As we pointed out in our article NXIVM Civil Lawsuit Begins but Only Bronfman Lawyers Show Up for Defendants of the 12 defendants in the civil lawsuit Edmondson v. Raniere, it appears that only Sara and Clare Bronfman are definitely represented by attorneys.
The defendants are the Bronfman sisters, Keith Raniere, Nancy Salzman, Lauren Salzman, Allison Mack, Kathy Russell, Karen Unterreiner, Dr. Brandon Porter, Dr. Danielle Roberts, and Nicki Clyne.
There are 83 plaintiffs. The lead attorney is Neil Glazer. At an October 15th status conference, Judge Eric Komitee said he wanted to hear from the defendants who had no attorney what their plans were to defend the case, what motions they planned to file, and other matters of interest.
One of the big undecided matters rests with the judge who must decide if the plaintiffs who seek monetary damages may remain anonymous with regard to the public aspects of the case.
Currently of 83 plaintiffs, only 10 are fully named. They are Sarah Edmondson, Toni Natalie, Jessica Joan, India Oxenberg, Bonnie Piesse, Tabitha Chapman, Ashley Mclean, Ana Ceclia, Mark Vicente, and Anthony Ames.
The other 73 are either first names or are referred to as Jane or John Doe.
Three of the defendants – Nicki Clyne, Danielle Roberts and Brandon Porter- have filed letters with the court explaining their plans going forward. All three admit they are broke and cannot afford a lawyer.
Here are their letters.
Nicki Clyne’s Letter
Dated: October 28, 2021
Judge Pollak and Komitee
Dear Honorable Judges Pollak and Komitee,
I am writing in response to Judge Komitee’s request that defendants submit letters concerning how they intend to proceed. As an initial matter, it seems appropriate for me to advise the Court, that I am not currently represented by counsel. Under my present financial circumstances, I frankly do not know how I could find an attorney competent to represent me in a lawsuit this complex and wide-ranging. I have concerns regarding how any testimony I might be compelled to give or rulings concerning my conduct might affect my rights in other legal proceedings that could occur in the future.
Having said this, however, I am submitting this letter as the Court has instructed. Based on my understanding of the law, as well as the comments of the attorneys who appeared at the October 15, 2021 status conference, it seems likely that I would join in any motion to dismiss under Rules 8, Rule 9, and Rule 12. I would also ask the Court to order that the names of all Jane Doe and John Doe plaintiffs. It seems impossible to contemplate litigating the claims against me, if they were to survive the initial motions, without knowing who is making them.
There are many other procedural issues, including possible conflicts of interest involving at least one of plaintiffs’ lawyers, that will have to be addressed early on in this case. I am eager to provide relevant evidence concerning both that issue and the claims against me. I hope the Court will appreciate, however, my reluctance to address any of these without the advice of counsel. Even though I do not have access to sufficient funds now, I am still looking for ways to overcome that issue and find an attorney so that the complete truth will come out if the case does in fact go forward.
I appreciate the Court’s consideration.
Daniele Roberts’ Letter
Dear Judge Komitee,
I am one of the defendants in case NO. 1:20-cv-00485. Late last week I filed a request for an extension in this matter, but have not yet received a response and in good faith wanted to submit at least a brief response in case my request is not granted. I have requested this
extension primarily due to the fact that that it has been difficult to secure counsel without the funds to pay for them, and I have limited legal knowledge. It would be difficult to meaningfully participate in this complex matter without properly trained representation, I have filed a request for pro bono counsel with the federal court and am looking for other options to be able to resolve this issue.
I have read the transcript from the court conference on the 15th and the amended complaint in order to discern what would be most helpful to this process at this juncture. The claims reviewed assert the existence of an enterprise or criminal organization with the intent to harm in
order to fit a RICO charge that has no basis. To my knowledge, no such thing existed. All the endeavors I was involved in or had knowledge of were created with the intent to help people and did so in significant and measurable ways. Therefore, the hellacious claims made from this
faulty assumption would need to be completely reexamined. Anything I participated In was done with positive intent and between consenting adults for intentional and mindful reasons.
I deny any participation in any of the charges or contribution to any damage the plaintiffs are claiming they experienced.
In addition, I agree with Ms. Clare Bronfman’s counsel that was present at the conference in regards to the lack of clarity set forth by these assertions. I would, in tandem, file motions to dismiss based on Rule 8, Rule 9(b), and Rule 12(b)(6). If any further evaluation of my
participation was appropriate, I would need further clarity as to the specific actions I took, the measurable damages incurred and by whom is claiming those damages including all Jane and John Does claiming involvement.
in light of these exceedingly false allegations, and other conflicts of interest, there are also specific counter claims I would like to file when appropriate counsel is obtained, I humbly request your honors help in this matter in response to my recently submitted application to the pro se’s office. It is very important these counter issues be properly brought to light as they will help put this entire matter in perspective.
Also relevant to this proceeding and the use of everyone’s time and resources is my financial status. As a result of the actions of the plaintiffs, which I will bring to light in counter claims, I have lost all primary means of income, including my privilege to practice medicine. In addition, I have sold my home and assets to afford legal counsel in the defense of these false claims against my medical license, and currently hold over $600,000 in debt for my medical education and legal fees to defend it. There are no monetary stores left to be recovered from me.
For all of the above reason’s I would move to dismiss and/or be dismissed from the above complaint.
Thank you for your time in this matter.
Dr. Danielle Roberts
Brandon Porter’s Letter
Dear Judge Komitee:
I am one of the defendants in the above case. I wasn’t at the status conference on October 15, 2021 because I was waiting to see if the plaintiffs were going to dismiss me from the lawsuit. I have had some informal discussions with Mr. Glazer and agreed to waive service. Mr. Glazer is aware that I must represent myself and I have provided him with my financial status. I have no money to hire a lawyer. It wasn’t until after the status conference that I saw that the plaintiffs’ attorneys entered my waiver of service.
I saw that your honor asked for defendants to submit letters regarding proposed next steps by October 29, 2021. I was just able to read the transcript from the October 15 conference and glean the purpose of the letters. Clare Bronfman’s council stated in the conference that her motions to dismiss would be related to Rule 8, Rule 9 (b), and Rule 12(b)(6). I would agree with these motions and I would file motions including motions to dismiss if necessary. It will be impossible to answer the Doe claims because I do not even know who the supposed victim is, when the claim happened and if they claim I was involved in the act. For instance, I am accused of mail fraud, wire fraud, bilking others out of large sums of money, forced labor, and forced sexual slavery, and trafficking in “sexual slaves.” Regarding the question of splitting the suit into two parts, I really have no thoughts on this.
I will challenge the claim that this suit fits a RICO conspiracy. If there was a conspiracy, as the plaintiffs claim, I was not aware of it or participated in it. The Federal Government didn’t even include me in their list of people in the government’s proposed “inner circle” of NXIVM. To my knowledge, I was not a target in their investigation. Since there was no conspiracy, the RICO claims have no standing and this suit should be dismissed. I did not have criminal intent; at all times my intent was to help people. Therefore, I will DENY all of the allegations in the Complaint and file motions to dispose of the claims at the appropriate time.
On another note, I was discharged from a no-asset Chapter 7 bankruptcy on July 15, 2019. This lawsuit was filed on January 28, 2020. All of the plaintiffs’ claims were from actions that took place before my bankruptcy was discharged. As such, these claims against me are barred by the Bankruptcy laws and the plaintiffs were obligated to not make these claims or dismiss them once they or their attorney received the Order of Discharge. The mere allegations in the claims have irreparably damaged me and my family and have deprived me of my livelihood. I provided Mr. Glazer with a copy of the Order of Discharge along with a position paper that the Order precludes this action. We briefly discussed that issue. I can provide a summary of that position paper when appropriate, in your view. I do not want to step out of bounds in this letter. For the above reason, I will claim that the plaintiffs do not have standing and will move to be dismissed from the suit. I also believe that the claims may well be barred by the applicable statutes of limitations. Other defenses may arise once facts are made known, if necessary.
Brandon B. Porter
“Sicily is a beautiful country.”
Good! Then we both agree you should go back to it! Now the agreement about the method of transportation and the destination in Sicily and what happens to you when you get there may be up for debate in your eyes, but not for me! 😉
What do you have in mind?
Well perhaps being arrested, tried by law with due process, executed and sent back back in a coffin to be cremated should do the trick! 👍🏻😁😉
“It is more and more acceptable to change your gender. If you want to identify as a male I urge you to do so. I also think if you do not wish to be Black, your birth race you can identify as being White.”
I do not wish to change my gender! I want to “identify” what I was *BORN* as, a masculine *WHITE MALE* southerner, who stands up for the truth against all the different kinds of niggers destroying my country! That is my *BIRTH RACE* and my *BIRTH RIGHT*! It isn’t even something that I “identify” as. IT’S WHAT I AM! We have never even met nor have we even talked in person! You know nothing of me except whatever that you make up!
That is why I’m warning you or liability in the courts along with your other crimes to me and God only knows what other kind of guido criminal activities that you’ve been involved with in regards to your guido “family”!
Please feel free to sue me. By the way, do you know Sultan?
You’re on buddy – and, no, I do not know “Sultan”!
“i like where this is going.”
If you truly mean that, then please go post up my other comments in all other articles with no trolling commentary from you! You already didn’t post up my medical documents on here (because you don’t have them) and I’m acting out of blind faith on your non-existent credentials! If all of my comments are not posted up within 24 hours, the deal is off, I will sell all of your imaginary meds to a ghetto nigger drug dealer who, let me tell you, would treasure them much more than me, and then you’re getting prosecuted, sued, and once convicted beyond a reasonable doubt, and then the rope when the patriots take back the country and we all believe again!
I’ve worked very hard on all of my comments and put a lot of effort, wisdom, thought, and time into them and it’s not fair that you claim to be a patriot and withhold my free speech! This is your last chance, Frank! Post them with no comments from you and let the battle of ideas win themselves out like they always do without trying to force people into mental institutions and medication! This is true patriotism in action!
The only true medication that will ever succeed in helping society the red pill! If you keep taking the blue pill and forcing your readers to do the same, then that’s not true freedom is it?! If you’re so right and I’m “crazy”, then why are you such a coward to let my voice be heard and logically corrected?! That should be fairly simple to do seeing the fact that words are just “crazy and senseless mumbo jumbo”, right?!
I think the real reason you hide my words and always yap about “meds” and “mental intuitions” and refuse to show any hint of documentation of your qualifications like you’ve been requested to, is because you’re terrified of your readers hearing the truth and so you have to be a virtual tyrannical dictator!
If this isn’t true, then you have 24 hours to prove it, if you don’t then you have shown your true colors (yes pun intended) to everybody on here forevermore!
No meds, no institution, and you oust yourself again, like you already have for not showing the documentations you were requested to, forevermore!
So please show that you actually have some love for this country and it’s freedom of speech! You have 24 hours to do that! The clock starts: NOW!
Which comments are you referring to?
The ones that I posted up on the articles:
And including the one that we’re on right now! Get to posting and no trolling comments from you!
Are you posting my comments or not?!
“Calm down, Karen.“
You do realize that the term “Karen” is a term that bigger Marxists use to mock their niggerized stereotype of a white blonde woman, don’t you?!
You’re already highly suspicious that you would choose a moniker of a cartoon character created by japs and makes your loyalty to this country highly questionable! So if you’re not some kind of nigger yourself, you shouldn’t be a nigger-sympathizer by being a crypto-Marxist and use their nigger-language to shit on the white women that they’re jealous of! If you are in fact a nigger of some kind, a crypto-marxist, and/or both or even worse, a nigger and an open Marxist, you must know that you’re getting the rope when then the true patriots take this country back just like Ginzo will! Don’t dig your hole deeper than your jap moniker already makes you to us!
Remember, nobody wants to be a Ginzo!
Food for thought!
Dear readers – this young lady whose comment you see above is actually one of my patients. She escaped the Bedford Institution for the Criminally Insane about three weeks ago and we are trying to find her. The only hope we have of capturing her and returning her to our care is to allow her to continue to post in the hopes she will give a clue as to her whereabouts.
You’re still abusing gender pronouns! I am a male! This is the true “criminally insane” activity on display! Were you too busy shoving cannolis up your ass when I talked to you about this! The courts will not have mercy on you over this if you don’t stop!
I’ve asked you to get medical treatment for your Alzheimer’s syndrome and Asperger’s grandiose fantasies about your delusions about being a doctor before you’re arrested and sued! Just for the sake of publicly demonstrating how big of a fraud that you are, can you provide the readers here of my “ Bedford Institution for the Criminally Insane” documents here?! Can you with evidence beyond a reasonable doubt show what crimes that I was convicted as well as by what court and judge in order to be sent there to begin with?! I bet you that you can’t because you’re the one that’s criminally insane and you’re projecting it onto me! If Frank does not post it in his next trolling session, know that he has permanently ousted himself as the Alzheimer’s and Asperger’s syndrome-ridden guido criminally insane fraud that he is and is just projecting and lying like the typical frutti di mare nigger that he is!
Claiming to be a doctor and forcing treatment on non-consenting victims like the fictional kike-concocted holo-hoax fable of the Nazis is a serious crime in this country! I understand that you’re a guido and your heritage has had a long history of committing organized crime like this in our country, but we now have the marinara nigger’s bane, it’s called: RICO!
While of course, kidnapping is very statistically and stereotypically accurate of your species, it is also an extremely serious crime in this country, and could land you in prison for decades! To any law enforcement who may read this: I DO NOT CONSENT TO FRANK “CAPTURING” ME AND FORCING ME TO TREATMENT HE IS NOT EVEN LICENSED TO SO, (WHICH FRAUDULENT BUSINESSES AND FALSE IMPERSONATIONS AND FAKE IDENTIFICATION IS ONCE AGAIN, ALSO NOT SURPRISING TO HIS KIND)!
IF I WIND UP MISSING, KNOW IT WAS FRANK AND HIS GUIDO MAFIA FAMILY! FRANK HAS MADE A PREMEDITATED CRIMINAL CONFESSION RIGHT HERE!
I must warn you that I have stand your ground rights and laws, Frank! If you or your guido “family” members come after me, I will have no choice but to use lethal force to protect myself from criminal danger! I have your written confession of your premeditated attempt kidnap me right here to defend myself in court! You’ve been warned!
Instead of committing a very serious anthropologically typical criminal act of your species and putting you or your “family’s” life in danger, I’d advise you to do something that is legal and more productive of your time, such as, oh I don’t know……… PUT UP MY GODDAMN POSTS ON THE OTHER ARTICLES THAT YOUR DUMBASS HASN’T POSTED YET EVEN THOUGJ YOU PROMISED! STOP ALL YOUR INFANTILE GUIDO NIGGERDRY AND DO WHAT YOU PROMISED, YOU WORTHLESS PIECE OF FUCKING SHIT!
DON’T SAY ANOTHER GODDAMN GUIDO WORD UNTIL YOU’VE POSTED UP ALL MY WORDS OF WISDOM ON ALL THE OTHER ARTICLES THAT I WROTE THEM ON LIKE YOU SAID YOU WOULD AND STOP NIGGER-LAGGING ON IT TO SAY STUPID MARINARA NIGGER SHIT, YOU FUCKING DUMB SICILIAN PIECE OF SHIT!
I’VE ASKED YOU NICELY, STOP BEING A GUIDO ON YOUR GET POSTING MY COMMENTS, YOU FUCKING DICK!
Now you know I have prescribed certain medications for you. Please take them. No one wants to put you in a straight jacket and return you to Bedlam.
You and your mother agreed that you would faithfully take your meds. Now you have broken your word.
I never agreed to any of this! You’re a liar! However you did agree to post up my other comments! Tell you what, I’ll take your imaginary meds if you keep your word and post up all my other comments on the other articles and if you don’t comment on them! Sound like a deal, champ?!
i like where this is going.
Seriously, the first step is admitting that you are powerless over alcohol…
Says the idiot who calls himself Snorlax from the japs!
Snorlax, this young lady is a patient of mine. She has not been taking her meds.
Good seeing you Nicki, or are you still going by Pea? How’s the herpes treating you?
“Anne — don’t worry about her violent temper. I’ll have her mother slip some Somenix into her formula. She is really a nice woman but after reading this blog she developed an acute epileptoid manifestation of the panphobic melancholiac. This combined with an unfulfilled desire to be an infant male baby and at times thinking she is a praying mantis has left her with a schizoaffective disorder.
It is incurable but manageable.”
It’s ok, Ginzo! I know that it’s just your “incurable but manageable” Alzheimer’s and Asperger‘s kicking in again! My mother isn’t even aware of you or your delusional psychotic conspiracy to play “doctor” and fraudulently prescribe people medications to force them to take against their will! She wouldn’t aid and abet you in criminal activity! I’m sorry that you’re so nearsighted to think everybody is a lawless guido piece of shit like your relatives are prone to be! Your kind is one of the many reasons why we have RICO laws to begin with! So that guido niggers can be stopped with these kind of racketeering conspiracies along with all other kinds of niggers!
I’m not a female nor do I desire to be an “infant male baby” which is ironically really adorable you would project that onto me because you’re not even mature enough to realize that “infant” and “baby” are redundant and therefore shouldn’t even be used in the same sentence! Perhaps you need your mommy to read you grammar books for “infants” when she tucks you in bed at night! As for me, I’m a true masculine southern male ADULT that is a real patriot and rightful citizen to this country who’s ancestors go back to the first colonies who landed here and don’t like to see this country going in the wrong direction from what my founding fathers intended! I don’t claim and never have claimed to be nothing else!
But I understand! You’ve had a long day playing “doctor” and “reporter” with all of your little pen pals haven’t you, champ?! Perhaps tomorrow you’ll do better before your Alzheimer’s and Asperger’s kick in! Try not to sundown again tonight, ok champ?!
I know you’re mentally retarded, but please try not to mispronounce my gender and identity to make yourself liable to lawsuits! Even you should have the mental capacity to know that the courts aren’t very friendly nowadays to people who recklessly and willingly continue to make that “mistake”!
Anne, if you’re not some kind of nigger, I’d highly suggest to step away from this guido! I’m dealing with him! He’s very sick and confused and perhaps even dangerous! He could even be prone to drive bys and restaurant shootings, all because “the Don says hello”! He’s illiterate, doesn’t understand true American history, is on a Marxist agenda, uses virtual gulags and Josef Mengele like tactics to subdue anybody who won’t subscribe to the Mossad narrative of America and race!
If you are some kind of nigger, I must warn you not to conspire with other nigger’s criminal activities, like Ginzo here, so that when the patriots take this country back, you can be sent back to your country safely instead of being publicly whipped brutally and hanged with other niggers begging for the rope with their actions like Frank! We’re just trying to manage him and his delusions right now while we get the rope ready to put him down like the guido dog that he is!
It’s very obvious about both of you, due to your unfortunate genetic inferiorities, that thinking is not your strong suits! That’s understandable because neither was it for your ancestors! But regardless, I would advise you both to please try your damnedest no matter how much effort it takes before it’s too late for Anne! It’s already too late for Ginzo! He’s done too much and must pay the price for of his treason and sedition! But Anne, if a nigger be a nigger, you may still have a chance to be deported back to the shit hole of your country without harm, (outside of what her incompetent government is doing to their citizens without the reign of whites to help them know what they’re doing of course 😉)!
Please remember that the true patriots will save this country from niggers of every kind one way or another and will bring justice upon them for what their degenerate cultures have to to our righteous country! Please don’t get yourselves caught in the utter ruin and devastation of the Wrath of God worse than you all will already suffer for it!
P.S. Ginzo! You better start posting my other comments on the other articles I made them on if you know what’s good for you! I’ve tried to ask you nicely, but you’re not listening and my guido patience is wearing thin! We let you out of your cage to do this task and you’re too busy jacking off with alfredo sauce and rolling around in your own garlic-stenched feces instead of paying attention! GET TO POSTING, YA DUMB NIGGER!
Please tell us your whereabouts and some nice young men in their clean white suits will be coming to take you away – to the Bedford Institution where you were happy.
Your mobster family in suits aren’t coming for me without with me sending them back in coffins, you stupid guido! I’ll never be “happy” in an imaginary “institution” made up by a psychotic, Marxist, Alzheimer’s and Asperger’s Syndrome-ridden frutti di mare nigher fraudulently and delusionally playing doctor to sastify his psychotic grandiose fantasies in order to protect his fragile guido-ego! What in God’s nigger-free earth gave you psychotic of an idea, you met ally worthless piece of fucking shit?!
What do we have to do in order to get your brain to work?! Do we bust your brains out with a bat like like your mobster nigger “family” does?’ Do they just do it because they project onto their innocent victims what they need done to them?! You don’t have to be ashamed of your projections, Frank! I can help take it all away very easily! 😉🏏
Please call your mother. She will get you back to the sanitarium.
How many times do I have to tell you that my mother doesn’t support your unlawful actions?! How are you this dumb, you sicilian nigger?! 🤨
How about I call ICE instead and see what “sanitarium“ you need to be in when your ass is deported back to your own country?! 🤔
THERE’S A BETTER WAY!
Sicily is a beautiful country.
If the lawsuit filed by attorney Glazer is successful, can he use “wage garnishment” to collect the verdict?
I don’t know the NY law.
Wage garnishment is just one of the many tools that Neil will be able to utilize to collect any judgments that are awarded in the lawsuit.
Perhaps the most noteworthy aspect of such judgments is the likelihood that the defendants will be held “jointly and severally liable” for them. That means that Neil will be able to collect all the judgments awarded from whichever defendants have funds available to pay them rather than needing to collect an equal portion of those judgments from each defendant (If one or more defendants ends up paying more than their proportionate share, they would have the right to attempt to collect funds from the other defendants).
Thank you for taking the time to answer my question.
I initially felt bad for Nicki, Porter, and the rest of the cult, I did not want them to needlessly suffer.
After this newest chapter – which I call “Haha! We’ve Camila’s Blackmail Material” – I no longer pity any of them.
Raniere and Nxivm did not make them cruel. That’s a sliver of who they’re and have always been.
A civil judgment is good for ten years, renewable for another ten. In NY, it attaches as a lien to real property, and bank accounts can be frozen.
There are caveats: they need to be domesticated in each jurisdiction. What applies in NY doesn’t apply everywhere.
Enforcement measures vary. Some states don’t allow garnishments, NY does.
A default judgment is trickier at the state level. Sometimes a brand new lawsuit has to be brought in a different state because defaults aren’t acknowledged.
Since this is Federal, it will be easier to domesticate in different jurisdictions, but state-specific issues will surely arise.
Brandon Porter? You had no right to be showing people films of actual murder without their informed consent.
Ugh. Nicki Clyne explains how she “frankly (does) not know how (she) could find an attorney competent to represent (her) in a lawsuit this complex and wide-ranging.”
Nicki? Why not live a day in the life of someone like Susan Dones and figure it out?
You believe that women can just cry their way out of situations?
Good luck with this one.
Nicki Clyne is an illogical nitwit.
She recently tweeted that a black, male professional athlete should make a documentary about white women in fashion modeling.
This line of “thinking” that any soul who creates art is then obligated to create a follow-up project about a subject Nicki Clyne chooses…is insane.
No artist is under any obligation to tell EVERY story. And certainly not the one Nicki Clyne picks out for them.
I guess before the director of ‘Pretty Woman” passed away, Nicki would have demanded that he make a movie about a black male streetwalker who does not live happily ever after with a wealthy white female client?
Only creatively bankrupt souls sit back and criticize others instead of making their own art and projects. But dictating what creations another soul must produce is next-level entitlement and arrogance.
And how out of touch is Nicki to believe that anyone making movies today is like, “I must do what Nicki Clyne tweets’.
IF (highly unlikely) a creator ever heard Nicki’s tweet mentioned, their only thought would be, “Who the fuck is Nicki Clyne”?!
I tend to shy away from really simple and obvious assessments of people but in Nicki’s case, it is undeniable.
That woman is dummmmb. AF. Like, she is real, real stooopiid.
Yeah, especially since she has the audacity to think a nigger should be judging a white woman and has the right or the mental capacity to do that!
SHE MUST BE INSANE!
GOD THIS CUNT PISSES ME OFF! I WANT TO PUNCH HER IN THE FACE AND THROW HER CANADIAN-TAINTED ASS INTO HELL!
This is the mentally ill patient I have been referring to. She is actually a Black woman herself and filled with self loathing.
Only in your niggerized fantasies, I am! Stop using deliberately abusing gender pronouns and misidentifying their races on purpose! You’ve been warned numerous times already what will happen in court about this! Stop being mentally retarded and spewing senseless and mentally retarded nigger-jabber and post up all of my other comments on all the other articles that you haven’t posted up yet like you said that you would, you lying sack of sicilian shit!
It is more and more acceptable to change your gender. If you want to identify as male I urge you to do so. I also think if you do not wish to be Black, your birth race you can identify as being White.
I am curious what Nicki enjoys more: Raniere’s limp d*ck or Suneel’s shrimp d*ck. At first blush, the two seem equivalent. I believe it’s worthy of contemplation.
“…in other legal proceedings that could occur in the future.” – Nicole Clyne. Ummm, you mean like visa fraud? Possession of illegal photographs and blackmail material?
“…currently hold over $600,000 in debt for my medical education and legal fees to defend it.” – Dr. Danielle Roberts. First, you aren’t a doctor anymore nor do you play one on tv. Second, if $600,000 in debt is what Executive Success looks like, I think I’ll pass.
“I have no money to hire a lawyer.” Brandon Porter. I find it hard to believe women aren’t lining up to pay you to show them videos of violence, rape, and live beheadings, all the while performing illegal mind experiments on them. It sounds like a hoot and you are just not trying hard enough, sir.
Will you please loan me some money so I can visit you in California?
I am broke, too.
nickiclyne’s profile picture
My friend said I looked like Hank Moody today. I don’t see it.
Doctor Brandon Porter lives in Waukee, Iowa, a Western suburb of Des Moines.
Waukee is one of the wealthiest towns in Iowa and one of the fastest growing.
Presumably Porter’s father owns the home.
At some point Porter’s father will pass away and Brandon will inherit his portion of the father’s estate.
Brandon might be broke now but he will not be broke forever.
Waukee is a city in Dallas County, Iowa, United States. The population was 23,940 at the time of the 2020 U.S. Census. It is part of the Des Moines – West Des Moines Metropolitan Statistical Area.
In 2017, Apple Inc. chose Waukee as the location of a massive $1.38 billion data center campus.
Data centers for Silicon Valley are located al over Iowa because of low land and energy prices as well as high speed connections to the East and West Coasts.
Facebook and Instagram have several massive data farms near Des Moines.
Look up the price of the home. My town has three or four billionaires in it, and I’m not wealthy or even rich.
[…] Erasend wrote the following in response to Clyne, Dr. Roberts, and Dr. Porter File Letters With Court in Civil Case – Saying They’re Broke … […]
Why isn’t Suneel representing these poor, simple-minded people? After all, he’s not a lawyer but likes to play one on the Frank Report….
Suneel stayed here.
It would seem Sen K Gillibrand has been applying the brand of ethics learned at the feet of KR. She’s the one who gave Megan Markle the Private numbers of female senators without asking them for their permission first, in a clear breach of security.
Danielle: I deny any participation in any of the charges or contribution to any damage the plaintiffs are claiming they experienced.
Judge: You deny it? Okay then, case dismissed!
Danielle: Thank you, Your Honor! By the way, what’s your favority ‘brand’ of pens, if I may ask…?
In unrelated news, Sen. Kirsten Gillibrand is planning to invite Megan Markle to have dinner with all the women senators and advocate for paid leave. Political ambitions running rampant with these two under the guise of ‘helping and empowering women’. Plus ca change …
There’s no reason these fools need to all be broke-ass this many years after the implosion of the cult.
EVERY one is hiring.
Get a job. Make an honest living.
Seriously. Every place is hiring.
What happened to agency? Taking responsibility?
Again. Jobs. Jobs. Jobs available.
There might be jobs everywhere, but if you ran a company, would you hire any of these idiots?
Would you want to work alongside any of them? I’m in IT and do a lot of the same things as Ben Myers. But if he were working next to me, all I’d want to do is punch him in the face.
The stench of vanguard following you everywhere you go makes it impossible to get a decent job; even for those that have left and denounced him it’s gotta be tough. Plus if there are any decent-looking women in the workplace, Nicki will try to brand them. Danielle admits she lost a client because she tried that.
They can’t be trusted with any personally identifiable information, financial materials, social security info, bank deposit info, etc. That’s collateral against any woman, the risk is too great. So any management-level positions are totally out of the question.
Financially, they are fucking fucked.
‘The two lawyers’ who are well versed in pig-latin are eager to help gratis and for free. Their knowledge of the law is both deep and wide-ranging, as repeatedly demonstrated in these pages.
Ms Roberts says “I have filed a request for pro bono counsel with the federal court and am looking for other options to be able to resolve this issue.
There is no pro bono counsel going to be given to you by the federal courts in a civil matter lady.
You waited until the last-minute to file for an extension in a legal case!
No wonder you think DOS is good and Keith Raniere is great. Your not that bright.
How is it you finished medical school?
These people are just plain stupid. I will take Bronfman door #3,6& 8.
They are defendants in a civil lawsuit and must of been served documents. Now they are saying I know nothing about my case.
There is Google, Law library’s, books about civil lawsuit, research they could be doing.
There are so used to Raniere telling them what to do and Clare Bronfman paying for it, they forgot how to think for themselves.
Brandon Porter at least signs without the “dr.”. Danielle however, as usual in full denial mode, signs her letter with “dr” ignoring the fact that she has been stripped of this title.
She knows she lost her title. She is using Porter’s, which she took along with his collateral and his lunch money.
Brandon Porter: Only man in NXIVM who wishes he could join DOS.
All sane letters, well written. Credit were it is due.
LOL. Talk about damning with faint praise.
(When copying in, small deviations in formatting can and do occur. The content of the text is not affected and does not affect the
understanding of the text.)
Fried, Frank, Harris, Shriver & Jacobson LLP FRIED FRANK
One New York Plaza
New York, New York 10004
Direct Line: 202.639.7040
October 29, 2021
The Honorable Eric R. Komitee
United States District Court
Eastern District of New York
225 Cadman Plaza East
Brooklyn, NY 11201
Re: Edmondson, et al. v. Raniere, et al., 20-cv-00485-EK-CLP
Dear Judge Komitee:
We represent Ms. Sara Bronfman in the above-captioned action. We write in response to
the Court’s October 15, 2021 order directing the defendants to submit letters to the Court by
today’s date regarding proposed next steps in this action. (ECF 92). In accordance with the
Court’s instructions, as discussed on the record at the October 15, 2021 status conference, we
also address our proposed motion to dismiss the first amended complaint (the “FAC”) (ECF 64).
Put simply, Ms. Sara Bronfman does not belong in this lawsuit. Upon a fair reading of
the FAC it is difficult to discern what possible claim any of the 84 plaintiffs might have against
Ms. Sara Bronfman. No plaintiff alleges that he or she was subjected to any abuse or harm by
Ms. Sara Bronfman. Indeed, the FAC — which represents plaintiffs’ second bite at the apple —
does not allege any facts suggesting that Ms. Sara Bronfman participated in, or even knew about,
the unfortunate (and, in some cases, heart-wrenching) abusive conduct perpetrated by certain
individuals associated with NXIVM.
Plaintiffs’ inability to allege any actionable conduct on the part of Ms. Sara Bronfman is
hardly surprising. After all — despite conducting an exhaustive investigation regarding NXIVM
and obtaining six convictions — the United States Attorney’s Office for the Eastern District of
New York (the “Office”) did not prosecute or seek to indict Ms. Sara Bronfman. Indeed, to our
knowledge, Ms. Sara Bronfman was not even a subject of the Office’s investigation. That the
Office did not seek to prosecute Ms. Sara Bronfman is not mere happenstance. It reflects the fact
that the Office recognized what the individual plaintiffs and their attorneys surely know already:
that Ms. Sara Bronfman was not aware of, was not involved in, and bears no responsibility for,
the wrongdoing perpetrated by others associated with NXIVM.
The Honorable Eric Komitee October 29, 2021
Equally striking, in connection with the filing of their two complaints in this action,
counsel for plaintiffs have enjoyed unfettered access to each of their 84 clients and had the
opportunity to speak with, interview, and gather information from those 84 plaintiffs. Further,
we understand that plaintiffs’ counsel was in the unique position to attend the interviews the
Office conducted with a significant number of the plaintiffs. And yet — in the 21 months since
plaintiffs filed their initial complaint — plaintiffs remain incapable of lodging any factual
allegations in support of their claims against Ms. Sara Bronfman. Notably, after all of this access
and the material passage of time, the FAC still does not contain any allegations that Ms. Sara
Bronfman even knew about the existence of DOS (the enterprise through which much of the
alleged sexual and physical abuse occurred), much less that she participated in those illicit
activities. To the contrary, the FAC acknowledges, as it must, that only “First Line Masters”
knew about DOS, and makes clear that Ms. Sara Bronfman was not a member of that group. See
FAC ¶ 19. Likewise, the FAC makes clear that Ms. Sara Bronfman was not a member of the socalled “Inner Circle.” FAC ¶ 277 n. 9.
For all these reasons, and as briefly detailed below, we respectfully request an
opportunity to file a motion to dismiss the FAC (or any further amended complaint if the Court
permits plaintiffs to file a third complaint in this action) pursuant to Rules 8, 9(b) and 12(b)(6) of
the Federal Rules of Civil Procedure.
THE FAC FAILS TO COMPLY WITH THE REQUIREMENTS OF RULE 8
Federal Rule of Civil Procedure 8(a)(2) mandates that every civil complaint “must
contain … a short and plain statement of the claim showing that the pleader is entitled to relief.”
Here, 84 individual plaintiffs collectively filed the FAC, asserting that 12 individual defendants
(plus four corporate defendants) are liable for the harms allegedly inflicted upon plaintiffs by
Keith Raniere and others at NXIVM. What remains missing, however, is any attempt to comply
with Rule 8’s requirement that plaintiffs provide Ms. Sara Bronfman with a “short and plain
statement” claiming that any of the plaintiffs (much less 84 of them) are entitled to relief from
Ms. Sara Bronfman: What wrongs, if any, did Ms. Sara Bronfman visit upon any of these
plaintiffs? When, if at all, did that conduct occur? How, if at all, did Ms. Sara Bronfman harm
any of these plaintiffs? Why, if at all, should Ms. Sara Bronfman bear responsibility for the harm
other individuals may have inflicted upon any of these plaintiffs?
Notwithstanding its epic length — clocking in at 1,020-paragraphs spread across 217-
pages — the FAC conspicuously fails to answer any of the questions required by Rule 8. To the
contrary, the FAC uses its many pages to mask the absence of substantive allegations of
wrongdoing on the part of Ms. Sara Bronfman. Thus, the FAC often indiscriminately sweeps all
of the defendants together under the defective (and undefined) moniker “Defendants” and
repeatedly makes allegations that obviously do not pertain to Ms. Sara Bronfman. See Atuahene
v. City of Hartford, 10 F. App’x 33, 34 (2d Cir. 2001) (Summary order) (“By lumping all the
defendants together in each claim and providing no factual basis to distinguish their conduct,
[plaintiff’s] complaint failed to satisfy [Rule 8’s] minimum standard . . .”); Gillespie v. St. Regis
Residence Club, N.Y. Inc., 343 F. Supp. 3d 332, 352-53 (S.D.N.Y. 2018) (“[B]lanket assertions
as to all Defendants are not sufficient to state a claim.”). For example, the FAC claims that
“Defendants” committed negligence per se by “branding women’s pubic regions with Raniere’s
The Honorable Eric Komitee October 29, 2021
initials.” FAC ¶ 930. Yet, as plaintiffs are well aware, this allegation cannot possibly pertain to
Ms. Sara Bronfman inasmuch as a full read of the FAC makes clear that she was not involved in
(and was not aware of) this conduct, conduct alleged to have occurred only within DOS. See,
e.g., FAC ¶¶ 34, 816-824.
Likewise, the FAC makes allegations regarding supposed conduct by the “Bronfmans,”
as if two sisters are automatically deemed to have acted as one unit simply because they are
related, notwithstanding the fact that they are, of course, two distinct individuals. See, e.g., FAC
¶¶ 707, 708 (referring to alleged conduct by the “Bronfmans”); id. ¶¶ 705, 715 (referring to
purported non-profit funding provided by “the sisters” or “the Bronfman sisters”).
In addition to its impermissible group pleading of defendants, the FAC employs the same
stratagem with the plaintiffs. To take just one egregious example: In Count III, the FAC asserts
a putative cause of action for human trafficking under 18 U.S.C. § 1595. Incredibly, the FAC
purports to bring this cause of action “on behalf of all plaintiffs.” See generally FAC Count III
(B)-(D), ¶¶ 889-906. That makes no sense. As Your Honor observed at the status conference,
the amended complaint asserts claims on behalf of at least two distinct types of plaintiffs,
including (a) individuals who were allegedly subjected to sexual, physical or psychological
abuse by individuals associated with NXIVM, and (b) individuals who appear to claim that they
suffered damages in connection with their purchases of various NXIVM programs or materials.
Based on the FAC’s own descriptions of the 84 plaintiffs, it is unreasonable — or, more
accurately, frivolous — for plaintiffs to assert that each of the 84 plaintiffs was subjected to
trafficking, much less that each of the 84 plaintiffs somehow has a colorable trafficking claim
against Ms. Sara Bronfman.
Further illustrating the FAC’s multiple, fatal defects, we review the example of John Doe
21. The FAC’s only factual allegations regarding John Doe 21 are that he is allegedly a resident
of Canada who at some unspecified point in time “enrolled in and paid for NXIVM curriculum.”
FAC ¶ 542. This is the only information we are provided regarding John Doe 21. Yet, on these
limited facts, the FAC declares that, as a result of “Defendants’” conduct, “John Doe 21 was
emotionally and financially harmed.” Id. ¶ 545. It is obvious that, if John Doe 21 was the only
plaintiff in this action, his claims would be swiftly dismissed inasmuch as “enroll[ing] and
pa[ying] for NXIVM curriculum” does not provide a “short and plain statement” showing that he
is entitled to relief as against Ms. Sara Bronfman. Id. ¶ 542. Nothing in the law gives John Doe
21 a free pass simply because he is merely one of a larger group of 84 plaintiffs. Critically, John
Doe 21 is not an isolated example of a plaintiff who must be dismissed because we are given no
meaningful facts regarding the individual’s claims. There are over 50 plaintiffs in this action for
whom the FAC likewise provides the same limited information (or non-information). All of
these plaintiffs must be dismissed. See Franzone v. City of N.Y., 2015 WL 2139121, at *7
(E.D.N.Y. May 4, 2015) (dismissing complaint that failed to “explain[ ] the role, if any,” one of
the plaintiffs “played in relevant events.”).
In sum, for these reasons — which merely scratch the surface of the FAC’s failure to
comply with Rule 8 — the FAC must be dismissed as against Ms. Sara Bronfman.
The Honorable Eric Komitee October 29, 2021
THE FAC MUST BE DISMISSED UNDER RULE 12(B)(6)
The FAC names Ms. Sara Bronfman as a defendant in seven of its 16 counts. We seek
the Court’s leave to move to dismiss these seven counts against Ms. Sara Bronfman. We do so
The Statute of Limitations Bars Many of Plaintiffs’ Claims. As an initial matter, the
statutes of limitations on many of plaintiffs’ claims have long expired. For the majority of
plaintiffs, as noted above, the FAC disingenuously fails to provide any dates or time-periods
whatsoever — or even years or decades — as to when the conduct at issue occurred. Given that
the complained-of conduct at NXIVM occurred over a decades-long period, it is highly likely
that the applicable limitations periods for claims asserted by many of the 84 plaintiffs ran out
long ago. For this reason, too, in any amended pleading, plaintiffs should be required to state
when the relevant conduct occurred for each individual plaintiff. Dallas v. Vosburgh, 2019 WL
4573743, at *3 (W.D.N.Y. Sept. 20, 2019) (When the “[p]laintiff neither explains when the
claims accrued. . .nor provides a date as to when they accrued. . .[the] [p]laintiff has not carried
his burden. . . .”).
RICO Claims. In Counts I and II, the FAC purports to assert claims for RICO and RICO
conspiracy against all individual defendants on behalf of all 84 plaintiffs. FAC ¶¶ 859-878.
Plaintiffs fall far short of satisfying the high burden necessary to allege a RICO claim. See, e.g.,
Targum v. Citrin Cooperman & Co., 2013 WL 6087400, at *5 (S.D.N.Y. Nov. 19, 2013) (“A
plaintiff’s burden is high when pleading RICO allegations.”). The FAC fails to allege that Ms.
Sara Bronfman, through the commission of two or more predicate acts constituting a pattern of
racketeering activity, participated in a RICO enterprise. The FAC’s only allegation of conduct
by Ms. Sara Bronfman that could conceivably constitute a predicate act is the false allegation
that “[i]n the days leading up to the trial [of Keith Raniere], Defendant Sara Bronfman and her
husband, Basit Igtet, attempted to obstruct or interfere with the trial by employing false pretenses
and promises of money to entice a critical witness, [a witness by the name of] Adrian, to leave
the United States and remain outside of it during Raniere’s criminal trial. The witness refused to
comply with Sara Bronfman’s scheme.” FAC ¶¶ 855. Even putting aside the reality that this
allegation is false, and further putting aside that there is no private cause of action under US law
for attempted obstruction of justice, and further putting aside that the Government has — most
tellingly — not charged Ms. Sara Bronfman with this fanciful charge, it would still leave
plaintiffs with (at most) a single alleged predicate act. Two predicate acts are, of course,
required to state a claim for RICO. The FAC likewise fails to adequately allege the other
elements of a RICO violation. Plaintiffs’ claim for RICO conspiracy must similarly be
dismissed because the FAC fails to factually allege that Ms. Sara Bronfman “agreed with at least
one other entity to commit a substantive RICO offense.” Crawford v. Franklin Credit Mgmt.
Co., 758 F.3d 473, 487 (2d Cir. 2014).
Sex Trafficking. In Count III, the FAC purports to assert certain trafficking claims on
behalf of all plaintiffs under the Trafficking Victims Protection Reauthorization Act (the
“TVPRA”) against all defendants in respect of forced labor, human trafficking and peonage.
FAC ¶¶ 879-906. These highly defamatory claims fail as against Ms. Sara Bronfman for several
reasons. First, the TVPRA provides a private cause of action only to “a victim of a violation of”
The Honorable Eric Komitee October 29, 2021
the TVPRA. See 18 U.S.C. § 1595(a). As noted above, the FAC does not plausibly allege that
all 84 plaintiffs were trafficking victims. Second, the FAC does not adequately plead — either
with or without the heightened particularity mandated by Fed. R. Civ. P. 9(b) — each of the
elements necessary to state a claim under the TVPRA. In other words, the FAC does not plead
that Ms. Sara Bronfman knowingly (i) participated in a trafficking venture, (ii) benefited from
any (non-existent) participation in such a venture, or (iii) knew or should have known the venture
was engaged in a violation of the TVPRA. See 18 U.S.C. § 1595(a). To the contrary, the FAC is
devoid of any allegations suggesting that Ms. Sara Bronfman had any knowledge of or benefited
in any way from violations of the TVPRA.
Negligence Per Se. In Count IV, the FAC purports to assert a claim for negligence per se
on behalf of all plaintiffs. FAC ¶¶ 912-932. In this count, plaintiffs seek to hold all defendants
liable for negligence per se predicated on the alleged violation of N.Y. Education Law § 6512
(“Section 6512”), which makes it a felony to engage in the unauthorized practice of psychology,
psychoanalysis or mental health counseling, or to aid and abet another person in the foregoing.
This count — which never mentions Ms. Sara Bronfman by name — fails for several reasons.
First, to state a claim for negligence per se, a plaintiff must allege a “violation of a State statute
that imposes a specific duty.” Cretcher v. U.S. Bank N.A., 2021 WL 1062057, at *3 (E.D.N.Y.
Mar. 19, 2021). In turn, for a state statute to impose a duty of care, a private cause of action
must exist under that statute. Cretcher, 2021 WL 1062057, at *3-4. Here, because Section 6512
does not contain any express or implied private cause of action, the FAC fails to adequately
allege a claim for negligence per se against Ms. Sara Bronfman. Moreover, this count also fails
for the additional, independently-sufficient reason that the FAC does not factually allege that Ms.
Sara Bronfman (or any alleged violation on her part of Section 6512) proximately caused injury
to any of the 84 plaintiffs, let alone every one of the plaintiffs.
Gross Negligence. In Count X, the FAC purports to assert a claim for gross negligence
(and possibly recklessness) against five of the defendants (including Ms. Sara Bronfman) on
behalf of Jane Does 20-22. FAC ¶¶ 965-971. In particular, plaintiffs claim that Ms. Sara
Bronfman acted with gross negligence and recklessness by failing “to supervise [d]efendants
[Brandon] Porter and Nancy Salzman’s treatment of Jane Doe 20, Jane Doe 21 and Jane Doe
22.” FAC ¶ 969. This claim fails for multiple reasons. As an initial matter, absent a special
relationship, an individual has no duty to control or supervise the conduct of another person so as
to prevent such other person from harming others. Doe v. Uber Techs., Inc., 2021 WL 3193166,
at *10 (S.D.N.Y. July 28, 2021). Here, the FAC asserts that such a duty existed because Ms.
Sara Bronfman supposedly founded or funded Ethical Science Foundation, wherein defendants
Porter and Nancy Salzman allegedly performed the treatments at issue. FAC ¶ 966. Such
funding or sponsorship, even if it occurred, does not suffice to create the requisite duty.
Moreover, even if a special duty did exist (it did not), there are no factual allegations suggesting
that Ms. Sara Bronfman breached such a duty. See D’Amico v. Waste Mgmt. of N.Y., LLC, 2019
WL 1332575, at *8-9 (W.D.N.Y. March 25, 2019) (recklessness in the context of a gross
negligence claim requires “an extreme departure from the standards of ordinary care, such that
the danger was either known to the defendant or so obvious that the defendant must have been
aware of it.”) (citation and internal quotation marks omitted).
The Honorable Eric Komitee October 29, 2021
Aiding and Abetting. In Count IX, the FAC purports to assert a claim for aiding and
abetting with respect to unauthorized human research against various individual defendants
(including Ms. Sara Bronfman) on behalf of five individual plaintiffs. FAC ¶¶ 956-964. In this
count, plaintiffs seek to hold Ms. Sara Bronfman responsible for “aiding and abetting” defendant
Porter in his alleged conduct of unauthorized human research. FAC ¶¶ 962, 964. This claim
must be dismissed because the FAC does not allege any facts suggesting that Ms. Sara Bronfman
had any knowledge whatsoever of defendant Porter’s alleged misdeeds. See Glob. Enter. Grp.
Holding, S.A. v. Ottimo, 2010 WL 11629556, at *7 (E.D.N.Y. June 8, 2010) (dismissing aiding
and abetting claim for alleging only “in conclusory terms” that the defendant “had actual
knowledge”). This claim also fails for the independent reason that the FAC fails to plausibly
allege facts suggesting that Ms. Sara Bronfman provided substantial assistance to defendant
Porter in the commission of his alleged misdeeds. See Goldberg v. UBS AG, 660 F. Supp. 2d
410, 425-26 (E.D.N.Y. 2009) (dismissing aiding and abetting claim for failure to adequately
plead facts showing substantial assistance).
Abuse of Process. In Count V, the FAC purports to assert a claim for malicious abuse of
legal process against certain individual defendants (including Ms. Sara Bronfman) on behalf of
eight individual plaintiffs. FAC ¶¶ 933-939. The plaintiffs’ claims center on the commencement
of largely unidentified “meritless and frivolous civil actions” that lacked “probable cause” (FAC
¶ 934), as well as the alleged instigation of various criminal investigations (FAC ¶ 936). These
claims fail for several reasons. First, a claim for malicious abuse of process requires that a
defendant have employed legal process, but the only action plaintiffs attribute to Ms. Sara
Bronfman in connection with their claims is that she purportedly provided financial support to
the alleged legal actions. See Cargill Soluciones Empresariales, S.A. de C.V., SOFOM, E.N.R. v.
Desarrolladora Farallon S. de R.L. de C.V., 2017 N.Y. Misc. LEXIS 2967, at *25-26 (Sup. Ct.
N.Y. Cty. July 21, 2017) (denying leave to amend to add abuse of process claim because plaintiff
“cite[d] no authority for the proposition that one who provides litigation funding for a baseless
lawsuit may personally face liability, whether under a tortious interference, abuse of process, or
malicious prosecution cause of action.”). Even if plaintiffs had alleged that Ms. Sara Bronfman
had taken a more active role and filed lawsuits, the filing of lawsuits — even frivolous lawsuits
— cannot serve as the basis for an abuse of process claim. Manhattan Enter. Grp. v. Higgins,
816 F. App’x 512, 514 (2d Cir. 2020) (complaint was correctly dismissed “insofar as it was
predicated upon the filing of lawsuits” alleged to be “duplicative, frivolous, and malicious”).
* * *
In conclusion, Ms. Sara Bronfman should not have been named as a defendant in this
lawsuit. We thus respectfully request an opportunity to file a motion to dismiss the FAC. In the
event plaintiffs file a further amended complaint naming Ms. Sara Bronfman, we respectfully
request an opportunity to file a motion to dismiss that complaint as well.
/s/ James D. Wareham
James D. Wareham (pro hac vice)
CERTIFICATE OF SERVICE
I certify under penalty of perjury pursuant to 28 U.S.C. § 1746 that on October
29, 2021 I served upon parties of record, by ECF filing, and caused to be served upon Dr.
Brandon Porter and Dr. Danielle Roberts, by email at firstname.lastname@example.org and
Drdanielledo@gmail.com, respectively, a true copy of the attached letter.
Dated: Washington, DC
October 29, 2021
/s/ James D. Wareham
James D. Wareham
WILLKIE FARR & GALLAGHER LLP
Craig C. Martin 300 North LaSalle
Chicago, IL 60654-3406
Tel: 312 728 9000
Fax: 312 728 9199
November 4, 2021
Hon. Eric R. Komitee United States District Judge
Eastern District of New York 225 Cadman Plaza East Brooklyn, New York 11201 Courtroom: 6G North
Re: Edmondson, et al. v. Raniere et al., 1:20-CV-00485-EK-CLP
Dear Judge Komitee:
We represent Defendant Clare Bronfman (“Ms. C. Bronfman”) in the above-referenced matter and submit this letter in response to Plaintiffs’ request to issue a non-party subpoena to Suneel Chakravorty prior to a Rule 26(f) conference. Dkt. 100. Plaintiffs’ request should be denied.
Plaintiffs’ request has nothing to do with Ms. C. Bronfman, nor any claims against Ms. C. Bronfman. It seeks materials allegedly related to DOS—and Ms. C. Bronfman was not part of DOS. See October 29, 2021 C. Martin Letter, Dkt. 102. Nonetheless, Ms. C. Bronfman feels compelled to respond because at least for now, the FAC inappropriately lumps all Defendants’ conduct together and Ms. C. Bronfman is in this case as pled.
Plaintiffs’ request comes at an extraordinary time in the litigation—before any responsive pleadings and before a Rule 26(f) conference has even been scheduled. Plaintiffs claim that they need this expedited non-party discovery to somehow prevent a supposed possibility for dissemination of certain images, and the discovery may provide a basis for injunctive relief regarding the storage, safeguarding, and disposition of this material. Plaintiffs also claim that the material may be transferred or destroyed. Aside from the fact that this material has nothing to do with Ms. C. Bronfman, Plaintiffs fail to state how the material they seek is relevant to the civil litigation pending before this Court, or show good cause exists to set aside the presumption that “[a] party may not seek discovery from any source before the parties have conferred as required by Rule 26(f).” Fed. R. Civ. P. 26(d)(1). Moreover, Plaintiffs’ letter indicates that the materials it seeks have been in existence and known to Plaintiffs for years—without broad dissemination or destruction. It is unclear what has changed such that Plaintiffs require the Court’s intervention now.
Plaintiffs’ request is also devoid of legal or factual support and is largely based on rumor and speculation, consistent with the narrative Plaintiffs have perpetrated in the media. Plaintiffs claim they “have been informed” that Mr. Chakravorty possessed and shared certain images, but fail to specify in any way, shape or form, a factual basis to support their extraordinary assertion. The only authority Plaintiffs provide, in a footnote, is inapposite. See Dkt. 100, n.1 (citing Ayyash
v. Bank Al-Medina, 233 F.R.D. 325, 327 (S.D.N.Y. 2005)). In Ayyash, the plaintiff sought to issue
NEW YORK WASHINGTON HOUSTON PALO ALTO SAN FRANCISCO CHICAGO PARIS LONDON FRANKFURT BRUSSELS MILAN ROME
a third-party subpoena to several New York banks regarding the defendants’ assets. 233 F.R.D. at
327. The court held that the plaintiff presented “good cause” for seeking expedited discovery because “defendants are foreign individuals and corporations who have both incentive and capacity to hide their assets” and “there is considerable urgency to plaintiff’s need to seek information about the location of defendants’ possible assets.” Id. Unlike in Ayyash, Plaintiffs’ request here has nothing to do with the preservation of assets held by Defendants. Rather, Plaintiffs’ request goes to material not in the possession, custody or control of Ms. C. Bronfman— nor any other party in this litigation. Defendants here, several who are incarcerated, do not have similar capacity and incentive to hide the discovery sought. Nor have Plaintiffs provided a basis for their sense of urgency.
Under the law, uncited by Plaintiffs, to succeed on a request for expedited discovery, “the party seeking discovery must ‘prove that the requests are reasonable under the circumstances.’” Pietsch v. Marcantonio, 2016 WL 1069656, *4 (quoting N. Atl. Operating Co. v. Evergreen Distribs., LLC, 293 F.R.D. 363, 367 (E.D.N.Y. 2013)). A request can be unreasonable because of its breadth, its basis on mere speculation, or its unrelatedness to the case. See Raza v. City of New York, 998 F. Supp. 2d 70, 75 (E.D.N.Y. 2013) (“Plaintiffs have [not] shown sufficient cause to justify expedited discovery or that Plaintiffs’ proposed discovery schedule is reasonable, given the breadth of Plaintiffs’ document requests and the likelihood of disputes over assertions of privilege by Defendants.”). See also Levy v. Young Adult Inst., Inc., 2015 WL 170442, *11 (S.D.N.Y. Jan. 13, 2015); Litwin v. OceanFreight, Inc., 865 F. Supp. 2d 385, 402 (S.D.N.Y. 2011).
Plaintiffs’ request does not meet this reasonableness standard. Most importantly, Plaintiffs have not demonstrated the relevance or urgency of their request. Plaintiffs make no assertion that Mr. Chakravorty just received the materials in question or that there is any imminent risk of spoliation. The fact that Plaintiffs ask that the discovery be one-sided and restricted to Plaintiffs further adds to the unreasonableness of their request.
Because Plaintiffs’ request is neither urgent nor relevant to the civil litigation, there is no good cause to bypass the requirements of the Federal Rules of Civil Procedure and grant this extraordinary discovery measure. We request that the Court deny this request.
Cc: All Counsel by ECF Respectfully,
WILLKIE FARR & GALLAGHER LLP
/s/ Craig C. Martin
Craig C. Martin
October 29, 2021
Via Electronic Filing
Honorable Eric R. Komitee United States District Court
Eastern District of New York 225 Cadman Plaza East Courtroom: 6G North Brooklyn, New York 11201
Re: Edmondson, et al. v Raniere, et al.
Dear Judge Komitee:
We write on behalf of Plaintiffs in this action to request the Court’s authorization to issue a non-party subpoena prior to the parties’ Rule 26(f) conference and the Court’s adoption of a discovery plan, directed to an individual whom we believe to have potentially significant and sensitive evidence relevant to claims asserted by Plaintiffs.1 As we explained at the status conference, our concern with this individual is the high risk that if this evidence is not preserved, it may be transferred to others or destroyed. As directed by the Court, we set forth below additional information that supports this narrow request.
The individual is Suneel Chakravorty, a former NXIVM member and associate of Defendant Keith Raniere. Mr. Chakravorty has publicly claimed to be working on Raniere’s behalf in the criminal case, United States v. Raniere. Among other things, it has been reported that Mr. Chakravorty, who is not an attorney, 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 three of the racketeering predicates: two violations of 18 U.S.C. § 2251, exploitation of a child, and one violation of 18
1 Federal Rule of Civil Procedure 26(d)(1) permits a party to take discovery prior to the Rule 26(f) conference
“when authorized . . . by court order.” In deciding whether to authorize the requested discovery, the Court should consider the “reasonableness of the request in light of all the surrounding circumstances.” Ayash v. Bank Al- Medina, 233 F.R.D. 325, 327 (S.D.N.Y. 2005) (internal quotation marks and citation omitted).
U.S.C. § 2252, 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 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. 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.
Plaintiffs’ request with respect to Mr. Chakravorty concerns materials that are not within the scope of Judge Garaufis’s inquiry 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 (the use of collateral formed the basis for racketeering predicate ten, state law extortion). 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. This request for authorization to take narrowly tailored non-party discovery is not only reasonable in light of all the circumstances, but compelling.
 The jury found that Raniere committed all fourteen charged racketeering predicates.
 Until the Court decides whether some Plaintiffs will be able to proceed using first names or pseudonyms, which Plaintiffs hope to resolve in a meet and confer with Defendants, Plaintiffs are endeavoring to follow the protocol for identifying victims established by Judge Garaufis in the criminal proceeding. Because she has been identified by her first name in the public record, Camila is identified in the same manner in this action.
 According to the government, these images were 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.
Specifically, Plaintiffs request leave of the Court to issue to and serve upon Mr.
Chakravorty a non-party subpoena demanding the following: (1) copies of all 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; and (5) a sworn affidavit identifying (i) each and every person who he has shown, transferred or transmitted any copy of any such image, specifying the means by which he showed, transferred or transmitted such image to such person,
(ii) each and every person who has shown, transferred or transmitted to him any copy of any such image, specifying the means by which such person showed, transferred or transmitted such image to him, and (iii) each and every person who he knows or has reason to believe has any such images in their possession, custody or control, specifying the location of such images and the media on which such images are stored. We further request that access to this discovery be restricted to Plaintiffs and Mr. Chakravorty until such time as the Court issues an appropriate protective order governing the handling of confidential and highly confidential information.
Neil L. Glazer
cc: All counsel via ECF
The prerequisite, however, is title to damages arising from a court judgment.
Claims arising from criminal acts are never subject to the statute of limitations. Even after private insolvency, all claims such as damages, compensation for pain and suffering, loss of income and all pecuniary losses are recoverable and enforceable without time limitation.
Civil cases have SOLs.
My hunch in this case is the SOLs will be covered under the concept of Tolling.
Damn you, boy! I’ve made numerous comments on other articles that you haven’t posted yet! This is why you shouldn’t be filtering people’s freedom of speech! You’re a virtual guido mobster monster, ya fuck!
I hope somebody sues the shit out of you over this bullshit! This is worse than all social media combined! You claim that you want “free speech”, but you won’t even practice what you preach when you have the opportunity to be the example of that on your own goddamn website! And you’re too big of a pussy to take any responsibility on it!
I wish I could beat the living shit out of you! Someone needs to stick their foot up your ass and sue the living shit out of you, you goddamn piece of mother-fucking shit! This is one of ten billion different reasons why we shouldn’t be having other races in our country! Go back to Italy if you want to play the pope on our 1st Amendment rights, you stupid US Constitution heretical frutti di mare nigger! There used to be a wonderful time in history when a nigger of any kind who did the shit that you’re doing right now to the true U.S. citizens, were hanged! We need to bring that back into our justice system! We’ve got a nigger for the rope right here begging for it!
Dear readers, Please excuse the rantings of this poor sick young lady. She is one of my patients. She got off her medication and her mother told me that the only way she will get back on them is if I post her comments.
Well then you by your own Asperger’s Syndrome fantasies of my gender and what my fictional mother “told you” about my kike-meds, ya better get to posting, ya dumbass wannabe patriot frutti di mare nigger!
I understand… Is your mother home right now. Tell her to call me.
My mother has never and will never speak to you! I already talked to your mom, though she says that you’re Alzheimer’s and are constantly confused about reality! You should really get help for that! Allow me to help remind you about what you’re actually supposed to be doing right now instead of pretending to be a “doctor”: be a good lamb and post my comments on the other threads and stop running around your house naked and shitting every where! After that, you can take your nap, ok champ?!
You obviously don’t “understand” seeing the fact that my comments on the other articles still haven’t been posted yet! Get the alfredo and marinara sauce out of your ears and brain and get to posting! You’re long overdue!
If not, I’m afraid I’m going to have to start getting the lawsuits prepared! Please don’t make a true and rightful citizen and patriot of this country wait any longer! 🤨
I thought she had been working with Dr. Hannibal Lecter, but her therapy was going nowhere…
Well obviously you’re statistically and anthropologically confused about which race would more prone to idolizing and taking psychological advice from a cannibal!
Perhaps you should pick up a book, other than what Karl Marx published, to help enlighten you when you’re done being asleep to reality! Your moniker serves to highlight your issues very well!
Calm down, Karen.
Your patient should take her medicine. She likes the “N” word when she’s not medicated and needs more one on one time with her doctor. I’d like to apply to be your assistant in her future mental health treatment.
I can arrange that. Have you had any experience in fitting a straight jacket. It is better than forcing a bottle of meds down her throat when she acts up.
You “arrange that”, Ginzo and I will “arrange” having you both in handcuffs with an American flag as well as a Confederate Flag, shoved up both of your sorry Marxist asses!
✊🏻IF WE BELIEVE! ✊🏻
You just try to help a this guido fraudulently apply “mental health treatment” to me and see if you slap the cunt out of you along with slapping you with a joint lawsuit with all your criminal charges!
Go ahead and make my day, you marxist bitch!
Anne — don’t worry about her violent temper. I’ll have her mother slip some Somenix into her formula. She is really a nice woman but after reading this blog she developed an acute epileptoid manifestation of the panphobic melancholiac. This combined with an unfulfilled desire to be an infant male baby and at times thinking she is a praying mantis has left her with a schizoaffective disorder.
It is incurable but manageable.
I guess they ‘haven’t been working the tools’…
So much for “There are no ultimate victims.”
Nicki likes older guys, maybe there lies a profitable career in that…
I was broke when NXIVM filed their fake lawsuit against me. If I hadn’t shown up to court and fought for myself, the Judge would have ruled in their favor.
If the judge awarded any damages to them, I would have been responsible for and would have had to pay them out of further earnings.
The law doesn’t care if you’re broke.
Yes, that’s because Jews are controlling it! But the law doesn’t need to “not care if you’re broke”, they need to care if you’re BLACK! That one of the biggest problems here in this country!
✊🏻IF WE BELIEVE!✊🏻
✊🏻THERE’S A BETTER WAY!✊🏻
But you are Black – at least your father is Black – don’t you like this country?
I AM NOT HALF BLACK, MY FATHER IS NOT BLACK, AND MY MOTHER, IS NOT JEWISH! I AM NOT A FEMALE! I AM WHITE SOUTHERNER WHO’S ANCESTORS GO ALL THE WAY BACK TO THE FIRST COLONIES OF THIS COUNTRY!
Don’t ask me if I “like this country” like you have any right to ask that you uppity little piece of fucking shit! Your paper “American” nigger ass doesn’t even have a right to be here! And you constantly keep disrespecting a true and rightful patriot of this country to make it even worse! Perhaps I need to send some of my patriots to Jew York to stick a foot up your guido ass! Let’s see how uppity you are then!
Now that’s a better way!
Note: Below is about this specific trio. Not the Bronfman sisters and others as I know many will just go “but the sisters are rich and so and so has money hidden.” I am theorizing in the realm of what is known which is these three are broke. Your theories on their hidden wealth are not relevant unless can be proven in court.
So what are the court’s options here? This isn’t like criminal, there is no equivalent of a public defender, nor do I think the court can force some lawyer to take it pro bono.
My best guess is this would be treated like any case where the other side doesn’t put up a defense and a summary judgement would be issued. This would be issued by the judge, not a jury, but often whatever they issue is based on what the other side is demanding (but they do have latitude to reduce the amount). He could try to keep them lumped in with the others but that is likely untenable. Besides the financial differences, the Bronfman lawyers likely would rather not have three new bosses that are not paying them, and probably loads of conflicts of interest involved to boot.
This is an interesting gamble the three are making. A smart one too. There really is no point in trying to fight this for them. They gain nothing but soul crushing debt no matter how it goes. Getting through a jury trial is super expensive, especially one that will be incredibly complex like this one. The costs per person probably would be at least a $250,000 each and that is lowballing it (~$500 to $1 million might be closer). Juries are fickle beasts and when they decide someone should pay, they tend to go into overkill mode mostly because juries are human and humans are greedy and they go “if I was them I would want enough money to never have to work again” and so award accordingly.
So in effect they are deciding not to fight and let the chips fall how they may. Assuming summary judgement, depending on what the judge decides, it could make or break their financial future. Weirdly, the higher the amount “rewarded” the better off it will be for them. Generally the courts do not force people to sell everything they own just because lost a lawsuit, but they are expected to work on restitution in some form, usually a payment plan against their paychecks (think of it as a paycheck tax for the rest of their lives if the amount is high enough).
But scale makes a difference. World of difference between being forced to pay back say $100,000 and $100,000,000 or more. $100k is achievable restitution debt to pay back (and cheaper then a lawyer). $100 million is so high that its pretty much assumed that it will be unrecoverable. Also so high that even if plaintiffs try to force repayment, if I was those three I wouldn’t even bother to get a job as why labor to achieve an unachievable goal. Easier to find under the table jobs and just let them piss money away on lawyers demanding money that doesn’t exist.
Scale will also impact those with money (referring to the Bronfman sisters and others). Winning big as a rather considerable side effect of making it worth while to appeal and delay for as long as the courts allow (which can be measured in many years) as paying the lawyers to kick the can is cheaper then paying say a $100 million judgement. There is an excellent chance that the plaintiffs could win a jury trial and win so big that any payment could literally be a decade away. By then the Bronfman investments would likely have accumulated enough money to effortlessly payoff the amount without ever actually hurting them . Being serious on that. They could set aside a $25 million “what if we lose” fund, start investing it now and in 10 years or whatever when appeals are exhausted, hit up that fund to do restitution and probably still have plenty left. Net effect would be no loss of money. Always remember, the rules are different for the rich, its why poor people working so hard politically to protect them always confuses the $#@$ out of me.
I point all this out because behind the scenes, there is a poker game going on. The goal is the maximize payout while minimizing losses by both sides. A “win” doesn’t mean a thing if can’t recover the money and a loss doesn’t mean a thing either if can delay things indefinitely. Its why ultimately I think this will be settled out of court. The costs of trial is simply too high for all sides both emotionally and financially. By emotionally, I refer to the plaintiffs. If I was the Bronfman lawyers my primary “defense” would be a highly aggressive offense, relentlessly attacking the credibility and character of every single plaintiff by simply forcing them to admit on the stand over and over and over how they participated in the same behavior they are now suing over while tossing in the many factoids that Raniere et all. had to have learned via collateral. Shoot some of issued books that will help with this. It would also have the impact of destroying the Bronfman’s character and credibility too but they really don’t have that anymore anyway and besides being rich (the rules are different…) means they can get all that restored with a paycheck to a college and a few PR articles.
My take is if this goes to trial, the plaintiffs will lose even if they win. As for the trio, (depending on what the judge does) may have accidently stumbled on to the best move – “A strange game. The only winning move is not to play.”
That’s _former_ doctors Brandon Porter and Danielle Roberts.
Knowing they all can’t afford counsel puts a smile on my face. What a nice end to the day.
Viva Executive Success Program!!
We take your money and make sure
you never make more hahahaha!
The destruction to lives brought on by involvement in this cult is truly staggering. Two doctors and an actress represented here, plus others.
Chapter7 doesn’t discharge willful and fraudulent acts.
If I am not mistaken, fraud would be a criminal matter. This case is civil. Perhaps KRC can help us here.
There’s civil fraud and civil acts, intentional acts, like a punch in the nose, that are non dischargeable.
But I don’t know if the players were put on adequate notice, etc.