Suneel Chakravorty has filed an affidavit in support of Keith Raniere’s lawsuit against the policy of his prison, USP Tucson.

Raniere is suing the US Attorney General, Merrick Garland; the Federal Bureau of Prisons director, Michael Carvajal; the warden at USP Tucson, Barbara VonBlankensee, and a USP Tucson staff member, Lieutenant Anthony Gallion, in their official capacities.

The lawsuit aims to have the privileges to speak with Chakravorty, his power of attorney, by phone and in-person restored. USP Tucson officials told Chakravorty in May 2021 that he could no longer visit Raniere in person.

This month USP Tucson Lieutenant Anthony Gallion informed Raniere that his phone contacts were scrubbed and that he would have to reapply for them. Raniere claims in his lawsuit that the lieutenant also told him that Chakravorty would not likely be approved for contact.

Raniere alleges this is retaliation for filing a Rule 33 motion claiming the FBI tampered with evidence. He further argues that Chakravorty’s communications with him are critical since his deadline for filing additional Rule 33 motions is June 19. 

Chakravorty’s affidavit is published below. Frank Report added photos were applicable. However, there were no photos in his affidavit.

Chakravorty’s Affidavit

 

I, Suneel Chakravorty, swear under penalty of perjury that the following is true to the best of my knowledge:

POWER OF ATTORNEY

1

Keith Raniere, the Plaintiff, has designated me as his attorney-in-fact.

2

I graduated from Harvard College in 2011 with a degree in Mathematics.

3

I have a background in computer technology.

4

From 2015 to 2018, I co-founded and ran a software consulting company in New York City.

5

I have been a software and data science instructor since 2014.

6

I attended every day of Mr. Raniere’s six-and-a-half-week trial in 2019.

7

I am not a witness, co-conspirator, or co-defendant in Mr. Raniere’s criminal case in the Eastern District of New York.

8

In the fall of 2019, after the trial, I met with Mr. Raniere and shared my observations about his criminal case with him.

9

Raniere was adamant that he was innocent of child pornography and related convictions.

10

Raniere alleged the digital evidence used for those charges was false.

11

I shared with Mr. Raniere that I thought that the government expert witness misrepresented the reliability of the digital evidence.

12

Raniere asked if I would help him investigate possible government tampering with the digital evidence and I agreed.

13

I received a file system “metadata” spreadsheet, including file names, dates, and times from the trial counsel team. The spreadsheet did not contain any photographic content.

14

I examined the spreadsheet and identified certain anomalies.

15

Raniere examined a similar spreadsheet and identified certain anomalies.

16

Based on our analyses, I concluded that Mr. Raniere’s tampering theory warranted further investigation by computer forensics experts.

17

I hired computer forensics experts to conduct an analysis. They concluded that manual alterations appeared to have taken place, and the government witness had testified falsely about the reliability of the digital evidence.

Raniere and I spoke about this information and analysis.

19

Before his sentencing in October 2020, Mr. Raniere asked me if I would agree to be his Power of Attorney for all legal, financial, and public relations matters.

20

In January of 2021, I signed a contract to act as Power of Attorney for Mr. Raniere.

21

As Power of Attorney, I retained additional experts to analyze the information and examine the initial experts’ preliminary information and findings rigorously and skeptically.

22

The experts concluded that certain anomalies could only be explained by deliberate manipulation and forgery.

23

Raniere’s criminal defense team retained the experts and gave them access to discovery materials. The experts corroborated their preliminary findings.

24

As Power of Attorney, I stand in Plaintiff’s shoes in various matters and can legally make decisions as though I were Mr. Raniere.

25

I take this responsibility seriously and want to ensure that every action I take is one Mr. Raniere wishes to be made.

26

I cannot conduct these duties ethically without regularly communicating with Mr. Raniere.

MANAGER OF LEGAL TEAM/PARALEGAL TO ATTORNEY JOSEPH TULLY

28

The experts’ findings convinced Mr. Raniere’s attorney, Joseph Tully, to draft and file a Rule 33 motion to reopen Mr. Raniere’s criminal case.

29

I act as a paralegal to attorney Tully for the purposes of the Rule 33 petition.

30

I have knowledge of technical and circumstantial evidence vital to Mr. Raniere’s criminal case, because of my role in retaining experts to analyze the digital information and my own in computer technology.

31

My expertise in data analysis allows me to translate the technical world of forensic data to Plaintiff’s legal team.

32

My knowledge of the facts of this case allows me to translate concepts and streamline communication between Mr. Raniere, the computer forensics experts, and the legal team.

33

After securing the opinions of the experts, my role evolved into paralegal and manager of the legal team. I am working to overturn the improper conviction of his criminal case.

34

As legal manager for Plaintiff, I have retained and discharged members of his legal team as circumstances warranted.

 

Attorneys Who Formerly Worked on Raniere’s Post Conviction Issues

35

As paralegal and legal manager, I helped with the Rule 33 motion. I will assist in preparing the attorneys and experts for a hearing on the Rule 33 petition.

36

I will also help the attorneys prepare additional Rule 33 motions based on newly discovered evidence. These must be filed in a month. June 19, 2022 is the third anniversary of Mr. Raniere’s conviction and the time bar for Rule 33 motions.

37

Raniere and I must have regular communication before this critical legal deadline expires.

38

I act on Plaintiff’s behalf, as Power of Attorney, to represent his financial and legal issues. Among these issues is the estate of Mr. Raniere’s deceased partner, Pamela Cafritz, currently in probate.

39

I also communicate with the mother of Mr. Raniere’s son in matters concerning his parenting.

Mariana and Keith Raniere with their son in 2017.

PAST AFFILIATION WITH NXIVM

40

Raniere founded an organization called NXIVM in 1998.

41

I was not a member of this organization.

42

NXIVM had no members.

43

NXIVM consisted of companies that offered self-development courses to over 17,000 students.

44

Between October 2016 and June 2018, I took courses from NXIVM-affiliated companies.

45

In June 2018, NXIVM ceased operations.

46

Raniere and five other individuals, who were all involved with NXIVM, including NXIVM president Nancy Salzman, were indicted on racketeering charges. See Second Superseding Indictment,

47

Although the co-defendants in the criminal case were all involved in NXIVM, NXIVM was not the alleged racketeering enterprise.

48

Raniere’s “inner circle” was the alleged racketeering enterprise.

49

In the criminal trial of Mr. Raniere, the government identified members of the so-called “inner circle.” I was not included in that group. See “Government Exhibit 362: The Inner Circle.” .

50

NXIVM has never been adjudicated to be a criminal enterprise.

51

The Honorable Judge Nicholas G. Garaufis sentenced Mr. Raniere, on October 27, 2020, to 120 years in prison, followed by a lifetime of supervised release.

52

In the criminal judgment, Judge Garaufis imposed special conditions on Mr. Raniere’s supervised release, including that, once released, Mr. Raniere “shall not associate in person, through mail, electronic mail, or telephone with any individual with an affiliation to Executive Success Programs, NXIVM, DOS, or any other NXIVM-affiliated organizations.”

53

The judge did not impose that same condition for Mr. Raniere’s 120-year sentence, for which he is currently incarcerated.

54

There is no court order prohibiting Mr. Raniere, while incarcerated, from associating with anyone who has had a past affiliation with NXIVM.