Sentencing Memorandum: Allison Mack’s Attorneys Ask for Probation –She Is ‘Free of the Twisting Influence of Keith Raniere’

Allison Mack

Allison Mack’s attorneys have filed a sentencing memorandum with the US District Court for the Eastern District of New York asking Judge Nicholas G. Garaufis to give the former actress probation instead of incarceration.

Lawyers William F. McGovern and Sean S. Buckley argue in the memorandum that the former actress deserves probation because she has “turned her life around,” and is “free of the twisting influence of Keith Raniere.”

Mack is scheduled to be sentenced on June 30 at 11 am.

The government earlier this week submitted a sentencing memorandum which recommended a downward departure from her federal sentencing guidelines of 14.5-17 years based on her cooperation with the government.

Mack accepted a plea deal on two counts – racketeering and racketeering conspiracy in 2019. The carry maximum penalties of 20 years each.

Mack’s sentencing memorandum was filed on June 25, 2021, shortly before the midnight deadline.

Mack has been subject to home detention at her parents’ home in Los Alamitos, California, since shortly after her arrest in April 2018, more than three years ago.

Allison Mack has been subject to home detention for three years.

Her attorneys wrote, “Because of the intervention by the victims of Nxivm and DOS, law enforcement, and this Court, in the last three years Allison Mack has turned her life around and earnestly dedicated herself to rehabilitation, renunciation of Keith Raniere and those who supported him, and making amends.”

Family First for Mack Ahead of ‘Cult’

Mack’s attorneys reveal her family have been supportive and her mother, brother and sister are quoted in the memorandum.

The memorandum reads, “Where once Raniere commanded Ms. Mack’s complete devotion and fealty to the exclusion of all others, Ms. Mack has now reintegrated into the life of her family, seeking out and offering support in a way that would have been unthinkable three years ago.”

Jonathan and Mindy Mack, Allison’s parents.

While her attorneys argue that Mack takes full responsibility for her actions, they reference the fact that Raniere held collateral over her – the most damning of which involved her family – coercing her to take some of the actions she undertook including the victimizing of Nicole and Jaye, who testified in the Raniere trial and were her ‘slaves’ in DOS, the secret sorority headed by Raniere..

Keith Raniere with Allison Mack.

According to FBI Special Agent Lever, on August 10, 2015, Mack sent an email to Raniere pledging her “full and complete life” to Raniere and identified “collateral” to “cement” this vow which included a letter regarding Mack’s mother and father that would “destroy their character” and a letter addressed to social services alleging abuse to Mack ‘s nephews.

In the sentencing memorandum Mack’s attorneys call NXIVM a cult and that she was the victim of “brainwashing,” supporting “Raniere’s sick fantasies and, to her unending regret, became a ‘master’ as well as Raniere’s ‘slave.’ The fact that Raniere was able to turn Ms. Mack into an agent of trauma is appalling, but consistent with the structure and function of cults like Nxivm.”

Marriage to Clyne Denounced

The memorandum states repeatedly that Mack has denounced Raniere and in one section they explain the reason she is divorcing fellow DOS member Nicki Clyne.

“In  December  2020, as part of her continuing  efforts to right her wrongs, Ms. Mack filed for divorce from longtime Nxivm and DOS member Nicki Clyne.

Allison Mack and Nicki Clyne, both members of DOS. They might be married.
Allison Mack and Nicki Clyne were wed in Feb. 2017

Citing Mack’s Pre-Sentencing Investigation Report [PSR] which states she married Clyne “at Raniere’s request in order to obtain a favorable immigration status for Ms. Clyne. [PSR ,r 210.]” Mack’s attorneys write, “The marriage represents another example of the now-incomprehensible lack of judgment Ms. Mack displayed during her time in DOS, and another action about which she is deeply remorseful. In addition to rectifying the fraud, Ms. Mack felt strongly about severing ties with Ms. Clyne because of Ms. Clyne’s continued outspoken support for Mr. Raniere, who Ms. Mack whole-heartedly rejects.”

Frank Report reached out to Nicki Clyne and Keith Raniere requesting comment on the allegations and are awaiting a response.

Active During Detention

In the Mack memorandum, we learn that Mack has been undergoing “difficult and invasive psychotherapy to unpack the trauma she suffered, and inflicted.”

We also learn that she has been working as a caterer, and that during the last three years on home detention, she got her associates degree from a local community college, where she got a 4.0 grade point average.

Her lawyers are ask for probation in part because she wants to continue college. She is now enrolled in a bachelors’ degree program at the University of California at Berkeley and if she gets probation is scheduled to graduate in Spring 2022 with a double major in Rhetoric and Psychology, they say.

Not in the Cult Anymore

Her lawyers also argue that Mack has undergone radical change. “Now that the blinders of the Nxivm cult have been removed, Ms. Mack recognizes that her actions were abhorrent. The Allison Mack of today barely recognizes who she was during those dark times.”

Suggesting that Mack endured “psychological trauma” of which she has emerged, they write, “Allison Mack of today does not recognize the Allison Mack of three years ago.”

Why Mack Took Her Plea Deal Revealed

MK10 Art sketch of Allison Mack and Keith Raniere on trial, Mack avoided trial by taking a plea deal.

Between the time she was arrested in April 2018 and the time she took a plea deal in April 2019, Mack stood strong in maintaining hers and Raniere’s innocence . The memorandum gives us evidence about what changed Mack’s mind – the discovery of the nude photos of Cami, a 15 year old Mexican girl, whose entire family were deeply involved in NXIVM.

“On March 13, 2019, the Government superseded its Indictment for a second time, charging Mr. Raniere with Sexual Exploitation of a Child and Possession of Child Pornography. These new charges, coupled with other information Ms. Mack found out through the discovery in this case, cemented Ms. Mack’ s emerging recognition of Raniere’s evil intentions and the extent to which she had been deceived and complicit in a criminal enterprise.”

Nxivm Camila
Mk10ART’s sketch of Camila. She joined NXIVM with her family when she was 13. She became one of the DOS first line masters along with Allison Mack.

In explaining why it took Mack almost a year to accept responsibility for her crimes and accept a plea deal, they write that she was “a shell of a human being…  It naturally took time for Ms. Mack’s psyche to adapt and come around to the truth that, for more than a decade, she had been following a false prophet who had abused dozens of women and, indeed, had abused her.”

Her Cooperation

The memorandum also discusses her efforts, once she realized Raniere’s evil, at cooperation with the government through “repeated, lengthy proffer sessions.”

“Ms. Mack told the Government everything she knew about Raniere, his co-conspirators, and the organization  he had created,” her lawyers wrote.

List of Arguments

Among the arguments her attorneys marshal for probation are

  1. Mack’s acceptance of responsibility,
  2. Her cooperation with the government
  3. Her commitment to family, education, and therapy
  4.  No criminal history
  5. Publicly denounced Raniere “in the strongest possible terms.”
  6. Remorse and rehabilitation
  7. Her criminal conduct is unique because she was “in the grips of a cult of which she was also a partial victim”
  8. She has been punished already by:
    1. Being subject to home arrest for three years with severe restrictions on communication with the outside world
    2. The loss of a once-promising acting career
    3. A felony conviction
    4. She and her family are hunted by paparazzi seeking headlines and clickbait
    5. Her reputation will be permanently tarnished by her association with Nxivm and Raniere.
    6. Physical and emotional scars from 12 years serving Raniere
  9.  She has provided deterrence since other potential criminals will not want to follow in Mack’s footsteps—and endure incredible suffering, trauma, and humiliation she has sustained

Hopes for the Future

Her lawyers also argue that there is significant hope if she is allowed to be placed on probation.

“The world can be a better place for having her in it, they write, adding “she has come to the hard-won realization that her decade-plus in Nxivm was a grievous mistake that will haunt her for the rest of her life. However, Ms. Mack has not succumbed to self-pity as a result of this realization, but rather has taken numerous, concerted, and consistent steps towards bettering herself, repairing the relationships she destroyed, and making amends to those who she hurt.”

The memorandum concludes with the statement that:

“Allison Mack recognizes that she has committed grievous wrongs and that she has earned punishment. She cannot undo what has been done, and she will have to live with the regret for the rest of her life. But Ms. Mack still holds the potential to be valuable to society—as a family member, as a friend, as a helper to those in need and as a cautionary tale. Since her arrest more than three years ago, Ms. Mack has completely turned her life around and recommitted to the values she lost during her time in Nxivm. We respectfully request that the Court permit Ms. Mack to continue on this new path by imposing a sentence that does not require incarceration that would separate Ms. Mack from the family, friends, and educational opportunities that have put her on the path to once again become a valuable member of society.”

Letters of Support and Mack’s Statement

The memorandum also includes 15 letters of support from family, friends and teachers and ends with a letter from Mack herself, which we will reprint in full in a subsequent post, but which states in part:

“It is now of paramount importance to me to say, from the bottom of my heart, I am so sorry. I threw myself into the teachings of Keith Rainire with everything I had. I believed, whole-heartedly, that his mentorship was leading me to a better, more enlightened version of myself. I devoted my loyalty, my resources, and, ultimately, my life to him. This was the biggest mistake and greatest regret of my life.”




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Frank Parlato

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Jane Smith
Jane Smith
2 years ago

If she continued acting rather than being a student, she might make enough money to pay huge amounts of damages to those whom she hurt for whom words are not much comfort. I wonder what financial settlement there will be between her and her wife on their divorce.

2 years ago

The arguments used to apply to herself support the women mentioned in this article, it summarizes some of the circumstances women endured before they entered prison. While Allison does deserve incarceration, she also deserves rehabilitation, her starting point doesn’t place her ahead of these women, if anything she should further her education under their tutelage. She experienced a different kind of coercion, but it was coercion.

“Tammy Gamache is in prison for life without parole because of her abusive husband’s crimes.

At the time her abuser murdered a man and shot his wife, 20-year-old Gamache sat in a car, watching in the rearview mirror, having been coerced with a gun to her back to accompany her violent husband in a robbery. Tammy Gamache never held a gun, never threatened the couple, and had been told that if she did as he said, nobody would get hurt.

It wasn’t the first time Richard Gamache had pointed a gun at her.

Just nine months before, after he took out a gun and forced her into a truck before he deliberately crashed it, the doctor who examined Tammy said her injuries didn’t look like a car accident.

On the day he nearly pushed her down a mineshaft, she thought the police would never believe her without witnesses.

When he raped her and she screamed through the gag forced into her mouth, no one intervened.

She tried repeatedly to get away, a report by domestic violence expert Nancy Lemon shows, once refusing to get in the car with Richard as he and his friend stalked her in a pickup truck. She told him to leave when he showed up at her job at a railroad station. When she said he and his friend Andre Ramnanan were not welcome at the home where she lived with another family, Richard called her a bitch. He never stopped harassing, threatening and intimidating her. And saying no was never enough.

From inside the Central California Women’s Facility in Chowchilla, Tammy Gamache, now 49 years old, told Ms. in an email she still feels angry over the times she couldn’t speak out back then. But then “there’s the times that I did speak up, did do something, and I’m amazed that I’m still alive.”

When she turned Richard down, he kept coming back. When she refused his demands to come with him, he threatened to kill her dog Rocky, who he tied to his car with a noose around his neck.”

2 years ago

The victim impact statements and the sentencing guidelines should be at the forefront of deciding how long her sentence is.

It will take her years to realize the gravity of her actions, being in close quarters with women who were subjected to life long abuse that she at one time thought was a principled laudable goal, will bring more clarity than she ever bargained for. There are women just like her in prison, influenced by an unethical man, manipulated into illegal acts. Few would have the financial resources she had for representation, or access to tell their story publicly. No one cares if poor brown women find themselves in similar situations. What is the weight of her deeds in comparison to theirs? She had everything in life that would preclude one from a federal prison, and yet she too now fits the statistics for patterns of abuse and prison sentences for women. All deserve rehabilitation and a safe place from which to accomplish it.

I don’t blame anyone for trying to escape a prison sentence, and it’s in her own best interest to bargain that time down as much as possible. I really hope she and everyone involved unravels the indoctrination and brainwashing they endured, but accountability is crucial to justice being served. She must be accountable, even if others weren’t or escaped early enough to craft their own narrative. She held out until there was no where left to go.

Half Full
Half Full
2 years ago

I really feel for this girl…therapy is not indulgence it is an integral part of her recovery…she was naive, stupid, gullible, delluded, entitled, arrogant…. what the fluck was she thinking? Being a victim of abuse myself I know very well how long it took me to overcome denial…Mack is being crucified by the media, her glory days are long gone, her career is over… she is a tortured soul. You all have forgiven and forgotten what the others did, India and Vicente…seriously? Accountability is also part of the healing process, those who freely joined the circus will only be free when they reconcile with the role they played and take account for the choices they made. BTW I think she is a terrible actress and her singing sucks!

2 years ago

Sounds to me that Allison Mack’s statement to the Judge is as full of rhetorical horse crap as her email to Raniere after having three way sex.

On Friday, March 4, 2016 10:19 AM, Allison Mack wrote [to]

i wanted to reach out to you both and thank you for this morning.

i arrived home and looked at myself in the mirror and what i saw was such beauty and grace.

i am new to this:

to being with more than one person.

to exploring and experimenting with my body and others in a free and open way.

to sharing and releasing and relaxing and enjoying.

the level of vulnerability is high and i feel nervous and insecure.

but when i am with you two something changes. i not only feel allowed to face this vulnerability with encouragement, i laugh my way through it.

i feel such gratitude for you both. you are the most dear souls to me and i feel such motivation to get better in every area of my life so i can provide even half the joy and satisfaction you have been able to introduce to my life.

i fight with my viscera sometimes – the unconventional approach to love and relationships is something i still wrestle with. but your care and commitment makes it so much easier. and what i find on the other side of this struggle is beyond what i ever imagined.

i am so glad to be tied to you for life.

i feel dedicated, eternally, to growing myself into a more loving, more kind, more generous, sensitive and genuine woman – even if it is only to be able to keep up with the two of you in the bedroom. ?

i love that i smell like a mixture of you both. i hold your love in my heart, it is obvious from the shine of my eyes.

“from wrong lead me to right.

from darkness lead me to light.

from death lead me to immortality”

within the shackles of commitment i find the greatest freedom of all. true love.


2 years ago

On March 4, 2016, Mack emailed Keith saying how fulfilled she was having had threesome sex– “even if it is only to be able to keep up with the two of you in the bedroom. i love that i smell like a mixture of you both.”

Was Mack writing about those three ways with Kristin Kreuk long rumored on the FR and CDAN?


crazy days and nights
crazy days and nights
2 years ago
Reply to  Anonymous

The crazy thing is, our actress has got her best friend, a foreign born B+ list movie and television actress from the same show also thinking this guy is incredible. No word on whether the pair were involved in a threesome with the boyfriend since our second actress claims to have a boyfriend, but if they did, Comic-Con probably would have exploded.

Allison Mack
Kristin Kreuk
Keith Raniere

2 years ago

“Frank Report reached out to Nicki Clyne and Keith Raniere requesting comment on the allegations and are awaiting a response.”

So how’s that evidence coming along there, Frank? Still waiting.

Aristotle’s Sausage
Aristotle’s Sausage
2 years ago

Mack’s attorneys claim she has been actively “making amends”. Yet they give not a single instance of these “amends”.

Instead, they think she deserves credit for amusing herself and furthering herself with college courses and therapy sessions.

How self-indulgent. She might as well expect credit for going to a nail salon and getting a massage.

It’s all about her, her, her.

I know these lawyers have to make SOME kind of appeal for leniency. But this is the best they could come up with?

She’s attempted no kind of community service, nothing?

They claim she is now an asset to society by being a friend and a good daughter. Is this a joke?

Far from turning her life around, Mack is the same self-centered entitled person she was when with Raniere. That’s the impression I get from her lawyers’ statement.

That and the same tired claim that she was “deceived”. An absurd claim, since she took an active part in Raniere’s deception. She knew what was going on, that much was proven in court. Do they think Judge Garaufis is an idiot?

She deserves 18 years in Federal prison and I think there’s a good chance Garaufis will give it to her.

2 years ago

— She’s attempted no kind of community service, nothing? —

One thing she could have done was Zoom meetings or lectures on the dangers of cults. That’s something she knows about…and maybe earn college credits and brownie points with the Judge.

2 years ago

“She’s attempted no kind of community service, nothing?”

(Note: I am not pro-NXIVM and I do not know Allison.)

I read the full report and there are a number of significant redactions, including some that I intuited might be concerning community service. It’s possible all information might not be available publicly.

2 years ago

Aristotle, I couldn’t agree with you more.

So self indulgent.

Alison should only get probation because she’s going to school, now?

Affording an education is a luxury to many people.

That woman should have started paying her dues before the judge ordered her to. Not continuing down her sick path of “self improvement”.

Too late for her now!

2 years ago

So when does Nicki get deported?

2 years ago

Frank, the sentencing memo just validated a lot of what you’ve written about her previously and the stance you’ve taken on her. Great job being pretty much the only accurate news source on this.

The Retard
The Retard
2 years ago

Well, Frank, I guess you can’t keep covering for Nicki Clyne’s suspicious marriage anymore, LOL.

Allison just confirmed what you’ve been actively denying for months —- that there is PROOF that Keith ordered that fake marriage for ‘immigration’ reasons. Allison is a FIRST HAND witness and party to that incident. That’s the best proof you can get.

You fucken dunce. I guess you’re not as smart as you thought.

…and why did you BLOCK my comment from being approved in Claviger’s article? Is it cuz you and Claviger don’t have a response for looking so foolish?

Please tell Claviger that I think he’s a pussy for not approving that comment and responding to it.

That fucken dunce was WAY OFF in his previous assessment of Allison’s sentencing guidelines.

Have a nice day. 🙂

2 years ago

Hmm. I just keep thinking about the years of lives that were collectively hijacked and stolen because of her participation.

Putting alison in jail for a super long time isn’t going make any of that right.

It’s a really good plea and I genuinely feel for the girl.

Different from the dossier girls who proudly flounce around, still working for their grandmaster.

Different from a life sentence for the destroyer abuser guy.

But? A crime is still a crime. She badly deceived people.

I have some thoughts I’d like to share but not until all the sentencing is complete.

Meantime, I’m honestly sending my prayers to these women. Also? To the judge.

What a shit show.

2 years ago
Reply to  my2cents

Yes, “my two cents”. Allison is looking for a house maid I noticed in the local paper. Might be more convincing to back up true feelings with some real life support. 🙂

2 years ago

I dont believe shes changed.If judge gives her a short sentence she will go back to sick brain washed people. And for what. All for a man noncence thinking that he thinks he’s god gift for these people.And she might try to rebuild again with them.Mack needs a good amount of time in jail. Personally at 10-15 years.

2 years ago
Reply to  Cindy

Cindy, I agree. It’s a hard pill to take hearing that alison is suddenly flourishing after harming so many.

2 years ago

They might as well ask for a gold clock as probation. She is definitely go to prison, just as she should. Despite any and all mitigating factors, she has committed serious crimes. I have confidence that judge G will pass an appropriate sentence.

2 years ago

Allison Mack sings and cries to Cult leader

2 years ago
Reply to  Anonymous

Lawyers are paid to lie on behalf of their clients.
Lawyers are the original spin meisters.

Allison’s lawyers are paid with Bronfman money.

Is Yoga a gateway to cults?
Is Yoga a gateway to cults?
2 years ago

Many cults like NXIVM have an association with Yoga. Now, a California’s yoga, wellness and spirituality community has a QAnon problem. A world that has long embraced love, light and acceptance is now making room for something else: QAnon.

2 years ago

Many of the actresses in Nxivm sought spirituality through their yoga masters, then it was an easy step to follow the teachings of a cult master. Mysticism and bullshit are easy to confuse.

Liar, liar Nicki's pants are on fire
Liar, liar Nicki's pants are on fire
2 years ago

Good for Allison.

Told ya that marriage was a fraud and Allison would make that even clearer.

Nicki is now saying Lauren, India and everyone else including her “wife” are lying?

Highly improbable.

Come on… Nicki is a proven liar. Enough with enabling her. She doesn’t even want people to baby her. Nicki has stated that repeatedly.

Allison, you can finish college from prison.

It’s much easier to turn your life around when your feature freedom depends on it and you’re living under house arrest at your mom and dad’s house.

Allison needs to do some time to really come out on the other side of her actions.

The public will feel that she paid her debt to society and Allison can move on.

Frank, are you going to write anything about the other ongoing lies from Nicki Clyne and her dossier project slaves that were further revealed to be utter B.S by Allison thru her cooperation with the government?

Such as the seduction assignments, the racial slurs etc. India was telling the truth. There is no way India could have known what Allison revealed to prosecution in secret back then.

If I were one of the people suing Nicki civilly I would add defaming to the list of damages. Nicki keeps using her fame as a bully pulpit to paint the victims as liars. When she KNOWS they are being truthful.

Too many people have independently corroborated facts that Nicki and her slaves continue to disseminate false information about for years now.

Mary Atwood
Mary Atwood
2 years ago

Liar, Liar,

“Frank, are you going to write anything about the other ongoing lies from Nicki Clyne and her dossier project slaves that were further revealed to be utter B.S by Allison thru her cooperation with the government?

Such as the seduction assignments, the racial slurs etc. India was telling the truth. There is no way India could have known what Allison revealed to prosecution in secret back then.”

What is this all about? Can someone clarify?

2 years ago
2 years ago

Yes, while reading her lawyers’ writings I can’t forget they’ve been paid for laying down all those words which could have easily been written completely against her welfare had they been paid by her victims.

A pack of toilet paper! XXL size!

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.

IMDb — Frank Parlato

Contact Frank with tips or for help.
Phone / Text: (305) 783-7083


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