Page:Superseding Indictment, United States of America v. Keith Raniere, Clare Bronfman, Allison Mack, Kathy Russell and Lauren Salzman.pdf/17

Case 1:18-cr-00204-NGG-VMS Document 430 Filed 03/13/19 Page 17 of 30 PageID #: 4305 threats of physical 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, and (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 physical restraint, and a combination of such means, in violation of Title 18, United States Code, Sections 1589(a) and 2.

RACKETEERING ACT FOURTEEN (Conspiracy to Commit Identity Theft – Jane Doe 7)
40. In or about and between November 2016 and March 2018, 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 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, unlawful 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(c), 1963(a) and 3551 et seq.)

COUNT THREE (Sexual Exploitation of a Child - Jane Doe 2)
41. On or about November 2, 2005, within the Northern District of New York, the defendant KEITH RANIERE, also known as "Vanguard," "Grandmaster" and "Master," did knowingly and intentionally employ, use, persuade, induce, entice and coerce a