Case 1:18-cr-00204-NGG-VMS Document 430 Filed 03/13/19 Page 19 of 30 PageID #: 4307
such visual depictions having involved the use of a minor engaging in sexually explicit conduct, and such visual depictions were of such conduct.
{Title 18, United States Code, Sections 2252(a)(4)(B), 2252(b)(2) and 3551 et seq.)
COUNT SIX (Forced Labor Conspiracy)
44. In or about and between September 2015 and June 2017, both dates being approximate and inclusive, within the Eastern District of New York and elsewhere, the defendants KEITH RANIERE, also known as "Vanguard," "Grandmaster" and "Master," ALLISON MACK and LAUREN SALZMAN, together with others, did knowingly and intentionally conspire to provide and obtain the labor and services of one or more persons, to wit: lower-ranking DOS members, by means of (a) force, physical restraint and threats of physical restraint to them and one or more other persons, (b) serious harm and threats of serious harm to them and one or more other persons, and (c) one or more schemes, plans and patterns intended to cause them to believe that, if they did not perform such labor and services, they and one or more other persons would suffer serious harm, and a combination of such means, contrary to Title 18, United States Code, Section 1589(a).
(Title 18, United States Code, Sections 1594(b) and 3551 et seq.)
COUNT SEVEN (Wire Fraud Conspiracy)
45. In or about and between September 2015 and June 2017, both dates being approximate and inclusive, within the Eastern District of New York and elsewhere, the defendants KEITH RANIERE, also known as "Vanguard," "Grandmaster" and "Master," ALLISON MACK and LAUREN SALZMAN, together with others, did knowingly and
