In the government response to Keith Raniere and Clare Bronfman’s appeals, before they got down to a tit for tat response to the various appeal issues, they took a few dozen pages to describe, in their own inimitable way, their view of Raniere and NXIVM.
Here is an slightly excerpted version with a few comments of my own in [brackets and bold]:
By Assistant US Attorneys Kevin Trowel and Tanya Hajjar
For over a decade, Raniere led a criminal enterprise (“the Enterprise”) that was comprised of and relied on an “inner circle” of adherents that included, at various times, defendants Clare Bronfman, Nancy Salzman, Lauren Salzman, Allison Mack and Kathy Russell, among others.
Members of Raniere’s “inner circle” were accorded “special positions of trust and privilege” with respect to Raniere and held high-ranking positions in one or more Raniere-founded organizations, including Nxivm and a “secret society” called “Dominus Obsequious Sororium” or “DOS.”
The primary purpose of the Enterprise was to promote Raniere and to recruit individuals into various purported self-help organizations that Raniere founded, including Nxivm and affiliated programs, and DOS.
During the relevant period, Raniere and his co-conspirators committed a wide range of criminal activity, including sex trafficking, forced labor, alien smuggling, wire fraud and obstruction of justice in connection with the Enterprise.
In the early 2000s, for example, Raniere and his co-conspirators trafficked a Nxivm adherent, “Daniela,” for labor and services and confined her to a room for nearly two years [from 2010-2012].
Raniere also sexually exploited Daniela’s sister, “Camila,” who was then a 15-year-old child, and took photographs of his
abuse constituting child pornography.
In 2015, Raniere created and led DOS, a secret organization in which women — referred to as “slaves” — were recruited to take “vows of obedience” to higher-ranking women, including members of Raniere’s inner circle, who were themselves “slaves” to Raniere.
DOS “slaves” were required to take nude photographs, perform labor, and in some cases, engage in sex acts with Raniere.
Raniere demanded absolute commitment from those he recruited and those within his inner circle, including as to his teachings and ideology.
Raniere and his co-conspirators maintained control over the Enterprise by, among other means, obtaining sensitive information about members and associates of the Enterprise; recruiting and grooming sexual partners for Raniere and obtaining nude photographs of women for Raniere; inducing shame and guilt in order to influence and control members and associates of the Enterprise; isolating associates and others from friends and family and making them dependent on the Enterprise for their financial wellbeing and legal status within the United States; and encouraging associates and others to take expensive Nxivm courses, and to incur debt to do so.
Members of the Enterprise recruited and groomed sexual partners for Raniere, both within and outside of DOS, and many
were themselves in sexual relationships with Raniere that involved pledges of loyalty, penances for “ethical breaches,” and the provision of collateral.