to sexual assaults during planned trips and events. On numerous occasions, the ALEXANDER
BROTHERS drugged and raped or sexually assaulted women they encountered by chance,
including women they met at bars and nightclubs, social events, and on dating applications. The
ALEXANDER BROTHERS similarly carried out these rapes and sexual assaults by, among other
things, drugging and incapacitating victims, taking victims to isolated locations, physically
restraining victims while raping and sexually assaulting them alone, together, and with other men,
and ignoring victims’ explicit demands to stop.
STATUTORY ALLEGATIONS
7. From at least in or about 2010, up to and including at least in or about 2021,
in the Southern District of New York and elsewhere, in and affecting interstate commerce, ALON
ALEXANDER, OREN ALEXANDER, and TAL ALEXANDER, the defendants, and others
known and unknown, knowingly, did combine, conspire, confederate and agree to recruit, entice,
harbor, transport, provide, obtain, advertise, maintain, patronize, and solicit, by any means,
persons, and to benefit, financially and by receiving anything of value, from participation in a
venture which has engaged in any such act, 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 persons to
engage in commercial sex acts, in violation of Title 18, United States Code, Section 1591(a)(1) and
(b)(1), to wit, ALON ALEXANDER, OREN ALEXANDER, and TAL ALEXANDER, and others
known and unknown, agreed to recruit, entice, harbor, transport, provide, obtain, advertise,
maintain, patronize, and solicit women, including but not limited to Victim-1 and Victim-2, as
alleged in Counts Two and Three respectively, knowing and in reckless disregard of the fact that
force, threats of force, fraud, and coercion, would be used to cause the women, including but not
10
5