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

Keith Raniere

Keith Raniere’s hoped-for halting payments to his 21 victims might have failed. 

See: Raniere Asks Court to Stop Restitution Payments to 21 Victims – Because of ‘Shocking FBI Tampering’

Raniere does not want any of the 21 victims paid – even with Clare Bronfman’s money.

Judge Nicholas Garaufis ruled Raniere owed $3.4 million to 21 victims – most of them from DOS.

The only challenge was that Raniere claimed to be penniless.

But it looks like they are being paid after all. 

And the DOJ has already paid some of them. 

In November 2020, Bronfman paid $6 million in restitution as part of her plea deal.

In December, the US Attorney’s Office for EDNY asked if they could use Bronfman’s money to pay Raniere’s victims. 

After all, Raniere always used Bronfman’s money to turn people into victims. It seemed only fair. 

They asked the top man, Attorney General Merrick Garland.

On March 8, 2022, he approved the payment of Bronfman cash to Raniere victims.

No sooner did they get started than Raniere objected.

His attorney Joseph Tully cited their Rule 33 Motion to the court as a reason to not pay them. The Rule 33 Motion, filed on May 3, alleges the FBI tampered with evidence in Raniere’s case.

Tully wrote, “It would be highly improvident for the government to distribute any restitution funds before these issues are fully briefed and ruled on.” 

He said if Raniere’s Rule 33 Motion is successful, it “would affect the grant of any restitution payments…. Thus Mr. Raniere objects to any distributions at this time.” 

But it looks like it is too late.

A letter from AUSAs Kevin Trowel and Tanya Hajjar tell the story.

They write to Catherine O’Hagan Wolfe, Clerk of Court. United States Court of Appeals for the Second Circuit

Re: United States v. Raniere Docket No. 21-1795

Dear Ms. Wolfe:

The government respectfully submits this update in accordance with the Court’s September 17, 2021 order…

The government has been advised by the Clerk’s Office for the Eastern District of New York that some victims have now received their restitution payments. Payments to the remaining victims have been processed and those victims will receive them in due course….

The government also writes in response to the defendant Keith Raniere’s letter… object[ing] to the distribution of funds to his victims.

[T]he decision to grant remission or restoration lies within the sole and exclusive discretion of the Attorney General and his designees… [T]he funds… were forfeited by Raniere’s co-defendant Clare Bronfman pursuant to Bronfman’s plea agreement… she does not challenge any aspect of her plea agreement on appeal…. The funds are lawfully under the government’s control. Raniere has no interest in them, and he therefore has no standing to object to the government’s distribution of those funds to his victims.

How sad for Raniere. 

The FBI arrested him, the DOJ prosecuted him, and a jury convicted him. Then a judge sentenced him to 120 years in prison.

And now he does not even control the spending of Bronfman’s money?

So much injustice.

Meanwhile, the DOJ has paid some and will continue to pay the remaining victims.

They are:

Camila: $507,997.45

Nicole: $412,779.18

India Oxenberg: $298,476.65

Amanda: $257,617.51

Daniela: $249,200

Sutton Family: $250,000

Souki: $244,680.03

Valerie: $241,247.50

Pam A.: $172,354.18

Audrey: $142,017.96

Jane Doe 35: $127,504.98

Jessica Joan: $116,568

Kristin T. $94,215

Paloma: $71,320.45

Erika $59,720.25

Add’l Jane Doe 14: $53,286.69

Rachel: $49,748.10

Allison W. $44,215.20.

Sarah Edmondson: $27,408.35

Sylvie: $25,809.78

James Loperfido: $5,625

It’s funny. Most people would be glad to see someone else pay their bills.

The Bureau of Prisons takes $300 out of Raniere’s commissary monthly to go towards victims.

A payment rate that would see them paid in 1198 years. But it leaves Raniere with about $75 per month for his needs that do not magically appear.  

Raniere would rather suffer deprivation than see his victims get a dime. He is one unusual ethicist.

 

 

 

 

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Frank Parlato

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  • I cannot remember his first child’s family name but I hope all that back child support or some of it is being paid too.

  • [Continued with pages 29 through 32 of Memorandum and Order.]

    use in an official proceeding in furtherance of a racketeering en-
    terprise – are crimes resulting in damage to, loss of, or
    destruction of property. While all of these crimes deprived vic-
    tims of property, they did so in a manner that defies easy
    valuation. The court finds that the Government has not yet es-
    tablished that any victims under the MVRA are entitled to
    restitution beyond the costs incurred (including lost income) in
    participating in the Government’s investigation, prosecution, and
    related proceedings.

    The collection of DOS members’ collateral through the wire fraud
    conspiracy deprived them of certain tangible assets but also,
    more fundamentally, of control over information and images to
    which they ascribed high personal value. That deprivation of con-
    trol caused them to endure an array of injuries and losses, the
    magnitude of which far exceeds any objective monetary value of
    the property that the defendants obtained. The court believes it
    is within its authority to order the defendants to return qualifying
    MVRA victims’ collateral to them, and it has reason to think that
    such an order would be a relief to victims who continue to worry
    about the exposure of their collateral by Raniere’s remaining ad-
    herents.7 But the mere return of collateral at this late stage, long
    after its rightful owners submitted to the injustices and indigni-
    ties of DOS membership, would be inadequate compensation for
    the damage wrought. To the extent the Government can provide
    a reasonable approximation of the value of victims’ collateral in
    this context, the court will order restitution in accordance with
    that estimate.

    ___________________________________________________
    7 The court encourages the Government, in its forthcoming submission, to
    address whether it recommends that the court order the return of DOS
    members’ collateral as one aspect of restitution for the victims of the wire
    fraud conspiracy offense. And, if so, the court seeks the Government’s input
    into how such an order may be enforced.

    29

    Similarly, identity theft victims were deprived of the exclusive
    use of and control over the use of their identity. That “property”
    cannot feasibly be returned to them, and the mere cessation of
    the theft is inadequate to compensate for the injuries that it
    caused. Accordingly, if the Government can reasonably approxi-
    mate the value of the damage incurred by Loperfido, he is
    entitled to recover an amount commensurate with that value, in
    addition to reimbursement for lost income and costs incurred
    through his participation in the investigation and trial.

    Finally, while the court finds that Nxivm’s production of altered
    videotapes in response to a civil litigation discovery request
    caused the Sutton family’s lawyers to expend additional time on
    the case, and, therefore, caused the Sutton family to incur addi-
    tional legal costs, the Government has not yet provided a
    reasonable approximation of those costs. The court cannot dis-
    cern from the current record, including the Sutton family’s
    restitution claim and supporting documentation, what portion of
    the Sutton family’s legal costs is directly attributable to the un-
    lawful alteration of evidence. Thus, in order for the court to
    award restitution to the Sutton family on this basis, the Govern-
    ment must reasonably approximate the amount of losses
    incurred by the Sutton family as a proximate result of this predi-
    cate racketeering act.

    IV. CONCLUSION

    In light of the above analysis, the court directs the parties to file
    supplemental letter briefs, and to append to them any relevant
    supplemental evidence, that address the following issues: (1)
    whether a victim of a predicate racketeering act that is a covered
    offense under § 1593 is a victim within the meaning of the TVPA;
    (2) whether Jane Doe 2 is entitled to restitution under 18 U.S.C.
    § 2259; (3) whether there is sufficient evidence to establish that
    any of the claimants discussed in section III.A.1.b. of this opinion
    are victims under the TVPA; (4) whether any qualifying TVPA

    30

    victims are entitled to recover for Nxivm-related costs; and (5)
    whether appropriate methodologies exist by which the court can
    reasonably approximate the value of MVRA victims’ lost prop-
    erty. The parties may address any additional issues that they
    consider relevant to the subject of restitution including, if appli-
    cable, any evidence that they believe the court overlooked in the
    foregoing analysis. The court asks that the Government submit a
    revised set of restitution recommendations that is consistent with
    this analysis, with the underlying bases for all recommended
    awards explained in detail.

    Accordingly, the court DIRECTS the parties to submit supple-
    mental letter briefs, along with any necessary exhibits and
    affidavits, according to the following schedule:

    • The Government shall submit a letter brief, along with a
    revised set of restitution recommendations, by June 21,
    2021.
    • Mr. Raniere shall submit a responsive letter brief by July
    5, 2021.
    • The Government may submit a reply letter brief by July
    9, 2021.

    The court will hold a supplemental sentencing hearing for Mr.
    Raniere during the week of July 12 or July 19, 2021. At that hear-
    ing, the court will hear argument from the parties, if needed, and
    order restitution. The parties are DIRECTED to contact the court’s
    Deputy to schedule the hearing. Defense counsel is DIRECTED to
    inform the court by May 28, 2021 whether Mr. Raniere consents
    to the hearing being held by videoconference.8 The Government

    ___________________________________________________________
    8 See Pub. L. No. 116-136, § 15002(b)(2), (4) (allowing for sentencings in
    criminal cases to be conducted by videoconference if the chief judge of the
    court “specifically finds … that … felony sentencings under Rule 32 of the

    31

    is DIRECTED to provide to the court by May 28, 2021 its recom-
    mended redactions to this Memorandum & Order, so that the
    court may file it on the public docket without exposing victims’
    identities or sensitive personal information.

    SO ORDERED.

    Dated: Brooklyn, New York
    May 21, 2021

    /s/ Nicholas G. Garaufis_
    NICHOLAS G. GARAUFIS
    United States District Judge

    __________________________________________________________
    Federal Rules of Criminal Procedure cannot be conducted in person with-
    out seriously jeopardizing public health and safety” and the district judge
    in the case finds that delaying sentencing would seriously harm the inter-
    ests of justice, so long as the defendant consents to the proceedings being
    held by video teleconference); U.S. District Court for the E.D.N.Y. Admin.
    Order Nos. 2021-4-1, 2021-5 (finding that sentencing proceedings should
    continue to be held remotely to the maximum extent possible and author-
    izing individual judges to hold such proceedings by videoconference).

    32

  • [Continued with pages 26 through xx of Memorandum and Order.]

    At trial, an attorney who had represented three of Nxivm’s coun-
    terparties in the case – Stephanie Franco, her father Morris
    Sutton, and her stepmother Rochelle Sutton (collectively, “the
    Sutton family”) – testified that the litigation lasted nearly fifteen
    years, and the Sutton family has submitted a restitution claim
    seeking over $2.8 million in compensation for litigation costs.
    (See Trial Tr. at 4525:15-20, 4533:12-17; Gov’t Recommenda-
    tions at 2.) The Sutton family’s attorney testified that counsel
    reviewed the edited videotapes in preparation for trial, and that
    counsel suspected the tapes had been altered and considered re-
    taining an expert to opine on that matter. (Trial Tr. at 4501:1-
    17, 4525:25-4527:7.)

    The court finds by a preponderance of the evidence that Nxivm’s
    production of fraudulent evidence in federal district court litiga-
    tion caused pecuniary losses to the Sutton family by requiring
    their lawyers to spend time reviewing the altered tapes and de-
    termining how to proceed in response. However, the court does
    not find that all litigation costs incurred by the Sutton family in
    its civil litigation against Nxivm are the proximate result of the
    alteration of evidence produced in discovery: many of those ex-
    penses would have been incurred even if Nxivm had produced
    the unaltered videotapes.

    Individuals Not Entitled to Restitution: Absent further evi-
    dence, the court finds that individuals other than those identified
    above, more than 80 of whom have submitted restitution claims,
    are not victims of Raniere’s crimes within the meaning of the
    MVRA. This group includes five claimants to whom the Govern-
    ment recommend that the court award restitution: Adrian
    Xxxxxxxxx (“Adrian”), the brother of Jane Does 2, 3, and 4, who
    seeks to recover for uncompensated labor and psychological care,
    and Toni Natalie, Barbara Bouchey, Susan Dones, and Xxxx
    Xxxxxxx, each of whom seeks to recover primarily for litigation

    26

    costs she incurred in defending against vexatious litigation initi-
    ated by Raniere and his co-conspirators.

    The MVRA provides for restitution only to the victims of a de-
    fendant’s crimes, not to every person victimized by his harmful
    or improper actions. While the jury found that Raniere commit-
    ted forced labor offenses, the charges relating to those offenses
    were specific to uncompensated work performed by members of
    DOS. Accordingly, the uncompensated labor and services per-
    formed by Adrian and other members of the Nxivm community,
    separate from DOS, are outside the scope of the specific crimes
    of conviction, and therefore such harms are not compensable un-
    der the MVRA. Similarly, while the court has seen ample
    evidence that Raniere habitually bullied and terrorized his de-
    tractors and perceived enemies through aggressive litigation,
    funded by co-defendant Clare Bronfman and designed to push
    his critics past the brink of financial ruin, that conduct is not a
    part of any of the crimes of which he was convicted.

    Many other individuals who immersed themselves in the Nxivm
    community, paying for its programming and subscribing to its
    teachings, now seek to recover for the costs of their tuition,
    books, housing, and travel, and for the mental health care that
    they require as they seek to heal the psychological damage
    wrought by the defendants’ conduct. The court recognizes that
    Raniere generated participation in Nxivm’s programs through co-
    ercive and manipulative tactics, which may cause many former
    participants to reasonably believe that they were cheated, misled,
    or pressured into paying the price of participation. The court is
    sympathetic to the financial toll that involvement in the Nxivm
    community took on so many individuals. Even so, the court can-
    not find by a preponderance of the evidence, on the existing
    record, that any such costs were the proximate result of Raniere
    and his co-defendants’ covered offenses. Rather, as the Govern-
    ment acknowledges, “the causal link between the defendants’

    27

    criminal conduct and any losses incurred as a result of the pur-
    chase of Nxivm classes and travel is too attenuated to satisfy the
    [MVRA’s] proximate cause requirement.” (Gov’t Restitution Ltr.
    at 5.)

    Many, if not all, of these claimants have suffered legitimate losses
    as a result of Raniere and his co-defendants’ abusive, manipula-
    tive, and vexatious conduct. In finding these claimants’ alleged
    losses to be uncompensable under the MVRA, the court makes
    no findings with respect to the validity or severity of their claimed
    losses, and it does not suggest that those losses are unworthy or
    less worthy of restitution in any moral sense. Notwithstanding
    that the harms they have suffered are beyond the scope of those
    losses that the court can order the defendant to redress, the court
    extends to these claimants both its sympathy and its admiration
    for their resilience.

    2. Identification of Compensable Losses

    Eligible victims under the MVRA are entitled to mandatory resti-
    tution tailored to the nature of the offense. Victims of offenses
    “resulting in damage to or loss or destruction of property” receive
    the return of the property or, “if return is . . . impossible, imprac-
    ticable, or inadequate,” payment equivalent to the property’s
    value. 18 U.S.C. § 3663A(b)(1). Victims of offenses “resulting in
    bodily injury” are entitled to recover the costs of medical care
    and “related professional services” relating to mental health care,
    the costs of “necessary physical and occupational therapy and re-
    habilitation,” and lost income that resulted from the offense. Id.
    § 3663A(b)(2). All victims under the MVRA are entitled to reim-
    bursement for lost income and expenses, including child care and
    transportation, “incurred during participation in the investiga-
    tion or prosecution of the offense or attendance at proceedings
    related to the offense.” Id. § 3663A(b)(4).
    Raniere’s covered offenses under the MVRA – wire fraud conspir-
    acy, and identity theft crimes and conspiracy to alter records for

    28

  • [Continued with pages 23 through 25 of Memorandum and Order.]

    Insofar as TVPA victims retained legal counsel in connection with
    their involvement with the Government’s investigation, their trial
    testimony, their victim impact statements, their restitution
    claims, or any other matters related to these criminal proceed-
    ings, such costs are fully compensable. Claims for attorneys’ fees
    and legal costs must be supported by statements from victims’
    counsel attesting to the work performed, and by worksheets de-
    scribing the work performed and the hours and rates billed. The
    court will not award restitution for attorneys’ fees and legal costs
    incurred in connection with any separate legal proceedings, in-
    cluding any civil litigation.

    B. Restitution Pursuant to Mandatory Victim Restitution
    Act of 1996

    1. Identification of Relevant Victims

    As noted above, the MVRA provides for mandatory restitution for
    persons who are “directly and proximately harmed as a result of
    the commission” of a qualifying criminal offense, including per-
    sons harmed by criminal conduct committed in the course of a
    scheme or conspiracy. 18 U.S.C. § 3663A(a)(2). Qualifying of-
    fenses include crimes of violence and crimes against property,
    including those “committed by fraud or deceit,” insofar as they
    result in either bodily injury or property loss or damage. Id. §
    3663A(c)(1), (b). Identifying individuals who meet the MVRA’s
    definition of “victim” therefore requires that the court examine
    the covered offenses and, where applicable, the criminal conduct
    committed in the course of a criminal conspiracy or scheme to
    determine which putative victims were directly and proximately
    harmed.

    DOS Members: Count Seven, which charged Raniere and cer-
    tain co-defendants with wire fraud conspiracy, is based on the
    defendants’ scheme to obtain lower-ranking DOS members’
    money and property, including rights to assets, credit card au-
    thorizations, and sexually explicit photographs and videos, as

    23

    “collateral” for their involvement in DOS. (PSR ¶ 21.) Where the
    Government establishes by a preponderance of the evidence that
    an individual was a lower-ranking DOS member who provided
    money or property as “collateral,” that individual is a victim of
    this offense – even if there is insufficient evidence to establish
    that she was also a victim of forced labor or sex trafficking.

    The court finds that DOS slaves were victims of wire fraud con-
    spiracy if they furnished collateral that included monetary assets,
    rights or access to monetary assets, or sexually explicit photo-
    graphs or videos of themselves. However, the court does not find
    by a preponderance of the evidence that every piece of collateral
    furnished by a DOS slave was sufficient to render its provider a
    victim of wire fraud conspiracy. In particular, trial testimony es-
    tablished that DOS members often recorded accusations,
    confessions, or secrets with the potential to harm or embarrass
    their subjects (usually either the DOS member herself or a close
    family member) as collateral. The court does not find, by a pre-
    ponderance of the evidence, that a DOS member was a victim of
    wire fraud conspiracy where the only collateral she provided was
    a statement of this nature.

    Based on these parameters, court finds by a preponderance of the
    evidence that the following individuals are victims of the defend-
    ants’ wire fraud conspiracy, on the basis of trial testimony
    establishing that they secured their membership in DOS by
    providing as “collateral” rights to assets, sexually explicit photo-
    graphs or videos of themselves, or other money or property: Jane
    Doe 5 (“Nicole”) (Trial Tr. at 3852:23-3853:4); Jane Doe 6
    (“Xxxxxx”) (id. at 1723:21-24, 1724:19-21.); Jane Doe 8 (“Jay”)
    (id. at 4329:23-4330:4); Sylvie (id. at 213:19-214:15.); Addi-
    tional Jane Doe 13 (“Sarah”) (id. at 1719:16-20); Additional
    Jane Doe 34 (“Xxxxx”) (id. at 5104:11-17); and Amanda (id. at
    1732:17-22). Notably, the Government has not yet been able to
    establish by a preponderance of the evidence that one of these

    24

    individuals – Additional Jane Doe 34 – meets the definition of
    “victim” under the TVPA. Additional former members of DOS
    may be entitled to restitution under the MVRA, if the Govern-
    ment provides additional evidence that establishes, by a
    preponderance, that they furnished money or property as collat-
    eral.

    Non-DOS Victims Entitled to Restitution: In addition to crimes
    related to his leadership role in DOS, Raniere was convicted of
    racketeering and racketeering conspiracy on the basis of numer-
    ous criminal predicate acts. To determine the victims of Raniere’s
    racketeering offenses, the court must look to the predicate rack-
    eteering acts which the jury found, beyond a reasonable doubt,
    that Raniere had committed.

    The jury found that Raniere had committed a number of identity
    theft offenses with specific victims: Jane Doe 1, James Loperfido,
    Edgar Bronfman, Sr., Jane Doe 3, and Jane Doe 7. (See PSR ¶¶
    4-5, 10-11, 13, 19.) Accordingly, all of these individuals are vic-
    tims of crimes committed in furtherance of the racketeering
    scheme for which Raniere was convicted. Of these victims, only
    James Loperfido has submitted a claim for restitution.

    Additionally, the jury found that Raniere and others had con-
    spired to alter records for use in an official proceeding, in
    violation of 18 U.S.C. § 1512(k), by directing individuals in the
    Nxivm community to remove portions of videotapes that were to
    be produced in discovery in a copyright lawsuit in the U.S. Dis-
    trict Court for the District of New Jersey. (See PSR ¶ 12.) Nxivm’s
    counterparties requested the production of certain Nxivm vide-
    otapes in support of their claim that Nxivm’s curriculum
    contained false statements and violated consumer protection
    laws. (Id. ¶ 81.) Acting on Raniere’s instructions, Nxivm members
    edited out segments of the videos that contained false claims, and
    Nxivm then produced the edited tapes while claiming that they
    were unedited. (Id. ¶ 82.)

    25

  • [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 17 through 19 of Memorandum and Order.]

    involving the victim.” 18 U.S.C. §§ 1593(b)(3), 2259(c)(2). Re-
    coverable losses include “medical services relating to physical,
    psychiatric, or psychological care;” “physical and occupational
    therapy or rehabilitation;” “necessary transportation, temporary
    housing, and child care expenses;” “lost income;” “reasonable at-
    torneys’ fees, as well as other costs incurred;” and “any other
    relevant losses incurred by the victim.” Id. § 2259(c)(2). Addi-
    tionally, victims under the TVPA recover “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 mini-
    mum wage and overtime guarantees of the Fair Labor Standards
    Act.” Id. § 1593(b)(3).

    a. Medical Services

    With regards to medical care costs, the court agrees with the Gov-
    ernment’s recommendation that losses are compensable only if
    supported by a letter from a licensed or credentialed medical pro-
    vider, counselor, or social worker. (See Gov’t Restitution Ltr. at
    6.) As a general matter, the court finds that the defendants im-
    posed on DOS slaves numerous physical and psychological
    burdens in order to perpetuate sex trafficking and forced labor
    offenses, including sleep deprivation, extreme food deprivation
    and compulsory weight loss, stress and psychological abuse,
    branding, and unwelcome sexual activity. These burdens, which
    were integral to defendants’ commission of the relevant offenses,
    were the proximate cause of a wide range of medical care needs,
    including but not limited to cosmetic surgery for brand removal
    and potentially extensive mental health care.
    With respect to mental health care, the court is prepared to find
    by a preponderance of the evidence that Defendants’ criminal
    conduct proximately caused the full extent of DOS victims’ psy-
    chological and psychiatric care needs, absent compelling
    evidence of a separate and unrelated mental health issue that

    17

    was not exacerbated by Defendants’ conduct. Defense counsel ar-
    gues that the court should reduce restitution awards to account
    for victims’ psychological harms that predated their involvement
    with DOS and Raniere. (See Raniere Restitution Ltr. at 28.) In
    support, it cites to the Northern District of New York’s decision in
    United States v. Pearson, in which the court reduced victims’ res-
    titution awards “because [they] presented with some mental
    health issues prior to [their] involvement with Defendant, [and]
    the Court cannot conclude that the full extent of the mental
    health interventions [they] now require[] are causally related to
    Defendant’s crimes.” No. 04-cr-340 (TJM), 2009 WL 2383025, at
    *4-5 (N.D.N.Y. July 30, 2009).

    One of the cruelest aspects of Raniere and his co-defendants’ con-
    duct is the way that they preyed upon victims’ preexisting
    vulnerabilities and past traumas in order to debase and control
    them, often under the guise of healing or self-improvement. In
    doing so, the defendants compounded and intensified victims’
    preexisting psychological issues. Thus, even where a victim might
    have benefitted from mental health care absent her participation
    in DOS, the extent and magnitude of her need for such care fol-
    lowing her involvement with DOS may be the proximate result
    of the defendants’ actions. The court is not well positioned to dis-
    entangle the psychological harms that a victim may address
    through the receipt of mental health care, let alone to apportion
    the costs of such care among underlying harms, and it will not
    do so absent clear evidence that the forced labor and/or sex traf-
    ficking of a specific victim did not give rise to the full extent of
    her psychological care needs.

    The court adopts the Government’s recommendation that, where
    a medical provider has given an estimated range for a victim’s
    future psychological or psychiatric care costs, the court should
    award restitution based on the midpoint of that range. (See Gov’t
    Restitution Ltr. at 6.) The court also adopts the Government’s

    18

    recommendation that the cost of cosmetic surgery for brand re-
    moval be estimated as $2,500, based on the cost quoted to Jane
    Doe 6 by a medical provider specializing in laser skin treatment.
    (See id.) Subject to these parameters, and to the other parameters
    discussed above, the court finds that TVPA victims’ relevant med-
    ical care costs, including mental health care costs, are the
    proximate result of Defendants’ commission of forced labor and
    sex trafficking offenses and are therefore fully compensable.

    b. Nxivm-Related Costs

    Several TVPA victims seek restitution for expenses incurred as a
    result of their participation in Nxivm and its programming, in-
    cluding tuition for ESP seminars and other Nxivm courses,
    membership fees for Nxivm groups, costs of “EM” sessions, and
    travel and housing costs incurred in order to attend Nxivm pro-
    gramming. As a general matter, the court finds that the
    defendants’ forced labor and sex trafficking offenses, which per-
    tain specifically to DOS, are not the proximate cause of DOS
    members’ costs related to Nxivm programming. Many of the vic-
    tims were recruited into DOS after they had already become
    involved with Nxivm and its programming, and insofar as they
    participated in Nxivm programming during the period in which
    they belonged to DOS, such participation can likely be attributed
    to their involvement with the larger Nxivm community.

    At this time, the court is not aware of any evidence providing a
    direct causal link between the covered offenses and Nxivm-re-
    lated costs. Absent further evidence that the defendants caused
    specific victims to incur specific Nxivm programming, housing,
    or travel costs in connection with the forced labor and/or sex
    trafficking of those victims, the court cannot direct the reim-
    bursement of TVPA victims for these costs.

    19

  • [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

  • [Continued with pages 7 through 12 of Memorandum and Order.]

    whom the Government recommends that restitution be awarded
    and 75 more to whom the Government recommends that no
    award be made, are not identified as victims under the TVPA.
    (Id.) The court considers first which of the claimants are entitled
    to restitution under the TVPA and, for those who are eligible vic-
    tims, which of their losses are recoverable. It then conducts a
    similar analysis with respect to the MVRA.

    A. Restitution Pursuant to Trafficking Victims Protection
    Act of 2000

    1. Identification of Relevant Victims

    The TVPA defines “victim” as “the individual harmed as a result
    of a crime under this chapter.” 18 U.S.C. § 1593(c). The Govern-
    ment identifies 18 of the 100 individuals who have submitted
    requests for restitution as victims within the meaning of Section
    1593 of the TVPA.
    Raniere was convicted of two separate counts of sex trafficking,
    in violation of 18 U.S.C. § 1591, pertaining to victims Jane Doe
    5 (“Nicole”) and Jane Doe 8 (“Jay”). Because sex trafficking in
    violation of § 1591 is a covered crime under the TVPA, Jane Doe
    5 and Jane Doe 8 are plainly entitled to restitution under § 1593.
    Additionally, Raniere’s conviction for racketeering was predi-
    cated, in part, on the trafficking for labor and services and
    document servitude of Jane Doe 4 (“Daniela”) – conduct that is
    criminal under 18 U.S.C. §§ 1590 and 1592. The court requests
    that the parties’ supplemental letter briefs address the question
    of whether a victim of a predicate racketeering act that is a cov-
    ered offense under § 1593 is a victim within the meaning of the
    TVPA. Assuming, for now, that victims of covered offenses are
    entitled to restitution under § 1593 even if such offenses were
    not crimes of conviction themselves, but rather were committed
    in furtherance of a racketeering enterprise, the court finds that
    Jane Doe 4 is entitled to restitution under § 1593.

    7

    Raniere was also convicted of sex trafficking conspiracy and
    forced labor conspiracy, in connection with his role in a scheme
    that used coercive and illegal means to compel lower-ranking
    DOS members to engage in uncompensated labor and sexual ac-
    tivity. Those conspiracy crimes are covered offenses under the
    TVPA. The testimony at Raniere’s trial made clear that lower-
    ranking DOS members (referred to as “slaves”) performed un-
    paid labor and, in some cases, engaged in sexual activity, and
    that they did so at the direction of higher-ranking DOS members
    (“masters”), in response to acute social, financial, and emotional
    pressures designed and imposed by Raniere and his co-conspira-
    tors. In convicting Raniere of these crimes, the jury determined
    that the defendants’ conduct met the elements of federal forced
    labor and sex trafficking offenses. Accordingly, the court finds
    that all lower-ranking DOS members who performed uncompen-
    sated labor and services or who engaged in sexual activity, in
    connection with their membership in DOS and at the direction of
    higher-ranking DOS members, are victims of a covered offense
    under the TVPA and are entitled to restitution under § 1593.

    Thus, in the court’s view, a putative victim is entitled to recover
    under § 1593 if the court finds by a preponderance of the evi-
    dence that: (1) she was a lower-ranking “slave” member of DOS5
    between February 2016 and June 2017; and (2) in connection
    with her membership in DOS and at the behest of a higher-rank-
    ing DOS “master,” she either performed unpaid labor or services,
    engaged in sexual activity, or both. All restitution claimants who
    meet these criteria are statutorily entitled to recover the full
    amount of their losses under the TVPA.

    __________________________________________________
    5 For purposes of this analysis, the court considers DOS members who were
    not “first-line masters,” and who therefore were “slaves” to other female
    “masters” within DOS and not directly to Raniere himself, to be “lower-
    ranking.” (See PSR ¶¶ 84-85.)

    8

    a. Victims Entitled to Restitution Under TVPA
    The court finds, by a preponderance of the evidence, that the fol-
    lowing individuals are victims of sex trafficking offenses, forced
    labor offenses, or both, and that they are therefore entitled to
    restitution under the TVPA.

    Daniela Xxxxxxxxx (“Jane Doe 4,” “Daniela”): As stated
    above, Racketeering Act Nine, which the jury found the Govern-
    ment had proved in support of Count Two, for racketeering,
    charged Raniere with the document servitude and trafficking for
    labor and services of Jane Doe 4. Assuming that victims of pre-
    dicate racketeering acts that are covered offenses under § 1593
    may receive restitution under the TVPA, the court finds that Jane
    Doe 4 is a victim within the meaning of that statute.

    Nicole Xxxxxx (“Jane Doe 5,” “Nicole”): As stated above, Ra-
    niere’s conviction on Count Nine concerned his sex trafficking of
    Jane Doe 5. The court therefore finds that she is a victim of a
    qualifying offense under the TVPA.

    Xxxxxxx Xxxx (“Jane Doe 8,” “Jay”): As stated above, Raniere’s
    conviction on Count Ten concerned his sex trafficking of Jane
    Doe 8. The court therefore finds that she is a victim of a qualify-
    ing offense under the TVPA.

    Xxxxxx Xxxxxxxx (“Jane Doe 6,” “Xxxxxx”): According to tes-
    timony at trial, Jane Doe 6 was recruited into DOS by Lauren
    Salzman and served as Salzman’s slave. (Tr. of Keith Raniere
    Trial (“Trial Tr.”) at 1601:19-25, 1722:25-1723:10, 1770:21-
    1771:2.) She submitted “collateral” in connection with her mem-
    bership in DOS, including financial assets and naked
    photographs. (Id. at 1723:21-1724:21.) She was branded on her
    pelvic area with the DOS brand. (Id. at 1753:23-1754:19.) The
    court therefore finds by a preponderance of the evidence that
    Jane Doe 6 was a lower-ranking member of DOS during the rel-
    evant period.

    9

    Salzman also testified that, in connection with her membership
    in DOS, that Jane Doe 6 sometimes functioned as a “personal
    assistant” for her, but that she preferred for Jane Doe 6 to per-
    form “executive level administrative type work for DOS,” such as
    conducting legal research and reviewing legal contracts. (Id. at
    1673:6-1674:20.) Accordingly, the court also finds by a prepon-
    derance of the evidence that Jane Doe 6 performed
    uncompensated labor and services in connection with her partic-
    ipation in DOS. The court determines that Jane Doe 6 is a victim
    of a qualifying offense under the TVPA.

    Sylvie Xxxxxx (“Sylvie”): Sylvie testified at trial regarding her
    recruitment into DOS and her submission of collateral, including
    naked photographs and a letter with the potential to disrupt close
    family relationships, in connection with her membership. (Id. at
    211:4-20, 213:3-214:15, 215:21-24.) The court finds by a pre-
    ponderance of the evidence that she was a lower-ranking DOS
    member during the relevant period. Sylvie also testified that she
    was assigned by her DOS master to seduce Raniere, and that she
    had sexual contact with Raniere pursuant to that assignment. (Id.
    at 219:13-220:6, 252:6-254:15.) The court therefore finds by a
    preponderance of the evidence that Sylvie engaged in sexual ac-
    tivity in connection with her role in DOS. The court determines
    that Sylvie is a victim of a qualifying offense under the TVPA.

    India Xxxxxxxx (“Additional Jane Doe 7,” “India,” “Addi-
    tional DOS Victim 1”): Multiple trial witnesses identified
    Additional Jane Doe 7 as a member of DOS: a slave who reported
    to Allison Mack and who recruited Jane Doe 8 and served as her
    master. (See id. at 4197:6-10, 4197:16-18, 4267:23-25, 4325:3-
    4328:3, 4333:20-4334:4, 5097:20-21.) The court finds by a pre-
    ponderance of the evidence that Additional Jane Doe 7 was a
    lower-ranking member of DOS during the relevant period.
    Lauren Salzman testified that Allison Mack informed her that she
    expected Additional Jane Doe 7 to begin having sexual contact

    10

    with Raniere in her capacity as Mack’s slave. (Id. at 1794:1-8.) In
    a March 3, 2016 email exhange, Raniere wrote to Mack to con-
    firm that “[Additional Jane 7] know[s] [that] to complete her
    [sic], she needs to take all of her clothes off while I am clothed,
    pose in the most revealing way, and have me take a picture of
    her with her phone to be immediately sent to you as proof.” (Id.
    at 5099:7-17.) The following day, Raniere wrote to Mack, “Any
    news on [Additional Jane Doe 7]?” and Mack responded that Ad-
    ditional Jane Doe 7 had “changed her flight” would “reach out”
    to Raniere regarding “meeting again to complete the assign-
    ment.” (Id. at 5097:23-5098:13.) According to the PSR, “Mack
    was notified by Raniere that [Additional Jane Doe 7] completed
    the assignment. At a later point, [Additional Jane Doe 7] had
    sexual contact with Raniere. She told Mack that Raniere per-
    formed oral sex on her.” (PSR ¶ 119.)

    Additional Jane Doe 7 gave a victim impact statement at Rani-
    ere’s sentencing in which she described her participation in DOS,
    including being branded, and stated that she was “instructed to
    seduce Keith as a test of [her] loyalty” and engaged in “dozens of
    sexual encounters” with him that she “would never have con-
    sented to” if not for the fear of her DOS collateral being released.
    (Stc’g Tr. at 81:16-22, 82:2-10.)

    In light of testimonial and documentary trial evidence suggesting
    that Raniere and Mack planned to assign Additional Jane Doe 7
    to have sexual interactions with Raniere, the Probation Depart-
    ment’s finding that Additional Jane Doe 7 had sexual contact
    with Raniere, and Additional Jane Doe 7’s own description of
    “dozens” of sexual encounters that would not have occurred ab-
    sent to her participation in DOS, the court finds by a
    preponderance of the evidence that Additional Jane Doe 7 en-
    gaged in sexual activity at the instruction of her DOS master and

    11

    in connection with her role in DOS. Accordingly, the court deter-
    mines that Additional Jane Doe 7 is a victim of a qualifying
    offense under the TVPA.

    Sarah Edmondson (“Additional Jane Doe 13,” “Sarah,” “Jane
    Doe 11”): At trial, Lauren Salzman testified that she recruited
    Additional Jane Doe 13 into DOS to serve as her slave, and that
    Additional Jane Doe 13 submitted collateral in connection with
    her DOS membership. (Trial Tr. at 1717:24-1721:22.) Addi-
    tional Jane Doe 13 was branded on her pelvic area in connection
    with her membership in DOS. (Id. at 1748:22-1749:17.) The
    court therefore finds by a preponderance of the evidence that Ad-
    ditional Jane Doe 13 was a lower-ranking member of DOS during
    the relevant period.

    At trial, Salzman testified that the concepts of “time and labor”
    were central to DOS in that slaves were expected to make a “full-
    time commitment to be always making [their] master more po-
    tent.” (Id. at 1671:10-23.) She explained that she conveyed to
    her slaves that they “should be seeking to provide the most value
    in the time and labor they’re providing,” and that “labor dedi-
    cated to furthering the master” was a core component of their
    involvement in DOS. (Id. at 1673:1-1674:13, 1671:22-23.) The
    court therefore finds by a preponderance of the evidence, on the
    basis of Salzman’s testimony, that DOS slaves who reported di-
    rectly to Salzman were required to engage in uncompensated
    labor. Thus, even though Salzman did not describe specific as-
    signments that she gave to Additional Jane Doe 13, the court
    finds that Additional Jane Doe 13 is a victim of a qualifying of-
    fense under the TVPA.

    Xxxxxx Xxxxxxx (“Amanda”): Lauren Salzman testified at trial
    that she recruited Amanda into DOS. (Id. at 1732:8-9.) She tes-
    tified that Amanda submitted collateral including sexually
    explicit photographs and material that, if released, could have
    negatively affected her own professional status and her romantic

    12

  • 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

  • Frank
    Rainere deserves to get Zero in prison. He is NOT important and he deserves stale bread & water. He is a seducer, rapist & a killer.

    That fact is flat. Rainere is a fat assed Killer who deserves to be behind bars and to die there –

    Viva when all playmates in NXIVM go to jail & never come out.

  • Knowing Raniere, the sharpest sting this poses isn’t money, it is his being ignored. The fact that he is now irrelevant and that he gets ignored has to be tormenting him. Viva Executive Success!

  • 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.

  • It seems the court was unimpressed by this tale of “shocking FBI tampering”.

    Nobody takes this bullshit tale seriously.

    Not even Clare Bronfman, and she’s a Raniere supporter. Note that none of Raniere’s jailed co-conspirators want any part of this bullshit theory. It’s too crazy for even them.

  • Almost $300K for co-conspirator #2, a DOS master herself. Seems on the level to me, certainly not anything that should be questioned or looked into…

    • Are you talking about India?

      She wasn’t a frontline DOS slave.

      India had no idea about Keith being involved in DOS at all. Let alone that Keith was the head of the entire criminal organization

      India did not know she was fraudulently branded with Keith’s initials, she did not know that all her pornographic and other blackmail material was going to Keith. India believed her friends. Like Alison Mack.

      Why is it hard for you to understand that distinction? You’re allegedly Allison’s friend.

      But Allison herself apologized to India. Allison wrote notes to all the former friends that she wronged. Why do you think you know better than Allison? Seems very misogynistic allison said she was guilty. And sorry. Are you calling Allison a liar?

      • Allison apologized because she did something wrong and illegal, admitted to it, and is taking responsibility for it and is being punished for it. Which makes her a bigger person than the fake, made for tv heroes who’ve been shoved down our throats for the last four years. Time for them to get a real job instead of continuing to milk Allison’s name for whatever they can get.

        Ironic that the person who is probably entitled to compensation, who was hurt the most by Allison’s behavior (other than Nicole, who I don’t know much about), ironic that she’s moved on with her life and has an actual grown up job.

        Why isn’t she on the compensation list? Why aren’t the teen Mexican slave workers who worked for India’s Delegates company, who were never paid for their labor, why aren’t they on the list?

        I don’t defend or condone any criminal activity. I do condemn that a small group of people took a big fall while other people who were equally responsible, or more responsible, walked away clean and with cash settlements, despite having participated in and having led the organization they are pointing fingers at.

        Why is Sarah a plaintiff if she owned, operated, directed, managed, and profited from the organization’s second largest center? Did she not know about Keith’s involvement either, even though his face was on the walls, even though she sung his praises and attended V week, even though the allegations about Keith had been made public for years? She gets a pass. Vicente gets a pass. The people they recruited who had a fraction of their power haven’t gotten a pass. Not from the FBI, not from the press, and not from this blog. Why the disparity?

        Have you ever heard of a business owner suing a customer for something that the business did? That Edmondson and Vicente are named as Plaintiffs in the civil suit while Danielle Roberts, a customer who never profited from the organization, who was at the bottom of the pyramid, is a defendant, is grounds to dismiss the lawsuit immediately.

        India didn’t know anything about Keith, except for all of those back and forth text and e-mail exchanges with her mother, via the FBI, where the entire thing was spelled out for her, word for word, and then shown to the public on her on tv series. And she still didn’t leave until the very end. And she gets $300K? Her slave only gets $116K? How many other slaves did she have who got nothing? Including the literal teen slave workers who were never paid?

        India was listed as a Co-conspirator, had slaves in DOS, and continued participating in the organization until the very end. But she’s a hero in the tale and somehow deserving of $300K, while other women of the same or lower rank in the same group are made into villains, have lost professional licenses, and continue to be ridiculed on this blog. While other women who denounced the group a lot earlier and never participated in criminal activity received nothing.

        Yeah, nothing to see here, sounds about right…

        • Are you crying?

          This is very personal to you, clearly.

          It’s been laid out for you repeatedly. And yet your comments still reflect this same false rhetoric.

          Running a self help center (like Sarah) is not illegal.

          It’s not equivalent to blackmailing women into fucking Keith.

          Recruiting people for ESP classes (while lame ass and distasteful imho) is not illegal.

          DOS was a deceitful blackmail slave ring that sexually trafficked and abused women who were “fuck toy slaves” for Keith. Raniere. The slaves were exploited for free labor. That is ILLEGAL

          Running the Vancouver Nxivm center is not.

          The damags are awarded for specific illegal acts. You seem willfully and stubbornly misinformed and unable to take in data that doesn’t fit your view. Being sexually blackmailed and assaulted, forced labor they all have a monetary value assigned by the court and it will vary based on the individuals personal criminal mistreatment within DOS or otherwise.

          No one is “forcing down your throat” documentaries on cable or streaming services. You can watch whatever you want. That’s how TV works. If you haven’t been able to change the channel for 4 years call your cable company.

          You really have an issue with Sarah and India. That is very clear.

          You’re gonna be okay. Everyone is okay. Change the channel.

          • Isn’t there a switch on electrical devices that allows you to turn the device off? This also applies to television sets. You should check the operating instructions.

          • I agree with Kevin. Roberts never owned a slave. Has received no help from all 3 sources mentioned and lost the most, she also paid for many classes., had no intel via Mommy/ fbi and believed she was promoting health, excersize and valuable info.
            If anyone deserves a settlement ( never a Dos master) just a worker bee and working saving lives within community ( Sally) and creating True helpful content., just her lost salary alone would be a million dollars in the last 4 years Not to mention attorney fees and class fees. DISGUSTING.

        • “I do condemn that a small group of people ….walked away clean and with cash settlements”
          These people were intentionally deceived and deserve every dime.

          “Why is Sarah a plaintiff”
          For the same reason.

          “Have you ever heard of a business owner suing a customer for something that the business did?”
          The analogy is entirely bogus: Edmondson and Vincente were not the business owners; Danielle Roberts wilfully carried out surgical procedures that could have harmed people in complete violation of medical ethics.

          “India didn’t know anything about Keith…”
          India was brainwashed like the rest of you. Unlike the rest of you, she came to her senses. The basis of her larger award in part reflected loss of potential earnings.

          • They were the business owners in Vancouver and Ca. for years Period
            Sarah.preformed.illegal.therapy.
            1500 Times
            Her MOM ( a therapist) surely would have cautioned her on that.
            Vicente.erased.evidence,not sure how many times?
            Kevin brings up a good point on India receiving fbi intel.

  • Bad going for Raniere and Tully. But things are much worse for others, as CalPERS shows, with a loss of $60 million in 2022.

    ____________________________________________________________________________________________________________

    The California Public Employees’ Retirement System, CalPERS, $442 billion pension fund has lost $60 billion in 2022.

    _____________________________________________________________________________________________________________

    CalPERS Announces Preliminary Net Investment Return of -6.1% for the 2021-22 Fiscal Year
    July 20, 2022

    Communications & Stakeholder Relations
    Contact: Megan White, Information Officer
    (916) 795-3991 – newsroom@calpers.ca.gov

    Challenging global public markets, strong private market returns lead to varied performance
    SACRAMENTO, Calif. – Tumultuous global markets played a role in CalPERS’ first loss since the global financial crisis of 2009, as the System today announced a preliminary -6.1% net return on investments for the 12-month period that ended June 30, 2022. Assets stood at $440 billion at the end of the fiscal year.

    “We’ve done a lot of work in recent years to plan and prepare for difficult conditions,” said CalPERS Chief Executive Officer Marcie Frost. “Despite the market conditions and their impact on our returns, we’re focused on long-term performance and our members can be confident that their retirement is safe and secure.”

    Volatile global financial markets, geopolitical instability, domestic interest rate hikes, and inflation all have had an impact on public market returns. CalPERS’ investments in global public stocks returned -13.1%, while fixed income investments returned -14.5%. Public market investments make up roughly 79% of the CalPERS’ total fund. CalPERS’ private market investments fared much better, with private equity and real assets sectors returning 21.3% and 24.1%, respectively.

    “This is a unique moment in the financial markets, and we’ve seen a deviation from some investing fundamentals,” said CalPERS Chief Investment Officer Nicole Musicco. “For instance, our traditional diversification strategies were less effective than expected, as we saw both public equity and fixed income assets fall in tandem. But despite a challenging year, we were able to outperform our total fund benchmark by 90 basis points and provide strong returns from our private market asset classes. These are bright spots that we can build on as we implement our new strategic asset allocation and increase our exposure to private market assets.”

    Total fund annualized returns for the 5-year period ending June 30, 2022 stood at 6.7%, the 10-year period at 7.7%, the 20-year period at 6.9%, and 30-year period at 7.7%.

    Asset Class Net Rate of Return Policy Benchmark
    Total Fund -6.1% -7.0%
    Public Equity -13.1% -13.2%
    Fixed Income -14.5% -14.5%
    Private Equity* 21.3% 8.3%
    Real Assets* 24.1% 27.1%
    Liquidity 0.3% 0.1%
    * Private market asset valuations lag one quarter and are as of March 31, 2022.

    [ … ]

    https://www.calpers.ca.gov/page/newsroom/calpers-news/2022/calpers-preliminary-investment-return-2021-22

  • Raniere’s desire to hurt people runs deep….

    It’s good news they get paid. But I still think Sylvie gets too little money, because she was in DOS, got a seduction assignment (from Monica Duran I believe), was sexually assaulted by Keith (she testified in court about this).

    So, it’s odd she gets a fraction of the sum paid out to, for example, Nicole, who had a similar experience. Even Jessica Joan gets more. Jessica got the seduction assignment but never had to endure Keith’s greasy fingers on her. I know Sylvie got restitution related to Clare’s sentencing, but still.

      • Mr. Parlato.

        I have seen that you never replied to my longer message about censorship.

        I plead with you and implore you to kindly please address the things that I said in my longer text and thrill me with your acumen on these very important points. Please and thank you.

        I look forward to hearing from you.

        • George,

          Frank is a crony capitalist. He is not a true conservative.

          Most conservatives of today are just yesterday’s liberals.

          Frank doesn’t answer you because he knows that he is defying the our 1st Amendment and he can’t debate it!

          He has been called out countless times by countless people and he always does the same thing when he’s confronted, he runs and hides like a pussy because he knows he is in the wrong and he doesn’t care!

          Frank wants to control thought! He doesn’t want anybody thinking about anything outside of what he tells them to think and/or what he “approves” of (funny how he of all people tries to exposes “cults”; huh?! But that’s the typical clusterfucks of a train of thought the average person in our society is today!)! Careful, though. He might label as somebody with a “mental disorder”. It’s basically his way of throwing a temper tantrum when you speak truth about him or anybody else. He labels you as “insane” until you subject to his thought paradigm.

          Remember the golden rule in FR, anybody who doesn’t subject to Frank’s ridiculous and unstable mindset is “mentally insane”.

          Frank is a piece of shit, dude! He will keep ignoring you even though you’re polite to him and no matter how many times you do because he has doesn’t have any morals or character! And then when you snap over him being a dick, then the mental “diagnosis” phase begins!

          You’re just wasting your time talking to him!

          He’s a jackass!

      • Sylvie was never listed as a co-conspirator and never owned slaves in DOS. Shouldn’t that entitle her to more than just a third of what said co-conspirator/DOS master received?

        • Sylvie did have one slave. But India had three slaves. I do not know why Sylvie got less than the others in DOS.

          • Frank,

            Kevin doesn’t care about facts. He just has very strong feelings about things he’s not really up to speed on. That’s kinda Kevin’s thing.

  • Vanguard keeps losing.

    And it keeps bringing me joy.

    Vanguard said: “He who has the most joy wins.”

    Therefore, I keep winning.

    • of what? dodgy made-up honorifics ? EGV sounds like something the prison doctor found in his urine sample.

  • Mr. Parlato.

    I have seen that you never replied to my longer message about censorship.

    I plead with you and implore you to kindly please address the things that I said in my longer text and thrill me with your acumen on these very important points. Please and thank you.

    I look forward to hearing from you.

Frank Parlato

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

https://en.wikipedia.org/wiki/Frank_Parlato,_Jr.

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

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