Case 1:19-cr-00286-AMD Document 43 Filed 03/12/20 Page 3 of 23 PageID #: 352
part of this communication, KELLY often requested that the women and girls provide him with photographs of themselves.
6. KELLY and other members of the Enterprise also arranged for the women and girls to travel to see KELLY on occasion, including at concerts throughout the United States and related events. To facilitate their travel, KELLY directed the women and girls to contact a member of the Enterprise, whq then arranged travel for the women and girls. When the women and girls arrived at the lodging, which was typically selected by a member of the Enterprise, a member of the Enterprise usually provided them with instructions. In addition, members of the Enterprise took steps to ensure that the women and girls did not interact with other women and girls whom KELLY planned to see. Members of the Enterprise then arranged for the women and girls to attend his concerts and positioned them such that KELLY could see them during his concerts.
7. KELLY promulgated numerous rules that many of his sexual partners were required to follow, including the following:
- (a) The women and girls were not permitted to leave their room without receiving permission from KELLY, including to eat or go to the bathroom;
- (b) The women and girls were required to wear baggy clothing when they were not accompanying KELLY to an event or unless otherwise instructed by KELLY;
- (c) The women and girls were not permitted to look at other men and instead were told to keep their heads down; and
- (d) The women and girls were required to call KELLY "Daddy."
