Page:Superseding Indictment, United States of America v. Keith Raniere, Clare Bronfman, Allison Mack, Kathy Russell and Lauren Salzman.pdf/1

Case 1:18-cr-00204-NGG-VMS Document 430 Filed 03/13/19 Page 1 of 30 PageID #: 4289


 * FILED
 * IN CLERK'S OFFICE
 * U.S. DISTRICT COURT E.D.N.Y.
 * ★ MAR 13 2019 ★

BROOKLYN OFFICE MKM:MKP/TH/MJL/KMT/KKO F.#2017R01840

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

-against-

KEITH RANIERE,
 * also known as "Vanguard,"
 * "Grandmaster"
 * and "Master,"

CLARE BRONFMAN, ALLISON MACK, KATHY RUSSELL and LAUREN SALZMAN,
 * Defendants.



= SUPERSEDING INDICTMENT =


 * Cr. No. 18-204 (S-2) (NGG)
 * (T. 18, U.S.C., §§ 981(a)(1)(C), 982(a)(2)(B), 982(b)(1), 1028(b)(5), 1028(f), 1349, 1591(a)(1), 1591(a)(2), 1591(b)(1), 1594(a), 1594(b), 1594(c), 1594(d), 1962(c), 1962(d), 1963, 1963(a), 2251(a), 2251(e), 2252(a)(4)(b), 2252(b)(2), 2253(a), 2253(b), 2 and 3551 .; T. 21, U.S.C., § 853(p); T. 28, U.S.C., § 2461(c))

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

The Enterprise
1. The defendant KEITH RANIERE, also known as "Vanguard," "Grandmaster" and "Master," was the founder of several pyramid-structured organizations ("the Pyramid Organizations"), including, but not limited to, (1) Nxivm; Executive Success Programs, Inc.; Jness, LLC; Society of Protectors, LLC; Ultima and other related entities (collectively, "Nxivm"); and (2) an organization referred to as "DOS," the "Vow" and "the