Case 1:18-cr-00204-NGG-VMS Document 430 Filed 03/13/19 Page 3 of 30 PageID #: 4291
financial opportunities and personal benefits, including increased power and status within the Enterprise.
5. The Enterprise operated within the Eastern District of New York, the Northern District of New York and elsewhere, including overseas.
6. Among the means and methods by which the defendants and their associates participated in the conduct of the affairs of the Enterprise were the following:
- (a) Promoting, enhancing and protecting the Enterprise by committing, attempting and conspiring to commit crimes, including but not limited to visa fraud, identity theft, extortion, forced labor, sex trafficking, money laundering, wire fraud, tax evasion and obstruction of justice;
- (b) Demanding absolute commitment to RANIERE, including by exalting RANIERE's teachings and ideology, and not tolerating dissent;
- (c) Inducing shame and guilt in order to influence and control members and associates of the Enterprise;
- (d) Obtaining sensitive information about members and associates of the Enterprise in order to maintain control over them;
- (e) Recruiting and grooming sexual partners for RANIERE and obtaining nude photographs of women for RANIERE;
- (f) Isolating associates and others from friends and family and making them dependent on the Enterprise for their financial well-being and legal status in the United States;
