The timing is inauspicious for Nancy Salzman to say the least. She is going to be sentenced on September 8th and now comes allegations that might not sit too well with US District Court Judge Nicholas G. Garaufis, who will be the one who determines her sentence.
Attorney Neil Glazer has amended his civil lawsuit against NXIVM defendants and added a new plaintiff, Camila, a woman who figured prominently in the trial against Keith Raniere.
The amended lawsuit now includes not only allegations against Raniere with respect to Camila but also against Nancy Salzman, largely for neglect when Camila was under her care.
Camila was central to the racketeering predicate acts of possession of child porn and exploitation of a minor in the trial against Raniere. The predicate acts were based on naked photos of her when she was 15 that were found on Raniere’s hard drive.
Camila did not testify at Raniere’s trial but appeared at Raniere’s sentencing hearing. Though not under oath as she would have been at trial, she condemned Raniere – stating, among other things, that he took photos of her and began a sexual relationship when she was 15 and he was 45 – in 2005.
The age of consent in New York is 17 and the age when nude photos may be taken legally, under federal law, is 18.
The new Camila allegations against Salzman in the civil suit may account for the prosecution asking for a one-week extension on filing their sentencing memorandum setting forth their recommendations on an appropriate sentence.
It is not improbable that Camila will appear at Salzman’s sentencing to speak as a victim.
We have published two other posts in this series on Glazer’s lawsuit.
The plaintiffs in the civil case include besides Camila, her sister Daniela, the woman who spent almost two years alone in a room in her parent’s house – to heal a so-called ethical breach; and DOS “slave” women Sarah Edmondson, Jessica Joan, India Oxenberg, Souki, Nicole and a number of Jane Does. It also includes former NXIVM members Mark Vicente, Anthony ‘Nippy’ Ames, Bonnie Piesse, Tabitha Chapman and Toni Natalie.
The defendants are Keith Raniere, Nancy Salzman, Clare Bronfman, Allison Mack, Lauren Salzman, Kathy Russell [six NXIVM convicted defendants], Sara Bronfman, Karen Unterreiner, Dr. Brandon Porter, Dr. Danielle Roberts, and Nicki Clyne
NEGLIGENCE – against Defendant Nancy Salzman on behalf of Camila
By Neil Glazer
The following is from the lawsuit.
- Defendant Nancy Salzman is a licensed nurse who held herself out to the NXIVM community as an experienced psychotherapist.
2. Beginning in 2005, when she was 15 years old, Camila was an abandoned child as that term is defined in New York Social Services Law section 384-b(5)(a), because, among other things, her parents evinced an intent to forego their parental rights and obligations as manifested in their failure to visit and communicate with Camila.
Camila remained an abandoned child until she attained the age of majority in 2008.
3. Beginning in 2005, Camila was separated from her siblings by Defendants Raniere and Nancy Salzman and she was instructed to reside in a house owned by Nancy Salzman that was in close proximity to Nancy Salzman’s house.
Raniere and Salzman assumed responsibility for providing all of Camila’s needs, including food, clothing, shelter, medical care and education, and Camila was entirely dependent on them to provide for those needs. Raniere and Salzman controlled Camila’s environment, including her housing, her relationships with others, the course of her education (or lack thereof), her nutrition and health care and other
aspects of her life.
4. Camila was in frequent contact with Nancy Salzman, often visiting her home daily. Other than Raniere, Salzman was the only adult authority figure in Camila’s life and, as such, Camila relied on her to provide guidance and to look out for Camila’s well-being. Camila’s relationship with and dependence on Salzman continued at least through the date on which Camila attained the age of 18.
5. Along with Raniere, Salzman had a close relationship with Camila’s parents, who entrusted Camila to Salzman’s care. Camila’s parents looked up to Salzman, who they revered as “Proctor [sic],” [Prefect] one of the top two leaders of the NXIVM community, who was responsible for (among other things) creation of the curriculum, and development and use of the EM method of psychotherapy.
Along with many others in the community, Camila’s parents viewed Salzman as the leading motherly figure in the community, a person who Camila’s parents trusted to dispense good advice, and whom they believed had only their (and their children’s) best interests at heart.
5. Nancy Salzman intended to assume, and assumed, responsibility to support and care for Camila on a permanent basis until Camila attained the age of 18. Salzman and Raniere were the functional equivalents of Camila’s parents.
6. Salzman knew, had reason to know, or recklessly or deliberately disregarded the high risk that Raniere would sexually abuse Camila while she was a minor and that, in fact, he did so repeatedly over a course of years. Salzman was one of Raniere’s many sexual partners; she was a member of his Inner Circle; and she knew of his sexual proclivities, including his deviant sexual interest in young women and minors.
Salzman helped create curriculum designed to promote the subjugation of women and to normalize rape and child sexual abuse. Among
other things, Salzman taught that there is nothing inherently wrong with pedophilia because the age of consent should be as low as 12, that many women enjoy being raped, and that rape is part of the natural order for men because it is a normal response to any indication that their female partner intends to break off their relationship.
Salzman pressured her daughter Lauren into a close relationship with Raniere and knew how abusively he treated Lauren. Salzman understood and accepted that one of her roles in the NXIVM community was to enable, facilitate or promote the grooming of young women and girls for sexual relationships with Raniere. Salzman accepted this role because her income, wealth and power within the community depended on her ensuring that all of Raniere’s needs and demands were met, and she committed numerous criminal acts to further the purposes of the Enterprise and the trafficking venture.
7. Salzman knew that Raniere was paying inappropriately close attention to Camila and she helped to draw Camila closer to him. Salzman knew that Camila was an abandoned child, and that she was almost completely isolated, permitted to have contact with only a few people including herself, Raniere and several other members of Raniere’s harem. Salzman knew that Camila was vulnerable to abuse, a circumstance Salzman played an active role in creating.
As the owner of the house in which Camila resided, with frequent contact with Camila, Salzman was one of the only adults in the NXIVM community in a position to protect Camila.
8. Nancy Salzman was a “person legally responsible” for Camila under New York law.
9. Camila was an abused child under New York law, because Salzman (i) created or allowed to be created a substantial risk of protracted impairment of Camila’s physical or emotional health, and/or (ii) committed or allowed to be committed (a) one or more offenses
against Camila defined in article 130 of New York penal law, or (b) acts that rendered Camila a victim of sex trafficking pursuant to 22 U.S.C. § 7102.
10. Camila was a neglected child under New York law, because she was an abandoned child. Camila was also a neglected child because she suffered impairment of her physical, mental or emotional condition as a result of Salzman’s failure to exercise a minimum degree of care (i) in supplying Camila with adequate food, clothing, shelter or education, though financially able to do so; (ii) in providing Camila with proper supervision or guardianship by unreasonably inflicting or allowing to be inflicted harm or a substantial risk thereof.
11. In her role in loco parentis or as a person legally responsible for Camila, Salzman owed her a duty of care.
12. Salzman breached her duty of care owed to Camila.
13. Salzman’s breach of her duty of care owed to Camila was a proximate cause of Camila’s physical, psychological and emotional injuries.
NEW YORK SOCIAL SERVICE LAW § 420 against Salzman on behalf of Camila
14. Defendant Raniere repeatedly engaged in conduct against Camila while she was a child under eighteen years of age that constituted sexual offenses as defined under article one hundred thirty of New York state penal law, including: (i) 130.25, rape in the third degree; (ii)130.40, criminal sexual act in the third degree; (iii) 130.55, sexual abuse in the third degree; and (iv) 130.20, sexual misconduct.
15. Defendant Raniere engaged in conduct against Camila when she was a child under seventeen years old in violation of New York penal law section 263.05, use of a child in a sexual performance.
16. Raniere was convicted for, among other things, sexual offenses against Camila in violation of 18 U.S.C. section 2251(a), sexual exploitation of a minor, and 18 U.S.C. section 2252(a)(4)(B), knowingly possessing visual depictions of a minor engaging in sexually explicit conduct (possession of child pornography). The elements of these federal offenses of conviction are identical or substantially similar to the elements constituting the New York state criminal offense of use of a child in a sexual performance.
17. Raniere’s sexual offenses committed against Camila as alleged herein caused and continue to cause Camila to suffer physical, psychological and emotional injuries or conditions.
18. … Defendant Nancy Salzman knew or had reason to know about or suspect Raniere’s physical, sexual, psychological, and emotional abuse of Camila when she was a child.
19. Camila was an abused child as defined in section 412 1 of the New York Social Service Law and section 1012 (e) (i), (ii), and (iii) of the New York Family Court Act.
20. Defendant Nancy Salzman was a person legally responsible for Camila under §1012 (g) of the New York Family Court Act.
21. Defendant Nancy Salzman was a registered nurse and thus a person required to report a case of suspected child abuse under section 413 of the New York Social Service Law.
22. Defendant Nancy Salzman, knowing of, having reason to know of, or suspecting the abuse being inflicted, and that was likely to be inflicted in the future, on Camila, willfully failed to report such abuse as required by the New York Social Service Law.
23. Defendant Nancy Salzman’s failure to report the known or suspected child abuse of Camila was a violation of New York criminal law under section 420 of the New York Social Service Law.
24. Defendant Nancy Salzman knowingly and willfully failed to report the known or suspected child abuse of Camila, and is thus liable for the damages proximately caused by her failure to comply with New York law that required her to report the abuse.