commit at least two acts of racketeering activity in the conduct of the affairs of the Combs
Enterprise.
Notice of Special Sentencing Factor
15. 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)(1) and (b)(1).
(Title 18, United States Code, Section 1962(d).)
COUNT TWO
(Sex Trafficking by Force, Fraud, or Coercion)
(Victim-1)
The Grand Jury further charges:
16.
From at least in or about 2009, up to and including in or about 2018, in the Southern
District of New York and elsewhere, 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, in and affecting interstate and foreign
commerce, knowingly recruited, enticed, harbored, transported, provided, obtained, advertised,
maintained, patronized, and solicited 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
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