- From at least in or about 2009, up to and including in or about 2018, in the Southern District of New York and elsewhere, as part of his agreement to conduct and participate in the conduct of the affairs of the Combs Enterprise through a pattern of racketeering activity, SEAN COMBS, a/k/a “Puff Daddy,” a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” the defendant, agreed to, in and affecting interstate and foreign commerce, knowingly recruit, entice, harbor, transport, provide, obtain, advertise, maintain, patronize, and solicit by any means a person, knowing and in reckless disregard of the fact that means of force, threats of force, fraud, and coercion, as described in Title 18, United States Code, Section 1591(e)(2), and any combination of such means, would be used to cause the person to engage in a commercial sex act, in violation of Title 18, United States Code, Section 1591(a)(l) and (b)(l).
- multiple offenses involving the possession with intent to distribute, or distribution of narcotics and controlled substances, including cocaine, oxycodone, alprazolam, 3,4-Methy lenedioxymethamphetamine, 4-Bromo-2,5-dimethoxyphenethy lamine, gamma hydroxybutyric acid, and ketamine, in violation of Title 21 , United States Code, Sections 841 (a)(l ), (b )(1 )(C), (b )(1 )(E), (b )(2), and 846 ( distribution and possession with intent to distribute and conspiracy to do the same), and Title 18, United States Code, Section 2 ( aiding, abetting, and willfully causing).
