RICO Is Why Glazer Wins and Bronfmans Will Pay Big $$$

By Allison Fenimore

The emotionally conflicted NXIVM half-holdover Damon Brink writes, “Neil Glazer and every single person involved in his law firm, Kohn, Swift, and Graf, are complicit in taking advantage of that caring under the guise of Justice.”

He is talking about NXIVM as a loving, caring community instead of the racketeering enterprise that created mentally disturbed, emotionally arrested individuals like him.

Damon Brink

Damon is dead wrong.

The Bronfmans, Keith Raniere, Allison Mack, Nancy Salzman, Lauren Salzman, Kathy Russell, Nicki Clyne, Karen Unterreiner, Dr. Porter and Dr. Roberts hurt a lot of people. They hurt him but he doesn’t know it.

Clare and Sara Bronfman helped Keith Raniere continue his NXIVM endeavors, or as Moira Penza called it, his racketeering enterprise.


Plaintiffs’ lead attorney, Neil Glazer


Nicki Clyne. You’re going to lose your Subaru.

Nicki Clyne and her 2011 Subaru.

In 2017, New York State and the Northern District of NY federal prosecutors declined to prosecute Raniere and others for DOS, telling would-be complainants theirs were the actions of “consenting adults.”

Glazer was looking to take down Raniere in preparation for suing the Bronfmans.

When the EDNY got involved, Glazer maintained the civil case, which predated the criminal charges, and helped clients pro bono in the criminal. He was working on spec on the civil with retainer agreements that gave his firm a percentage of what they collected in the civil.

Richard Donoghue, then US Attorney for the Eastern District of New York, announced the conviction of Keith Raniere.

Glazer spent hours working pro bono on the criminal case because he knew if Raniere were convicted, the civil case would be a slam dunk against the Bronfmans.

He represented more than a dozen civil clients when they went to speak with the EDNY, including witnesses Nicole, Daniela, Jaye, and Mark Vicente. He worked to get the women he represented restitution after Raniere was convicted.

Nicole, Daniela, Vicente, and others started as civil clients. Glazer had to hold their civil claims until after the criminal was concluded – which took more than 18 months after Raniere’s conviction to sentence the last one –Nancy Salzman.

Daniela and Nicole should be credited because they and Camila, who joined after the criminal trial, had to wait until after the criminal case was concluded to bring their civil claims which are worth millions.

Artist sketch of a woman who looks not unlike Daniela

After five years of planning and working full-time on this, Glazer and his firm, Kohn Swift, who paid his salary and all expenses including substantial travel have a serious investment in this case.

Get Me In Front of a Jury

Do you think the antics of NXIVM dead-enders like Michele Hatchette threatening to name names of plaintiffs and Suneel’s mind-numbing articles about “tampering” will stop their plans?


Let’s dispense with the argument that Clare had nothing to do with the abuse of Nicole, Daniela, and Camila.

Michele Hatchette and Nicole were sisters in DOS.

Clare’s attorneys will argue she had nothing to do with Nicole’s sex trafficking incident because she didn’t know about DOS. She was not present at Camila’s apartment when Camila and Raniere did what they did.

There is a “causal nexus.” A causes B.

Raniere would not have created DOS or tied Nicole on the table and forced Camila to sexually assault her if he didn’t have Bronfman money. Bronfman money probably paid for the apartment.

MK10ART’s painting of Keith Raniere, Clare Bronfman, and Sara Bronfman.

It doesn’t matter if Bronfman knew about DOS.

Nicole, the prosecution’s sex trafficking victim.

A criticism made of Glazer is that his complaint is vague and does not identify who is suing whom.

All seem to be suing everyone.

Keith Raniere and Clare Bronfman

Judge Eric Komitee seems less offended by Raniere and Bronfman than Judge Nicolas G. Garaufis. He seems to be open to bifurcating the case by consumer fraud victims as separate from sex trafficking, peonage, and forced labor plaintiffs.

But Glazer can keep them together as one.

Judge Eric Komitee presides over the civil case against Raniere, the Bronfmans, Clyne, and others.


Judge Nicholas G. Garaufis presided over the criminal trial of Keith Raniere.

That plan has been unveiled if you read between the lines.

But he does not need to explain now.

Glazer knows the civil case can’t be dismissed outright because there are issues of triable fact, and the attempts by the Bronfmans’ attorneys to bifurcate the case before trial will be defeated.

Besides, the judge won’t dare dismiss a civil case that was a landslide criminal case.

Glazer doesn’t need to cough up details at this stage. There will be enough time when the case progresses. This case is going to trial, even if it takes years.

He’ll make his arguments to the jury and show how Bronfman & Bronfman are culpable for plaintiffs’ damages. They have been mentally compromised by NXIVM courses, which would have been impossible without the Bronfmans’ support.

They suffered mental injuries, Glazer alleges, and emotional harm; some require a lifetime of therapy.  The Bronfmans will not escape responsibility.

Bronfmans’ attorneys with well-funded attempts, will try to exploit the system.

Craig Martin of Willkie Farr & Gallagher, LLP of Chicago appears for Clare.

They’ll argue that Bronfman didn’t “fund NXIVM.” For example, they only funded trips to Fiji, and NXIVM had its own revenue and operated as a separate, distinct business.

But money is fungible. So were trips to Fiji.

Fiji is where the so-called “fitness” company exo|eso held VIP trainings, and where NXIVM leadership gathered to plot illegal deeds.

Bikini-clad NXIVM women in Fiji

The winsome Bronfman sisters – especially winsome to plaintiffs.

Glazer’s secret weapon?

RICO, created to prosecute the mob, gives prosecutors broad powers to bring charges and get indictments against individuals indirectly linked with specific crimes.

If you caught a low-level assassin in the act, you have a way of getting to the higher-ups, who usually keep their fingerprints off everything.

How does that factor in civil case?

The Raniere criminal case included one count for RICO – adn another count for RICO Conspiracy. The government charged Clare Bronfman, Allison Mack, Nancy Salzman, Lauren Salzman, and Kathy Russell as co-conspirators with him in a criminal enterprise. They were part of Raniere’s “inner circle” of friends and colleagues who conspired to promote him and committed criminal acts.

The six NXIVM defendants, Upper Row: Kathy Russell, Keith Raniere, Nancy Salzman, LowerRow:  Allison Mack, Lauren Salzman, Clare Bronfman

Neither DOS, NXIVM, nor ESP was alleged to be a criminal enterprise. It was the inner circle of supporters who were the racketeering enterprise.

People, not a company.

The “Inner Circle” of NXIVM/ESP

In a pre-trial hearing on August 21, 2018, Bronfman’s then-attorney, Susan Necheles, told the judge:


NECHELES: People are involved in a criminal enterprise, where NXIVM has not been named a criminal enterprise.

THE COURT: Well, maybe not. But I have a letter here, that I’m not using today, from a lawyer in Philadelphia that says a lot of stuff that is very disturbing and if we credit it, which I’m trying to avoid doing –


That Philadelphia lawyer mentioned is Neil Glazer.

Even though NXIVM was not a criminal enterprise in the criminal case, in his Second Amended Complaint, in the civil lawsuit, Glazer alleges NXIVM IS a criminal enterprise.

He writes, “Plaintiffs file this second amended complaint against the Defendants for conspiring to operate, and for operating, a criminal Enterprise under the “NXIVM” umbrella (the “Enterprise”). Defendants also conspired to participate and participated in a “Venture” to commit sex trafficking, peonage, forced labor, and human trafficking offenses in violation of Chapter 77 of Title 18. The central purpose of the conspiracy, Enterprise, and Venture was to entice Plaintiffs to join NXIVM, which functioned as both a Ponzi scheme and a coercive community.”

Why is NXIVM not alleged as a criminal enterprise in the criminal but is in the civil?

Because the evidence bar is lower. In the criminal, you need proof “beyond a reasonable doubt.” In the civil, you need a “preponderance of evidence.”

Just because the government could not, or chose not to prove NXIVM was a criminal enterprise, doesn’t mean Glazer can’t prove the company was a criminal enterprise in the civil case.

By alleging NXIVM a criminal enterprise, Glazer can tie Bronfmans into anything that happened in the company, like emotional or financial harm, and make them pay.

Former Assistant US Attorney Moira Kim Penza, the lead prosecutor in the Raniere criminal case masterminded a relatively novel RICO approach by making Raniere’s inner circle the enterprise. She did not try to allege that NXIVM or DOS were a criminal enterprise. That would have been hard to prove beyond a reasonable doubt.

Penza now refers to NXIVM as a criminal enterprise, though she didn’t in the criminal case.

Moira Kim Penza, lead prosecutor of USA v. Raniere.

Here is what Penza said on A Little Bit Culty on November 21, 2021:

Moira Kim Penza on A Little Bit Culty


PENZA: So one of the first things I did was really try to figure out who was your [Sarah Edmondson’s] agent, who are your lawyers. And so I think the first people I spoke to were people who were connected to you as entertainment lawyers, not as a lawyer representing you in the context of NXIVM, the criminal organization, but really sitting down with you, that was one of the first experiences that we really had where we started to learn more about this organization and more about what was happening.


PENZA: But the whole way in which NXIVM operated, or certainly one of the primary means and methods of NXIVM – the criminal organization – as we conceived of it, was having this collateral in all forms, right?


The key to Glazer’s success is to show NXIVM and DOS were criminal enterprises, not just the people individually doing crimes. Once NXIVM is proven to be a criminal enterprise, the Bronfmans are responsible for everything, including DOS.

RICO is the key to the civil suit, and Bronfmans were clearly part of the RICO enterprise. They did not need to know everything that happened,

Just like a Mafia ‘made man’ does not know everything that happens in La Cosa Nostra, he is still responsible.

Bronfmans were not the Godfathers, they were the Capos. Without them, there was no NXIVM enterprise.

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  • The criminal case definitely can be helpful in the charges related to fraud and deception. It doesn’t necessary mean a big payday as its going to be hard to prove emotional damage from classes (for most of the plaintiffs). For the plaintiffs suing for more than just bad classes, most engaged in the exact same behavior they are suing for. So things get very murky there. End result is a possibility of victory but not necessarily a big payout.

    The money is the sexual abuse and pedo charges. Problem there is Keith engaged in all of that. If they can make an argument the Bronfmans knew about it and continued to pay for it, then yes big payday.

    But if the argument is “well they gave him lots of money and this is what he used it for” and cannot prove they knew about it, then not so much. The bank (aka the Bronfmans) are rarely, if ever, held responsible for what is done with the money they provide. If they were, pretty much all banks would have been sued into bankruptcy ages ago (see 2008 housing market as just a starting point).

    Giving money to someone and that someone using it badly isn’t proof. Using the justice system to harass people isn’t proof (the only other real argument others are making), otherwise Scientology would have been sued into non-existence a long time ago. There has to be dots connecting Keith’s bad behavior to the Bronfmans knowingly enabling it. Key word there is “knowingly”.

    If that evidence exists, then yeah huge payday for several of the plaintiffs and thus the lawyers.

    And yes the standard for civil cases is basically what the jury feels like that day, but generally people are loath to give millions to people without something significant to make it ok to do it. Bronfmans have Keith as the ultimate scapegoat.

    • Animus Liber:

      How about the willful ignorance argument that even Judge Garaufis made against Clare Bronfman in his sentencing memorandum? Clare Bronfman herself committed crimes on Raniere’s behalf and with Raniere’s approval and she herself must have been aware of all the illegal and criminal acts that she herself committed or commissioned. Therefore, Clare Bronfman cannot claim to have known nothing of crimes, her own involvement and participation in crimes proves it. Clare Bronfman had the opportunity to know but ignored all information and took no note of the information proving Raniere’s crimes and all crimes committed by others and drew no consequences for her own actions.

      This is more than just claiming Clare Bronfman did not know or even suspect anything. This is more than negligence. Clare Bronfman willfully ignored or suppressed everything because she wanted to support Raniere no matter what. Even after many crimes were revealed in the trial, Clare Bronfman was unwilling to distance herself from Keith Raniere and his crimes and continued to support him. This response proves her support of the RICO enterprise run by Raniere and his accomplices. And that includes herself.

  • My perfectly valid comment didn’t even make it through the administration here so there’s that. Guess Fiji comments from both sides of the fence are off limits. Hmm., very interesting!

  • Glazer undermines his own case by having Vicente and Edmunson as victims. If it’s RICO, they are part of the racketeering operation.

  • Glazer is the hero of the Nxivm story. There are very few heroes. Vicente, Edmondson, Toni Natalie, and Mr. Glazer are the front-line Glazer is the vanguard of the movement to stop NXIVM.

    Babs Bouchey, India Oxenberg, and Jim Odato are the second line.

    Frank Parlato, Susan Dones, and O’Hara were in it for spite.

    Glazer did it to help innocent victims.

  • Some four years, ago I warned Frank Report readers that NXIVM was a RICO case
    RICO has both criminal and civil provisions.

    How did I know this fact?
    For over forty years I lived in the Chicago area and in the Federal Court House in Chicago, the Dirksen Court House, there are endless
    criminal and civil cases targeting racketeers.

    Right now, there are two big RICO cases involving Chicago politicians.
    Alderman Ed Burke, who has served for 50 years on the Chicago City Council and is married to Illinois Supreme Court Justice Anne Burke, faces a RICO indictment for shaking down restaurants that want building permits.
    Illinois Speaker of the House Mike Madigan, who has served over 50 years in the Illinois legislature, faces a RICO indictment for shaking down Exelon, the Chicago electric utility, to force them to hire Madigan’s cronies to ghost pay roll jobs.

    Anyone who lives in and around Chicago and reads the newspapers and watches the TV news and listens to radio news knows and understands what RICO is.

    NXIVM is a RICO and Raniere, the Bronfmans, the Salzmans, and Mack are all racketeers.

    • ShadowState,

      You said “Ann Borshin” shouldn’t be allowed in Illinois. I agree! These politicians are too corrupt.

  • Madame Fenimore :

    But money is fungible. So were trips to Fiji.

    Fiji is where the so-called “fitness” company exo|eso held VIP trainings, and where NXIVM leadership gathered to plot illegal deeds.

    Sounds like your confusing Necker Island trip Frank previously wrote about where Allison Mack, K. Kreuk, Catherine Oxenburg, her then husband Casper, Sarah B., and her mother Georgina all gathered to discuss (plot?)…NXIVM business… ..with an actual working business trip to Fiji

    Clare owned the island, why wouldn’t she want to promote a fitness company for her future guests to avail themselves of as she sought to provide every amenity a luxurious vacation/ resort would entail? It’s simply good business sense, the fact that she chose someone with immense knowledge of anatomy and body mechanics who wasn’t afraid of hard work was a wise business decision.

    Pretty sure bikini-clad is proper attire in Fiji ? or is that now illegal too?

  • “He’ll make his arguments to the jury and show how Bronfman & Bronfman are culpable for plaintiffs’ damages. They have been mentally compromised by NXIVM courses, which would have been impossible without Bronfman’s support.

    They suffered mental injuries, Glazer alleges, and emotional harm; some require a lifetime of therapy. The Bronfmans will not escape responsibility.

    The opposite of a placebo is called a nocebo.

    A placebo is an inert substance that you believe will help you, and so when you ingest, swallow, or believe it, it does.

    A nocebo is an inert substance that is suggested will harm you. By ingesting, swallowing or believing a nocebo, so it does.


    When religions use nocebos, “Cult Expert” Steven Hassan called them installed phobias. An example of an installed phobia is telling your flock, such as Catholics do, that if you masturbate you will go to hell after you die. It’s a means of control through fear and terror. L Ron Hubbard used a nocebo by telling Scientologists that if they were exposed to the Xenu story before they were “ready” (meaning before they had paid) then they would get sick and die.

    So yes, religions, both mainstream and minority, use nocebos and installed phobias to control their flocks..

    And as you can see here, nocebos are used by AntiCults, too.

    They tell you that you have been mentally damaged because you held non-mainstream beliefs while you were in a minority religion.

    I’m going to love seeing Neil Glazer taking a page from L Ron Hubbard’s playbook in his attempt to make millions using his, and the government’s, installed phobias. He’s going to have to prove that taking courses or holding certain beliefs in NXIVM caused real harm.

    And that is just hilarious.

    It’s going to be a highly entertaining next couple of years.


    • Alanzo-

      Alanzo, much like Scott Johnson’s understanding of pyramid schemes; your conceptual perspective of the anti-cult, dogmatic, identity is altogether fascinating.
      I thank you, Alonzo, for your convoluted explanation of such a simple subject.

    • — It’s a means of control through fear and terror.

      So is the law. Don’t sell drugs, steal, rape, or murder someone or you’ll get a long prison sentence or worse (the death penalty). So is saying, don’t touch that fire on the stove or it can permanently damage your hand and cause severe pain.

      Aloonzo doesn’t think that people can determine from an objective criteria what is harmful and what is not.

      He thinks he’s informing people when it’s just a guise to throw out his stupid anti-cult dichotomy, thinking people are ignorant of what is precisely the point of the law.

      • “Aloonzo doesn’t think that people can determine from an objective criteria what is harmful and what is not.”

        Using objective criteria, please assist us in determining how being exposed to, and even believing, non-mainstream beliefs causes harm or damage.


    • Alanzo, since Frank finds you such a fine fellow, maybe he could hook you up with his other best buddy, Scott Johnson? You guys are a match made in heaven. I think there could be a bromance if you give it a chance.

  • That is a logical and well presented explanation. Now please explain why Mark Vincente is a plaintiff and Sarah Bronfman is a defendant. Why is Sarah Edmondson a plaintiff and Allison Mack a defendant. Why is India Oxenberg a plaintiff? Weren’t everyone I listed part of the criminal enterprise? What distinguishes them?

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.

IMDb — Frank Parlato

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