Raniere Attorneys Memo to Judge Seeks 15 Years in Prison Instead of Life: Raniere ‘Maintains His Innocence; Stands by ESP, NXIVM and DOS’

Keith Alan Raniere .

Lawyers for Keith Alan Raniere have submitted to Judge Nicholas G. Garaufis an 86 page sentencing memorandum on behalf of their client.

They seek to persuade the judge to sentence Raniere to the minimum sentence he is allowed by federal law to impose – 15 years.  The 15 year minimum is required by Raniere’s conviction on sex trafficking charges.

The prosecution is asking the judge to sentence Raniere to life in prison.

Should Raniere, 60, get 15 years [a sentence that most observers see as unlikely] he would be qualified to be released in a little more than 10 years. He has already logged in almost 30 months of time served and could shave off a couple more years with good behavior.

Raniere’s lawyers argue that he is innocent.

Let us quote from the memorandum written by Raniere’s attorneys Marc Agnifilo and Paul DerOhannesian II/

My comments are in [brackets and bold].

Marc Agnifilo [l] and Paul DerOhanessian [r]
By Marc Agnifilo and Paul DerOhannesian II


Keith Raniere continues to assert his complete innocence to these charges. He does, of course, recognize that a jury convicted him of very serious crimes, ironically crimes that he and others in NXIVM have been seeking to prevent others from committing for many years. The jury’s verdict, however, did not reflect the quality of the evidence, but rather was a product of a media campaign involving witnesses who were motivated to testify falsely, [Daniella and Nicole who, the defense claims lied in court about their plans to participate in a civil lawsuit against Raniere and others] a heavy-handed prosecution that threatened potential defense witnesses and, most respectfully, an unfair trial where, we believe, the Court was not provided with full, candid information from the prosecution.

Therefore, Mr. Raniere objects to this Court moving this matter on to sentencing because of these significant violations of his due process rights, as well as perjury by critical witnesses and threatening actions taken by the Government toward potential defense witnesses, [Raniere’s attorneys allege the prosecution threatened and intimidated potential defense witnesses, threatening to charge them, particularly Mexican Nxivm members who offered to come to the US and testify for Raniere] events that individually and in combination defeated his right to a fair trial.

For the reasons set forth on the record before and during the trial, including in the several mistrial motions and in the Rule 33 motion [seeking a new trial] filed since the verdict, [the Court denied the Rule 33 motion] Mr. Raniere respectfully maintains that his trial was fundamentally unfair and in violation of the rights assured to him and to all defendants by the U.S. Constitution, and that he should be granted a new trial now due to the accumulation of prejudicial errors and due process violations, including those coming to light since the verdict, which in totality mandate the setting aside of the verdict and the awarding of a new trial, at a minimum.

Mr. Raniere not only maintains his innocence, he stands by ESP, NXIVM, DOS and all of the projects, curriculum and teachings to which he and many others have devoted their lives.

Keith Alan Raniere is proud of Nxivm and DOS.

He remains proud to have played a role in helping people achieve greater happiness and better lives. He remains proud to have been permitted to play a part in helping citizens and residents of Mexico strive to bring peace to a country beset by violent gangs, kidnappings and murders, a struggle that continues to the present and that will continue into the future. He also remains proud that he and others helped people with Tourette’s syndrome to be able to minimize or eliminate the symptoms of this difficult condition.

Simply put, he remains proud of his life’s work. He also remains determined to fight this case, which he views as a terrible injustice and, respectfully, an affront to what should be one of the great systems of Justice to ever exist.

Mr. Raniere recognizes that on the very day that judgment will be caste upon him, he may be better-served to be contrite, and that his best hope for a sentence that permits him to one day walk the earth as a free man is for him to say he is sorry for all that he has done. The truth is that he is mindful of all the people that have been hurt by this process, and he experiences deep pain at the plight of the many good, innocent people hurt by the events of the last 30 months. He maintains that he did not harm anyone intentionally, yet he has seen how a once wonderful, loving, close-knit community of people genuinely motivated to bring about positive change in the world has been destroyed by a handful of people who have lied to newspapers, media outlets, prosecutors and juries, and have caused others to lie as well.

To the extent that Mr. Raniere brought about a community of people that was vulnerable to such destruction, he is deeply sorry that he participated in this. This is not what he intended, but he is mindful of the people he has
let down. He is mindful of the people whose lives have been upended by the events depicted at the trial.

However, he is not sorry for the way in which he lived his life. He is not sorry for his conduct or his choices. Rather, he maintains that he has lived mindfully and carefully and that he has made deliberate choices, often with the input of others, and that even on the day of judgment, he stands by the life he has chosen to live….

Keith Raniere asks the judge not to give any prison time to his codefendants such as Kathy Russell.

In regard to his five co-defendants [Clare Webb Bronfman, Nancy Salzman, Lauren Salzman, Allison Mack and Kathy Russell], Mr. Raniere’s position is that each of them believed in him, trusted him and followed him and that they are no more blameworthy than are the 18,000 others who took NXIVM courses over 22 years….

Mr. Raniere is not looking to be a martyr. In fact, he wants to be released from jail as soon as possible and believes he deserves to be released.

However, he recognizes that he was the leader of a community, and that the members of his community looked up to him and trusted in his motives and his good-will.

If he acted recklessly while attempting to push people to be better versions of themselves (a notion that always
concerned him but which he does not believe), no one else is as responsible as him. He understands that the Court may not want to hear his opinions on matters that are firmly within the sole discretion of the Court, but he also wants it said publicly that his co-defendants should not go to jail. If anyone is to be punished for his or her actions, that person should be Mr. Raniere alone.

The trial evidence shows that the NXIVM community was based primarily on trust and a belief that everything that was done, especially those things that were difficult, was for a higher purpose.

Raniere trusted that others in the community would see his motives as genuine and pure because over the course of 22 years, he endeavored to earn that trust. Others in the community trusted that when Raniere or another person asked them to perform challenging tasks, that this was being done to help them and not for some darker reason.

Keith Raniere’s attorneys assert the real villain is Mark Vicente who led the outing of Raniere’s branding and blackmail scheme known as DOS.

The evidence shows that a small group of people, [Mark Vicente, Bonnie Piesse, Sarah Edmondson, Anthony Ames] motivated by their own personal circumstances, successfully poisoned the trust that hundreds if not thousands of people had developed over two decades. They did this by lying to others and claiming they knew things they did not in fact know. They did this by enrolling bloggers [Frank Report] who threatened to publicize personal facts about people unless they joined the anti-NXIVM side. [I do not recall doing this.] They did this by lying to the New York Times, specifically that a woman [Sarah Edmondson] was held down and branded against her will (when in fact she absolutely knew about the branding weeks ahead of time and that she actively told others she wanted to be branded) and causing a media firestorm based on false information.

Catherine Oxenberg set out to rescue India Oxenberg from DOS. Keith Raniere’s attorneys claim India was living a peaceful and happy life as a DOS slave. 

They did this by telling the mother [Catherine Oxenberg] of a young woman [India Oxenberg] that her daughter was in grave danger when the daughter was living her life in peaceful anonymity. They waged a campaign of hate and falsehood with the goal of burning down everything in its path.

They joined forces with a federal prosecutor [Moira Penza] who, rather than seeking out the truth, quickly took the side of the Anti-NXIVM group. It must be remembered that this “case” was initially referred to the U.S. Attorney for the Northern District of New York (the District in which all of the relevant conduct took place) and a highly experienced AUSA in that office as well as the FBI in that area concluded that no crimes had occurred. However, in Brooklyn, a District in which none of the challenged conduct took place, the anti-NXIVM group
found an ally.

Potential defense witnesses were threatened with prosecution if they dared to testify in a manner inconsistent with the Government’s theory. Ultimately, this combination led to the wholesale destruction of something that each of these people once loved: the very community they each helped nurture and create.

This complex situation of personal motives, individual regrets and life-choices has no place in a federal courtroom. Yet, the Government seeks a life sentence for Keith Raniere in a case that has no guns, no knives and no force. No one was shot, stabbed, punched, kicked, slapped or even yelled at.

Despite the sex offenses, there is no evidence that any woman ever told Keith Raniere that she did not want to kiss him, touch him, hold his hand or have sex with him. On the contrary, the women who testified stated that they expressed to Raniere only that their intimate contact was altogether welcome and consensual. For instance, neither Sylvie nor Nicole ever stated or even suggested to Raniere that they did not want to be intimate with him.

Every single person making the decision to get branded or not get branded, to join DOS or not to join DOS, to write book reports [Daniella] or not, to participate in Pam Cafritz’s memorial or not [Nicole], or to make any one of a thousand other decisions was a free-thinking adult. Not only were they adults, they were adults of considerable means, success and options. Many of them had already achieved some measure of success in their professional lives yet they viewed their lives as having insufficient meaning and content.

Many wanted to have closer relationships with their parents, children, friends and colleagues. Many wanted clearer conceptions of what their purpose might be, who they really were and how they should devote their time and energies to this one life they have been given. They were successful people who specifically wanted to be pushed, to be challenged, to be inspired to do things differently than they had done.

They joined NXIVM or DOS because they wanted to overcome fears and limitations and because they firmly believed that this was the best thing for them. The Government has no place in the realm of personal choices made by adults concerning these sorts of essential, private matters over how each person decides to live his or her life. Similarly, the Government should not transform regret over one’s choices into federal crimes, much less seek a life sentence for them.

Keith Raniere will appear in Court at his sentencing hearing not as a man seeking forgiveness from the Court or the Justice System, but as one who will to his last breath defend the community and the ideals he created against the destructive forces that have for the moment burned them to the ground. He will also stand against unfairness in the criminal justice process for all people. Finally, he intends to fight this case with all of his might, confident that he will one day be vindicated.

[Frank Report will be publishing additional arguments by Raniere’s attorneys where the delve into the specifics of why Raniere is innocent of various charges he was convicted of. Stay tuned.]


About the author

Frank Parlato


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  • Everyone participated of their own free will… yes… when you hold blackmail over someone they participate of their own free will because they don’t want the blackmail released. So, yes, they were adults participating of their own free will.

    Blackmail and extortion are still illegal though and it looks like Keith may participate of his own free will in a long term prison experience.

  • This level of narcissism isn’t surprising but it still does make my jaw drop. Wow. The judge is going to throw this clown away forever, and cut him to pieces while doing it.

  • In my opinion, here is a fundamental problem:

    Vanguard promoted himself as a scientist. He used doctors to experiment on people, and at least one of them has since been defrocked.

    SCIENCE gets tested. Over and over and over again. There is strict protocol and peer engagement to make sure it is, well, SCIENCE.

    Vanguard didn’t follow scientific principles and guidelines. His “science ” is what he concocted–and he viciously attacked anyone who questioned it.

    He can stand by any position he wants. But without expert testimony (was there?), research scientists, psychiatrists and more, he basically stands in the house he built, without knowing if the foundation was properly constructed.

    • Raniere has no peers, so who would you suggest review his brilliant work? LOL

      By the way, a pro-Raniere person would ask the same question, without the LOL at the end, thus illustrated the Raniere word salad thinking. LOL

    • Agreed. It was Pseudo-science. It appears as science but it is a collection of opinions, untested, unverified.

  • Right or wrong, he is willing to stand up for his principles and the community he created. He can live his life knowing he lived in accordance with his principles, even if the rest of his life is in prison..

    Regarding sentencing; he is not charged with murder or rape but he is facing an angry court and angry public opinion which may exert further bias and pressure against him… A 15-year sentence is already a very long time. The danger of an even harsher sentence is that he may be turned into a martyr and a “political prisoner” and I don’t think he deserves that honor.

    • Raniere is facing seven guilty felony convictions regardless of the level of anger. LOL

      It was over the day the trial jury openly laughed at him. LOL

      If you haven’t noticed, Raniere isn’t getting very much press coverage, even with all of the MDC dancers, I doubt that will change after sentencing except that it will be even less. LOL

    • Meh. All false leaders are turned into martyrs by those followers who still drink the kool-aid. This is irrelevant. It’s only when people outside of the group start to sympathize with the plight of the leader and the group does the term martyr gain additional power, because now you have a larger, more unbiased group that agrees in principle with the smaller one. I don’t see that happening at all in the current public opinion that is on display in social media such as the Twitter hashtag #TheVowHBO. In fact, I see the opposite where people reflect a desire to throw the book at its leader and anyone else who still believes in him. The documentary is a massive bane to any future staying power of NXIVM.

  • Hardly any cross-examination questions and no defense during the trial, and NOW they explain why Raniere is innocent? LOL

    • I would be interested in reading Keith’s attorneys experience of defending Keith and where opportunities may have existed during the trial to prove his innocence “at the expense of others.”

      Keith addressed this situation directly in the Ethicist curriculum, foreshadowing his own demise, and I think it would be interesting to make public these decision points so that the public may have a fuller understanding of the process of justice and how it played out.

      Regardless of your opinion on Keith, I think these data points would help us all understand what our system of justice provides for and does not provide for. Frank, if you have any insight into this, I would be interested.

      • I had the opportunity to interview Mark Agnifilo previous to the trial of KAR. The transcript of the interview was never released because it would have violated an unspoken agreement made with Agnifilo and also I felt it would bias the trial and cause a potential mistrial.

        Long story short: Mark opined Raniere should have protected himself better and never allowed the branding or extreme collateral. DOS was a mistake. Mark told me indirectly he did not expect to win. I got the impression he was in negotiations with the prosecution and I expected an agreement which, as we know, never materialized.

        IMO, Mark liked Raniere but failed to fight hard enough for him. He seemed to enjoy talking to the press more than taking a bullet for his client.

    • Agreed, his attorney, Mark Agnifilo, is better in front of the cameras than in the courtroom! Agnifilo is a great press hound but I saw nothing that showed he fought for his client tooth and nail during the actual trial.

    • As much as Amway and other MLM scam distributors join “on their own free will” after being told various lies. NXIVM throws in the added “benefit” of blackmail. LOL

  • This was a smart move. He knows the judge will not be lenient on him. The judge won’t save him. So he gains nothing by throwing others under the bus.

    He can win his followers, however, if he stands up and bravely says he will take all the blame.

    Sad he did not do this when Laura Salzman was on the ground with machine guns pointed at her.

  • —However, he is not sorry for the way in which he lived his life. He is not sorry for his conduct or his choices.

    Poor, pathetic little man. He still doesn’t see the problem.

    • “Poor, pathetic little man. He still doesn’t see the problem.”

      How is it possible that Keith Alan Raniere does not see the problem when he is one of the top three problem solvers in the world? It becomes clear that Keith Alan Raniere can only solve straightforward problems that he can recognize. This makes Keith Alan Raniere only a problem solver for problems that are obvious and easy to solve and that probably even a 7-year-old can solve. How many 7-year-olds are there in the world? Keith Alan Raniere falls quite far behind in the ranking of problem solvers.

  • So what’s the ratio on that lovely piece of propaganda to prop up the putrid prince – straight dictation vs judicious lawyerly editing? I’m thinking that screed is 98% pure unadulterated (oops – in his case it would be adulterated because adultery is a key facet of his noble, ethical lifestyle) Raniere BS. That’s a nice chunk of change his lawyers made from a simple task of taking dictation – probably pawned that off on the lowliest legal secretary in the firm and gave a bonus for botox to counter all the eye-rolling required to get through typing that florid fantasy.

    Narcissists are deathly allergic to apologizing or admitting fallibility. And they’ll only admit responsibility if it’s something that will make them look heroic. I’m just waiting for sentence to finally be passed. Lock him up, melt the key into slag, and make sure he can’t ever approach a young female again. As for the full grown adult whackeroos who continue to follow the self-proclaimed guru, I hope they’ve got some good psych help lined up for when they finally smack face first into the brick wall of their own self delusion. Hope Judge G gets a good laugh out of it – I think he should be getting bonus pay for having to continue to deal with this.

    • Narcissists are reluctant to admit to shortcomings and Raniere resists admitting wrong doing. This is troubling but also very complex. His group did help some people achieve the changes they wanted and he still has loyal followers because of this. This is not a simple case of good vs. evil. Raniere, despite his narcissism, dishonesty and abuse, did some good. Unfortunately, Raniere is not able to come clean with himself and admit to wrongdoing.

      • –Raniere, despite his narcissism, dishonesty and abuse, did some good. Unfortunately, Raniere is not able to come clean with himself and admit to wrongdoing.

        I have said this before on this very site in the comments, and will emphasize it again: the fact that some good is done while being tainted by ulterior motives is irrelevant to justifying it because the good is simply serving the latter. The good would not be done otherwise. Intentionality is rooted in sincerity, and once the latter is questionable, the principle of the former encapsulated in its meaning is decimated. For example, let’s say you have an intent to steal something from someone, and in the act of doing so, you somehow save that person from being killed. You shouldn’t get any “credit” for saving that person because there was no sincere motivation to do so. It was merely an accidental situation that happened to occur. Similarly, if you give advice to someone because your future desire is to simply have sex with them, it is irrelevant that your advice did some good, because you’re only giving such advice for some other ultimate aim. You wouldn’t have given such advice if it didn’t forward you to that end, and especially so, if it stunted its resolution. All ends are justified by means, but in the previous examples given, the means have been sullied by impure intentions and acts.

  • I’m sure the Judge will take this drivel Into consideration when he sentences Keith to life in prison.
    Agnifilio is getting paid to have his office type this trash that Keith has obviously written
    It’s an easy payday for the attorneys and bye bye for the smartest man on earth!

  • “In regard to his five co-defendants [Clare Webb Bronfman, Nancy Salzman, Lauren Salzman, Allison Mack and Kathy Russell], Mr. Raniere’s position is that each of them believed in him, trusted him and followed him and that they are no more blameworthy than are the 18,000 others who took NXIVM courses over 22 years….”

    What a load of crap.
    The Jesus of Saratoga is setting himself up as a Martyr as all aspiring Messiahs do!
    Mark my words if Jesus of Saratoga’s co-defendants go free, these clowns will be back to their old tricks!
    Right, Nicki Clyne?
    I made a warning in a recent story about Allison Mack taking Gender Studies classes at a local Southern California community college that Mack was really engaged in recruiting young women for NXIVM.

    August 21, 2020 at 11:19 am
    Don’t you all see what Allison Mack is doing here?
    It should be as obvious as the noses on your faces!
    She is “‘Super Participatory”
    She DMs fellow classmates!
    It is a class that is designed to appeal to women.

    Not one guy in a thousand would be caught dead taking a “gender studies” course.
    Wake up and smell the coffee!

    Allison Mack is recruiting young women to join NXIVM!
    Just like when she was recruiting coeds through her A Capella singing group!
    Just like when she was working on that NXIVM group for college coeds TEN C.
    The Emperor has no clothes.

    She did not go to this class to learn anything.
    She went to this class to ensnare young women in NXIVM.”

    • Wow, great point. It could be very well to recruit women. That is scary 🙁

      Also a good point. Keith is setting him up as a martyr. Perfect for his followers

      • It’s not to recruit women, that is only a construct of Shadow’s fantasy. You realize that they are monitoring everything that Allison does, right? She needs permission to take these classes and, of course, they are overlooking her behaviour.

        • How do you know she is now recruiting women? We don’t know to what extent they are monitoring her. They could monitor the websites she visits. But would they even know that a school website has also a chat they need to monitor?

          Why is a convicted sex trafficker of women able to contact young women?

          We don’t know for a fact if they are monitoring her conversations on a school platform. We don’t know if she is recruiting other women.

          • Yes, I know for a fact, that they are monitoring every Chat and everything she is doing! If she would try to recruit people, this would be reported to her probation officer immediately. The administration at her college is aware of the situation.

      • Mex
        This is dangerous for his followers and dangerous for society. We don’t really need a “FREE KEITH” movement. A stiff sentence (20 years or more) may guarantee more attention and a possible backlash. There are more worthy causes than one to free KAR.

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.” He also appeared in "Branded and Brainwashed: Inside NXIVM, and was 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 premieres on May 22, 2022.

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Contact Frank with tips or for help.
Phone / Text: (305) 783-7083
Email: frankparlato@gmail.com