Sara Bronfman Makes Motion to Dismiss NXIVM Lawsuit
Sara Bronfman has filed a motion to dismiss the Third Amended Complaint in the NXIVM-related lawsuit – Edmondson Et Al v Raniere Et Al – in the U.S. District Court for the Eastern District of New York
James D. Wareham, Robin A. Henry, Anne S. Aufhauser, and Alexis R. Casamassima of Fried, Frank, Harris, Shriver & Jacobson LLP represent the former NXIVM financier and member of its executive board.
Bronfman is one of two targeted defendants – the other being her sister, Clare Bronfman. The two are the only defendants with sufficient money to justify the lawsuit, which involves 70 plaintiffs and a dozen attorneys.
Bronfman’s attorneys argued that the plaintiffs’ Third Amended Complaint (TAC) fails to provide the necessary factual allegations specifically relating to her to survive dismissal.
The TAC heavily relies on allegations from previous criminal proceedings against civil defendants Keith Raniere, Allison Mack, Kathy Russell, and Clare Bronfman – and against former civil defendants Nancy and Lauren Salzman – all of which had already been adjudicated, and non of which resulted in any indictment or prosecution of Sara Bronfman.
Sara further argues that Toni Natalie’s malicious prosecution/use of process claim (Count IV) and her gross negligence claim (Count VII) against her within the TAC are particularly vulnerable and should be dismissed.
Sara also alleges that the malicious prosecution/use of process claim in Count IV suffers from similar flaws as its previous versions in the original Complaint, and the First and Second Amended Complaints.
To withstand a motion to dismiss, Bronfman argues, Natalie, the sole plaintiff asserting the Count IV claim, must provide some factual allegations – even a flimsy shred – demonstrating how Bronfman was involved in actions that caused harm to her, and not merely speculative conclusory allegations or outright fabrications.
Bronfman claims the TAC fails to meet this requirement, leaving Natalie’s claims unsupported and subject to dismissal.
Similarly, Bronfman asserts that Natalie’s gross negligence claim in Count VII lacks any substantial or clarifying improvements compared to previous iterations
Natalie must either present factual allegations directly implicating Sara Bronfman – as opposed to the bald assertions she makes – or the claim must be dismissed as a matter of law.
Without any essential allegations, the Count VII claim lacks the necessary basis for further consideration.
Bronfman also claims the whole TAC should be dismissed with respect to her because it failed to establish sufficient factual allegations.
By law, the burden rests on the plaintiffs to provide factual support that qualifies for relief beyond a “speculative” level – which, according to Sara, is all the TAC offers.
Without legally sufficient allegations against Bronfman, as exemplified by the wholly unmeritorious and probably false claims of Natalie, the claims against Bronfman lack the foundation necessary to proceed.
The final decision of whether to dismiss some – or all – of the claims against Sara will be made by U.S. District Court Judge Eric Komitee.
Read the entire motion and memorandum of law.
Sara Bronfman reportedly lives in Portugal and may have secreted her estimated $500 million fortune outside the USA.
This question is regarding Clare, not Sara, but I’m hoping someone will provide an answer.
Clare and her lawyers claimed she was unaware of DOS, and it appears to be true that she was not a member. However, she was in Mexico with Keith and the DOS slaves, and they were all staying together at the same place (yes? no?). So how did Clare not know that a group orgy with Keith and the DOS slaves was planned? How could he have kept something like that from Clare if she was there? Reportedly, she was in Mexico but not at the house when Keith was arrested. Anyone know where she was?
Nicki, Allison and Lauren (among others) were there, but not Clare? So, what did Clare think was going on that his harem showed up in Mexico? Why does she think they were summoned to go be with him? Was Clare really unaware?
I certainly can see Keith wanting to keep his sexual activities with his other slaves (DOS member or not, Keith was Clare’s master–and Nancy’s) a secret from Clare. To me, it looks like he was dangling his penis to her like a carrot but was only interested in her money. I think he knew she’d be very upset if she found out about all of his sexual partners. I do believe she was aware of some of them.
I personally believe Clare is naturally a lesbian, but can’t accept it in herself, and perhaps Keith convinced her he turned her heterosexual. Or perhaps I should say Keithrosexual. Females in his orbit were not allowed to have sexual feelings for anyone but him. I really think this is why Clare feels he helped her so much. I think he destroyed her ability to feel natural sexuality and replaced it with keithrosexuality which she would perceive as a cure to her lesbianism.
But keithrosexuality aside, what I want to know is, did Clare really not know about DOS, and if she didn’t, how was he able to keep the group sex commitment ceremony a secret from her if she was there?
Is Sara still loyal to Keith? I feel like her commitment to NXIVM was waning in the latter years. Last I knew, Clare is still 100% unconditionally loyal to Vanturd. The Bronfman sisters have the combined IQ’s of pocket lint. They are so fucking stupid it’s painful.
“… How were the Rainbow Cultural Gardens able to carry on for so long? Was this part of a trafficking scheme, where the kids and “teachers” were all being brainwashed? There are still huge questions in my mind about this exercise, and there should be a proper investigation by the educational authorities in each country that hosted these schools …”
https://frankreport.com/2020/11/13/rainbow-cultural-garden-every-child-that-went-through-this-program-will-show-cognitive-damage-and-language-deficiency/
Rainbow CULTural Grooming was a massive waste of time and money for the customers. Why the actual fuck does a child need to know seven languages? I get knowing maybe two or three: English, Spanish and one other, maybe. I had a friend who learned Japanese, and leveraged it to create a career in finance in American and Japanese markets. To me, it was a very strategic and unique way become a standout in his field. But seven languages? At $120,000 per year, it seems an almost reckless waste of money. I mean, it could cost a million dollars. Also, how fucking creepy and weird is it to have a nanny with your family 16 hours per day? I mean, its just bizarre to have a stranger going on vacation with you. Brandon Porter Potty – I believe – had his kids enrolled. The fact Cami was at the birth of one of his kids is just flat out weird. She was only 15 years old when her sexual relationship started with Keith. Did Porter Potty know this? If he did, when did he know it? And Cami was a main teacher? I mean, she had zero teaching credentials. How can she have been a teacher? I think at this point it would be a waste to further investigate Rainbow CULTural Grooming, by law enforcement. But if a journalist could do a deep dive, I would love to know more. I think Sahajo was an instructor in Rainbow CULTural Grooming as well. Cami and Sahajo should do a comprehensive expose on it. Was it just another grooming operation for Keith?
Cami wasn’t a teacher just a bi lingual nanny. Also, witnessing birth at 15 seems incredibly lucky thing to do.
I learned multiple languages as a child and I can tell you that once you know any of the latin based languages (French, Spanish or Italian) you can easily learn the others.
I spoke French at home, and English or French or German with neighborhood kids. It was an unspoken rule, if I was at their home, I spoke their mother t9ngue, and if they were at my house, they spoke French. It was all very natural.
I formally learned Latin starting in grade 1. Once we knew Latin, around grade 2, we built on that, learning how to read and write the Latin based languages, French, Italian and Spanish. We started to learn how to read and write in English earlier, around 5 yrs old. When I was 10, German was introduced, and it was a sister to English in that a lot of the concepts and word roots were the same. So for me, French, Italian and Spanish were one family of languages, and German and English were another.
As a child, I never got confused, but it’s because we were taught to concentrate on one language at a time. For a year starting grade one it was morning in French, afternoon in English, and as we grew older, after the core concepts had become, “natural”, that we didn’t even have to think about them, we then learned the other languages two hours a day, but only one extra language for a full year, then a sister language the following year, with exposure and maintenance curriculum for the other languages.
But it took very experienced and accredited professionals with a very well planned curriculum lasting thirteen years to produce multilingual young adults. To be honest, I don’t think I could learn a foreign language as an adult fluently. I could learn a few sentences to get by, but to learn the grammar, to read and write Japanese or Russian, something totally foreign to me, I just couldn’t do it. As a matter of fact, my mother tongue is French, but I wouldn’t want to learn why some words are feminine and others are masculine as an adult. That simply soaked itself into my brain by osmosis as I grew up in the French culture. When the teacher was explaining the rules, I was drawing pictures. Not the slightest bit interested as to “why” it was la instead of le.
When I read about Keith’s sham of a language school for children I just shook my head. I bet it had a zero percent success rate. Keith was too stupid to know how learning languages work, and he also didn’t know that different dialects affect the learning. He had no clue which dialects his “nannies” spoke, and there was no actual teaching involved. If all it took to learn a language was to hear it being spoken, all parents would have to do is plunk them in front of the TV and have them watch a foreign language channel.
Let’s take the Vanturd blinders off here. That Rainbow Cultural sham had only two purposes: 1) bring in cash and 2) recruit young girls (not actual teachers) for Keith to groom and boink. Why the hell was that not shut down by the dept of Education??
Depth of Ed: What qualifications do your teachers have?
Keith: I personally pick each and every one of them. Teenagers who have left school, under a hundred pounds so they look 12 yrs old, and have a timid personality so they won’t fight me off or report me when I rape them.
Depth of Ed: And the parents pay you $120,000 to do that?
Keith with a huge grin: They sure do! Cuz I’m the Vanturd.
How long did that horror show go on for? Was it ever shut down, or did it only stop after Vanturd was arrested?
You underestimate how STUPID Clare is. It is possible she did not know about DOS, although she should have, so she is liable.
I do not believe she was in Mexico with the other slaves when the Federales picked up Keith.
Keith only kept Clare around for her money. Keith surrounded himself with subservient and very low IQ women. Many did not graduate high school. The ones who did, could not start or finish college. India Oxenberg is another example: dumb as a box of rocks, but has a trust fund. Clare and Sara’s roles in NXIVM were to cover Keith’s gambling losses and fund his doomed-from-the-beginning projects. Keith was brilliant at losing money. He had a unique ability to take a project with a guaranteed positive ROI and drive it into the ground and turn it into a toxic investment.
Keith was a compulsive gambler, who frequently lost other peoples money. Firstly, you have to be a special type of moron to trust Keith Raniere with money.
The only reason Clare is “loyal” to Keith is because she feels foolish for blowing all those millions on him. She is dumb, but she realizes she got in too deep and past the point of no return. Its easier for her to just ride it out, at this point. Sara is equally stupid, but has a husband with a slightly larger than pea size brain, whom educated her on her past.
Bullshite
With her money if she could rationalize his behavior was abhorrent and all he hurt, she has more than enough to put a stop to it all, apologize, and make amends to the ones who truly were hurt by this. Life is short.
About Sahajo and the other NXIVM victims, Frank Parlato Jr. wrote, “It is astonishing. These are good people. They cannot ever seem to understand that the sweet voice is a fraud. That he wishes them harm. But time will bring counsel.”
It seems Frank tends to give as many as possible the benefit of the doubt. He’s said and written at least a thousand times, some variation of, “These people are good people.” when referencing the victims of the NXIVM cult.
We need more people like Frank Parlato Jr. in journalism, law and politics to balance the harm done by those with no good will or common sense working in journalism, law and politics today.
ROBERT DEnIRO’S GRANDSON WAS MURDERED BY A FEMALE DRUG DEALER KNOWN AS THE PERDOCOCET PRINCESS.
You know, tiny Toni, instead of talking shit about things you don’t understand regarding Parlato, you should focus on yourself. Now, we all get to pick your falsehoods apart again. Your bogus lame ass book, your Botox, and now this. If you win money from the Broffmans, it will be your own demise.
I have wondered from the outset why Toni Full-of-Baloney Natalie is a plaintiff in this lawsuit. Given that she left Raniere several years before the Bronfmans got involved, it’s pretty clear this is just her latest attempt to get money for no good reason. Once a grifter, always a grifter….
The Bronfmans are an early version of the saying “Go Woke, Go Broke!”
Raniere v. Garland (4:22-cv-00561)
District Court, D. Arizona
Jul 13, 2023: Remark re Pro Hac Vice Motion
Jul 13, 2023: Pro hac vice motion(s) granted for Arthur L Aidala on behalf of Plaintiff Keith Raniere. This is a text entry only. There is no PDF document associated with this entry. (BAS)
With any luck NXIVM lawsuits will las for ten or twelve years.
They are a gift that keeps on giving.
To the Plaintiffs: any Bronfman money you get, immediately donate it to charity. If you keep even a penny of this money for yourself, your life will be altered in a negative way.
The Bronfman fortune is a source for evil. It has funded addiction, sickness, disease, death, torture, sex trafficking, child sex trafficking, sex cults, etc.
If you think keeping Bronfman money will help you “heal”, you are very wrong. It will destroy your life. By all means, sue them for all they’re worth, but donate that money to a good cause anonymously.
This is the only way to cleanse this money without cursing your soil and damning yourself to a life of misery.
Ask Frank. He has gone through a decade of Hell for dealing with the Bronfmans.
They are the fruit of the poisonous tree. Curiously, their elder brother squandered most of the Bronfman fortune through some of the most incredible acts of stupid business the world ever witnesses – in the Vivendi deal.
Edgar Jr. is almost as stupid as Horseface and Sara. Although, those two are difficult to top. They truly are the dimmest, most airheaded, assholes of the entire Bronfman brood. Edgar Sr. disowned Jr. because he married a black woman. I forgot about the Bronfman history of racism as well. They are truly evil people.
Is that really Toni Baloney, or is it a trans person?
What are Toni’s allegations? Can we see them?
Yes. I will make a post with the answers.
The gangsta rap crushing families in American cities probably funded the Bronfman sisters’ crimes and lawfare. Maybe it was the international warmongering. Whatever it was, it wasn’t the legacy their good ancestors hoped for.
War, war everywhere and no justice to be seen.
“…Natalie, the sole plaintiff asserting these claims, must provide some factual allegations – even a flimsy shred – demonstrating how Bronfman was involved in actions that caused harm to her through court processes, and not merely speculative conclusory allegations or outright fabrications.”
This continues to be one of the primary problem of this lawsuit (besides Edmondson defense). Basically the accusation comes down to “she gave money to him that enabled Raniere to do his crimes that victimized me. No money, no crimes. For this to work, it means that loans, payouts and gifts from any source is responsible for the crimes committed with that money. In effect any bank, employee, or parent paying for children’s stuff is responsible for the crimes that are committed. I do not see that implication flying with any judge.
Yes the standard for civil cases is lower but there has to still be connective tissue between the events suing for and the person accusing of participating in it. And email indicating knowledge, recording, something beyond “she had to have known and didn’t care” and I have yet to read or here anything that passes muster unless the lawyer found his silver bullet and keeping it close to his chest.
https://storage.courtlistener.com/recap/gov.uscourts.nywd.105325/gov.uscourts.nywd.105325.361.0.pdf
Sara is in for a rude awakening. She’s gonna be in this for the long haul. She deserves all the karma she gets.