United States Attorney for the Eastern District of New York

“ CRIMINAL FORFEITURE ALLEGATION AS TO COUNT SEVENCRIMINAL FORFEITURE ALLEGATION AS TO COUNT SEVEN 55. The United States hereby gives notice to the defendants charged in Count Seven that, upon their conviction of such offense, the government will seek forfeiture in accordance with Title 18, United States Code, Section 98l (a) (l) (C) and Title 28, United States Code, Section 2461 (c) , which require any person convicted of such offense to forfeit any property, real or personal, constituting, or derived from, proceeds obtained directly or indirectly as a result of such offense. ”

“ The Enterprise operated within the Eastern District of New York, the Northern District of New York and elsewhere, including overseas.
6. Among the means and methods by which the defendants and their associates participated in the conduct of the affairs of the Enterprise were the following:
(a) Promoting, enhancing and protecting the Enterprise by committing, attempting and conspiring to commit crimes, including but not limited to visa fraud, identity theft, extortion, forced labor, sex trafficking, money laundering, wire fraud, tax evasion and obstruction of justice ”

“ If any of the above-described forfeitable property, as a result of any act or omission of the defendants:
(a) cannot be located upon the exercise of due diligence; (b) has been transferred or sold to, or deposited with, a third party; (c) has been placed beyond the jurisdiction of the court; (d) has been substantially diminished in value; or (e) has been commingled with other property which cannot be divided without difficulty ”

“ In leading the Pyramid Organizations, RANIERE relied on certain individuals, sometimes referred to as his "inner circle," who were accorded special positions of trust and privilege with RANIERE and who carried out his directives.
2. Members of RANIERE's inner circle also held high positions, or had an ownership interest, in one or more of the Pyramid Organizations, including serving as executives, directors and officers ofNxivm. ”