“The Allison Mack of today does not recognize the Allison Mack of three years ago,” states the sentencing memorandum filed by Mack’s attorneys on June 25.
“Now that the blinders of the Nxivm cult have been removed, Ms. Mack recognizes that her actions were abhorrent.” Since her arrest in April 2018, Mack’s life has turned around completely “from depravity and trauma to peace, acceptance, and remorse,” asserts the memo.
Who was the Allison Mack of yesterday, and who is she today? Mack’s attorneys attempted to shed some light on the life and character of Allison Mack, asking the judge to allow her “to continue down this path of growth and reform by imposing a sentence without incarceration.” Mack’s sentencing date is June 30, 2021.
The text below contains excerpts from the sentencing memorandum filed on Mack’s behalf. It tells of the path the actress took to a life as a devoted member of Keith Raniere’s so-called sex cult, which ultimately led to her arrest. Her lawyers also describe her attempts at rehabilitation and desire to make amends.
Early Life: Mack Became a Child Performer at Four
Young Allison Mack in the 1989 movie ‘Police Academy 6: City Under Siege.’ “It is no secret that the life of a child performer can involve experiences, and create stresses, that impact development,” says the memo.
Allison Christine Mack was born on July 29, 1982, in Preetz, Germany, to her parents Jonathan and Melinda. [The family relocated to Long Beach, California, when Mack was two.] Ms. Mack’s father, now 72, was a professional opera singer. Her mother, age 69, was a schoolteacher and a bookkeeper for a talent agency. Ms. Mack has a brother who is one year her senior, and a sister who was born when Ms. Mack was eight years old.
Allison Mack’s childhood began uneventfully,[…] but at the age of four, this trajectory changed when Ms. Mack’s mother began to involve Ms. Mack in the child acting and modeling industry. It is no secret that the life of a child performer can involve experiences, and create stresses, that impact development.
The memorandum cites a Psychology Today article, The Child Performer, observing that, “young actors must constantly cope with rejection, jealousy, self-scrutiny, obsessive thoughts, and the nonstop need to be perfect.”
She Stopped Traditional Schooling at 15
Allison Mack, 3rd from right, in an autographed photo of the Hiller and Diller cast, circa 1997.
At the age of 15, Ms. Mack booked her first television show as an actor [she was a regular on a comedy called “Hiller and Diller.”] At that time, Ms. Mack ended her progression through the ordinary avenues of education, instead taking “independent study” classes designed for children in show business. In 2001, around the same time she earned a high school diploma through the independent study program, Ms. Mack was cast in the television show, Smallville, based on the Superman character from DC Comics.
On Her Own at 18, Mack Grew Apart From Family, Felt Hollow and Without Purpose
Allison Mack, 2nd from left, with her Smallville costars
The Smallville program was shot in Vancouver, Canada, and as a result Ms. Mack left home and moved to live full-time in a new city in a different country, all at the age of 18. Smallville would go on to become a successful television show, running for 10 seasons. During this time, Ms. Mack saw her family only intermittently, mostly at holidays.
As a result, she and her family grew apart. Still, Ms. Mack made attempts to keep in touch, and was generous with the money that resulted from her role on Smallville. For example, during this time Ms. Mack paid half of the tuition for her brother to complete [redacted].
Likewise, Ms. Mack’s sister recalls that, even though Ms. Mack was often not physically present with the family, she would regularly check in on her sister by text message and would send gifts between visits.
Ms. Mack also paid the tuition for [redacted].
Ms. Mack did make efforts to participate in family life when the filming schedule permitted. Mack fondly recalls a surprise visit by Ms. Mack one Mother’s Day when she called her mother saying that she was in London but wished her mother a happy holiday—and then Ms. Mack appeared unexpectedly, holding her cell phone, a few yards away.
Despite the material and professional success that Ms. Mack had achieved in her acting career, Ms. Mack was plagued by feelings of hollowness and a lack of purpose.
She Was Immediately Enthusiastic About Nxivm & DOS
Allison Mack meeting Keith Raniere for the first time; November 2006
In 2007—five years into the run of Smallville—Ms. Mack first attended a self-help-stylized workshop of the organization then known as ESP, or “Executive Success Programs,” which would subsequently become part of an umbrella organization called Nxivm. […] The company billed itself as providing “coaching” for members to attain a “new ethical understanding” to allow humanity to “rise to its noble possibility.”
Ms. Mack was immediately enthusiastic about the program. In fact, Ms. Mack prevailed upon her mother to attend a Nxivm program with her soon after Ms. Mack became aware of the group. Ms. Mack’s friends recall that she was “excited about the opportunity for personal and professional growth offered by the program” and “was looking forward to empowering other young women and helping them find the same strength they were discovering.”
Ms. Mack’s family members also easily recall Ms. Mack’ s beginnings with the program, remembering that “Allison was tremendously excited about this new self-development course she had taken with this brilliant man, Keith Raniere.” Indeed, even during Ms. Mack’s early involvement with Nxivm, Raniere had set himself up as the “spiritual founder” of the organization and its philosophy.
In Ms. Mack’ s early years with Nxivm, the programs she paid to attend appeared to have some initial, positive impact. As recounted by her brother [redacted].
“Fatefully and Unfortunately” Mack Chose Nxivm, Not Yale
Allison Mack chose Keith Raniere and his library at 8 Hale Drive over higher learning at Yale.
Following the end of Smallville in 2011, Ms. Mack moved to New York City to pursue additional acting roles in theater. She also continued to attend additional Nxivm seminars and programs, occasionally traveling to Albany, where Raniere lived.
In 2012, Ms. Mack was presented with a choice: pursue an application to Yale Drama School or move to Albany to be closer to Nxivm and its leader, Raniere. Fatefully, and unfortunately, she chose the latter.
At the outset, Ms. Mack’s decision to associate more deeply with Nxivm seemed to be a positive and rewarding experience. As her longtime friend [redacted] describes it “[o]nce she was in Albany, she told me about the classes she was running and the women she was working with. Allison was proud of the impact she was having on the women around her. I was proud of her for following what I believed was a healthy and meaningful path in her life.”
According to Ms. Mack’s mother, “[w]hen people in the [Nxivm] community learned that I was her mother they would joyfully exclaim that they loved Allison! She had been there for them with kindness and patience in their moments of crisis and confusion.”
‘Nxivm Seemed to Be Taking a Sinister Turn’
Allison Mack looking underweight.
However, Ms. Mack’s family soon began to see troubling changes. As related by her brother, by 2013, Ms. Mack appeared physically depleted by her lifestyle in Nxivm. This only became more pronounced as time went on.
Ms. Mack’s mother recalls having concerns about Nxivm after Ms. Mack moved to Albany:
“I was concerned about the level of commitment the Nxivm community expected of her. They were all expected to report their activities, goals, weight and diet to select members of the community, including their successes and failures in these areas. Punishments and rewards were given based on performance. The community’s expectations and demands caused Allison to be sleep deprived. She survived on three to four hours of sleep per night.”
Ms. Mack’s brother similarly recalled that Nxivm seemed to be taking a sinister turn:
“In 2016, she came to our house for Thanksgiving dinner claiming that she was on day 7 of a ten day cleanse and ate absolutely nothing. She was almost in a daze the whole time. She would often absent herself to have a phone or video call with her “people” in New York. While she acted caring and loving, it was clear that she was in an unhealthy situation that was taking a toll on her.”
The Secret Sorority DOS Was Created
Sarah Edmondson, Allison Mack and Daniella Padilla — three DOS members.
By 2016, there was a very specific reason for Ms. Mack’s deteriorating condition. The prior year, Raniere had created an organization called “Dominus Obsequious Sororium,” or DOS for short, which is bastardized Latin intended to mean “Master of the Obedient Female Companions.”
DOS was comprised of female members, except for Raniere (whose involvement was to remain secret from Nxivm and anyone outside of the original group of DOS members he recruited), who constructed the organization to his own specifications to create [a] modern-day harem for himself. The system created by Raniere set up so-called “masters” and so-called “slaves” recruited to join the organization. Prior to Ms. Mack’s involvement with DOS, [redacted].
Raniere’s Demands Became Depraved and Sadistic
At its conception, Ms. Mack (wrongly) understood DOS to be an organization designed to empower women. As more people became involved in DOS, however, Raniere’s demands and directives to his “slaves” increased and became depraved and sadistic.
One of those directives was for initiates to provide an ever-increasing amount of “collateral” to DOS, in the form of compromising photos, videos, or written confessions (both true and false) of damaging facts. This “collateral” was meant to demonstrate an initiate’s commitment to the organization. Ms. Mack herself was compelled to provide collateral to Raniere, thus handing Raniere a cudgel that could be wielded to keep her in line.
Raniere Obtained Control Over Mack via Collateral
Raniere used the control he gained from collateral to impose his will on Allison Mack and others in DOS
Upon Ms. Mack’s delivery of collateral, Raniere had thus obtained control over Ms. Mack, and used that control to impose his will on her and others in DOS. Ms. Mack’s condition as a member of DOS was described in the trial testimony of Mark Vicente, a former member of Nxivm turned whistleblower:
Q: Was there anybody in particular who looked exceedingly skinny?
A: My — my greatest concern back then was Allison Mack. I was very concerned. I — I think at the time — yes, I was spending a lot of time with her back then, and I just couldn’t understand why she was — her weight was — was dropping so much. And also accompanying the weight loss was sort of this tired, kind of out-of-it look. You know, she sometimes couldn’t focus very well. And to me it looked like a kind of malnutrition. So I was deeply concerned about that, and so I went to talk about Raniere about it.
[ . . . ]
Former Nxivm member Mark Vicente with Keith Raniere
Q: So you discussed — you had a discussion with the defendant. What did he say?
A: Well, I went to see him […] and I said, I’m concerned that all these people have this idea that skinniness is the ultimate objective. And I said to him, it also worries me deeply given that in this society right now, with — with the — the obsession, with the bodies and models and everything, like I don’t think it’s healthy to tell a woman that their — her weight is tied to her enlightenment or her growth or whatever.
It’s just unhealthy. It’s going to — it – it’s bad. Women, and especially young women, have enough issues already with their appearance given the culture we live in, why - why do that?
And [Keith] said to me, well, you know, I work with different people in different ways, and there’s different reasons for different things.
And I – you know, it wasn’t making any sense whatsoever. And I said, but Allison — you know, what about Allison? She’s — you know, she looks terrible. [I]f this is her having some kind of breakthrough […] then I don’t understand breakthroughs because she looks horrible. And I said, you know, she looks broken.
And [Raniere] said, well, I’m trying to break her. (emphasis added).
Raniere succeeded in breaking Allison Mack. As explained by [this explanation is redacted, and makes reference to Exhibit 7, which is filed under seal]
During breaks in volleyball games, members of NXIVM would line up and kiss Raniere on the lips.
Brainwashing Complete, Mack Gave in to Raniere’s Sick Fantasies
Keith Raniere amuses Allison Mack with a rare genius.
Her brainwashing complete, Ms. Mack acquiesced in Raniere’s sick fantasies and, to her unending regret, became a “master” as well as Raniere’s “slave.”
The fact that Raniere was able to turn Ms. Mack into an agent of trauma is appalling but consistent with the structure and function of cults like Nxivm. As the Government’s expert, Dr. Hughes, explained at Raniere’s trial, indoctrination by an abuser “continues to sort of chop away and diminish an individual’s own sense of their independence, own sense of their individual capacity, their sense of their own autonomy and freedom of thought.”
The cumulative effect of these experiences is to put an abuse victim in constant fear and under the control of the indoctrinator. As Dr. Hughes also explained, the pattern of abuse by somebody like Raniere “creates the sense of the omnipotence, the omnipresence of the perpetrator, that it crosses time and space barriers, that they are wherever you are.”
Arrest Was ‘The Best Thing That Could Have Happened to Her’
In 2017, the Federal Bureau of Investigation began investigating Raniere and Nxivm more broadly. In October 2017, an expose in the New York Times revealed the existence of DOS, and Raniere, spooked by the media attention, relocated to Mexico.
In February 2018, a sealed arrest warrant was issued for Raniere and, subsequently, he was arrested in Mexico on March 26, 2018, and extradited to the United States.
On April 20, 2018, Allison Mack was arrested at her home in Brooklyn, New York. Ms. Mack now understands that this was the best thing that could have happened to her at that time.
Allison Mack in 2018
Under the bail conditions ordered by this Court, Ms. Mack was finally separated from Raniere and the Nxivm community. Instead of continuing her blind adherence to Raniere and the organization he created, Ms. Mack’s arrest wrested her away from his (and their) influence and reunited her with her family.
The Government’s insistence that Ms. Mack reside with her family, and the Court’s endorsement and reaffirmance of that requirement, proved to be both beneficial and prescient. As a result, Ms. Mack has been subject to home confinement at her parents’ house for more than three years.
It is not an overstatement that the intervention of victims, law enforcement and the Court likely saved Ms. Mack’s life by leaving her no choice but to reintegrate into her family. Beyond the direct reach of Raniere or those who continued to support him, Ms. Mack slowly but surely began to think for herself again and to understand and internalize the sinister nature of the man she had trusted and the group she had committed to.
At First, Mack Believed Criminal Charges Were a Big Misunderstanding
Ms. Mack recognizes that her subsequent cooperation with the Government could have been even more substantial had it started sooner.
To be sure, Ms. Mack’s turnaround was not instantaneous. For several months following her arrest, Ms. Mack remained in denial about the nature of Nxivm, DOS, and the intentions of Raniere, to whom she had been utterly devoted for more than 10 years.
During Mack’s time inside Nxivm, Raniere had frequently warned Ms. Mack that society would unjustly penalize them for living unconventional, but legal, lives.
Allison Mack outside court.
Viewed through the lens of those warnings, Ms. Mack felt that the charges were a big “misunderstanding,” because, “in her mind, she was following Keith’s guidance in helping herself and other women to conquer their attachments and limitations.”
Eventually, that realization did come. Deeply devastated by the realization that she had harmed, rather than helped, several women she cared about, [redacted].
Ms. Mack’ s brother also saw Ms. Mack come to the recognition that Raniere had been a false prophet who was leading her astray. Freed from Raniere’s influence, and with the help of family and attorneys, Ms. Mack was finally able to admit to the crimes she had committed.
Mack Woke Up to Raniere’s Evil Intentions After His Child Porn and Exploitation Charges
Allison Mack pleaded guilty to racketeering and racketeering conspiracy. By so doing, she avoided the more serious charges of sex trafficking and sex trafficking conspiracy.
On March 13, 2019, the Government superseded its Indictment for a second time, charging Mr. Raniere with Sexual Exploitation of a Child and Possession of Child Pornography. These new charges, coupled with other information Ms. Mack found out through the discovery in this case, cemented Ms. Mack’s emerging recognition of Raniere’s evil intentions and the extent to which she had been deceived and complicit in a criminal enterprise.
Accepting the evil of which she was a part of, Ms. Mack shifted her focus to “process[ing] [her] shame and remorse” and “mov[ing] into [her] future with integrity,” which included taking responsibility for her behavior before this Court and doing whatever she could to ensure that Raniere would never harm anybody again.
To that end, on April 8, 2019, Ms. Mack pleaded guilty pursmmt to a cooperation plea agreement with the government. At her change of plea hearing, following her allocution, Ms. Mack made the following statement expressing her remorse for what she had done:
“I am very sorry for the victims of this case. I am also very sorry for the harm that I caused to my family. They are good people who I have harmed through my misguided adherence to Keith Raniere ‘s teachings. I apologize to them from the bottom of my heart, and I am truly very sorry for what I have done.”
She Worked Through Psychological Trauma of Past 10 Years
Ms. Mack not only pleaded guilty but cooperated with the Government in its efforts to bring Raniere and others to justice. The initial stages of Ms. Mack’s cooperation proceeded in fits and starts, as Ms. Mack was working through some of the psychological trauma of the past decade in real time during her proffer sessions with the Government.
Notwithstanding the emotional difficulty of this process, between the end of March 2019 and the end of Raniere’s trial in July 2019, Ms. Mack met with the Government for several multi-hour proffer sessions at which she described in wrenching detail her experiences with Raniere.
During these repeated, lengthy proffer sessions, Ms. Mack told the Government everything she knew about Raniere, his co-conspirators, and the organization he had created. To participate in these sessions, Ms. Mack made multiple cross-country flights, and was prepared to make more, as she remained on standby to testify at Raniere’s trial, which she was ready and willing to do.
Ultimately, Ms. Mack was not called as a witness during Raniere’s mid-2019 trial. Nevertheless, Ms. Mack respectfully submits that her cooperation reflects her best efforts at the time, given the physical and emotional difficulties she was experiencing after more than a decade as an acolyte of Raniere inside Nxivm.
Sketch of Keith Raniere at his trial. Allison Mack was not called to testify against him, although she was prepared to do so.
Her Cooperation Was ‘Critical to the Prosecution of Raniere’
Indeed, even though Ms. Mack was not called to testify, her cooperation with the Government was critical to the prosecution of Raniere and his co-conspirators. The Government’s letter confirms as much, noting that Ms. Mack provided the Government with “relevant emails, documents and recordings.”
It was only through her cooperation that the Government obtained access to a particularly significant recording of Raniere discussing the branding of DOS “slaves.” The centrality of this evidence is confirmed by the fact that the Government referenced it in both the opening and closing arguments at Raniere’s trial.
As the Government’s letter makes clear, “[t]he government was not previously in possession of this recording.”
The letter also recognizes that Ms. Mack’s cooperation also aided in the prosecution of Raniere’ s co-conspirators, observing that “it is highly likely that the fact of her public guilty plea was a factor in other defendants’ decisions to plead guilty.”
Efforts to Rehabilitate and Make Amends
Jonathan and Mindy Mack, Allison’s parents.
The three foundations of [Allison Mack’s] turnaround have been therapy, education, and her family. As described above, Ms. Mack subjected her family to untold stress and worry during her time in Nxivm, and Ms. Mack witnessed the pain and fear inflicted on them by the withering media attention after the Nxivm story became public.
It would have been completely understandable if they wanted nothing to do with her, given the horrors they suffered as a result of her conduct. But they did not turn their backs on Ms. Mack, and the support they have provided is an act of grace for which Ms. Mack will be eternally grateful.
Indeed, it is no stretch to say that without her family, Ms. Mack likely would not have survived the last three years.
The importance of this relationship repair has also been apparent to Ms. Mack’s friends, including her longtime friend who writes that “[t]he strongest and most consistent of Allison’s feelings have been for her family [ … ] [s]he marvels at the unwavering support and love they have given her despite everything she has put them through.”
Ms. Mack’s friend has also witnessed the marked shift in Ms. Mack’s attitude towards, and appreciation for, her family:
“It is astounding to watch her introspective process as she has nudged headlong into unraveling all the parts of her journey. This process has been painful for her, and she continues to fight for authenticity and accountability. In this process of growth, I have seen her extend grace to her siblings and parents in ways that she would not have done in the past.”
The Nxivm Years Were Like a Nightmare for Her Family
Ms. Mack’s reunification into her family unit has not only been positive for Ms. Mack herself, but also for her family members. Ms. Mack’s younger sister attests that she “often reflect[s] on [Allison’s] arrest as a blessing in disguise: never in my life have I felt so deeply immersed in sisterhood as I do now.”
Ms. Mack’s older brother similarly described the incredible relief he felt at having his sister back: “Looking at it now, I feel like Allison’s twelve years in NXIVM were almost a bad dream. She had become completely lost in that organization and it had swallowed her whole life.”
Thanks to the Government and the Court, Ms. Mack has had an opportunity to wake up from that bad dream and begin the work of making amends to her family, friends, and those hurt by Nxivm.
Professors Marvel at Mack’s Thirst for Knowledge
As part of her change of direction, Ms. Mack has also embarked on new courses of education — a pursuit that she had previously set aside in service of her career as an actor. Ms. Mack has diligently sought to “make up for lost time” in her educational development by obtaining an associate’s degree from a community college in California, and is now working towards her bachelor’s degree at the University of California, Berkeley.
Ms. Mack’s passion for learning is evident, and she graduated from community college with a perfect 4.0 grade point average. As recounted by one of her professors, “[b]ecause she once gave up formal education, she is now visibly thirsty for knowledge, working to make up for everything that she might have missed.”
Another professor attests that “Ms. Mack is one of the most intelligent, insightful and authentic learners that I have worked with in my 25 year career as a Professor, and goes on to note that “Ms. Mack is deeply engaged in the process of discovering who she was, who she is and who she is becoming as a person, daughter, sister, aunt and as a member of the larger community and society with a positive and meaningful role to play.”
Ms. Mack has found the outlet of education to be deeply fulfilling, and wishes to stay the course in her pursuit of education and to learn skills that can benefit others.
A Change From Denial to Grief
Ms. Mack has completely changed course and recognized that she must acknowledge the damage she has caused and embrace accountability. In the words of one of Ms. Mack’ s friends, she has been participating in “fierce and honest conversations” in which she has learned to ” take herself on.” Another of Ms. Mack’s friends has also witnessed Ms. Mack’ s change from denial into grief:
“She has fought tenaciously for all of this. I have watched her sit in the sorrow and experience the waves of pain over all the things she cannot change. I have held her hand as she has wept in remorse, realizing her disillusionment with Keith and all that she participated in.”
Mack Is Now Able to ‘Own How She Was Deceived’
Those close to her have seen these events as nothing short of a “transformation” by which Ms. Mack is “owning, as best she knew how, what she had been a part of.”
Ms. Mack’s sister describes Ms. Mack having “a deep sense of shame in her heart” yet remaining ”utterly direct about the mistakes she has made and the damaging consequences.”
The contrast between the Ms. Mack of three years ago and Ms. Mack today is striking, with friends having “witnessed Allison in dissonance and confusion — not knowing how someone she trusted could be someone evil — to being able to own how she was deceived.”
Put differently, Ms. Mack’s friends and loved ones have “watched her step out of one life and into a new one […] with the wherewithal to make amends.”
Mack’s Marriage to Nicki Clyne: An ‘Incomprehensible Lack of Judgment’
Wedding picture of Allison Mack and Nicki Clyne
In December 2020, as part of her continuing efforts to right her wrongs, Ms. Mack filed for divorce from longtime Nxivm and DOS member Nicki Clyne, whom she married at Raniere’s request in order to obtain a favorable immigration status for Ms. Clyne.
The marriage represents another example of the now-incomprehensible lack of judgment Ms. Mack displayed during her time in DOS, and another action about which she is deeply remorseful. In addition to rectifying the fraud, Ms. Mack felt strongly about severing ties with Ms. Clyne because of Ms. Clyne’s continued outspoken support for Mr. Raniere, who Ms. Mack whole-heartedly rejects.
A New, Positive Path After a Decade of Indoctrination by a Depraved Manipulator
For more than a decade, Ms. Mack put her trust in a depraved manipulator and let herself be indoctrinated. Ms. Mack knows that she has committed grave wrongs as part of her association with Raniere. She will be forever remorseful for her failings during that dark time.
However, as set forth above, the arc of Ms. Mack’s life is now trending in a positive direction, towards truth, healing, education, and family. As a result, we respectfully submit that the Allison Mack standing before the Court at her sentencing hearing should receive a sentence that accounts for the progress she has made in charting this new path.
