Prosecution Seeks To Admit Evidence Of Uncharged Criminal Acts – Which, If Approved, Will Almost Certainly Guarantee Convictions

Judge Nicholas G. Garaufis gave his reasons why he sentenced Keith Raniere for more than a century behind bars.

[Editor’s Note: The motion described in this post was filed on March 13, 2019, one day after Nancy Salzman pleaded guilty to one charge of Racketeering Conspiracy – and several weeks before Lauren Salzman and Allison Mack entered into plea deals. Needless to say, things have gotten worse – much worse – for the remaining defendants in this case as a result of those pleas].

The prosecution has sought approval from U.S. District Court Judge Nicholas G. Garaufis to admit evidence of “uncharged criminal acts and other acts committed by the defendants and other conspirators”.

If the prosecution’s motion is approved, it will be allowed to introduce such evidence to prove:
– The existence of the criminal enterprise that is the basis for Count One: Racketeering Conspiracy and Count Two: Racketeering in the second superseding indictment;
– The defendants participated in a pattern of criminal activity; and
– The defendants were members of – and participated in – the criminal enterprise.


The evidence of “uncharged criminal acts and other acts” that the prosecution plans to introduce includes, but is not limited to, the following:
– The way in which Consumers Buyline, Inc. (CBI) was structured and operated – and the fact that it served as a model for the way that NXIVM was structured and operated. One member even referred to NXIVM as “CBI Part 2” in an email to Nancy Salzman.

– The fact that Keith Raniere was aware of unpaid tax liens and other judgments against him and CBI – and did nothing to resolve them. In addition, he proactively worked to keep assets out of his name in order to avoid paying his past judgments – and to keep himself “judgment proof” going forward.

Keith may not have invented the internet but he did create Consumers Buyline, Inc.

– NVIVM’s practice of allowing individuals who could not afford to pay for more classes to commit to “exchanges” of their labor in lieu of class fees – but never providing a clear accounting of what these individuals had paid off or how much they still owed. In one instance, a couple accumulated more than $300,000 of debt through such “exchanges” – which eventually forced them to file for bankruptcy.

– NXIVM’s practice of recruiting people to work for the company by offering them lucrative positions – and then informing them, after the fact, that they were not being paid everything they were owed because they had “issues” that needed to be resolved before that would be done. In order to resolve those “issues”, the recruits were encouraged to take EMs (“Explorations of Meaning) – which often cost more than what they were owed.

– The fact that NXIVM members were often told they had committed “ethical breaches” – i.e., some sort of harm that they supposedly caused to the NXIVM community – that they needed to remedy in order to advance in the organization. These supposed “ethical breaches” were arbitrary – and could include things like failing to complete assigned tasks in an appropriate manner, failing to lose weight quickly enough, “playing the victim”, causing negative publicity for NXIVM or Raniere, etc.

– NXIVM’s teachings that women were inferior to men, that men were naturally inclined to have multiple sexual partners while women were meant to be monogamous, and that women who had been sexually assaulted were likely to blame for what happened to them.

This is an artist’s conception: Keith Raniere [standing in shower left] teaches a beta male of The Society of Protectors [lower center on hands and knees ] and his DOS slave wife
– The use of various techniques to illegally bring cash received from foreign students taking classes in other countries into the U.S. Thereafter, NXIVM would record those students as having received “scholarships” in order to avoid having to pay taxes on the fees they paid to the company.

– The use of multiple schemes that were designed to hide NXIVM’s true profitability – and its tax liabilities. In addition, similar schemes were used to disguise the reality that Raniere had access to and controlled all the financial resources of NXIVM and its various affiliates.

– The fact that at least 14 members of the NXIVM community were directed to make the maximum possible financial contribution to the presidential primary campaign of Hillary Clinton in 2007 with the understanding that they would be fully reimbursed for their “contributions” by Clare Bronfman or Nancy Salzman. The overall purpose of this scheme was to gain political influence with the candidate so that “perceived enemies of Raniere” could be targeted in the future.

– The attempt to illegally secure visas and immigration status for dozens of non-citizens so they could work in NXIVM and/or in one or more of its affiliated organizations. Several of these non-citizens obtained visas in order to work as “Research Analysts” for a company owned by Clare but actually ended up working as “Multi-Cultural Development Specialists” (AKA unqualified “nannies”) for Rainbow Cultural Garden LLC.

– The use of various illegal schemes to assist sexual partners of Raniere to enter – or remain in – the U.S. This specifically included hands-on assistance from Kathy Russell and Clare Bronfman.

– The arranging of “sham marriages”, often at the direction of Clare or Keith, so they could have various non-citizens remain in the U.S.

– The recruiting and grooming of sexual partners for Raniere – which was done at his direction – both before and after he founded NXIVM. This included at least several underage girls: i.e., a 12 or 13-year girl when Raniere was running CBI – and a 15-year old when he was running NXIVM.

– The use of aggressive – and, in several instances, illegal tactics to gather personal information about perceived enemies of Raniere. “The targets of these efforts included federal judges overseeing litigation in which Nxivm was a party, political operatives, high-ranking politicians, reporters, ex-girlfriends of Raniere, Nxivm’s own lawyers, legal adversaries, and their families, John Doe 2 and John Doe 1’s employer”.

– The use of abusive litigation – and the obstruction of justice – “to seek retribution against individuals who left Raniere, defected from the Nxivm community or who spoke critically of either”. This included Clare’s active attempts to get various people indicted – and Keith’s false and misleading testimony in his lawsuit against AT&T and Microsoft.


So, just imagine what kind of impression a juror will form about whichever of the current defendants – Keith Raniere, Clare Bronfman and Kathy Russell – ultimately decides to go trial when they hear about all those “uncharged criminal acts and other acts”.

And remember, the jurors are going to hear all that BEFORE the prosecution introduces any evidence about the crimes that each of the remaining defendants has been charged with.

Seriously, if Judge Garaufis allows this evidence to be introduced – which I believe he will do – you’ve got to wonder why any of the defendants would choose to go forward with the trial.

Viva Executive Success!


Editor’s Note: One week after it filed this motion, the prosecution unveiled the second superseding indictment – which, among other things, included charges of possession of child pornography and sexual exploitation of a child. Although those crimes were subsequently dismissed and transferred to the NDNY for prosecution, it will be up to Judge Garaufis to decide whether evidence of them can still be introduced in the EDNY trial to prove the existence of the criminal enterprise. 

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K.R. Claviger


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  • Frank. Given the many insinuations in your recent articles, I have to ask if there was any point at which women of the inner circle believed they knew “too much” and felt unsafe. Are any women willing to go on record?

  • If the judge doesn’t allow any of that to be admitted, all the prosecution needs to do is admit that photo of KAR next to the flip chart. Talk about a dweeb! How a group of attractive women got conned into a sexual relationship with this portly little effeminate guy is baffling.

    • I thought this the moment I first saw Keith short fat and not attractive. Two hours later, I was not impressed with his intelligence. He said nothing of substance.

  • Evidence must be true or else is should not be admitted. And it must be admitted in context. Keith Raniere did nothing but help people. You are NOT the judge of the good he did. He is so good and the judge is allowing him to appear to be a criminal in plain sight by allowing false evidence. The judge is evil. This is a mistrial. He always sides with the prosecution. What’s with that?

    • Oh Pea Brain,
      Don’t ya think the United States has a legal system that knows what can and can’t be admissible in court?

      This is a RICO case and evidence from the past can be brought into this case to show a pattern of criminality.

      This isn’t a kangaroo court where justice is bought and sold.


    • Wow, Yolan-dunce you are high on meth! Once you ween yourself off of it, you will be able to handle the truth that your V manipulated ALL OF YOU… because I look at photos of him and have no idea how any woman would want to have relations of any kind with him!

      • Or it’s just a troll.

        The irony is, it’s hard to tell the difference between the predictable things a deluded true believer will say, and the easily predicted things that a troll would post as bait.

        I think it’s about as sad that true believers would post in a forum like this as a sort of demonstration of faith – psychologically, it’s often part of the process in which they try to reinforce their own beliefs in the face of challenges, and possibly their own doubts* – as that people would take time to troll rather than doing something more contributory and positive.

        * Also part of the same psychological mechanism exploited, when groups send members out to proselytize – often in pairs, who effectively thought police one another – which functions as much or more to reinforce belief, as to recruit.

  • Consumers’ Buyline was actually Amway 2.0. If Amway didn’t have the political influence via massive campaign contributions over the years, estimated to be on the order of $200 million, it would have been shut down decades ago.

      • Actually, it is a partisan issue when it comes to Amway. Republicans are seen as pro-business, and that’s why almost all money from Amway went to Republicans. One of the founders was even in charge of the Republican finance committee until he got booted for bringing unwanted attention for ripping off Canada, and eventually plead guilty both criminally and civilly, paid $50-60 million in fines.

      • Amway loaded both American political party coffers and as well as international. I am no fan of Amway but get back to us when they pulled the shit that NXIVM did.

        • Actually, Amway gives very little to the Dems. Amway may not have done exactly what NXIVM did, but they did it, and are still doing it, to 1,000s of times more people. There are divorces, bankruptcies, ruined relationships, massive debt, and lots more. Most of NXIVM’s participants were relatively wealthy and took an overpriced course or two and left. It’s not even close.

  • The way people were lured to jobs with bait-and-switch pay packages that were actually conditional, penalized over infractions that were arbitrary or trivial, and put into debt, reminds me of the tactics of Scientology.

    And just to demonstrate how the Bronfmans were trying to buy influence on both sides of the political fence, in addition to all the smaller donations to Clinton, Clare and Sara also gave much larger amounts that were permitted, about equal to all of the smaller ones together – to a New York State Senate campaign fund. The really interesting thing about those larger donations, though, was that was local to Albany, where NXIVM seems to have been successful in buying influence and using the legal system to go after “perceived enemies of Raniere” in ways that have yet to be fully explained.

    • Names of these republicans please and are any of them still involved in government. Thank you

  • Thanks Krclaviger for the awesome news and taking the time to explain the legal complexities so us lay people can understand it all.

    Hope you have a good night !!!!!

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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