Page:Superseding Indictment, United States of America v. Robert Sylvester Kelly, also known as "R. Kelly".pdf/1

Case 1:19-cr-00286-AMD Document 43 Filed 03/12/20 Page 1 of 23 PageID #: 350


 * FILED
 * IN CLERK'S OFFICE
 * U.S. DISTRICT COURT E.D.N.Y.
 * ★ MAR 12 2020 ★

BROOKLYN OFFICE EAG/NS/MCM F.#2019R00029

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

-against-

ROBERT SYLVESTER KELLY, also known as "R. Kelly,"

Defendant.


 * SUPERSEDING INDICTMENT


 * Cr. No. 19-286 (S-3)(AMD)
 * (T. 18, U.S.C., §§ 1962(c), 1963, 1963(a), 1963(m), 2421(a), 2422(a), 2422(b), 2423(a), 2 and 3551 et seq.)

INTRODUCTION
At all times relevant to this Superseding Indictment, unless otherwise indicated:

The Enterprise
1. The defendant ROBERT SYLVESTER KELLY, also known as "R. Kelly," and individuals who served as managers, bodyguards, drivers, personal assistants and runners for KELLY, as well as members of KELLY's entourage, comprised an enterprise (the "Enterprise") within the meaning of 18 U.S.C. § 1961(4), that is, the Enterprise constituted a group of individuals 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.