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Raniere files new bail motion – seeks to live in Clifton Park, $1M bail bond, no guards

Keith Raniere’s latest motion was filed on November 14. It is an attempt to get out of MDC on bail before he goes to trial. The motion is made before Judge Nicholas G. Garaufis who denied his earlier motion to be released on June 20, 2018.  The letter motion is signed by Raniere’s lead attorney, Marc Agnifilo.
[My comments are in brackets and in bold]
The Teachings of Keith Raniere and Nxivm  
The work Keith Raniere and others, many of whom are his co-defendants, have done is a source of great pride. Executive Success Programs (“ESP”) was founded in 1998 by Mr. Raniere and Nancy Salzman, the predecessor to Nxivm which was founded in 2003. The company is a for profit business entity that sells professional success training programs. The programs Nxivm offers include, among others, ethics, logical analysis and problem-solving skills based on a patent pending system called Rational Inquiry.
Nancy Salzman, co-founder and co-defendant
[In the USA, Rational Inquiry is NOT patent pending. On September 25, 2013, the US Patent Office refused this patent.] 
Rational Inquiry is a complex, essential concept to the Nxivm teachings. However, in the simplest terms, it is the Socratic Method of pointed questioning. As any law student knows, a law professor may call upon him or her during a lesson and ask well-placed questions to determine what the student believes about a certain topic and where, if anywhere, that belief comes from.  What the law professor does in a law school classroom, Nxivm does elsewhere regarding how we view ourselves, form relationships and make decisions for ourselves and others.
[Nice touch comparing NXIVM methods to that of a law professor.]
Just as Socrates challenged the young people of Athens to question sacrosanct beliefs of the time, and indeed was executed for his disruption of a closed-minded system of government, Nxivm challenges participants to question, rather than blindly accept, the fundamental content of their lives.
[Socrates had the opportunity to escape the jurisdiction of the Athenian government but chose not to flee – and, instead, committed suicide by drinking hemlock. I wonder if Raniere – if released  – will choose, like Socrates, not to flee?]
Did Marc Agnifilo really write this? .
Why, for example, are we practicing the religion we are? Do we really believe its precepts or is it just easier to not disappoint our parents? Do we have the relationships with our parents or our children that we really want? If not, why not? What can we do to have better relationships with the people we love? Nxivm challenges people to ask these questions and challenge one’s own limiting beliefs that prevent attaining one’s goals. The fundamental premise is that people are not made happy or fulfilled by material items.
[In NXIVM this is true, since most of the members are broke and the ones who inherited money or had a good career, are usually stripped of all their wealth after Raniere encouraged them to keep taking expensive NXIVM courses. See In Search of Keith Built Millionaires]

We are not happier because of a car or a house.

[So give them to Keith]


Rather, we are happier when we have thought through the true content of our lives and have made a plan to improve ourselves and our relationships by thinking deeply about them, rather than taking them for granted. Nxivm provides its students with effective tools to achieve success and greater happiness.

[Who would have known Marc Agnifilo could spout word salad that is almost as profound as that spouted by Raniere?]


Two hundred years ago these may have been some of the questions taken up by traditional religion or by students of philosophy. However, as mankind has generally become untethered from religion in favor of a version of spiritual and intellectual freedom, many people find value and content in developing a system of thought and belief through which to address these eternal questions.

[it is hard to believe this was written by a practicing attorney and included in a court filing for a judge to read. Did Keith writes this memo?]


An overriding theme of Nxivm is that we strive to be part of something larger than we are. That something is humanity. We participate in the progress or lack of progress of humanity in each of our choices.

[“We strive to be part of something larger than we are. That something is humanity.” That writer is Raniere.]


Another important premise of Nxivm is that each of us harbor (sic) emotional associations with different events or triggers. Some of these experiences are positive; others are decidedly negative. If we can free ourselves of the negative ones—the ones that restrain our decision-making—we can be more free and happier. To illustrate the true nature of Nxivm and Keith Raniere, we have attached as Exhibit 3 a brief video that shows how Rational Inquiry transforms students’ lives, and in some instances, even successfully helps people transform the debilitating symptoms of Tourette’s Syndrome.

[This is the video we previously reviewed and is found on You Tube.  Some people who appear in the video as Raniere supporters – those “free and happier” people – have left Raniere and call him a dishonest and sinister man who tried to steal their freedom from them.]


…. Nxivm is interesting to certain people because it challenges their existing belief systems, and even what it means to believe something.

[NXIVM is meant to make sure they believe in Vanguard.]



The valuable intellectual property of Rational Inquiry includes the technology, methods, procedures, discoveries, understandings, course-work, coaching materials and other aspects of a highly developed body of knowledge memorialized, in part, in written materials that Nxivm has developed over many years and which it is continuing to

{I would ask the judge if he would be comfortable taking a series of 14 hours per day Intensives and learn their methods, procedures, discoveries, understandings?]


Intelligent, successful executives, politicians, actors and actresses agree to pay Nxivm for its training services, and decide to continue such training, precisely because of the company’s well developed methods and the confidential and proprietary information it has developed.

[How many of these are willing to pay for courses now? Of all the successful actors and actresses – all of repudiated NXIVM except one who is indicted.]


In addition to providing the intellectual content for these teachings, Mr. Raniere has lived nearly six decades without any criminal record.

[Some say he has been committing crimes for more than three decades. How did he escape having a criminal record? That should be investigated, if it is not already being investigated.]


While the government raises the specter of danger,…There are…no allegations of guns, knives or weapons…

{There are other dangers a man of his character can visit on men, women, and girls.]


…Mr. Raniere is a peaceful man, whose work includes founding a company Anima, Inc., which produced and directed the Opening and Closing Ceremonies of the Central American and Caribbean Games in Veracruz, Mexico,  in 2014.5

[Why did Anima just change its name to Espectaculous Massivos Internaitonal? Is the company trying to distance itself from Keith?]


The ceremonies recited a peace pledge that Mr. Raniere helped create and inspire, and were witnessed by nearly 23,000 live spectates and more than 150 million viewers. This same peace pledge is recited by people every Sunday in Mexico as a stand in solidarity against the violence which pervades their country.

[Why did the mother of his elder child accuse him of trying to lure women to Mexico where he could have them falsely imprisoned, raped and possibly killed?]


2. The Proposed Release Conditions

(1) A $1M personal recognizance bond;

[He previously proposed $10 million. This is less than Nancy and Lauren’s bail bond. Can anyone reasonably assume that Keith is less of a flight risk than Nancy or Lauren?]


(2) The bond shall be secured by the following three properties, with the owners of the properties signing onto the bond:

[The addresses of the three property addresses are redacted.]


(3) Several other people—the identities of whom will be provided to the government and the Court in advance of any hearing, will also sign onto the bond;

[These are likely NXIVM intelligent, successful executives, politicians, actors, and actresses – too poor to have property to pledge.] 


(4) The defendant shall be on full home confinement in Clifton Park, NY;

[Where exactly in Clifton Park will he be living — and who will be living with him? Also note that, unlike his first proposed bond package, no armed guards are proposed to guaranty he won’t escape.] 


(5) The defendant will be electronically-monitored by a GPS device that tracks his every movement;

[It will not stop his movements – it will track them. Even if he gets on a plane – and up until take off.]


(6) The defendant shall not leave the location of his home confinement, except for emergent medical matters and scheduled court appearances; his lawyers will be
obligated to travel to this location for any meetings;

[I wonder which mansion he will live in, in Clifton Park? Rosa Laura’s, Sara’s, Clare’s?]


(7) When the trial starts, or if the defendant’s presence at court is required on a more regular basis, he will live at a location near the courthouse, and will be accompanied by one of his attorneys from that location to the courthouse;

(8) The defendant shall not communicate with anyone by phone or in person aside from his attorneys or authorized members of their staff or unless his attorneys are present;

(9) The defendant shall have access to a computer to review the discovery provided in this case, but no internet access; and

(10) Surrendering of the defendant’s passport and an agreement not to secure new travel documents.

….  the current proposal does not involve armed security guards. As was apparent from the Court’s comments and questions during the proceedings on June 12, 2018, the Court was uncomfortable with private armed guards ensuring Mr. Raniere’s appearance.

[It doesn’t make much difference. If Raniere paid for the guards or not. If he wants to escape, he will.]


…. the Court was concerned that the prior proposal did not involve co-signers with moral suasion over Mr. Raniere….   the renewed bail motion proposes a bond with several co-signers who have known Mr. Raniere many years, are confident that he will return to court as expected and have put their own hard-earned funds on the line.  Even if he were able to flee, which he is not,

Mr. Raniere would not do so because, among other reasons, he would not jeopardize the financial situations of the co-signers. Mr. Raniere has known his suretors
for many years and cares for them, and their livelihoods.

[Suppose he did flee. Would the two or three suretors be reimbursed by Sara Bronfman?  If he fled, he has supporters who could easily reimburse the million dollars his two or three supporters put up for his bail. Is this a clue that he intends to flee?  Why not put up a larger sum?]


In addition, these co-signers are willing to come to court and be questioned by Your Honor …. there is significant apprehension shared by people who otherwise would be willing to co-sign a bond for Mr. Raniere. …. The government has repeatedly sent federal agents to the homes of people who may be defense witnesses or are viewed by the government as assisting the defense. Moreover, anyone showing allegiance to Mr. Raniere is defamed in blog sites to the potential detriment of their livelihoods.

[They are talking about the Frank Report. Here is footnote 6: Frank Parlato, Court does not need to seal names of Raniere co-guarantors – Frank Report knows already], 


These co-signers’ willingness to sacrifice their resources and face public scrutiny, if not obloquy and defamation, further enhances the value of their commitment.

[Or their willingness to do anything for Raniere – anything at all.]


…. the sum of money securing Mr. Raniere’s bond is significantly less than for other defendants in this case….  Raniere does not have any financial resources of his own….

[He has control or “moral suasion” over a number of followers with plenty of assets.]


… Raniere …. does not pose a danger to the community and is not a risk of flight….

[Pretrial Supervision and the prosecution dettermined that he was both.]


B. The Weight of the Evidence

…. [T]he Court, as well as the defense, is being kept in the dark as to critical exculpatory evidence currently in the government’s possession directly related to the sex
trafficking charges….   the government has been informed ….  by multiple women during interviews that these women were in DOS and were not required to have sex with Mr. Raniere.  …. the overwhelming majority of women in DOS did not, were not asked to, and certainly were not required to, have sex with Mr. Raniere. And at trial, the defense will show that any sexual relationships with Mr. Raniere were entirely consensual and aggressively pursued by Mr. Raniere’s partners.

[In other words, women aggressively pursued Raniere for sex. And he consented.] 


…. With Mr. Raniere’s pretrial liberty currently on the line, the government should be compelled to inform the Court of how many women in DOS have told the U.S. Attorney’s Office and/or the FBI that DOS had nothing to do with sex with Mr. Raniere and similar facts…..]

[One might as well ask a rape defendant ‘how many women did he not rape?” Suppose he did not rape 1,000 women and only raped three? Does that make him innocent or harmless? One should ask the opposite: How many women said they were coerced to have sex with Raniere?  A number of Jane Does are evidently ready to testify.  I get the defense argument. “Hi, I’m Keith Raniere and I did not sex traffic an overwhelming majority of the women I branded with my initials.”] 


…. Mr. Raniere Did Not Flee the Government in Mexico

… Raniere did not flee the United States for Mexico….   There is no basis to believe he will do anything but fight this case, in keeping with his character. He has only been out of the country a handful of times in the past few years—twice to visit Fiji, and most recently, to be with the mother of his child and his infant child in Mexico after her visa expired in October 2017 ….”  The government’s repeated and knowingly misstatements as to Mr. Raniere’s dates of travel …. are highly misleading. ….

Mr. Raniere did not leave the country because of The New York Times article, but rather came back into the country the day the story was published….

[Raniere’s attorney tells the story of how Mariana’s visa expired and they tried to go to Canada. Then they flew to San Diego and drove a car out of the country to Mexico. He came back to the USA on the day the NY Times Story was published. At that time, there was no known investigation. Raniere soon found out about the investigation in November – and within days of the FBI interviewing witnesses, Raniere flew out of the country and did not come back again except in handcuffs. It was the second trip to Mexico in November, not the first trip in October – that evidences his desire to flee.]


….in November. …. Mr. Raniere traveled back to Mexico to be with his three-month-old son who was with the mother as she was awaiting a new visa. Mr. Raniere traveled back to Monterrey, Mexico, to be with them. And, in an abundance of caution, hired a well- respected attorney, Michael Sullivan, the former United States Attorney for the District of Massachusetts to interface with any governmental entities that may be investigating any charges stemming from false allegations of coercion….  Mr. Sullivan openly communicated with the U.S. Attorney’s Office in the Northern District of New York, thereby demonstrating Mr. Raniere had no intention of fleeing or hiding

…. At the June 12th hearing, this Court asked “what about the situation with him going down to…Puerto Vallarta, Mexico and staying in a gated community and operating an [encrypted] email account…. Why would you do that if you were not trying to evade law enforcement?” ….

[The defense wants the Court to believe that he went to Mexico in November, right after the investigation started – to be with his baby mamma and son. He was apprehended in March 500 miles from Mariana and baby. He used an encrypted phone. He did not respond to FBI messages left for him in Monterrey. Why did he have his attorney Michael Sullivan contact the Northern District, not the Eastern District, about a possible investigation – when the NY Times and other publications, including the Frank Report, stated the EDNY was investigating?]  


First, as we have written in previous memoranda, for nearly two decades, people associated with ESP and Nxivm have been the targets of threats, computer-hacking and blatant false statements on websites and other media specifically to damage their reputations, business and lives….. One hacking defendant John Tighe even pleaded guilty to the felony of Computer Trespass….

Most recently, in the summer of 2017, before Mr. Raniere and the mother of his child went to Mexico …  Nxivm became aware that the login credentials of former students, Sarah Edmondson, Jennifer Kobelt and J.O. were accessing Nxivm servers from Canada. These accounts deleted data, stole ESP student profiles and documentation and cancelled over $100,000 credit card payments….. Conspicuously, days later, personal and identifying information about Nxivm clients was published on the internet. (Id. at 10.)

Second, as we stated in earlier memoranda, anti-NXIVM press was and continues to be associated with a prolific blogger named Frank Parlato, who is currently under indictment in the Western District of New York…..  Parlato is an active antagonist who has admitted time and again that he is obsessed with ruining Mr. Raniere and others supportive of the organization. Apparently, this obsession does not stop with posting photos of Mr. Raniere’s newborn baby. On multiple occasions, Parlato published the exact location of Mr. Raniere’s whereabouts in Monterrey, Mexico, and even published multiple photos of him walking his child in the daytime….

It is no wonder, then, that with the presence of this blogger posting Mr. Raniere’s daily whereabouts together with photographs of his four-month-old child, that Raniere would choose to leave Monterrey to protect his child.

[He ran away from Monterrey because I posted a photograph of him walking with his child? But he left his child behind?]


Moreover, with a recent Nxivm server breach and misappropriation of electronic information, Mr. Raniere chose to use an encrypted email shortly after Sarah Edmondson’s story was published in The New York Times.

{So Sarah made him use encrypted email?]


Rather than trying to evade law enforcement, Mr. Raniere chose a more secure location to reside, and an email server that could prevent hacking from a mobilized group of enemies who were ready and willing to hack in the past and willing to publicize their illegally seized information

{He went to Mexico to hide out from Sarah Edmondson and me?] 


Third, Mr. Raniere was arrested in a gated resort near Puerto Vallarta where he was on a vacation openly socializing with friends from Albany and different parts of Mexico. The friends were all together for the weeks leading up to “Holy Week” in Mexico. Many of the Mexican families left the resort near Puerto Vallarta on March 25th to begin the Holy Week celebrations with their families and some guests stayed, including Mr. Raniere and guests from Albany. Therefore, Mr. Raniere’s presence in the Puerto Vallarta area was simply to go on a vacation with his friends, many of whom he had not seen since leaving Albany in November 2017.

Lastly, the Court also observed that at the time Mr. Raniere was arrested, the mother of his child was residing in Monterrey and not at the resort in Puerto Vallarta….  Indeed, the mother of his child and his child were in Puerta Vallarta beginning on March 16th and stayed with Mr. Raniere until March 25th, the day before Mr. Raniere’s arrest. (See Ex. 4: Flight Itinerary.)  That day, they left just a few hours earlier with friends so that their child could continue his language development at a school in Monterrey.

[Rainbow Cultural Garden]


Because companions and others from Albany were still vacationing in the Puerto Vallarta resort, Mr. Raniere stayed behind and planned to join the mother of his child and his child later.

[Mariana had been there for 9 days. Raniere had been there for months. She came and left. He was there before and after. That he was in hiding is undisputed. Was he hiding from Sarah Edmondson and me – or the Feds?]


…. Mr. Raniere’s Lack of Personal Wealth

The Court …. expressed concern with the fact that Mr. Raniere’s lack of personal wealth means that he has little to lose if he flees….  While it is true that virtually
everyone is concerned with losing money, there are other things that one can fear losing. Mr. Raniere’s life has not been about money or wealth.

[No he gives his teachings free as air.]


He has had the support of people with substantial means, no doubt. His long-time partner, Pamela Cafritz, with whom he had shared his life for nearly thirty years before she passed away on November 7, 2016, had means.

[The defense makes it sound like they were partners in the traditional sense. Pam Cafritz was one of many women. She allegedly procured many women and even girls for him. She was one of his harem.]


At the risk of sounding too trite, Mr. Raniere had two things primarily that he risks losing: love and respect.

[That doesn’t sound trite. It sounds stupid.]


If he were to leave, his life’s work and his reputation would be lost.

[Right now his reputation is pretty good I would say.]


The government has lamented in several filings that people paid a lot of money and spent a lot of time to go to Mr. Raniere’s birthday celebration …

{Was the government lamenting? I think they were pointing out it is part of his insane obsession with being loved and respected that he had a 10-day birthday celebration that he called Vanguard Week.] 


These people were not forced to celebrate Mr. Raniere’s birthday, nor did they go because they were brainwashed, nor because they would lose their “cult” status if they failed to go.

[There are plenty of NXIVM members who will testify that if they did not go, they were criticized, chastised, sometimes shunned for not giving Vanguard tribute. They had better have a good excuse for not attending V-Week.]


They went for the same reason that one might go to another person’s birthday party:

[A 10-day birthday party.]


because they love him. This love is precisely why people are willing to sign on as suretors, despite the negative effect it will have on their lives.

[But only two or three are willing to sign as suretors- for only one million. If all those hundreds of people went to his birthday celebration because they love him, why aren’t there 100 people ready to sign as suretors? That would be moral suasion.]


The respect, love and admiration of the people whose lives he has touched is ultimately all Mr. Raniere has.  Fleeing a court obligation would be cowardly, unethical, wrongful, illegal, and morally-weak.

[I say a man who leads a group that brands women is cowardly, unethical, wrongful, illegal, and morally-weak.]


If Mr. Raniere were to do that, he would lose everything he ever had.

[He already lost everything. He is known to the world as cowardly, unethical, wrongful, illegal, and morally-weak.]


…. Mr. Raniere has no arrest history and has lived and worked in New York state for his entire life…. there is no suggestion that someone stole another person’s money

[I would look into the commodities losses of $65 million of Bronfman money.]


…. This is an organization that has advocated peace and humanity to the exclusion of all else.

…. The second form of danger that must be addressed is this notion that Nxivm harassed people who left the group through litigation…..  a group of people, including
members of the press, repeatedly hacked into Nxivm’s confidential computer system. Nxivm sued these people because they committed both a criminal and civil wrong against them.

[Except for one person, John Tighe, all criminal computer trespass cases were dismissed and the civil case against journalists and others was dismissed.]


On another occasion, a group of nine women sent an extortionate letter on the eve of a well-publicized event stating that if a large sum of money was not paid, these former Nxivm members would make false and disparaging statements to the press. Legal measures were taken to address this situation.

[The NXIVM 9 sent a letter asking for money owed to them. Raniere allegedly lost more than $1.6 million of Barbara Bouchey’s money in commodities trades. She asked for it back. NXIVM contacted law enforcement. No charges were filed.]


These are but two examples of instances where former clients or contractors of Nxivm took unlawful actions and were then faced with legal process to address these actions. To characterize these reasonable legal measures as harassment of potential witnesses is brutally unfair and untrue.

[Raniere/Bronfman engaged in more than 50 legal actions. See Albany Times Union NXIVM is a Litigation Machine.]


….  [T]he government has made factual assertions to the Court that Mr. Raniere has an alleged “decades’ long history of abusing women and girls,” which he flatly denies.

[Women have gone on record alleging he raped them.]


…. the government has stated, and even now indicted, an instance where Mr. Raniere purportedly “ordered the long-term confinement of a Nxivm member who was approximately in her early-20s to heal an ‘ethical breach’ because she had developed romantic feelings for someone other than him.”….

…  The thousands of emails and handwritten notes from this adult woman show that this woman willingly stayed in her unlocked bedroom for a year and a half to work on many issues, such as the fact that she would constantly steal from people in the community. In addition, she lived in the house with her family, who bought her fresh food and
prepared her meals for her. Incredibly, and what the government conveniently leaves out, is that her mother stayed in the room next door to the woman for nearly a year, also entirely of her own volition.

{Both mother and daughter were imprisoned. The Mexican woman was here illegally and vulnerable to Raniere’s demands. I have interviewed this women at length in the past – before the FBI investigation commenced. She says her “issue” was that she did not want to be part of Raniere’s harem. Regardless, if Raniere was a loving person, could he not find another way to heal issues other than confining a woman in a room for 18 months?]


The government proffers that “[w]hen the woman finally did leave the room, the defendant, as he had threatened, had her driven to the Mexican border and ordered to walk across, without money or identification papers.” ….  Notably, once this woman wanted to leave her bedroom, she was driven to Mexico by her father and another person.

[She says she escaped during Raniere’s birthday celebration when everyone including Raniere was out of town.] 


…. At the June 12, 2018 Court proceeding, the Court expressed concern … that …. Clare Bronfman, may facilitate Mr. Raniere’s departure from the jurisdiction. …  At the time, Ms. Bronfman had not yet been indicted ….  because Ms. Bronfman was not yet a defendant, the Court had no power to influence her actions. …

In July 2018, Ms. Bronfman and three others were arrested. …  she is subject to stringent conditions and pretrial supervision. ….  this Court has received assurances from her trust advisors that they have “the ability to and propose to enter into a binding agreement in a form acceptable to the Court to limit distribution to Clare to pay for certain expenditures that are encompassed within the overall purview of Clare’s health, education, maintenance, and support…” ….  these expenditures do not include supporting Mr. Raniere. ….  the Court need not have … concerns … about the possibility that Clare Bronfman could arrange for Mr. Raniere’s departure from the District.

[I have a two-word rebuttal to this argument: Sara Bronfman.] 


Finally, since the Superseding Indictment, the government “has produced over 96,000 pages of discovery” and has made available “forensic copies of nearly all the devices seized from the residence of defendant Nancy Salzman.” … The volume of discovery that the government has turned over is enormous. In fact, the government repeatedly characterizes as 144 “library floors” of data….  ….  Among other reasons, Mr. Raniere requests to be released from prison so that he and his lawyers can prepare for trial and so Mr. Raniere can assist in reviewing the vast amounts of discovery that have recently been produced to counsel…..

The Current Bail Package Addresses Any Issues with Flight, Danger and Witness Matters

Under the proposed conditions, Mr. Raniere will be without his passport,

[He won’t need one to take a private plane to certain countries amenable to granting sanctuary to people with money.]


will be on fulltime GPS monitoring and under the strict supervision of Pretrial Services.

[They can’t guard him 24/7]


In addition, he has absolutely no means to flee, as he lacks any of his own money.

[Sara Bronfman]


Also, as noted, to the extent that the Court was once concerned that Ms. Bronfman may help Mr. Raniere flee, that concern has been eliminated with her arrest and current pretrial conditions.

[Sara Bronfman]



Sara Bronfman

…. Since Mr. Raniere will be permitted to speak only to his counsel and others in the presence of his counsel, the potential danger to witnesses is fully eliminated.

[If he obeys the conditions. As an ethicist only he can decide what is ethical in this matter.]


6. Conclusion
For these reasons, we ask that the Court approve the bail package set forth above.

[The letter  is signed by Marc Agnifilo.]


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Frank Parlato

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