Case 1:18-cr-00204-NGG-VMS Document 430 Filed 03/13/19 Page 4 of 30 PageID #: 4292
- (g) Protecting and attempting to protect RANIERE and the Enterprise by, among other things, gaining political influence and evading regulatory agencies;
- (h) Using harassment, coercion and abusive litigation to intimidate and attack perceived enemies and critics of RANIERE; and
- (i) Encouraging associates and others to take expensive Nxivm courses, and incur debt to do so, as a means of exerting control over them and to obtain financial benefits for the members of the Enterprise.
The Defendants and Their Co-Conspirators
7. The defendant KEITH RANIERE, also known as "Vanguard," "Grandmaster" and "Master," founded and was the leader ofNxivm and DOS. RANIERE was also the head of the Enterprise.
8. The defendant CLARE BRONFMAN was a member of the Enterprise and a high-ranking member ofNxivm. From at least in or about 2009 to 2018, BRONFMAN served on Nxivm's Executive Board.
9. The defendant ALLISON MACK was a member of the Enterprise and a high-ranking member of Nxivm. At various times relevant to the Indictment, MACK was also a first-line master in DOS.
10. The defendant KATHY RUSSELL was a member of the Enterprise and a high-ranking member ofNxivm. From at least in or about July 2002 to 2014, RUSSELL served as Nxivm's bookkeeper.
11. The defendant LAUREN SALZMAN was a member of the Enterprise and a high-ranking member of Nxivm. From at least in or about 2009 to 2018, SALZMAN
