Raniere’s Rule 33 ‘Historic Level of Proven Government Criminal Activity’ – Accuses Three in FBI of Perjury & Parlato of Starting Mad Dog Hate Campaign

Keith Raniere

Keith Raniere filed a pro se Rule 33 motion for a new trial 30 minutes before the three-year deadline. Raniere is seeking “an immediate evidentiary hearing based on ‘newly discovered evidence.”

Raniere moved to disqualify US District Judge Nicholas G. Garaufis. He filed his motion before Judge Garaufis or another judge “to whom this matter is reassigned.” 

In the motion, Raniere writes of himself in the third person. 

 The court timestamp shows he filed it on June 21, 2022, at 11:30 pm. 

Raniere includes exhibits to bolster his claim the FBI tampered with evidence. Raniere includes “Expert Reports by Dr. J. Richared Kiper, Steven Abrams Esq, and Wayne B. Norris. They are not new but are re-attached from the Rule 33 motion filed on May 3 by attorney Tully.

Raniere writes the experts “concluded to a scientific certainty” that the FBI tampered. He writes, “government actors created, destroyed and changed digital evidence.” Raniere’s experts are “pro-law-enforcement” and “disturbed by their findings.”

Parlato in the Rule 33

I am writing an “Analysis of Allegations of FBI Tampering of Evidence in US v Raniere.”  I include in my report redacted excerpts of seven emails from attorney Neil Glazer to myself.  Raniere’s power of attorney, Suneel Chakravorty, is co-authoring the report.

Suneel wanted Raniere to be able to use the excerpts. I was going to publish them anyway. I had one condition for letting Raniere use the excerpts in his Rule 33. He must agree to include my affidavit. In it, I would state that Raniere sexually abused Camila starting when she was 15. I did not care if he agreed or not. 

It pleased me to have Raniere include my affidavit in his plea for a new trial. For in that affidavit, I state that he is guilty of the despicable crime of raping a child.  I said that up front. I want everyone to know Raniere is guilty. 

But I also feel that the FBI should not cheat to convict guilty criminals.

Glazer represents about 70 ex-Nxivm members suing Raniere in a civil suit. The excerpts show Glazer is an aggressive, dedicated attorney. They raise concerns over whether the FBI acted in bad faith.

My affidavit explains, “I am Raniere’s adversary. I am opposed to Raniere and deplore what he has done. I believe Raniere is guilty of abusing the victim, Camila. He abused her. It was child sexual exploitation.”

I also wrote, “I do NOT think Glazer would participate in tampering or permit a client to do so. One of the best reasons to doubt FBI tampering is Glazer. He represents Camila and her sister, Daniela.”

In his pro se Rule 33,  Raniere lays it on. He writes, “In addition to the government’s premeditated creation, planting, and adjustment of digital evidence, the newly discovered evidence, including the experts’ reports, also demonstrates precise and specific perjury among the major government witnesses, including government agents, as well as government intimidation of potential defense witnesses.”

Moira Kim Penza, lead prosecutor in USA V Raniere

Raniere points out that AUSA Penza said before the trial: “the child pornography is … at the heart of our racketeering conspiracy.” She also said,“the alleged victim of the child pornography charges [Camila] goes throughout this case … there’s very little evidence in this case that does not relate to that victim.”

Raniere tied it in with something Glazer wrote to me. “On April 3, 2019, Glazer wrote to Parlato that Camila would not be testifying, but that ‘Moira [AUSA Penza] told [him], and this is a quote, ‘we have all the evidence we need.’”

Raniere wrote, “The alleged victim, Camila, who was at the ‘heart’ of the case did not testify in the trial. The government relied upon FBI Senior Examiner Brian Booth to date the photos to establish her age in them.”

Raniere says that SFE Booth lied twice and told the truth once.

He testified about EXIF data. He also testified that evidence “does not always come to us sealed” and chain of custody “does not always need to be kept.”.

Raniere wrote, “FE Booth lied repeatedly about EXIF data and chain of custody and yet he told the truth about the camera and CF card being given to him unsealed. Unsealed evidence is a critical issue of admissibility. This evidence was at the ‘heart’ of the case. To admit to this issue of admissibility would, on the face of it, appear to be a serious risk.

“That SFE Booth was willing to[tell the truth about the camera and CF card being given to him unsealed] means either he was certain that it would be admitted [as evidence] or there was some benefit to him, or both. The only benefit to him from admitting break in the chain of custody is that it provided SFE Booth plausible deniability of his involvement in the tampering, for the tampering on the CF card could have taken place before it was given to him, while it was in the custody of SA Elliot McGinnis, or SA Mills.”

Raniere included the FBI chain of custody reports on the camera and camera card in his exhibits.

Raniere also said that FBI Special Agent Christopher Mills “lied” when he said the his office handled the camera “according to the FBI protocol.” Raniere noted that this was established in Tully’s supplement to the Tampering Rule 33.

Lexar camera card similar to the one the FBI used in evidence.

Receipt of evidence items seized at 8 Hale.

Raniere went back to a theme raised by Tully – that the FBI seized the camera and hard drive first at 8 Hale.

“Agents seemed to home in on the items, Raniere wrote. He quoted Dr. Kiper, “It was as if the FBI agents knew what would eventually be ‘found’ on those devices and used at trial.”

The camera was under the desk and hard drive on a shelf.

Evidence Item #1 was the camera with a camera card inside.

Evidence item #2 – the hard drive.

Raniere accuses Daniela of participating in the FBI scheme. He writes, “Daniela testified that she managed the computers and backups at 8 Hale Drive.” He says “Glazer represented Daniela,” and that Daniela is “his favorite” client.

Then he references a Glazer excerpt that predated the raid of 8 Hale.

Glazer wrote: “I am not working on the civil litigation angle at the moment, there are far more important matters to resolve. There are moving pieces you are unaware of, interested eyes beyond the Albany region… We are learning precise locations of evidence, we need time to get rock solid warrants.”

Raniere concludes: “Mr. Glazer writes about ‘precise locations’ and roughly four months later, this comment is solidified as agents strangely collect the camera and hard drive as the top priority, bypassing and ignoring dozens of other evidentiary items along the way.”

Raniere then goes through a list of things he thinks are peculiar:

  1.  Daniela and Lauren Salzman were never asked to identify their own photos on the hard drive, nor the camera that was used, yet they were both asked to describe the photos and the camera.
  2. Neither of them were asked to identify the alleged photos of Camila, despite both knowing her well and Daniela being her sister.
  3. Only FBI SA Michael Weniger identified Camila as being the one in the photos.
  4. Lauren Salzman testified Mr. Raniere took two photos of her, yet on the hard drive there were six in Lauren’s folder on the drive.
  5. Daniela testified that presence or lack of a visible appendectomy scar would determine Camila’s age in the photo. However, she was not asked to view the photos to confirm whether or not there was a scar.
  6. The alleged photos of Camila belonged inside a folder dated the month and day as Daniela’s anniversary with Mr. Raniere (November 2
  7. FBI SA Michael Lever was able to identify a fifteen-year-old Camila in the accidentally discovered photos, yet even her friends sometimes cannot distinguish between her and her sisters.
Raniere say FBI Special Agent Mike Lever and Daniela likely conspired together.

Raniere moves on to witnesses who lied and the government’s intimidation of his witness.

He includes eight witnesses’ affidavits describing their encounters with the prosecution team.

  1. Michele Hatchette,
  2. Danielle Roberts,
  3. Nicki Clyne,
  4. Samantha LeBaron,
  5. Sahajo Haertel,
  6. Brian Elliot,
  7. Marc Elliot,
  8. Brandon Porter.

Parlato Started Hate Campaign

Frank Parlato

Raniere has a few choice words for me:

“Mr. Raniere holds Mr. Parlato to be responsible for crafting and disseminating a false, hate narrative against him and his organization. He believes this narrative was engineered to inspire public outrage through exaggeration. This public outrage, supported by a ‘mad dog’ media, allowed this prosecution to commit malfeasance, which is historical in its premeditation, complexity, the number of actors involved, the high-profile nature of the case, and the credible scientifically certain proof of the malfeasance.

“In including Mr. Parlato’s evidence in this motion, Mr. Raniere is not in anyway condoning Mr. Parlato’s conduct against him or Mr. Parlato’s conduct against anyone who had been involved in his organization NXIVM, or in DOS.”

Hajjar Blamed

He also accuses AUSA Tanya Hajjar of being part of the scheme.

AUSA Tanya Hajjar

He writes, “Because the prosecution failed to correct SFE Booth’s perjurious testimony about chain of custody, and this Court did not intervene, the jury was taught that a broken chain of custody is not abnormal in the FBI.

“Note also that AUSA Hajjar questioned SFE Booth and Mills…. AUSA Hajjar likely knew that the camera was not handled according to protocol, and thus proactively elicited false testimony from Mills. However, even if AUSA Hajjar did not know her witnesses perjured themselves, which would require assuming egregious incompetence and negligence on her part, it does not matter. AUSA Hajjar, and in fact the entire prosecution team, is imputed with knowledge of Booth’s and Mills’ perjury, for they are government agents who testified.”

At the end of the day Raniere wants the judge to “grant a complete reversal of Mr. Raniere’s conviction on all charges, not only because this falsified digital evidence was at the ‘heart’ of the case but because anything less would condone structural error in the form of government criminal malfeasance, reliably proven, that involved, at a minimum, multiple government agents breaking protocol, spoliating and manipulating evidence, and perjuring themselves repeatedly….

“This Court should not condone the prosecution’s violation of Mr. Raniere’s due process nor their Orwellian tactics of methodically silencing ordinary, law-abiding civilians through fear of imprisonment.

“The newly discovered evidence reveals multiple government actors were involved in criminal malfeasance that was executed over an 18+ month period and was orchestrated to deprive Mr. Raniere of his constitutional rights and to dishonestly win a conviction.

“Mr. Raniere moves this Court to grant a public evidentiary hearing so that he, and the public, are allowed to ask the pertinent questions of our public servants.”


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Frank Parlato


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  • Why is it considered sketchy by Raniere’s defenders that the FBI would make a beeline to a camera & hard drive belonging to a criminal known for demanding pornographic photos of his victims, some of whom were underage?

  • You manipulate hurting women into joining your harem, and even con them into doing your dirty work for you. You know carving your initials into their labia, blackmail them into staying, and stealing their money.

    And a mean jury convicts you and a judge sends you to jail. Life is so unfair.

    I would not put framing him past the FBI, but they certainly did not have to.

    I have no doubt KR believes he is being persecuted, but the surprise is that people like Suneel and Nicki do.

  • Again, Frank, I’m confused. I fail to see how any of the emails from Glazer matter at all. None of these claims will win Raniere a new trial.

    1. There is nothing wrong with interviewing witnesses who disclose where evidence may be hidden for the purpose of a search warrant. In fact, it’s needed to get a search warrant. There must be an affidavit (from an officer or directly from the informant) underlying the search warrant, which provides information to the court about what evidence will be seized and where it is located. Search warrants require specificity. It’s a non-claim unless I’m missing something.

    2. Cami not testifying and Penza stating she had enough evidence is, well, nothing. So what? The criminal investigation was “massive” in Glazer’s words. This means nothing.

    3. Regarding Dani, all that matters is if she signed an agreement with Glazer to be part of the civil suit at the time she testified. There’s no way in hell that she did. Dani was already Glazer’s client in the criminal case so I fail to see the big deal about him calling her a client. Even assuming, arguendo, that Dani did not tell the truth, Raniere cannot show that he would have prevailed at trial if she had testified otherwise. The evidence was simply too overwhelming.

    4. The BS claims from the left-overs being threatened by the prosecution was already in Raniere’s motion for a new trial, which, obviously, was denied by the court.

    5. The tampering claim is BS. ’nuff said.

    All of Raniere’s claims are meritless. With the exception of the Dani emails, none of the claims are newly discovered evidence.

    Most importantly, Raniere would have been convicted anyway. This will not win him a new trial.

    FYI: I am not sure the court accepted Raniere’s filing. It is not listed on the docket. Perhaps he lied to you when he said he filed it with 30 minutes to spare.

    • It does not matter. Raniere is merely rehashing the claim about Daniela and the civil lawsuit. Even if it were true, it is not sufficient to overturn the conviction.

      I do not know either if they accepted it or not. It doesn’t matter. It is not going to be approved.

  • Good to see you get some credits for nailing Raniere…..
    But other than that: Keith sending a motion 33 pro se, with an affidavit from Frank attached? It’s crazy. It reeks of desperation.
    I can’t wait to see these appeals denied and then an appeal to the Supreme Court rejected in a few years or so.

    Game over for Vanguard.

  • Huh. What do you know… the 2567th verse of 10,000 Bottles of Beer on the Wall is almost identical to the 2566th!

    Who could have imagined that?

    Viva Executive Success®!!!!!

  • I’m not a big fan of Keith, but I’m also not a big fan of unfair trials. Seems like there’s enough question here to warrant a new one. Thanks for covering this in such detail, Frank.

    • You are probably right about the trial not being fair however I don’t believe there is enough political will to give a sex offender another trial.

      What judge would sign off on that? It would put that judge in a very bad light. Especially, with a guy like Raniere where everything has been sensationalized already in the media. Branding women! 15-year-olds! Slaves! Lying about credentials! Mexican acolytes! Even if Raniere were innocent, all the hype would prevent a new trial from happening.

      • The media did not have to sensationalize this case. The misdeeds, crimes, and abuses were worthy of extreme disgust Everyone hates pedophiles except for pedophiles and their dead-end supporters. If there’s no outrage over creating child pornography – what is there to be outraged over?

        It was completely justified for people to be appalled by the nxivm cult and its travesty of pain inflicted over decades. And it’s clowning volleyball shaped rolly poly cross-eyed evil leader

    • But are you a little fan of Keith?

      What other “unfair trials” have you. Blog commented on or come out to support exposing Amy B?

      Would love to look into them! Do tell.

  • Poor little whiny bitch Keith…grasping at straws as his freedom slips through the cracks haha.

    Does he really think by finding a few DOS slaves he didn’t sexually assault, we will believe he didn’t sexually assault/rape other women? Haha what a fool.

    Once again Frank…another article full of opinions with no facts or new evidence. Bravo!

  • Frank, were you paid in any way for your time or work on this matter?

    It’s mostly same old same old.

    There’s so much that is laugh out loud funny in this filing.

    Like this idea that all three sisters are practically identical. Hilarious. Not true.

    But it’s fun for Keith to actually put it in writing that he thinks all Mexican women and girls look alike.

    Is that his premise for why he was sleeping with all three of the sisters? He just couldn’t tell them apart?

    It’s so insulting to them. “Their friends can’t tell them apart”?!

    They are all so different looking

    Maybe Keith trying to starve all women into the same shape and demanding that they “look uniform” in nude photos was a set up for this excuse the start?

  • This is what desperation looks like. Panicked, bowel-liquifying fear as this coward realizes he really will spend the rest of his life in that prison.

    Conspiracy! Hate! They all lied! That evidence… it’s all fake! The government… the FBI… the media… Parlato… they’re all out to get me… can’t you SEE!

    The coward can’t think straight he’s so scared. Abandon all hope, “Vanguard”. End of the line for you.

    Aristotle’s Sausage is so happy!

    • It is indeed a fine day to grill some wurst!

      Viva Executive Success®!!!!!

  • Maybe, he gets a new trial but I don’t see much changing. Public sentiment against men who abuse 15 year old girls is very strong. Branding was not a crime in itself but sensationalized everything. Maybe, Raniere did some good for some people but he never took responsibility for any of the messes he created. I don’t see much changing as far as his prison status.

    My personal opinion is his sentence is overdone. A 20-25 year sentence would have accomplished the same thing. Getting out of prison at 80 means your life is basically over; but we all need something to live for. Hope for the future is what we all need ….Hope to reconcile one’s life, one’s mistakes and a new future free of the past….

    • You make some decent points. Prison is punitive. People forget that. The recent push about prison being a reforming institution is fairly new. Some crimes are not just about the punishment of the person who committed them.

      They also are sentences to give Justice to the victims and send a message to society about what will be tolerated.

      Honestly I don’t think that’s bad. It’s controversial but that’s one argument people make to keep the death penalty. A lot of criminals will plead and they will reveal bodies and their locations they will give families closure under just the threat of being possibly tried for the death penalty. I don’t want to confuse the cases and the issue by bringing up the death penalty I’m just using it as an example. Punishment is also about deterrent.

      It is about the society and what it will accept in human behavior. And it is about the victims and their families as well. It’s not just about getting somebody into a therapeutic program and helping them get a GED. Again prison is punitive. At its core.

    • He was offered a plea deal of 20 years. He gambled and received 120 years. He’s gambled and lost many times in the past.

      A narcissist can never be wrong even when he obviously is to everyone except to his most loyal of deadender followers.

      John Tighe has asserted he was innocent, but he took a plea deal because he knew the ramifications. He didn’t care for the stain of child pornography on his name as any innocent person wouldn’t, but he weighed the options to his health and remaining life and took it because he’s not a narcissistic megalomaniac like Raniere.

      Unlike the likely probability that John is innocent, Raniere is guilty as hell and fights for his innocence as if he isn’t. Narcissism — which is a reflection of excessive pride — is a disease that can only be “burned” out of you.

      • I didn’t know he was offered a 20 year plea deal. Where was that reported? Can you send a link etc.

      • Yes. Trials are expensive. They cost a lot from the humans who take the stand too. If trials don’t have potentially stiffer sentencing then every guilty narcissist with a thirst for attention and publicity would go that route.

        Again, it’s a deterrent. There are a lot of criminals. A lot of crimes. Courts are. Backed up. Take responsibility. Keith knew he was guilty. You are correct. Vanguard gambled. And the house won.

        • If he was offered 20 year plea deal, he was a fool not to take it. Agnifilo was aware before trial that a guilty verdict was a certainty. I’m sure he made Raniere aware any sentence would start at 20 years+.

          Was Raniere gambling he’d magically be set free? Gambling he’d win on appeal? Hoping he’d die a hero’s death in prison? Hoping he’d only get 15 years or maybe less? Willing to go to prison for life to preserve his image? I’m really curious what Keith was thinking if he did turn down a plea??

  • Can’t see it but I was making a wanking motion while skimming through this. Not seeing anything compelling here that would force a re-trial. Also whatever on the affidavit. Its an appeal on the trial, Frank’s opinion is irrelevant. Not clear on why it was submitted.

    Also not clear on why Raniere filed a pro se appeal if his attorney already filed one on May 3. Why the redundancy? Maybe the lawyers in the crowd can explain the distinction between this and whatever it was his attorney did last month.

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


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