Case 1:19-cr-00286-AMD Document 43 Filed 03/12/20 Page 5 of 23 PageID #: 354
COUNT ONE (Racketeering)
11. The allegations contained in paragraphs one through 10 are realleged and incorporated as if fully set forth in this paragraph.
12. In or about and between January 1994 and the present, both dates being approximate and inclusive, within the Eastern District ofNew York and elsewhere, the defendant ROBERT SYLVESTER KELLY, also known as "R. Kelly," together with others, being a person 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 the Enterprise through a pattern of racketeering activity, as defined in Title 18, United States Code, Sections 1961(1) and 1961(5), consisting of the racketeering acts set forth below.
Racketeering Act One (Bribery)
13. On or about August 30, 1994, within the Northern District of Illinois, the defendant ROBERT SYLVESTER KELLY, together with others, did knowingly and intentionally cause another individual to promise and tender to a public officer and public employee property, to wit: Unites States currency, that such public officer and public employee was not authorized by law to accept, with the intent to influence the performance of an act related to the employment and function of a public officer and public employee, to wit: the creation of a fraudulent identification document for Jane Doe #1, an individual whose identity is known to the Grand Jury, in violation of Illinois Criminal Code Sections 5/33-1(a) and 5/5-1.
