Clare Bronfman Calls Glazer Lawsuit a ‘Sprawling Mass of Allegations’

Clare Bronfman with Keith Raniere

Clare Bronfman’s lawyers have filed an extensive motion to dismiss the civil lawsuit, Edmondson et al vs. Keith Raniere, et al.

Craig Martin of Willkie Farr & Gallagher, LLP is one of a battery of lawyers who represent Clare Bronfman in the civil suit

Her attorneys are Craig C. Martin, Sara T. Horton and Jeffrey B. Korn of Willkie Farr and Gallagher and Ronald S. Sullivan, Jr., who represented Clare during her disastrous sentencing hearing, where she got triple the sentencing guidelines, largely because of her sentencing memorandum wherein she expressed to Judge Nicholas Garaufis that she remained steadfast and loyal to Keith Raniere.

The allegations in the civil lawsuit are contained in the First Amended Complaint – which is 217 pages, with 1,020 numbered paragraphs.

Bronfman and 10 other individual defendants [plus four entities] are accused of:

(1) RICO

(2) RICO Conspiracy

(3) Sex Trafficking

(4) Assault

(5) Forced Labor

(6) Human Trafficking

(7) Peonage

(8) Unlawful Conduct

(9) Unauthorized Practice of Counseling

(10) Aiding & Abetting, Conspiracy

(11) Malicious Abuse of Legal Process

(12) Battery

(13) Negligence Per Se

(14) Gross Negligence & Recklessness

(15) Battery

(16) Intentional Infliction of Emotional Distress

(17) Negligence


Changing Number of Plaintiffs

During the lawsuit, there have been a changing number of anonymous plaintiffs who seek Bronfman money for injuries they allege they incurred by being part of NXIVM and/or DOS.

Seventy-nine anonymous plaintiffs signed onto the original complaint. When the First Amended Complaint (FAC) was filed a year later, it listed 70 anonymous plaintiffs.

As it stands on the FAC, there appear to be 58 Jane and John Doe plaintiffs, eight first-name-only plaintiffs, and 10 fully-named plaintiffs for a total of 76.

However, it may be less than that now.

Since the FAC was filed, at least 10 plaintiffs have dropped out.

They are: Ana Cecelia, Jane Does 51, 13, 23, 26, 33, 55, and John Does 2, 16 and 17.

In the FAC itself, the allegations are varied.

Plaintiffs bring individualized allegations.

Plaintiffs allege in identical language that they enrolled in and paid for NXIVM curriculum and performed unspecified, uncompensated labor.

Nine Plaintiffs allege in identical language that they enrolled in and paid for NXIVM curriculum.

One Plaintiff makes no allegations at all.


Judge Eric Komitee thinks there might be two lawsuits, not one.

The presiding judge, Eric Komitee noted at the October 15, 2021 status hearing that there may be two different lawsuits: a sexual assault case [DOS] and a consumer-fraud case [NXIVM].

Bronfman’s lawyers point out, “many Plaintiffs engaged in the same conduct which they now allege caused them harm. The crucial fact that distinguishes most Plaintiffs from Defendants is a purported change of heart and, most obviously, a desire to seek monetary gain from [the Bronfmans].”

Her attorneys further argue that “Clare Bronfman had little to nothing to do with most of the accusations.”

Her attorneys write, “Plaintiffs do not plead any sexual relationships or sexual conduct related to the women … Clare Bronfman allegedly assisted in recruiting to be sexual partners for Raniere.”

In fact, “the FAC is bereft of allegations tying Clare Bronfman to the bulk of the alleged events in question. Plaintiffs, nonetheless, levy a multitude of claims against her, lumping her in with ‘all Defendants’ for certain claims…”

Philadelphia Detention Center

Clare Bronfman presently is serving an 81-month sentence at the Philadelphia Detention Center.

Ironically, this is the city of residence of the plaintiffs’ lead attorney, Neil Glazer.

Nicki Clyne and Clare Bronfman

Meanwhile, Sara is reportedly in Portugal, living with her husband, Basit Igtet, and their two children, along with a retinue of servants.

Clare’s lawyers were quick to point out that NXIVM was a positive force in the world.

“NXIVM was a 20-year-old company with more than 17,000 past students from 33 countries, which sought to inspire joy in people’s lives independent of religion or politics….  NXIVM’s goal was to help people live more ethical lives and create a more humanitarian society.

“All of that is ignored in service of Plaintiffs’ goal of converting their own participation and leadership in NXIVM into a claim for money damages.”

Her lawyers continue, “It is difficult to imagine how Clare Bronfman—or the other Individual Defendants— could mount a coherent defense to the sprawling allegations here, which also include inflammatory statements irrelevant to the allegations against Defendants generally… and against Clare Bronfman specifically…”

The FAC includes Clare Bronfman as a Defendant in 9 of the 15 counts.

Her attorneys argue, “The FAC, however, fails to substantiate Clare Bronfman’s involvement in the alleged misconduct with specific factual allegations. For example, 35 Plaintiffs allege identical boilerplate claims based on enrollment in NXIVM or uncompensated labor ‘for the benefit of the Defendants,’ with no mention of Clare Bronfman.

“…  Plaintiffs also devote more than 60 paragraphs of the FAC to detailing the history and inner workings of the highly secret organization DOS. … While Plaintiffs attempt to rope Clare Bronfman into their sex-based claims in Counts I, II, and III, they do not allege that Clare Bronfman was a part of DOS or even knew about its existence before it became public, nor do Plaintiffs allege that Clare was involved in or aware of any sexual activities related to Camila, Daniela, or any other Plaintiff.

“… In sum, the FAC’s massive length and persistent vagueness as to Clare Bronfman—coupled with its repeated reliance on group pleading—leave it far short of the minimum pleading standard…

“Although Plaintiffs baldly assert that One Asian, TEN C, and exo/eso were intended to be used to ‘recruit and groom suitable female candidates for sexual servitude to Raniere,’… Plaintiffs do not allege that any sexual relationships, acts, abuse or servitude occurred in the context of these entities or its recruits….

“The FAC therefore should be dismissed with prejudice as to Clare Bronfman in its entirety.

“35 Plaintiffs do not mention anything about Clare Bronfman or offer anything more than generic assertions of harm unconnected to Clare Bronfman. An additional 13 Plaintiffs make individualized allegations (such as to DOS or RCG) but never mention Clare Bronfman….

“Accordingly, none of these 58 Plaintiffs’ alleged injuries was proximately caused by Clare Bronfman.

“With respect to the former, Plaintiffs have not pleaded any facts that Clare Bronfman was even aware of any coercive sexual conduct. As such, the FAC fails to allege that Clare Bronfman participated in any purported coercive sex enterprise, and a RICO claim operating under this theory fails as to her. Nor have Plaintiffs adequately pleaded an enterprise based on consumer-fraud claims because the FAC does not allege that Defendants shared a common goal of defrauding Plaintiffs through a particular course of conduct….

“Plaintiffs do not state any times or dates when the allegedly fraudulent statements were made…. Plaintiffs do not specify any allegedly fraudulent statements, stating only that emails, text messages, and court papers contained ‘false and misleading statements.’…

“Nor do Plaintiffs ‘provide some minimal factual basis for conclusory allegations of scienter that give rise to a strong inference of fraudulent intent’ as to Clare Bronfman.

“Plaintiffs must ‘either (1) alleg[e] a motive for committing fraud and a clear opportunity for doing so’ (although allegations that a defendant was motivated by economic gain are insufficient) ‘or (2) identify[] circumstances indicating conscious behavior by the defendant.’

She Stands By Her Man

Keith Raniere and Clare Bronfman

The motion to dismiss continues, “Plaintiffs have not provided a factual basis for conclusory allegations that Clare Bronfman acted with any fraudulent intent. In fact, as Plaintiffs note, Clare Bronfman continues to stand by Raniere…. Clare Bronfman’s sincere belief in NXIVM illustrates that she did not and could not have had any fraudulent intent. Further, Plaintiffs’ allegations that Clare Bronfman donated millions to NXIVM and NXIVM-related entities, further belies any suggestion of an intent to defraud.

“Moreover, Plaintiffs do not ‘identify any statements made by [Clare Bronfman] that were fraudulent, much less the dates and the times those statements were made or the identities of the recipients.’”

And it concludes: “CONCLUSION For the foregoing reasons, Plaintiffs’ First Amended Complaint should be dismissed as to Clare Bronfman pursuant to Rules 8, 9(b), 12(b)(1), and 12(b)(6).”


Perhaps the most interesting parts of the motion are the charts.

They are:

Bronfman MTD Ex. A

Bronfman MTD Ex. B

Bronfman MTD Ex. C

Bronfman MTD Ex. D

I would guess this motion cost a minimum of $150,000.

Let us see how well it fares.

About the author

Frank Parlato


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  • I don’t think the civil case is ONLY about the money.

    It’s also about holding these grotesque tormentors accountable. And bringing their abuses to light.

    This is going to be damning testimony about the twisted cruelty of Keith Raniere, Clare, Nancy and Lauren, DOS, Nxivm, ESP. And All of the other defendants.

    Win or lose. It’s going to go VERY badly for the defendants.

    They know what they did. And to whom.

    The defendants know their offenses better than anyone. Just a fraction of the horrific abuse in this cult has yet been revealed.

    The damage and dirt that come out from this lawsuit will be written about for years.

    Two things reportedly help trauma survivors: Healing touch. And telling their story.

    Not every person that the cult hurt so badly was a part of the criminal trial. This is their chance.

    Treat people like maybe they are going to testify about you in court one day.

    Because they just might.

    Especially if you are a part of a high control cult and actively facilitating abuse and supplying victims for its squat, smelly, sexual predator leader.

    There is still a chance for a last minute out of court settlement offer to get made. But it’s a slim chance, because you’d have to be smart to go that route.

    And they aren’t.

    Remember all the cult dead-enders who claimed Cami did not testify to the child porn, child rape and other cruelty of cult leader, Keith Raniere? And they used that to excuse themselves from believing Cami? Well, now Cami can be heard in a court setting.

    As can so many others.

    Again. Win a settlement or not – the defense will lose. Big time. By what’s about to be revealed.

    And that’s why they are FREAKING OUT.

  • to make this a viable case. Clare Bronfman’s attorneys actually did a great job in their motion to dismiss and my money says they’ll be successful. Agree with Frank that the exhibits are the most powerful yet simplistic way of demonstrating their position.

  • I suspect that the lawsuit is a “sprawling mass of allegations.” That is due to the sprawling mass of offenses. And yes, it is a cash grab. The lawyers involved would not waste their time if there was no money to be gained. Clare should have thought about that before she funded NXVIM. She painted the target on herself.

    • It’s restitution in a manner in which it can punish as well as seek justice for the wrongs committed by these two moronic wealthy, financial backers of the cult, who threatened with and also executed litigation as a weapon to drive the enemies of their d-bag leader — many of whom didn’t have the same wealth as power mechanism — either into financial hardship and/or bankruptcy. These NXIVM deadenders are utter dummies if they can’t see the obvious. What goes around comes around.

      • I think restitution is a separate legal term. This is a civil case, so a judgement against her does not make her guilty of a crime. The burden of proof is much lower in a civil case, so “probably” is good enough. And yes, this means that she can pay for harassing people without being convicted of harassments.

        I fully expect her wallet to shrink, and she did bring this on herself.

        I also expect Clare to file lawsuits against her codefendants in the future, if they have acquire any money.

        Perhaps KR Claviger will comment on this.

  • To all the those “make justice blind” types who call suing a wealthy person a “cash grab”…

    Is it your stance that wealthy people should be exempt from all civil lawsuits in America?

    Should we create (even more) a separate legal class for the wealthy?

    One in which the wealthy can act however they please with impunity?

    Because any lawsuit against them is just a “cash grab” to sue the wealthy?

    Should only poor people be subject to civil lawsuits?

    Or just the middle class?

    Both? But not the wealthy class?

    In your very unbalanced (and not blind) legal system, what about civil lawsuits brought BY the wealthy? Are those allowed?

    Do you want to live in a country where the very wealthy cannot be sued in the same manner as any other US citizen?

    Because if so — that is not America that you are describing.

About the Author

Frank Parlato is an investigative journalist.

His work has been cited in hundreds of news outlets, like The New York Times, The Daily Mail, VICE News, CBS News, Fox News, New York Post, New York Daily News, Oxygen, Rolling Stone, People Magazine, The Sun, The Times of London, CBS Inside Edition, among many others in all five continents.

His work to expose and take down NXIVM is featured in books like “Captive” by Catherine Oxenberg, “Scarred” by Sarah Edmonson, “The Program” by Toni Natalie, and “NXIVM. La Secta Que Sedujo al Poder en México” by Juan Alberto Vasquez.

Parlato has been prominently featured on HBO’s docuseries “The Vow” and was the lead investigator and coordinating producer for Investigation Discovery’s “The Lost Women of NXIVM.” Parlato was also credited in the Starz docuseries "Seduced" for saving 'slave' women from being branded and escaping the sex-slave cult known as DOS.

Additionally, Parlato’s coverage of the group OneTaste, starting in 2018, helped spark an FBI investigation, which led to indictments of two of its leaders in 2023.

Parlato appeared on the Nancy Grace Show, Beyond the Headlines with Gretchen Carlson, Dr. Oz, American Greed, Dateline NBC, and NBC Nightly News with Lester Holt, where Parlato conducted the first-ever interview with Keith Raniere after his arrest. This was ironic, as many credit Parlato as one of the primary architects of his arrest and the cratering of the cult he founded.

Parlato is a consulting producer and appears in TNT's The Heiress and the Sex Cult, which premiered on May 22, 2022. Most recently, he consulted and appeared on Tubi's "Branded and Brainwashed: Inside NXIVM," which aired January, 2023.

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