Sara Bronfman Motion to Dismiss NXIVM Lawsuit – It Is Still a Shotgun!

sara bronfman headshot photo
Sara Bronfman

The lawsuit is a quest for Bronfman money.

Seagram’s heiress, and NXIVM financier, Sara Bronfman, filed a motion asking Judge Eric Komitee to dismiss the lawsuit against her in Edmondson et al v. Raniere et al.

The lawsuit was filed in the U.S. District Court for the Eastern District of New York. 

The basis of Bronfman’s motion is that the complaint is a “shotgun” complaint.

A shotgun, also known as impermissible group pleadings, is where a group of plaintiffs asserts multiple claims against multiple defendants without specifying which defendants are responsible for which acts or omissions, often using vague and immaterial facts in the counts.

The law firm Kohn Swift, with lead attorney Neil Glazer, represents the plaintiffs. Glazer first filed a complaint in January 2020. 

Presently 70 former NXIVM plaintiffs are suing Bronfman and her currently incarcerated sister, Clare Bronfman, plus a few far less wealthy NXIVM co-defendants who are there to tie bad conduct to the two sisters.

Clare Bronfman is one of two key targets in the lawsuit.

The remaining defendants have little or no money, and this is litigation seeking money.

The other defendants are NXIVM founder Keith Raniere, now incarcerated; Allison Mack, also incarcerated; Kathy Russell, who is on probation; Danielle Roberts and Brandon Porter, who both lost medical licenses for NXIVM-related conduct; and Nicki Clyne.

Throughout the three years of the case, the plaintiffs have dismissed claims against NXIVM leaders Nancy Salzman [now incarcerated], Lauren Salzman [on probation], and Karen Unterreiner, and first-line masters from NXIVM’s sorority, DOS, Daniela Padilla, Rosa Laura Junco, Loreta Garza, and Monica Duran. Lauren Salzman was also a first-line master in DOS.

On August 13, 2021, the Plaintiffs filed a 217-page First Amended Complaint, asserting 16 claims against various defendants on behalf of over 80 plaintiffs.

On October 15, 2021, Judge Komitee held a conference and asked whether Glazer would like to amend his complaint before the defendants filed motions to dismiss.

On October 28, 2021, Sara Bronfman and other defendants submitted letters regarding proposed motions to dismiss.

On November 12, 2021, Glazer said he would “move forward with the current Complaint.”

At a status conference on November 30, 2021, Judge Komitee again asked Glazer if he intended to amend. Judge Komitee cautioned him that group pleading could “determine whether any dismissal, if one occurs, should be with prejudice or without prejudice.”

Glazer told Judge Komitee that he did not believe “it would be productive . . . to amend the complaint in any way.”
On February 25, 2022, Glazer filed a Second Amended Complaint, naming and removing several plaintiffs but not altering the complaint.

On February 1, 2023, Judge Komitee held an oral argument on the motions to dismiss. For the first time, Glazer did not appear for a hearing.

Kohn, Swift lawyers Craig W. Hillwig, Zahra R. Dean, William E. Hoese, and Aarthi Manohar, and Zuckerman Spaeder lawyers Aitan D. Goelman and Bryan M Reines represented the plaintiffs.

The judge asked the plaintiffs’ attorneys if they would like to simplify the 217-page Second Amended Complaint to make it “easier for everybody to understand what they’re accused of.”

He said he would allow the plaintiffs to submit a proposed Third Amended Complaint, adding that he was less likely to dismiss the case if the plaintiffs simplified and streamlined it.

He would also allow the defendants to object to its filing and then decide whether to let the case proceed, subject to further motions to dismiss by the defendants.

While her sister Clare chose not to challenge the plaintiffs’ motion asking leave to file an amended complaint, Sara Bronfman has submitted a memorandum of law opposing the Plaintiffs’ motion.
Robin A. Henry, Anne S. Aufhauser, Alexis R. Casamassima, and James D. Wareham of Fried, Frank, Harris, Shriver & Jacobson represent Bronfman.

Henry wrote:

Plaintiffs have been on notice of the deficiencies of their complaint since October 2021… In the 17 months since, Plaintiffs have repeatedly declined the Court’s invitations to meaningfully amend their complaint.
Their proposed Third Amended Complaint… engages in impermissible group pleading, lumping individual Defendants together into a convenient “Inner Circle,” and continuing to assert claims on behalf of 70 plaintiffs without identifying how each individual Defendant is responsible for the alleged harm to each individual plaintiff.
At 112 pages and attaching a 17 page chart identifying Plaintiffs, the proposed Third Amended Complaint can hardly be called a “short and plain statement” consistent with Rule 8.2…
Plaintiffs’ brief identifies only one instance in which they added
information about Sara Bronfman (pertaining to a RICO predicate act), and their remaining “new” allegations merely invite speculation that Sara Bronfman had to have known about or must have participated in alleged wrongdoing simply because she held titles in and participated in an organization — an organization in which many Plaintiffs also held titles and leadership roles….
The [Proposed Third Amended Complaint] re-pleads six counts against Sara Bronfman without remedying any of their fatal infirmities…. by engaging in impermissible group pleading….
With respect to group pleading of the Defendants, the PTAC… lumps Sara Bronfman into Raniere’s purported “Inner Circle,” alleging that, as a member of the so-called Inner Circle, she “operated and furthered” DOS without making any specific allegations specifying how, when, or to what extent she did so….
Instead, Plaintiffs make sweeping allegations about the Inner Circle’s purported misconduct without stating whether all supposed members engaged in all alleged conduct. For example, the PTAC alleges that “Defendant Mack and other Inner Circle members had edited the video [of the DOS branding] to make it appear as though Edmondson had consented to the branding…”
It does not clarify who these “other Inner Circle members” are, and whether they purportedly include Sara Bronfman.
The Second Circuit squarely rejects this type of group pleading.

If the judge dismisses the claims against Sara Bronfman, this civil case will have lost a large slice of its value. While the claims against Clare Bronfman are more severe than against her sister, both women willfully financed the demonic enterprises of Raniere, hardly caring who they hurt.

If the judge dismisses the claims against Sara because of shotgun or group pleadings, will he dismiss the claims against Clare too?
Some say this lawsuit is not about money. It’s about justice. That may be true for some plaintiffs. But for the lawyers representing the plaintiffs, this is about money. They are not victims. They are lawyers, and this is their living. They are not offering their services pro bono. They take a neat one third of the award, if any. And if there is none, they spent years working on a case for nothing.

If the judge dismisses the claims against the two Bronfmans, this lawsuit will end in two minutes. The battery of lawyers from two law firms representing the plaintiffs will not come from Philadelphia and Washington DC to Brooklyn to show what a rat’s ass Keith Raniere is or collect money from Kathy Russell.

This lawsuit is a quest for Bronfman’s money, and the judge made it clear in February that he would dismiss the case if they did not cure their shotgun pleadings.

They came back with another complaint that, if it is not a shotgun, it seems to smell a little like gun smoke.

What the judge decides on this motion may tell the whole story of this case.

About the author

Frank Parlato


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  • “On the morning of November 4, 2019, an unassuming caravan of women and children was ambushed by masked gunmen on a desolate stretch of road in northern Mexico controlled by the Sinaloa drug cartel. Firing semi-automatic weapons, the attackers killed nine people and gravely injured five more. The victims were members of the LeBaron and La Mora communities—fundamentalist Mormons whose forebears broke from the LDS Church and settled in Mexico when their religion outlawed polygamy in the late nineteenth century. The massacre produced international headlines for weeks and prompted President Donald Trump to threaten to send in the US Army.

    In The Colony, bestselling investigative journalist Sally Denton picks up where the initial, incomplete reporting on the attacks ended and delves into the complex story of the LeBaron clan. Their homestead—Colonia LeBaron—is a portal into the past, a place that offers a glimpse of life within a polygamous community on an arid and dangerous frontier in the mid-1800s, though with smartphones and machine guns. Rooting her narrative in written sources as well as interviews with anonymous women from LeBaron itself, Denton unfolds an epic, disturbing tale that spans the first polygamist emigrations to Mexico through the LeBarons’ internal blood feud in the 1970s—started by Ervil LeBaron, known as the “Mormon Manson”—and up to the family’s recent alliance with the NXIVM sex cult, whose now-imprisoned leader, Keith Raniere, may have based his practices on the society, he witnessed in Colonia LeBaron.

    The LeBarons’ tense but peaceful interactions with Sinaloa deteriorated in the years leading up to the ambush. LeBaron patriarchs believed they were deliberately targeted by the cartel. Others suspected that local farmers had carried out the attacks in response to the LeBarons’ seizure of water rights for their massive pecan orchards. As Denton approaches answers to who committed the murders and why The Colony transforms into something more than a crime story. A descendant of polygamist Mormons herself, Denton explores what drove so many women over generations to join or remain in a community based on male supremacy and female servitude. Then and now, these women of Zion found themselves in an isolated desert, navigating the often-mysterious complications of plural marriage—and supported, Denton shows, only by one another.

    A mesmerizing feat of investigative journalism, The Colony doubles as an unforgettable account of the sisterhood that can flourish in polygamist communities against the odds.“

  • I don’t think Sara B was ruthless like her sister Clare. Sara has the looks. She used her good looks and wealth to procure younger men to satisfy her. In some ways she wanted a “mans version” of DOS so she could have her own selection of guys similar to what KR had with the women.

  • Do Bronfman sisters think about the suffering and cruelty they unleashed upon others at Keith's request? says:

    I don’t agree with this lawsuit, because I think Sara Edmonson et al already got justice in that regard. However, I do feel Clare deserves to be sued by Susan Dones, Barbara Boucher, Toni, Frank, and everyone else who was harassed and financially tormented, some financially ruined, by Clare’s hired guns.

    By all accounts, Clare was ruthless and had so much more financial power to go after anyone Keith asked her to. From former romantic partners, to critics, Keith pointed his finger, and she unleashed the dogs. Clare needs to be stopped from continuing to do that, and I definitely feel that Clare’s victims deserve restitution. There should be enough evidence showing who she targeted and how much it cost them.

    Sara and Clare, every time you hired lawyers to go after someone, it was equivalent to picking up an axe and hacking them to pieces. Do you not understand how evil and destructive your actions were? You used your money to destroy people. Not to alleviate suffering, but to CAUSE suffering. Do you ever think about that? Do you ever think about all the people Keith Raniere got YOU to cause enormous suffering to?

  • Why are people saying Nicki Clyne jumped ship because of Allison’s early release from prison? I don’t get the connection.

    • Neither do I (get the connection). But I do feel that Nicki has made that public announcement because she felt forced into it, not because she truly came to her senses. It happened too suddenly (just days prior she was defending him). Plus, the wording in her statement is “I will not publicly support Keith…” Keyword there is “publicly” support him. Privately she still does?

      I think her statement is either part of some secret settlement, or she feels the statement was required to protect herself from something coming down the pike. Nicki deleted a lot of DOS videos (the last one recorded just days before her statement) where she fervently supported Keith and expressed her love and admiration towards him. You don’t go from that to her statement literally overnight.

      So something happened, (something quickly) and unfortunately, I really don’t believe that she suddenly saw the light. She’s been oddly silent since her 33 point statement. She never once questioned any of those points prior, had denied all of them, and 48 hours after defiantly expressing her support of Keith, she releases a written statement (not a video) that states, “I will no longer publicly support Keith Raniere”. Why is the word “publicly” in there?

      And why hasn’t she released a single video since so-called denouncing him? She wasn’t afraid to show her face so people could read her emotions when she was supporting him, so why is she suddenly so camera shy, not wanting to publicly show her face? Is it because her face would betray her words?

      Something doesn’t jive here. There’s something just not right about Nicki’s sudden reversal.

  • Sara Bronfman is an angel. She contributed to Keith to help good things to happen. If Keith had not been falsely stopped by you and other beasts by now we would have had cured for cancer. Yes he and the Ethical Science Foundation was working on it. He had discovered the cure for Pam on the day after she died.

    Sara gave off her heart and her pocketbook. You would rather see the money in Mark Vicente hands?

    • You mean, he could have been curing people of cancer in 2012, 2013, 2014, 2015, 2016, 2017…. but he was too busy organizing blowjobs and getting young virgins to use as fucktoys?

      He found the cure for cancer, but didn’t cure one single person in the 7 or so years he was free to do so? Why didn’t he? If he was so smart to cure cancer, was he too dumb to patent the cure? He hasn’t submitted any patent for his cancer cure. Why is that?

      Though I feel like I’m trying to have a conversation with a flea here. I realize you’re so stupid that basic common sense questions are far beyond your capabilities to comprehend or respond to.

      • Keith found the cure in November 2016. He got arrested in March 2018. Less than a year and a half.

        • Keith can’t even cure his own wretched behavior, so Mr. Lazy Ass couldn’t obtain the knowledge nor have the wherewithal to cure cancer. It is also not just one disease, but one with many different forms.

          • So why didn’t he cure a single person in that year and a half? Or file patents, or let hospitals around the world, or anyone else knowing that year and a half? A year and a half is enough time to cure everyone of cancer IF you have the cure. So why didn’t he do anything with it? He certainly had time to have sex with dozens of women in that year and a half. But not the time to cure people of cancer when he, and he alone had the cure? Look up the word naive. That’s YOU. Keith whispered this bullshit lie in your ear and you shockingly believed it, despite it not making any sense whatsoever.

        • Lol ohhh Yolanda…how ridiculously stupid you sound. Stop drinking the Koolaide…get some professional help from a real psychologist…get on your meds and pray you snap out of this delusional state.

          I’m sure if you are aware but KR absolutely did not find a cure for anything…not cancer…not his herpes…literally nothing.

    • Yolanda. You’re saying the most ethical man in the world discovered a cure for a specific cancer, and that’s not what he’s fighting for from prison? He’s never bringing that up whatsoever? Keith is just cool with the fact that he discovered a cure for cancer and it’s not being utilized?

  • Guess I get to side with Sara’s attorneys….lucky me. Hard to believe these complaints were written by actual attorneys, especially Harvard educated ones. They read like pro se pleadings. Rambling and not at all specific. The judge has been exceptionally lenient with Glazer & his team by allowing so many amendments to the complaint. Frankly, I’m surprised we haven’t seen a Rule 11 sanction motions yet. Seems ripe for it.

      • Federal Rules of Civil Procedure, Rule 11, covers what makes a legitimate suit and outlines sanctions for violations. It’s the ‘frivolous lawsuit’ rule.

        All the amended complaints indicate Plaintiffs are struggling to follow 11(b)(3). The complaint is supposed to state a fact alleging a harm to Plaintiff AND also point to which specific defendant(s) committed such harm. The complaints and amendments continuously fail to specify which defendant did which alleged harm. That is the violation of Rule 11 that I am seeing.

    • Le’Gal-

      Thank you for the insight.

      “They read like pro se pleadings…”
      LMAO! Now that’s an insult!

      Glad you’re back!

  • “We will defend our island home,” defense attorney Marc Agnifilo said, paraphrasing a 1940 Churchill speech before the British Parliament during World War II.

    “And I will defend my island home in this courtroom,” Agnifilo continued. “And my island home is that man’s good faith. My island home is that man’s good intentions.”

  • Civil cases ARE about justice too.

    They are also a deterant.

    Bronfman money funded A LOT of vexatious litigation.

    Bronfman dollars subsidized stealing people’s personal information and having women like Kristin Keefe followed while she tried to flee with her child

    There’s been much speculation about what Claire will do when she is released from prison.

    Will Bronfman take back up where she left off going after the “enemies” of the cult?

    Losing a big lawsuit might make Clare Bronfman think twice about endlessly funding further harassment.

    • The Bronfman sisters are community terrorists. They endlessly torment, intimidate, and traumatize women who rejected Vanturd’s advances.

      When Clare is out of prison, she will destroy the women who testified against Vanturd. These women are in extreme physical and psychological danger upon Clare reuniting with the remaining Dead-Enders. Thank God Nicki walked.

  • Regardless of the lawyer fees, courts operate with lawyers a key integral part of the justice system. That’s how it’s done. In pretty much every single country in the world. Except perhaps North Korea.

    The Bronfman’s terrorised women with their wealth.
    Yes they did.
    Both sisters.
    They used their wallet, chequebooks, credit and debit cards and envelopes full of cash. They used it to shut down any accusations against beloved Keith and the rest of the pack of travelling vaginas. They will never understand the carnage their ‘financial generosity’ wrought in peoples lives. They will never contemplate their role in this horror show. Why should they? They will never come to the conclusion that they ever did anything wrong. Wealth like that, you can kill a person and never be held accountable. That’s how that shit works.
    And when Claire is released they will come at the victims again. And again and again.
    They can’t be sued into poverty. Any financial penalty the courts issue won’t even feel like the loss of gum money to them.
    When you are that wealthy you have no personality or character. All you are is a great big pile of stinking money that everyone reacts to. No one ever treated them like a regular person. No one ever said no to them. Keith convinced them they were incredible and part of so something noble and world altering. He gave them a personality, characteristics, an endeavour, and adventure, They felt like the most blessed people on the planet, working with one of the most intelligent, noble humanitarians ever spat out of a vagina ever. And he delivered half of that promise. The world altering part. They had their arms elbow deep in the sexual exploitation of children, young women and socially awkward people unable to cope in the real world. The first nine NXIVM women who were forced to defend themselves into poverty, Barbs, SusanToni et al. And those that followed them. All financed by Bronfman cash.
    Justice may be blind. But it isn’t deaf and dumb and it CAN read a retrieved text message, letter and hear a tape recording of Keith and his predatory paedophilic behaviour. Even if a private school educated woman can’t.
    If anyone connected to the Bronfman’s ever reads this. Please, from me. Just fuck off, leave these people alone. Go live in Fiji or whereverthefuck. Attempt to be a better person. Stop screwing with lives that aren’t your own. Just stop.

  • What no one is discussing here is the real reason for this lawsuit: Jewish Space Lasers.

    The Bronfman’s are GUILTY!

    • Don’t be a Anti-semite!

      The attorney suing the Bronfman is a Jew and the Bronfmans are Jews.

      The space laser – California forest fires thing – isn’t true. We just hire Mexicans with Bic Lighters.

      • Your words there are toxic.

        Your words in that comment serve to divide and to distract.

        What helpful point are you trying to make?

  • Five long years ago …

    “… Well, there you have it – the communications circle is in place. (Clare – Sara – Ben – Michelle – Nancy.) It is horrible that the organization can continue operations from behind the scenes.

    I believe the feds have just scratched the surface of what will turn out to be a massive criminal enterprise with tentacles reaching everywhere …”

  • “It’s not about money. It’s about justice. That’s why they dropped Nancy Salzman but kept Kathy Russell in.” Anonymous

  • The decision whether or not to dismiss is up to Judge Komitee. It’s hardly surprising that Bronfman’s lawyer thinks the plaintiffs’ case is an “impermissible group pleading”

    It ain’t up to him. Nor the Frank Report. It’s up to the judge.

    Anyone who thinks this lawsuit has no chance should read up on the Perdue Pharma case where the Sackler family was held personally liable for their corporation making and marketing an FDA approved painkiller that was distributed legally and properly by prescription only. Also read up on the legal definition of corporations and why they were defined that way, as separate entities under the law.

    The issue is simple: people were harmed by Nxivm. The Bronfman sisters funded it, they funded Raniere’s whole operation. Should they be held financially liable?

    Finally, let me point out that civil law is ancient, a fundamental recourse for righting wrongs. Material recompense for damages. It was how civilization established an alternative to the blood feud. So it’s a bit more than the sordid money-grab the FR asserts.

    • Agreed.

      Bromfman money funded both NXIVM and DOS. Whatever about Sara, Clare must surely have known her money was also supporting DOS. It’s almost inconceivable she didn’t, even with her limited IQ.

      People like “Kevin” might point the finger at Sarah and Mark as being more senior than some of the defendants, but neither of them engaged in the kind of criminality and injury alleged against more senior people in DOS.

  • Wow, what a freaking mess. Kathy Russell the actual accountant for Nxivm is being sued as well? Why?

    • Kathy Russell pled guilty to visa fraud for her role in NXIVM’s immigration fraud scheme. She arranged the payments for Camila’s apartment (facilitating Raniere’s rape of her) and illegally smuggled Daniela into the country (sex trafficking, forced labor). It’s also alleged she was instrumental in much of the frivolous litigation against NXIVM dissidents.

  • — Some say this lawsuit is not about money. It’s about justice.

    It can be about both. Financial restitution for injustice done (whether intentionally or not) has been part of many different societies throughout history for centuries.

    The truth Sarah and Clare were the primary financiers of the NXIVM project and its offshoots, which was proven to be a criminal organization. They are partly responsible for its “livelihood”, just like anyone else who was part of it is partly responsible (in various amounts, large or small) for it.

  • Odd that Glazer did not appear at the February 2023 hearing, given all that he has invested in this case. I seem to recall one of Glazer’s colleagues telling the Court something to the effect of: “He’s not here today, and that’s all I can say about that.” Very cryptic. Health issues?

  • How many people willingly funded “NXIVM” crimes, how many apologized and how many were punished?

  • Do believe way back when I (and others) described the lawsuit as a shotgun approach. Didn’t realize it is apparently a legal term too called a “Shotgun Pleading”. The things you learn.

    Seems like the judge in one of the recent meetings indicated he was thinking it was one too but I may reading too much into my vague recollections of what read on that.

  • I disagree with your premise that the lawyers are in it for the money.

    The half dozen lawyers will continue to invest their time to prove in court that Keith and others are bad even if Bronfmans are out.

    It’s not about money. It’s about justice. That’s why they dropped Nancy Salzman but kept Kathy Russell in.

    • …..Nancy Salzman but kept Kathy Russell in.

      Nancy is probably going to be named as a material witness.

      Nancy getting dropped from the lawsuit was not about Justice.

      • First time I’ve agreed with Nice Guy
        Nancy was up to her eyes balls and also EM’ d many people over and over and over and over Again, even after he was arrested!!!
        Loose your fear dear!!

        • Sarah Edmondson’s book notes a few subtle dynamics that speak volumes about that well-funded criminal enterprise.

          ESP/NXIVM wasn’t just a frivolous “sex cult” involving a few interesting people as some commenters want readers to believe.

          That group was as organized as Jeffrey Epstein’s “Intelligence” racket and a few well-placed feds allowed ESP/NXIVM to get established and thrive for about 20 years.

          Did ESP/NXIVM serve to help globalists take control of the world through brainwashing, blackmail, various positive incentives and control? How many “centers” did they set up in Mexico? How many in Mexican government were actively involved and how many had no idea they were fooled?

          Sarah wrote about a peculiar experience at “V week” in August 2005. Sarah she was eating an apple. Nancy walked up to her and said, “You’re not supposed to eat during trainings.” Sarah responded, “Oh, I’m sorry. I didn’t realize a forum is a training.”

          Nancy told Sarah: “You’re mad-dogging me. Next time you’re hungry or tired, I would advise you to change your state.”


          Was Nancy’s response a normal response to someone eating an apple? Was that a “NXIVM tech” response?

          Was that response also close to what Ghislaine Maxwell might have told a worker or a slave on a Caribbean island or a mansion in Manhattan?

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.” He also appeared in "Branded and Brainwashed: Inside NXIVM, and was 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 premieres on May 22, 2022.

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