Clare Bronfman’s civil lawyer, Craig Martin, has responded to attorney Neil Glazer’s Plaintiff’s letter to Judge Eric Komitee in the matter of Edmondson et al v. Raniere et al.

Craig Martin of Willkie Farr & Gallagher, LLP of Chicago appeared for Clare Bronfman
Glazer wants to keep Bronfman in every aspect of a civil lawsuit with 81 plaintiffs suing on various and disparate issues connected to NXIVM.
Martin wants to get Bronfman out of any claims that do not directly relate to her actions, such as sex trafficking allegations.
Glazer’s argument is that Bronfman, along with her sister, Sara Bronfman-Igtet, were responsible for funding NXIVM, enabling it to thrive and do its foul deeds – and that the sisters were aware of the invidious nature of the organization.
All of the 81 plaintiffs were former NXIVM members, some quite high ranking.
The 11 defendants include Keith Raniere and the two Bronfman sisters, along with Nancy Salzman. Allison Mack, Lauren Salzman, Kathy Russell, Dr. Brandon Porter, Karen Unterreiner, Dr. Danielle Roberts and Nicki Clyne. With the exception of the Bronfman sisters, the other defendants have little to no assets.
Martin, writing to the judge, argued that many of the plaintiffs changed their minds about NXIVM.
He wrote, “Plaintiffs’ views of NXIVM today are an extreme departure from their long-time devotion to an organization they once participated in and profited from for many years. Indeed, what makes them plaintiffs is simply their change of heart—otherwise perhaps many of the Plaintiffs might have found themselves Defendants in this action.”
Martin also says Glazer’s First Amended Complaint:
is incomprehensible—it is unwieldly in length and scope while simultaneously failing to allege facts sufficient to support Plaintiffs’ claims…
makes allegations against “Defendants” without specifying which Defendants are included…
alleges conduct related to “Plaintiffs” without specifying which Plaintiffs are included…
includes Ms. C. Bronfman in claims unrelated to the… allegations Plaintiffs make about her (and, in particular, Plaintiffs include Ms. C. Bronfman in their sex-trafficking claims without alleging facts suggesting that Ms. C. Bronfman was even aware of any of Plaintiffs’ sexual activities, much less involved in them)…
does not identify the “enterprise” that forms the basis of their RICO claims…
ignores what constitutes an abuse of legal process…
brings claims that are time-barred…
despite its length,…fails to distinguish which Defendant allegedly did what, when, and to whom, or include sufficient facts to put Ms. C. Bronfman on notice of what Plaintiffs are specifically alleging against her…
failed to establish that Ms. C. Bronfman knew about or agreed to any illegal scheme…does not include any such facts as to what actions Plaintiffs allege she took…
fails to allege any specific actions by Ms. C. Bronfman showing that she knew about, agreed to facilitate, or took action with the purpose of pursuing the same criminal objectives as her alleged co-conspirators.
Martin further argues that the lawsuit improperly alleges Bronfman’s “deception and intimidation” tactics and that “with each iteration of Plaintiffs’ narrative, Ms. C. Bronfman and Ms. S. Bronfman are assigned greater decision-making positions.”
“Plaintiffs’ new allegations of intimidation and deception thus only further add to the morass of baseless accusations,” Martin wrote.
He points out that, despite Glazer’s letter, nowhere in the complaint “do Plaintiffs allege that Ms. C. Bronfman… engaged in ‘conniving and outright lies to the Dalai Lama … to promote the falsehood to persuade people to ignore negative media reports.’”

Clare Bronfman with the Dalai Lama. Did Clare deceive the Dalai Lama? Was he used to promote NXIVM under false pretenses?
Martin also points out that the complaint fails to allege that Bronfman targeted Plaintiff Toni Natalie.
The big argument perhaps at this juncture is whether or not Bronfman will remain a plaintiff on the sex-based schemes of the lawsuit. Martin wants the court to divide the lawsuit into two —one addressing Plaintiffs’ sex-based claims and one addressing their consumer-based claims.
Glazer argued that Bronfman should remain a defendant in all claims since “[n]one of these harmful acts were distinct.”
Martin argues that the sex trafficking claims are not “inextricably connected to their consumer-based claims.”
He points out that the majority of plaintiffs —at least 46— “make no allegations beyond enrollment in NXIVM. These Plaintiffs cannot plausibly state a claim for sex trafficking. Likewise, Plaintiffs have not alleged facts indicating involvement in or knowledge of sex-based claims for several Defendants, including Ms. C. Bronfman, and thus have no plausible claim against these Defendants. Bifurcation of the case therefore makes sense to avoid confusion of the issues and the evidence.”
Will the judge divide the case into two parts – sex and consumer fraud?
This ruling will be well worth looking out for and may make or break the case as it pertains to the Bronfmans, who after all, are the only reason for having this lawsuit since they are the only ones with any money to pay the plaintiffs with – and this lawsuit is about money.
***
Esther Carlson Selling Life Insurance

Esther Carlson
It is nice to know there can be life after NXIVM.
Former green sash proctor and longtime NXIVM coach, Esther Carlson, is now selling life insurance for Symmetry, according to a website for the Purdy Financial Group.
In fact, she is a Regional Agency Director. Apparently, Symmetry is a multilevel marketing company and Carlson has a downline that may include other former NXIVM members such as Michele Hatchette, Justin Elliot, Danielle Roberts and Brandon Porter.
Carlson writes on her page: “My favorite thing about building my agency is seeing other people who have worked so hard and built so much find a company that appreciates them and their gifts. Symmetry was built by people that are looking out for agents’ futures – the entire system is set up to take care of the builder, the care-giver, and the hard worker. You just need to stay focused and be coachable.
“What I look forward to in the future with Symmetry is spending more time with the new friends I am fortunate to have met and worked with so far.
“It’s so refreshing to be part of a team that holds out the best for you. What a cool job to work with people that like what you like and want to work for it. ‘Have fun and get stuff done!’”
On the page also is a four-minute video of Esther where she describes her work and the benefit of having her own business, pointing out that she had a hand in building businesses in the past which she did not reap permanent financial benefit from since they were not hers.
She is referring to NXIVM and some of its offshoots, though she does not mention the companies by name. She does say she lost her job, however. NXIVM closed its doors in 2018.
Carlson was the longtime companion of the late James Del Negro who passed away in Mexico earlier this year. Del Negro also sold term insurance for Symmetry. Carlson says she is living in Saratoga Florida and helps take care of her elderly mother.

James Del Negro, Esther Carlson, Justin Elliot and Samantha LeBaron.
From what I understand, hard-working salespeople can make a good living selling term insurance and with a downline where commissions roll upwards. I would not be surprised if Esther can build her business into a six-figure annual income range.
Much of the work concerns cold-calls to people who might want insurance and part of the work is to recruit salespeople who will do the same and establish a downline. The model is not dissimilar to NXIVM, except the product is term life insurance instead of learning the teachings of Keith Raniere.
***
Mexican Investigation of NXIVM Finances

Cecilia and Emiliano Salinas [green] with other Mexican Nxivm members.
The El Herald of Mexico reports a pending investigation of NXIVM by Unidad de Inteligencia Financiera [Financial Intelligence Unit or UIF.] Reportedly it began in late 2020, after Raniere was sentenced.
The UIF is a Mexican agency focused on detecting and preventing financial crimes such as money laundering and terrorist financing.
The investigation reportedly is looking into money flowing from Mexico to the United States to finance Nxivm, which had branches in Mexico City, Guadalajara, Guanajuato and Monterrey.
El Herald reports, “So far there is only an estimate that sets at about 50 million dollars a year what ESP earned from its courses, but the investigation of the US justice system recorded the shipment of carloads of cash from Monterrey, Nuevo Leon to Albany, New York, in overland trips, which would be more difficult to trace.”
The report names prominent NXIVM Mexican member Emiliano Salinas Occeli, son of former President Carlos Salinas de Gortari, who operated the Nxivm franchise in Mexico, “whose headquarters were located in a discreet building in Lomas de Chapultepec, very close to Reforma Avenue and the Periferico” and his partner, Alejandro Betancourt – and adds, “both are also partners in Prorsus Capital, an investment fund company under which the firm MoneyBack is grouped, beneficiary of a Treasury concession for tax refunds to international tourists justified to avoid double taxation.”
The report further mentions that the leader of the Morena political party, Mario Delgado, took ESP courses as did the failed Morenista candidate for governor in Nuevo Leon, Clara Luz Flores Carrales.

Clara Luz Flores was filmed enjoying a convivial conversation with Keith Raniere. This came back to bite the candidate who had previously said she never met Keith Raniere.
“There was no way to clean up the image of Flores Carrales…” El Herald wrote, but was more hopeful towards “the spouse of Emiliano Salinas, the actress Ludwika Paleta, [who] has begun a repositioning strategy in social networks and increased her participation in different film productions.”

Ludwika Paleta
I would be surprised if NXIVM earned $50 million per year on the sale of its courses. NXIVM claimed it had about 17,000 total students over 20 years. Some took more than one class per year. Most took only one or two classes. If they even had two thousand students taking classes at $2,000 per average class that would only amount to about $4 million annually.
If more than half of the revenues came from Mexico, then it is possible that over the years $10 million or more was laundered into the USA.
It will be hard to prove since my sources say the money was in cash and often on private airplanes. The cash was the fees for the courses paid for by various students.
Absent witnesses who will give details of how it was bundled and stored, it seems hard to imagine the UIF can make much of a case. Perhaps I am wrong.
As a hint to them, it seems likely that Nancy Salzman stored a fair amount of the cash at her house at 21 Oregon Trial. The FBI found $520,000 in cash stored in various places in her house when they raided it in 2018.
There may be more money stashed elsewhere in other properties.

