Motion to Dismiss: Judge Tests Whether Complaint Has Enough to Keep Sara Bronfman in Lawsuit

Sara Bronfman

We are reviewing the February 1 hearing in the civil lawsuit, Sarah Edmonsdson et al, vs. Keith Raniere et al.

This is part #3.

Hearing: Motions to Dismiss in Edmondson v Raniere: PT #1 Clare Bronfman RICO

Part # 2 Motion to Dismiss: Plaintiffs Allege Clare Bronfman Responsible for Raniere’s False Claims About Himself, Teachings

The venue is the US District Court in the Eastern District of NY. The judge is US District Court Judge Eric R. Komitee.

A hearing was held on the afternoon of February 1, 2023.

The purpose of the hearing was to hear oral arguments for motions to dismiss against the defendants, Clare and Sara Bronfman, Nicki Clyne, Brandon Porter and Danielle Roberts.

Defendants Raniere and Kathy Russell made no appearance.

Judge Eric Komitee is presiding in the civil case against Raniere, the Bronfmans, Clyne and others.

After hearing the RICO predicate acts against Clare Bronfman, Judge Komitee switched gears to Sara Bronfman.

To be candid, this lawsuit rises and falls on Clare and Sara Bronfman, the only two defendants with substantial assets.

And as Judge Komitee points out, the allegations against them of predicate acts in Racketeering of forced labor and alien harboring is where the RICO claim is “going to rise or fall.”

Aitan D. Goelman of Zuckerman Spaeder LLP of Washington, DC, spoke for the plaintiffs, of which there are about 70.

GOELMAN: … With respect to Sara Bronfman, one of the predicate acts is witness tampering, which is a 18 United States Code 1512. It’s one of the RICO predicates….

THE COURT: [paraphrasing the civil complaint: Sara] told somebody [Adrian] shortly before [Raniere’s criminal] trial… to make themselves scarce in the lead up to trial. …

GOELMAN: But it’s not just Sara Bronfman [who] did that. The complaint also contains allegations that Clare Bronfman did that….. to Camila… [in] 2017 Ms. Clare Bronfman and Raniere were down in Mexico. And Camila, who was a potential witness to child sex abuse and child pornography against Raniere, was hidden away by others, primarily Clare Bronfman [and] told that the FBI was after her. And she was hidden in an apartment…

THE COURT: Let’s switch gears to [Sara Bronfman]…

GOELMAN: … Ms. Sara Bronfman says in her motion to dismiss … that the First Amended Complaint [is] vague [in its] allegation that Clare and Sara Bronfman provided the funds for the rent of premises and the purchases of equipment used in the unauthorized human research through ESF [Ethical Science Foundation] substantially assisting [Dr. Brandon] Porter. I don’t know how anyone can call that vague. It says how they assisted, what entity they used to funnel money, the specific use of the money.

MK10ART’s painting of the human experiments

THE COURT: … So which predicate act are we talking about here?

GOELMAN: …. Your Honor, [ESF] actually doesn’t have to do with the RICO claim. [As for the RICO claim a predicate act of RICO is] the witness tampering with Adrian.

Sara Bronfman attempts to get him to go abroad so that he can’t testify in the criminal case. … Sara Bronfman actually concedes that witness tampering is a plausible predicate. And you know, intimidation of witnesses is a primary tool in the Mafia tool kit –

THE COURT: [the complaint says that] In the days leading up to trial, Sara Bronfman and her husband attempted to obstruct by employing false pretenses and promises of money to entice Adrian to leave the United States, and remain outside of it through the criminal trial. I understand the import of that reference to money… I think … the specific monetary amount needs to be stated, but what are the false pretenses that you’re referring to?

GOELMAN: That he should go to Europe so that he can pursue this promising career opportunity.

THE COURT: Is that alleged in there or are you just saying false pretenses with no additional detail?… so the false pretense is that there’s a promising career opportunity awaiting him in Europe, assuming he departs now and stays out of the United States for the duration of the trial…. that’s one predicate act of witness tampering. What’s the second… predicate act [two predicate acts are required for RICO] that you allege as to Sara Bronfman?

GOELMAN: Aiding and abetting, immigration fraud. Founding an organization called ESF, which was supposedly to sponsor foreign nationals for educational scholarships so they could get visas to come to the United States. And then, putting these people to work in the Rainbow Cultural Garden, which Sara Bronfman founded and I believe ran. And then, that caused them to lose their immigration status….

THE COURT: So everybody who gives somebody who’s in the United States on a student visa a job, thus undermining their student visa immigration status, you’re saying is committing this crime?

GOELMAN: …If you sponsor students to come to the United States under the false pretense that they’re going to get a scholarship and they’re going to be a student. And what you really do is you put them to work and pay them very little and are aided by the fact that they’re then illegally in the country, that that qualifies for [immigration fraud]… a violation of [The Illegal Immigration Reform and Immigrant Responsibility Act 8 U.S.C. §] 1324 to encourage or induce aliens to come to or reside in the United States with knowledge or in reckless disregard of the fact that such coming to residence would violate the law. You have people come into the country under false pretenses, that’s against the law.

THE COURT: Okay, but all this says, if I look at [paragraphs] 705 and 706 [in the civil complaint], is that Sara, together with others established these two nonprofits. But you don’t say that she made any of the false representations about student immigration status or even that she knew about it… You’re just saying the fact that an entity that she started employed these people…

GOELMAN: Yeah, so she starts an entity, ESF, says we’re going to sponsor students to come in here on student visas, right? They get there and then a different entity, which she also founded and controls, [Rainbow Cultural Garden] put them –

THE COURT: Where does it say that she said that we’re going to sponsor people on student visas?

GOELMAN: … paragraph 6, that Defendants used ESF to sponsor foreign nationals for educational scholarships, so they could get visas to come to the United States.… I understand that, you know, a title by itself may not mean that a person actually did a particular action, but if you are the founder and operator of a fraudulent foundation, I think that it’s not too great a leap to say that, you knew or at least were willfully blind in not knowing what the foundation was doing….[This was] Ms. Sara Bronfman…  her organization. And these are not, you know, multinational companies….

THE COURT:… So going back to the predicate acts alleged as to Sara Bronfman, the first one was witness tampering, right?

Sara Bronfman’s lawyer, James D Wareham spoke:

James Wareham of Fried, Frank, Harris, Shriver & Jacobson, LLP represents Sara Bronfman.

WAREHAM: …. Sara Bronfman left the United States in 2011. Sara Bronfman was never… a target in a criminal act that kind of underlies this thing. She was never a witness. She was interviewed –

THE COURT: Did she speak to… Adrian about leaving the country for the duration of the criminal trial?… I’m asking whether there’s even a general reference in the complaint to Sara Bronfman’s participation in this conversation about – [Adrian leaving the USA while the Raniere trial is ongoing]

GOELMAN: Paragraph 855, Your Honor. Sara Bronfman and her husband.

THE COURT:… Saying [to] somebody — I’ll set you up in a promising career opportunity in Europe if you leave the country right now, knowing that that person is a likely witness in a criminal trial that’s set to begin imminently, that’s –

WAREHAM: Well, that’s a hypothetical not in the complaint….

THE COURT: Okay. Put aside that for a moment. And talk to me about the second predicate act that we spoke to Mr. Goelman about, aiding and abetting immigration fraud through the establishment of the two entities [Rainbow Cultural Garden and Ethical Science Foundation].

WAREHAM: … There’s not a solitary allegation that Sara took any action with respect to any alien. None are identified in the amended complaint. They point to impermissible group pleading arguments, [accusing every defendant of everything in the complaint]…You got to talk about individual……cWe can’t tell who was harmed when or where by Sara Bronfman for any single count …

THE COURT: [we need to have a] level of specificity [as to whom Sara Bronfman harmed] if we can. Okay, so I think I have at least clarity in my mind…


Stay tuned for Part 4 when the judge turns his attention to Nicki Clyne.


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Frank Parlato


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  • Everything about “Nxivm” is extremely disturbing:

    “… Kristin Snyder’s first 16-day ESP intensive course was taught by Salzman in Anchorage in November 2002, Clifford said. She ate it up and demanded more, her partner said.

    The Snyders said they knew something had changed when Kristin Snyder visited the family’s 300-acre cotton farm a few weeks after her first intensive. They say they hardly recognized the tearful, angry woman.

    When her parents challenged her about NXIVM, Kristin Snyder would cut off discussion and telephone her ESP “coach,” her mother said.

    “She had this ‘We can do anything we want to do’ attitude,” Jonnie Snyder said. “She thought Keith was incredible.”

    Kristin Snyder visited ESP headquarters in Halfmoon for several days in January 2003 to learn more about the group. When she returned to Anchorage, she was sleep-deprived and seemed irrational, but intent to start another $7,000, 16-day intensive, Clifford said.

    “She went to Albany and said, ‘Vanguard doesn’t sleep, so I don’t need to sleep,’ ” Clifford said.

    NXIVM’s customs made Clifford uncomfortable, but she said she signed up for an ESP intensive to support her partner.

    Kristin Snyder became emotionally disturbed on about the 10th day of that session, Clifford recalled, but a NXIVM instructor told her and other students to ignore suicide threats Kristin Snyder was making, saying they were just attempts at getting noticed. After being rebuffed for medical attention, Kristin Snyder left the hotel. Clearly upset, she waved goodbye to Clifford through a window as she walked away.

    “I was told (by a NXIVM instructor) not to bring her to the hospital. That’s what makes me feel really bad,” Clifford said.

    During the training, Kristin Snyder came to believe she had been sexually abused as a child and that she could not remember parts of her past, Clifford and the Snyders said. In her last days, she became so consumed with remembering details from her early childhood that she often called her parents to ask about mundane memories such as the costume her sister wore one Halloween, Jonnie Snyder said.

    The Snyders said they have no reason to suspect their daughter was ever molested. When she last spoke to her parents, Kristin Snyder told them that she was responsible for the explosion of the space shuttle Columbia, her mother said.

    Though no body has been found, memorial services for Kristin Snyder were held on Resurrection Bay and in Anchorage last February. A Catholic Mass was celebrated in Dillon last March 14 and 15.

    The Snyders have taken no legal action against NXIVM, though they blame it for their daughter’s disappearance.

    “I do, indeed, feel that her involvement in ESP was a first-cause factor in her death,” her father said. “As it was, her personality disintegrated right before their eyes, and no one knew how to pick up the pieces. I do not believe that Kris wanted to kill herself. She cried out for help for almost a week, but was totally ignored.”

    In the four months that Kristin Snyder took classes, she paid $14,000 for the two 16-day courses and an additional $2,000 for two weekend courses, Clifford said.

    “And she was a frugal woman,” Clifford said.

    Clifford’s NXIVM bill was $11,500. She sold the couple’s Tacoma truck to help pay it, as well as Kristin Snyder’s $16,000 debt. She said NXIVM rejected her request for a partial refund for the second intensive course. …”

  • Sara was smart enough to skidaddle and is living the life of luxury. The least she should do is pay damages.

    Let’s not pretend any of this has to do with laws.

  • They are horrible people. Given so much by their parents and used it to destroy lives. Nothing happened without the Bronfman money.

    How has Nicki Clyne managed to get away with all of this? She’s a Canadian and was a leader in recruiting women and taking collateral. She’s out there gloating on social media as others are in prison.

  • Bronfman, Roberts, Clyne et al look over the hill in these old photos you post.

    They are even more haggard now.

    Hope their search for the new Virgin Successor is going well for them.

    • Sara Bronfman, Clare Bronfman and Nancy Salzman were honored members of the Clinton Global Initiative. Membership is allegedly by invitation only and requires at least a $15,000 donation per year.

      It’s interesting to note that an early description of NXIVM as a “cult” in 2007 was over their lavish donations to the Democrat Party:

      So this video of Joe Biden smirking as he “promises” that “we will bring an end” to Nord Stream 2 is not irrelevant here. These are NXIVM’s peeps. This is gross international terrorism, carried out by a senile and incontinent moron, whose only concern is to cover up his family’s vast criminal enterprises in Ukraine (including biowarfare labs), China, Russia and elsewhere. Don’t forget it was Hunter Biden who was laundering money from the wife of the former mayor of Moscow, if you’re looking for Russian connections.

      And that evil goblin Victoria “Fuck The EU” Nuland is without question one of the most toxic and malignant “diplomats” in modern history. After orchestrating the coup in Ukraine that caused all the trouble and installing her hand-picked Nazis, she then openly smirked as she boasted that “one way or another, Nord Stream 2 will not move forward” — and then smirks again as she tells Ted Cruz how “gratified” she and the administration are (she very directly links this “gratified” statement to the whole Biden administration) that the pipeline is now a “twisted hunk of metal” on the sea floor.

      Does she think she’s being clever? Is there anyone here who doubts that she is openly gloating over this successful sabotage? I mean seriously, is there anyone here who believes (as Biden said) that it was actually the Russians who blew up their own pipeline? When all the investigations show absolutely no trace whatsoever of any Russian involvement? Please put your hands up, I want to see you.

      So if you openly “promise” to “put an end” to the pipeline, then blow it up, then boast about it — with Blinken saying withing 24 hours that this sabotage opens “tremendous opportunities” for Europe — then you shouldn’t be surprised that all the details get leaked. If you’re so damn proud of what you did, you should admit it and say “THIS is the new rules-based world order.”

      What is especially fascinating in Seymour Hersh’s account is how these open threats by Biden were quite calculated, this was how they got around having to ask Congress for permission for these attacks. I still don’t fully understand the twisted logic, but I do understand that Joe Biden truly believes he is being very clever by making these open boasts. You could see it in his face, he just couldn’t wait to make his “promise.” After all, he is The Big Guy.

      You literally have rogue terrorists in the White House, blowing up critical infrastructure that is going to devastate Europe, and who then tell the Europeans it’s all a “tremendous opportunity” to free themselves from the terrible oppression of cheap and plentiful energy from Russia, and rather pay far higher prices for American gas and “freedom” and “following the rules-based world order.”

      I’m sorry, but something really has to be done now, and it requires Americans to wake up, which I know is painful. Wake up from the woke nightmare and understand that your country is truly on an evil and catastrophically destructive path, with stupid and malicious monsters in charge, flailing about and doing everything they can to precipitate global nuclear conflict. That vicious troll Victoria Nuland is personally responsible for the deaths of hundreds of thousands of Ukrainians. Take a look at her track record and you’ll see she’s responsible for murder and mayhem wherever she sticks her nose. Like Sara Bronfman, she also got involved in Libya, with absolutely disastrous effects.

      She also pushed the stinking fake Steele dossier, to try and smear Trump — so she is a nasty partisan hack.

      Personally, despite the overwhelming detail, I don’t believe Seymour Hersh’s account is anything like the full story. It all seems to come from a single source. For one thing, it completely neglects the British and puts huge blame on the Norwegians for this sabotage. Please don’t tell me that the UK wasn’t involved. Why was Liz Truss removed so quickly from office? She was alleged to have breached security through careless use of mobile phones:

      The Russian foreign ministry commented officially on leaked information that Liz Truss texted Blinken minutes after the pipeline was blown up, to say “It’s done.” Kim Dotcom claimed that he got this information from iPhone administrator level access. So were the Brits part of the communications network, liaising between the Norwegians and the Americans? And was Liz Truss so delighted at the news that she just had to send a quick, insecure text to the Americans? And become the shortest-reigning PM in recent British history?

      Are you Americans happy to be open international terrorists, bringing misery and destruction to your European “allies”? And how do Europeans feel, especially the Germans, because they paid for this pipeline? Remember what Victoria Nuland said: “Fuck the EU” (see 3:10 into this video). That’s how much NATO cares about you.

    • Shadow- why is Tucker so pissed everyday of the year?

      Even when Republicans controlled both houses of Congress and the White House—Tucker still had tantrums.

      Last question!

      Why does Tucker dress like a
      Lands End model?

      • Why does Tucker dress like a Land’s End model??
        For reasons the social class to which you and your parents belong, was not given by nature, the privilege to understand.

      • Looking back on it all, he’s got to be thinking that the whole branding of a married woman probably wasn’t such a good idea. Dude would still be getting group blowjobs all day long.

        Instead, you get torturous prison confinement with feces on the wall, an occasional punch to the face, and fuckin’ Suneel is your only friend. ¯\_(ツ)_/¯

  • What I would be interested in is where they procured the snuff movie video – the source of it. This is an extremely important question because if someone paid money for it, it could be argued that that money directly or indirectly subsidized mass murder. The other question arising is whether Raniere actually commissioned it himself.

    The fact that it appears to have taken place in Mexico prompts questions surrounding whether the Bromfmans funded its purchase through their own high level contacts there. Was Porter himself aware of its source? If not, who else in NXIVM might have known about it?

    I don’t know about anyone else, but I watched it on FR along with the other videos, which were all pretty tame by comparison. I’d never watched a snuff movie before, but being a horror buff perhaps underestimated its impact. It was by far the most disgusting and disturbing thing I’ve ever seen.

    I’d love to hear from Porter on precisely what the goal of the Fright Experiment was. What the fuck was he thinking, and how exactly did he imagine it was going to contribute to medical science?? I guess these are questions only he can answer, and I trust they’ll be put to him in Court.

  • Judge Komitee sounds like a no-nonsense kind of guy. He said, “… In determining whether claims against a defendant should be dismissed … We’re testing the legal sufficiency of the complaint. We’re limited to the factual allegations that fall within the four corners of the complaint – except to the extent to which there are matters of which the Court can take judicial notice …”

    There should be a law on the books making sure lawyers in courts are no-nonsense, too:

    1. just the facts
    2. straight and to the point
    3. full disclosure of everything they know about whatever’s discussed
    4. as soon as possible

  • Posting that banner picture, especially near the dinner hour should be a crime. She looks painfully constipated and in mile 23 of a marathon at the same time.

    • Agreed, Snorlax.

      Frank, please no more unfiltered pics of either of the horse-faced Bronfman Demons. I vomited in my mouth when I saw Saras disgusting, smooshed in little face.

      Question to all: Would you rather spend one romantic evening with Clare or get water-boarded for 72 hours straight?

      • As Nice Guy tells the story, Snorlax once considered marrying Clare Bronfman and the heiress apparently was eager enough because of Snorlax’s evident charisma but at the last minute they broke it off. Nutjob asked Snorlax about how he felt about not marrying the heiress and Snorlax replied ‘I am sad about it every day and happy about it every night.’ At least that’s the story I heard.

          • There is a story, told by Snorlax or some other comedian I believe, that Nice Guy met a girl online. They agreed to meet in person in a secluded area near a thruway rest stop [a class date for Nice Guy]. But when the girl saw how different he was in person than his profile she fled into a nearby field.

            Nice Guy thinking she was sporting, ran fast after her. The woman knew she could not outrun him, and seeing his grinning face nearer than before, she became desperate. Spotting a big tree with its low branch 20 feet up, she resolved to make one desperate leap in the hope of grabbing its branch and escaping his embarces. She jumped hard but missed the branch.

            But it was OK because she caught the branch on the way down.

About the Author

Frank Parlato is an investigative journalist.

His work has been cited in hundreds of news outlets, like The New York Times, The Daily Mail, VICE News, CBS News, Fox News, New York Post, New York Daily News, Oxygen, Rolling Stone, People Magazine, The Sun, The Times of London, CBS Inside Edition, among many others in all five continents.

His work to expose and take down NXIVM is featured in books like “Captive” by Catherine Oxenberg, “Scarred” by Sarah Edmonson, “The Program” by Toni Natalie, and “NXIVM. La Secta Que Sedujo al Poder en México” by Juan Alberto Vasquez.

Parlato has been prominently featured on HBO’s docuseries “The Vow” and was the lead investigator and coordinating producer for Investigation Discovery’s “The Lost Women of NXIVM.” Parlato was also credited in the Starz docuseries "Seduced" for saving 'slave' women from being branded and escaping the sex-slave cult known as DOS.

Additionally, Parlato’s coverage of the group OneTaste, starting in 2018, helped spark an FBI investigation, which led to indictments of two of its leaders in 2023.

Parlato appeared on the Nancy Grace Show, Beyond the Headlines with Gretchen Carlson, Dr. Oz, American Greed, Dateline NBC, and NBC Nightly News with Lester Holt, where Parlato conducted the first-ever interview with Keith Raniere after his arrest. This was ironic, as many credit Parlato as one of the primary architects of his arrest and the cratering of the cult he founded.

Parlato is a consulting producer and appears in TNT's The Heiress and the Sex Cult, which premiered on May 22, 2022. Most recently, he consulted and appeared on Tubi's "Branded and Brainwashed: Inside NXIVM," which aired January, 2023.

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Contact Frank with tips or for help.
Phone / Text: (305) 783-7083