This just came in and adds to our knowledge of Keith Raniere and his soon to be transferred cellmate, William Anthony ‘Toni’ Fly.
Declaration/Affidavit of Keith Alan Raniere, #57005-177, 11/22/22
By Keith Raniere
I am an inmate at USP Tucson, currently in the S.H.U. on administrative detention and referred for transfer.
I object to my circumstances and feel I should not be transferred for the stated reasons of too many legal visits and calls (all approved by my Unit team), and too many administrative remedies (I believe six from the time I was placed in the S.H.U.)
I have been in the SHU for approximately 120 days.
My cell-mate in the S.H.U. is inmate Toni Fly, #18658-023.
I am appalled by the direct dishonesty I have seen in my case by the B.O.P. and its representatives.
Assertions the B.O.P. makes are often directly contradicted by their own preferred evidence. I have also observed the same in Toni Fly’s case (4:21-cv-00506-SHR).
I believe by showing some of these contradictions in Toni Fly’s case a fuller picture of the bad-faith B.O.P. culture of legal deception can be seen.
Toni Fly and I have the same USP Tucson Attorney in our cases.
In Doc 55 filed 10/28/22, pg 5, lines 15-18, Toni Fly opposition states Toni Fly has not been diagnosed with any of a list of ailments of which she complains.
This assertion is absurd and can only be categorized as a knowing, calculated lie. Amongst these conditions are asthma, allergies, Reynaud’s syndrome, and poor vision.
Within the B.O.P’s own submission is Doc 55-1, attachment 1 to exhibit C.
I know Toni Fly receives prescribed medications for some of these conditions and definitely needs eyeglasses.
If one examines the above attachment, one with find a page with a date of 8/17/22 titled “Clinical Encounter” to see Toni Fly is prescribed an asthma inhaler (RX# 392742-TCX, created at USP Tucson).
Using this attachment, one will find records of allergies, and Reynaud’s diagnosis (noted by Dx).
In my case, I have found that the B.O.P. will say whatever they want to achieve whatever they want – even if it is improper and untrue.
The administrative remedy process works the same way.
More than 1 year ago, I was placed in the S.H.U. – again for retaliation for my legal cases – and given 2 shots. This month, I received the final answer to my administrative process journey to get these improper shots expunged. (I told another inmate to tell my 15+-year partner, [Nicki Clyne] with whom I had very active and extensive communication, to “send her my love, I will see her Saturday.”)
I did not violate any policy and should not have gotten the shots.
My request for expungement was denied, and to date I have not been told any policy which I violated.
National [ BOP] sat on this for 3 months, and the National Administrative Remedies Coordinator (1), Ian Conners, did not even initial this denial, although it has a place for signature.
After more than a year, going through the administrative remedy process was not only fruitless, I still do not know what policy I violated. How can I be sure I won’t offend again?
Additionally, through this lawsuit, I was encouraged to file administrative remedies on other retaliatory events (some of them).
I now sit in the S.H.U. for 120 days and counting, in part, because I filed these remedies. Furthermore, I am being transferred, because of these remedies and this legal action.
How can I file an admin. remedy about being punished for filing them?
I certify under penalty of perjury, the above is accurate and true to the best of my knowledge. I also grant my attorneys the right to retype, edit, and format this affidavit, and sign for me using this as a reference document.