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Charles Manson was the cult-leader of the "Manson Family".
Captain Donald Cragen used Manson as an example to explain to ADA Casey Novak that Abraham Ophion had to be charged with the murder of seven children, even tough he didn't commit them. He said that Manson wasn't present for the Tate murders, but that they still convicted him for killing them. Novak argued that Manson was a different case, because members of his cult testified that Manson ordered the murders. (SVU:"Charisma")