paychecks during the time 2 that you worked on Backpage.com? 3 A. On advice of Counsel, I decline to answer 4 the question and invoke my Fifth Amendment rights. 5 Q. How have you been paid for your work on 6 Backpage.com? 7 A. On advice of Counsel, I decline to answer 8 the question and invoke my Fifth Amendment rights. 9 Q. You've received profits from the operation 10 of Backpage.com, correct? 11 A. On advice of Counsel, I decline to answer 12 the question and invoke my Fifth Amendment rights. 13 Q. You've received profits for ads that are 14 posted in the escort section of Backpage.com, 15 correct? 16 A. On advice of Counsel, I decline to answer 17 the question and invoke my Fifth Amendment rights. 18 Q. How much have you earned from working on 19 Backpage.com? 20 A. On advice of Counsel, I decline to answer 21 the question and invoke my Fifth Amendment rights. 22 Q. What positions have you held with 23 Backpage.com? 24 A. On advice of Counsel, I decline to answer 25 the question and invoke my Fifth Amendment rights. 1 Q. Can you give me a thumbnail sketch of your 2 employment history after stopping the construction 3 work you did after high school? 4 A. On advice of Counsel, I decline to answer 5 the question and invoke my Fifth Amendment rights. 6 Q. Have you ever worked on a website called 7 Backpage.com? 8 A. On advice of Counsel, I decline to answer 9 the question and invoke my Fifth Amendment rights. 10 Q. How did you come to work for a website 11 called Backpage.com? 12 A. On advice of Counsel, I decline to answer 13 the question and invoke my Fifth Amendment rights. 14 Q. How did you first learn about a position 15 with Backpage.com? 16 A. On advice of Counsel, I decline to answer 17 the question and invoke my Fifth Amendment rights. 18 Q. You were hired to help promote sex 19 trafficking on Backpage.com, correct? 20 A. On advice of Counsel, I decline to answer 21 the question and invoke my Fifth Amendment rights. 22 Q. Who was your employer during the time that 23 you've worked on Backpage.com? 24 A. On advice of Counsel, I decline to answer 25 the question and invoke my Fifth Amendment rights. 1 Q. What were your job responsibility -- 2 strike that. 3 What have been your job responsibilities 4 in each of the positions that you've held with 5 Backpage.com? 6 A. I decline to answer; pursuant to the Fifth 8 Q. When you first started working at Page 14 9 Backpage.com, did you receive any sort of training? 10 A. I decline to answer pursuant to the Fifth 11 Amendment. 12 Q. When you were first hired to work at 13 Backpage.com, you were told by the company that one 14 of your jobs was to promote sex trafficking on the 15 website, correct? 18 Q. When you first started working on 19 Backpage.com, you were told that the company derived 20 nearly -- nearly all of its profits from sex 21 trafficking in the escort section of the website, 22 correct? 23 A. I decline to answer pursuant to the Fifth 24 Amendment. 25 Q. Who have been your supervisors while Page 15 Page 16 4 (Pages 13 to 16)

6 1 you've worked on Backpage.com? 4 Q. Who have you supervised during the time 5 that you've worked on Backpage.com? 8 Q. During the time that you've worked at 9 Backpage.com, you had control over the content of 10 ads that were posted in the escort section of the 11 website, correct? Q. During the time that you've worked at 15 Backpage.com, you helped to set the policies and 16 procedures regarding advertisements that are posted 17 in the escort section of the website, correct? Q. What is your knowledge of allegations of 21 the plaintiffs in this case? Q. You understand that the plaintiffs were 25 advertised for sex in the escort section of Page 17 1 Q. You support allowing sex traffickers to 2 market children for prostitution, correct? 3 A. I decline to answer pursuant to the Fifth 4 Amendment. 5 Q. Do you know how the website Backpage.com 6 came into existence? 7 A. I decline to answer pursuant to the Fifth 8 Amendment. 9 Q. How did Backpage.com come into existence? 10 A. I decline to answer pursuant to the Fifth 11 Amendment. 12 Q. Do you know who started the website 13 Backpage.com? 14 A. I decline to answer pursuant to the Fifth 15 Amendment. 16 Q. You understand that Backpage.com was 17 created in order to profit from sex trafficking, 18 correct? 21 Q. You've personally shared in the profits 22 from sex trafficking that has occurred on 23 Backpage.com from 2009 to present, correct? Page 19 1 Backpage.com in 2010, correct? 4 Q. You understand that the plaintiffs are 5 suing Backpage.com for the sexual abuse and 6 exploitation that they suffered as a result of being 7 advertised for sex in the escort section of 8 Backpage.com, correct? 9 A. I decline to answer pursuant to the Fifth 10 Amendment. 11 Q. And you support adult prostitution, 12 correct? 13 A. I decline to answer pursuant to the Fifth 14 Amendment. 15 Q. You support allowing sex traffickers to 16 profit from marketing prostitutes, correct? 17 A. I decline to answer pursuant to the Fifth 18 Amendment. 19 Q. Okay. You support what's commonly known 20 as pimping, correct? 21 A. I decline to answer pursuant to the Fifth 22 Amendment. 23 Q. You support child prostitution, correct? Page 18 1 Q. You have caused profits from the operation 2 of Backpage.com to be transferred out of the United 3 States, correct? 4 A. I decline to answer pursuant to the Fifth 5 Amendment. 6 Q. You've caused profits from the operation 7 of Backpage.com to be transferred out of the United 8 States in order to conceal those profits from the 9 United States government, correct? 10 A. I decline to answer pursuant to the Fifth 11 Amendment. 12 Q. You've caused profits from the operation 13 of Backpage.com to be transferred out of the United 14 States in order to conceal the profits from law 15 enforcement, correct? 18 Q. You have caused profits from the operation 19 of Backpage.com to be transferred out of the United 20 States in order to conceal the profits from the 21 plaintiffs in this lawsuit, correct? Q. You've caused profits from the operation 25 of Backpage.com to be transferred out of the United Page 20 5 (Pages 17 to 20)

7 1 States in order to conceal the profits from the 2 plaintiff -- plaintiffs in this lawsuit in the event 3 they are successful and obtain a judgment against 4 the company, correct? 5 A. I decline to answer pursuant to the Fifth 6 Amendment. 7 Q. All right. You have solest -- strike 8 that. 9 You have solicited women for sex, correct? 10 A. I decline to answer pursuant to the Fifth 11 Amendment. 12 Q. You've solicited women for paid sex, 13 correct? 14 A. I decline to answer pursuant to the Fifth 15 Amendment. 16 Q. You have contacted women for paid sex 17 through advertisements on Backpage.com, correct? Q. You did that in 2009, correct? 21 A. I decline to answer pursuant to the Fifth 22 Amendment. 23 Q. You did that in 2010, correct? Page 21 1 Backpage.com, you told her that one of her jobs was 2 to help promote sex trafficking in the escort 3 section of Backpage.com, correct? 4 A. I decline to answer pursuant to the Fifth 5 Amendment. 6 Q. You have paid women for sex after 7 contacting them through an advertisement on 8 Backpage.com, by giving them free ads on 9 Backpage.com, correct? 10 A. I decline to answer pursuant to the Fifth 11 Amendment. 12 Q. You did that in 2009, correct? 13 A. I decline to answer pursuant to the Fifth 14 Amendment. 15 Q. And you did that in 2010, correct? 18 Q. You've paid a woman for sex after 19 contacting her through an advertisement on 20 Backpage.com, by giving her pimp free ads on the 21 website, correct? Q. You did that in 2009, correct? Page 23 1 Q. 2009, you understood that customers of 2 Backpage.com were arranging to have sex with 3 children through advertisements in the escort 4 section of Backpage.com, correct? 5 MR. NEEL: Object -- it's objection to the 6 form; calls for speculation. 7 Q. (BY MR. AMALA) Go ahead. 10 Q. All right. You have paid a woman for sex 11 after contacting her through an advertisement for 12 paid sex on Backpage.com, correct? 13 A. I decline to answer pursuant to the Fifth 14 Amendment. 15 Q. You did that in 2009, correct? 18 Q. And you did that in 2010, correct? 21 Q. You helped hire to work for 22 Backpage.com, correct? 23 A. I decline to answer pursuant to the Fifth 24 Amendment. 25 Q. And you hired to work for 1 Amendment. 2 Q. And you did that in 2010, correct? 3 A. I decline to answer pursuant to the Fifth 4 Amendment. 5 Q. You saw each of the ads for the plaintiffs 6 in this lawsuit before they appeared on 7 Backpage.com, correct? 8 MR. NEEL: Objection, form of the 9 question; and calls for speculation. 10 Q. (BY MR. AMALA) Go ahead. Page Q. One or more moderators of Backpage.com saw 14 each of the ads for each of the plaintiffs before 15 they were posted on Backpage.com, correct? 16 MR. NEEL: Same objection. 17 A. I decline to answer pursuant to the Fifth 18 Amendment. 19 Q. (BY MR. AMALA) You I edited the content of 20 the advertisements of each of the plaintiffs before 21 the advertisements were posted on Backpage.com, 22 correct? 23 MR. NEEL: Same objection. Page 24 6 (Pages 21 to 24)

8 1 Q. (BY MR. AMALA) You helped sanitize each of 2 the ads of the plaintiffs to make it less obvious 3 that the ads were for sex before the ads were posted 4 on Backpage.com, correct? 5 MR. NEEL: Same objection. 8 Q. (BY MR. AMALA) One or more moderators at 9 Backpage.com edited the content of the ads of each 10 plaintiff before they were posted on Backpage.com, 11 correct? 12 MR. NEEL: Same objection. 13 A. I decline to answer pursuant to the Fifth 14 Amendment. 15 Q. (BY MR. AMALA) And one or more moderators 16 edited the ads to make it so the ads appeared less 17 obvious for sex for money, correct? 18 MR. NEEL: Same objection. 21 Q. (BY MR. AMALA) At the time each of the 22 plaintiffs was advertised for sex in the escort 23 section of Backpage.com, you understood that each 24 plaintiff was an underage girl, correct? 25 MR. NEEL: Same objection. 1 correct? 2 MR. NEEL: Same objection. 3 A. I decline to answer pursuant to the Fifth 4 Amendment. Page 25 5 Q. (BY MR. AMALA) The moderators took no 6 steps to prevent those ads from being posted because 7 they wanted to help the company continue to profit 8 from the ads, correct? 9 MR. NEEL: Same objection. 10 A. I decline to answer pursuant to the Fifth 11 Amendment. 12 MR. AMALA: Guess we're on 5? 13 THE REPORTER: Yes. 14 MR. NEEL: Thank you. 15 (Deposition Exhibit 5 marked) 16 Q. (BY MR. AMALA) Mr. Padilla, I've handed 17 you what's been marked as Exhibit You understand that Exhibit 5 is a copy of 19 the subpoena that required your attendance at 20 today's deposition? 21 A. Yeah. 22 Q. Did you bring any documents with you in 23 response to this subpoena? 24 A. No. 25 Q. Do you possess any documents that are Page 27 1 A. I decline to answer pursuant to the Fifth 2 Amendment. 3 Q. (BY MR. AMALA) And the moderators who 4 reviewed those ads before they were posted on the 5 website, knew that the girls were underage, correct? 6 MR. NEEL: Same objection. 7 A. I decline to answer pursuant to the Fifth 8 Amendment. 9 Q. (BY MR. AMALA) At the time each plaintiff 10 was advertised for sex on Backpage.com, you knew 11 that the persons who were posting the ads were sex 12 traffickers, correct? 13 MR. NEEL: Same objection. 14 A. I decline to answer pursuant to the Fifth 15 Amendment. 16 Q. (BY MR. AMALA) And the moderators, who 17 reviewed the ads, knew that the users who were 18 posting the ads were sex traffickers, correct? 19 MR. NEEL: Same objection. 20 A. I decline to answer pursuant to the Fifth 21 Amendment. 22 Q. (BY MR. AMALA) You made no effort to 23 prevent those people from posting ads for sex for 24 each of the plaintiffs because you wanted to 25 continue to profit from such advertisements, 1 responsive to this subpoena? Page 26 4 Q. (BY MR. AMALA) Mr. Padilla, I'd like to 5 hand you what's been marked as Exhibit 1. 6 Please take a moment to review Exhibit 1, 7 and let me know when you're finished. 8 A. I'm finished. 9 Q. All right. Mr. Padilla, Exhibit 1 is a 10 copy of an advertisement for sex that was posted in 11 the escort section of Backpage.com regarding 12 Plaintiff L.C., correct? 13 A. I decline to answer pursuant to the Fifth 14 Amendment. 15 Q. In 2010, Backpage.com contracted with one 16 or more sex traffickers to advertise Plaintiff L.C. 17 for sex on the website, correct? 18 MR. NEEL: Objection, form of the 19 question; calls for speculation. 20 A. I decline to answer pursuant to the Fifth 21 Amendment. 22 Q. (BY MR. AMALA) Mr. Padilla, do you know 23 whether or not Backpage.com in 2010, contracted with 24 one or more sex traffickers to advertise Plaintiff 25 L.C. for sex in the escort section of Backpage.com? Page 28 7 (Pages 25 to 28)

9 1 A. I decline to answer pursuant to the Fifth 2 Amendment. 3 Q. At the time that this advertisement that 4 is Exhibit 1 regarding Plaintiff L.C. was posted on 5 Backpage.com, you knew that this was an ad for paid 6 sex because it included the terms "cum" spelled, C- 7 U-M, and "quickie," Q-U-I-C-K-I-E, correct? 8 MR. NEEL: Same objection. 9 A. I decline to answer pursuant to the Fifth 10 Amendment. 11 Q. (BY MR. AMALA) And the moderator who 12 reviewed this ad would have removed those terms to 13 make it less obvious that the ad was for sex, 14 correct? 15 MR. NEEL: Same objection. 18 Q. (BY MR. AMALA) The moderator would have 19 then posted this ad without those terms in order to 20 conceal the fact that this was actually an 21 advertisement for sex, correct? 22 MR. NEEL: Same objection. 23 A. I decline to answer pursuant to the Fifth 24 Amendment. 25 Q. (BY MR. AMALA) Those changes were made to Page 29 1 MR. NEEL: Same objection. 4 Q. (BY MR. AMALA) The fact that Plaintiff 5 L.C. was a minor was obvious from the pictures that 6 were included with her ad, correct? 7 MR. NEEL: Same objection. 10 Q. (BY MR. AMALA) At the time that Plaintiff 11 L.C. was advertised for sex in the escort section 12 Backpage.com, you knew that the people who were 13 posting ads regarding L.C. were sex traffickers, 14 correct? 15 MR. NEEL: Same objection. 18 Q. (BY MR. AMALA) Management of Backpage.com 19 knew that as well, correct? 20 MR. NEEL: Same objection. 21 A. I decline to answer pursuant to the Fifth 22 Amendment. 23 Q. (BY MR. AMALA) The moderators who reviewed 24 her ads knew that as well, correct? 25 MR. NEEL: Same objection. 1 this ad to help the sex trafficker who posted the ad 2 avoid law enforcement, correct? 3 MR. NEEL: Same objection. 4 A. I decline to answer pursuant to the Fifth 5 Amendment. 6 Q. (BY MR. AMALA) And that was important to 7 Backpage.com because it wanted to continue to profit 8 from ads like this, correct? 9 MR. NEEL: Same objection. 10 A. I decline to answer pursuant to the Fifth 11 Amendment. 12 Q. (BY MR. AMALA) At the time this 13 advertisement regarding Plaintiff L.C. was posted in 14 the escort section of Backpage.com, you knew that 15 L.C. was a minor, correct? 16 MR. NEEL: Same objection. 17 A. I decline to answer pursuant to the Fifth 18 Amendment. 19 Q. (BY MR. AMALA) The management at 20 Backpage.com knew that as well, correct? 21 MR. NEEL: Same objection Q. (BY MR. AMALA) And the moderator who 25 reviewed the ad knew that as well, correct? 1 A. I decline to answer pursuant to the Fifth 2 Amendment. 3 Q. (BY MR. AMALA) At the time that L.C. was 4 advertised for sex on Backpage.com, you knew that 5 L.C. was more likely than not being forced to have Page 30 6 sex with dozens of men because of the ads that were 7 being posted about her on Backpage.com, correct? 8 MR. NEEL: Same objection. 9 A. I decline to answer pursuant to the Fifth 10 Amendment. 11 Q. (BY MR. AMALA) And the management of 12 Backpage.com knew that as well, correct? 13 MR. NEEL: Same objection. 14 A. I decline to answer pursuant to the Fifth 15 Amendment. 16 Q. (BY MR. AMALA) The moderators who reviewed 17 her ads knew that as well, correct? 18 MR. NEEL: Same objection. 21 Q. (BY MR. AMALA) You didn't take any steps 22 to prevent Plaintiff L.C. from being advertised for 23 sex on Backpage.com, correct? 24 MR. NEEL: Same objection. Page 31 Page 32 8 (Pages 29 to 32)

10 1 Amendment. 2 Q. (BY MR. AMALA) Nobody from Backpage.com 3 took any steps to prevent L.C. from being advertised 4 for sex on Backpage.com, correct? 5 MR. NEEL: Same objection. 8 Q. (BY MR. AMALA) All right. You personally 9 profited from the sex advertisements that were 10 posted in the escort section regarding Plaintiff 11 L.C., correct? 12 MR. NEEL: Same objection. 13 A. I decline to answer pursuant to the Fifth 14 Amendment. 15 Q. (BY MR. AMALA) And Backpage profited from 16 each of those advertisements, correct? 17 MR. NEEL: Same objection Q. (BY MR. AMALA) As of January 2010, you 21 knew that children were being trafficked for sex in 22 the escort section of Backpage.com, correct? 23 MR. NEEL: Same objection. Page 33 1 Q. And you discussed that with the management 2 of Backpage.com, correct? 3 MR. NEEL: Same objection. 4 A. I decline to answer pursuant to the Fifth 5 Amendment. 6 Q. (BY MR. AMALA) Throughout 2010, you didn't 7 take any steps to prevent children from being 8 trafficked for sex in the escort section of 9 Backpage.com, correct? 10 MR. NEEL: Same objection. 13 Q. (BY MR. AMALA) Management of Backpage.com 14 took no steps to prevent children from being 15 trafficked for sex on the website, correct? 16 MR. NEEL: Same objection. 17 A. I decline to answer pursuant to the Fifth 18 Amendment. 19 Q. (BY MR. AMALA) Throughout 2010, you 20 allowed the same advertisements of children to be 21 posted in the escort section of Backpage.com, even 22 after you received complaints that the 23 advertisements were of children, correct? 24 MR. NEEL: Same objection. Page 35 1 Q. (BY MR. AMALA) Okay. And you discussed 2 that with the management at Backpage.com, correct? 3 MR. NEEL: Same objection. 4 A. I decline to answer pursuant to the Fifth 5 Amendment. 6 Q. (BY MR. AMALA) As of January 2010, you 7 knew that children were being trafficked for sex in 8 the escort section of Backpage.com, were likely to 9 suffer severe emotional distress as a result of 10 being advertised for sex on the website, correct? 11 MR. NEEL: Same objection Q. (BY MR. AMALA) And you discussed that with 15 the management of Backpage.com, correct? 16 MR. NEEL: Same objection. 17 A. I decline to answer pursuant to the Fifth 18 Amendment. 19 Q. (BY MR. AMALA) You also knew that those 20 children would suffer severe emotional distress as a 21 result of being forced to have sex with dozens of 22 men, correct? 23 MR. NEEL: Same objection. Page 34 1 Amendment. 2 Q. (BY MR. AMALA) Throughout the time that 3 you've worked with Backpage.com, one of your goals 4 was for the website to be the largest source of 5 online sex trafficking in the United States, 6 correct? 7 A. I decline to answer pursuant to the Fifth 8 Amendment. 9 Q. You discussed that goal with management, 10 correct? 13 Q. That was one of management's goals before , correct? 15 MR. NEEL: Same objection. 18 Q. (BY MR. AMALA) And that has been one of 19 management's goals since 2010, correct? 20 MR. NEEL: Same objection. 21 A. I decline to answer pursuant to the Fifth 22 Amendment. 23 Q. (BY MR. AMALA) Since the adult services 24 section of Craigslist was shut down, you've known 25 that Backpage.com is the largest source of online Page 36 9 (Pages 33 to 36)

11 1 sex trafficking in the United States, correct? 2 MR. NEEL: Same objection. 3 A. I decline to answer pursuant to the Fifth 4 Amendment. 5 Q. (BY MR. AMALA) You've discussed that with 6 Carl Ferrer, correct? 7 MR. NEEL: Same objection. 10 Q. (BY MR. AMALA) You discussed that with 11 other managers of Backpage.com, correct? 12 MR. NEEL: Same objection. 13 A. I decline to answer pursuant to the Fifth 14 Amendment. 15 Q. (BY MR. AMALA) Throughout 2010, you were 16 responsible for setting the policies and procedures 17 that were followed by moderators who reviewed and 18 revised ads that were posted in the escort section 19 of Backpage.com, correct? 20 A. I decline to answer pursuant to the Fifth 21 Amendment. 22 Q. And you helped supervise those moderators, 23 correct? 1 A. I decline to answer pursuant to the Fifth 2 Amendment. 3 Q. Do you understand what the purpose of 4 those posting rules was? 5 A. I decline to answer pursuant to the Fifth 6 Amendment. 7 Q. Do you understand that one of the goals of 8 the posting rules was to help sex traffickers avoid 9 prosecution by law enforcement? 10 A. I decline to answer pursuant to the Fifth 11 Amendment. 12 Q. Did you discuss with Carl Ferrer that was 13 one of the goals of the posting rules? 14 A. I decline to answer pursuant to the Fifth 15 Amendment. 16 Q. Did you discuss with other managers that 17 that was one of the goals of the posting rules? 1 1 Page Q. Are you familiar with the content 21 requirements that were implemented in 2010 regarding 22 ads posted on Backpage.com in the escort section? 23 A. I decline to answer pursuant to the Fifth 24 Amendment. 25 Q. Did you ever -- do you have any Page 39 1 Q. Throughout the time that you've worked at 2 Backpage.com, you understood that the goal of the 3 company was to create an online marketplace for sex 4 trafficking, correct? 5 MR. NEEL: Same objection. 8 Q. (BY MR. AMALA) You've discussed that goal 9 with Mr. Ferrer, correct? 10 MR. NEEL: Same objection. 13 Q. (BY MR. AMALA) You've discussed that goal 14 with other managers at the company, correct? 15 MR. NEEL: Same objection. 18 Q. (BY MR. AMALA) Are you familiar with the 19 posting rules that were implemented in 2010 for ads 20 posted in the escort section of Backpage.com? 21 A. I decline to answer pursuant to the Fifth 22 Amendment. 23 Q. Are you familiar with the posting rules 24 that governed ads posted in the escort section of 25 Backpage.com in 2010? Page 38 1 understanding as to the purpose of those content 2 requirements? 3 A. I decline to answer pursuant to the Fifth 4 Amendment. 5 Q. Do you understand that one of the purposes 6 of the content requirements was to help sex 7 traffickers avoid prosecution by law enforcement? 10 Q. Do you understand that one of the purposes 11 of the posting rules that were implemented in was to give sex traffickers plausible deniability of 13 the fact that their ads were for sex? 14 MR. NEEL: Objection, same objection. 15 A. I decline to answer pursuant to the Fifth 16 Amendment. 17 Q. (BY MR. AMALA) Did you discuss that with 18 Carl Ferrer? 19 MR. NEEL: Same objection. 20 A. I decline to answer pursuant to the Fifth 21 Amendment. 22 Q. (BY MR. AMALA) Did you discuss that with 23 other managers of Backpage.com? 24 MR. NEEL: Same objection. Page (Pages 37 to 40)

12 1 Amendment. 2 Q. (BY MR. AMALA) Do you understand that one 3 of the purposes of the content requirements that 4 were implemented in 2010 for ads posted in the 5 escort section of Backpage.com was to give sex 6 traffickers plausible deniability that the ads 7 posted in that section by them were for sex? 8 MR. NEEL: Same objection. 9 A. I decline to answer pursuant to the Fifth 10 Amendment. 11 Q. (BY MR. AMALA) Did you discuss that 12 purpose with Carl Ferrer? 13 MR. NEEL: Same objection. 14 A. I decline to answer pursuant to the Fifth 15 Amendment. 16 Q. (BY MR. AMALA) Did you discuss that 17 purpose with other managers of the company? 18 MR. NEEL: Same objection. 21 Q. (BY MR. AMALA) Before and during the time 22 that the plaintiffs were advertised for sex on 23 Backpage.com, you were helping to develop the comp the website's reputation as a website for sex 25 trafficking, correct? 1 the other managers of Backpage.com, correct? 2 MR. NEEL: Same objection. 3 A. I decline to answer pursuant to the Fifth 4 Amendment. Page 41 5 Q. (BY MR. AMALA) Do you know how much money 6 Backpage.com generated in profit from illegal sex 7 trafficking in 2008? 8 MR. NEEL: Same objection. 9 A. I decline to answer pursuant to the Fifth 10 Amendment. 11 Q. (BY MR. AMALA) Do you know how much money 12 Backpage.com generated in profit from illegal sex 13 trafficking in 2009? 14 MR. NEEL: Same objection. 15 A. I decline to answer pursuant to the Fifth 16 Amendment. 17 Q. (BY MR. AMALA) Do you know how much money 18 Backpage.com generated in profit from illegal sex 19 trafficking in 2010? 20 MR. NEEL: Same objection. 21 A. I decline to answer pursuant to the Fifth 22 Amendment. 23 Q. (BY MR. AMALA) Do you know how much money 24 Backpage.com has generated in profit from illegal 25 sex trafficking from 2011 through present? Page 43 1 A. I decline to answer pursuant to the Fifth 2 Amendment. 3 Q. And you discussed with Carl Ferrer how you 4 could help shape the website's reputation as a 5 website for sex trafficking, correct? 8 Q. You discussed that with other managers at 9 Backpage.com, correct? 10 A. I decline to answer pursuant to the Fifth 11 Amendment. 12 Q. Before and during the time that the 13 plaintiffs were advertised for sex in the escort 14 section of Backpage.com, you knew that virtually 15 every advertisement in the escort section was an 16 advertisement for illegal sex, correct? 17 MR. NEEL: Same objection Q. (BY MR. AMALA) You discussed that with Mr. 21 Ferrer, correct? 22 MR. NEEL: Same objection. 23 A. I decline to answer pursuant to the Fifth 24 Amendment. 25 Q. (BY MR. AMALA) And you discussed that with Page 42 1 MR. NEEL: Same objection. 4 Q. (BY MR. AMALA) In 2008 Backpage.com 5 generated millions of dollars in profit from illegal 6 sex trafficking, correct? 7 MR. NEEL: Same objection. 10 Q. (BY MR. AMALA) Those profits increased in , correct? 12 MR. NEEL: Same objection. 13 A. I decline to answer pursuant to the Fifth 14 Amendment. 15 Q. (BY MR. AMALA) And those profits from 16 illegal sex trafficking increased even more in 2010, 17 correct? 18 MR. NEEL: Same objection. 21 Q. (BY MR. AMALA) In 2008 you, personally, 22 profited from illegal sex trafficking in the escort 23 section of Backpage.com, correct? 24 MR. NEEL: Same objection. Page (Pages 41 to 44)

13 1 Amendment. 2 Q. (BY MR. AMALA) And the profits that you 3 earned increased in 2009, correct? 4 MR. NEEL: Same objection. 5 A. I decline to answer pursuant to the Fifth 6 Amendment. 7 Q. (BY MR. AMALA) The profits that you earned 8 as a result of illegal sex trafficking on 9 Backpage.com increased even more in 2010, correct? 10 MR. NEEL: Same objection. 13 Q. (BY MR. AMALA) As of January 2010, you 14 knew that Backpage.com was, in fact, the largest 15 source of sex trafficking in the United States, 16 correct? 17 MR. NEEL: Same objection Q. (BY MR. AMALA) In that time, you also knew 21 that more than 99 percent of the advertisements in 22 the escort section of Backpage.com were ads for 23 illegal sex, correct? 24 MR. NEEL: Same objection. 1 other managers at Backpage.com, correct? 2 MR. NEEL: Same objection. 3 A. I decline to answer pursuant to the Fifth 4 Amendment. Page 45 5 Q. (BY MR. AMALA) And you discussed that with 6 the moderators who reviewed the ads that were being 7 posted to the escort section of Backpage.com, 8 correct? 9 MR. NEEL: Same objection. 10 A. I decline to answer pursuant to the Fifth 11 Amendment. 12 Q. (BY MR. AMALA) Throughout 2010, you knew 13 that Backpage.com was generating significant amounts 14 of profit from children who were being advertised 15 for sex in the escort section of the website, 16 correct? 17 MR. NEEL: Same objection Q. (BY MR. AMALA) You discussed that with 21 Carl Ferrer, correct? 22 MR. NEEL: Same objection. 23 A. I decline to answer pursuant to the Fifth 24 Amendment. 25 Q. (BY MR. AMALA) You discussed that with 1 Amendment. 2 Q. (BY MR. AMALA) Throughout 2010, you knew 3 that children were being advertised for sex in the 4 escort section of Backpage.com, correct? 5 MR. NEEL: Same objection. 8 Q. (BY MR. AMALA) Do you know whether as of , children were being advertised for sex in the 10 escort section of Backpage.com? 11 MR. NEEL: Same objection Q. Throughout 2010, you knew that hundreds of 15 children were being advertised for sex each day in 16 the escort section of Backpage.com, correct? 17 MR. NEEL: Same objection Q. (BY MR. AMALA) And you discussed that with 21 Carl Ferrer, correct? 22 MR. NEEL: Same objection. 23 A. I decline to answer pursuant to the Fifth 24 Amendment. 25 Q. (BY MR. AMALA) You discussed that with 1 Joye Vaught, correct? 2 MR. NEEL: Same objection. 3 A. I decline to answer pursuant to the Fifth 4 Amendment. Page 46 5 Q. (BY MR. AMALA) And you discussed that with 6 the other managers of Backpage.com, correct? 7 MR. NEEL: Same objection. 10 Q. (BY MR. AMALA) As of January 2010, you 11 knew that Backpage.com could reduce the number of 12 children who were being trafficked for sex on the 13 website, if it required photo identification for ads 14 posted in the escort section, correct? 15 MR. NEEL: Same objection. 18 Q. (BY MR. AMALA) You discussed that with 19 Carl Ferrer, correct? 20 MR. NEEL: Same objection. 21 A. I decline to answer pursuant to the Fifth 22 Amendment. 23 Q. (BY MR. AMALA) You discussed that with 24 as well, correct? 25 MR. NEEL: Same objection. Page 47 Page (Pages 45 to 48)

14 1 A. I decline to answer pursuant to the Fifth 2 Amendment. 3 Q. (BY MR. AMALA) And you discussed that with 4 the other managers at Backpage.com, correct? 5 MR. NEEL: Same objection. 8 Q. (BY MR. AMALA) As of January 2010, you 9 knew that Backpage.com could reduce the number of 10 children being trafficked for sex on the website, if 11 it required photo identification for ads posted in 12 the escort section but you chose not to require 13 photo identification because you wanted to continue 14 profiting off of ads for children sex, correct? 15 MR. NEEL: Same objection. 18 Q. (BY MR. AMALA) And you discussed that with 19 Carl Ferrer, correct? 20 MR. NEEL: Same objection. 21 A. I decline to answer pursuant to the Fifth 22 Amendment. 23 Q. (BY MR. AMALA) You also discussed that 24 with 25 MR. NEEL: Same objection. Page 49 1 Q. As of January 2010, you knew that 2 requiring users to click a button, indicating they 3 were 18 or older, did nothing to meaningfully 4 prevent children from being advertised for sex in 5 the escort section of Backpage.com, correct? 6 MR. NEEL: Same objection. 7 A. I decline to answer pursuant to the Fifth 8 Amendment. 9 Q. (BY MR. AMALA) You discussed that with Mr. 10 Ferrer, correct? 11 MR. NEEL: Same objection Q. You discussed that with 15 MR. NEEL: Same objection. 18 Q. (BY MR. AMALA) And you discussed that with 19 the other managers, correct? 20 MR. NEEL: Same objection. 21 A. I decline to answer pursuant to the Fifth 22 Amendment. 23 Q. (BY MR. AMALA) Throughout 2010, you knew 24 that children were in high demand in the illegal 25 marketplace for sex trafficking that was occurring 1 A. I decline to answer pursuant to the Fifth 2 Amendment. 3 Q. (BY MR. AMALA) And you discussed that with 4 the other managers at Backpage.com? 5 MR. NEEL: Same objection. 8 Q. (BY MR. AMALA) As of January 2010, you 9 knew that Backpage.com was the doing virtually 10 nothing to meaningfully verify the age of the people 11 who were the subject of advertisements in the escort 12 section of the website, correct? 13 MR. NEEL: Same objection. 14 A. I decline to answer pursuant to the Fifth 15 Amendment. 16 Q. (BY MR. AMALA) You discussed that with 17 Carl Ferrer, correct? 18 MR. NEEL: Same objection. 21 Q. (BY MR. AMALA) And you discussed that with 22 the other managers of Backpage.com, correct? 23 MR. NEEL: Same objection. 1 in the escort section of Backpage.com, correct? 2 MR. NEEL: Same objection. 3 A. I decline to answer pursuant to the Fifth 4 Amendment. 5 Q. (BY MR. AMALA) You discussed that high 6 demand with Carl Ferrer, correct? 7 MR. NEEL: Same objection. Page Q. (BY MR. AMALA) And you discussed that high 11 demand with correct? 12 MR. NEEL: Same objection. 13 A. I decline to answer pursuant to the Fifth 14 Amendment. 15 Q. (BY MR. AMALA) And you discussed that high 16 demand with the other managers of Backpage.com, 17 correct? 18 MR. NEEL: Same objection. 21 Q. (BY MR. AMALA) As of January 2010, you 22 knew that users who posted ads in the escort section 23 of Backpage.com were posting ads of women and 24 children for sex, correct? 25 MR. NEEL: Same objection. Page 51 Page (Pages 49 to 52)

15 1 A. I decline to answer pursuant to the Fifth 2 Amendment. 3 Q. (BY MR. AMALA) And you discussed that with 4 Carl Ferrer, correct? 5 MR. NEEL: Same objection. 8 Q. (BY MR. AMALA) And you discussed that with 9 other managers of Backpage.com, correct? 10 MR. NEEL: Same objection. 13 Q. (BY MR. AMALA) As of January 2010, you 14 knew that Backpage.com was profiting from users who 15 posted ads for sex in the escort section of 16 Backpage.com, correct? 17 MR. NEEL: Same objection Q. (BY MR. AMALA) And you discussed that with 21 Carl Ferrer, correct? 22 MR. NEEL: Same objection. 23 A. I decline to answer pursuant to the Fifth 24 Amendment. 25 Q. (BY MR. AMALA) You also knew as of January Page 53 1 Q. (BY MR. AMALA) You discussed that with 2 Carl Ferrer, correct? 3 MR. NEEL: Same objection. 4 A. I decline to answer pursuant to the Fifth 5 Amendment. 6 Q. (BY MR. AMALA) And you discussed that with 7 other managers of Backpage.com, correct? 8 MR. NEEL: Same objection. 9 A. I decline to answer pursuant to the Fifth 10 Amendment. 11 Q. (BY MR. AMALA) As of January 2010, you 12 knew that sex traffickers believed that the 13 Backpage.com provided a marketplace for sex 14 trafficking, correct? 15 MR. NEEL: Same objection. 18 Q. (BY MR. AMALA) And you discussed that with 19 Mr. Ferrer, correct? 20 MR. NEEL: Same objection. 21 A. I decline to answer pursuant to the Fifth 22 Amendment. 23 Q. (BY MR. AMALA) And you discussed that with 24 the other managers at Backpage.com, correct? 25 MR. NEEL: Same objection , that Backpage.com was of profiting from users 2 who posted ads of children for sex in the escort 3 section of Backpage.com, correct? 4 MR. NEEL: Same objection. 5 A. I decline to answer pursuant to the Fifth 6 Amendment. 7 Q. (BY MR. AMALA) You discussed the fact that 8 Backpage was profiting from ads for sex with 9 children with Mr. Ferrer, correct? 10 MR. NEEL: Same objection. 13 Q. (BY MR. AMALA) And you've discussed that 14 with other managers of Backpage.com, correct? 15 MR. NEEL: Same objection. 18 Q. (BY MR. AMALA) Throughout 2010, you knew 19 that some of the children, who were being advertised 20 for sex in the escort section of Backpage.com, were 21 being forced to have sex with more than ten men a 22 day, correct? 23 MR. NEEL: Same objection. 1 A. I decline to answer pursuant to the Fifth 2 Amendment. Page 54 3 Q. (BY MR. AMALA) You didn't do anything at 4 that point to stop the sex trafficking that was 5 occurring in the escort section of Backpage.com, 6 correct? 7 MR. NEEL: Same objection. 10 Q. (BY MR. AMALA) Rather than do anything to 11 stop that sex trafficking marketplace, you 12 understood that one of your jobs was actually to 13 promote and grow that marketplace for illegal sex 14 trafficking, correct? 15 MR. NEEL: Same objection. 18 Q. (BY MR. AMALA) Did Mr. Ferrer ever tell 19 you whether or not that was one of your jobs in 20 working for Backpage.com? 21 A. I decline to answer pursuant to the Fifth 22 Amendment. 23 Q. (BY MR. AMALA) In 2010, Backpage.com revie relied on people known as moderators to review 25 ads that were being posted in the escort section of Page 55 Page (Pages 53 to 56)

16

17 1 Q. (BY MR. AMALA) Throughout 2010, you knew 2 that selling sex for money is illegal in the State 3 of Washington, correct? 4 MR. NEEL: Same objection. 5 A. I decline to answer pursuant to the Fifth 6 Amendment. 7 Q. (BY MR. AMALA) Did you know in 2010, 8 whether or not selling sex for money is illegal in 9 the State of Washington? 10 MR. NEEL: Objection, calls for a legal 11 conclusion Q. (BY MR. AMALA) Did you know in 2010, 15 whether or not helping another person sell sex for 16 money is illegal in the State of Washington? 17 MR. NEEL: Same objection Q. (BY MR. AMALA) Did you know in 2010, 21 whether or not sex trafficking is illegal in the 22 State of Washington? 23 MR. NEEL: Same objection. 1 Q. (BY MR. AMALA) Throughout 2010, you knew 2 that thousands of prostitution advertisements had 3 appeared on Backpage.com in the escort section, that 4 targeted Washington State citizens, correct? 5 MR. NEEL: Objection, calls for 6 speculation. 7 A. I decline to answer pursuant to the Fifth 8 Amendment. 9 Q. (BY MR. AMALA) Did you know whether or not 10 thousands of those ads targeted citizens in Pierce 11 County, Washington? 12 MR. NEEL: Same objection. 13 A. I decline to answer pursuant to the Fifth 14 Amendment. 15 Q. (BY MR. AMALA) Do you know whether 16 thousands of those ads targeted citizens in King 17 County, Washington? 18 MR. NEEL: Same objection. 21 Q. (BY MR. AMALA) Throughout 2010, did you 22 know whether or not women from Washington were being 23 advertised for sex in the escort section of 24 Backpage.com? 25 MR. NEEL: Same objection. Page 61 1 A. I decline to answer pursuant to the Fifth 2 Amendment. 3 Q. (BY MR. AMALA) Did you ever discuss that 4 with Carl Ferrer? 5 MR. NEEL: Same objection. 8 Q. (BY MR. AMALA) Throughout 2010, you knew 9 that hundreds of women from Washington were being 10 advertised for sex in the escort section of 11 Backpage.com, correct? 12 MR. NEEL: Same objection. 13 A. I decline to answer pursuant to the Fifth 14 Amendment. 15 Q. (BY MR. AMALA) Throughout 2010, did you 16 know that hundreds of women from Pierce County, 17 Washington were being advertised for sex in the 18 escort section of Backpage.com? 19 MR. NEEL: Same objection. 20 A. I decline to answer pursuant to the Fifth 21 Amendment. 22 Q. (BY MR. AMALA) Throughout 2010, did you 23 know whether or not hundreds of women from King 24 County, Washington were being advertised for sex in 25 the escort section of Backpage.com? 1 MR. NEEL: Same objection. Page 62 4 Q. (BY MR. AMALA) Throughout 2010, you knew 5 that the business model for Backpage.com is based on 6 paid advertisements for commercial sex, correct? 7 MR. NEEL: Same objection. 10 Q. (BY MR. AMALA) As of January 2010, you 11 knew that Backpage.com generated virtually no profit 12 from ads for legitimate goods and services, correct? 13 MR. NEEL: Same objection. 14 A. I decline to answer pursuant to the Fifth 15 Amendment. 16 Q. (BY MR. AMALA) Throughout 2010, you knew 17 that Backpage.com was using advertisements of 18 legitimate goods and services as a cover for 19 profiting from advertisements from sex trafficking, 20 correct? 21 MR. NEEL: Same objection Q. (BY MR. AMALA) And you discussed that with 25 Carl Ferrer, correct? Page 63 Page (Pages 61 to 64)

18 1 MR. NEEL: Same objection. 4 Q. (BY MR. AMALA) As of January 2002, did you 5 know whether the term "escort" means prostitution? 8 Q. Throughout the time that you've worked at 9 Backpage.com, you've understood that the word 10 "escort" means prostitution, correct? 11 MR. NEEL: Same objection Q. (BY MR. AMALA) Throughout the time that 15 you've worked at Backpage.com, you understood that 16 the term "escort" was used by with the company to 17 try to conceal its knowledge that nearly all of the 18 wealth -- the website's profits are derived from sex 19 trafficking, correct? 20 MR. NEEL: Same objection. 21 A. I decline to answer pursuant to the Fifth 22 Amendment. 23 Q. (BY MR. AMALA) Throughout 2010, you 24 personally admonished moderators if they created a 25 record and suggested the company knew that Page 65 1 MR. NEEL: Same objection. 4 Q. (BY MR. AMALA) You discussed that with 5 Carl Ferrer, correct? 6 MR. NEEL: Same objection. 7 A. I decline to answer pursuant to the Fifth 8 Amendment. 9 Q. (BY MR. AMALA) You discussed that with 10 correct? 11 MR. NEEL: Same objection Q. (BY MR. AMALA) And you discussed that with 15 the other managers at Backpage.com, correct? 16 MR. NEEL: Same objection. 17 A. I decline to answer pursuant to the Fifth 18 Amendment. 19 Q. (BY MR. AMALA) Throughout the time that 20 you've worked on Backpage.com, you knew that the 21 term "pimp" refers to a sex trafficker, correct? 22 MR. NEEL: Same objection. 23 A. I decline to answer pursuant to the Fifth 24 Amendment. 25 Q. (BY MR. AMALA) You also knew that the term 1 prostitution was occurring on the website, correct? 4 Q. You admonished those moderators not to 5 create any record that suggested that they knew that 6 prostitution was occurring on the website as part of 7 Backpage's efforts to conceal the fact that it knows 8 the majority of its profits come from sex 9 trafficking, correct? 10 MR. NEEL: Same objection. 13 Q. (BY MR. AMALA) As of January 2010, you 14 knew that using the term "escort" on the Backpage 15 website was a way to attract sex traffickers, 16 correct? 17 MR. NEEL: Same objection Q. (BY MR. AMALA) You also knew that by using 21 the term "escort" for the website, people who wanted 22 to pay money for sex would know that each of the 23 women and children whose ads were posted in the 24 escort section were available for sex for money, 25 correct? Page 66 1 "john" refers to someone who wants to pay money for 2 sex, correct? 3 MR. NEEL: Same objection. 4 A. I decline to answer pursuant to the Fifth 5 Amendment. 6 Q. (BY MR. AMALA) As of January 2010, you 7 knew that sex traffickers were trying to conceal the 8 identity of the women that they were advertising for 9 sex in the escort section at Backpage.com, correct? 10 MR. NEEL: Same objection. 13 Q. (BY MR. AMALA) And you discussed that with 14 Mr. Ferrer, correct? 15 MR. NEEL: Same objection. 18 Q. (BY MR. AMALA) As of January 2010, you 19 knew that sex traffickers were trying to conceal the 20 identity of children who they were advertising for 21 sex in the escort section of Backpage.com, correct? 22 MR. NEEL: Same objection. 23 A. I decline to answer pursuant to the Fifth 24 Amendment. 25 Q. (BY MR. AMALA) And you discussed that with Page 67 Page (Pages 65 to 68)