https://www.justice.gov/usao-edny/press-release/file/1046381/download
AL:MKP/TH
F. #2017R00588
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
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UNITED STATES OF AMERICA
- against -
KEITH RANIERE, also known as
"The Van guard,"
Defendant.
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EASTERN DISTRICT OF NEW YORK, SS:
MICHAEL LEVER, being duly sworn, deposes and states that he is a Special Agent with the Federal Bureau of Investigation, duly appointed according to law and acting as such.
In or about and between February 2016 and June 2017, both dates being approximate and inclusjve, within the Eastern District of New York and elsewhere, the defendant KEITH RANIERE, together with others, did knowingly and intentionally conspire to recruit, entice, harbor, transport, provide, obtain, maintain, patronize and solicit persons, to wit: Jane Does 1 and 2, individuals whose identities are known to the undersigned, in and affecting interstate and foreign commerce, knowing that means of force, threats of force, fraud and coercion, as described in Title 18, United States Code, Section 159l(e)(2), and one or more combinations of such means, would be used to cause such persons to engage in
https://www.justice.gov/usao-edny/press-release/file/1046381/download
