Glazer Files for Protective Order to Prevent Release of Raniere Victims’ Names

Neil Glazer, plaintiffs' attorney

In what is shaping up as a classic First Amendment versus Victims’ Rights battle, and the stakes are getting higher.

Attorney Neil Glazer, who represents a number of plaintiffs, most of them anonymous, in the civil lawsuit, Edmondson, et al versus Raniere, et al. has filed for a protective order to prevent Michele Hatchette from publishing names of the anonymous plaintiffs.

In a serious revelation, Gazer admits that among those in the case who have thus far chosen to be anonymous and are using Jane Doe, the number has been reduced from more than 50 to now a mere dozen.

Glazer noted, “As the Court is aware from Plaintiffs December 17, 2021 ex parte submission (No. 133), there are only twelve Plaintiffs remaining who continue to seek the relief requested in Plaintiffs’ motion for the Protective Order. Of the other Plaintiffs who sought that relief, ten have terminated their claims and withdrawn from the litigation, and fifty-nine Plaintiffs informed the Court of their willingness to proceed using their full identities.”

Initially Glazer represented some 81 plaintiffs. Now, if there are only 12 who wish to be anonymous and 59 who want to proceed with their names revealed publicly, his pool of plaintiffs are 71 plaintiffs.  That is more than enough to bring suit against the NXIVM defendants and in particular the deep-pocketed Clare and Sara Bronfman.

Here is Glazer’s motion:

Neil Glazer

Here is Glazer’s argument [my comments in bold and in brackets.]

We write on behalf of Plaintiffs in this action to alert the Court that one or more Defendants are threatening to publicly identify the twelve remaining “Jane Doe” Plaintiffs [again this is a surprise. There was at one time 50 Jane Does] while
their motion to proceed by pseudonym or first name is still pending.

[Glazer has made an earlier motion to have the names of the plaintiffs who wish anonymity to be protected by the court, much like the victims were in the criminal case against Keith Raniere.]

This conduct is inimical to the orderly administration of this action and the well-being of the Plaintiffs being targeted.

Therefore, Plaintiffs respectfully request the Court to promptly issue Plaintiffs’ requested Protective Order, prohibiting direct or indirect disclosure by any Defendant of the identities of the small number of Plaintiffs who continue to request that protection, [in addition to the 12 Jane Does, there are Souki, Nicole, Daniela, and Camila, who are using only their first names and an unknown number of John Does, who also seek anonymity] and to further address this matter with the particular Defendants involved in this highly improper conduct.

Eight DOS women operate the website DOSsierproject.com. Two of them, Nicki Clyne and Danielle Roberts are defendants in the Glazer lawsuit.

Specifically, on February 2, 2022, a group calling itself The DOSsier Project, which is led by Defendants Nicki Clyne and Danielle Roberts, published a statement on its website attributed to co-member Michelle [sic. it is Michele] Hachette threatening to publicly disclose the full identities of all Plaintiffs seeking pseudonymity. The statement links to a video on the group’s Instagram feed in which Ms. Hachette reiterates and reframes their threat as a demand that she will reveal
these Plaintiffs’ identities if they do not publicly identify themselves first.

Defendant Nicole Clyne then posted links to both statements on her Twitter feed to her thousands of followers, along with comments that make abundantly clear her active participation in this scheme.

Defendant Roberts has also posted links to the threats to support the effort. This extortionate demand is blatant retaliation, an attempt to harass, intimidate and further traumatize the Plaintiffs seeking the protective order, as well as a brazen demonstration by a party to these proceedings of her utter contempt for the rule of law and the judicial process.

L-r Nicki Clyne, Allison Mack, Michele Hatchette, Samantha LeBaron and Danielle Roberts of DOS.

Defendants Nicole Clyne, Danielle Roberts and their fellow members of The DOSsier Project are all members of DOS engaged in a public relations campaign to portray Defendant Keith Raniere and his co-conspirators as victims of government persecution and a corrupt judicial system, themselves as victims of persecution by individuals who they claim were never harmed, justify what was done to women in DOS (including Plaintiffs in this action), and to criticize and attack the reputations and credibility of the former DOS members who are Plaintiffs in this action.

India Oxenberg is a plaintiff in the action and is using her full name.

Attached hereto as exhibits A to I are screenshots of pages from The DOSsier Project website and social media accounts of the organization and certain of its members, including Defendants Clyne and Roberts, along with Ms. Hachette.

In her video statement, The DOSsier Project’s Ms. Hachette warns the Plaintiffs: “For those of you who are Jane and John Does watching this, this is your last opportunity to come forward and put your name to your claims. If you do n’t, it is my moral obligation to name every single one of you. The clock starts now.”

In their written statement, The DOSsier Project elaborates: “The same anonymous women that Judge Garaufis, at Raniere’s sentencing hearing, called ‘brave victims’ are in this anonymous lawsuit. When in history have you ever had a
government officially labeling people as brave when they are making anonymous accusations? Calling them brave while sheltering them with anonymity is Orwellian. I know who these ‘Does’ are and I’m not going to play their game. I’m going to name them, starting with [Plaintiff] Nicole . . .”

The message from The DOSsier Project is clear: the Plaintiffs better quickly accede to their demands because even if they do not want to be publicly identified, Ms. Hachette will identify them.

Ms. Clyne did not merely re-post these threats to her personal Twitter feed. She endorsed and amplified them with her own comments that leave no doubt about her involvement in this campaign.

Among other things, she states on Twitter that, “Women accusers who hide behind anonymity further the paternalistic idea that women need to be babied and are too weak to put their name to things.”

She also states, in the same thread, that “Women in the NXIVM case have hidden behind their anonymity long enough. With equal privilege comes equal responsibility. Time’s up!”

Ms. Roberts shared their threatening statement on her Twitter feed, joining in the effort.

Ms. Hachette may be the organization’s face for this disgraceful conduct, but Ms. Clyne’s responsibility is indisputable.

Ex. B is a screenshot of the Instagram post of the video, which can be found in full at
https://www.instagram.com/p/CZf4E_xBdzm/.

The full video can also be accessed on a secure server hosted by Plaintiffs’ counsel at

Screenshot from Michele Hatchette’s Instagram video.

https://kohnswiftgraf.sharepoint.com/:v:/g/EbiGAAz6Wy9Nvbh4dOiVGX8BgtjKnnkcW37akS_J-qYV3g.

In addition, a courtesy copy of the video file pre-screened for viruses will be submitted on USB drive to the Court
pursuant to this Court’s individual rules.

Ex. A is a screenshot of the written statement, which can be found at https://www.theDOSsierproject.com/articles/statement-from-michele-hatchette

No one has a legitimate interest in having the identities of sex crime victims revealed, especially in this manner threatened here. Harassment, intimidation and threats of this nature are traumatic, particularly for people who are already struggling to recover from related trauma. It is abundantly clear that Defendant Clyne is working in concert with others in a brazen effort to undermine the Court’s exclusive authority to decide this matter, and to inflict additional harm on those Plaintiffs in the process.

The protective order in the criminal proceeding only applied to the Defendants in that proceeding, but the judgment of Judge Garaufis that certain victims of the defendants in that case – including Plaintiffs in this action who had escaped from DOS, and Daniela, Camila and their brother– deserved some protection from full public disclosure of their identities has been respected beyond the criminal case.

A Protective Order by this Court will bar the Defendants in this action from directly or indirectly publicly disclosing the protected Plaintiffs’ identities. But this most recent development may warrant more, irrespective of the Court’s decision on the pending motion. Ms. Hachette asserts on Twitter that she is a “civilian” not subject to this Court’s jurisdiction, but the fact that The DOSsier Project includes Ms. Clyne, who is a party, and her own flagrant and public disregard for the clearly established legal process justifies sanctions.

However, because Ms. Clyne is a pro se litigant and lacks access to advice from competent counsel, Plaintiffs respectfully suggest that a stern admonishment from the Court may be appropriate, so that she can fully understand that her efforts to make end-runs around this Court’s authority, and to harass and threaten Plaintiffs outside of these proceedings, can have serious consequences.

Plaintiffs respectfully request that the Court expeditiously consider all the circumstances in this matter and take appropriate action, before even more damage is done.

Respectfully Submitted,

Neil L. Glazer

NLG/yr
cc: All counsel and pro se defendants via ECF

[Footnote by Glazer]  Ms. Hachette seems to believe this is protected First Amendment speech, but it may constitute coercion in the third degree, a felony offense under NYS Penal Law § 135.60.

Plaintiffs’ concerns extend well beyond this particular issue. Looming over their heads every day is the continued
existence and possible threat of release of some or all of their collateral, which is the subject of Plaintiffs’ separate
motion pending before Magistrate Judge Pollack for leave to issue a non-party subpoena directed at collateral. (No.
100).

That motion raises the concern that the subject non-party likely obtained copies of collateral from Ms. Clyne and has shared those materials with others. Ms. Roberts has publicly stated that she is in possession of a video of the branding of at least one Plaintiff, [Sarah Edmondson] which is also collateral…. [Roberts got her copy of the branding video of Sarah Edmondson as part of the discovery material in her license revocation hearing. It was provided to her by New York State and may have been obtained by NY from the US DOJ, although the source of providing the video to Roberts is unclear. When asked, Roberts said she does not know who provided the video to NY State.]

If these Defendants believe that they can disclaim responsibility and avoid consequences simply by encouraging non-party associates to engage in the wrongful conduct, as is happening here, there is a very high risk that they will continue to do just that, with potentially disastrous results.

 

****

Ed Note: This is a high-stakes matter. It is interesting that only a dozen out of more than 70 plaintiffs want to maintain anonymity. Glazer also raises some interesting legal issues. He acknowledges that the court cannot prevent non defendants from doing whatever they want, but he claims that anything that non defendant Hatchette does should be laid at the doorstep of defendant Clyne.

Glazer also raises a New York State third degree felony law of inducing or compelling a person to engage in conduct that he or she has every legal right not to participate in.

According to the law firm Crotty Saland “the means by which you persuade a person to abstain or engage in conduct must be based in a fear that if the target person does not comply you will take certain acts against this person as follows:

  1. Whether true or not, expose a secret or publicize an asserted fact: This act must subject the person to contempt or ridicule.
  2. Testify, provide information or withhold information with respect to that person’s legal claim: Fairly straightforward, this section speaks for itself.
  3. Perform any act that would not in itself materially benefit you but is calculated to harm the person: The harm that you intend to cause must relate to the other person’s health, safety, business, career, finances, reputation or personal relationships.

It is hard to say whether or not Hatchette’s statement that if they do not reveal their identities she will, falls under this conduct. But if I were Hatchette, I would strongly reconsider naming names. Either she should withdraw her threat that if they do not reveal themselves, she will, or better yet, not reveal anyone’s names at all.

But that is not my choice. It is not even Mr. Glazer’s. I do not think it is the judge, Eric Komitee’s decision – at least as far as Hatchette, a non defendant, is concerned.

But Glazer may have missed a point though. Hatchette does not live in New York State and might not be subject to NY prosecutors’ jurisdiction.  Still, knowing the wide discretion prosecutors have, Hatchette might be well advised to shy away from this controversy.

Stay tuned, and as always, Viva Executive Success!

About the author

Frank Parlato

17 Comments

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  • According to DOS ladies Nicki and crew, DOS was based on a vow of strict secrecy. Also, according to these folks (Asunsolo and crew), ethics are at the forefront of what they do and why.

    Setting aside the extortion aspect to this whole thing, there’s a deeper issue that should be a “moral” consideration – and that’s the issue of ethics. Do you sell out (give away DOS secrets) when things get uncomfortable and to compel people to do what you want? Or do you uphold your vow of secrecy and let the dominos fall how they will, maintaining your “honor” and integrity?

    Sounds like a SOP/Jness/ESP/Ethicist kind of question to me. But, then again, Nicki was only an “Ethicist-in-Training” and things are heating up. She seems like the kind of person that can logic her way out of anything and justify pretty atrocious things.

    She may be of the mindset “Well they didn’t uphold their vow, so why should I?” Because that’s the foundation of ethics and integrity, isn’t it?

    The timing of all of this doesn’t help her justification. Saying “I’m going to release names” when all else has failed and the civil case is moving forward is the worst time to do it if ever at all. She has a small army of girls now that will do what she wants if she can find just the right justification to cloud her true intentions.

  • I’m a rich, white, good-looking, intelligent female malignant narcissist psychopath, so what I have to say is of extreme importance to all. Oops, gotta run, my trailer is getting repossessed by rats.

  • How to Defeat Blackmailers and Extortionists.

    The best way to defeat blackmailers and extortionists is to defy them and not back down.
    Extortionists only win if you let them win.

    In 1957 a prominent American journalist named Joseph Alsop traveled to the Soviet Union.
    Alsop, a member of the DC press was bisexual.
    A handsome young KGB male agent picked up Alsop in a hotel bar and in an upstairs room engaged in salacious activities with Alsop.

    Alsop was told by the KGB they had compromising photos of him and was offered a deal.
    Alsop went to the American embassy and came clean with the then American Ambassador Chip Bohlen.
    Alsop’s quick extraction from the USSR was arranged and the journalist told the FBI what happened.
    The story was quickly and quietly revealed to the Washington DC elite.

    Alsop not only kept his job but also when the compromising photos were anonymously mailed to the DC elite over the next 15 years they were ignored.
    Alsop, who was a conservative Republican, was a friend of John F. Kennedy and Alsop’s stature was not reduced.

    Joseph Alsop
    Sexuality
    Alsop kept his homosexuality a closely guarded secret all of his life.[22] Richard Helms called him “a scrupulously closeted homosexual.”[23] Nevertheless, Senator Joseph McCarthy insinuated that Alsop was homosexual in the course of a dispute with The Saturday Evening Post about its coverage of his campaign to remove perverts from government employment. When McCarthy implied that Alsop was not “healthy and normal,” a Post editor vouched for him: “I know Alsop well, and I know he is a man of high character, with great courage and integrity.”[24]

    Early in 1957, the KGB photographed him in a hotel room in Moscow while he was having sex with another man, an agent of the Soviet Union. He rebuffed Soviet attempts at blackmail, instead writing “a detailed account of the incident and a relevant narrative history of his sex life.” It has been described as “brimming with revelations about Alsop’s sex life on several continents,” including a report that one of his lovers was Arthur H. Vandenberg Jr., who had resigned as Dwight Eisenhower’s appointments secretary in 1953.[25] His accounts, delivered to a friend in the CIA, quickly reached the FBI, allowing J. Edgar Hoover to spread the information through the Eisenhower administration, many of whose members had fought sharp battles with Alsop.[26]

    Hoover told President Lyndon B. Johnson about the Moscow incident in 1964,[27] and Johnson told Secretary of Defense Robert S. McNamara about Alsop’s FBI file.[28] In 1965, Alsop complained to friends that Johnson was tapping his phone, a claim that infuriated Johnson, who believed that he had protected Alsop from McCarthy’s attacks. Alsop told White House Press Secretary Bill Moyers that he believed the administration was tapping his phone and was spreading gossip about his personal life, all in an attempt to stop leaks. When Moyers reported the charges, Johnson ordered Attorney General Nicholas Katzenbach to be certain no such wiretap was in place and protested that he never ordered one: “I’m as innocent of it as I am of murdering your wife,” he told Katzenbach.[29]

    In the 1970s, the Soviets sent the aforementioned photos to several prominent American journalists without adverse consequences. Alsop considered making his homosexuality public to end the harassment but decided otherwise.
    https://en.wikipedia.org/wiki/Joseph_Alsop

    Nicki Clyne:
    Go Pound Sand!

    • Why don’t you come clean and tell us what you know? These copy/paste posts of yours are beginning to smack of a jilted fellow’s attempt at revenge.

  • IF I were truly innocent of the accusations, then I would passionately WANT my day in civil court. I would not be trying to harass and silence the plaintiffs.

    If I were so confident that I had done nothing wrong and there was truly proof of my sterling conduct, then I would LIVE to be heard in court.

    These DOS die-hards are constantly claiming that they’ve got the secret sauce to show the world how wrong the “Nxivm was a destructive cult” narrative has been.

    Civil court is your stage, ladies. This is your shot to prove the “Nxivm was a good thing” doubters and the “Keith is a wonderful human” disbelievers wrong.

    IF I were desperately wanting to “set the record straight” about DOS, ESP, Nxivm, my own conduct and illuminate the faultless actions of my shared lover, Keith Raniere, then the civil court date could not come fast enough for me.

    The opportunity to finally show the world the brilliance, innocence and integrity of my revered leader and all of our front-line slaves shared lover plus the amazing master/slave ring that was DOS in a documented legal setting would be such a wonderful moment…IF I were innocent. If we all were innocent of the complaints laid out in the civil case, this civil case would be a welcome opportunity

    Court would be so much better of a place than Instagram, Facebook, or Twitter, to truly make good on all my past promises to finally show Keith and all of the masters and slaves were blameless.

    IF I WERE innocent.

  • If New York’s isn’t the correct jurisdiction (that was me yesterday; I assumed MH was there when making her threats), then pretty much everywhere in the U.S. has a blackmail-related statute.

  • In the latest Dossier Project video, released tonight, Dr. Danielle Roberts shares a personal experience with lead federal prosecutor Moira Penza where it makes you wonder if Moira was the one who was brainwashed.

    It starts at 6:50.

    Yes, I know – brainwashing doesn’t exist. But in the same way that a “cult member” can be so obtuse and resistive to contrary experience, so can everyone else. Including you, and including federal prosecutor Moira Penza.

    Watch Dr. Roberts’ experience with Moira for yourself.

    Ask yourself – was Moira brainwashed?

    Is that why she resigned? She finally ‘deprogrammed’ herself after seeing what she saw of the ‘cult’ of the federal prosecutor’s office?

    https://youtu.be/HfBHCpSx_9Y

  • “In what is shaping up as a classic First Amendment versus Victims’ Rights battle, and the stakes are getting higher.”

    Says the piece of shit who is censoring Patriot God and his friends and raping them of their free speech and runs away hide hide like a little pussy when he’s confronted about his hypocrisy every single fucking day!

    Shut the fuck up, Frank! You little two-faced, hypocritical, bitch! It’s amazing how deep and long you’ll wade in your own bullshit!

  • Why do the NXIVM loyalists feel it is so important expose these names? What do they have to gain?

    I can only think of two possible reasons:

    1. They are still deep in the NXIVM psychobabble about upholding values and keeping promises or vows. They feel that the request for anonymity is dishonorable.

    2. Intimidation and vengeance pure and simple. Hoping some will drop out of the suit out of embarrassment. Hoping to see them run away with their tails between their legs.

    I’d be interested if anyone has any other thoughts on this.

    • Dianne – My thoughts – These idiots don’t do anything without keith’s direction. Michelle is too stupid to think on her own. keith told her to do it. keith is doing this purely for his own amusement because he knows once the people are exposed, it’ll ruin some of their lives, and he loves that shit. And keith is likely hoping that Michelle gets ruined for it too because, well, he is an asshole. Everything keith does is to torment, humiliate, and destroy. Everything. This is just another example.

  • How dare that vile dork Nicki Clyne co-opt “time’s up” after mocking it so in the past.

    Nicki has no money to lose. She says.

    That makes it so crystal clear that it is the victim testimony and what it will reveal that has Keith Raniere’s leftover branded slave women so shook.

    All the seduction assignments. All the fake marriages. All the close-up pussy porn. All the no masturbation, swear yourself only to vanguard sexually and don’t groom your pubes. All the starve yourself till your period stops and your head hair falls out. All the blackmail. And so much more that has remained hidden.

    Should have settled out for court. Dumb.

    So much abuse Clare heaped on Sylvie. And then the sexual abuse from Keith.

    Nicki in particular is very concerned.

    Can you imagine the horrors that Daniella, Camilla and others can/will reveal?!

    Show no mercy, plaintiffs. Nicki and Michelle and Dr. Crotch-brander have no love for you.

    Tell. It. All.

    And then tell even more. And then more.

    These DOS asshole are begging for it.

    Go HARD plaintiffs. Leave nothing out.

Frank Parlato

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.” In addition, he was credited in the Starz docuseries 'Seduced' for saving 'slave' women from being branded and escaping the sex-slave cult known as DOS.

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 premieres on May 22, 2022.

IMDb — Frank Parlato

https://en.wikipedia.org/wiki/Frank_Parlato,_Jr.

Contact Frank with tips or for help.
Phone / Text: (305) 783-7083
Email: frankparlato@gmail.com

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