Frank Report has obtained a copy of Sara Bronfman’s motion to dismiss the civil lawsuit filed by plaintiffs in the Sarah Edmondson et al. against Keith Raniere et al case. The plaintiffs are represented by the Philadelphia law firm of Kohn Swift and Graf. The lead attorney is Neil Glazer.
Bronfman Memorandum of Law Here
Notice of motion here
Bronfman retained the white-shoe law firm, Fried, Frank, Harris, Shriver & Jacobson LLP, headquartered in New York City, with offices in Washington, D.C., London, and Frankfurt to represent her.
Fried Frank’s predecessor firms were formed in the early 20th Century, founded by German Jewish attorneys. In 1971, the firm took its current form with Walter Fried, Hans Frank, Sam Harris, Sargent Shriver [Kennedy family and ‘creator’ of the Peace Corps], and Leslie Jacobson. The firm reportedly grossed $776 million in 2020, and profits per partner were $3.79 million. Associates start at $200,000 annually.
Bronfman retained two partners from the firm, including the chairman of their litigation department, and three associates.
J
Global Chair of the Litigation Department, James D. Wareham
Israel David is a ‘bet the company’ litigation partner.
The three associates are Anne S. Aufhauser, Alexis R. Casamassima, and James M. Lockerby.
Glazer’s First Amended Complain [FAC] alleges that Sara Bronfman
- Served on the NXIVM board
- Was a “member of the Executive Board of ESP
- Held various titles at NXIVM
- head of Rainbow Cultural Garden
- Master of Humanities
- Director of Humanities
- Regional Vice President of ESP
- Professional Coach
- Head Trainer
- Contributed money toward NXIVM initiatives or activities
- Co-founded the Ethical Cultural Foundation
- Co-founded the Ethical Science Foundation [ESF]
- Founded ESP’s “VIP Programs.”
- Opened a Rainbow Cultural Garden in London
- Provided funding for the Dalai Lama to speak at an NXIVM event
- Promoted NXIVM
- Recruited people to join NXIVM [no plaintiff, however, alleges that Bronfman recruited them]
- Attempted to convince Adrian to leave the United States during the trial against Raniere. [Adrian is the brother of Camila, Daniela, and Mariana. Daniela and Camila were part of the criminal trial] Adrian did not leave the US during the trial.
- “was part of the NXIVM RICO enterprise.”
Though Bronfman was a significant funding source, and a draw for people joining NXIVM because of her famous family’s wealth, she was not named a member of the racketeering enterprise in the criminal racketeering charges against Raniere and his codefendants.
The “Inner Circle” of NXIVM/ESP government exhibit.
Unlike her sister, Sara Bronfman was not charged criminally. She left the USA before the criminal trial. She is reportedly living in Portugal with her husband and their two daughters.
Bronfman, a Seagram’s heir, and her sister, Clare Bronfman, are the only defendants of the 11 individual defendants known to have money. The crucial argument is whether the plaintiffs can tie Clare and Sara Bronfman into liability. If not, the lawsuit is worthless.
The other defendants are
- Keith Raniere, serving a 120-year prison sentence
- Nancy Salzman, serving a 41-month sentence,
- Allison Mack, serving a three-year sentence
- Lauren Salzman, on probation and in the dog grooming business.
- Kathy Russell, on probation
- Nicki Clyne
- Brandon Porter had medical license revoked
- Danielle Roberts had medical license revoked
- Karen Unterreiner
There were initially over 80 plaintiffs in the lawsuit, but several dropped out. At the time of the Bronfman fling in January, there were 74. Presently there are, I estimate, 65 plaintiffs remaining.
Like there are only two defendants with money, there are only a few plaintiffs with serious claims. More than half of the plaintiffs only claim they took NXIVM classes and were harmed somehow by doing so.
The three prominent plaintiffs are Camila, Daniela, and Nicole. If these three dropped out – or it was shown that the Bronfmans had nothing to do with their injuries – the case would evaporate.
The FAC, however, alleges that Sara Bronfman is liable for
- RICO & RICO Conspiracy
- Trafficking
- Negligence Per Se
- Gross Negligence
- Forced Labor & Peonage
- Aiding and Abetting
- Abuse of Process
Bronfman’s attorney argues that the lawsuit should be dismissed against her with prejudice, meaning the plaintiffs cannot bring the action against her again in federal court.
Despite its length – the FAC is 217 pages long – her attorneys say, “the FAC does not contain any factual allegations suggesting that Ms. Sara Bronfman was aware of any inappropriate conduct at NXIVM, participated in any such conduct, or subjected any plaintiff to any harm.”
Bronfman’s attorneys assert that the complaint frequently and “indiscriminately sweeps all of the defendants together under the defective moniker ‘Defendants’ and then asserts blanket allegations against the ‘Defendants.'”
FAC does not show “how or why any of the plaintiffs (much less all 74 of them) are entitled to relief from Ms. Sara Bronfman. Instead, the FAC routinely sweeps all of the defendants together under the term “Defendants” and then proceeds to make allegations against them that cannot possibly refer to Ms. Sara Bronfman.
Fried Frank argues that while there is “a wide-ranging and differently situated set of 15 defendants [who are accused by the plaintiffs of violating] a laundry list of federal and state laws, by virtue of their alleged connections to NXIVM,” the FAC does not state “what claim any of these plaintiffs might have against Ms. Sara Bronfman.
Here are some of the arguments of Sara Bronfman’s attorneys. My comments are in [bold and brackets.]
RICO Claims
The RICO claim fails because the FAC does not allege that Ms. Sara Bronfman, through the commission of two or more predicate acts, participated in the management or operation of a RICO enterprise (or was even aware of the existence of any such enterprise). The separate RICO conspiracy claim fails because there are no allegations that Ms. Sara Bronfman “agreed with at least one other person or entity to commit a substantive RICO offense.”
***
Despite reciting a laundry list of potential predicate acts that the “Individual Defendants” purportedly engaged in, the FAC does not adequately allege any conduct by Ms. Sara Bronfman that amounts to a RICO predicate act.
***
Adrian Obstruction?
The sole allegation that could potentially be considered a predicate act by Ms. Sara Bronfman is a vague allegation of witness tampering (alleging that Ms. 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, Adrian, to leave the United States and remain outside of it during Raniere’s criminal trial”).
This conclusory allegation offers no details as to where and when this supposed discussion occurred, what the alleged “false pretenses” were, or what “promise of money” was made…
Here, the FAC pleads that Adrian “refused to comply” with the alleged attempt at obstruction… and thus, plaintiffs were not harmed in any way. Moreover, plaintiffs cannot show that Adrian’s alleged unavailability at the Raniere trial caused them to suffer any harm. After all, Raniere (the only defendant to stand trial) was found guilty of all charges, including sex trafficking and RICO conspiracy.
***
In addition to the FAC’s failure to plead the elements of a RICO claim, plaintiffs also lack standing to bring such a claim. To bring suit under RICO, each plaintiff must allege injury to their “business or property” caused “by reason of the substantive RICO violation.” … Many of plaintiffs’ alleged harms are not RICO injuries; in fact, they are precisely the type of physical, emotional, personal injuries that courts routinely reject in the RICO context.
[The FAC alleges these injuries, none of which qualify for RICO]
- (“moderate-to-severe psychological and emotional injuries, including post-traumatic stress disorder and complex post-traumatic stress disorder.”
- “emotional and psychological injuries.”
- “panic attacks, psychological breakdowns, and major setbacks in” therapy
- “tremendous fear and intimidation.”
- “psychological abuse.”
- “unable to sleep.”
- “fearful”
- “severe physical and psychological problems.”
- “serious psychiatric crisis.”
- “nightmares and panic attacks.”
- “severely traumatized.”
- “serious emotional trauma.”
- “shame and humiliation.”
Courts in this Circuit have held that a “loss of career” is too “speculative and indefinite” to state a claim under RICO, and the “loss of Plaintiff’s reputation and resulting inability to gain future employment are personal injuries [that] are not compensable under RICO.”…
The FAC also fails to allege that plaintiffs’ purported injuries were caused by any conduct of Ms. Sara Bronfman that amounted to a RICO violation… According to the FAC, plaintiffs’ alleged injuries stem from the alleged assaults and actions of others, not from Ms. Sara Bronfman’s conduct.
Sara Bronfman – did she traffic women?
Trafficking
The FAC purports to assert claims under the Trafficking Victims Protection Reauthorization Act [TVPRA]…
To state a claim … for perpetrator liability, a plaintiff must plead that the defendant knowingly and in interstate or foreign commerce: (1) recruited, enticed, harbored, transported, provided, obtained, or maintained by any means a person, (2) knowing, or in reckless disregard of the fact, that means of force, threats of force, fraud, or coercion or any combination of such means would be used (3) to cause the person to engage in a commercial sex act…
The FAC contains no facts suggesting that Ms. Sara Bronfman knowingly recruited or caused any person to engage in a commercial (or any other) sex act.
The allegations in the FAC concerning the alleged recruitment of sexual partners make no mention of Ms. Sara Bronfman.
For example, the FAC alleges that “First Line Masters were tasked with selecting attractive, trustworthy women who could become sexual partners for Raniere.” The FAC clarifies that Ms. Sara Bronfman was not a “First Line Master” (or, indeed, even aware of the term, concept, or alleged activities of those individuals).
The FAC…. contains no allegations remotely suggesting that Ms. Sara Bronfman had any knowledge of any person engaging in sex trafficking…
The FAC does not allege facts suggesting that Ms. Sara Bronfman knowingly benefited in any way from any alleged participation in a likely sex trafficking venture.
Here, the FAC simply declares in conclusory fashion that “for Defendants Clare Bronfman and Sara Bronfman, the benefits they received, including perceived future benefits, warranted an investment of a reported $150 million.”
The FAC never details or elaborates on what these current or “perceived future benefits” entailed. To the contrary, the FAC alleges only that Ms. Sara Bronfman expended money.
Sara Bronfman***
Rainbow Gardens
Here, the FAC does not allege TVPRA claims premised on slavery or involuntary servitude, and its claims of forced labor and peonage are… insufficiently plead as against Ms. Sara Bronfman. Even putting aside this fatal defect, a claim for human trafficking is not sufficiently pled where, as here, plaintiffs allege in a conclusory fashion that the defendants “fraudulently induced [the plaintiffs] to immigrate to the United States.”
“Most of the MDS [Rainbow nannies] were simply foreign recruits, brought to the United States under false pretenses.”). While the FAC contains a section entitled “Defendants’ Exploitation of Foreign Nationals,” none of the allegations contained in that section (which does not even mention Ms. Sara Bronfman) allege that Ms. Sara Bronfman induced any of the plaintiffs to secure their labor or services in a manner that violates the TVPRA…
Forced Labor
The FAC contains no allegations that Ms. Sara Bronfman knowingly obtained the labor or services of any person at any time or by any means, let alone by means of force or by threats of force, physical restraint, or any other harm…
Moreover, the FAC does not allege that Ms. Sara Bronfman knowingly received any “benefit” from any non-existent “participation” in any venture that engaged in forced labor…
Sara Bronfman with Keith Raniere
Negligence Per Se
The FAC purports to assert a claim for negligence per se predicated on an alleged violation of N.Y. Education Law § 6512, which makes it a felony to engage in the unauthorized practice of psychology or mental health counseling or to aid and abet in the foregoing. This count fails as against Ms. Sara Bronfman because a negligence per se claim may only be predicated upon a statute that — unlike Section 6512 — contains an express or implied private cause of action, and (separately) because Ms. Sara Bronfman is not alleged to have engaged in the unauthorized practice of psychology or counseling or to have aided or abetted such practice.
***
The FAC broadly claims that “Defendants” committed negligence per se by “branding women’s pubic regions with Raniere’s initials.”
Yet, 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 unaware of) this conduct, which is alleged to have occurred only within DOS.
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.
Gross Negligence
The FAC asserts that Ms. Sara Bronfman acted with gross negligence by failing to supervise other defendants in their treatment of Jane Does 20-22. [The Tourette’s/OCD subjects of NXIVM experiments.]
Absent a special relationship, an individual has no duty to supervise the conduct of another person so as to prevent such other person from harming others. No such special relationship is alleged in the FAC.
Moreover, even if a special duty did exist (it did not), there are no factual allegations suggesting that Ms. Sara Bronfman breached that duty.
***
***
The FAC asserts that Ms. Sara Bronfman funded Ethical Science Foundation (“ESF”), the entity that allegedly administered treatments for obsessive compulsive disorder and Tourette’s Syndrome.
According to the FAC, these treatments allegedly were designed by Raniere and Nancy Salzman, overseen by Salzman and administered by Brandon Porter.
The FAC does not allege that Ms. Sara Bronfman administered, planned, or participated in these treatments. Rather, it asserts that Ms. Sara Bronfman breached her supposed duty of care by failing to ensure that the treatments met the standard of care that a reasonable doctor or nurse would provide in similar circumstances. However, Ms. Sara Bronfman had no such duty to supervise or control the actions of those individuals…
Special relationships have been relegated to “quite narrow settings” — which are not alleged to be present here — such as master-servant, parent-child, common carrier-passenger, landlord-tenant, innkeeper-guest, and employer-employee… While the FAC makes the rote assertion that Ms. Sara Bronfman had a duty of care to supervise Porter and Salzman’s treatments of Jane Does 20-22, it fails to explain the basis for this unsupported conclusion.
Even accepting the FAC’s allegation that Ms. Sara Bronfman participated in the founding of ESF, it contains no facts showing Ms. Sara Bronfman served in any leadership or supervisory role at ESF. Nor would such a role even be dispositive in showing a special relationship…
The FAC fails to include even bare allegations, much less concrete facts, asserting that Porter or Salzman, the individuals allegedly involved in administering the treatments, were subordinates or employees (or acted under the direction) of Ms. Sara Bronfman. At most, the FAC alleges that Ms. Sara Bronfman funded and founded ESF.
Aiding and Abetting
The FAC asserts a claim against several defendants for allegedly aiding and abetting another individual [Dr. Brandon Porter] in his alleged conduct of unauthorized human research. This claim fails because the FAC does not allege any facts suggesting that Ms. Sara Bronfman had any knowledge of that research and because the FAC fails to allege that she provided any assistance — much less the requisite “substantial assistance” — to such individual.
***
The FAC fails to allege her (i) knowledge of any alleged underlying tort and (ii) substantial assistance to advance the commission of the alleged unauthorized human research… To plead an aiding and abetting claim, a plaintiff must allege “actual knowledge” of the underlying tort, as opposed to constructive knowledge.
[Actual knowledge is actually knowing something. Constructive knowledge is something a person could reasonably be expected to know.]
Here, the only allegation regarding Ms. Sara Bronfman’s supposed actual knowledge of the alleged unauthorized human research is the conclusory statement that “Defendants had actual knowledge that Porter was conducting unauthorized human research on human subjects in violation of N.Y. Pub. Health Laws…
Accordingly, the aiding and abetting claim must be dismissed for failure to plead Ms. Sara Bronfman’s “actual knowledge” of the underlying tort of alleged unauthorized human research…
The FAC’s lone attempt to plead substantial assistance as to Ms. Sara Bronfman is its vague allegation that “Defendants Clare Bronfman and Sara Bronfman provided the funds for the rent of the premises and the purchase of the equipment used in the unauthorized human research through ESF, substantially assisting Porter.”
Even assuming arguendo that Ms. Sara Bronfman paid rent for the premises or purchased the unspecified equipment allegedly used by another defendant, these actions do not constitute substantial assistance because they fail to show “knowledge of the [unauthorized human research] that is being aided and abetted, [and] a desire to help [the unauthorized human research] succeed.”
Malicious Abuse of Process
First, such a claim requires a defendant to have employed legal process, but the only conduct attributed by the FAC to Ms. Sara Bronfman is that she purportedly provided “financial support” for unspecified legal actions. That is insufficient as a matter of law.
[Abuse of process is the unjustified or unreasonable use of legal proceedings to further a cause. The process is formal notice including summons, subpoena, mandate, and warrant.]
Moreover, even if the FAC had alleged that Ms. Sara Bronfman filed the lawsuits at issue, the mere filing of a lawsuit (even a frivolous one) is insufficient to state a claim; rather, abusive conduct after the filing of the complaint is required. No such conduct is alleged here on the part of Ms. Sara Bronfman.
***
Sarah Edmondson
In particular, [abuse of process] is alleged on behalf of plaintiffs Jane Doe 19, Edmondson, Salazar, Souki, Audrey, and Natalie…
Yet, none of these plaintiffs’ allegations relate to Ms. Sara Bronfman. They focus on the alleged actions of other individuals or of “Defendants” generally. (alleging that other named individuals caused attorneys to send letters to several of the plaintiffs); describing statements allegedly made by another individual[Clare Bronfman] to the Vancouver Police regarding Edmondson)…. (alleging that “Raniere and Nancy Salzman embarked on a campaign of vexatious abuses of the legal system” against Natalie). Compounding this lack of specificity is the FAC’s failure to identify the most basic information regarding the allegedly abusive actions….
***
Rick Ross’s case is mentioned as Sara Bronfman’s abuse of process. The problem is Ross is not a plaintiff in the lawsuit.Only one allegation provides any detail… The FAC alleges that “[i]n 2003, Defendants launched a legal crusade against … Rick Ross and Ross Institute” and “[o]ver the next fourteen years,” “the [d]efendants” brought “parallel proceedings in multiple courts.”… Putting aside that Rick Ross is not a plaintiff in this action, and even accepting these allegations as true, this allegation would be barred by the one-year statute of limitations.
***
The sole allegation against Ms. Sara Bronfman is that she purportedly “financed these efforts, spending millions of dollars on lawyers, private investigators and to cover other related expenses.”
But financing litigation is not a legal process [legal process is formal notice or writ by a court obtaining jurisdiction over a person or property include a summons, subpoena, mandate, and warrant, An abuse of process is the unjustified or unreasonable use of legal proceedings or process to further a cause of action] and cannot support an abuse of process claim…
The filing of lawsuits cannot serve as the basis for an abuse of process claim…
In a curious and telling contrast, the FAC does identify specific cases involving parties not asserting this claim. (In re Dones), (NXIVM Corp v. O’Hara), (Raniere v. Microsoft Corp.). {Susan Dones, Joseph O’Hara, and Microsoft are not plaintiffs in the Glazer lawsuit.]
NXIVM’s abusive litigation targeted Susan Dones. She is, however, not a plaintiff in the Glazer suit.
.…The alleged retention of private investigators cannot constitute an abuse of process because “aggressive investigatory tactics… do not relate to the issuance of process.”
Similarly, “making false or misleading statements to law enforcement” — to be clear, there are no allegations that Ms. Sara Bronfman made any such statements — is not a “legal process”…
SUMMARY OF ALLEGATIONS
The FAC also makes “group” allegations regarding supposed conduct by the “Bronfmans,” as if the two sisters acted as one unit simply because they are related… (referring to purported non-profit funding provided by ‘the sisters’ or ‘the Bronfman sisters’).
***
Further illustrating the FAC’s multiple fatal defects is 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.” This is the only information the FAC provides regarding John Doe 21.
Yet, on these limited facts, the FAC boldly declares that, as a result of “Defendants’” conduct, “John Doe 21 was emotionally and financially harmed.”
John Doe 21 is not an isolated example of a plaintiff who must be dismissed because no meaningful facts are alleged regarding his claims.
There are over 40 plaintiffs in this lawsuit for whom the FAC likewise provides the same limited information (or non-information). All of these plaintiffs must be dismissed…
In sum, the FAC should be dismissed because it does not furnish notice to Ms. Sara Bronfman as to what she allegedly did wrong or why she is named in this lawsuit.
Frank Parlato 
Janine Morrison 
J.J. O'Hara 
Richard Luthmann 
Marie White 
Paul Serran
Please leave a comment: Your opinion is important to us!
Fried Frank is the kind of law firm that God would hire if God had the money!
Frank, please fix the link to Bronfman’s memo of law. It is not working. Thanks!
When deciding motions to dismiss, courts should functionally ignore allegations that
“are no more than conclusions” by refusing to “assume their veracity, in contrast to “well-pleaded factual allegations,” which should be taken as true and evaluated to “determine whether they plausibly give rise to an entitlement to relief.”
The “plausibility” standard is met only if the complaint contains “factual content that
allows the court to draw the reasonable inference that the defendant is
liable for the misconduct alleged.”
These quotes are from the most recent US Supreme Court case on this issue. As you can see, the claims do not need to be proved in the complaint. There need only be sufficient facts from which the court can REASONABLY INFER that the defendant is liable.
In essence, Sara’s attorneys are claiming that more is required in terms of proof at this stage of litigation. The law states otherwise.
Glazer provided enough factual content from which the court can make a reasonable inference of liability. He should be permitted to proceed to discovery to prove these claims by a preponderance of the evidence.
Frank, please ignore my earlier post. I read the comments first! After reading your post, I realized it was not on point. Thanks!
I am severely traumatized. Give me money.
Anon 12:47-
Well, when you get molested, raped or blackmailed (into having sex with a cross-eyed, squared footed, hairy-ass, fat slob), you too can seek compensation.
You think Dani and Cami don’t deserve compensation?
But, that was already addressed and Keith has to pay reparations!!
Omg, it’s true…Frank, they really do go by Fried Frank.
A hilarious spellcheck replacement? Or an unkind epithet?
>>Fried Frank<< argues that while there is “a wide-ranging and differently situated set of 15 defendants [who are accused by the plaintiffs of violating] a laundry list of federal and state laws, by virtue of their alleged connections to NXIVM,” the FAC does not state “what claim any of these plaintiffs might have against Ms. Sara Bronfman.
Sara left Keith when he needed her. She ran off to France and didn’t care a bit that the man who taught her everything was kidnapped. Shame on her.
Pea Onyu
March 13, 2022 at 7:53 am
Sara left Keith when he needed her. She ran off to France and didn’t care a bit that the man who taught her everything was kidnapped. Shame on her.
To Pea Onyu:
When the going gets tough, the tough get going!
“The man who taught her everything”.
First, neither Clare nor Sara finised any formal education, so the bar was very low to begin with.
Second, what is it exactly that Keith taught Sara? The “smartest man in the world” has been proven to be a liar, an imposter, a grifter. Not the best of teachers….
I am not surprised they are suing given the damage done by the cult but if they want money from the only ones with money, they need proof of what those people knew. The Bronfmans probably did know things but that will need to be proven and indeed pleaded. Here in the UK, the defendants can require further and better particulars of a claim (if it is not well pleaded or indeed apply to strike it out) and the claimant (plaintiff) also can reasonably early on only request the court to allow them to amend their original pleaded case.
It will be interesting to hear about the counter to this because it has to be more than “if the Bronfmans’ didn’t provide the money, none of this would have happened.”
Being the bank is not sufficient evidence of wrong doing, otherwise banks could no longer exist. They have to prove somehow, that the Bronfmans actively participated in the illegal activity and influenced Keith in participation of illegal activity. One needle they will have to thread is NXIVM tricked all these wonderful innocent plaintiffs out of money, tricked woman into behavior they otherwise never would have engaged in, brainwashed many into believing things would not have….except these few defendants who benefited from this scheme.
Plaintiff lawyers: “How did they benefit? Money of course…except for those two super rich women who gave NXIVM more money than NXIVM ever gave back. They also got to enjoy the ego stroke of having power over others, well except those super rich women who had that power from the day they were born. But trust us, they benefited in great ways so give us a bunch of money in restitution.”
Selling that to a jury is feasible, the trick is getting past the judge to do it.
Erasend,
The Bronfmans funded terrorizing lawsuits against those who left NXIVM. In addition to the fear of having their collateral released, I am sure they all feared ruthless litigation if they left DOS.
That is only one connection. I am sure they also funded Porter’s illegal experiments. And, they knew of or highly suspected Raniere’s sexual activities, especially Clare. It was a small community. Perhaps, this is where Glazer will prove willful blindness in the legal sense.
I believe the connections are there. Hopefully, Glazer proves them. And, remember, he does not have to prove anything beyond a reasonable doubt – that is the criminal standard.
His claims will definitely survive this phase of litigation.
If funding terrorizing lawsuits was grounds for successful civil suits, Scientology would have been bankrupted ages ago.
On sexual activity, proving knowing is hard and if do that while doing nothing does her no favors, it’s not required for her to do anything. No action isn’t participating. This would fall into how well jury selection goes.
Funding those terror studies only really matters if they can prove Bronfmans knew where money going. Again jury selection will matter here.
The case is really NXIVM on trial not the Bronfmans. I get that but making the Bronfmans take the blame for all things NXIVM is going to be tricky. In a criminal case, this would fail but in civil cases a jury is 80% emotion, 20% vague understanding of what a fact is. So yeah, it is doable but it’s still a mountain to climb.
Re The Defense Attorneys Filing:
Sarah Bronfman’s attorneys make some very valid arguments. Sarah wasn’t a part of the RICO case and had nothing to do with DOS.
Is Sarah legally liable for funding Rainbow Cultural Gardens because of the actions of other individuals?
So, Sarah writes a check and is not involved in day to day operations. How is she on the hook, for the actions of others she was not employing.
There are a number of fascinating and complex legal issues at play. I’m looking forward to following this case.
***
What is K.R. Claviger’s take and what will the Judge Rule?
Wow Frank. Well done.
I cooked a duck today, in my oven.
Lots of smoke.
No fire.
Alanzo
“Cooking a duck in the oven” is Alonzo’s euphemism for taking a big dump.
Lots of “smoke” means it was extra stinky.
Those RingDing®️ dumps can be pretty potent. That’s why Alonzo craps at the gas station or library.
Wrong! Alonzo craps in his backyard. He don’t own no car and his broke-ass hasn’t paid the water bill.