Case 1:19-cr-00286-AMD Document 43 Filed 03/12/20 Page 4 of 23 PageID #: 353
8. The Enterprise operated within the Eastern District of New York and elsewhere, including overseas.
Methods and Means of the Enterprise
9. Among the means and methods by which KELLY and his associates participated in the conduct of the affairs of the Enterprise were the following:
- (a) Committing, attempting and aiding and abetting the commission of crimes and conspiring to commit crimes, including but not limited to engaging in sexual activity with girls under 18 years old, engaging in and facilitating sexual activity without disclosing a sexually transmitted disease KELLY had contracted, producing child pornography, bribery, extortion, coercion and blackmail;
- (b) Demanding absolute commitment to KELLY and not tolerating dissent;
- (c) Obtaining sensitive information about sexual partners and members and associates of the Enterprise to maintain control over them;
- (d) Creating embarrassing and degrading videos of sexual partners to maintain control over them;
- (e) Recruiting and grooming sexual partners for KELLY; and
- (f) Isolating women and girls from friends and family and making them dependent on KELLY for their financial wellbeing.
The Defendant
10. The defendant ROBERT SYLVESTER KELLY, also known as "R. Kelly," was the leader of the Enterprise.
