Case 1:18-cr-00204-NGG-VMS Document 430 Filed 03/13/19 Page 7 of 30 PageID #: 4295
COUNT TWO (Racketeering)
16. The allegations contained in paragraphs one through 12 are realleged and incorporated as if fully set forth in this paragraph.
17. In or about and between 2003 and March 2018, 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," CLARE BRONFMAN, ALLISON MACK and LAUREN SALZMAN, together with others, being persons employed by and associated with the Enterprise, an enterprise that engaged in, and the activities of which affected, interstate and foreign commerce, did knowingly and intentionally conduct and participate, directly and indirectly, in the conduct of the affairs of such enterprise through a pattern of racketeering activity, as that term is defined in Title 18, United States Code, Sections 1961(1) and 1961(5), consisting of the racketeering acts set forth below.
RACKETEERING ACT ONE (Conspiracy to Commit Identity Theft and to Unlawfully Possess Identification of Jane Doe 1)
18. The defendant KEITH RANIERE, together with others, committed the following acts, either of which alone constitutes Racketeering Act One:
- A. Conspiracy to Commit Identity Theft
19. In or about 2004, within the Northern District of New York and elsewhere, the defendant KEITH RANIERE, together with others, did knowingly and intentionally conspire to transfer, possess and use, without lawful authority and in and affecting interstate and foreign commerce, one or more means of identification of another
