MKM:MKP/TH
F. #2017R01840
ZBIBAPR

l9

Pl{ tr: 19

T]NITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK

x
INDI CTMENT

LTNITED STATES OF AMERICA
- agalnst -

04

Cr

(r.
KEITHRANIERE,

.c.,

s

5

axl),

1s91(a)(2), 15el(bxl), 1 594(a),
1594(b), 1s94(c), 1s94(d),2 and 3551
et geq.; T. 21, U.S.C., $ 853(p))

also known as "Vanguard," and

ALLISONMACK,
Defendants

GARAUEIS, J.

x
THE GRAND JURY CI{ARGES:

SCANLON, M.J.

COI.JNT ONE
(Sex Trafficking - Jane Does 1 and 2)

l.

In or about and between February 2016 and June 2017, both dates

being approximate and inclusive, within the Eastem District of New York and elsewhere, the
defendants KEITH RANIERE, alsO known as "Vanguard," and

AILISON MACI! together

with others, did knowingly and intentionally: (1) recruit, entice, harbor, transport, provide,
obtain, advertise, maintain, patronize and solicit one or more persons, to wit: Jane Does

1

and 2, individuals whose identities are known to the Grand Jury, in and affecting interstate
and

foreip

commerce, and attempt to do the same; and (2) benefit, and attempt to benefit,

financially and by receiving a thing of value,.from participation in

a

venture which had

engaged in such acts, knowing that means of force, threats of force, fraud and coercion, and a

 2

combination ofsuch 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(a)(2),1591(bX1),

1594(a), 2 and 3551 et sgq.)

COIINT TWO
(Sex Traffi cking Conspiracy)

2.

In or about and between February 2016 and June 2017, both dates

being approximate and inclusive, within the Eastem District of New York and elsewhere, the
defendants KEITH RANIERE, also known as "Vanguard," and ALLISON MACK, together

with ottrers, did knowingly and intentionally conspire to: (1) recrui! entice, harbor, transport,
provide, obtain, advertise, maintain, patronize and solicit persons, in and affecting interstate
and foreign colnmerce; and (2) benefit, financially and by receiving a thing ofvalue, from

participation in

a

venture which was to have engaged in such acts, knowing that means

of

force, threats offorce, ftaud and coercion, and a combination ofsuch means, would be used

to cause such persons to engage in one or more commercial sex acts, contrary to Title 18,
United States Code, Sections 1591(a)(l), l59l(a)Q), and

(Title

18,

l59l(bxl).

United States Code, Sections 1594(c) and 3551 et ggq.)

COT]NT THREE
(Consptacy to Commit Forced Labor

3.

-

Jane Doe

l)

ln or about and between February 2016 and June 2017, both dates

being approximate and inclusive, within the Eastern District of New York and elsewhere, ttre
defendants KEITH RANIER-E, also known as "Vanguard," and ALLISON

MACII

together

with others, did knowingly and intentionally conspire to provide and obtain the labor and
services ofa person, to wit: Jane Doe 1, by means of serious harm and threats of serious

 J
harm to her and one or more ottrer persons, and by means ofone or more schemes, plans and

pattems intended to cause Jane Doe I to believe that,
services, Jane Doe

Title

I

if

she did not perform such labor and

and one or more other persons would suffer serious harm, contrary to

18, United States Code, Sections 1589(a)(2) and 1589(a)(4).

(Title

18, United States Code, Sections 1594(b) and 3551 et ggq.)

CRIMINAL FORFEITURE AILEGATION

4.

The United States hereby gives notice to the defendants that, upon their

conviction ofany ofthe offenses charged herein, the govertrment will seek forfeiture in
accordance with Title 18, United States Code, Section 1594(d), of (a) any property, real or
personal, that was involved in, used or intended to be used to commit or to facilitate the

commission of zuch offenses, and any property traceable to such property; and (b) any
property, real or personal, constituting or derived from, proceeds obtained directly or

indirectly as

a

rezult of such offenses, or any property traceable to such property.

5-

Ifany ofthe above-described forfeitable property,

as a result

ofany act

or omission of the defendants:

(a)

cannot be located upon the exercise ofdue diligence;

O)
(c)

has been transferred or sold to, or deposited

(d)

has been substantially diminished in value;

(e)

has been commingled

divided without diffi culty;

has been placed beyond the

with,

a

third party;

jurisdiction ofthe coud;
or

with other properly which cannot be

 4

it

is the intent

ofthe United States, pursuant to Title 21, United States Code, Section 853(p),

to seek forfeiture ofany other property ofthe defendants up to the value ofthe forfeitable
property described in this forfeiture allegation.

(Title

18, United States Code, Section 1594(d);

Title 21, United States Code,

Section 853(p))

A TRIIE BILL

l
FOREPERSON

tfi;r-l--O

/. D*,"^-l^,--\

RTCITARDP.DONOGHUE

\)

UNITED STATES ATTORNEY EASTERN DISTRICT OF NEW YORK

 F. # 2017R01840

FORM DBD-34

No.

JUN. 85

UNITED STATES DISTRICT COURT
EASTERN District of NEW YORK

CRIMINAL DIVISION

THE UNITED STATES OF AMERICA
KEITH RANIERE, also known as " Vanguard, "
and ALLISON MACK,
Defendants

INDICTMENT
(r.

18, U.S.C., $$ 1591(a), 1se1(b), 15e4(d), 15e4O), tsea@),
1594(d), 2 and,355l et ssq.; T. 21, U.S.C., $ 853(p))

Atuebi.

Filed in open coutt this

of

day,

4.D.20
Clerk

Bail, $

Moira Kim Penza and Tanya Hajjar, Assistafi a.S. Attorneys
(718) 2s4-7000