Confidential court records: Bouchey walks out of deposition, Dones stands up to NXIVM’s Attorney’s threats

It never ends.

On Sept. 14, 2011, NXIVM attorney Pam Nichols called Barbara Bouchey as a non-party witness in the matter of NXIVM v Susan Dones.

After four hours of being deposed [the amount of time the court allowed], Bouchey called the clock; she had enough; she rose and left Nichols’ law offices where she was being examined and cross examined by Dones.

Bouchey flew in to Albany to make her appearance and had a plane to catch to go home.

The deposition commenced  at 11 :30 a .m . By 4:15 she was ready to leave.

Pamela Nichols (billing at $375 per hour) and her junior colleague,  Joshua McMahon  (billing at $175 per hour) were there for NXIVM. Kristin Keeffe was there also on behalf of NXIVM.

This is from the confidential transcript. Page 242.

Bouchey: I have to go.

Nichols: N o.  N o.  N o.

B:  Listen, you all knew at 4:15 —

N:  Then you are coming back. I’m getting the judge on the phone.

B:  Listen, I have a plane to catch. You all knew I had to leave at 4: 15.

N: N o. No. She doesn’t get to go off on these tangents.

B:  Fuck you, Kristin, fuck you.

N: I’m getting the judge on the phone. You don’t get to walk out.

B:  Of course I do. You all knew I have a plane to catch. You all knew I had to leave at 4 :15.

N: Then you’re coming back.

B: You know what? Listen you had your time with me. [the deposition had four hour time limitation for that day].

N: If you want to walk out.

B:  Look, I m leaving.  I have to leave. Kristin, you know exactly what you are doing.   Please.  Please.  Tell her the truth some day why don’t you? [Ironically that day did come in 2014. Kristin Keeffe fled the cult and later did email Nichols a list of crimes Raniere has allegedly committed].

N: It will be a motion for contempt.

B: Tell me about Gaelen [Keeffe and Raniere’s child who Raniere was lying about, claiming the boy was adopted.]  Really.

Bouchey leaves.

N [sarcastically]:  She is gone, so thank you.

Dones:  I don’t  know what happened.

N: What happened was you used up the time on irrelevant matters and she walked out and that is the end. So I will take this up with Judge Peebles, because this deposition, based on your questioning, is not closed.

Dones:  Sorry about that, but you had your four hours.

N:  No , I did not. Actually, I did not have my full four hours. You started questioning, you wouldn’t stop, and she doesn’t get to walk out and that is the way it goes.

D:  What does that have to do with me?

N: Ms. Dones, I’m not going to attribute any motive to anybody right now. I’m just going to tell you that I am going to get Judge Peebles involved in this.

D: Well, I would like to be on that call.

N: It will be a motion.

D: You accused me of eating up time. I know my  case, and you guys called the deponent to be deposed, which means I have a right to cross-examine.


Nichols appeared to be upset by the Bouchey walk-out.

It must be admitted that Pam Nichols may not have enjoyed the encounter between Dones, Bouchey and Keeffe very much; (indeed she may have shed copious crocodile tears). Still she got to bill for herself and her associate for four hours, plus preparation – and, as we shall see, would bill substantially more in preparing her motion for sanctions against Bouchey.

It is also to be noted that there is a large and growing club of unscrupulous attorneys – of which Nichols may be a charter member –  who love to feign indignation and perturbation on behalf of their clients, knowing full well that it will incite their clients, which, in turn, will mean more billable hours.

Nichols was to make a motion against Bouchey seeking $10,272.50 in billable hours for her time. We will reveal the results in a later post.


As a final point to ponder, as you contemplate the love, ethics and compassion of the Vanguard, Keith Raniere – consider what a load of hate, controversy and grief – one man creates and how it follows and spreads in the form of terror and grief and waster wherever his plans are executed anywhere.



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Frank Parlato

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About the Author

Frank Parlato is an investigative journalist.

His work has been cited in hundreds of news outlets, like The New York Times, The Daily Mail, VICE News, CBS News, Fox News, New York Post, New York Daily News, Oxygen, Rolling Stone, People Magazine, The Sun, The Times of London, CBS Inside Edition, among many others in all five continents.

His work to expose and take down NXIVM is featured in books like “Captive” by Catherine Oxenberg, “Scarred” by Sarah Edmonson, “The Program” by Toni Natalie, and “NXIVM. La Secta Que Sedujo al Poder en México” by Juan Alberto Vasquez.

Parlato has been prominently featured on HBO’s docuseries “The Vow” and was the lead investigator and coordinating producer for Investigation Discovery’s “The Lost Women of NXIVM.” Parlato was also credited in the Starz docuseries "Seduced" for saving 'slave' women from being branded and escaping the sex-slave cult known as DOS.

Additionally, Parlato’s coverage of the group OneTaste, starting in 2018, helped spark an FBI investigation, which led to indictments of two of its leaders in 2023.

Parlato appeared on the Nancy Grace Show, Beyond the Headlines with Gretchen Carlson, Dr. Oz, American Greed, Dateline NBC, and NBC Nightly News with Lester Holt, where Parlato conducted the first-ever interview with Keith Raniere after his arrest. This was ironic, as many credit Parlato as one of the primary architects of his arrest and the cratering of the cult he founded.

Parlato is a consulting producer and appears in TNT's The Heiress and the Sex Cult, which premiered on May 22, 2022. Most recently, he consulted and appeared on Tubi's "Branded and Brainwashed: Inside NXIVM," which aired January, 2023.

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Phone / Text: (305) 783-7083


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