Raniere Thwarted, Tried to Kill Payments to 21 Victims – DOJ Paying Anyway

[Continued with pages 19 through 22 of Memorandum and Order.]

c. Uncompensated Work

TVPA victims are entitled to recover the value of their unpaid
labor and services, calculated as “the greater of the gross income
or value to the defendant of the victim’s services or labor or the
value of the victim’s labor as guaranteed under the minimum
wage and overtime guarantees of the Fair Labor Standards Act.”
18 U.S.C. § 1593(b)(3). The victims performed labor and ser-
vices not for a single employer, but rather for the benefit of DOS
masters to whom they were indentured. Because the Fair Labor
Standards Act (“FLSA”) applies only to employers who earn at
least $500,000 in annual revenue, see 29 U.S.C. §
203(s)(1)(A)(ii), DOS masters are not covered employers and
their slaves do not have the protection of minimum wage and
overtime guarantees under the FLSA. Accordingly, the value of
the victims’ labor must be calculated based on the “gross income
or value to the defendant.” 18 U.S.C. § 1593(b)(3).

The Government’s proposed methodology for calculating the
value of DOS victims’ unpaid labor looks to the nature of the
work performed, identifies a relevant job classification used by
New York State’s Bureau of Labor Statistics, and uses the mean
hourly wage for that job classification from the year in which the
work was performed to determine the value of the defendant’s
work on a per-hour basis. (See Gov’t Restitution Ltr. at 8-9.) Thus,
for example, the Government uses the mean hourly wage for the
job classification “typist” for a DOS victim who transcribed re-
cordings, and it uses the mean hourly wage for the job
classification “executive administrative assistant” for a DOS vic-
tim who performed administrative work. (See Xxxxx Xxxxxxxx
Restitution Worksheet; Xxxxx Xxxxxxxx Restitution Work-
sheet.) The Government uses the mean hourly wage for the job
classification “personal care and service worker” in order to cal-
culate the value of DOS victims’ labor for the hours spent “on

20

call” in order to satisfy DOS masters’ expectation of slaves’ 24-
hour “readiness.” (See Gov’t Restitution Ltr. at 8-9.)

The court finds that this is a sound methodology for approximat-
ing the value of DOS victims’ unpaid labor. The nature of the
victims’ labor and services, and the circumstances under which
they were obtained, are so unusual that ascribing an appropriate
job classification and hourly wage is a difficult task. The Govern-
ment’s recommended method assumes that the victims, if fairly
compensated, would have been paid the mean salary for the rec-
ognized category of labor that most closely approximates the
work they performed. The court agrees that applying this as-
sumption allows for a reasonable approximation of the value of
the victims’ labor. If the defense believes that certain job classifi-
cations recommended by the Government overstate the value of
the work performed by victims, it may seek to persuade the court
to use alternative job classifications in applying this methodology.

Several TVPA victims seek restitution not only for the specific
work assignments they performed at the behest of their DOS
masters, but also for their obligation to be “on call” for their DOS
masters at every hour of the day and night. In connection with
that responsibility, they seek to recover the mean salary of a “per-
sonal care and service worker” for every hour of their
membership in DOS during which they were not performing
other labor. (See, e.g., Xxxxx Xxxxxxxx Worksheet; Xxxxx
Xxxxxxxx Worksheet; Xxxxx Xxxxxxxx Worksheet.) DOS slaves
were subjected to “readiness” drills that required them to re-
spond to a master’s message within sixty seconds, at any hour, or
be “punished.” (Trial Tr. at 4378:25-4379:10.) The purpose of
these drills, they were told, was to ensure that they were “con-
stantly thinking about [their] commitment to [DOS]” and that
their masters “knew where [they] were at all times.” (Id. at
4173:17-21.) A slave’s punishment for failing to meet a master’s

21

“readiness” demands included, in some instances, being paddled
with a leather strap on her bare bottom. (Id. at 1635:3-6,
1636:16-1637:1.) DOS masters intended for their slaves to un-
derstand that their “master was supposed to [be their] highest
priority and that [their] main job as a slave was to always be
thinking about them . . . and that should be the highest priority
always above all other things.” (Id. at 1642:1-5.)

Raniere questions the appropriateness of compensating victims
for 24 hours of daily labor. (Raniere Restitution Ltr. at 22.) The
court recognizes the unusualness of this form of “labor,” which
defies easy comparison to any kind of work that exists in the reg-
ular economy. But the idiosyncratic nature of DOS slaves’
“readiness” obligations does not negate the fact that they de-
manded lower-ranking DOS members be perpetually available,
at the exclusion of other activities or opportunities to earn in-
come. Trial testimony revealed at least one instance in which a
DOS slave was required to forgo a paid work opportunity because
it conflicted with her commitment to DOS. (See id. at 4391:12-
4392:4.) The Second Circuit has recognized that a court may
award restitution to victims of forced labor on the basis of 24-
hour workdays for which they worked in an “on call” capacity.
See United States v. Sabhnani, 599 F.3d 215, 255-57 (2d Cir.
2010). The court therefore agrees with the Government that DOS
victims’ restitution awards must compensate them for the exclu-
sive, around-the-clock nature of their commitment. Moreover,
because DOS slaves were required to respond to the whims of
their masters (and, in some cases, to those of Raniere) at any
hour, without notice, the court finds that their on-call obligations
were sufficiently analogous to the work of a “personal care and
service worker” to render that an appropriate job classification.

d. Attorneys’ Fees and Legal Costs

Several TVPA victims have submitted claims for recovery of at-
torneys’ fees incurred in connection with these proceedings.

22

[Continued with pages 13 through 16 of Memorandum and Order.]

partner’s employment. (Id. at 1732:13-22.) She was branded on
her pelvic area, on the same day as Lauren Salzman’s other DOS
slaves. (Id. at 2197:8-15.) The court therefore finds by a prepon-
derance of the evidence that Amanda was a lower-ranking
member of DOS during the relevant period.

In addition to Salzman’s testimony about the centrality of labor
and a “full-time commitment” to her slaves’ involvement in DOS,
she specifically testified that she directed her slaves to “review[]
legal contracts and d[o] legal research.” (Id. at 1671:10-23,
1674:5-13.) Salzman also testified that Amanda was an attorney,
and Amanda’s restitution claim lists “[l]egal for Lauren” as a DOS
assignment to which she devoted 30 hours. (See id. at 1732:10-
12; Xxxxxx Xxxxxxx Restitution Worksheet.) The court there-
fore finds by a preponderance of the evidence that Amanda
engaged in uncompensated labor in connection with her role in
DOS, and it determines that she is a victim of a qualifying offense
under the TVPA.

b. Putative TVPA Victims Not Entitled to Restitution on the
Basis of Existing Record

At this time, the court cannot find by a preponderance of the
available record evidence that the following individuals were vic-
tims of forced labor and/or sex trafficking offenses. The court will
consider sworn testimony submitted by the parties in connection
with their subsequent letter briefs that relates to these individu-
als’ eligibility for restitution under the TVPA, including testimony
that corroborates or disputes facts set forth in the PSR or Victim
Impact Statements.

Camila Xxxxxxxxx (“Jane Doe 2,” “Camila”): Trial testimony
established that Jane Doe 2 was a member of DOS, but as a “first-
line master” rather than a lower-ranking slave. (Id. at 1509:15-
23, 1738:3-1739:7.) While she participated in at least one DOS-
related sexual encounter with Raniere and Jane Doe 5, the testi-
mony at trial did not establish whether her participation in that

13

encounter was specifically compelled by her involvement with
DOS. (See PSR ¶ 107.) Nor does the trial testimony establish by
a preponderance of the evidence that she engaged in uncompen-
sated labor compelled by her membership in DOS. Accordingly,
the court lacks sufficient evidence to conclude, at this time, that
Jane Doe 2 is a statutory victim of Raniere’s forced labor or sex
trafficking offenses under the TVPA. If presented with unrebut-
ted sworn testimony describing Jane Doe 2’s performance of
uncompensated work or participation in a sexual act in connec-
tion with her role in DOS and at the direction of a higher-ranking
DOS member to whom she owed obedience, the court would be
better positioned to determine that Jane Doe 2 is a qualifying
victim under the TVPA.

The court also notes that Jane Doe 2 may be entitled to manda-
tory restitution under 18 U.S.C. § 2259, which provides for full
restitution for victims of child pornography offenses. Covered of-
fenses under that statute include 18 U.S.C. § 2252, which the jury
found that Raniere had violated as a predicate act for his racket-
eering conviction. (See PSR ¶¶ 2, 8.) The court encourages the
parties to address the question of Jane Doe 2’s eligibility for res-
titution under § 2259 in their supplemental letter briefs.

Xxxxx Xxxxxxxx (“Additional Jane Doe 34,” “Xxxxx,” “Addi-
tional DOS Victim 3”): Multiple trial witnesses referred in their
testimony to Additional Jane Doe 34 as a DOS slave who re-
ported to Additional DOS Victim 2, a DOS slave who served
under Mack. (See id. at 1865:15-25, 4408:19-4409:7, 5104:11-
13.) The Government introduced into evidence at trial an email
from Additional DOS Victim 2 to Mack describing collateral that
Additional Jane Doe 34 had submitted and the expectation of
additional forthcoming collateral. (Id. at 5103:18-5104:24.) The
court therefore finds by a preponderance of the evidence that Ad-
ditional Jane Doe 34 was a lower-ranking member of DOS during
the relevant period.

14

The PSR states that Mack and Additional DOS Victim 2 directed
Additional Jane Doe 34 “to read and edit 100 articles for Raniere
during a one-month period” and “encouraged [her] to have a
sexual relationship with Raniere.” (PSR ¶ 121.) Raniere objected
to this portion of the PSR on the grounds that it was based on the
accounts of putative victims who had not testified. (Raniere Obj.
to PSR at 22.) Additional Jane Doe 34 submitted a Victim Impact
Statement that describes “being groomed to be a sexual partner
for [Raniere]” and engaging in repeated sexual activity with him.
(Xxxxx Xxxxxxxx Victim Impact Stmt. at 6-7.) However, because
the only accounts of Additional Jane Doe 34 engaging in uncom-
pensated labor or sexual activity are from unsworn sources, the
court cannot find by a preponderance of the evidence at this time
that Additional Jane Doe 34 was a victim of forced labor or sex
trafficking in connection with her role in DOS.

Xxxxx Xxxxxxxx (“Additional Jane Doe 36,” “Xxxxxxx”): Jane
Doe 8 testified that she recruited Additional Jane Doe 36 into
DOS to be her slave, at Mack’s urging and with Mack’s assistance,
and that she collected collateral from Additional Jane Doe 36.
(Id. at 4387:3-4388:19, 4390:9-4391:6.) The court therefore
finds by a preponderance of the evidence that she was a lower-
ranking member of DOS.

At trial, the Government published into evidence an email ex-
change between Additional Jane Doe 36 and Raniere, in which
they made plans to meet outside at approximately 4:15 a.m. for
a “walk,” after Raniere asked if she was “available at all hours of
the night.” (Id. at 5107:9-5109:13.) In a Victim Impact Statement
submitted to the court, Additional Jane Doe 36 describes how
Mack groomed her for a sexual relationship with Raniere but im-
plies that no such relationship was consummated. (Xxxxx
Xxxxxxxx Victim Impact Stmt. at 1.) Additional Jane Doe 36
does describe, in her statement, performing uncompensated
work including data entry as an aspect of her participation in

15

DOS. (Id.) However, because the court does not have sworn tes-
timony regarding Additional Jane Doe 36’s unpaid labor, it
cannot at this time find by a preponderance of the evidence that
she performed such labor.

Additional Putative Victims: The court also finds that it has in-
sufficient record evidence, apart from unsworn Victim Impact
Statements, to corroborate eight additional putative TVPA vic-
tims’ involvement in DOS or performance of unpaid labor and/or
sexual acts pursuant to such involvement. Some of these individ-
uals were not discussed in the trial testimony at all; others were
mentioned briefly, but the testimony did not establish any details
of their recruitment into DOS, position in DOS, participation in
obligatory DOS rituals, or performance of unpaid labor or sexual
acts in connection with their DOS membership. The individuals
in question are: (1) Xxxxx Xxxxxxxx (“Additional Jane Doe 8”);
(2) Xxxxx Xxxxxxxx (“Additional Jane Doe 14”)6; (3) Xxxxx
Xxxxxxxx (“Additional Jane Doe 15”); (4) Xxxxx Xxxxxxxx
(“Additional Jane Doe 25”); (5) Xxxxx Xxxxxxxx (“Additional
Jane Doe 30”); (6) Xxxxx Xxxxxxxx (“Additional Jane Doe 35”);
(7) Xxxxx Xxxxxxxx; and (8) Xxxxx Xxxxxxxx.

2. Identification of Compensable Losses

Eligible victims under the TVPA are entitled to mandatory resti-
tution totaling the “full amount of [their] losses,” including “any
costs incurred, or that are reasonably projected to be incurred in
the future, by the victim, as a proximate result of the offenses

____________________________________________________
6 While the Government did not identify Additional Jane Doe 14 as a pu-
tative TVPA victim, the court notes that her Victim Impact Statement, a
version of which she read at Raniere’s sentencing, suggests that she was a
member of DOS and that she had a sexual relationship with Raniere. (See
Stc’g Tr. at 87:5-88:25.) The court therefore includes her among the puta-
tive DOS victims who have submitted restitution claims, but for whom the
court lacks sufficient evidence to find are “victim[s]” within the meaning
of the TVPA.

16

These are the first 6 pages of a total of 32 pages of Memorandum and Order.
_____________________________________________________________

Case 1:18-cr-00204-NGG-VMS Document 1036 Filed 05/28/21 Page 1 of 32 PageID #: 19427

MEMORANDUM & ORDER
18-CR-204 (NGG)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
__________________________________________________________________________

UNITED STATES OF AMERICA,

-against-

KEITH RANIERE

Defendant.
__________________________________________________________________________

NICHOLAS G. GARAUFIS, United States District Judge.
On June 19, 2019, following a six-week trial, a jury convicted
Defendant Keith Raniere of racketeering, racketeering conspir-
acy, wire fraud conspiracy, forced labor conspiracy, sex
trafficking conspiracy, and two counts of sex trafficking. (Jury
Verdict (Dkt. 735).) On October 27, 2020, this court sentenced
Raniere principally to a 120-year term of imprisonment. (Stc’g
Mem. (Dkt. 966) at 18-19.) At that time, the court directed the
Government to submit any claims of restitution within 90 days.
(Id. at 20; Tr. of Oct. 27, 2020 Stc’g of Keith Raniere (“Stc’g Tr.”)
(Dkt. 1002) at 154.)

On January 27, 2021, the Government provided the court with
copies of the restitution requests it had received from putative
victims, a letter setting forth its proposed methodology for eval-
uating those requests, and its recommendations regarding
restitution. (See Jan. 27, 2021 Letter re Restitution ( “Gov’t Res-
titution Ltr.”) (Dkt. 997); Ex. A. to Restitution Ltr. (“Gov’t
Recommendations”).) In an order dated January 27, 2021, the
court acknowledged receipt of the Government’s submission and
indicated that it would award restitution after the Defendant had
an opportunity to respond. (See Jan. 27, 2021 ECF Order.) Rani-
ere filed a response on March 23, 2021. (See Raniere Letter in
Reply to Gov’t’s Request for Restitution (“Raniere Restitution
Ltr.”) (Dkt. 1018).)

1

The court has reviewed the parties’ submissions and has made
certain factual and legal determinations, as set forth below, that
will guide the terms of its forthcoming restitution order. The
court has also identified certain issues that warrant further brief-
ing and, where available, supplemental evidence. Accordingly,
the court DIRECTS the parties to submit supplemental letter
briefs, along with any necessary exhibits and affidavits, and for
the Government to submit a revised set of restitution recommen-
dations that are consistent with the findings of fact and legal
conclusions set forth below.1

I. BACKGROUND
Raniere was convicted of seven counts of conviction, as follows:
• Count One: Racketeering Conspiracy, in violation of 18
U.S.C. §§ 1962(d) and 1963(a). (Presentence Investiga-
tion Report (“PSR”) ¶ 2.)
• Count Two: Racketeering, in violation of 18 U.S.C. §§
1962(c) and 1963(a). (PSR ¶ 3.)
• Count Six: Conspiracy to provide and obtain forced labor,
in violation of 18 U.S.C. § 1594(b). (PSR ¶ 20.)
• Count Seven: Wire Fraud Conspiracy, in violation of 18
U.S.C. §§ 1349 and 1343. (PSR ¶ 21.)
• Count Eight: Sex Trafficking Conspiracy, in violation of
18 U.S.C. §§ 1594(c) and 1591(b)(1). (PSR ¶ 22.)

_______________________________________________________________
1 The court requests that the Government, in making its revised restitution
recommendations, specify for each recommended award exactly which of
the claimed losses it regards as compensable, and the amount(s) that it
recommends awarding in order to compensate for those losses, so that the
court and Defendant can easily discern how the Government arrived at the
total figures for each of its recommended awards.

2

• Count Nine: Sex Trafficking of Jane Doe 5, in violation of
trafficking of 18 U.S.C. §§ 1591(a)(1), (a)(2), and (b)(1).
(PSR ¶ 23.)
• Count Ten: Sex Trafficking of Jane Doe 8, in violation of
trafficking of 18 U.S.C. §§ 1591(a) and (b)(1). (PSR ¶
24.)

The two racketeering counts of conviction are predicated on nu-
merous indictable acts including, inter alia, sexual exploitation of
a minor, Jane Doe 2; identity theft and conspiracy to commit
identify theft of multiple individuals (Jane Doe 1, James Lop-
erfido, Edgar Bronfman, Sr., Jane Doe 3, and Jane Doe 7);
trafficking and document servitude of Jane Doe 4; and sex traf-
ficking and forced labor of Jane Doe 5. (PSR ¶¶ 4, 6-7, 9-11,13-
15, 17-27.) Counts Six, Seven, and Eight concern conspiracies by
Raniere and his co-defendants to obtain labor, assets, and the
performance of sexual acts from lower-ranking members of a se-
cret organization known as “DOS.” (PSR ¶¶ 20-22.) Counts Nine
and Ten concern the sex trafficking of two individual lower-rank-
ing DOS members. (PSR ¶¶ 23-24.)

To date, 100 putative victims have submitted requests for resti-
tution, including Jane Doe 2, Jane Doe 4, Jane Doe 5, Jane Doe
8, and James Loperfido, as well as several additional lower-rank-
ing members of DOS, and many individuals who were not
affiliated with DOS but who nonetheless claim that they were
harmed by Raniere and his co-defendants’ criminal conduct. (See
Gov’t Restitution Ltr.)

II. LEGAL STANDARD

In evaluating restitution claims, the court recognizes that “the
Government bears the burden of proving a victim’s actual loss by
a preponderance of the evidence.” United States v. Finazzo, 850

3

F.3d 94, 117 (2d Cir. 2017). 2 The Second Circuit has “never used
the term ‘actual’ in this context to mean ‘mathematically precise’”
or “adopted a one-size-fits-all standard of precision for applica-
tion in restitution cases.” United States v. Gushlak, 728 F.3d 184,
195 (2d Cir. 2013). Rather, what is required is “only a reasonable
approximation of losses supported by a sound methodology.” Id.
at 196.

Two statutes relevant to this case provide for mandatory restitu-
tion for victims of certain crimes.3 First, the Trafficking Victims
Protection Act of 2000 (“TVPA”) provides for mandatory restitu-
tion for “the full amount of the victim’s losses” for crimes
including forced labor, sex trafficking, and document servitude.
18 U.S.C. § 1593(b)(1). In Raniere’s case, counts Six (forced la-
bor conspiracy), Eight (sex trafficking conspiracy), Nine (sex
trafficking of Jane Doe 5), and Ten (sex trafficking of Jane Doe
8) are covered offenses that give rise to mandatory restitution
under the TVPA, as is Racketeering Act Nine (forced labor and
document servitude of Jane Doe 4). The TVPA defines “victim”
as “the individual harmed as a result of a crime under this chap-
ter.” Id. § 1593(c).

Under the TVPA, victims are entitled to full compensation for
“any costs incurred, or that are reasonably projected to be in-
curred in the future, by the victim, as a proximate result of the
offenses involving the victim,” including, inter alia, “medical ser-
vices relating to physical, psychiatric, or psychological care,” “lost
income,” and “reasonable attorneys’ fees.” Id. §§ 1593(b)(3),

____________________________________________________________

2 When quoting cases and unless otherwise noted, all citations and quota-
tion marks are omitted, and all alterations are adopted.
3 As noted below, the court believes that Jane Doe 2 may be entitled to
mandatory restitution under an additional statute, the Amy, Vicky, and
Andy Child Pornography Victim Assistance Act of 2018, and it asks the
parties to address her eligibility to recover under that statute in their sub-
sequent letter briefs. See 18 U.S.C. § 2259.

4

2259(c)(2). A victim’s compensable losses under the TVPA also
include “the greater of the gross income or value to the defendant
of the victim’s services or labor or the value of the victim’s labor
as guaranteed under the minimum wage and overtime guaran-
tees of the Fair Labor Standards Act.” Id. § 1593(b)(3).

Second, the Mandatory Victim Restitution Act of 1996 (“MVRA”)
requires that defendants convicted of certain crimes, including
crimes of violence or offenses against property that cause a “phys-
ical injury or pecuniary loss” to “an identifiable victim,” “make
restitution to the victim of the offense.” 18 U.S.C. § 3663A(a)(1),
(c). The MVRA applies to certain of Raniere’s crimes of convic-
tion, including racketeering, racketeering conspiracy, and wire
fraud conspiracy. (See PSR ¶ 166.)

The MVRA defines “victim” as “a person directly and proximately
harmed as a result of the commission of an offense for which
restitution may be ordered including, in the case of an offense
that involves as an element a scheme, conspiracy, or pattern of
criminal activity, any person directly harmed by the defendant’s
criminal conduct in the course of the scheme, conspiracy, or pat-
tern.” Id. § 3663A(a)(2). “In restricting its definition of ‘victim’ to
persons proximately harmed by the defendant’s acts, the MVRA
aims to limit restitution to those harms that have a sufficiently
close connection to the conduct at issue.” United States v. Thomp-
son, 792 F.3d 273, 277 (2d Cir. 2015). Thus, the MVRA’s
“definition of ‘victim’ governs the calculation of the reimbursable
loss itself.” Id.

“[C]ourts have uniformly read [the MVRA] to provide for resti-
tution payable by all convicted co-conspirators in respect of
damage suffered by all victims of a conspiracy, regardless of the
facts underlying counts of conviction in individual prosecutions.”
United States v. Boyd, 222 F.3d 47, 50 (2d Cir. 2000). However,
the MVRA “does not authorize the court to order a defendant to
pay restitution to any person who was not a victim” of an offense

5

of conviction. United States v. Reifler, 446 F.3d 65, 121 (2d Cir.
2006). “While the language [in the MVRA’s definition of ‘victim’]
expands what it is that will give rise to compensable loss when a
scheme, conspiracy or pattern is involved, the reference point to
which such conspiracy is tied remains the ‘offense’ of which the
defendant has been convicted.” In re Local #46 Metallic Lathers
Union & Reinforcing Iron Workers & Its Associated Benefit & Other
Funds, 568 F.3d 81, 87 (2d Cir. 2009). In other words, conduct
committed “in the course of the scheme or conspiracy [may] be
considered as a basis for determining compensable harm” only if
the “scheme, conspiracy, or pattern of criminal activity” that en-
compasses that conduct is an element of the offense of
conviction. Id.

Where more than one defendant has contributed to a victim’s
loss, “the court may make each defendant liable for payment of
the full amount of restitution or may apportion liability among
the defendants to reflect the level of contribution to the victim’s
loss and the economic circumstances of each defendant.” 18
U.S.C. § 3664(h). If a defendant owes restitution to multiple vic-
tims, “the court may provide for a different payment schedule for
each victim” based on the victims’ economic circumstances and
the nature and extent of their losses. Id. § 3664(i).

III. DISCUSSION
The Government recommends that the court award restitution to
25 of the 100 putative victims who submitted claims in connec-
tion with this case. 4 (See Gov’t Recommendations.) The
Government identifies 18 of those 25 claimants as victims under
§ 1593 of the TVPA. The other claimants, including the seven to

__________________________________________________
4 Based on the representations in the Government’s letter of January 27,
the court includes in this tally Jane Doe 4, for whom the Government has
not yet formally recommended a specific restitution award because it was
not able to review her request in connection with its prior submission and
recommendation. (See Gov’t Restitution Ltr. at 4, 4 n.3.)

6

Here we go again

https://nypost.com/2022/07/23/manhattan-cult-osg-bought-compound-upstate-uses-forced-labor/

Clare Bronfman is paying too much for her car insurance.

She must pay less. This is a DEMAND that Clare pay less for her car insurance.

Clare. Pay. Less. For. Your. Car. Insurance.

A little face fun time with the Vanguard
https://www.instagram.com/p/CgW0pJ4lu1Q/?igshid=MDJmNzVkMjY=

Fuck Raniere pay the victims they suffered enough already.