Defendant Danielle Roberts, acting as her own lawyer, filed a declaration in opposition to the plaintiffs’ motion for leave to amend their Complaint in Edmondson v. Raniere.
The lawsuit pits 70 former NXIVM members as plaintiffs against wealthy sisters Clare and Sara Bronfman and a handful of NXIVM defendants – three of whom are not defending themselves and three representing themselves as their own lawyer.
The non-Bronfman defendants are Keith Raniere, Allison Mack, Brandon Porter, Roberts, Nicki Clyne, and Kathy Russell.
Oddly, claims against Nancy and Lauren Salzman were dismissed.
None of the non-Bronfman defendants have enough money to justify a lawsuit with a dozen lawyers and 70 plaintiffs.
Roberts, a physician who lost her medical license for her role in branding women in DOS, features in her declaration a history of delays in this case and arguments for the judge to deny the plaintiffs another bite at the apple.
She also defends her role in DOS.
If Judge Komitee grants the defendants leave to amend the Complaint, it will be the fourth version over three years.
January 28, 2020
The Plaintiffs filed their original Complaint.
August 13, 2021
Plaintiffs filed the First Amended Complaint. (FAC)
October 15, 2021
At a status conference, Judge Komitee instructed the parties to file letters discussing, among other things, issues bearing on amendment or dismissal of the Complaint.
Sara Bronfman’s attorney James Wareham said the plaintiffs have “already taken their ‘as of rights’ amendment opportunity and this is the second version of this Complaint. So it seems a little odd to me that they’re going to put in writing a third version [the Second Amended Complaint] of the Complaint.”
Judge Komitee said, “it’s early enough that it may be the better course to let them amend one more time now, instead of fighting about that question later.”
November 24, 2021
Danielle Roberts wrote to the judge and the plaintiffs, pointing out deficiencies and the motions she would file if the plaintiffs did not cure the defects.
November 30, 2021
At a status conference, Judge Komitee said, “just to make sure that we’re not going through the entire process of briefing motions to dismiss, orally arguing those motions to dismiss, writing a long decision on a motion to dismiss only to have the Plaintiff come back and say, ‘look, any dismissal should be without prejudice for us to replead with new facts.’ Obviously better and amend up front where possible…. I think there’s been enough of a preview of what the defense arguments will be that the Plaintiffs should have a decent sense of whether that’s something they are interested in or not at this point.”
Attorney for the plaintiffs, Neil Glazer, replied, “we do not believe it would be productive at this time to amend the Complaint in any way. We think that the allegations, the fact allegations, in the Complaint are sufficient to support the causes of action.”
Judge Komitee asked, “What about the group pleading allegation?… But just to be clear, you do not wish the 30 days that I would give you at this point to amend for that reason or any other?”
February 17, 2022
The judge instructed the plaintiffs to file an amended complaint.
February 25, 2022
The plaintiffs filed their Second Amended Complaint [SAC]
February 1, 2023
Judge Komitee heard oral arguments on the defendants’ motions to dismiss- 15 months after the plaintiffs’ attorney said he so no reason to amend the Complaint.
At this hearing, Judge Komitee told the plaintiffs’ lawyers in no uncertain terms that the SAC was so riddled with deficiencies that he would dismiss it “with prejudice” if they did not cure them.
As an example of the shotgun pleadings in the SAC, Plaintiffs, even those not in DOS, alleged sex trafficking claims and forced labor claims against all defendants.
At the hearing, Judge Komitee challenged the plaintiffs to “articulate that [fraud charges] with particularity.”
The Plaintiffs dropped the fraud charges. The plaintiffs were also unable to articulate two valid predicate acts and dropped the RICO claims against Roberts and Porter.
April 3, 2023
Plaintiffs filed their proposed Third Amended Complaint [TAC].
The TAC dropped the sex trafficking count against Defendant Sara Bronfman and dropped the peonage charges against defendants.
Roberts wrote in her declaration:
By Danielle Roberts
I believe the Court will want to seriously consider the frivolity, bad faith and dilatory motives… In addition, the plaintiffs themselves should take a hard look at rule 11, and basis for malicious prosecution and abuse of process.
The distinct information that has been added to the TAC is irrelevant, false and/or prejudicial which adds to my concern that this undue delay, lack of proactive research, shotgun approach and inability to cure are futile and in bad faith, rather than born of innocent incompetence and neglect, which though inconsiderate and wasteful of all of our time and resources, would be important to allow for in order to try this case based on its merits.
However, Plaintiffs seem to be “scrambling to devise new theories of liability” by any means, even at the price of continuing to fabricate information to protect their previously asserted fabrications, and now, legal liability.
I am not a lawyer – but even I can glean from the motions to dismiss 10 months earlier what would have been needed in the SAC.
The Court has continued to make the plaintiff attorneys aware of the need for amendment, but that doesn’t mean that they were not or should not have been aware for all of these months. If the issue was easily remedied it would have been done in a reasonable period of time…
The question remains – Why wait this long? Why use such a shot gun approach? Why add so many unsubstantiated claims that hurt innocent people’s reputation and livelihood that have now been dropped?…
The Plaintiffs have a record in this case of bringing unsubstantiated charges through shotgun pleading by “just throwing a whole bunch of spaghetti at the wall, over hundreds of paragraphs…” to see if something sticks….
Again, I am not a lawyer – but this approach indicates to me reckless frivolity, verging on rule 11 violation. That individuals bring such egregious charges, unsubstantiated, destroying another persons’ hard earned reputation and livelihood is sickening to me….
As previously stated in my motion to dismiss, I was not convicted nor even indicted throughout our Federal Government’s exhaustive investigation in the U.S. v Raniere case, upon which, as cited above, The Plaintiffs substantiate a large part of their complaint. It seems they now trying to establish a connection that FBI agents (the “best” in our country were not
concerned existed between me and this alleged criminal enterprise). I was informed in proffer sessions with Ms. Moria Penza herself that I was a mere witness in their investigation, not even a subject, much less a target…
The Plaintiffs were forced to drop Count 1, acknowledging I was never a part of the RICO claim as they had originally asserted.
Their last recourse is to try to show I had knowledge of and supported the alleged criminal behavior. I was a second line [DOS] member restricted to and limited by the information the 1st line gave me and of the same circumstance as the second line Plaintiffs suing me. For them to merely allege that I had additional knowledge of a criminal enterprise at the time of the brandings in 2016 and 2017 does not raise this PTAC’s accusations to a level above speculation….
This TAC would not survive a motion to dismiss based on this.
Fails To State a Claim
Despite the undue time, multiple opportunities, embellishments and lies Plaintiffs still fail to state a claim that substantiates all of the elements of a RICO case…
The issue remains that the complaint doesn’t contain enough factual material to raise a right to relief above the speculative level…
Prejudicial and Irrelevant
They have had multiple attempts throughout an untimely period and they still fail to cure these deficiencies. Based on my assertions and the case law above, if granted (the PTAC) would not withstand a motion to dismiss…
Bad Faith
I think it’s very clear… the Plaintiffs are acting in bad faith. If they are willing to participate in the unethical behavior I have outlined above they are quite capable of bringing charges against me in bad faith to protect their previous lies.
Furthermore, it may be legal (though I believe unethical) for criminal prosecutors to intimidate, threaten, and lie to civilians and their families to try to induce a plea, it is wholly illegal for civil prosecutors to do this….
As much as I would love to have this dismissed from my life even on technicalities, it is more important to be sure I haven’t hurt someone inadvertently or done something negligent that hurt another. It is equally important to be sure that others aren’t doing that to me (or others).
Their failure to cure despite multiple attempts, adding of embellished and non-factual information to try to cure, and their outright dishonest, unethical behavior, leads me to believe their attempts are not only futile but made in bad faith.
In this case, despite undue delay, multiple opportunities to cure, frivolous and dishonest claims, the deficiencies in the PTAC remain wholly uncured. The PTAC is futile and smacks with
bad faith.
Frank Parlato 
Janine Morrison 
J.J. O'Hara 
Richard Luthmann 
Marie White 
Paul Serran
Please leave a comment: Your opinion is important to us!
I am utterly perplexed by Danielle Roberts. When asked by NBC Dateline in February, 2021, how would she feel if she lost her medical license, she visibly trembles, her lips start to quiver, and she makes it clear that training for years and becoming a doctor meant so, so much to her.
Yet, she clings so fervently to DOS, which cost her what she seemed to treasured most in life. Being a doctor was her passion, her career path, her livelihood. Yet she cares more about her vow to Keith (DOS) than any of that.
In her Desperate, Over-the-top, Sermons she posted to the DOSsier project’s social media accounts, she said it would be easier to say she was brainwashed, that she was a victim, and renounced Keith Raniere and DOS, but that it wouldn’t be true. She paints herself as an extremely brave, kick-ass woman who is choosing “what is true, not what is easy.”
Though she never states what that “truth” is. When asked why she remains so staunchly committed to DOS she says, “I made a lifelong commitment.” With a side-dish attitude of: I’m so kickass because I’m so noble for remaining loyal to what/whom I’ve committed to. No matter how harsh the obstacles, I will remain loyal and committed forever and ever because I’m so tough and bad-ass.
Yes, to Danielle Roberts, DOS is such a kick-ass female empowerment group, and has been the most wonderful, uplifting, and empowering to my life. That’s the number one theme when she speaks on social media: DOS is not a cult, it’s a wonderful women’s empowerment group. (Which she convinces no one of.)
The TRUTH is that Keith created DOS and the rules for his DOS slaves. (There was a video posted on the original Dossier Project youtube account, where Danielle Roberts admitted she knew “Keith’s signature was all over this”.) Despite knowing and admitting Keith’s involvement in a now deleted? video, in all other videos she sticks to the lie that DOS was created by women.
Below is a list of some of (not all) the rules Keith created and ordered his slaves to adhere (proven by mostly audio and video recordings of Keith himself creating the rules). The few times she tried to address them, this is how she’s responded:
1. To starvation diets so they would look like pubescent girls and turn Keith on.
(DR: calorie restriction taught us to have control over our bodies).
2. To getting branded with Keith’s initials as a vow to him, AND giving him OWNERSHIP of their bodies, like a rancher owns cattle.
(DR: The brand is merely a more kickass version of a tattoo, and says they are not Keith’s initials. Even though there are recordings of him stating that the brand IS his initials).
3. To the whole mind-boggling master/slave construct, which was designed and controlled by Keith, and that she vowed to be a SLAVE for life to her female master and Keith.
(DR’s response: To become totally free, you must understand slavery.) I *think* that’s the point she tries to make. Her so-called answers are more deflection than explanation. The most frequent explanation… “These actions were part of my private life.”)
4. Collateral. Keith ordered his slaves to procure “collateral” for three reasons. 1) Pornographic photos and videos of themselves and their slaves for Keith to use to get off on. 2) Blackmail material to obtain and retain control of the members. 3) To gain financial control over the members by getting deeds to properties and other assets transfered to Keith’s control via his first-line slaves.
(DR’s response: The aim of the collateral was to prove how dedicated we were. No collateral was ever released.) If no collateral was ever released, it’s only because DOS got exposed first, and releasing it at that point would be incriminating.
Aside from the fact that ALL of Danielle Roberts’ so-called explanations are pure bullshit, it’s her continued belief that NXIVM and DOS are so magical and amazing, that she’s SO empowered and a stronger, kickass woman now…
HOW can she possibly think this, after losing her medical license, her livelihood, her reputation…. ?? She’s also completely broke, no longer has a home or assets, no longer has a practice where she’s helping others with her medical knowledge.
Danielle, if you’re reading this, please explain why you believe being a member of DOS has improved your life. Please, let us know why it is more important to you to remain a member of DOS, than to regain your medical license and move on from Keith Raniere.
All I hear when you speak, is Keith’s words telling you how noble you are to still be adhering to your vow of obedience and loyalty to him and your sister wives. Does it really feel so kick-ass to have destroyed your career and lost all the assets you had accumulated?
If you had taken the thousands of dollars you gave to Keith and Nancy, and instead invested in your career, you’d have a thriving business by now. Truly, truly ask yourself what Keith and DOS have given you. WHY do THEY matter more to you than YOU do? Are you still trying to heal an “ethical breach” with Keith? For the love of God, Danielle, get on with rebuilding your life, and stop ruining it to gain favour with Keith Raniere.
Great commentary here.
Danielle is a true believer in what Keith was doing. She always will be. She is past the point of no return. She is the most hardened “Dead-Ender” aside from Eduardo and Asswiper Suneel.
If Danielle stayed the course with being a doctor and treating people, her practice would be flourishing right now. Instead she was lured into a shady pyramid scheme and fell hook, line and sinker. Exo/Eso was a scam.
I have some very simple questions for Danielle:
1. Have you read the transcripts of his text messages with Cami? If yes, then you know he was clearly an emotionally abusive man to a girl half his age. Also you know he was her “husband” when she was 15 years old. Do you still support Keith?
2. You admitted on camera that you knew Keith was behind DOS. This means you either lied or knew the First Line slaves were lying to recruits. Do you believe this is “ethical” behaviour?
3. The child porn pic of Cami when she was 15: You and the remaining Dead-Enders continue to say the pic was “manipulate”, however you never dispute that Keith took the picture or had sex with Cami when she was underage. Why is this? None of you are lawyers, yet you very much sound like it. You are deflecting.
Thanks Danielle. I look forward to your responses.
Frank, did Danielle have a sexual/romantic relationship with Keith? Is she just head over heels in love with him?
I believe she said they had a brief encounter along the lines of kissing. But made it clear she was open for something more. This may be difficult to accomplish Insofar as his Lordship is not accepting any intimate meetings with women at present.
It’s such a sad case. As I have said in other posts, I have a massive crush on Danielle. She totally reminds me of a girl I let get away a while back. She’s sexy as hell, smart and has an attitude. I cannot believe she threw all her chips in on Keith Raniere. What a losing bet.
# 1)
I imagine her priority was fighting for her license , finding, interviewing and paying an attorney, answering supeonas, being interviewed by DOJ, paying her bills,, finding a place to live, earning a living, studying for a life insurance licensure test rather than reading transcripts of Camis emails , You know TRYING to take care of HERSELF. in the midst of a Mutiny and Nancy still offering( charging ) for EM’s!
# 2)
She actually said, ” She surmised he was” as anyone in the community would have due to his involvement in everything! And most welcomed his input at least they acted like they did . ie: Vicente
#3 )
How can she dispute he took the picture one way or the other if she wasn’t Physically there?
She said “She surmised he was”? Referring to herself? That makes no fucking sense.
So, let’s get to the bottom line: if she “surmised he was” then why is she still supporting him? If he is a pedophile and she made that conclusion, why does she still have her head up his ass? She was doing flips outside the prison he was housed in to entertain his pedo, child-fetish having ass.
Perhaps based on others lies & embellishments & her belief of tampering with evidence she prefers to keep an open mind , after all Cami ( wether abused or not) was one of the front line who was actually lying or deceitful about the initials in the brand so it may be hard for her to believe her now.
Ok. Points taken. Your opinions on this matter are legit and valid. Different perspectives are always good.
Why does Lauren get out of the civil case ?
4:38 @ PILGRIM
Also , Exo Eso was looked into with a fine tooth comb and all the taxes were paid~
Frankly, It looked like a dynamic program
Why were the complaints against Nancy and Lauren Salzman dismissed?
Material witnesses
Material witnesses and fell out side Rico
[…] Danielle Roberts Opposition to NXIVM Plaintiffs Fix of Flawed Complaint: Their ‘Frivolous and … Comment Share This! […]
How long do they get to make the complaint not a shotgun. If the 3rd amended complaint is still a shotgun do they get to dis 4th amended complaint ?
This article is sorely disappointing, and would carry far more impact if it contained pics of the good former doctor doing yoga in her underwear. Just saying. Get those pics in, as she’s rapidly approaching her “sell by” date.
Snorlax-
💯🙌🏼
I get the idea that these bozos can’t get their complaint straight
Their last recourse is to try to show I had knowledge of and supported the alleged criminal behavior. I was a second line [DOS] member restricted to and limited by the information the 1st line gave me and of the same circumstance as the second line Plaintiffs suing me. For them to merely allege that I had additional knowledge of a criminal enterprise at the time of the brandings in 2016 and 2017 does not raise this PTAC’s accusations to a level above speculation
I want to be clear. I think Daniele made a mistake by not disclosing to the women of was Keith and Allison initials
I am in love with Danielle! Damn she has a sexy body. I do NOT think she has a “butterface” at all. She’s a girl next door type. I don’t care for Botox face/lips/forehead. I just want a woman who I can fold in half and bang six ways to Sunday. With the Bodhi Mastery in play with Doc Roberts, I could keep myself busy all weekend long.
Danielle, HMU ON FRANK REPORT!!
BTW, even though the branding was “consensual”, they Plaintiffs still need you and Porter Potty in the suit to validate certain things. There needs to be a constellation of players to make the case stick. I wish you well, however seeing the Bronfman’s go down would be a wonderful thing. I am sorry you are collateral damage in all this. I don’t really think it’s fair. Porter Potty is different though: what he did with the “Fright Experiments” has caused people psychological trauma.
“I do NOT think she has a “butterface” at all.”
No it’s more of a Picasso:
https://external-content.duckduckgo.com/iu/?u=https%3A%2F%2Ftse2.mm.bing.net%2Fth%3Fid%3DOIP.8V5bvVj0D5M8gRn1UywnJQHaI0%26pid%3DApi&f=1&ipt=1577572a7c44cfeeaa0a6080bf64ac92075d43f5aa17d8306d39621477ccb3e1&ipo=images
Ha ha. So funny. Danielle is a bombshell.