Case Document 1 Filed 02/14/18 Page 1 of 22 PageID 25 F. #201 71100588 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA - against - KEITH RANIERE, also known as ?The Vanguard,? Defendant. EASTERN DISTRICT OF NEW YORKFILED UNDER SEAL COMPLAINT AND AFFIDAVIT IN SUPPORT OF ARREST WARRANT (18 use. 1589(a)(2), 1589(a)(4), 1591(a)(1), 1594 1594(c), 2 and 3551 e_t mJ MICHAEL LEVER, being duly sworn, deposes and states that he is a Special Agent with the Federal Bureau of Investigation, duly appointed according to law and acting as such. In or about and between February 2016 and June 2017, both dates being approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant KEITH RANIERE, together with others, did knowingly and intentionally conspire to recruit, entice, harbor, transport, provide, obtain, maintain, patronize and solicit persons, to wit: Jane Does and 2, individuals whose identities are known to the undersigned, in and affecting interstate and foreign commerce, knowing that means of force, threats of force, fraud and coercion, as described in Title 18, United States Code, Section 1591(e)(2), and one or more combinations of such means, would be used to cause such persons to engage in Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 2 of 22 PageID 26 one or more commercial sex acts, contrary to Title 18, United States Code, Section 1 9 1 (Title 18, United States Code, Sections 1594(c), 1591(b)(1) and 3551 e_t sea) In or about and between February 2016 and June 2017, both dates being approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant KEITH RANIERE, together with others, did knowingly and intentionally recruit, entice, harbor, transport, provide, obtain, maintain, patronize and solicit persons, to wit: Jane Does 1 and 2, individuals whose identities are known to the undersigned, in and affecting interstate and foreign commerce, knowing that means of force, threats of force, fraud and coercion, as described in Title 18, United States Code, Section and one or more combinations of such means, would be used to cause such persons to engage in one or more commercial sex acts. (Title 18, United States Code, Sections 1591(a)(1), 1591(b)(1), 2 and 3551 at me) In or about and between February 2016 and June 2017, both dates being approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant KEITH RANIERE, together with others, did knowingly and intentionally conSpire to provide and obtain the labor and services of a person, to wit: Jane Doe I, by threats of serious harm to her and one or more other persons, and by means of one or more schemes, plans and patterns intended to cause Jane Doe I to believe that, if she did not perform such Case Document 1 Filed 02/14/18 Page 3 of 22 PageID 27 labor and services, Jane Doe I and one or more other persons would suffer serious harm, contrary to Title 18, United States Code, Sections 1589(a)(2) and 1589(a)(4). (Title 18, United States Code, Sections 1594(b) and 3551 e_t ml.) The source of your deponent?s information and the grounds for his belief are as follows: 1. I am a Special Agent with the Federal Bureau of Investigation and have been involved in the investigation of cases involving sex traf?cking and civil rights violations. 2. I have personally participated in the investigation of the offenses discussed below. The information set forth in this Complaint and Af?davit in Support of Arrest Warrant is derived from my participation in the investigation as well as from, among other things, a review of other records, emails, and reports from other law enforcement agents involved in the investigation. In particular, the FBI has interviewed eight victims and many additional ?rst?hand witnesses to the events described herein, electronic evidence recovered from the victims and witnesses, and the results of several search warrants including one executed on an email account belonging to RANIERE. Because this affidavit is submitted only to establish probable cause to arrest, I have not included each and every fact known to me concerning this investigation. I have set forth only the facts I believe are necessary to establish probable cause. In addition, whenI refer below to the statements of others, such references are in sum and substance and in part. I. Background 3. In or about 1998, the defendant KEITH RANIERE, also known as ?The Vanguard,? founded Executive Success Programs, Inc. a series of workshops Case Document 1 Filed 02/14/18 Page 4 of 22 PagelD 28 designed, according to its promotional literature, to "actualizc human potential.? In or about 2003, founded an organization called invm (pronounced NEX-i-um), which served as an umbrella organization for ESP and other KANIERE-affiliated entities. 4. On its official website, invm is described as a "professional business providing educational tools, coaching and trainings to corporations and people from all walks of life,? and describes its philosophy as "a new ethical understanding? that allows "humanity to rise to its noble possibility." 5. invm is headquartered in Albany, New York. invm operates centers all over the Americas including in the United States, Canada, Central America and Mexico. RANIERIJ and many members of invm ("inans'") live approximately 20 miles outside ofAlbany, New York, in Clifton Park, New York, near invm's headquarters. A number of inans were residents of the Eastern District of New York, when they were recruited, and invm has held promotional recruiting events in Brooklyn, New York. 6. Each of the entities offers classes promising personal and professional development. Based on information obtained during the course of this investigation, classes offered by entities can cost up to $5,000 for a five-day workshop. Participants are encouraged to keep attending classes and to recruit others into the organization in order to rise within the ranks of invm and to reach certain "goal levels.? These levels are marked by different color sashes, which are worn by inans, as well as different responsibilities and privileges, including the ability to receive a salary or commissions. Many inans find themselves in debt from the courses they are required to take, and some are obliged to take jobs working for invm in order to continue taking courses and ostensibly to pay off their debts. However, because of the high price of the Case Document 1 Filed 02/14/18 Page 5 of 22 PageID 29 5 courses and the pressure to continue taking them, participants often would continue to accumulate new debts and remain obliged to invm. invm operates largely in secrecy. inans were often required to sign non-disclosure agreements and to make premises not to reveal certain things about invm's teachings. 8. invm maintains features of a multilevel marketing scheme, commonly known as a pyramid scheme, in which members are recruited via a promise of payments or services for enrolling others into the scheme. formerly ran a multilevel marketing scheme called Consumers Buyline, which -?as forced to close after a settlement with the New York Attorney General in 1997', approximately one year before ESP was founded. 9. RANIERE is referred to as "The Vanguard? by inans. livery year in August, inans pay $2,000 or more to gather in Silver Bay, New York to celebrate "Vanguard Week? in honor of RANIERE, whose birthday is August 26, 1960. 10. Based on infonnation obtained during the course of this investigation, since ESP's founding, RANIERE has maintained a rotating group of fifteen to twenty women with whom he maintains sexual relationships. These women are not permitted to have sexual relationships with anyone but RANIERE or to discuss with others their relationships with RANIERE. Some of the invm curriculum included teachings about the need for men to have multiple sexual partners and the need for women to be monogamous. Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 6 of 22 PageID 30 II. OS A. Founding and Structure 11. In or about 2015, a secret society was developed within invm called or the ?Wow? (collectively 12. DOS is an organized criminal group that operates in the Eastern District of New York and other parts of the United States, Canada and Mexico. DOS engages in, and its'activities affect, interstate and foreign commerce. 13. DOS operates as a pyramid with levels of ?slaves? headed by ?masters.? Slaves are expected to recruit slaves of their own (thus becoming masters themselves), who in turn owe service not only to their own masters but also to masters above them in the DOS pyramid. 14. Based on information gathered over the course of this investigation, including own admissions and emails between RANIERE and other members of DOS, RANIERE alone forms the top of the pyramid as the highest master. Other than RANIERE, all participants in DOS are women. status as head of the pyramid was concealed from all newly recruited slaves, other than those directly under RANIERE. B. Recruiting and Collateral 15. From the time of its inception through in or about Spring 2017', DOS masters recruited slaves mostlj,r from within invm?s ranks. Men identifying prospective 1 According to various sources of information, DOS stands for ?Dominus Obsequious Sororium,? which at least one DOS slave was told by her master translates to ?Master Over the Slave Women.? According to a Latin expert I consulted, this phrase is broken Latin (?ob sequious? is an English word and the Latin would properly be ?obscquicsarum,? and ?sororium? would properly be ?sororum?), but roughly translates to ?LordfMaster of the Obedient Female Companions?. Case 1:18-inj-00132-LB Document 1 Filed 02/14/18 Page 7 of 22 PageID 31 slaves, masters often targeted women who were currently experiencing dif?culties in their lives, including dissatisfaction with the pace of their advancement in Naivm. While avoiding the words ?master? and ?slave? in the initial recruiting pitch, a master would tell her prospective slave that the proSpective slave had an opportunity to join an organization that would change her life. The master then told the prospective slave that, in order to learn more, she had to provide ?collateral,? which was meant to ensure that the proSpective slave would keep what she was about to learn a secret. Collateral consisted of material or information that the prospective slave would not want revealed because it would be ruinous to the prospective slave herself and! or someone close to her. 16. Collateral provided by prospective slaves included sexually explicit photographs; videos made to look candid in which the prosPective slaves told damning stories (true or untrue) about themselves, close friends andfor family members; and letters making damaging accusations (true or untrue) against friends and family members. In man},r cases, the masters helped the prospective slaves develop ideas for what would be appropriate collateral or instructed the prospective slaves on lies to tell in order to make the collateral even more damaging. After prospective slaves provided collateral in order to learn more about the organization, the masters informed them that DOS was a women?only organization role as the highest master was not mentioned) and that the goal of DOS was to eradicate weaknesses in its members. The Naivm curriculum taught that women had inherent weaknesses including ?overemotional? natures, an inability to keep promises and embracing the role of victim. The masters also told prospective slaves that their respective relationships would be of ?masters? and ?slaves,? using those words. If prospective slaves Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 8 of 22 PageID 32 expressed hesitation about the program or about becoming ?slaves?. and having ?masters,? the masters downplayed the terms, saying that all women are slaves to various things. In many cases, masters also used Naivm techniques to manipulate the prospective slaves into believing that any hesitation to join was due to weaknesses on the part of the prospective slaves and that the hesitation itself was evidence of why they needed DOS. 18. Prospective slaves who agreed to join DOS were told that in order to join they had to provide additional collateral, similar in type to the collateral they had already provided. Some slaves were told that they had to collateralize all aspects of their lives, including signing over any assets, disclaiming their faith, and doing things that would ruin their careers and relationships if the collateral were released. DOS slaves understood that if they left DOS, spoke publicly about DOS, or repeatedly failed DOS obligations or assignments, their collateral could be released. 19. All DOS slaves were ultimately required to provide collateral beyond what had initially been described to them. For example, most DOS slaves were not initially told thatlthey would have to provide collateral every month. In most cases the DOS slaves continued to provide additional collateral beyond what they had initially understood was expected, in part because they feared that the collateral they had already provided would be released. C. Bene?ts Conferred on DOS Masters 20. DOS slaves were required to perform ?acts of care? for their masters and to pay ?tribute? to their masters in various ways- In many cases these acts of care and tribute were akin to acting as personal assistants to the masters bringing them coffee, buying them groceries, making them lunch, carrying their luggage, cleaning their houses and Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 9 of 22 PageID 33 retrieving lost items for them, among other tasks. The understanding among DOS members was that acts of care provided by a master?s slaves, and those slaves? own slaves, should ultimately amount to the master having the work of at least one full time employee. 21. Slaves were chastised and punished for not performing suf?cient acts of care, and slaves believed that if they repeatedly failed at acts of care they risked release of their collateral. D. Sex Trafficking Within DOS 22. Beyond acts of care, DOS slaves were also regularly given assignments to complete by their masters. Some of the masters gave their slaves assignments that either directly or implicitly required them to have sex with RANIERE, which they then did. Other assignments appeared designed to groom slaves sexually for RANIERE. For example, RANIERE is known to sexually prefer women who are exceptionally thin, and a number of the slaves? assignments required them to' adhere to extremely low-calorie diets and to document every food they ate. Other women were assigned to periods of celibacy, during which they were not allowed to have sex with anyone or masturbate. 23. Based on information obtained over the course of the investigation, DOS victims who received the assignment to have sex with RANIERE believed they had to complete the assignment or risk release of their collateral. 24. The DOS masters, including Co-Conspirator 1 described below), who directed their slaves to have sex with RANIERE pro?ted from the resulting sex acts. Those DOS masters received a financial benefit in the form of continued status and participation in DOS, the masters continued to receive acts of care and the work of the equivalent of a full time employee. In addition, by requiring DOS slaves to have sex with Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 10 of 22 PagelD 34 10 RANIERE, DOS masters also received bene?ts from RANIERE in the form of increased status and ?nancial opportunities within invrn more broadly. also often discussed or promised career opportunities to the DOS slaves who had sex with him and the DOS slaves with whom he expressed an interest in having sex. As one example, discussed further below, once Jane Doc 1 began having sex with RANIERE, he provided her with money and offered her a job, but as soon as she defected from DOS and stopped having sex with him, RANIERE told her she had to pay the money back. E. Other Assignments and ?Readiness? 25. DOS slaves were also regularly given assignments to complete by their masters that included reviewing ESP materials and doing other work for invm or i This work included reviewing and editing dense articles written by RANIERE and, at least in one case described further below, transcribing interviews of a high-ranking member of invm fer a memorial service being hosted by RANIERE. 26. In addition to completing acts of care and assignments, DOS slaves were required to participate in ?readiness? drills. The purpose of these drills was to have everyone in the DOS pyramid end by text message at any given time of the day or night. Readiness drills along with other aspects of the DOS program resulted in the slaves suffering from severe sleep deprivation. 27. DOS slaves also had to engage in acts of self?denial or acts that would cause them discomfort, including taking ice cold showers for several minutes, standing for an hour at 4:00 am. and performing planks (a dif?cult exercise where one rests on her forearms and tiptoes and keeps her back as ?at as possible). Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 11 of 22 PagelD 35 11 28. Based on information obtained over the course of the investigation, DOS victims have explained that they believed they had to complete their assignments and comply with readiness drills and acts of self-denial or risk release of their collateral. Additionally, several DOS victims believed that their success in the invm ranking system depended on their successfully completing DOS assignments. 29. Furthermore, masters informed their slaves that if the slaves failed to complete their assignments, it re?ected badly on the masters and could cause them to be punished by their own masters. In at least one instance, a master who, unbeknownst to her slaves, was herself a direct slave of told her slaves that she could be punished by being paddled or by being put in a cage by her master, by RANIERE, for her slaves? failure to succeed at ?readiness.? F. Branding 30. Many of the DOS victims were branded in their pubic regions with a cauterizing pen in a process that took twenty to thirty minutes. During the branding ?ceremonies,? slaves were required to be fully naked, and the master would order one slave to ?lm while the others held down the slave being branded. Some DOS victims were told that the brand stood for the four elements (the lines represented air, earth and water and the cauterizing pen represented sealing with Based on information obtained during the course of the investigation, however, it is clear that the brand in fact consisted of initials. A?er defections, discussed below in paragraph 33, RANIERE acknowledged to one DOS victim that his initials are incorporated into the brand as a form of ?tribute.? Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 12 of 22 PagelD 36 12 31. Masters told their slaves after the branding ceremonies that the videos of the branding ceremonies and photographs of the women with their brands were additional pieces of collateral. 32. The ?rst image below is a picture of victim Jane Doe 1?s brand as it appeared on her body shortly after the procedure. The second image shows the brand turned counter-clockwise with initials (the upside donor) superimposed. Defections and Aftermath 33. In or about May 2017, a DOS slave (who was also a high-ranking member of invm) defected in a public way. At that time, inans began learning about the existence of DOS andthere was some defection of inans, including a member bf the I Executive Board and additional DOS members. 34. In or about October 2017, the New York Times published an article revealing the existence of DOS. Several weeks after that article was published and after the Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 13 of 22 PagelD 37 13 13131 began interviewing witnesses, flew to Mexico with an heiress (the "l leiress?i), who is a member of invm's Executive Board and is a known financial backer of RANIERE and invm. Prior to this trip, RANIERE had not flown out of the country since 2015, when he visited the lleiress's private island in liiji. RANIERE is currently believed to be residing in Monterrey, Mexico, where invm maintains a center, with a branded DOS slave. 35. Since defecting, several DOS victims have received "cease and desist? letters from a Mexican attorney. Emails exchanged between and the lleircss, received pursuant to a search warrant executed on RANIERB's email account, discussed below, reveal that the lleiress and orchestrated the sending ofthose letters. Additionally, the lleiress has made multiple attempts to have criminal charges brought against a former DOS slave, who has discussed her experience in the media. 1V. Yahoo! Email Account 36. On January 13, 2018, Eastern District of New York United States l?vlagistrate Judge Cheryl Pollak signed a search warrant for Yahoo! e-mail account keithranieref?iQy-?ahoocom (the "account?). 1 served the warrant on Yahoo! on January 19, 2018. On February 1, 2018, Yahoo! produced information associated with the account. The subscriber for the account was identified as "Mr Keith Raniere.? The subscriber information also included a date of birth that matched that of RANIERE. 37'. Within the material provided by Yahoo! were numerous emails, only a few of which are described here, which support the conclusion that created DOS. On August 10, 2015, sent an email to the account. CC- 1 's email was titled ?vow 3? and included an attached letter. The letter pledged CC- 1 's "full and complete life? to Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 14 of 22 PagelD 38 14 RANIERE. In the letter, used the terms ?slave? and ?master? to refer to herself and RANIERE. Moreover, the letter identi?ed ?collatera ?to ?cement? the vow made by This collateral was described as: a letter regarding 00-1 ?3 mother and father that would ?destroy their character?; (2) a contract that transferred custody of any children birthed by to RANIERE if broke her commitment to (3) a contract that transferred camership of ?s home if the commitment to RANIERE was broken; and (4) a letter addressed to social services alleging abuse to CC-l?s nephews. 38. On July 12, 2015, another woman believed to be a DOS master directly under sent an email to another email account believed to belong to RANIERE, which RANTERE then forwarded to the account. In the email, the woman requested edits from RANIERE to a series of passages in which she described a vow of total obedience to RANIERE. 39. The account also contained emails between another woman believed to be a DOS slave and RANTERE. Attached to some of the emails were WhatsApp chats between the woman and RANIERE. These chats include discussions from as early as in or about May 2015 about a ?vow? that required ?collateral.? On or about, October 1, 2015, RANIERE stated to the woman, think it would be good for you to own a fuck toy slave for me, that you could groom, and use as a tool, to pleasure me . . . On or about, October 23, RANIERE. Throughout the chat RANIERE alludes to the fact that DOS was his creation. V. Co-Conspirators 40. GUI is an actress and is currently understood to be one of the women with whom RANIERE maintained a sexual relationship prior to the development of DOS. Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 15 of 22 PagelD 39 15 Statements on Naivm-related websites, including video interviews of RANIERE and refer to mentorship of and to and CC-l?s co-development of ?The Source,? a Nathan?affiliated entity focused on improving actors? performance skills. Based on information obtained over the course of the investigation, including admissions by RANIERE and emails between RANTERE and is direct slave. 41. Co-Conspirator 2 had been involved in invm for several years before being introduced to DOS. In or about 2016, RANTERE co-founded ?The Delegates? with CC-2, which is a business that provides a network of people who can perform tasks for people in the invm community in exchange for a fee. Based on information obtained over the course of the investigation, is ?a direct slave. VI. Sex Traf?cking and Forced Labor of Jane Doe I 42. Jane Doe 1 is an actress in her early thirties who began taking invm classes in or about 2015, including The Source classes with In or about February 2016, invited Jane Doe 1 to join a ?women?s mentorship group,? but asked that Jane Doc 1 first provide collateral. At direction, Jane Doc 1 wrote letters detailing false and highly damaging accusations against her family members. Once Jane Doe I had provided this collateral, told her about DOS, referring to it as ?The Vow.? 43. Jane Doe I agreed to become ?s slave, provided more collateral (eventually including her credit card numbers with letters granting _CC?1_permission to use . . . the numbers to make charges) and began receiving assignments. Throughout her time in DOS, Jane Doe I was living in Brooklyn, New York. ordered Jane Doe I to travel to Clifton Park nearly every week from Brooklyn. When Jane Doe was in Clifton Park, she stayed with (101 and (EC-2, another of ?s slaves. Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 16 of 22 PagelD 4O 16 44. told Jane Doe I that Jane Doe I had to be celibate for six months. Eventually, Jane Doc 1 began receiving assignments that involved contact with RANIERE. At ?rst tasked Jane Doe 1 with getting RANIERE to send Jane Doe I an email, which she eventually succeeded at doing. One night when Jane Doe 1 was staying with in Clifton Park, received a text message from RANIERE, woke Jane Doe I in the middle of the night, and told her that RANIERE was there to go on a walk with her. (:01 told ane Doe I that Jane Doc 1 was assigned to tell RANIERE that Jane Doe 1 would do anything RANIERE asked her to do. Jane Doc 1 did as she was ordered and RANIERE asked her what the worst thing he could order her to do was. Jane Doe I told RANIERE that she had initially thought it would be something sexual, but that the worst thing would be if he asked her to kill herself or someone else. At the end of the walk, RANIERE told Jane Doc 1 that he did not believe she really meant she would do anything he asked. 45. The next night again received a text message from RANIERE, woke Jane Doe 1 in the middle of the night and assigned her to meet RANIERE and tell him she would do anything he asked her to do. Jane Doe 1 did as she was assigned, and RANIERE led her to a house across the Street. RANIERE directed her to remove all her clothes and made comments about her naked body. RANIERE then blindfolded Jane Doe 1, led her into a car and drove her around in a manner that made Jane Doe believe Jane Doc 1, still blindfolded, through some trees, into what she believed was a shack, and tied her to a table. Another person in the room, who Jane Doc 1 did not previously know was present, began performing oral sex on Jane Doc 1 as RANTERE circled the table making comments. Jane Doe 1 did not want to participate in this sexual activity, but believed it was Case Document 1 Filed 02/14/18 Page 17 of 22 PagelD 41 17 part of her commitment to DOS and that if she broke her commitment to DOS her collateral could be released. 46. Jane Doc 1 was never put on a diet by CC- 1, but Jane Doe I was 5 tall and weighed only 100 pounds before joining DOS, and she then lost some additional weight as a member of DOS due to stress and lack of sleep. 47'. In the following months, RANIERE had repeated sexual contact with Jane Doc 1, including oral sex and sexual intercourse on a number of occasions. He would take her to a space he called the "Library,? which was on the second floor of a house in Clifton Park (the first floor was under construction). The Library had a hot tub and a loft bed. RANIERE told Jane Doe I that he was 's master and Jane Doe 1?s "grandmaster." told Jane Doc 1 that he had conceived the concept of DOS. RANIIJRE explained to Jane Doc 1 that he could order her to have sex with him, although he claimed that was not what he was doing. Jane Doc I felt, however, that having sex with RANIERE was part of her DOS commitment and that if she broke her commitment to DOS, her collateral might be released. 48. Jane Doc I believed that at some point all the other slaves directly under CC- 1, which included (TC-2, learned that RANlLile was 's master and their grandmaster. Throughout Jane Doe 1's time in DOS, regularly required her slaves to pose for nude photographs, including on one occasion close-up pictures of their vaginas, either as assignments or collateral. Jane Doc 1 later learned that was sending these photographs to RANIERE, because Jane Doc 1 observed sending these photographs using 's cellphone to someone over a messaging service and then receiving responses which would sometimes relay to her slaves. The responses included that the Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 18 of 22 PagelD 42 13 photographs were not graphic enough or that the slaves were not smiling enough, and that they had to be retaken. On one occasion, Jane Doc 1 saw a text exchange on 's phone between RANIERE and in which sent a nude photo she had just taken of all of the slaves on Jane Doe 1's level and wrote back, ?All mine?? with a smiling devil cmoji. 49. At one point, Jane Doc 1 expressed to that she was having difficulty affording the frequent trips to Clifton Park. RANIERE was frustrated with her and took a bag with EB 10,000 in cash from a drawer in the Library and asked her if that would make her happy. Jane Doe I began using the cash to pay for her trips, only taking enough for the ticket each time she visited. On one occasion when she needed money, gave her $1,000 from the bag. Jane Doe I also occasionally expressed frustration at having to be celibate and only be sexual with RANIERE, and RANIERE would encourage her to wait a year, which gave Jane Doe 1 some hope that although she could not leave then, she might be able to leave in a year without risking release of her collateral. Jane Doe I stated that when she would bring up the one-year period with RANIERE, he would frequently change the date on which he said the year started. 50. As part ofhcr DOS assignments, Jane Doe I was tasked by with reading and reviewing dense articles written by RANIERE that were labeled at the bottom with ESP's copyright. Each article took hours to review and Jane Doe I was tasked with reviewing up to approximately 95 articles. Jane Doc 1 was required to fill out a standardized form after reading each article, which appeared designed to determine whether the articles were appropriate to include in ESP curriculum or if there were further edits that needed to be made in order for them to be useful to students. Jane Doe I also received Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 19 of 22 PagelD 43 19 an assignment from to transcribe interviews given by a long-term sexual partner of who had died, in preparation for that woman?s memorial service. Jane Doe 1 was awake for 23 hours straight completing that project, and RANIERE exchanged messages with her throughout the night encouraging her to stay awake and complete the assignment. also directly tasked Jane Doe 1 with an assignment to befriend and learn information about an ostracized member of the ESPfoivm community. As part of this plan, RANIERE directed Jane Doe I to make a false social media pro?le and eventually to meet this ostracized member of the community in person. Jane Doc 1 believed that each one of these assignments was part of her commitment to DOS and that if she failed at her to DOS, her collateral could be released. 51. After the May 2017 incident, as described in paragraph 33, because other DOS members had left without having had (to Jane Doe 1?s knowledge) their collateral released, Jane Doc 1 began to believe she might also be able to leave without having her collateral released. When she told (30-1 and that she was leaving DOS, they engaged in a two-hour ?intervention,? during which Jane Doc 1 was berated for leaving. Throughout the conversation, Jane Doc 1 sought assurances about her collateral. Although and CC-2 never directly said her collateral would not be released, she felt assured enough that as long as she did not speak out about DOS (as opposed to just breaking her lifetime assesses): he collateral. ?eels est be. released.- . Agatha inmates ma. Jane Doe I and told her she needed to return the money he had previously given her. V11. Sex Traf?cking of Jane Doe 2 52. Jane Doe 2 is an actress and model who began taking invrn classes in or about 2016, during which time she became friendly with When Jane Doe 2 was in Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 20 of 22 PagelD 44 20 Clifton Park for a invm class in or about November 2016, (EC-2 invited Jane Doe 2 on a walk. As they walked, CC-2 told Jane Doc 2 that she was part of a secret society that had transformed life and enabled to uphold commitments. told Jane Doc 2 that in order to learn more, Jane Doc 2 had to provide collateral, which Jane Doe 2 did in the form of a video in which Jane Doc 2 divulged a damaging secret. After providing this video, CC-2 told Jane Doc 2 about DOS and Jane Doc 2 agreed to become slave. 53. Eventually CC-2 told Jane Doc 2 that Was master and thus Jane Doe 2?s grandmaster. When Jane Doc 2 was introduced to DOS, she was living in Los Angeles, California. After Jane Doe 2 joined DOS, suggested that Jane Doe 2 temporarily move to Clifton Park, New York and spend more time with and Jane Doc 2 began spending more time in Clifton Park, but regularly traveled back to Los Angeles for jobs. When Jane [Joe 2 would travel between Los Angeles and Clifton Park, she would regularly ?y into John F. Kennedy International Airport in Queens, New York before taking the train or bus to Albany. 54. Two of Jane Doe 2?s ?rst acts of self-denial were to refrain from sex and masturbation. 55. At one point when Jane Doc 2 was in Clifton Park, RANIERE sent Jane Doc 2 a message in the middle of the night asking her to go on a walk with him. . During metals BAMERE told. Jens ?nalists; Ore the cease. 9f sass. Walks . . . . Jane Doc 2 expressed to RANIERE that she wanted to open a T?shirt business. RANIERE expressed interest and told her he would partner with her. Jane Doc 2 left for Los Angeles for a job and while she was there RANIERE sent her a text message saying, ?If you want to start this business with me then come back, the sooner the better.? Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 21 of 22 PagelD 45 21 56. . Jane Doc 2 returned to Clifton Park. She was soon given new assignments, including being kept on a regimented diet of 860?1000 calories per day. After several months, Jane Doc 2 received a text message from stating that wanted to speak to Jane Doc 2 about a ?special assignment.? (:01 and CC-2 then contacted Jane Doe 2 and told her the assignment was to ?seduce Keit and have him take a picture of Jane Doc 2 to prove she had done it. told Jane Doe 2 that this assignment was a privilege that few women had the honor of experiencing, but that and CO2 both had. At the end of the call told Jane Doc 2, give you permission to enjoy it,? which Jane Doc 2 interpreted to mean, give you permission to enjoy sex with Not suspecting that RANIERE was involved with DOS until this call, Jane Doc 2 asked on the call if RANTERE knew about DOS. said that he did not. After the call, in an effort to avoid having sex with RANIERE, Jane Doe 2 made arrangements to leave DOS. Jane Doe 2 retrieved a car that she had loaned to and her cat and possessions from Clifton Park. Before defecting, Jane Doe 2 also captured images of collateral belonging to other DOS members, including CC-2, from an online Dropbox account, believing that she could protect the release of her own collateral by having other DOS members? collateral as leverage. Jane Doe 2 of?cially left DOS in or about May 2016. WHEREFORE, your deponent respectfully requests that an arrest warrant be . issued for the defendant KEITH RANIERE so that he may be dealt with according to law. Your affiant ?irther requests that this af?davit and any associated arrest warrant be ?led Case 1:18-mj-00132-LB Document 1 Filed 02/14/18 Page 22 of 22 PagelD 46 22 under seal, because public ?ling would give the target of the investigation an opportunity to ?ee, to destroy evidence and to harm or threaten witnesses. MICHAEL LEVER Special Agent, Federal Bureau of Investigation Sworn to before me this ?t day of February, 2018 I A TEE ROICIORABLE IZOIS BLOOM UNITED STATES MAGISTRATE JUDGE EASTERN DISTRICT OF NEW YORK