ATTORNEY GENERAL ANDPROSECUTING ATTORNEYS'OPPOSITION TO PLAINTIFF'SMOTIONS FOR PRELIMINARYINJUNCTION -- NO. C12-954-RSM3
ATTORNEY GENERAL‟S OFFICE
Criminal Justice Division800 Fifth Avenue, Suite 2000Seattle, WA 98104-3188(206) 464-6430
1234567891011121314151617181920212223242526preliminary injunction against the Attorney General and the Prosecuting Attorneys of this stateshould be denied, and the temporary restraining order should be lifted.
STATEMENT OF FACTSA.
The trafficking of minors in Washington for commercial sexual abuse.
“Experts estimate at least 100,000 American juveniles are victimized through prostitution in America each year.” Declaration of Lana Weinmann ¶ 3.
Online classifiedadvertisements are frequently used to pimp minors to prospective customers. Declaration of
Ryan Long (“Long Decl.”
) ¶ 19. The Washington State Legislature, in enacting SB 6251,found the growing problem of child sex trafficking through advertisements must be addressed:
The legislature finds it unacceptable that Washington‟s children are being sold
for sex in advertisements. A 2008 Seattle human services department reportestimated that there are three hundred to five hundred children being exploitedfor sex in the Seattle area alone each year. The legislature finds that the practiceof escort services advertising includes minors who are being sold for sex, a formof sex trafficking and commercial sexual abuse of minors. According to theSeattle police department, since the beginning of 2010, at least twenty-twochildren have been advertised online in the Seattle area for commercial sex andwere recovered by the police department. The legislature is committed toeliminating sex trafficking of minors in a manner consistent with federal lawsprohibiting sexual exploitation of children.SB 6251, section 1.
The escort services advertising business.
Online escort advertisements are thinly veiled offers of prostitution. Long Decl. ¶¶ 19-21, 24. Even in the absence of discovery, there is evidence that Backpage.com is aware of thisfact. Declaration of Paula Selis ¶ 3. Advertisements on Backpage.com are often made byprostitutes at the direction of a pimp or by the pimp. Long Decl. ¶ 19. These advertisements
The Kitsap County Prosecuting Attorney has noted a separate Motion pursuant to Fed. R. Civ. P.12(b)(6).
Case 2:12-cv-00954-RSM Document 41 Filed 07/10/12 Page 3 of 39