Page:Superseding Indictment, United States of America v. Keith Raniere, Clare Bronfman, Allison Mack, Kathy Russell and Lauren Salzman.pdf/10

Case 1:18-cr-00204-NGG-VMS Document 430 Filed 03/13/19 Page 10 of 30 PageID #: 4298

RACKETEERING ACT FIVE (Conspiracy to Commit Identity Theft)
24. The defendants KEITH RANIERE and CLARE BRONFMAN, together with others, committed the following acts, either of which alone constitutes Racketeering Act Five:


 * A. Conspiracy to Commit Identity Theft

25. In or about and between August 2005 and November 2008, both dates being approximate and inclusive, within the Northern 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 lawful authority and in and affecting interstate and foreign commerce, 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, unlawful 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) unlawfully 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).


 * B. Identity Theft of John Doe 1

26. In or about and between January 2006 and November 2008, both dates being approximate and inclusive, within the Northern District of New York and elsewhere, the defendant KEITH RANIERE, together with others, did knowingly and intentionally transfer, possess and use, without lawful authority and in and affecting interstate commerce, one or more means of identification of another person, to wit: John Doe 1, an individual