Case 1:25-cr-00281-BMC Document 1 Filed 09/17/25 Page 1 of 13 PageID #: 35

FILJ D
IN q LERK'S OFFICE
EMR/MEF:TBM/RSB US !DISTRICT COURT E.D.N.Y.
F. #2017R01960
*SEPTEMBER 17, 2025*
UNITED STATES DISTRICT COURT BROOKLYN OFFICE
EASTERN DISTRICT OF NEW YORK
- -- --- - - - ----------- ---- --- --X

UNITED STATES OF AMERICA INDICTMENT

Cr. No. _ 25-CR-281

__ _ _ _ _ _ _ __
- against -
(T. 18, U.S.C., §§ 982(a)(2)(A), 982(bXl},
HOWARD RUBIN, 1344, l59l(aXI), 159l (aX2), 1591(b)( l ),
also known as "Howie" l594(d), 2421(a), 2428(a), 2 and 3551 et
and "H," and ~.; T. ;21 , U.S.C., § 853(p))
JENNIFER POWERS, JUDGE MARGO K. BRODIE
MAGISTRATE JUDGE SETH D. EICHENHOLTZ
Defendants.

---- --- --- ---- -- - - - - - - - -- - ---X

THE GRAND JURY CHARGES:

INTRODUCTION

At all times relevant to this Indictment, unless otherwise indicated:

I. The Defendants

I. The defendant HOWARD RUBIN, also known as "Howie" and "H," is a

retired New-York based financier. From at least 2009 through 2019, RUBIN recruited dozens
l
of women to engage in commercial sex acts with him involving ,bondage, discipline, dominance,

submission and sadomasochism ("BDSM"). During many such encounters, RUBIN engaged in

conduct beyond the scope of the women's consent.

2. From at least 20 11 through 2019, the defendant JENNIFER POWERS

facilitated RUBIN's commercial sexual encounters. Among other things, POWERS recruited

women to have commercial sex with RUBIN, arranged travel and accommodations for women to

fly to New York to engage in commercial sex acts with RUBIN, secured non-disclosure
Case 1:25-cr-00281-BMC Document 1 Filed 09/17/25 Page 2 of 13 PageID #: 36

agreements ("NOA") from women, procured BDSM toys and inJtruments for RUBIN to use
I
during commercial sex acts with women, paid women after theirlsexual encounters in amounts

directed by RUBIN, and managed the fallout from women's coniplaints stemming from the

commercial sex acts with RUBIN.

II. The Sex Trafficking and Prostitution Operations

3. From approximately 2009 to 2019, the defendants HOWARD RUBIN and

JENNIFER POWERS, together with others, operated a network whereby they recruited women,

including Jane Does #1 through #10, individuals whose identities are known to the Grand Jury,

to engage in commercial sex acts with RUBIN, in exchange for money, which acts involved

BDSM. During many of these encounters, RUBIN brutalized women's bodies, causing them to

fear for their safety and/or resulting in significant pain or injuries, which at times required

women to seek medical attention. RUBIN and POWERS spent at least $1 million dollars of

RUBIN's money operating and maintaining the trafficking network described herein.

4. Between 2009 to 2011, the commercial sex acts primarily occurred at

luxury hotels in Manhattan, New York. Beginning in 2011, the defendant HOW ARD RUBIN

leased a luxury penthouse apartment located near Central Park, New York (the "Penthouse").

RUBIN and the defendant JENNIFER POWERS transformed one of the bedrooms in the

Penthouse into a sex "dungeon" that was painted red and soundproofed; had a lock on the door;

was furnished with BDSM equipment to which women could be strapped and restrained; and

contained devices to shock or electrocute them, among other items. RUBIN also traveled out of

state to engage in commercial sex acts with women, including to Las Vegas, Nevada.

5. The defendants HOWARD RUBIN and JENNIFER POWERS, together

with others, recruited women-often targeting former Playboy models, whom they found
Case 1:25-cr-00281-BMC Document 1 Filed 09/17/25 Page 3 of 13 PageID #: 37

3
I

through social media, modeling pages or high-end prostitution nJtworks-to engage in

commercial sex acts with RUBIN. RUBIN and POWERS, togelher with others, materially
!
I
I
misrepresented to women the extent, manner and/or degree to wrch RUBIN would engage in

physical and sexual violence. For example, in some instances, RUBIN provided a "safe word"
I

the women could say to convey that they wanted the violent sexual conduct to cease, but then

disregarded the safe word when women used it and continued the violent conduct without the

women's consent. In other instances, regardless of whether RUBIN had provided a safe word,

the women were unable to object to RUBIN's conduct because they were bound and/or gagged

during the sexual encounter. In still other instances, women became unconscious during the

sexual encounters, such that they were unable to consent.

6. The defendant HOWARD RUBIN paid different women for commercial

sex multiple times a week, sometimes on consecutive days. The defendant JENNIFER

POWERS frequently arranged the women's flights to New York, often to LaGuardia or John F.

Kennedy Airports in Queens, New York, and transportation to the Penthouse; facilitated the

women's entry with the Penthouse building doormen; and coordinated with the women to ensure

that their visits to the Penthouse did not overlap. After the sexual encounters, RUBIN often

described the encounters in detail to POWERS, who used the information to manage fallout with

the women because of RUBIN's violence. Additionally, after the sexual encounters, RUBIN

and/or POWERS used RUBIN's money to pay the women by wire transfer or a payment service

such as PayPal or Venmo. At times, POWERS structured the payments to avoid sending a

single transaction of$10,000 or more. If RUBIN was satisfied with the way that the women had

endured a sexual encounter, the women received $5,000 per encounter; if he was dissatisfied, he

paid them several thousand dollars less.

Case 1:25-cr-00281-BMC Document 1 Filed 09/17/25 Page 4 of 13 PageID #: 38

7. The defendants HOW ARD RUBIN and JNNIFER POWERS, together

I
with others, required the women to sign NDAs, which, among oiher things, purported to require
I

that the women assume the risk of the hazards and injury of the BDSM encounters with RUBIN,

prohibit the disclosure of information about the BDSM sex withlRUBIN, and require the
I
I
payment of damages in the event of a breach. RUBIN and POWERS kept a safe in the

Penthouse where they held a stock of qlank NDAs. The women were not provided a copy of the

NOA prior to being required to sign it. Moreover, at times, women were only presented the

NOA after they had consumed alcohol with RUBIN.

8. After some of these encounters, women contacted the defendant

JENNIFER POWERS and described what the defendant HOW ARD RUBIN had done to them

and/or sent images of their injuries. POWERS at times assuaged the women by, for example,

telling them to ice their injuries or to apply bruise cream. Other times, POWERS minimized

RUBIN's behavior by telling the women he was too drunk or even blaming the women for

letting RUBIN get too drunk. On various occasions, victims notified RUBIN and POWERS

that RUBIN had caused lasting pain and physical injuries to them, including, for example, a

woman's breast implant that had flipped upside down and required surgery to fix, or pain,

bruising and discoloration that lasted for weeks such that the women could not work.

9. The defendants HOWARD RUBIN and JENNIFER POWERS, together

with others, employed coercive, fraudulent, threatening and deceptive tactics when they

recruited, enticed, harbored, transported, provided, obtained, maintained, patronized and solicited

and paid the women to engage in commercial sex acts, including by minimizing the level and

nature of the anticipated BDSM encounter. For example, RUBIN and POWERS, together with

others:
Case 1:25-cr-00281-BMC Document 1 Filed 09/17/25 Page 5 of 13 PageID #: 39

(a) Employed a referral and recruijent system that failed to fully

apprise women of what would occur during the commercial selual encounters with RUBIN,
I
including the manner and degree to which RUBIN would physically and sexually abuse them,
I

and instead often mischaracterized the nature of the conduct, g~nerally describing it as light

fetish play or activity, or omitting that it would include sex acts with RUBIN;

(b) Obtained consent from women on the basis that they could use a

safe word during the encounters, at which point RUBIN would cease engaging in the

objectionable conduct, but then during the subsequent encounter, women were either physically

unable to use the safe word, due to a gag, or when women used the safe word, RUBIN failed to

cease the activity, including penetrating women with foreign objects, to which the women did

not or no longer consented, even after they had asked RUBIN to stop;

(c) Encouraged women to become intoxicated with alcohol and drugs,

such as sedatives, including by providing such substances before the sexual encounters, resulting

in the women being unable to consent, including because of Iadk of consciousness; and

(d) Threatened women with legal consequences and public shaming if

they sought legal recourse.

III. The Fraudulent Conduct

I 0. From at least 2018 until 2023, the defendant HOWARD RUBIN funded

virtually all aspects of the defendant JENNIFER POWERS's life, including paying for the

following: the rent on her Manhattan apartment, private schooling for her children, her credit

card bills, her legal fees associated with the trafficking operation described above, a down

payment on her home in Texas and her mortgage payments, totaling approximately $8,000,000.
Case 1:25-cr-00281-BMC Document 1 Filed 09/17/25 Page 6 of 13 PageID #: 40

11. In or about 2017, the defendants HOW AI

l RUBIN and JENNIFER
I
POWERS, and others, were sued in the U.S. District Court for the Eastern District of New York
I
by women who had engaged in commercial sex acts with RUBIN, requesting millions of dollars
I

in damages (the "Civil Case"). Throughout 2018, RUBIN waj,deposed in connection with the

Civil Case, and he also attended the depositions of POWERS a d all of the plaintiffs, among

others. The Civil Case continued following RUBIN's deposition and a jury trial commenced on

or about March 23, 2022, and continued until on or about April 7, 2022. RUBIN testified in that

jury trial on or about March 30, 2022.

12. In or about 2020, the defendant JENNIFER POWERS relocated to Texas

and purchased a home, secured by a mortgage co-signed by the defendant HOW ARD RUBIN,

with a financial institution ("Financial Institution"), an entity the identity of which is known to

the Grand Jury. On or about June 3, 2020, while RUBIN was in Suffolk County, New York, he

emailed the Financial Institution a financial statement in support of his petition to co-sign

POWERS's mortgage. The financial statement was signed by RUBIN and dated on or about

June 3, 2020. In response to the question, "Are you a party to any suit or are there any

unsatisfied judgments against you?" (the "Question") RUBIN responded, "No," when in fact he

was actively engaged in the Civil Case. The financial statement further provided that RUBIN

would notify the Financial Institution in writing of any material unfavorable change, and that

absent such notice, the Financial Institution could consider the financial statement "a continuing

statement and substantially correct."

13. Thereafter, the defendant JENNIFER POWERS's home mortgage was

restructured. On or about April 4, 2022, POWERS emailed the Financial Institution a renewed

financial statement, signed by the defendant HOWARD RUBIN and dated on or about April 2,
Case 1:25-cr-00281-BMC Document 1 Filed 09/17/25 Page 7 of 13 PageID #: 41

2022. The financial statement did not include a correction by UBIN stating that he was a party

to a lawsuit, notwithstanding the fact that days earlier he had tes ified at the jury trial in the Civil
I
I
Ca~. /

COUNT ONE j
(Sex Trafficking - Jane Does # 1 thro gh #5)

14. The allegations contained in paragraphs one through 13 are realleged and

incorporated as if fully set forth in this paragraph.

15. In or about and between 2015 and 2017, both dates being approximate and
I

inclusive, within the Eastern District of New York and elsewherb, the defendants HOWARD

RUBIN, also known as "Howie" and "H," and JENNIFER POWERS, together with others, did

knowingly and intentionally recruit, entice, harbor, transport, provide, obtain, maintain, patronize

and solicit, by any means one or more persons, to wit, Jane Does # 1 through #5, in and affecting

interstate commerce, and did benefit, financially and by receiving anything of value, from

participation in a venture which engaged in such acts, knowing ~nd 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 a combination of such means, would be used to cause such

persons to engage in one or more commercial sex acts, which offense was effected by means of

force, threats of force, fraud and coercion, and a combination of such means.

(Title 18, United States Code, Sections 159l(a)(1), 159l(a)(2), 159l(b)(l), 2 and

3551 et seq.)

COUNTTWO
(Sex Trafficking-Jane Doe #6)

16. The allegations contained in paragraphs one through 13 are realleged and

incorporated as if fully set forth in this paragraph.

Case 1:25-cr-00281-BMC Document 1 Filed 09/17/25 Page 8 of 13 PageID #: 42

I
8
I

17. In or about 2018, within the District of Nbvada, the defendant HOWARD

RUBIN, also known as "Howie" and "H," together with others,jdid knowingly and intentionally

recruit, entice, harbor, transport, provide, obtain, maintain, patr,I nize and solicit, by any means
I

one or more persons, to wit, Jane Doe #6, in and affecting interJtate commerce, and did benefit,
• l
I
financially and by receiving anything of value, from participation in a venture which engaged in

such acts, 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 a

combination of such means, would be used to cause such persons to engage in one or more

commercial sex acts, which offense was effected by means of force, threats of force, fraud and

coercion, and a combination of such means.

(Title 18, United States Code, Sections 1591(a)(l), 159l(a)(2), 159l(b)(l), 2 and

3551 et seq.)

COUNTS THREE THROUGH EIGHT

(Mann Act-Transportation)

18. The allegations contained in paragraphs dne through 13 are realleged and

incorporated as if fully set forth in this paragraph.

19. In or about and between 2009 and 2019, both dates being approximate and

inclusive, within the Eastern District of New York and elsewhere, the defendants HOWARD

RUBIN, also known as "Howie" and "H," and JENNIFER POWERS, together with others, did

knowingly and intentionally transport individuals in interstate commerce with intent that such

individuals engage in prostitution as described below:

Case 1:25-cr-00281-BMC Document 1 Filed 09/17/25 Page 9 of 13 PageID #: 43

COUNT INDIVIDUAL APPROXIM1 ~TE DATE<S)

THREE Jane Doe #1 2009-2017

FOUR Jane Doe #2 2015

FIVE Jane Doe #4 2016 I

SIX Jane Doe #7 2014-2019 ,

SEVEN Jane Doe #8 2016

EIGHT Jane Doe #9 2016

(Title 18, United States Code, Sections 2421 (a),~ and 3551 et seq.)

COUNT NINE
(Mann Act-Transportation)

20. The allegations contained in paragraphs one through 13 are realleged and

incorporated as if fully set forth in this paragraph.

21. In or about 2011, within the Eastern District of New York and elsewhere,

the defendant HOWARD RUBIN, also known as "Howie" and ''H," together with others, did

knowingly and intentionally transport an individual, to wit: Jane Doe # 10, in interstate

commerce, with intent that such individual engage in prostitution.

(Title 18, United States Code, Sections 2421 (a), 2 and 3551 et seq.)

COUNT TEN
(Bank Fraud)

22. The allegations contained in paragraphs one through 13 are realleged and

incorporated as if fully set forth in this paragraph.

23. In or about and between June 2020 and April 2022, both dates being

approximate and inclusive, within the Eastern District of New 'I: ork and elsewhere, the defendant
HOWARD RUBIN, together with others, did knowingly and intentionally execute a scheme to
Case 1:25-cr-00281-BMC Document 1 Filed 09/17/25 Page 10 of 13 PageID #: 44

II
defraud the Financial Institution, and to obtain moneys, fundb, credits and other property, owned

by, and under the custody and control of, such financial instttions by means of materially false
I

and fraudulent pretenses, representations and promises. I

I
i
(Title 18, United States Code, Sections 1344, f and 3551 et seg.)
I

CRIMINAL FORFEITURE ALL~GATION

AS TO COUNTS ONE AND TWO

24. The United States hereby gives notice to the defendants that, upon their

conviction of either of the offenses charged in Counts One or Two, the government will seek

forfeiture in accordance with Title I 8, United States Code, Section l 594(d), of: (a) any property,

real or personal, that was involved in, used, or intended to be hsed to commit or to facilitate the

commission of such offenses, and any property traceable to such property; and (b) any property,

real or personal, constituting, or derived from, proceeds obtained, directly or indirectly, as a

result of such offenses, or any property traceable to such property.

25. 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;

i
(d) has been substantially diminished in value; or

(e) has been commingled with other property which cannot be divided

without difficulty;
Case 1:25-cr-00281-BMC Document 1 Filed 09/17/25 Page 11 of 13 PageID #: 45

11

I
it is the intent of the United States, pursuant to Title 21, United ;states Code, Section 853(p), to

seek forfeiture of any other property of the defendants up to the value of the forfeitable property

described in this forfeiture allegation.

(Title 18, United States Code, Section 1594(d); itle 21, United States Code,

Section 853(p))

CRIMINAL FORFEITURE ALLEGATION

AS TO COUNTS THREE THROUGH NINE

26. The United States hereby gives notice to the defendants that, upon their

conviction of any of the offenses charged in Counts Three through Nine, the government will

seek forfeiture in accordance with Title 18, United States Code,! Section 2428(a), which requires

the forfeiture of: (a) any property, real or personal, that was used or intended to be used to

commit or to facilitate the commission of such offenses; and (b) any property, real or personal,

constituting or derived from proceeds obtained directly or indirectly as a result of such offenses.

27. 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;
Case 1:25-cr-00281-BMC Document 1 Filed 09/17/25 Page 12 of 13 PageID #: 46

12

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to

seek forfeiture of any other property of the defendants up to the value of the forfeitable property

described in this forfeiture allegation.

I
(Title 18, United States Code, Section 2428(a); Title 2 I, United States Code,
I
I

Section 853(p)) I

CRIMINAL FORFEITURE ALLEGATION

AS TO COUNT TEN

28. The United States hereby gives notice to the defendant charged in Count

Ten that, upon his conviction of such offense, the government will seek forfeiture in accordance

with Title 18, United States Code, Section 982(a)(2)(A), which requires any person convicted of

such offense to forfeit any property constituting, or derived from, proceeds obtained directly or

indirectly as a result of such offense.

29. If any of the above-described forfeitable property, as a result of any act or

omission of the defendant:

(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;
Case 1:25-cr-00281-BMC Document 1 Filed 09/17/25 Page 13 of 13 PageID #: 47

13

it is the intent of the United States, pursuant to Title 2 1, United States Code, Section 853(p), as

incorporated by Title l8, United States Code, Section 982(b)(l), to seek forfe iture of any other

property of the defendant up to the value of the forfeitable property described in this forfe iture

a llegation.

(Title 18, United States Code, Sections 982(a)(2)(A) and 982(b)(l ); Title 21,

United States Code, Section 853(p))

A(~UE BILL
r.A
) , /l J
...? I \:..:/
s/ /
a DtUNd /Jd:tuc/4 A~CI.S. At:t;,
;J" JOSEPH NOCELLA, JR. 7
UNITED STATES ATTORNEY
EASTERN DISTRICT OF NEW YORK