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