In previous posts, we described the wretched conditions at the Metropolitan Detention Center [MDC], but a letter to Judge Nicholas Garaufis, filed as a supplement to Raniere’s third attempt at bail, by Raniere’s attorneys, hammers home the point: MDC is not fit for humans.
Since the letter is relatively short, it is reprinted below in full:
The Honorable Nicholas G. Garaufis
United States District Judge
United States District Court
225 Cadman Plaza East
Brooklyn, New York 11201
Re: United States v. Keith Raniere, et al., 18 Cr. 204 (NGG)
Dear Judge Garaufis:
We write to supplement our Third Motion for Bond (Dkt. 303) and reply to the Government’s short letter in response to the Motion (Dkt. 304).
We write to alert the Court to Raniere’s detention at the MDC, which is functioning as a more extreme deprivation of his rights than what is typical for pretrial detainees. During the Government shutdown, legal visiting was constantly suspended, making pretrial and trial preparation extremely difficult. [1]
When the Government reopened, legal visiting resumed and we did not include this to our Motion for Bond (Dkt. 303) because regular visiting would apparently have resumed. However, now, even after the temporary resolution of the shutdown, we have been prevented from visiting Raniere because the
MDC has been closed all week.
MDC has been without heat, electricity, hot water, commissary or warm food since January 27, 2019, following an apparent fire in the institution. Raniere has relayed to us, through a colleague in the Federal Defender’s Office, that MDC has not provided Raniere with any means to keep warm—and apparently the temperature in the institution is 44 degrees. Raniere has also informed us that the corrections officers are wearing masks to mask the smell of noxious fumes, but have not provided any masks to the inmates.
These conditions have substantially hindered trial preparation. Counsel has been unable to follow up Monday’s proceedings and issues raised during that appearance, review multiple recent filings, and prepare Raniere for the February 6 court appearance and issues to be addressed at the conference.
Counsel has called MDC daily asking when we can next expect to be able to see Raniere and they have been unable to answer us. Even in the frigid temperatures during the Polar Vortex this week, counsel Danielle Smith traveled to the MDC from Albany, NY to see visit our client and assess the situation in person. The guards would not let her in.
These conditions merit relief. Not only is Raniere in MDC with no heat or hot water in the coldest temperatures in the United States to date this year, but he is also unable to meet with counsel to prepare for his imminent trial. In a case that the Government requested be deemed
complex, [2] with a significant volume of discovery, it will be nearly impossible to prepare for trial
with Raniere detained.
The lack of counsels’ access to our client represent a violation of his Due Process rights as set forth in our bail application and his Right to the effective assistance of counsel.
Thank you for your consideration.
Respecfuly submitted,
________________
Marc Agnifilo
Teny Geragos
Paul DerOhannesian
Danielle Smith
cc: All Counsel (via ECF)
Footnote 1
Often without advance notice, legal visiting at the MDC was suspended on January 4, 5, 6, 9, 10,
11, 14 and 21.
Footnote 2
The Government notes that “defendant calls the government’s request to designate the case
complex a ‘ruse,’ despite this Court’s finding of complexity (DE 138) and the defendant’s
affirmative consent to the complex case designation at every court appearance since the finding
was made.” (Dkt. 304 at 1 at n.1.) Raniere notes, as he has since the Government first sought to
designate this case complex in September, that the complex nature of it “is a problem of the
government’s own making.” (September 12, 2018 Ltr .on Behalf of All Defendants at 3.) Counsel
stated then, and has stated since that “the government has frustrated defense counsel at every turn
in our efforts to make this case manageable.” (Id.)
Frank Parlato 
Janine Morrison 
J.J. O'Hara 
Richard Luthmann 
Marie White 
Paul Serran
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[…] is little question that Marc Agnifilo’s filing with the court on behalf of Raniere – seeking his release on bail – based, in part, because it was too […]
[…] is little question that Marc Agnifilo’s filing with the court on behalf of Raniere – seeking his release on bail – based in part because it was too […]
Keith Raniere strikes the pose of Auguste Rodin’s, “The Thinker”
[…] Yet, is the one week or longer, of cold at MDC reason to release Raniere on bail, as Agnifilo suggests to Judge Garaufis? […]
44 F = 6.7 Celsius. Inside temperature? The temperature is probably from the weather forecast.
Keith is missing everthing at the MDC, but he has a thermometer to messure the temperature?
A few years ago there was a huge ice storm where I lived and the power was out for thousands of us. We went five days without power and some went two weeks.
Stores were closed or did have fresh food, most couldn’t cook, restaurants were not an option either.
You learn how to get through things like that when faced with adversity and the reality that nothing can be done until the power situation got fixed.
Raniere, on the other hand, appears to have a strong sense of entitlement to be comfortable. He’s used to being waited on by his girl servants, enjoyed the comforts of being the King of NXIVM and the mastermind behind a criminal organization.
He finally got caught with his hand in the cookie jar and put himself in this situation.
He will use every excuse to have some freedom. A glimmer of hope to leave the country once again but this time not be found by the Feds.
Let’s hope the Judge sees through this silly game of “poor me” suffering and keeps Raniere right where he belongs, the MDC
[…] Yet, is the one week or longer, of cold at MDC reason to release Raniere on bail, as Agnifilo suggests to Judge Garaufis? […]
I taught my children many many things as they were growing up. One of the important life rules is to “follow the laws of the land”. Don’t get yourself mixed up in illigal shit, because if you do. you will end up in a Pen, a real human pigpen.
Mr Raniere is being accused of sexually abusing and enslaving innocent children and not so innocent grown ass WEAK women.
He is were he put himself. He got himself mixed up in iilegal things.
No need to feel sorry for him.
Meh…I might just give a damn if I weren’t so apathetic.
This is a little off topic, but I stumbled upon this KAR quote in his affidavit in the Rick Ross case. He makes this statement after various states sued the crap out of him over Consumers Buyline.
“Throughout this process I had learned how people can cheat and win. In mathematical game theory cheaters, if undetected, always have the advantage because they have more options. I now added game theoretic strategies to my model. This enabled an ethical honest person to choose the best outcome options against a potentially dishonest opponent. Sadly, I found, we live in a world that has more than just opinion-based honest conflicts. We live in a world where some people cheat and cheaters have advantages.”
So…was this the genesis of his aggressive litigation tactics? To “choose the best outcome against a potentially dishonest opponent” (as an “ethical honest person”)? I’m beginning to think this man could convince even himself of anything, no matter how absurd.
He now sits in uncomfortable confinement as a result of his own misguided tactics. If he had had any sense, he would have calculated his moves so that he would now be on home confinement instead of in pretrial detention.
As a side note, I hope they fix the heat, for all the others at MDC.
Bail motion denied. The arguments stay the same. Sorry.
Well, if one is to believe Agnifilo, Raniere has now prouven that he is truly superhuman.
Us mere mortals would have already died of hypothermia if we had nothing to keep us warm in 44F temperatures since 27 jan.
Having flaunted exposing his teenager daughter to Raniere, I was suspect of his drama queen tendencies.
Claiming legal visits were suspended for over a month is now equal to 8 days in a footnote.
How can anyone take anything seriously from someone who makes such ridiculous claims ?
No sympathy for the devil or his overpaid and dramatic ‘counsel’.
Raniere also saved the lives of thousands of other criminals in those cold temperatures. He should get a Nobel Peace Prize.
KAR lawyer Marc Agnifilo is just eating up the legal defense trust fund while there is still some pay dirt left. He knows the trial isn’t going to happen in April. If Marc is such a Super Lawyer, he will have plenty of time to meet with his client and come up with a bag of lies in an attempt to get a jury to buy them. They won’t and Marc and KAR are going to lose.
Raniere time after time continues to prove that he himself cannot apply his technology making it CRAP and his life is now just CRAP. If he could, the conditions at the MDC would not be any issue for him. Sure it’s no Club Med Cancun, it’s jail. You put yourself there KAR, get over yourself.
Corrections officers wearing masks to mask the smell of noxious fumes are most likely coming for KAR himself. The man hates to shower.
“Raniere has also informed us that the corrections officers are wearing masks to mask the smell of noxious fumes, but have not provided any masks to the inmates.”
His hygiene hasn’t improved then!
This is just lawyer-style comedy for the world to see.
Agnifilo claims that MDC hasn’t provided Keith with any means to keep warm, but that’s likely not true since I guran-fucken-tee that MDC has given blankets to every fucking inmate.
I somehow doubt that Keith was denied a blanket and must sit in his freezing cell, shivering in his undies.
Oh, and 44 degrees (even inside a building) is hardly one of the lowest temps in human history since most of our Canadian brethren live in subarctic temperatures for most of the year which make “44 degrees” seem like summertime.
Granted, most of them have heating at home but that’s not the fucking point.
What’s the point?
Ice cream fucking melts at 44 degrees. Milk spoils at 44 degrees.
FACT: Keith is sitting in a cell that’s hot enough to melt ice cream.
Guess what?
Canadians with broken heaters wear jackets and don’t freeze to death. Keith likely has a blanket to keep him warm which is even better than wearing a jacket.
Plus, Keith hails from ALBANY which is basically just a southern province of Canada and a bonafide “cold-as-fuck” ice box.
So he’s gotta be accustomed to cold temps.
Let’s not forget that Keith takes late night walks in Albany every single night (with pussy that he fancies) even during wintertime, so I’m not sure what the fuck he’s complaining about.
That panzy-ass pussy!
Plus what about his likely masturbation? I’m sure he’s jackin’ his beanstalk at least 10 times per day and that’s gotta keep him warm too. He reportedly has erection problems (according to Frank Parlato) so in order to achieve RELEASE he’d have to spank his monkey at least 5 times faster than the average male. That creates heat and raises his internal body temperature. It’s just basic physics.
Plus what about Keith’s excess body fat? That pudgy mother fucker has lots of excess body fat which functions just like a polar bear’s body fat to shield him from cold temps in the winter.
Plus he’s stocky with short limbs, which helps to keep his body warmer than a taller and lankier guy. Being a short & fat slob has very few privileges in life, but keeping warmer is one of them.
Look…
If things are truly as ‘dire’ as Agnifilo claims then Keith (along with many other inmates) should be reporting to the prison hospital for pneumonia and other SERIOUS issues. But they’re not!
This is likely just more drama-queen antics from Agnifilo. Let’s not forget, this is the same guy who filed a motion claiming that Keith was basically kidnapped at gunpoint by Federal police in Mexico. LOL. Most people would call that being “arrested”, not kidnapped, but Agnifilo loves his drama-prone wording.
Plus, isn’t Teny Geragos the daughter of Mark Geragos? He’s one of the most silly and drama prone lawyers on Earth. Like daddy like daughter, I guess. Marc and Teny should join the circus as honorary clowns, they’d fit right in.
*guaran-fucken-tee (not guran-fucken-tee) 🙂
In the immortal words of Vanguard: “There are NO VICTIMS only volunteers.”
At least two of these incidents were mere manifestations of Vanguard’s own mighty Mothman powers — the January 27th fire and the Polar Vortex itself, obviously.
But the most chilling revelation of KAR’s powers in this seemingly frivolous filing is found in its footnotes, wherein the Govt.’s “RUSE” is revealed. For it was KAR — The Vangurd himself —not the evil Govt. oppressors — who first declared this case complex, as God and Marc Agnifilo both witnessed!
Who does he think he is?! This is prison for crying out loud! There are a lot of other prisoners in there and we don’t hear then whining. Maybe he should consider sharing his bed with another inmate to “warm up.” LOL
“SHRUGS”
Like I could care Keith is suffering.
Like Shylock, I want his victims to get their pound of flesh and then some.
Another filing, cha-ching!
Jail is suppose to be a deterrent. Not a country club. Don’t want to be uncomfortable, don’t be an oxygen wasting piece of filth like this shit bomb receptacle.
For christ sake, stop crying like a little bitch.
No, it’s not a deterrent, considering how many go to jail. The criminals always weigh the risk
of being caught and sentenced against them against the profit / benefit of the crime.
Actually, the criminals generally don’t weigh the risk or miscalculate the risk.
Why did Marc send a woman from his law office in Albany to make the dangerous trip to NYC during the “Polar Vortex?” Is he as soft as Raniere?
Hey Flowers,
If you want to worry about something…. worry about whether the Patriots will cover the point the spread at this years Super Bowl!!!
Hey *Nice* guy
If YOU want to worry about something, why don’t you worry about what drives you address a rude comment to a women you don’t know and who has never once addressed you previous to this.
Misogyny perhaps?
Perhaps Keith Raniere in a former life was a holocaust survivor and is just having flashbacks? Keith believes many of us our reincarnated. Reincarnation can be a tricky thing poor Kieth.
Or more likely my impromptu article published on January 26, 2019 inspired the Great Vanguard and his criminal defense attorney.
I can only dream to have influenced the worlds greatest mind Vanguard!!!
Actually it would be a nightmare. I would never want to help out an alleged child molester.
Awwww…Poor Vanguard! Temps too cold? Call the WHAAAAmbulance. Boohoo. Boohoo.
If it was really that bad, the ACLU and bleeding hearts would be protesting. It was prolly just a little chilly at MDC.
What is really cruel & unusual punishment is that crazy attorney billing.
3.5 hours from Albany to MDC. 7 hours roundtrip + 3 hours preptime = 10 billable hours at $1,000 per hour.
So that trip from the Albany associate attorney cost El Cheapo’s Trust $10,000. Now that hurts!!! No wonder the money in the Trust is almost gone. At this rate, it will be depleted in 1-2 months.
Perhaps they should warm up KR with a hot cauterizing pen!
Now that is funny. It could take his mind off the Non-club Med Cancun conditions he feel entitled to. A good branding could also toughen up the stumpy soft cry baby Jane. It’s character building, right.
Needs to be done ON the junk. Accept the pain, Vantard.
Excellent idea
If the description of those conditions is accurate, I think its appalling to treat the prisoners this way.
I think all of us who have suffered because of crime can feel vengeful at times and hope that the criminals suffer, but treating them this way doesnt help anyone, and their suffering doesn’t help their victims heal.
Still blaming others for the mess you created for yourself, EH?
Whatev. Guess that’s the Dems for you. Crying for the incarcirated and totally fine with murdering full term babies. Go figure.
And that’s the far right for ya … incredibly illogical but far too stupid to know how illogical they are.
Go figure.
I agree the treatment is appalling, especially since many there are simply awaiting trial and have not yet been convicted. Some of them may even be innocent. Reading the NY Times coverage was eye opening.
It’s not a country club, but for God’s sake, if the heat breaks and it’s 44 degrees or lower in there, what would it take to obtain and hand out some blankets?
Exactly. It’s completely inexcusable to treat people like that. They could distribute some warm clothing to the inmates. Why can’t they get a generator so at least they can have some warm meals. Also, consider the working conditions for the employees there (but who at least get to go home each day and warm up.)
I think the comments here are pretty telling of the general mindset of most of those who follow this forum.
No surprises there….
Based on this argument, everyone at MDC should be released. Let’s just let all the prisoners go!
What mess are you talking about?
And where do I say that prisoners should be released? Why would anyone suggest releasing dangerous criminals?
You need to learn to read before you can comment, Al.
He forgot to add……Due to the low temperatures ink pens freeze up making it impossible for him to color his hair.