A0 106 (Rev. 04/10) Application for a Search Warrant (Page I) I. II Peg-H i1. '5 UNITED STATES DISTRICT COURT Northern District of New York 5' I In the Matter of the Search of 1 (Brie?y describe the property :0 be searched . I or idemg?) the person by name and address) CaseNo. 8-MJ- IEH (DJ S) THE PRENIISES KNOWN AND I A DESCRIBED AS 3.0REGON TRAIL, WATERFORD, NY 12188, INCLUDING ANY LOCKED AND CLOSED CONTAINERS AND CLOSED ITEMS CONTAINED THEREIN APPLICATION FOR A SEARCH WARRANT I, a federal law enforcement of?cer or an attorney for the government, request a search warrant and state under penalty of perjury that I have reason to believe that on the following person or property: (identrj?z the person or describe the property to be searched and its given location): Please see Attachment A. located in the Northern District of New York I there is now concealed (identi?) the person or describe the property to be seized): Please see Attachment B. The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more): as evidence of a crime; >14 contraband, fruits of crime, or other items illegally possessed; preperty designed for use, intended for use, or used in committing a crime; El a person to be arrested or a person who is unlaw?illy restrained. The search is related to a violation of: Code Section Offense Description Sex traf?cking by force, fraud or coercion and interference in an 18 U.S.C. 1591; 18 U.S.C. 1589; investi ation into sex traf?Ckin force fraud or coercion' forced The application is based on these facts: Please see attached affidavit. Continued on the attached sheet. Delayed notice of days (give exact ending date if more than 30?days): Click here to enter a date. is requested under 18 U.S.C. 3103a, the basis of which is set forth on the attached sheet. A0 106 (Rev. 04/10) Applicatioq for a Search Warrant (Page Applicant ?8 signature FBI Special Agent Michael Lever Printed name and title Sworn to before me and signed in my presence. Date; March 26, 8 City and State: Albany, NY Hon. .Stewart, U.S. Magistrate Judg Printed name .and title I F. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK . IN THE MATTER OF THE SEARCH OF FILED UNDER SEAL THE PREMISES KNOWN AND DESCRIBED AS 3 OREGON TRAIL, AFFIDAVIT IN SUPPORT OF WATERFORD, NY 12188, INCLUDING APPLICATION FOR A ANY LOCKED AND CLOSED SEARCH WARRANT CONTAINERS AND CLOSED ITEMS CONTAINED THEREIN . .. NORTHERN DISTRICT OF NEW TORK, MICHAEL LEVER, being ?rst duly sworn, hereby deposes and says that he is a Special Agent with the Federal Bureau of Investigation duly appointed according i to law and acting as such. Upon information and belief, there is probable cause to believe that there is located in THE PREMISES KNOWN AND DESCRIBED AS 3 OREGON TRAIL, WATERFORD, NY 12188 (the INCLUDING ANY LOCKED AND CLOSED CONTAINERS AND CLOSED ITEMS CONTAINED THEREIN, ?nther described in Attachment A, the things described in Attachment which constitute evidence, fruits and instrumentalities of violations of, among other crimes, 18 U.S.C. 1591 (sex tmf?cking by force, fraud or coercion and interference in an investigation into sex tra?icking by force, fraud or coercion) and 18 U.S.C. 1589 (forced labor), 18 U.S.C. 1952 The source of your deponent?s information and the grounds for his belief are _as follows:1 I 1. I am a Special Agent with the-Federal Bureau of Investigation (the and have been since 2015. During my tenure with the FBI, I have participated in long-term investigations into civil rights violations and other crimes, during the course of which I have conducted physical electronic surveillance, executed search warrants, reviewed and analyzed location data and reviewed and analyzed numerous taped conversations and debriefed cooperating witnesses. 2. I am familiar with the facts and circumstances of this investigation among other sources: my personal participation in this investigation; reports made to me by other law enforcement personnel; interviews with witnesses; and the review of records, documents and reports. Where I rely on statements made by others, such statements are set forth in sum and substance and in part unless otherwise indicated. . SUBJECT PREMISES 3.. The SUBJECT PREMISES is atwo-story residential property, color The residence is accessible via a driveway which leads to a single garage. There is a walkway which leads ??om the driveway to the front door of the premises. 1 Because this af?davit is submitted for the limited purpose of establishing probable cause for a search warrant, I have not set forth each and every fact learned during the course of this investigation. I PROBABLE CAUSE I. Background 5. In or about 1998, Keith Raniere and Nancy Salzman c'o?founded Executive Success Programs, Inc. a series of workshops designed, according to its promotional literature, to ?actualize human potential.? In or about 2003, Raniere founded an organization called invm (pronounced which served as an umbrella organization for ESP and other Raniere-af?liated entities. 6. On its of?cial 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.? 7. invm is headquartered in the city of Albany, New York. invm operates centers all over the Americas including in the United States, Canada, Central America and Mexico. Raniere andmany members of invm (?Nazism?) live approximately 20 miles outside of Albany, New York, in Clifton Park, New York, near invm?s headquarters. I 8. Raniere is referred to as ?The Vanguard? by inans. Every year in August, inans celebrate ?Vanguard Week? in honor of Ranierc?s birthday; Nancy Salzman is referred to as ?The Prefect? by inans, and her birthday is celebrated in May the ?Festival of Flowers.? . 9. The public invm website lists Nancy Salzman as the President of ESP. 10. Each of the Raniere entities offers expensive courses (many, for example, costing $5,000 for 5 days), promising personal and professional deve10pment. 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 di?erent color sashes,? which are worn by inans, as well as different responsibilities and privileges, including the ability to receive a salary or commissions. 11. invm 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. Raniere formerly ran a multilevel marketing scheme called Consumers Buyline, which wasforced to close after a settlement with the New York Attorney General in 1997, approximately one year before ESP was founded. . 12. Based on information obtained during the course of this investigation, since founding, Raniere has maintained a rotating group of ?fteen 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. 4 A. Development and Structure OS 19. In or about 2015, Raniere founded a secret society within invm called or the ?Vow? (collectively 2 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 (?obsequious? is an English word and the Latin would prOperly be ?obsequiosarum,? and ?sororium? would properly be ?sororum?), but roughly translates to ?Lord/Master of the Obedient Female Companions.? 20. 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. i 21 . Based on information gathered over the course of this investigation, I including Raniere?s own admissions, and emails between Raniere and other members of DOS, Raniere alone forms the top of the pyramid the highest master. Other than Raniere, all participants in DOS are women. Ranier'e?s status as head of the pyramid was concealed from all newly recruited slaves, other than those directly under Raniere. . 22. From the time of its inception through in or about Spring 2017, DOS masters recruited slaves mostly ?om within invm?s ranks. When identifying prospective slaves, masters o?en targeted women who were currently experiencing di?culties in their lives, including, dissatisfaction with the pace of their advancement in invm. While avoiding the words ?master? and ?slave? in the initial recruiting pitch, amaster would tell her prospective slave that the prospective slave had 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. 23. Collateral provided by prospective slaves included sexually explicit photographs; videos made to look candid in which the prospective slaves told damning 7 stories (true or untrue) about themselves, close friends and/or family members; and letters making damaging accusations (true or untrue) against friends and family members and assigning the rights to certain assets. In many 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. 24. After prospective slaves provided collateral in order to learn more about the organization, the masters informed them that DOS was a women-only organization (Rainiere?s role as the highest master was not mentioned) and that the goal of DOS was to eradicate weaknesses in its members. . 25. .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 that they 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. 26. DOS slaves provided collateral to their masters in multiple forms including uploading collateral to an online storage account and providing collateral on thumb drives. Lauren Salzman, who is a DOS master,'told one of her slaves that'the collateral is kept in a safe. 27. DOS slaves were required to perform ?acts of care? for their masters . and to pay ?tribute? to their in various ways. In many cases these actsof and tribute were akin to acting as personal assistants to the masters bringing them coffee, 8 buying them groceries, making them lunch, carrying their luggage, .cleaning their houses and 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 amomt to the master having the work of at least one full time employee. 28. 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. 29. Many DOS slaves were also branded a cauterizing pen during a process that took 20-30 minutes. The branding ?ceremony? involved slaves taking turns holding each other down while the branding was ?lmed DOS masters informed the DOS slaves that the video footage of the slaves being branded and naked pictures of the women bearing their brands were further pieces of collateral. B. Sex Traf?cking Within DOS 30. Beyond acts of care, DOS slaves were also regularly given assignments to complete by their 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. 31. 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 release of their collateral. 32. The DOS masters, who directed their slaves to have sex with Raniere, pro?ted ?om the resulting sex acts. Those DOS masters received a ?nancial bene?t in the form of continued status and participation in DOS, i.e. 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 Raniere, DOS masters also received bene?ts from Raniere in the form of increased status and ?nancial opportunities within invm more broadly. Raniere I 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 Doe I beganhaving sex 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. C. Defec?ons and A?ermath 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 and there was some defection of inans, including a member of the 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 FBI began interviewing witnesses, Raniere ?ew to Mexico with an heiress (the ?Heiress? 10 who is a member of invm?s Executive Board and is a known ?nancial backer of Raniere and invm. Prior to this trip, Raniere had not ?own out of the country since 2015, when he visited the Heiress?s private island in Fiji. On March 25, 2018. after a month and a half of searching, the defendant was located staying in a luxury villa in Puerto Vallarta, Mexico. The defendant had stopped using the cellular telephone known to law enforcement and began using end-to?end email, which made ?nding him dif?cult. The defendant was deported by Mexican authorities and arrested by the FBI today in Dallas, Texas on a complaint charging him with sex traf?cking, sex traf?cking conspiracy and forced labor conspiracy. A copy of the complaint is attached as Exhibit 1 and incorporated herein by reference. 35. Since defecting, several DOS ?victims have received ?cease and desist? letters from a Mexican attorney. Emails exchanged between Raniere and the Heiress, received pursuant to a search warrant executed on Raniere?s email account, reveal that the Heiress and Raniere orchestrated the sending of those letters. Additionally, the Heiress has made multiple attempts to have criminal charges brought against a former DOS slave, who has discussed her experience in the media. 36. In or about December 2017, a letter purporting to be from Raniere was posted on invrn?s website. In the letter Raniere stated that neither he nor invm are af?liated with DOS. invm has continued to enroll students in courses since Raniere left for Mexico, though enrollment numbers have been down since the media reports of DOS. ll TECHNIQAL TERMS 47. Based on my training and experience, I use the following technical terms to convey the following meanings: a. IP Address: The IP address is a unique numeric address used by computers on the internet. An IP address looks like a series of four numbers, each in the range 0-255, separated tiy periods 121.56.97.178). Every computer attached to the internet must be assigned an IP address so that internet traffic sent from and directed to that computer may-be directed properly from its source to its destination. Most internet service 16 providers control a range of IP addresses. Some computers have static?that is, long- IP addresses, while other computers have dynamic?mat is, ?equently changed?[P - addreSses. b. Internet: The internet is a global network of computers and other electronic devices that communicate with each other. Due to the structure of the internet, connections between devices on the internet often cross state and international borders, even when the devices communicating with each other are in the same state. 0. Storage medium: A storage medium is any physical object upon. which computer data can be recorded. Examples include hard disks, RAM, ?oppy disks, ?ash memory, CD-ROMs, and other magnetic or optical media. COMPUTERS, ELECTRONIC STORAGE, AND FORENSIC ANALYSIS 48. As described above and in Attachment B, this application seeks permission to search for records that might be found on the SUBJECT PREMISES, in whatever form they are found. One form in which the records might be found is data stored on a computer?s hard drive or other storage medium. Thus, the warrant applied for would authorize the seizure of electronic storage medium or, potentially, the copying of electronically stored information, all under Rule . 49. Probable cause. I submit that if a computer or storage medium is found on the SUBJECT PREMISES, there. is probable cause to believe those records will be stored on that computer or storage medium, for at least the following reasons: a. Based on my knowledge, training, and experience, I know that computer ?les or remnants of such ?les can be recovered months or even years after they 17 have been downloaded onto a storage medium, deleted, or viewed via the intemet Electronic ?les downloaded to a storage medium can be stored for years at little.or no cost. I Even when ?les have been deleted, they can be recovered months or years later using forensic tools. This is so_ because when a person ?deletes? a ?le on a computer, the data contained in the ?le does not actually disappear; rather, that data remains on the storage medium until it is overwritten by new data. b. Therefore, deleted ?les, or remnants of deleted ?les, may reside in ?ee space or slack space?that is, in space on the storage medium that is not currently being used by an active ?le?for long periods of time before they are overwritten. In addition, a computer?s Operating system may also keep a record of deleted data in a ?swap? or ?recovery? ?le. i c. Wholly apart from user-generated ?les, computer storage media?in particular, computers? internal hard drives?contain electronic evidence of how a computer . hasbeen used, what it has been used for, and who has used it. To give a few exarhples, this forensic evidence. can take the form of operating system con?gurations, artifacts ?om operating system or application operation, ?le system data structures, and virtual memory ?swap? or paging ?les. Computer users typically do not erase or delete this evidence, . because special software is typically required for that task. However, it is technically possible to delete this information. id. Similarly, ?les that have been viewed via the intemet are sometimes automatically downloaded into a temporary intemet directory or ?cache.? 18 50. Forensic evidence. As further described in Attachment B, this application seeks permission to locate not only computer ?les that might serve as direct evidence of the crimes described onthe warrant, but also for forensic electronic evidence that establishes how computers were uSed, the purpose of their use, who used them, and when. There is probable cause to believe that this forensic electronic evidence will be on any storage medium in the SUBJECT PREMISES because: a. Data on the storage medium can provide evidence of a ?le that was once on the storage medium but has since been deleted or edited, or of a deleted portion of a ?le (such as a paragraph that has been deleted ?'om a word processing Virtual memory paging systems can leave traces of information on the storage medium that show what tasks and processes were recently active. Web browsers, e-mail programs, and chat programs store con?guration information on the storage medium that can reveal information such as online nicknames and passwords. Operating systems can record additional information, such as the attachment of peripherals, the attachment of USB ?ash storage devices or other external storage media, and the times the computer was in use. Computer ?le. systems can record information about the dates ?les were created and the sequence in which they were created, although this information can later be falsi?ed. b. As explained herein, information stored within a computer and other electronic storage media may previde crucial evidence of the ?who, what, why, when, where, and how? of the criminal conduct under investigation, thus. enabling the United States to establish and prove each element or alternatively, to exclude the innocent from ?thher - suspicion. In my training and experience, information stored within a computer or storage 19 media registry information, communications, images and movies, transactional . information, records of session times and durations, internet history, and anti-virus, spyware, and malware detection programs) can indicate who has used or controlled the computer or storage media. This ?user attribution? evidence is analogous to the search for ?indicia of ?occupancy? while executing a search warrant at a residence. The existence or absence of anti-virus, spyware, and malware detection programs may indicate whether the computer was remotely accessed, thus inculpating or exculpating the computer owner. Further, computer and storage media activity can indicate how and when the computer or storage mediawas accessed or used. For example, as described herein, computers typically contain information that log: computer user account session times and durations, computer activity associated with user accounts, electronic storage media that connected with the computer, and the IP addresses through which the computer accessed?networks and the intemet. Such information allows investigators to understand the chronological context of computer or electronic storage media access, use, and events relating to the crime under investigation. Additionally, some information stored within a computer or electronic storage media may provide crucial evidence relating to the physical location .of other evidence and the suspect. For example, images stored on a computer may both show a particular location and have geolocation information incorporated into its ?le data. Such ?le data typically also contains information indicating when the ?le. or image was created. The existence of such image ?les, along with external device connection logs, may also indicate the presence of additional electronic storage media (mg, a digital camera or cellular phone with an incorporated camera). The geographic and timelineinformati?on described herein may either inculpate or exculpate the I. 20 computer user. Last, information stored within a computer may provide relevant insight into the computer user?s state of mind as it relates the o??ense under investigation. For example, information within the computer may indicate the owner?s motive and intent to - commit a crime (egg intemet searches indicating criminal planning), or consciousness of guilt nmning a ?wiping? program to destroy evidence on the computer or password such evidence in an effort to conceal it ?om law enforcement). c. A person with appropriate familiarity with how- a computer worlm can, after examining this forensic evidence in its proper context, draw conclusions about how computers were used, the purpose of their use, who used them, and when. . i d. The process of identifying the exact ?les, blocks, registry entries, logs, 'or other forms of forensic evidence on a storage medium that are necessary to draw an accurate conclusion is a dynamic process. While it is possible to specify in advance the records to be sought, computer evidence is not always data that can be merely reviewed by a review team and passed along to investigators. Whether data stored on a computer is evidence may depend on other information stored on the computer and the application of knowledge about how a computer behaves. Therefore, contextual information necessary to understand other evidence also falls within the scope of the warrant. e. Further, in ?nding evidence of how a computer was used, the purpose of its use, who used it, and when, sometimes it is necessary to establish that a particular thing is not present on a storage medium. For example, the presence or absence of coimter- forensic programs or anti-virus programs (and associated data) may be relevant to establishing the user?s intent. . 21 f. . I know that when an individual uses a computer to obtain or exploit personal information over the internet, the individual?s computer will generally serve both as an instrumentality for committing the crime, and also as a storage medium for evidence of the crime. The computer is an instrumentality of the crime because it is used as a means of committing the criminal offense. The computer is also likely to be a storage medium for evidence of crime. rom my training and experience, I believe that a computer used to commit a crime of this type may contain: data that is evidence of how the computer used; data that was sent or received; notes as to how the criminal conduct was achieved; records of intemet discussions about the crime; and other records that indicate the nature of the offense. . 51. Necessity of seizing or copying entire computers or storage media. In most cases, a thorough search of a premises for information that might be stored on storage media often requires the seizure of the physical storage media and later off-site review consistent with the warrant. In lieu of removing storage media ?'om the premises, it is sometimes possible to make an image copy of storage media. Generally speaking, imaging is the taking of a complete electronicpicture of the computer?s data, including all hidden sectors and deleted ?les. Either seizure or imaging is often necessary to ensure the accuracy and completeness of data recorded on the storage media, and to prevent the loss of the data either from accidental or intentional destruction. This is true because of the following: a. The time required for an examination. As noted above, not all evidence takes the form of documents and ?les that can be easily viewed on site. Analyzing evidence of how a computer has been used, what it has been used for, and who has used it 22 requires considerable time, and taking that much time on premises could be unreasonable. . i As explained above, because the warrant calls for forensic electronic evidence, it is exceedingly likely that it will be necessary?to thoroughly examine storage media to obtain evidence. Storage media can store a large volume of information. Reviewing that information for things described in the warrant can take weeks or months, depending on the volume of data stored, and would be impractical and invasive to attempt on-site. b. Technical requirements. Computers can be con?gured in several I different ways, featuring a variety of different operating systems, application software, and con?gurations. Therefore, searching them sometimes requires tools or knowledge that might not be present on the search site. The vast array of computer hardware and software available makes it dif?cult to know before a search what tools or knowledge will be required to analyze the system and its data on the. Premises. However, taking the storage media off- site and reviewing it in a controlled environment will allow its examination with the proper tools and knowledge. c. Variety of forms of electronic media. Records sought under this warrant could be stored in ?a variety of storage media formats that may require off-site revieng with specialized forensic tools. 52. Nature of examination. Based on the foregOing, and consistent with Rule the warrant I am applying for would permit seizing, imaging, or otherwise copying storage media that reasonably appear to contain some or all of the evidence described in the warrant, and would authorize a later review of the media or information consistent with the warrant. . The later review may require techniques, including but not 23 limited to computer-assisted scans of the entire medium, that might expose many parts of a hard drive to human inspection in order to determine whether it is evidence described by the warrant. 53. Based on the forgoing, I respectft?ly submit that there is probable cause to believe that a search of the SUBJECT PREMISES, further described in Attachment A, will lead to'the discovery of the things described in Attachment B, all of which constitute evidence, ?'uits and instrumentalities of the Subject O??enses, and request that a search warrant be issued i?or THE PREMISES KNOWN AND DESCRIBED AS 3 OREGON TRAIL, WATERFORD, NY 12188 (the INCLUDING ANY LOCKED AND CLOSED CONTAINERS AND CLOSED ITEMS CONTAINED 5.4. . I further respect??ly request that the Court issue an order sealing, until further order of the Court, all papers submitted in Support .of this application, including the application and search warrant. I believe that sealing these documents isnecessary'because the items and ini?ormation to be seized are relevant to an ongoing investigation, and that the targets of this investigationare not aware of its existence or its nature and, scope. Based on my and experience, I have learned that criminals actively, search'for criminal af?davits and search warrants via the intemet, and disseminate them to other criminals as they deem appropriate, e. by posting them publicly through online forums. Premature disclosure of the contents of this af?davit and related documents may have a 24. signi?cant and negative impact on the continuing investigation and may severelyjeopardize its effectiveness, lead to the destruction of evidence, or cause criminals to change patterns of behavior. MICHAEL LEVER Special Agent Federal Bureau of Investigation Sworn to before me this. NORTHERN DISTRICT OF NEW YORK 25- ATTACHMENT A Prooertv to Be. Searched The premises to be searched is known and deScribed as 3 OREGON TRAIL, WATERFORD, NY 12188 (the INCLUDING ANY LOCKED AND CLOSED CONTAINERS AND CLOSED ITEMS CONTAINED THEREIN, is a two-story residential property, color brown. The residence is accessible via a driveway which leads to a single garage. There is a walkway which leads from the driveway to the front door of the premises. Two photographs of the SUBJECT PREMISES which were taken in approximately tee 211 111W. ATTACHMENT Particular Things to be Seized Things to be seized fromthe SUBJECT PREMISES, all of which constitute evidence, fruits and instrumentalities of violations of 18 U.S.C. 1591 (sex by feted-fraud or coercion and interference in an investigation into sex traf?cking by force, hand or coercion), 18 U.S.C. 1589 forced labor (collectively, the ?Subject Offenses?) involving KEITH occurring in or after January 1, 2015, include: . a. Records, things and other information that constitute evidence, ?'uits and instrumentalities of the Subject Offenses, including but not limited to, ?collater . as described in the af?davit; sex traf?cking paraphernalia; evidence regarding the formation and structure of notes or writings related to communications between RANIBRE and any DOS masters/slaves; evidence showing an attempt to dissociate invm from and evidence of ?ight from prosecution; Computers or storage media used as a means to commit or facilitate the commission of the Subject Offenses (including to store ?collateral,? as described in the af?davit); and c. Bundles of United StateS currency evidencing the existence of schemes to commit the Subject Offenses or proceeds of the Subject Offenses. For any computer or storage medium whose seizure is otherwise authorized by this warrant, and any computer or storage medium that contains or in which is stored records or information that is otherwise called for by this warrant (hereina?er, - . al - Evidence of who used, owned, or controlled the COMPUTER at the time the things described in this warrant were created, edited, or deleted, such as logs, registry entries, con?guration ?les, saved usernames and passwords, documents, browsing history, user pro?les, email, email contacts, ?chat,? instant messaging logs, photographs, and correspondence; Evidence of software that would allow others to control the COMPUTER, such as viruses, Trojan horses, and other forms of malicious software, as well as evidence of the presence or absence of security software designed to detect malicious software; Evidence of the lack of such malicious software; Evidence indicating how and when the computer was accessed or used to determine the chronological context of computer access, use, and events relating to crime under investigation and to the computer user; e. Evidence indicating the computer user?s state of mind as it relates to the Subject Offenses; . f. Evidence of the attachnient to the COMPUTER of other storage devices or containers for electronic evidence; g. Evidence of counter-forensic programs (and associated data) that are designed to eliminate data from the h. Evidence of the times the COMPUTER was used; i. Passwords, keys, and other access devices that may be necessary to access the . I j. Documentation and manuals that may be necessary to access the COMPUTER or to conduct a forensic examination of the k. Records of or information about Internet Protocol addresses used by the 1. Records of or information about the internet activity, including ?rewall logs, caches, browser history and cookies, ?bookmarked? or ?favorite? web pages, search terms that the user entered into any Internet search engine, and . records of user-typed web addresses; m. Contextual information necessary to understand the evidence described in this attachment; and - n. Routers, modems, and network equipment used to connect computers to the Internet. As used above, the tenns ?records? and ?information? includes all forms of creation or storage, .including any form of computer or electronic storage (such as hard disksor other media that can store data); any handmade form (such as writing); any mechanical form (such as printing or typing); and any photographic form (such as micro?lm, micro?che, prints, slides, negatives, videotapes, motion pictures, or photocopies). - The term ?computer? includes all types of electronic, magnetic, optical, electrochemical, or other high speed data processing devices performing logical, arithmetic, or storage functions, including desktop computers, notebook computers, mobile phones, tablets, server computers, and network hardware. - The term ?storage medium? includes any physical object upon which computer data be recorded. Examples include hard disks, RAM, ?oppy disks, ?ash memory, CD-ROMs, and other magnetic or optical media. (Exhibit Complaint and Af?davit in Support of Arrest Warrant, dated 2/14/18) F. UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK - - .X. UNITED STATES OF AMERICA .. against- KEITH RANIERE, also known as . ?The Vanguar Defendant. EASTERN DISTRICT OF NEW YORK, SS: 18m133 :0 BE FILED UNDER SEAL COMPLAINT AND AFFIDAVIT IN SUPPORT OF ARREST WARRANT (18 use~ 1589(a)(2), 1591(a)(l), 1594 15943:), 2 and 3551 aged) 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 inclusiye, within the Eastern District of New York and elsewhere, the defenth KEITH RANIERB, together with others, did 1:11theg and intentionally conspire to 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 a??ecting interstate and foreign commerce, knowing that means of force, threats of force, - fraud and coercion,? described in Title 13, United Stains Code, Section 1591(e)(2), andone or more combinations of such means, would be used to cause such persons to engage in one or more commercial sex acts, contrary to Title 18, United States code, Section 1591(a)(l). (Title 18, United States Code, Sections 1594(0), 1591(b)(1) and 3551 otter.) In or about and between February 2016 and June 2017, both dates being approximate and inclusive, the Eastern District of New York and elsewhere, the defendant RANIBRE, together with others, did knowingly and inton?onally recruit, entice, harbor, transport, provide, obtain, maintain, patronizeand solicit persons, to wit: Jane Does 1 and 2, individuals Whose identities are known to the undersigned, in and a?ec?ng 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 one or more commercial sex acts. (Title 18, United States Code, Sections 1591(a)(l), 1591(b)(1), 2 and 3551 etst - In or about and between February 2016 and Jam 2017, both dates being approximate and inclusive, within the 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 Doc 1, 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 labor and services, Jane Doe I and one or more other persons would suffer serious harm, contrary to Iitle 18, United States Code, Sections 1589(a)(2) and 1589(a)(4). (Title 18, United States Code, Sections 1594(b) and 3551 93m.) The source of your deponent?s information and the grounds for his belief are as followsSpecial Agent with the Federal Bureau of Investigation and have been involved in the investigationof cases involving sex traf?cking and civil rights violations. . 2. a I have personally participated in the investigation of the offenses discussed below. The information set forth in this Complaint and A?davit in Support of Arrest Warrant is derived ?om my participation in the investigation as well as from, among other things, a review of other records, emails, and reports ?om 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 ??om the victims and witnesses, and the results of several search warrants . including one executed on an email account belonging to RANIERE. Because this a?idavit is submitted only to-establish probable cause to arrest, I have not inch 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, when I refer below to the Statements of others, such references are in sum and substance and in part. I. Bac ound 3. In or about 1998, the defendant KEITH RANIERE, also known as ?The Vanguard,? founded Enemrtive Success Programs, Inc. a series of workshops 4 designed, according to its promotional literature, to ?actualize human potential.? In or about 2003, RANIERE founded an organization called invm(pronounced NEX-i-um), which served as an umbrella organization for ESP and other RANIERE?af?liated entities. 4. On itsof?cial 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. RANIERE and many members of invm (?inans?) live approximately 20 miles outside of Albany, 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 events in Brooklyn, New York. 6. Each of the RANIERE entities offers classes promising personal and professional development. Based on information obtained during the course of this investigation, classes offered by RANIERE?a?iliated entities can cost up to $5,000 for a ?ve-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 di??erent 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 ?nd 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 courses and the pressure to continue taking them, participants often would continue to accumulate new debts and remain obliged to invm. 7. invm operates largely in secrecy. inans were often required to sign non-disclosure agreements and to make promises not to reveal certain things about invm?s teachings. 8. invm 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. RANIERE formerly ran a multilevel marketing scheme called Consumers Buyline, which was 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. Every year in August; inans pay $2,000 or more to gather in Silver Bay, New York to celebrate ?Vanguard Wee in honor of RANIERE, whose birthday is August 26, 1960. 10. Based on information obtained during the course of this investigation, since founding, has maintained a rotating group of ?fteen to twenty women 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 about the need for men to have multiple sexual partners and the need for women to be monogamous. 11. m5. A. Foundin and Structure 11. In or about 2015, a secret society was developed within invm called or the ?Vow? (collectively 12. DOS is an organized 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'aclivities a??ect, intetstate and foreign commerce. 13. DOS operates as a pyramid with levels of ?slaves? headed by ?masters.? Slaves are expected to recruit slaves of 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 RANIERE alone forms the top ofthe pyramid as the highest master; Other than all participants in DOS are women. status as head of the pyramid was concealed from all newly recruited slaves, other than those directlyunder RANIERB. B. gunning and Collateral 15. From the time of its inception through in or about Spring i017, DOS masters recruited slaves mostly from invm?s ranks. When 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 (?obsequious? is an English word and the Latin would properly be ?obsequiosarum,? and ?sororium? would properly be ?sororum?), but roughly translates to ?Lord/Master of the Obedient Female Companions?. slaves, masters often targeted women who were currently experiencing di?culties in their lives, including dissatisfaction with the paceof their advancement in invm. 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. . I 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 and/or family members; and letters making damaging accusations (true or mine) against friends and family members. In many cases, the masters helped the prospective slaves develop for would be appropriate collateral or instructed the prospective slaves on lies totell in order to make the collateral even more damaging. 17. After prospective slaves provided collateral in order to learn more about the Organization, the masters informed them that DOS wasa women-only organization role as the highest master was not mentioned) and that the goal of DOS was to . eradicate weaknesses members. The invm 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. prrospective slaves 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 invm 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 been described to them. For example, most DOS slaves were not initially told thatthey 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 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 wereaalcin to acting as personal assistants to the masters bringing them coffee, buying them groceries, making them lunch,,carrying their luggage, cleaning their houses and retrieving lost items for them, among other tasks. The understanding among DOS members was that of care provided by a master?s slaves, and those slaves? own slaves,.should ultimately amount to the having the work oi 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 Traf?cking Within DOS 22. Beyond acts of care, DOS slaves were also regularly given assignments to complete by their masters. Some of the masters gave 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 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 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 ?nancial 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 10 RANIERE, DOS masters also received bene?ts from in the form of increased- status and ?nancial opportunities within invm more broadly. RANIERE. 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 Doe I began having sex with RANIBRE, he provided her with money and offered her a job, but as soon 'as she defected from DOS and stopped having sci: With him, RANIBRE told her she had to pay the money back. E. Qt_her Assimts gd ess? 25. DOS slaves were also regularly giVen assignments to complete by their masters that included reviewing ESP materials and doing other work for NM or . RANIERE. This work included reviewing and editing dense articles written by RANIBRE and, at least in one case described further below, transcribing interviews of a member of invm for a memorial service being hosted by RANIERB. 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 respond 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 su??e'ring from severe sleep deprivation. . 27. DOS slaves also had to engage in acts of self-denial or 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). 11 28; Based on information obtained over the course of the investigation, DOS have explained that they believed they had to' complete their assignments and cemply with readiness drills and acts of self-denial or risk release oftheir collateral. Additionally, several DOS victims believed that their success in the NXivm 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 leastone instance, a master who, unbelcnownst to her slaves, was herselfa 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 RANIERB, for her slaves? faihire to succeed at ?readiness.? F. 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 ?illy 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 canterizing 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. After 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.? 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 down) superimposed. Ill. 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 ?ii?t?hbe at Dos same defeetloh Naiahls; reamed stag 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 13 FBI began interviewing witnesses, RANIERE ?ew to Mexico with an heiress (the who is a member of invm?s Executive Board and is a known ?nancial backer of RANIERE and invm. Prior to this trip, had not ?own out of the country since . 2015, when he visited the Heiress?s private island in Fiji; RANIERE is currently believed to be residing in Monterrey, Mexico, where invm a center, with a branded DOS . slave. . .35. Since defecting, several DOS victims have received ?cease and desis letters from a Mexican attorney. Emails exchanged between RANIERE and the Heiress, received pursuant to a search warrant executed on email account, discussed below, reveal that the Heiress and RANIERE orchestrated the sending of those letters. Additionally, the Heiress has made multiple attempts to have criminal charges brought against a former DOS slave, who has discussed her experience in the media. IV. Yahoo! Email Account . 36. On January 18, 2018, Eastern District of New York United States Magistrate Judge Cheryl Pollak signed a search warrant for Yahoo! e-mail account keithraniere@yahoo.com (the ?account?). I 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 identi?ed as ?Mr Keith Raniere.? The subscriber information also included a date of birth that matched that of RANIERE. I 37. Within the mate?alerOvided by Yahool were numerous emails, only a .few of which are described here, which support the conclusion that RANIERE created DOS. On August 10, 2015, 001 sent an email to the account. 00-1 ?5 email was titled ?vow 3? and included an attached letter. The letter pledged ?8 ?full and complete life? to 14 RANIERE. In the letter, used the terms ?slave? and ?master? to refer to herself and RANIERB. Moreover, the letter identi?ed ?collater to ?cement? the vow made by . This collateral was described as: a letter regarding OC-l?s mother and father that would ?destroy their character?; contract that transferred custody of any children . birthed by C01 to RANIERE if 001 broke her commitment to (3) a contract that transferred ownership of 001 ?3 home if the commitment to RANIBRE was broken; and (4) a letter addressed to social services alleging abuse to ?s nephews. 3:8. On July 12, 2015, another woman believed to be a DOS master directly under RANIERE, sent an email to another email account believed to belong to RANIERE, which RANIERE then forwarded to the account. In the the woman requested edits ?rom RANIERE to a series of passages in which she described a vow of total obedience to 39. The account also contained emails between another woman believed to be a DOS slave and RANIERE. Attached to some of the emails were WhatsApp chats betxiveen the woman and RANIBRE. 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 and use as a tool, to pleasure me .-. . On or about, October 23strata tart . . . . . RANDERE. Throughout the chat RANIERE alludes to the that DOS was his creation v. Co-Con_spirators 40. 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. 15 Statements on invm-related websites, including video interviews of RANIERE and refer to mentorship of C01, and to and ?s co-development of ?The Source,? a invm?a?iliated entity focused on improving actors? performance skills. Based on infonna?on obtained over thecourse of the inVestigation, including admissions by RANIERE and emails between RANIERE andCC?l, is direct slave. 41. Co-Conspirator 2 had been involved in invm for several years before being introduced to DOS. In or about 2016, RANIERE co-fonmded. ?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, 00?2 is ?s direct slave. VI. Sex Tra?cking and Forced Labor of Jane Doe I 42. Jane Doc 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, 00-1 invited Jane Doe I to join a ?Vvomen?s mentorship group,? but asked that Jane Doe 1.?rst provide collateral. At CC?l?sdirection, Jane Doe I wrote letters detailing false andhighly damaging accusations against her family members. Once Jane Doe I had I provided collateral, told her aboutDOS, referring to it as ?The Vow.? 43. Jane Doe 1 agreed to become ?s slave, provided more collateral . Manually maladies. ass were 11.89the numbers to make charges) and began receiving assignments. Throughout her time in DOS Jane Doe I was living in Brooklyn, New York. ordered Jane Doc 1 to travel to Clifton Park nearly every week from Brooklyn. When Jane Doe I was in Clifton Park, she stayed with C01 and CC-2, another of ?s slaves. 16 44. CC-litold Jane Doe I that Jane Doe I. had to be celibate for six months. Eventually, Jane Doe I began receiving assignments that involved contact with At ?rst tasked Jane Doe 1 with getting RANIERE to send Jane Doc 1 an email, which she eventually succeeded at doing. . One night when Jane Doe I was staying with C01 in Clifton Park, received a text message ?'om RANIERE, woke Jane Doc 1 in the middle a the night, and told her that RANIERE was there to go on a walk with her. (:01 told Jane Doe I that Jane Doe I wasassigned to tell that Jane Doe I would do anything RANIERE asked her to Jane Doe 1. did as she was ordered and RANIERE asked her what the worst thing he could order her to do was. Jane Doe 1- told RANIBRE 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 Doe I that he did not believe she really meant she would do anything he asked. 45. The next night again received a text message from RANIBRE, ;woke Jane Doe I 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 Doc 1 did as she was assigned, and RANIERB led her to a house across the street. RANIBRE directed her to remove all her clothes and made comments about her naked body. RANIERE then blindfolded Jane Doe I, led her into a car and drove her around in a manner that made Jane Doe I believe . . . . tater leaves. the? sass: . 1.69 . . Jane Doe I, 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 Doe I did not previously know was present, began performing oral sex on Jane Doe I as RANIERB circled the table making comments. Jane Doe I did not want to participate in this sexual activity, but believed it was 17 part of her commitment to DOS and that if she broke her commitment to DOS her collateral could be released. 46. Jane Doe I was never put on a diet by but Jane Doe I was 5?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 Doe 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 ?oor of a house in Cli?on Park (the ?rst floor was under construction). The Library had a hot tub and a loft bed. RANIERE told Jane Doe I that he was CC?l?s master and Jane Doe 1?s I ?grandmaster.? RANIERE told Jane Doe I that he hadconceived the concept of DOS. . RANIERE explained to Jane Doe I that he could order her to have sex with him, although he claimed that was not what he was doing. Jane Doe 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 Doe believed that-at some-point all the other slaves directly under which included CC-2, learned that RANIERE was ?3 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 Doel later learned that was sending these photographs to RANIERE, because Jane Doe I observed sending these photographs using 00-] ?s cellphone to someone over a messaging service and then receiving responses which would sometimes relay to her slaves. The responses included that the 18 photographs were not graphic enough or that the slaves were not smiling enough, and that they had to be retaken. On one occasion, Jane Doe I saw a text exchange on ?3 phone between and in which sent a nude photo she had just taken'of all of the slaves on Jane Doe 1?s level and RANIERE wrote back, ?All mine?? with a smiling devil emoji. 49. At one point, Jane Doe I expressed to RANIERE that she was having dif?culty affording the frequent trips to Clifton Park. RANIERE was frustrated with her and took a bag with $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, RANIERE. gave her $1,000 from the bag. Jane Doe I also occasionally expressed frustration at having . to becelibate 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 ?equently change the date on which he'said the year started. 50. As part of her DOS assignments, Jane Doc 1 was tasked by with reading and reviewing dense articles written by RANIERE that were labeled at the bottom with copyright. Each article took hours to review and Jane Doe I tasked with reviewing up to approximately 95 articles. Jane Doe I was required to ?ll out a standardized form after reading each article, which appeared designed to determine whether the articles were appropriate to include in the 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 - 19 an assignment from 00-1 to transcribe interviews given by a long-Ltenn sexual partner of who had died, in preparation for that woman?s memorial service. Jane Doe I was awake for 23 hours straight completing that project, and RANIBRE exchanged messages I. with her throughout the night encouraging her to stay awake and complete the assignment. I also directly tasked Jane Doe I with an assignment to befriend and learn information about an ostracized member of the ESP/invm 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 Doe I believed that each one Iof these assignments was part of her commitment to DOS and that if she failed at her . commitment 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 l?s knowledge) their collateral released, Jane Doe I began to believe she might also be able to leave without having her collateral released. When she told not and 002 that she was leaving DOS, they engaged - in a two?hour ?intervention,? during which Jane Doe II was berated for leaving. Throughout the conversation, JaneDoe I sought 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 brealcing her lifetime . unlit-lotto ao- recto-Oooco-OOoo . Jane Doe 1 and told her she needed to return the money he had previously given her. VII. Sex Tra?icking of Jane Doe 2 52. Jane Doe 2 is an actress and model who began taking invm classes in or about 2016, during which time she became friendly with can. When Jane Doe 2:Was in 20 Cli?on Park for a invm elass in or about November 2016, invited Jane Doe_2 on a walk. As they walked, 00?. told Jane Doe 2 that she was part of a secret society that had - transformed life and enabled CC-2 to uphold commitments. CC-2 told Jane Doe 2 that in order to learn more, Jane Doe 2 had to provide collateral, Which Jane Doe 2 did in the form of a video in which Jane Doe 2 divulged a damaging secret. After providing this video, CC-2 told Jane Doe 2 about DOS and Jane Doe 2 agreed to become slave. 53. . Eventually CC-Z told Jane Doe 2 that CC-llwas and thus Jane Doe 2?s grandmaster. When Jane Doe 2 was introduced to DOS, she was living Los Angeles, California. After Jane Doe 2 joined DOS, suggested that Jane Doe 2 I temporarily move to Clifton Park, New York and spend more time with 00-1 and 00-2. Jane Doe 2 began spending more time in Clifton Park, but regularly traveled back to Los Angeles for jobs. When Jane Doe 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 thetrain or bus to Albany. . 54. Two of Jane l)oe 2?s ?rst acts of self-denial were to re?ain ?'om sex and masturbation. 55. At one point when Jane Doe 2 was in fl??on Park, RANIERB sent Jane Doe 2 a message in the middle of the night asking her to go on a walk with . Paintbrush WIFE $91.4 Jasabw? answer: . #11? was. swat . . . . .-. . . . . . . Jane Doe 2 expressed to RAMERE that she to open a T-shirt business. expressed interest and told her he (would partner with her. Jane Doe 2 left for Los Angeles for a job and while she there RANIERE sent her a text message saying, ?If you want to start this business with me then come back, the sooner the better.? - - an.na..lo.-a-ont 21 56. . Jane Doe 2 returned to Cli?O'n Park. She was soon given new assignments, including being kept on a regimented diet of 860-1000 calories per day. Alter several months, Jane Doc 2 received a text message ?om stating wanted to speak to Jane Doc 2 about a ?special assignment.? and C02 then contacted Jane Doe 2 and told her the assignment was to ?fseduce Kei and have. him take a picture of Jane Doe 2 to prove she had done it told Jane Doc 2 that this assignment was a privilege-that few women had the honor of experiencing, but that C01 and C02 both had. At the end of the call told Jane Doe 2, give you permission to enjoy it,? which Jane Doe 2 interpreted to mean, give you permission to enjoy sex Not suspecting was involved withDOS until this JaneDoe 2 asked on the can if RANIERE knew about DOS. said that he did not. . i 57. 7 After the call, in an e?brt to avoid having sex with RANIBRE, Jane 3 Doc 2' made arrangements to leave DOS. 'Jane Doc 2 retrieved a car that she had loaned to 00-1 and her eat and possessions from Clifton Park. Before defecting, Jane Doc 2 also captured images of collateral belonging to other DOS members, including CC-Z, ?om an online Dropbox account, believing that she could protect the release of her own collateral by having other DOS members? collateral as leverage. Jane Doc 2 o?icially left DOS in or I about May 2016. WHEREFORE, your deponent respectfully requests that an arrest Warrant issued for the defendant KEITH RANIBRE so that he may be dealt with according to law. Your a?iant further requests that this af?davit and any associated arrest warrant be ?led . 22 under see], because public ?ling would give the target of the investigation an Opportunity to flee, to destroy evidence and to harm or threaten witnesses. min, MICHAEL LEVER Special Agent, Fedeial Bureau of Investigation Sworn to before me this . L?Lday ofFebTuary, 2018 THE ONORABLE LOIS BLOOM UNITED STATES MAGISTRATE JUDGE EASTERN DISTRICT OF NEW YORK