Case 1:18-cr-00204-NGG-VMS Document 430 Filed 03/13/19 Page 13 of 30 PageID #: 4301
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 unlawful activity, to wit: visa fraud, in violation of Title 18, United States Code, Section 1546, all in violation of Title 18, United States Code, Sections 1956(a)(2)(A) and 2.
RACKETEERING ACT NINE (Trafficking and Document Servitude - Jane Doe 4)
31. The defendants KEITH RANIERE and LAUREN SALZMAN, together with others, committed the following acts, either of which alone constitutes Racketeering Act Nine:
- A. Trafficking of Jane Doe 4 for Labor and Services
32. In or 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 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, Chapter 77, to wit: ( 1) document servitude, in violation of Title 18, United States Code, 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.
- B. Document Servitude of Jane Doe 4
33. In or 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
