Glazer Wants Judge to Compel Suneel to Turn Over Collateral He May Possess

BROOKLYN – October 29, 2021; Attorney Neil Glazer of Kohn Swift and Graf of Philadelphia, the lead attorney in the civil lawsuit, Edmondson et al. v Raniere et al. filed a request to US District Judge Eric Komittee for authorization to issue a subpoena to Suneel Chakravorty, who he says he suspects has the collateral of one or more DOS slaves.

Chakravorty is not a party in the lawsuit. He has Raniere’s power of attorney.

Glazer expressed concern that Chakravorty “possesses and is sharing images of DOS collateral with others” including adult nude images of Camila.

Glazer wants the court to order Suneel to turn over to him on behalf of the plaintiffs:

1. copies of all [nude] images of Camila and any other woman who was ever a member of DOS that are in his possession, custody or
   control;
2. a bit-for-bit copy of any computer or storage device in his possession, custody or control that contains or ever contained such images;
3. identification of every cloud storage service he has ever utilized or had access to in which such images are or have ever been stored;
4. every communication concerning such images;
5. a sworn affidavit identifying:
   1. Anyone he has shown, transferred or transmitted any copy of any such image,
   2. Anyone who showed, transferred or transmitted to him any copy of any such image, and
   3. Anyone he knows or believes has any images in their possession, custody or control, specifying the location and the media on which the images are stored.

The civil lawsuit seeks damages from Clare Bronfman, Sara Bronfman, Keith Raniere, Nancy Salzman, Lauren Salzman, Allison Mack, Kathy Russell, Karen Unterreiner, Dr. Brandon Porter, Dr. Danielle Roberts and Nicki Clyne, for their roles in NXIVM and DOS.

The plaintiffs are Edmondson, Toni Natalie, Jessica Joan, India Oxenberg, Bonnie Piesse, Tabitha Chapman, Ashley Mclean, Ana Cecilia, Mark Vicente, Anthony Ames, four women whose first names only are being used in the complaint (Daniela, Camila, Souki, and Nicole), and some 50 Jane Does and 15 John Does.

[Ed. note: A motion was made by plaintiffs before Judge Komitee asking that plaintiffs be permitted to proceed using first names or pseudonyms. Glazer wants the civil court to adopt the same protocol for plaintiffs as Judge Nicholas Garaufis did for alleged victims in the criminal proceeding against Raniere. Judge Komittee has not ruled on that matter yet.]

In writing to Judge Komitee, Glazer expanded on issues he raised at a status conference on October 15th.

Glazer wrote in his letter about Chakravorty, “our concern with this individual is the high risk that if this evidence is not preserved, it may be transferred to others or destroyed.”

Glazer noted that Chakravorty, “who is not an attorney”, is “a former NXIVM member and associate of Defendant Keith Raniere…. [who] has been directing efforts to prepare and file on behalf of Raniere a motion for a new trial under Fed. R. Crim. P. 33, based on what he alleges is proof that the FBI tampered with evidence introduced at trial to support [racketeering predicate acts of] exploitation of a child, and…possession of child pornography.

“Those predicates concerned lewd photos taken by Raniere in 2005 of a then-fifteen-year-old Jane Doe victim who is a Plaintiff in this action, Camila. He [Suneel] purports to have hired experts who will opine that the metadata associated with these files was altered to reflect a 2005 creation date when they were allegedly created much later.”

Chakravorty publicly disclosed that he has reports from three forensic experts who support his theory that the FBI altered or tampered with photos on a Western Digital hard drive and camera card that were seized by the FBI in a raid on Raniere’s executive library in March 2018.  About 10 months later, the FBI discovered the hard drive contained 22 images of Camila which their forensic examiner said were taken in 2005, based on the EXIF data on the digital photos and other evidence. In 2005, Camila was 15.

Glazer continued, “The hard drive on which these files were stored is the subject of an inquiry by Judge Garaufis into whether the protective order he issued in the criminal proceeding has been violated.”

Chakravorty issued a statement on October 14th, claiming he never possessed a copy of the hard drive.

His statement was in response to Assistant US Attorney Tanya Hajjar who filed a letter with US District Judge Nicholas G. Garuafis advising that she “received a report that Suneel Chakravorty, an associate of defendant Keith Raniere’s, is in possession of electronic discovery materials, including a copy of a hard drive that was produced to defense counsel pursuant to the Protective Order,”

In response, Judge Garaufis issued an order that “All current and former counsel of record for Mr. Raniere are DIRECTED to provide individual sworn declarations identifying any and all persons to whom information covered by the Protective Order was shown or provided to during the course of this litigation…  including a copy of a hard drive, to Mr. Raniere, to Suneel Chakravorty, or to any person not entitled to such material under the Protective Order.”

What concerns Glazer, however, is not that which is under inquiry by Judge Garaufis.  According to the government, the nude images of an adult Camila and possibly others are not discovery materials covered by the protective order in the criminal case.

“For this reason, these images are beyond the scope of Judge Garaufis’ current inquiry,” Glazer wrote. “… but are of equally serious concern: nude images of Camila taken when she was an adult and a DOS ‘slave… Such images were kept as ‘collateral,’ meant to enforce slaves’ compliance with all demands of their ‘masters,’ and to ensure their continued silence about DOS and what was taking place within the group. It is blackmail material, which the jury concluded was used to extort slaves.”

Camila’s master was Keith Raniere. She was one of eight first-line masters. DOS had 105 female members when it disbanded in 2017 and one male, Raniere.

Glazer added, “DOS collateral was compiled and stored on hard drives, including drives possessed by a defendant in this action, Nicole Clyne, another vocal advocate for Raniere who Plaintiffs have learned currently resides with Mr. Chakravorty.

“We were recently informed that Mr. Chakravorty shared these images of Camila with one or more third parties. He apparently shared these images because they relate to other evidence of the child exploitation and child pornography predicates underlying Raniere’s racketeering conviction. The prosecution also presented to the jury later-dated photographs of Camila that showed a surgical scar on her abdomen from an appendectomy performed when she was sixteen years old. This evidence supported the prosecution’s contention that the lewd images of Camila were taken when she was younger than sixteen because those images did not show an abdominal scar.

“Mr. Chakravorty claims that the images he has shared do not show the scar, which he asserts somehow proves that the government may have altered the photos introduced at trial.

“We do not know how Mr. Chakravorty obtained these images. Nor do we know if he has, or has knowledge of the whereabouts of, other DOS collateral. The fact that he is co-habiting with Defendant Clyne (who was a DOS ‘master’) both explains how he obtained the images he shared with others and raises the concern that he may have or have access to other collateral. If this public supporter of Raniere possesses and is sharing images of DOS collateral with others, it is of grave concern. Not only is this collateral significant evidence in this action, but the mere possibility of its dissemination is a continual source of anxiety and trauma for all DOS victims, including Plaintiffs.

“We respectfully submit that these circumstances warrant prompt action, because (among other things) the proposed discovery may provide a basis for injunctive relief regarding the storage, safeguarding and ultimate disposition of this highly sensitive material.”

***

By injunctive relief, Glazer hopes to compel Chakravorty to surrender the DOS collateral or at least be forbidden to share it, should he possess it.

Frank Report contacted Chakravorty. He said he does not possess any DOS collateral and will issue a written statement concerning the matter.

“I believe in transparency,” Chakravorty told Frank Report. “I do not possess nude photos of Camila nor do I have any DOS members’ collateral or nude photos. There are a number of assumptions Mr. Glazer has made concerning myself that are not quite correct and I plan to set the record straight on Frank Report and possibly directly to the court.”

Frank Parlato