MKM:MKP/TH/KKO
F. #2017R01840

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK

x
SUPERSEDING

UNITED STATES OF AMERICA

INDICTMENT

- against Cr. No. 18-204 fNGG) (S-l)

(r.

18, u.s.C., $$ e81(a)(lXC),
e82(a)(2)(B), e82(bx I ), 1 028(bX5),
1028(0, 1349, 1sel(a)(l), 1se1(a)(2),
I 59 1 (bX l), 1 s94(a), I 594(c), 1 s94(d),
1962(d),1963,2and 3551 etseq.; T.
21, U.S.C., $ 8s3(p); T. 28, U.S.C.,
$ 2461(c))

KEITHRANIERE,
also known as "Vanguard,"

CLAREBRONFMAN,

ALLISONMACK
KATHY RUSSELL,
LAUREN SALZMAN ANd
NANCY SALZMAN,
also known as "Prefect,"
Defendants.

X
THE GRAND JURY CHARGES:
INTRODUCTION

At all times relevant to this Superseding Indictment (the "Indictment"), unless
otherwise indicated:
The Enterprise

L

The defendant KEITH RANIERE, also known as "Vanguard," was the

founder of several pyramid-structured organizations ('the Pyramid Organizations"),

including, but not limited to,

(l) Nxivm, Executive Success

Progtams, Inc., Ultima and other

related entities (collectively, 'Nxivm"); and (2) an organization referred to as "DOS," the

"Vof'

and "the sorority" (collectively,

"DOS).

In leading the Pyramid Organizations,

RANIERE relied on certain individuals, sometimes referred to

as

his "inner circle," who

 2

were accorded special positions of trust and privilege with RANIERE and who carried out
his directives.

2.

Members of RANIERE's inner circle also held high positions in one or

more of the Pyramid Organizations, including serving as executives, directors and officers

Nxivm.

of

*frst-line masters"
Members of RANIERE's inner circle also, at times, served as

directly under RANIERE, meaning that they comprised the second-highest level within the
DOS "pyramid" and that, other than RANIERE, they wielded the most power within DOS.

3.

RANIERE and his inner circle, including the defendants CLARE

BRONFMAN, ALLISON MACK, KATHY RUSSELL, LAUREN SALZMAN ANdNANCY

SALZMAN, also known

as

"Prefect," and others known and unlnown, comprised an

organized criminal enterprise (the "Enterprise"). The Enterprise, including its leadership,
membership and associates, constituted an "enterprise" as defined in Title 18, United States
Code, Section 1961(4), that is, a group ofindividuals associated in fact that was engaged in,
and the activities

of which affected, interstate and foreign commerce. The Enterprise

constituted an ongoing organization whose members functioned as a continuing unit for a
common purpose of achieving the objectives of the Enterprise.
Pumoses. Methods and

4.

The principal purpose

M eans of the Entemrise

ofthe Enterprise was to obtain financial and

personal benefrts for the members ofthe Enterprise by promoting the defendant KEITH

RANIERE, also known

as

"Vanguard," and by recruiting new members into the Pyramid

Organizations. By promoting RANIERE and recruiting others into the Pytu-id
Organizations, the members ofthe Enterprise expected to receive financial opportunities and
increased power and status within the Enterprise.

 3

5.

The Enterprise operated within the Eastem District of New York, the

Northem District of New York and elsewhere, including overseas.

6.

Among the means and methods by which the defendants and their

associates participated in the conduct

(a)

ofthe affairs ofthe Enterprise were the following:

Promoting, enhancing and protecting the Enterprise by

committing, attempting and conspiring to commit crimes, including but not limited to
identity theft, harboring ofaliens for financial gatr, extortion, forced labor, sex tra{hcking,
money laundering, wire fraud and obstruction ofjustice;

(b)

Demanding absolute commitment to RANIERE, including by

exalting RANIERE's teachings and ideology, and not tolerating dissent;

(c)

Inducing shame and guilt in order to influence and control

members and associates of the Enterprise;

(d)

Obtaining sensitive information about members and associates

of the Enterprise in order to maintain control over them;

(e)

Recruiting and grooming sexual partners for RANIERE;

(0

Using harassment, coercion and abusive litigation to intimidate

and attack perceived enemies and critics of

(g)

RAMERE; and

Encouraging associates and others to take expensive Nxivm

courses, and incur debt to do so, as a means of exerting control over them and to obtain

financial benefits for the members of the Enterprise.

 4

The Defendants and Their Co-Co nsoirators

7.
and was the leader

The defendant KEITH RANIERE, also known as 'Yanguard," founded

ofNxivm

8.

and

DOS. RANIERE was also the head of the Enterprise.

The defendant CLARE BRONFMAN was a member ofthe Enterprise

and a high-ranking member

ofNxivm. From at least in or about 2009 to 2018,

BRONFMAN served on Nxivm's Executive Board.

9.
a

The defendant ALLISON MACK was a member of the Enterprise and

high-ranking member of

Nxivm. At various

times relevant to the Indictnent, MACK was

also a firstJine master in DOS.

10.
a

The defendant KATHY RUSSELL was a member of the Enterprise and

high-ranking member of

Nxivm. From at least in or about July 2002to2014, RUSSELL

served as Nxivm's bookkeeper.
I

1.

The defendant LAUREN SALZMAN was a member of the Enterprise

and a high-ranking member of

Nxivm. From at least in or about 2009 to 2018, LAUREN

SALZMAN served on Nxivm's Executive Board. At various times relevant to the
Indictment, LAUREN SALZMAN was also a first-line master in DOS.

12.

The defendant NANCY SALZMAN, also known as '?refect," was a

member of the Enterprise and the President of

Nxivm. NANCY SALZMAN

is LAUREN

SALZMAN's mother.

13.

The defendants also acted in concert with other co-conspirators, both

known and unknowq who were members and associates of the Enterprise, some of whose
identities are known to the Grand Jury.

 5

COUNTONE
(Racketeering Conspiracy)

14.
and incorporated as

15.

The allegations contained in paragraphs one through 13 are realleged

if fully

set

forth in this paragraph.

In or about and between 2003 and March 2018, both dates being

approximate and inclusive, within the Eastem District of New York and elsewhere, the
defendants

KEITH RANIERE, also known

as

..\,zanguard,"

CLARE BRONFMAN,

ALLISON MACK, KATHY RUSSELL, LAUREN SALZMAN ANdNANCY SALZMAN,
also known as "Prefect," together with others, being persons employed by and associated

with the Enterprise, an enterprise that engaged in, and the activities ofwhich affected,
interstate and foreign commerce, did knowingly and intentionally conspire to violate Title
18, United States Code, Section 1962(c), that is, to conduct and participate, directly and

indirectly, in the conduct ofthe affairs of such enterprise through
activity,

as that

a pattern

ofracketeering

term is defined in Title I 8, United States Code, Sections I 96 1 ( I ) and

1961(s).

16.

The pattem ofracketeering activity through which the defendants

KEITH RAMERE, CLARE BRONFMAN, ALLISON MACK, KATHY RUSSELL,
LAUREN SALZMAN and NANCY SALZMAN, together with others, agreed to conduct the
affairs ofthe Enterprise consisted ofthe racketeering acts set forth in paragraphs 17 ro 34
below, as Racketeering Acts One through

Ten.

Each defendant agreed that a conspirator

would commit at least two acts ofracketeering in the conduct of the affairs ofthe Enterprise.

 6

RACKETEERING ACT ONE
(Conspiracy to Commit Identity Theft and to
Unla*ftlly Possess Identification of Jane Doe l)

A.

Conspiracy to Commit Identity Theft

l'7.

In or about 2004, within the Northem District of New York and

elsewhere, the defendants KEITH RANIERE and

KATHY RUSSELL, together with others,

did knowingly and intentionally conspire to transfer, possess and use, without lawfrrl
authority and in and affecting interstate and foreign commerce, one or more means
identification of another person, to wit: Jane Doe

l,

of

an individual whose identity is known to

the Grand Jury, with the intent to commit, and to aid and abet, and in connection with,

unlawful activity that consituted one or more violations of federal law, to wit: bringing in,
transporting and harboring an alien, in violation of Title 8, United States Code, Section

132a(a)(l)(A), contrary to Title 18, United States Code, Section 1028(a)(7), all in violation
of Title 18, United States Code, Section 1028(fl.

B.

Conspiracy to Unlawfully Pos sess Identification Document

18.

In or about December 2004, within the Northem District of New York

and elsewhere, the defendants KEITH RANIERE and

KATHY RUSSELL, together with

others, did knowingly and intentionally conspire to possess a false identification document,

to wit: a sheriff s identification card with the last name and date of birth of Jane Doe l, with
the intent that such document be used to defraud the United States, contrary to Title 18,

United States Code, Section 1028(a)(4), in violation of Title 18, United States Code, Section
1028(f).

 7

RACKETEERING ACT TWO
(Conspiracy to Commit Identity Theft)

A

Conspiracy to Commit Identitv Theft

19.

In or about and between August 2005 and November 2008, both dates

being approximate and inclusive, within the Northem District of New York and elsewhere,
the defendants KEITH RANIERE, CLARE BRONFMAN,

KATHY RUSSELL

and

NANCY

SALZMAN, together with others, did knowingly and intentionally conspire to transfer,
possess and use,

without la*firl authority and in and affecting interstate and foreigal

co[rmerce, one or more means of identification of one or more other persons, with the intent
to commit, and to aid and abet, and in connection with, unlar*drl activity that constituted one
or more violations of federal law, to wit: (1) intercepting wire and electronic
communications, in violation of Title 18, United States Code, Section 2511; and (2)

unla*frrlly accessing wire and electronic communications, in violation of Title

18, United

Titte 18, United States Code, Section 1028(a)(7), all

States Code, Section 2701, contrary to

in violation ofTitle 18, United States Code, Section 1028(f).

B.

Identiw Theft of John Doe

20.

1

In or about and between January 2006 and November 2008, both dates

being approximate and inclusive, within the Northem District of New York and elsewhere,
the defendants KEITH RANIERE and

KATHY RUSSELL, together with others, did

knowingly and intentionally transfer, possess and use, without lawful authority and in and
affecting interstate cornmerce, one or more means ofidentification of another person, to wit:
John Doe

l,

an individual whose identity is known to the Grand Jury, with the intent to

commit, and to aid and abet, and in connection with, unlawful activity that constituted one or

 8

more violations of federal law, to wit: (1) intercepting wire and electronic communications,

in violation of Title 18, United States Code, Section 251 l; and (2) unlawfirlly accessing wire
and electronic communications, in violation of

Title

18, United States Code, Section 2701,

all in violation of Title 18, United States Code, Sections 1028(a)(7) md2.

C.

Identity Theft of John Doe 2

21.

In or about and between January 2006 and November 2008, both dates

being approximate and inclusive, within the Northem District of New York and elsewhere
the defendants KEITH RANIERE and CLARE BRONFMAN, together with others, did

knowingly and intentionally transfer, possess and use, without lawfirl authority and in and
affecting interstate commerce, one or more means of identification of another person, to wit:
John Doe 2, an individual whose identity is known to the Grand Jury, with the intent to

commit, and to aid and abet, and in connection with, unlawful activity that constituted one or
more violations of federal law, to wit:

(l)

intercepting wire and electronic communications,

in violation of Title 18, United States Code, Section 251l; and (2) unlawfully accessing wire
and electronic communications, in violation of

Title

18, United States Code, Section 2701,

all in violation ofTitle 18, United States Code, Sections 1028(a)(7) and 2.
RACKETEERING ACT THREE
(Conspiracy to Alter Records for Use in an Official Proceeding)

22.

In or about and between February 2008 and March 2018, both dates

being approximate and inclusive, within the District ofNew Jersey and elsewhere, the
defendants KEITH RANIERE and

NANCY SALZMAN, together with others, did

knowingly and intentionally conspire to comrptly alter, destroy, mutilate and conceal one or
more records, documents and other objects, to wit: video recordings of NANCY SALZMAN,

 9

with the intent to impair such objects' integrity and availability for use in an official
proceeding, to wit: NXIVM Corp.. et al. v. Ross Institute. et al., 06 CV 1051 (D.N.J.),
contrary to Title 18, United States Code, Section 1512(c)(1), all in violation of Title 18,

United States Code, Section 1512(k).

RACKETEERINGACT FOUR
(Conspiracy to Commit Identity Theft - Jane Doe 2)

23.

In or about November 2008, within the Northem District of New York

and elsewhere, the defendant KEITH RANIERE, together with others, did knowingly and

intentionally conspire to transfer, possess and use, without lawful authority and in and
affecting interstate commerce, one or more means of identification of another person, to wit:
Jane Doe 2, an individual whose identity is known to the Grand Jury,

with the intent to

commit, and to aid and abet, and in connection with, unlawful activity that constituted one or
more violations of federal law, to

wit:

(l)

intercepting wire and electronic communications,

in violation of Title 18, United States Code, Section 251 1; and (2) unlawfirlly accessing wire
and electronic communications, in violation of

Title

18, United States Code, Section 2701,

contrary to Title 18, United States Code, Section 1028(a)(7), all in violation of Title 18,

United States Code, Section 1028(f).

RACKETEERINGACT FIVF,
(Encouraging and Inducing Illegal Entry and Money Laundering Jane Doe 3)

A

Encourasing and Inducins lllesal Entrv

24.

In or about March 2009, within the Northem District of New York and

elsewhere, the defendant CLARE BRONFMAN, together with others, did knowingly and

intentionally encourage and induce an alien, to wit: Jane Doe 3, an individual whose identity
is known to the Grand Jury, to come to, enter and reside in the United States, knowing and

in

 l0
reckless disregard

ofthe fact that such coming to, entry

and residence was and would be

in

violation of law, for the purpose offinancial gain, in violation of Title 8, United States Code,
Sections 1324(a)(1)(A)(iv), 132a(a)(1)(B)(i) and 1324(a)(l)(AXv)(Il).

B.

Money Larmderinq

25.

In or about March 2009, within the Northern District of New York and

elsewhere, the defendant CLARE BRONFMAN, together with others, did knowingly and

intentionally transport, tmnsmit and transfer monetary instruments and funds, to wit: wire
transfers, from one or more places in the United States to and through one or more places
outside the United States and to one or more places in the United States from and through
one or more places outside the United States, with the intent to promote the carrying on

of

specified unlawfill activity, to wit: bringing in and harboring an alien for financial gain, in

violation of Title 8, United States Code, Section 1324, all in violation of Title 18, United
States Code, Sections 1956(aX2XA) and 2.

G ACT SIX
RACKETEE
(Trafiicking and Document Servitude - Jane Doe 4)

A

Traffickins of Jane Doe 4 for Labor and Services

26.

In or about and between March 2010 and April 2012, within the

Northern District of New York and elsewhere, the defendants KEITH RANIERE and

LAIJREN SALZMAN, together with others, did knowingly and intentionally recruit, harbor,
transport, provide and obtain a person, to wit: Jane Doe 4, an individual whose identity is

known to the Grand Jury, for labor and services in violation of Title 18, United States Code,
Cl€lpter 77,to wit: (1) document servitude, in violation of Title 18, United States Code,

 1l
Section 1592; and (2) forced labor, in violation of Title 18, United States Code, Section
1589, all in violation of

Title

18, United States Code, Sections 1590 and 2

of Jane Doe 4

B

27.

In and about and between March 2010 and April 2012, both dates being

approximate and inclusive, within the Northern District of New York and elsewhere, the
defendants KEITH RANIERE and LAUREN SALZMAN, together with others, did

knowingly and intentionally conceal, remove, confiscate and possess one or more
immigration documents and actual govemment identification documents of a person, to wit:
Jane Doe 4, in the course of, and

with intent to commit, one or more violations of Title I 8,

United States Code, Sections 1589 and 1590, all in violation of Title 18, United States Code,
Sections 1592 ond 2.

RACKETEERING ACT SEVEN
(State Law Extortion)

28.

In or about and between September 2015 and June 2017, both dates

being approximate and inclusive, within the Eastem District of New York and elsewhere, the
defendants KEITH RANIERE, ALLISON

MACK and LAUREN SALZMAN, together with

others, did knowingly and intentionally steal property by extortion, in that RANIERE,

MACK, LAUREN SALZMAN and others obtained property, to wit: personal property and
other things of value, by compelling and inducing one or more persons, to wit: lower-ranking
DOS members, to deliver such property by instilling in them a fear that, if the property were
not so delivered, RAMERE, MACK, LAUREN SALZMAN and others would

(l)

expose a

secret and publicize an asserted fact, whether true or false, tending to subject one or more
persons to hatred, contempt and ridicule; and (2) perform an act which would not in

itself

 t2
materially benefit RANIERE, MACK, LAUREN SALZMAN and others, but which was
calculated to harm one or more persons materially with respect to their health, safety,
business, calling, career, financial condition, reputation and personal relationships,

in

violation ofNew York Penal Law Sections 155.30(6), 155.05(2)(e)(v), 155.05(2xexix) and
20_00.

RACKETEERING ACT EIGHT
(Sex Trafficking, Forced Labor and State Law Extortion

A.

Sex

Trafficki

29.

-

Jane Doe 5)

o fJane Doe 5

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

being approximate and inclusive, within the Eastem District of New York and elsewhere, the
defendants KEITH RANIERE and ALLISON

MACK, together with others, did knowingly

and intentionally recruit, entice, harbor, transport, provide, obtain, maintain, patronize and

solicit a person, to wit: Jane Doe 5, an individual whose identity is known to the Grand Jury,
in and affecting interstate and foreign commerce, and did benefit, financially and by
receiving anlthing of value, from participation in a venture that engaged in such acts,
knowing and in reckless disregard ofthe fact that means of force, threats of force, fraud and
coercion, and a combination of such means, would be used to cause Jane Doe 5 to engage in
one or more commercial sex acts, in violation of

Title

18, United States Code, Sections

1591(a)(1), 1591(a)(2) and 2.
B,

Forced Labor of Jane Doe 5

30.

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 and ALLISON MACK, together with others, did knowingly

 13

and intentionally provide and obtain the labor and services
means

ofa person, to wit:

Jane Doe 5, by

of(a) force, physical restraint and threats ofphysical restraint to her and one or more

other persons, (b) serious harm and threats of serious harm to her and one or more other
persons, (c) one or more schemes, plans and patterns intended to cause her to believe that,

if

she did not perform such labor and services, she and one or more other persons would suffer

serious harm, and a combination of such means, in violation of

Title

18, United States Code,

Sections 1589(a) and 2.
C

State Law Extortion ofJane Doe 5

31.

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 AILISON MACK, together with others, did knowingly and intentionally steal

property by extortion, in that MACK and others obtained property, to wit: credit card
authorizations, jewelry and sexually explicit photographs and videos, by compelling and

inducing Jane Doe 5 to deliver such property by instilliag in her a fear that, ifthe property
were not so delivered,

MACK and others would (1) expose

a secret and publicize an asserted

fact, whether true or false, tending to subject one or more persons to hatred, contempt and

ridicute; and (2) perform an act which would not in itself materially benefit MACK, but
which was calculated to harm one or more persons materially with respect to their health,
safety, business, calling, cmeer, financial condition, reputation and personal relationships,

in

violation ofNew York Penal Law Sections 155.30(6), 155.05(2)(e)(v), 155.05(2)(e)(ix) and
20.00.

 14

RACKETEERING ACT NINE
(Forced Labor and State Law Extortion

A.

-

Jane Doe 6)

Forced Labor ofJane Doe 6

32.

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

being approximate and inclusive, within the Eastem District of New York and elsewhere, the
defendant LAUREN SALZMAN, together with others, did knowingly and intentionally
obtain the labor and services ofa person, to wit: Jane Doe 6, an individual whose identity is

known to the Grand Jury, by means of(a) force, physical restraint and threats ofphysical
restraint to her and one or more other persons, (b) serious harm and threats of serious harm to
her and one or more other persons, (c) one or more schemes, plans and pattems intended to
cause her to believe that,

if

she did not perform such labor and services, she and one or more

other persons would suffer serious harm, and a combination of such means, in violation

Title

of

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

B.

State Law Extortion ofJane Doe 6

33.

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

being approximate and inclusive, within the Eastem District of New York and elsewhere, the
defendant LAUREN SALZMAN, together with others, did knowingly and intentionally steal
prop€rty by extortion, in that LAUREN SALZMAN and others obtained property, to wit:
bank account authorizations and sexually explicit photographs and videos, by compelling and

inducing Jane Doe 6 to deliver such property by instilling in her a fear that, ifthe property
were not so delivered,

LAIIREN SALZMAN and others would (1) expose

a secret and

publicize an asserted fact, whether true or false, tending to subject one or more persons to
hatred, contempt and ridicule; and (2) perform an act which would not in itself materially

 15

benefit LAUREN SALZMAN, but which was calculated to harm one or more persons

materially with respect to their health, safety, business, calling, career, financial condition,
reputation and personal relationships, in violation of New York Penal Law Sections
I

55.30(6), 1 ss.0s(2)(e)(v), 1 ss.05(2Xe)(ix) and 20.00.
G ACT TEN
RA
(Conspiracy to Commit Identity Theft - Jane Doe 7)

34.

In or about and between November 2016 and March 2018, both dates

being approximate and inclusive, within the Northem District of New York and elsewhere,
the defendants KEITH RANIERE and CLARE BRONFMAN, together with others, did

knowingly and intentionally conspire to transfer, possess and use, without la*firl authority
and in and affecting interstate and foreign cornmerce, one or more means of identification

of

another person, to wit: Jane Doe 7, an individual whose identity is known to the Grand Jury,

with the intent to commit, and to aid and abet, and in connection with, unla*ftI activity that
constituted one or more violations of federal law, to wit: tax evasion, in violation of Title 26,

United States Code, Section 7201, contrary to Title 18, United States Code, Section
1028(a)(7), all in violation of Title 18, United States Code, Section 1028(f).

(Title

18, United States Code, Sections 1962(d),1963 and 3551 et scq.)

COUNTTW o
(Forced Labor Conspiracy)

35.

In or about and between September 2015 and June 2017, both dates

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

MACK and LAUREN

SALZMAN, together with others, did knowingly and intentionally conspire to provide and
obtain the labor and services of one or more persons, to wit: lower-ranking DOS members,

 16

by means of(a) force, physical restraint and threats ofphysical restraint to them and one or
more other persons, (b) serious harm and threats of serious harm to them and one or more
other persons, (c) one or more schemes, plans and pattems intended to cause them to believe
that, if they did not perform such labor and services, they and one or more other persons

would suffer serious harm, and a combination of such means, contrary to Title 18, United
States Code, Section 1589(a).

(Title 1 8, United

States Code, Sections 1594(c) and 3551 et g9g.)

CO1JNT THREE
(Wire Fraud Conspiracy)

36-

In or about and between September 2015 and June 2017, both dates

being approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendants K-EITH RANIERE, also known as "Vanguard,"

ALLISON MACK and LAUREN

SALZMAN, together with others, did knowingly and intentionally conspire to devise a
scheme and artifice to defraud one or more persons, to

wit: lower-ranking DOS members,

and to obtain money and property, including rights to assets, credit card authorizations and

seiually explicit photographs and videos, Iiom them by means of materially false and
fraudulent pretenses, representations and promises, and for the purpose of executing zuch
scheme and artifice, to tmnsmit and cause to be transmitted by means of wire communication

in interstate and foreign commerce writings, signs, signals, pictures and sounds, to wit:
electronic messages, telephone text messages and Telegram messages, contrary to Title 18,

United States Code, Section 1343.

(Title

18, United States Code, Sections 1349 and 3551 et 59q.)

 t7
COUNT FOUI:
(Sex Traffi cking Conspiracy)
37

.

In or about and between February 20 I 6 and June 20 1 7, 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 others, did knowingly and intentionally conspire to recruit, entice, harbor, transport,
provide, obtain, maintain, patronize and solicit one or more persons, to wit: one or more
lower-ranking DOS members, in and affecting interstate and foreign commerce, and to
benefit, financially and by receiving anything ofvalue, Iiom participation in a venture that
engaged in such acts, knowing and in reckless disregard

ofthe fact that means of force,

threats of force, fraud and coercion, and a combination ofsuch means, would be used to
cause such persons to engage in one or more commercial sex acts, which offense was

effected by force, fraud, coercion and a combination of such means, contrary to Title 1 8,

United States Code, Sections l59l(a)(l) and l59l(a)(2).

(Title

18, United States Code, Sections

1594(c),1591(bXl) and 3551 et rcg.)

COUNT FIVE
(Sex Trafficking - Jane Doe 5)

38.

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 others, did knowingly and intentionally recruit, entice, harbor, tzulsport' provide,
obtain, maintain, patronize and solicit a person, to wit: Jane Doe 5, in and affecting interstate
and foreign commerce, and did benefit, financially and by receiving anylhing ofvalue, from

participation in a venture that engaged in such acts, knowing and in reckless disregard of the

 l8
fact that means of force, threats of force, fraud and coercion, and a combination ofsuch
means, would be used to cause Jane Doe 5 to engage in one or more commercial sex acts,

which offense was effected by force, fraud, coercion and a combination of such means.

(Title

18, United States Code, Sections

1591(a)(l), 1591(a)(2), 1591(bX1),2

and 3551 et seq.)

COTINT SIX
(Attempted Sex Trafficking

39.

-

Jane Doe 8)

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 others, did knowingly and intentionally attempt to recruit, entice, harbor, transport,
provide, obtain, maintain, patronize and solicit one or more persons, to wit: Jane Doe 8, an
individual whose identity is known to the Grand Jury, in and affecting interstate and foreign
commerce, and to benefit, financially and by receiving anlthing ofvalue, from participation

in a venture that engaged in such acs, knowing and in reckless disregard ofthe fact that
means offorce, threats of force, fraud and coercion, and a combination of such means, would
be used to cause such person to engage in one or more commercial sex acts, which offense
was effected by force, fiaud, coercion and a combination of such means, in violation of
18, United States Code, Section

(Title
ses.)

Title

l59l(a)(l) and 1591(a)(2).

18, United States Code, Sections 1594(a),

1591(bxl),2 and 3551 et

 t9
COUNT SEVEN
(Conspiracy to Commit Identity Theft

40.

-

Jane Doe 7)

In or about and between November 2016 and March 2018, both dates

being approximate and inclusive, within the Northem District of New York, the defendants

KEITH RANIER-E, also known

as

"Vanguard," and CLARE BRONFMAN, together with

others, did knowingly and intentionally conspire to transfer, possess and use, without

authority and in and affecting interstate and foreign commerce, one or more means

lawfrl

of

identification of another person, to wit: Jane Doe 7, with the intent to commit, and to aid and
abet, and in connection with, unlawfi-rl activity that constituted one or more violations

of

federal law, to wit: tax evasion, in violation of Title 26, United States Code, Section 7201,
contrary to Title I 8, United States Code, Section 1028(a)(7).

(Title

18, United States Code, Sections 1028(0 and 3551 et qeq.)

CRIMINAL FORFEITT'RE ALLEGATION
AS TO COLIN

41.

The United States hereby gives notice to the defendants charged in

Count One that, upon their conviction of such offense, the govemment
accordance with

Title

will

seek forfeiture

in

18, United States Code, Section 1963(a), which requires any person

convicted ofsuch offense to forfeit: (a) any interest the person acquired or maintained in

violation of Title 18, United States Code, Section 1962; (b) any interest in, security of, claim
against, or property or contractual right of any kind affording a source of influence over any

enterprise which the person has established, operated, confiolled, conducted or participated

in the conduct of, in violation of Title 18, United States Code, Section 1962; and (c) any
property constituting, or derived from, any proceeds which the person obtained, directly or

 20

indirectly, fiom racketeering activity in violation ofTitle 18, United States Code, Section
1962.

42.

If

any

ofthe above-described forfeitable property,

as a result

of any act

or omission ofthe defendants:

(a)

cannot be located upon the exercise of due diligence;

(b)

has been transferred or sold to, or deposited with, a third party;

(c)

has been placed beyond the

(d)

has been substantially diminished in value;

(e)

has been commingled

jurisdiction ofthe court;
or

with other property which cannot be

divided without difficulty;

it is the intent ofthe United

States, pursuant to

Tifle

18, United States Code, Section

1963(m), to seek forfeiture of any other property of the defendants up to the value of the

forfeitable property described in this forfeiture allegation.

(Title 18, United States Code, Section 1963)

CRIMINAL FORFEITURE ALLEGATION
AS TO COLINTS TWO. FOUR FIVE AND SIX

43.

The United States hereby gives notice to the defendants charged

in

Counts Two, Four, Five and Six that, upon their conviction of any such offense, the
govemment 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 such offenses, and any property traceable

to such property; and (b) any property, real or personal, constituting, or derived from,

 2t
proceeds obtained directly or indirectly as a result ofsuch offenses, or any property traceable

to such property.
44.

If

any of the above-described forfeitable properfy. as a result

ofany act

or omission of the defendants:

(a)

cannot be located upon the exercise of due diligence;

O)
(c)

has been transferred or sold to, or deposited

(d)

has been substantially diminished in value;

(e)

has been commingled with other property which cannot be

has been placed beyond

with,

a

third party;

thejurisdiction ofthe court;
or

divided without difiiculty;

it is the intent ofthe United

States, pursuant to

Title 21, United States Code, Section 853(p),

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

(Title 18, United

States Code, Section 159a(0;

Title 21, United States Code,

Section 853(p))

CRIMINAL FORFEITURE ALLEGATION
AS TO COLTNT THREE

45.

The United States hereby gives notice to the defendants charged in

Count Tkee that, upon their conviction of such offense, the govemment

will

seek forfeiture

in accordance with Title 18, United States code, Section 981(a)(l)(c) and Title 28, United
States Code, Section 2461(c), which require any person convicted

of such offense to forfeit

any property, real or personal, constituting, or derived from, proceeds obtained directly or

indirectly as a result of such offense.

 22

46.

Ifany ofthe above-described forfeitable property,

as a result

of any act

or omission of the defendants:

(a)

carmot be located upon the exercise ofdue diligence;

(b)

has been transferred or sold to, or deposited

(c)

has been placed beyond the

(d)

has been substantially diminished in value;

(e)

has been commingled

with,

a

third party;

jurisdiction ofthe court;
or

with other property urhich cannot be

divided without diffi culty;

it is the intent ofthe United States, pursuant to Title 21, United States Code, Section 853(p),
to seek forfeiture of any other property ofthe defendants up to the value of the forfeitable
property described in this forfeiture allegatioo.

(Title 18, United States Code, Section 981(a)(1)(C); Title 21, United States
Code, Section 853(p); Title 28, United States Code, Section 2461(c))

CRIMINAL FORFEITURE ALLEGATION
AS TO COUNT SEVEN

47.

The United States hereby gives notice to the defendants charged

in

Count Seven that, upon their conviction of such offense, the government will seek forfeiture

in accordance with: (a) Title 18, United States Code, Section 982(a)(2)(B), which requires
any person convicted ofsuch offense to forfeit any property constituting, or derived from,
proceeds obtained directly or indirectly as a result ofsuch offense; and (b)

Title

18, United

States Code, Section 1028(b)(5), which requires any person convicted ofsuch offense to

forfeit any personal property used or intended to be used to commit the offense.

 23

48.

Ifany ofthe above-described forfeitable property,

as a result

ofany act

or omission ofthe defendants:

(a)

cannot be located upon the exercise ofdue diligence;

(b)

has been transferred or sold to, or deposited

(c)

has been placed beyond

(d)

has been substantially diminished in value;

(e)

has been commingled

with,

a

third party;

thejurisdiction ofthe court;
or

with other property which cannot be

divided without diffi culty;

it is the intent ofthe United
as incorporated by

Title

States, pursuant to

Title 21, United States Code, Section 853(p),

18, United States Code, Sections

982(bXl), to seek forfeiture ofany

other prop€rty ofthe defendants up to the value ofthe forfeitable property described in this

forfeiture allegation.

(Title

18, United States Code, Sections

982(a[2[B), 982(b)(1) and

1028(b)(5); Title 21, United States Code, Section 853(p))

ATRUEBILL (

PERSON

/n.L-"-9 O

b..&.-

RrcHARD P. DONOGHUU/
UNITED STATES ATTORNEY
EASTERN DISTRICT OF NEW YORK

 F.

20t7R01E40

FORM DBD.34

No.

l8-CR-204 (NGc) (S-l )

JUN,85

UNITED STATES DISTRICT COURT
EASTERN District o/'NEW YORK

CRIMINAL DIVISION

THE UNITED STATES OF AMERICA
KEITH RANIERE, also known as " I/anguard, " et al.,
Defendants.

SUPERSEDING INDICTMENT
(r.

I8, u.S.C., $$ e81(a)(I)(C), e82(a)(2XB), e82(b)(I), 1028(bX5)'
I 028(f), I 349, 1 se I (a)( I ), I s9 I (a)(2), I s91 (bX I ), 1 se4(a), I se4(c),
ls94(d), 1962(d), 1963,2and 3551 etxs.; T.21, U.S.C., $ 853(p); T.
28, U.S.C., $ 2461(c))
,4

lrue hill.

Filed in open courl lhis

,1r),

,,1.D.20

(-lerk

Bail, $

Moira Kim Penxa/Tanya Hajjor, Assista t U.S. Attorney (718) 254-7000