It’s as long as book – the entire complaint filed against Nxivm leaders, Keith Raniere, Sara Bronfman, Clare Bronfman, Nancy Salzman, Lauren Salzman, Allison Mack.
The plaintiffs number 80 — all of them anonymous except lead plaintiffs Sarah Edmondson, Mark Vicente and Toni Natalie.
There are 60 women and 20 men. The complete complaint is here
Here is the summary of the case:
The case is filed in the US District Court in the Eastern District of NY, the same jurisdiction that tried Keith Alan Raniere and convicted him.
The lawsuit is against
KEITH RANIERE;
NANCY SALZMAN;
CLARE BRONFMAN;
SARA BRONFMAN;
LAUREN SALZMAN;
ALLISON MACK; :
KATHY RUSSELL;
KAREN UNTERREINER; :
DR. BRANDON PORTER; :
DR. DANIELLE ROBERTS; :
DANIELLA PADILLA BERGERON;:
ROSA LAURA JUNCO;
LORETA J. GARZA DAVILA;
MONICA DURAN;
NICKI CLYNE; :
NXIVM CORPORATION; :
EXECUTIVE SUCCESS PROGRAMS, INC.; :
ETHICAL SCIENCE FOUNDATION; and :
FIRST PRINCIPLES, :
:
Defendants. :
—————————————————————x
COMPLAINT
Plaintiffs file this complaint pseudonymously against the Defendants for conspiring to operate, and for operating, a criminal Enterprise under the “NXIVM” umbrella (the “Enterprise”). Defendants also conspired to participate and participated in a “Venture” to commit sex trafficking, peonage, forced labor and human trafficking offenses in violation of Chapter 77 of Title 18.
The central purpose of the conspiracy, Enterprise, and Venture was to entice Plaintiffs to join NXIVM, which functioned as both a Ponzi scheme and a coercive community.
Defendants exerted power over the Plaintiffs; took their money; made it financially, physically and psychologically difficult, and in some cases impossible, to leave the coercive community; and systematically abused Plaintiffs physically and emotionally. In doing so, the Defendants achieved a number of personal benefits including but not limited to enriching themselves; wielding power over others; advancing in the perverse social order they created; and enhancing their own feelings of self-esteem.
Many of the Defendants also benefited financially through the receipt of profits and substantial access to free labor, including personal assistants, housekeepers, drivers, personal shoppers and others.
In pursuit of both the Enterprise and the Venture, Defendants engaged in a variety of wrongdoing, some of it tortious and some of it criminal. Each Defendant played a critical role in the conspiracy, and neither the Enterprise nor the Venture could have functioned without them – particularly Keith Raniere and Nancy Salzman who created NXIVM, as well as Clare and Sara Bronfman, who served in leadership positions and who invested their vast wealth – reportedly $150 million – to fund the operations and obstruct the ability of others to uncover the misconduct. It was foreseeable that each of the Plaintiffs would be harmed by this conduct, and all conspirators are liable for the entire amount of the physical, emotional, psychological, and economic harm caused to the Plaintiffs.
SUMMARY OF THE ACTION
1. Plaintiffs’ claims arise out of their involvement with NXIVM Corporation (pronounced /NEX-ee-um/), an organization based in Albany, New York and founded by Defendants Keith Raniere (“Raniere”) and Nancy Salzman.
2. NXIVM’s principal business is the sale of personal improvement and professional development training programs through Defendant Executive Success Programs, Inc. (“ESP”) and other entities.
Footnote 1 However, as described herein, NXIVM’s insidious reach extended far beyond just ESP, and it was far more than simply a personal improvement program.
3. Drawing from methods used in pyramid schemes and multilevel marketing, NXIVM induced students to recruit and form their own downstream sales organizations within NXIVM, so that the students might work their way up in the hierarchy, known as the “Stripe
Path” (after the colored striped sashes members wore to indicate rank and recruitment achievements), to a level where they could earn commissions and build careers and income for themselves.
4. However, few students ever qualified for commissions, because the Defendants continually manipulated the program requirements, expanded the required curriculum, and graded most of the students as failures who needed to work harder and take more of NXIVM’s
expensive courses. Out of the more than sixteen thousand people who took NXIVM’s courses, fewer than one hundred ever earned any income from NXIVM’s businesses, and fewer than twenty-five received substantial earnings within NXIVM.
Most of the earnings were received by the small group collectively known within the organization as the “Inner Circle.”
5. Raniere claimed to be the conceptual creator of NXIVM’s programs, and the various related legal entities themselves. Defendants promoted NXIVM’s programs in part by representing that Raniere was the world’s smartest man, who allegedly had an IQ of 240 and was
a child prodigy, speaking in complete sentences at age one, mastering college level mathematics in two days at age eleven, winning championship judo and track tournaments, and graduating college with three degrees. None of this was true.
Footnote 1 Unless otherwise stated, “NXIVM” means NXIVM, ESP, First Principles and all other NXIVM-related entities identified as such herein. Members of NXIVM were sometimes referred to as “Nxians” (pronounced “Nexians”) and sometimes as “ESPians” (pronounced “Espians”).
6. Before forming ESP with Nancy Salzman, Raniere ran another pyramid scheme called Consumers Buyline Inc. (“CBI”) that was investigated by 25 state attorneys general and eventually shut down by New York’s Attorney General Robert Abrams on September 3, 1996. Pursuant to the consent decree entered in that case, Raniere was permanently prohibited from “promoting, offering or granting participation in a chain distributor scheme in the State of New York.” Two years later he was back at it with ESP.
Rational Inquiry
7. NXIVM’s programs were based upon a system Raniere and Nancy Salzman labeled Rational Inquiry. Defendants claimed this was a patent-pending technology for changing behavior and thinking. They claimed that it was based in science and could thus be replicated,
producing empirically measurable results. Defendants also claimed that NXIVM’s system or “tech” could cure medical conditions, including Tourette’s Syndrome and Obsessive-Compulsive Disorder. None of this was true.
8. Rational Inquiry had two primary components: (1) a self-esteem eroding curriculum designed to break down students’ resistance to Raniere’s and Nancy Salzman’s radical reframing of ethics, morality, and gender roles and relations, among other things, and (2) an inherently dangerous form of psychotherapy called “Exploration of Meaning” (“EM”), which was administered by so-called EM Practitioners (“EMPs”), all of whom were unqualified to practice psychoanalysis, psychology or mental health counseling. Nancy Salzman, the principal
therapist and head of this individual therapy branch of NXIVM, held a nursing license and claimed to have a background as a psychiatric nurse. In fact, she worked as a nurse for only one year in a general practice and did not have a license to practice psychotherapy.
9. Defendants intended, knew, or deliberately disregarded the fact that EM exposed its subjects to a high risk of injury, because over time it produced disturbing alterations in the subjects’ thinking, behavior, and emotional experience.
10. The longer someone was immersed in this system, the more likely it became that they would suffer moderate-to-severe psychological and emotional injuries, including post traumatic stress disorder and complex post-traumatic stress disorder. Many of the Plaintiffs in
this action were injured in this way and still struggle with the effects of their time in NXIVM and exposure to Defendants’ programs.
Psychological Dependence and Coercion
11. Through the continual and systematic application of the Rational Inquiry methods, Defendants obtained the complete trust of their victims, rendering them psychologically and emotionally dependent upon the Defendants. On a near-daily basis, these victims were told that they were failing to advance on the Stripe Path and improve their careers, income and well-being, because they were not working hard enough on their “issues” and thus needed to take additional courses and receive additional EMs.
12. Once Defendants had stripped members of their psychological defenses, they exploited these highly vulnerable people for advantage and gain. This included coercing members into working for the Defendants on “exchanges” in which they would be severely undercompensated or even uncompensated for their labors, but for which they supposedly would earn credits toward the additional expensive courses and EMs that they were assured would improve their lives.
13. Quitting was failure and would result in immense shame and humiliation. Further, it could expose the victim to malicious litigation, a common tactic of the Defendants, and would leave the defector shunned, declared a “suppressive” or “psychopath”, and cut off from the community of friends that had, as a direct and intentional result of Defendants’ efforts, become his or her entire world. Being shunned also meant losing one’s livelihood, which for a community of people who were impoverished and in debt, having abandoned their former
careers to devote their lives to NXIVM, made it impossible in many cases to simply walk away.
Illegal Experimentation on Human Beings
14. The Enterprise and Defendants were also responsible for conducting experiments on NXIVM members that strayed far beyond the bounds of what is acceptable in the medical and psychotherapeutic professions. Indeed, these reckless experiments, sponsored, financed, and facilitated by Defendants Clare and Sara Bronfman, seriously damaged many people.
15. For instance, at least forty members of the NXIVM community, trusting in Raniere, Nancy Salzman and Defendant Dr. Brandon Porter, M.D. (“Porter”), were subjected to a “human fright experiment,” in which individuals were seated in front of a video display with electroencephalogram (“EEG”) electrodes placed on their skulls to measure brainwaves. These subjects believed they were going to watch a talk by Raniere, but instead were subjected to scenes of escalating violence including actual, extremely graphic footage of the brutal beheading and dismemberment of five women in Mexico.
16. There were other so-called medical studies as well, which purported to prove that use of Rational Inquiry could cure illnesses, including Tourette’s Syndrome and ObsessiveCompulsive Disorder.
17. Because of the involvement of Porter, these “studies” attracted the attention of the New York State Board for Professional Medical Conduct. Multiple hearings were held between June 2018 and April 2019, witnesses were heard, documents were reviewed.
18. Ultimately, an opinion was issued, vilifying Porter and terminating his license to practice medicine in New York. It laid out in excruciating detail the many reckless, unethical experiments on human beings that Porter performed at the behest and with the complicity of his co-conspirators at NXIVM.
DOS – The Subjugation and Exploitation of Women
19. Beginning in or about 2015, the Defendants formed an organization within NXIVM called “DOS” (or the “Vow”), secretly headed by Raniere. Defendants Allison Mack, Lauren Salzman, Rosa Laura Junco, Daniela Padilla Bergeron, Loreta J. Garza Davila, Monica
Duran, and Nicki Clyne held high positions in DOS as “First Line Masters.”
20. First Line Masters were tasked with selecting attractive, trustworthy women who could become sexual partners for Raniere. Recruits were told they were being invited to join a sisterhood, which would empower them to overcome the weaknesses that Raniere and the other Defendants taught held them back in life. Recruits were told that DOS offered a unique opportunity to enter a one-on-one mentorship with women who had been elevated in stature within the community, and who thus were looked up to as role models.
21. Recruits were also told that DOS was an all-female group in which no male had a role. These features made DOS appear unique and desirable for women who, through subjection to Defendants’ methods, had been primed to want precisely just such a once-in-a-lifetime
“opportunity.”
22. In order to find out more about this sisterhood, prospective DOS recruits were required to provide “collateral” to prove their trustworthiness. The collateral could consist of assets, compromising confessionals, letters falsely accusing close family members or friends of unethical, immoral or illegal conduct, nude photos, videos, or other materials that would, if released, subject the recruits or their loved ones to loss, humiliation or shame.
23. After supplying collateral, which had to be approved by the First Line Masters and Raniere, DOS was revealed to the recruits. But to their surprise and dismay, they were told that now, before they could learn about the structure and nature of this sisterhood, they had to
provide additional humiliating and damaging collateral. Thus, before knowing anything about the internal workings of DOS, they were trapped, fearful that if they did not do precisely as instructed, the collateral that they had already provided would be released.
24. Once that second collateral had been given and approved, the recruiter/master revealed a little more about DOS: that it was a pyramid of “master/slave” relationships, explained as no different from a guru and disciple or a mentor-mentee relationship, which would
strengthen women by testing and challenging their boundaries but would require absolute trust and obedience by “slaves” to their “masters.” Shortly after being admitted into the group, slaves were commanded to provide additional collateral every month.
25. Even after providing abundant collateral, however, the slaves were never told certain material facts: that Raniere created and ran DOS with the assistance of the First Line Masters (if asked, the First Line Masters denied Raniere’s involvement); that the gathering of
collateral was intended to coerce women into a lifetime of personal servitude; and that the ultimate objective of DOS was to recruit and groom women for sexual slavery under their “grandmaster” – Raniere.
26. In exchange for developing and operating this pipeline of attractive young women for Raniere, the First Line Masters of DOS acquired personal servants or “slaves,” garnered favor with Raniere and achieved elevated status, stature, and power within NXIVM.
27. DOS “slaves” were subjected to a severely abusive environment, which included caloric deprivation, sleep deprivation, arduous physical labor, performance of menial tasks, and a variety of punishments for any failure to fully comply with their masters’ commands. They had
to “check in” with their masters when they awoke and when they went to bed with text messages of “good morning M” and “goodnight M.”
28. Further, they had to be available to their masters twenty-four hours a day, because they were subjected to a stress-inducing sleep-deprivation technique referred to as “readiness drills,” in which they would receive a message on their phones with a “?”, to which they had a mere sixty seconds to respond “ready M.”
29. Failure to timely respond to their masters’ calls resulted in punishments called “penances” or “consequences,” which included long cold showers, extended periods during which they had to hold themselves in a physically demanding position known as a “plank,” ridicule, extreme diets, being forced to strip naked and be paddled on the buttocks, and, if a master so chose, imposition of these same punishments on other “slaves.”
30. “Slaves” were also required to clean their masters’ homes, shop for their groceries (at times with their own money), buy gifts for their masters, do their work for them and, for some “slaves,” be available for sex with Raniere on demand.
31. At all times, in addition to the continual threat of punishments within this highly regimented and abusive environment, “slaves” were acutely aware of the ultimate punishment hanging over their heads: the very real threat that their collateral would be released. Thus,
“slaves” were rendered fully compliant, striving to achieve extremely unhealthy weight loss goals, adhering to diets of as little as 500-800 calories per day, having to ask permission to eat, having to weigh their food and calculate calories precisely, even having to send photographs of everything they ate to their masters.
32. “Slaves” were thus in a constant state of near-starvation, sleep deprivation, forced to physically exert themselves and push themselves well beyond exhaustion, always anxious and fearful that anything they said or asked might be interpreted as rebellious and subject them to punishments, both mental and corporeal.
33. Not a single DOS member understood when she gave that first collateral that she was signing up for a life of servitude and sexual slavery under a cruel grandmaster and his circle of mistresses.
Branding
34. Some DOS “slaves” were branded. In a secret ceremony, they were forced to disrobe, read from a script stating they requested to be branded, lie down on a table, and submit to branding with a cauterizing iron in their pubic region. No anesthesia was administered during
this procedure, which was extremely painful. The ceremonies were recorded, thereby creating an additional piece of collateral. They were told that the brand was a symbol representing the elements of nature. Only later did they come to realize that they would be carrying Keith Raniere’s initials around with them for the rest of their lives.
Abuse of Foreign Nationals
35. Defendants also recruited people from foreign countries, offering false promises of educational or financial gain. Ultimately, they left these recruits in compromised circumstances, without an immigration status, leaving them working for little or nothing, accumulating debt and fearful that if they left the NXIVM community they would be arrested and deported.
Vexatious Litigation and Threats of Litigation
36. In order to silence critics and witnesses, Defendants engaged in withering campaigns of abusive, vexatious litigation and the initiation of bogus criminal investigations, by falsely accusing people who left the community, going so far as to inject themselves into these
victims’ NXIVM-caused bankruptcy proceedings. It has been reported that, with the involvement and backing of Defendant Clare Bronfman, NXIVM hired 50-60 lawyers from 30 or so law firms to pursue litigation or threats of litigation against actual or perceived potential NXIVM critics.
37. These highly publicized in terrorem legal wars were financed in large part by Defendants Clare and Sara Bronfman. Also, as part of a pattern of vexatious litigation, witness tampering, and retaliation, Defendants engaged in and directed unlawful activities including
perjury, making false statements to law enforcement agencies, destroying or altering evidence, spying on victims and their attorneys, computer hacking, intercepting communications, and even attempts to unlawfully obtain financial account records and other private information about federal judges and other “enemies.”
38. These activities intimidated victims and witnesses, who were so fearful of ending up on the receiving end of a destructive legal onslaught that they were, in fact, silenced, prevented from asserting claims for their injuries, prevented from making statements in support
of others who had been injured, and prevented from reporting to and/or cooperating as witnesses for law enforcement with respect to Defendants’ unlawful activities.
39. Numerous Plaintiffs suffered in silence for years, even avoiding cooperation with law enforcement authorities once it became known that the federal government was investigating Defendants. Only now, after the guilty pleas and convictions of a number of the Defendants, do Plaintiffs feel safe enough to come forward and assert their claims. So great was the fear generated by Defendants, that Plaintiffs believe there are still many victims and witnesses hiding in the shadows, frightened at the prospect of seeing their lives further destroyed if they come forward and assert their rightful claims in this or any other legal proceeding.
Investigation, Indictments, Guilty Pleas, and Guilty Verdict
40. The United States Department of Justice (“DOJ”) investigated NXIVM.
41. On April 19, 2018, the first of several indictments was unsealed, charging Defendants Keith Raniere and Allison Mack with federal sex trafficking and conspiracy crimes based on with their operation of the Enterprise, Venture, and conspiracy.
42. On July 23, 2018, a second indictment was unsealed, adding new charges and four more Defendants, Clare Bronfman, Nancy Salzman, Lauren Salzman, and Kathy Russell.
43. On March 13, 2019, Nancy Salzman pled guilty to one count of Racketeering Conspiracy, admitting to predicate acts of identity theft and altering records for use in an official proceeding.
44. On March 25, 2019, Lauren Salzman pled guilty to counts of Racketeering Conspiracy and Racketeering, admitting to predicate acts of Trafficking and Document Servitude, State Law Extortion, and Forced Labor.
45. On April 8, 2019, Allison Mack pled guilty to counts of Racketeering and Racketeering Conspiracy, admitting to predicate acts of State Law Extortion and Forced Labor.
46. On April 19, 2019, Clare Bronfman pled guilty to counts of Conspiracy to Conceal and Harbor Aliens for Financial Gain, and Fraudulent Use of Identification.
47. On April 19, 2019, Kathy Russell pled guilty to Visa Fraud.
48. These five women will be sentenced in the next few months. Each is expected to be sentenced to terms of imprisonment ranging from 18 months to five years or longer.
49. Defendant Keith Raniere, the commander-in-chief of the Enterprise, went to trial (the “Raniere Trial”), and on June 19, 2019, was convicted by a jury of Racketeering Conspiracy, Racketeering, Forced Labor Conspiracy, Sex Trafficking Conspiracy, Sex Trafficking, Attempted Sex Trafficking, and Wire Fraud Conspiracy, all involving NXIVM. He faces possible life imprisonment.
50. The Defendants benefited from participation in the forced labor and trafficking venture within the Enterprise in several ways. First, they received enhanced status, titles, and power to wield over the rank-and-file members, as well as enhanced feelings of self-esteem and
worth, because they were deemed “successes” within the Enterprise. Second, they benefited financially through the receipt of profits and substantial access to free labor, including personal assistants, housekeepers, drivers, personal shoppers and others. Third, the Defendants received the satisfaction of believing that they were at the forefront of a new era in the history of human civilization, and they were poised to benefit by gaining exceptional status within this remade society they were setting out to create.
Indeed, for Defendants Clare Bronfman and Sara Bronfman, the benefits they received, including perceived future benefits, warranted an
investment of a reported $150 million.
Plaintiffs’ Claims
51. Each of the Plaintiffs in this action was a member of the NXIVM community. As set forth below, some Plaintiffs were recruited into DOS, others were subjected to one or more medical experiments, and others were manipulated and coerced into servitude. All Plaintiffs in
this action expended substantial sums of money for what they were led to believe were legitimate courses in self-development.
52. None of the Plaintiffs consented to be the subject of the unauthorized practice of psychoanalysis, psychology or mental health counseling, and indeed none recognized that they were psychotherapy subjects, because those elements were masked within the larger frame of Rational Inquiry. Many of the Plaintiffs suffered emotional and psychological injuries as a result of their subjection to the Rational Inquiry methods and the highly abusive environment of the NXIVM community.
53. Plaintiffs bring claims for compensatory and punitive damages, disgorgement and other equitable relief against Defendants for conspiring to and operating a criminal Enterprise and Venture, the objects of which were financial gain, self-aggrandizement, and psychological benefits through a continuing pattern of multiple acts of mail fraud; wire fraud; identity theft; unlawful interception of wire and electronic communications; unlawful accessing of electronic data storage devices; visa fraud; peonage; document servitude; forced labor and sex trafficking; negligence per se and negligence for engaging in, aiding and abetting, and acting in concert to engage in the unauthorized practice of psychoanalysis, psychology and/or mental health counseling; negligence per se for engaging in, aiding and abetting and acting in concert to engage in unauthorized and unlawful human medical experiments; malicious abuse of legal
process; and claims arising under 18 U.S.C. § 1595(a) for peonage, forced labor, sex trafficking, and conspiring and attempting to engage in peonage; forced labor and sex trafficking in violation of 18 U.S.C. §§1581, 1589, 1590, 1591, 1592; and 1593A, and violations of the Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C §§ 1962(c) and (d).
************************************************
Obviously the money defendants are Clare and Sara Bronfman, and Rosa Laura Junco. It is interesting that Emiliano Salinas and Alex Betancourt are not defendants.
Stay tuned for more.
To read the complete complaint
Frank Parlato 
Janine Morrison 
J.J. O'Hara 
Richard Luthmann 
Marie White 
Paul Serran
Please leave a comment: Your opinion is important to us!
I was thinking, what’s the point, except for our entertainment and some lucky lawyers getting rich to defend these idiots, First Principals is worthless. Aren’t Natalie and company bleeding a turnip? Won’t this actually work against them, especially Natalie? She’s a thief pointing fingers at a thief. It wasn’t the actual criminality that made Vicente and Edmondson leave anyway. They were consenting adults and branding strangely is still not illegal.
Every person who ever took classes with Nx is “branded.”
If you are in the public eye at all, the internet will link you to “Nxivm, a sex cult” FOREVER.
If you are the average person, maybe just your friends and family may know…until the gossip, then your boss, your co-workers, the other parents in your PTA, the members of your church will think–“What, she was in Nxivm? Wasn’t that a sex cult?!
It doesn’t matter if you weren’t in, and never even heard of Keith’s harem or DOS or even Smallville, others will always doubt, just a little, you claim tha “it was a self-help group.”
Test
Frank& Claviger,
Not all victims of NXIVM are equal or equivalent in suffering and pain in regards to their damages
No doubt all of NXIVM’s victims deserve compensation for their pain and suffering.
Some of NXIVM’s victims suffered more than others.
Example:
Do Toni or Mark Vicente deserve as much money as Dani?
From reading a summary of Glazer’s lawsuit, it is my understanding that all victims have “equal standing” to any verdict or settlement.
I believe and am of the opinion attorney Glazer is doing a disservice to Dani and some of the other plaintiffs.
If I were everybody except Toni, I’d fire Glazer. This is going to be embarrassing for all of them. IMO
If Bonehead Neil Glazer has Toni Natalie as a Lead Plaintiff, he’s in trouble.
Isn’t this the same NEIL GLAZER that threatened the readers of the Frank Report with a civil lawsuit because we exposed Toni NataLIE’s lies.
It seems more like a yell from the law firm of Dewey Cheatham and Howe than a whimper from a reputable firm or even Gloria Alred.
TEN C
643. Raniere, along with Defendants Nancy Salzman, Allison Mack and Nicky Clyne,
created another group called “TEN C,” which was aimed at procuring young women from
college sororities for Raniere. The young women were promised opportunities to build character
through NXIVM curriculum and programs, and to develop a sisterhood or sorority of women in
their age group within NXIVM, mentored by Mack, Clyne, and Raniere
“TEN C,” which stood for “The Emperor has No Clothes.”
TEN C SHOULD BE RENAMED TEN B.
The Emperor Has No Brains.
Kristin Kreuk should ask Glazer to add her name as a plaintiff. Being part of NXIVM has ruined her reputation, and consequently has been accused of money laundering, recruiting girls into a sex cult and worst of all, virtue signalling.
The last few years of the Frank Report would prove her case.
And it also caused some sick bastard (sultan) to stalk her.
After reading the complaint filed by Neil Glazer I urge anyone who was victimized by NXIVM and these gangsters to contact Attorney Glazer for vindication.
Neil Glazer can add you to the lawsuit and protect your identity.
Glazer should sue a bunch of MLM scams as well, this lawsuit can serve as the template. You can contact me at stoptheamwaytoolscam@yahoo.com, Glazer.
I hope Glazer paid Frank for the content of this lawsuit, it’s all lifted right out of the Frank Report.
I have no idea why Natalie is included in this lawsuit, the defense will rip her a new one with the stories on this website showing that she’s a serial liar. My suggestion, drop her from the lawsuit.
Hey, Frank.
Do you think it’s too late for Allison Mack to join the victims’ list? After all, she was a victim of everything before she became a conspirator.
I believe it is too late. I wish she had gotten out earlier and Catherine Oxenberg and I did make an attempt to reach her and get her to leave but this was before Raniere’s arrest. She was perhaps too busy trying to manage her escaping slaves.
I have some questions that maybe someone here can answer. If the case goes to trial in civil court, will all the defendants have to appear? Can Sara Bronfman and Rosa Laura Junco avoid this by evading process? Would that mean there might be a default judgement against them? I suppose both women have taken their assets out of the US. Mr. Agnifilo asked some of the ex-NXIVM members if they planned to be part of a lawsuit, so this cannot be a complete surprise to anyone. I’d appreciate any feedback on these issues.
It probably varies a bit from state to state, but here’s what is probably a typical arrangement: https://www.tippecanoe.in.gov/841/Default-Judgment
Defendant have been dropped from civil lawsuits when they couldn’t be served: https://behindmlm.com/companies/bitconnect/bitconnect-class-action-reduced-to-three-defendants/
Given the deep pockets of Bronfman and Lunco, it would be difficult for them to hide and it would be worth the time, money, and effort to serve them.
Kristin Kreuk is a victim and may be one of the Jane Does
I doubt she would want to bring attention to the fact that she was trying to recruit under age girls for the convicted pedophile to have sex with.
When it was revealed that Neil Glazer, a tort lawyer, was representing two of the witnesses in the Raniere criminal trial it became quite obvious that a personal injury lawsuit would be forthcoming.
Too many people were injured by the sadistic NXIVM defendants for there not to be a tort trial.
This is where the NXIVM defendants will really get it in the neck!
And when some commenters on the Frank Report foolishly doubted the credibility and the veracity of Glazer’s clients Nicole and Jaye, both of whom gave clear and convincing evidence of Allison Mack’s cruelty and duplicity, Neil Glazer proved that he will be a pit bull in pursuing all of the NXIVM gangsters.
I actually took the trouble to look up the civil provisions of the RICO statute and it showed the blueprint for how a civil RICO case could devastate the NXIVM gangsters.
And I warned the readers of the Frank Report that there would be a civil case using the provisions of the RICO statute.
So all of you NXIVM chuckle heads and Allison Mack fan boys can stew in your own juices.
Mr. Shadow, you’re my HEE-RO!!!
Scott:
No matter what I have said about you and Amway in the past, you have your crusade and it has some value to it.
MLMs are not the only evil in the world but they are frauds against consumers.
Keep up the good fight and be your own hero!
MLMs aren’t evil, MLM scams are evil. Most MLMs are scams, however.
Godspeed, Mr. Glazer.
I hope you make the Bronfmans pay through the nose.
But I do question Mr. Glazer’s choice to include Ms. Natalie as a lead plaintiff, as that choice may wind up hurting the other plaintiffs by lessening any financial judgments that his side may win (or settle for).
How can Mr. Glazer make a strong case that his women are all innocent victims (worthy of a HUGE judgment) if NXIVM exposes stuff like this:
1) Toni was a leading salesperson (and spokesperson) for Keith’s Pyramid Scheme called CBI which was shut down. She even appeared on a TV infomercial (confidently) trying to sucker innocent victims into that scheme. During an ABC interview (more than 20 years later) Toni claimed that the idea behind CBI was ‘brilliant’ —- she showed no remorse for having personally suckered so many victims into that Pyramid scam.
2) Can Mr. Glazer argue that Toni Natalie ‘learned her lesson’ or changed her ways after the CBI debacle? Can Mr. Glazer argue that Toni finally ‘saw the light’ and abandoned Keith and his nefarious activities after CBI? Nope. According to Frank Parlato, Toni started up 2 brand new (failed) pyramid schemes and remained with Keith for several years after the CBI debacle. She was neck deep into Keith’s nefarious financial activities.
3) I’m not sure if Toni’s temporary indictment for ‘allegedly’ committing lease fraud (according to Frank Parlato) is gonna be admissible in this lawsuit, however, I have a hard time believing that Toni’s past history of (alleged) fraudulent activity is gonna be barred from this case —— especially if Toni ‘testifies’ and her character becomes relevant for cross examination, allowing her credibility to be impeached. I’m sure the discovery process will unearth even more negative shit about Ms. Natalie’s past behavior. The Bronfmans will inspect every nook and cranny of her life.
4) With regard to Toni’s lies told in her book (exposed by Frank Parlato), if Toni ‘testifies’ then it’s possible that the Bronfman attorneys will be allowed to impeach her credibility and confront her on these many lies. Especially the lie about blaming Keith for her brother’s decision to commit suicide, since her brother didn’t die of a ‘suicide’ (according to the death certificate and his longtime girlfriend). This will show that Toni is prone to telling lies about Keith Raniere. It shows that she’s willing to lie about Keith for financial profit.
I just don’t see how adding a plaintiff like Toni Natalie is gonna help (and not hurt) Mr. Glazer’s lawsuit.
Other people like Sarah Edmondson and Mark Vincente are good plaintiffs.
Sarah was kept in the dark about many things and was mostly a legit teacher/manager for an ESP center. Mark Vincente is also a decent guy with none of the baggage of Toni Natalie.
Boy I wish I could sit in on the depositions. Every deepest darkest secret is fair game. THAT will be the book and movie.
No where for KAR to run and hide.
Raniere can run back and forth in his jail cell, about 8-10′ each way.
I’m sorry….but isn’t it hypocritical of these striped-sash coaches to sue for damages for the exact same thing they were teaching?
Also, it seems very few — if any — of these charges actually apply to Toni Natalie. But as someone else said — it’s the money train for her. I can only imagine the phone call between her and Edmondson about who would be actually named as the “Plaintiff, et al.” I am sure NataLIE threw a fit!!
They weren’t teaching the crimes that the defendants are being accused of.
All the defendants cannot be held responsible, for things that we all know did not involve them, Allison, Nicky, Rosa Laura have nothing to do with the actions that affected Toni Natalie, and as we all know, the DOS group was not part of the courses taught by the other coaches so DOS-related action could affect Mark Vicente and Toni.
If you’re referring to Vicente and Edmondson, if I have it right they actually had green sashes, two levels above coaches. Vicente was also on NXIVM’s board, though he did resign when the worst of what was going on started to come out, plus he seems like a fairly credulous cult follower (NXIVM wasn’t his first) who might have been put on the board in part as a figurehead because of his reputation in the outside world. And Edmondson was the victim of some of the worst of that, the branding.
The two of them are in the grey area between perpetrators and victims, but even if they do have claims against the key players in the scam, I think they themselves should at least be liable for returning the profits they made from recruiting people. Edmondson in particular is arguably among the worst of hypocrites and virtue signalers because she has written and promoted her book, promising only some token donation, rather than dedicating all the proceeds to victims and survivors – she’s actually effectively still profiting off her position in NXIVM, and trying to increase her take with that little gesture.
Being a hypocrite and/or a virtual signaler isn’t against the law.
What about Emiliano Salinas, Edgar Boone and Alejandro Betancourt..they are responsible too!!!
Responsible for which of the crimes?
It looks like they would have to be sued in Mexico – which I realize means, probably not.
All that work and effort just to get a piece of ass. Now he likely got himself a lengthy jail sentence, not to mention civil penalties.
And Raniere’s current and future cellmates will get a piece of Raniere’s ass.
Yes, all it would have taken is a few beers and/or vodka tonics. But Raniere didn’t just want to f*ck them, he wanted to f*ck with their heads, too.
Raniere won’t suffer much in the way of civil penalties, he’s broke and will probably never leave prison alive to earn any money to pay them back.
He’s not necessarily broke.
Supposedly he inherited $8 million from Cafritz, though what’s going on with that is not entirely clear; and there was said to be a lot of money in Jaske’s estate, as well. Plus he may also have a 1/3 interest in Bronfman’s island, which was reportedly purchased for $47 million.
Regardless, Raniere will probably die in prison. If it is proven he does own those assets, then he will get a few more years tacked onto his sentence for perjury, because he signed a sworn statement that he’s essentially broke. I think he claimed to own half of a house/condo, worth about $60,000 or so. Compared to the Bronfman money, that’s nothing.
If you ever want to know how to spot a psychopath early on:
1. Watch the eyes;
2. Introduce them to your dog.
If your dog still barks vehemently after the first several visits, run.
Ps: shelter rescues rule.
Fool Me, you are so right about the dogs. Mine reacted that way to a man I later learned was serial wife beater.
Right! I trust their judgment 100% of the time.
I wouldn’t recommend that, psychopaths can fool dogs, too. Watch the eyes for WHAT?
Scott, know how a dog has a sense of smell 20,000 times stronger than a human’s?
They can smell if a person is an asshole with that very same nose.
You can’t fool a pooch. They look at auras, too, and psychos can’t cover that up.
The eyes are the mirror to the soul. That’s where you first spot evil.
Look into KAR’s eyes in some of these pictures. Something doesn’t look right, in my humble opinion.
You’re joking, right? Depending on the breed, dogs have a sense of smell 1,000,000 times stronger than a human, but that doesn’t mean they can associate a smell with evil. Do you have scientific proof regarding auras even existing, or can you see auras, look into someone’s eyes and see that they are evil BEFORE you know they are evil, too? LOL
That turns out to be something of an old wives’ tale. Dogs are sensitive to a wider ranger of smells, and more trainable, but humans are actually more sensitive in limited ways:
In Some Ways, Your Sense of Smell Is Actually Better Than a Dog’s
“Human noses are especially attuned to picking up odors in bananas, urine and human blood”
“…the total number of odorants for which dogs have an established, lowest detectable threshold level is 15. Humans actually have a lower threshold for five of those.”
https://www.smithsonianmag.com/science-nature/you-actually-smell-better-dog-180963391/
One of the reasons that people fall for scams including MLMs and cults, is failure to perform due diligence, or fact-checking. The Forbes 2003 expose’ was the death knell for ESP/NXIVM’s recruiting of actual successful professionals, in large part because people at that level know to vet and scrutinize their investments of time and money, or at least have people who check on their behalf, so NXIVM was left with the lower-hanging fruit of those with less rigorous habits and training.
The point is can’t smell evil. Another reason people fall for MLM scams is that they are told to NOT to do research, because the internet is full of garbage. The ones who don’t follow that instruction generally don’t join, the ones who do and join get scammed. Again, you have proven you don’t have the least whiff of a clue regarding what you’re talking about. LOL
This was Toni’s game plan all along – get on the money train.
First of, why after the first trial…
Second why after Allison was clearly shown to be in the victim (and pointed as such by Edmondson and Vicente (Sara said she was the scapegoat)) include her in this stupid case…
Forced labor is the absolute BS…As for sex trafficking…
Human trafficking , it’s another story but Allison didn’t do as she was, once again, one of the victim of it!
“the Defendants achieved a number of personal benefits including but not limited to enriching themselve”
Tell that to the broke Allison…
“Each Defendant played a critical role in the conspiracy”
This include 2 of the plaintiff, especially 2 of the plaintiff actually …Both benefited financially of the accusation they made and this include against one of the person accused..
Who was the recruiters for Vancouver? and amongst the recruit, who did they had? It’s incredible the gut they have to participate such masquerade of justice!!!
Allison is one of their victim too! they committed to recruit both Allison and cline and now they are the one going against…it’s like if Raniere sued the student for the crime HE committed!!!
“Most of the earnings were received by the small group collectively known within the organization as the “Inner Circle.””
False…it was by the executive…Allison is broke, Vicente and Edmondson have a confortable money seat under their asses…
“6. Before forming ESP”
Why include Allison when making such absurd accusations? it was in the 90 and Allison was not in and was a child
“9. Defendants intended, knew, or deliberately disregarded the fact that EM exposed its subjects to a high risk of injury”
There is not such a proof (and i doubt their will) and this as nothing to do with Allison, she was one of the subjects of those experiments…
A victim, once again
“10. The longer someone was immersed in this system, the more likely it became that they would suffer moderate-to-severe psychological and emotional injuries”
And Allison got through a lot of those…so still makes her another victims Mr Glazer…
“11. Through the continual and systematic application of the Rational Inquiry methods, Defendants obtained the complete trust of their victims, rendering them psychologically and emotionally dependent upon the Defendants.”
This include Allison but nevermind…she was one of the victim, yet again
“12. Once Defendants had stripped members of their psychological defenses, they exploited these highly vulnerable people for advantage and gain.”
This is actually the description of Allison…Once she was stripped of her psychological defeneses, she was exploited for advantage and gain…
“13. Quitting was failure and would result in immense shame and humiliation. Further, it could expose the victim to malicious litigation”
Which is still the case now for Allison but not due to Raniere’s work…but to a borderline lawyer going after one of the victim
“14. The Enterprise and Defendants were also responsible for conducting experiments on NXIVM members ”
Not the defendants as a group…just Raniere ,Nancy and the bronfman’s money… Allison was, once again , one of the victim of those experiments
19,20,21 , trial happened about this, why the wait? and better yet, why after proved (in court) that Allison(for example) had no power in it and was a victim too of the scheme. Why include her in the list?
Also it’s not sex trafficking nor human trafficking…it’s at best a fraud…something that Allison has already been “judged” (through the plea deal) while it ignore the facts of her own coercion and the psychological side (the suffering and abuse she had as all the other victims)
22,23,24, trial done and she was victim of it so Allison has nothing to do with it
25, Agreed but it’s a fraud, nothing else
26, False…In court, they showed that in the case of Allison, She asked 1 service (under the demand of Raniere) while she (Allison) provided several services…
India took advantage of the situation way more and isn’t in the defendants (but i suspect she is in the “plaintiffs”)
It’s awfull to see how one ignore the victim statuts of some just to accuse them to obtain a financial gain…
27 Allison was a victim of those abuse…
34. They accepted to do this…there is no point to even try…if it wasn’t in trial it’s for several reason Mr Glazer:
They accepted, each of the plaintiff hold each others…so are you going to sue the victim you are defending too?
Most of those accusation are not related to Allison (except the lie) and in the end, most of those accusations, Allison was a victim of those!!
The simple fact we see Edmondson and Vicente in this ridiculous complaint show the credibility of this accusation!!!
48. yes but what is the point? to obtain more money ? the victim included in the case will obtain (in due time) restitution (Allison and most already sign the acceptance)
Allison is completly broke now so why include her?
50. Disproved as only Raniere benefitted of those advantages…Example, even the “funeral” speech Nicole had to do for “Allison”, she admitted it was a demand of Raniere!!
NOT ALLISON
51,52,53 fair only if against the REAL LEADERS …this doesn’t include Allison or Cline but include 2 of the plaintiffs…
BTW, little reminder, Sex trafficking was supported only for Raniere’s position, nobody else did…and to be honest, It’s far to be Sex trafficking (more like a sexual abuse)
But it’s a matter of money here, not justice…
The matter is to obtain “compensation”.
If it was me, i’d say too little too late as all this “new case” is doing is repeating what was judged (and not yet sentenced) to obtain a compensation already authorized on the victims…
If this complaint pass as such, it will be the biggest display of lack of justice as it would be mostly a double jeopardy.
Further more, this would abuse one of the victim beyond the limit of humanity while this complaint was filled by atleast 2 real culprit!!!
I don’t diminish the pain of the real plaintiff but they accuse someone who should be on the same side of the bench…just because she was forced to do a plea deal!
The trial showed clearly that Allison had nothing to say and that she was obviously under coercion and not in a proper mental/psychological state…
Some of the accusation are actually some of the reason why she was abusively used against her will but let ignore the fact and just go in for the money right?
If “victims” support that Allison should be punished further than she already is, does that make them better than some of the culprit?
I’m not saying Raniere, nobody is worst than him but i’m referring to people like Nancy or her daughter?
90% of the accusation are what Allison was a victim of.
If it was a fair accusation, Allison would be in the plaintiff, not the defendants
again very good points Anonymous!
Anonymous spewed out several irrelevant points.
I told you on August 7, 2019 that there would be a civil suit against the sadistic Allison Pimp Mack.
Allison Mack Will Be Sued for Being a Pimp for Nxivm
August 7, 2019
By Shadow State
Neil Glazer represents scores of Nxivm victims in an expected lawsuit against Nxivm and its leaders.
https://frankreport.com/2019/08/07/allison-mack-will-be-sued-for-being-a-pimp-for-nxivm/
Actually, all of the points sucked.
Anonymous:
The first trial was a criminal trial.
The second trial is a civil trial for the damages that criminals Allison Pimp Mack inflicted upon women.
You must be the anti-Mr. Shadow.
As others have already pointed out, Mack has already been indicted and plead guilty – as one of only a handful of designated principals in NXIVM’s scams and crimes, based on the proceedings of a grand jury that reviewed evidence and took witness testimony, and which could have declined to include Mack if they thought she wasn’t really as culpable as the others, or even broadened the indictment if they thought she was being unfairly singled out when others not included were just as guilty.
Even you admit she’s at least 10% guilty, and she may well get assessed less than 10% of the total judgment – based on the verdict of a jury who will get to go over testimony and evidence in much more detail than any of the armchair observers here ever will – so isn’t that actually rather fair even by your own standards?
Finally, I’m going to do a Shadow and just quote what I wrote in response to your screed responding to the earlier post on this topic:
“The accusation[s in the lawsut complaint are] being made by people highly trained and experienced in American law, who have gone over the case and evidence in more detail than anyone here, plus who have interviewed high-level insiders like Vicente and Edmonds about what they know – which almost certainly includes things never revealed publicly, including in court. The chances very high that it’s actually you who is completely mistaken.”
There is no such thing as being 10% guilty. Each charge is handled individually and the person is found to be either guilty or not guilty, or more accurately, finding for the plaintiff or defendant.
Also, keep in mind that, no matter how brilliant the lawyers are, almost 100% of the time 50% of them lose. The facts and hourly rate have a lot more to do with winning and losing than whether they are “highly trained and experienced in American law.”
“Frenchie” doesn’t seem to understand US law, and so I was just trying to frame the layman’s argument in their terms.
Also, in a civil case, judgments can apportion differing percentages of liability to different parties.
Why you call someone who goes by “Anonymous” is beyond me. Agree on the civil liabiliy apportioning.
Just because Allison was initially victimized doesn’t mean she should not be held accountable for the pain she directly caused individuals. The federal case was for Rico while this is a civil case for damages to individual victims. I’m no lawyer but I am not sure that’s double jeopardy.
The term “double jeopardy” refers to a situation where someone is being charged a second time for the same criminal offense – and usually comes into play after the first charge was dismissed. The civil lawsuit is totally separate and distinct from the criminal charge – and requires a lower standard of proof than the criminal charge.
I also found it interesting that Emiliano was not named . The media in Mexico discussed him much more than Laura junco.
I would say this connects with their parents power . Laura junco dad controls the media. Salinas has apparently a bit less control here. However I think emolios personal relationships were stronger than Laura’s. So nobody came to ir him. I am disgusted by Laura recruiting minors. I hope she gets jail time or such a bad reputation she is never free
I say it connects with the lack of evidence regarding crimes committed.
Many of these plaintiffs will also file Victim Impact Statements.
Bet On It!
I’ve heard that a reason that sentencing has been delayed so many times is that Shadowstate’s letter/victim impact statement against Alison Mack was more then 500 pages long!
You hear wrong.
Here is the full complaint 189 pages worth.
Read it!
https://frankreport.com/wp-content/uploads/2020/01/1-Complaint-00207560xAADF6.pdf
So why did you write 500plus pages letter (at least on FR articles) only against Alison ??(be honest) are we really meant to believe you have never met her?? Why do you not target the other defendents?? (Again be honest)
Why are you defending a woman who submitted women to extreme physical torture with hot irons?
For Shadow to be honest:
He would have to admit that a) prior to arriving on the Frank Report, he probably spent hundreds of hours cyberstalking Allison Mack and b) since Mack and Shadow appeared (almost simultaneously) on the Frank Report, Shadow has spent most of his life(?) becoming the world’s foremost Mackologist.
Exhibit A of a man barely tethered to reality:
Composing a post which repeats the words “Allison Mack is a PIMP” multiple times, in a Bart Simpson at the blackboard moment.
As a as pre-emptive strike against Shadow accusing me of being a defender of Allison Mack:
a) would never have heard of her if it weren’t for Frank Report; b) matters not to me if she spends 20 years in prison or makes a comeback on the Hallmark Network because c) the only woman who really matters to me is having an afternoon nap at this moment.
Regards to Ms. Shadowstate, she must be a very patient lass. Still awaiting a follow up on the great NXIVM California license plate caper.
“So why did you write 500plus pages letter” Truthseeker (Lie Spewer)
Lie Spewer:
You need Nasty Nurse Nancy Salzman to give you a Coffee Enema.
Hot, High and Heavy!
Asking shadow to be honest about his obsession with allison mack, is like asking Keith for advice on how to take care of a woman or a son or a business or how to be a criminal and not leave evidence scattered everywhere
Regards to Ms. Shadowstate
Sorry witches, there is no Ms Shadowstate. Shadowboy has been married to Allie Mack in his mind for close to twenty years. She is his mental blow up doll
What about Kathy Russell…she is truly a victim. They paid her nothing… she didn’t gain anything!!
Russell is no victim, she’s a ballet dancer.
You read wrong. It was YOUR complaint to the judge that was referenced. Have Frank post it.