On September 6, 2022, Keith Raniere filed an affidavit alleging maltreatment at the prison. He signed this affidavit while being housed in the Special Housing Unit at USP Tucson.
USP Tucson is a maximum security prison operated for the safety of sex offenders. It provides a federal facility where sex offenders, because they are the majority, can be relatively free from the targeting that occurs against them in other max security prisoners.
Raniere has been in the SHU since July 26.
Here is his affidavit.
I, Keith Raniere BOP register number 57005-177, pursuant to 28 U.S.C. § 1746, avow under penalty of perjury that the following is true to the best of my knowledge, information, and belief:
1. I am currently incarcerated in the United States Bureau of Prisons, at Tucson, AZ.
2. I am currently challenging my criminal convictions through the courts and the media.
3. I am the Plaintiff in this action against the United States Department of Justice and the Federal Bureau of Prisons for various violations of my civil rights.
4. I am being retaliated against by prison staff as a result of that lawsuit, and my efforts in challenging my criminal convictions.
5. Shortly after my legal team filed a F.R.Crim.P. Rule 33 petition on my behalf, my contact with my power of attorney Suneel Chakravorty was cut off with no explanation or valid reason.
Mr. Chakravorty serves as a go between for myself and my legal team, and denying him access was a major disruption to my legal efforts.
6. I was held in disciplinary segregation for 97 days with no valid reason given.
7. On January 6, 2022, I submitted an informal complaint to initiate the grievance process.
8. The issues I intended to grieve were:
1) I was punished for violating a policy, but I was never
told what the policy was;
2) Without knowing what policy was violated, I could not defend
myself against the disciplinary action; and
3) The charges were changed in the middle of the disciplinary process.
I believe that these issues were deliberate attempts to retaliate against me for trying to challenge my criminal conviction.
10.The disciplinary hearing report states that I violated Code 396 – Use of the mail (email) for abuses other than criminal activity and Code 397 – Use of the telephone for abuses other than criminal activity.
11. The report states that I used my cellmate to give messages to Nicole Clyne. However, I was able to speak with Ms. Clyne directly at that time, so there was no reason to do anything improper in order to speak with her.
12. I was able to visit with Ms. Clyne only 2 days after being put in the SHU as punishment for allegedly trying to talk to her through my cellmate.
13. On appeal, the discipline was upheld because I admitted the actions that were claimed. However, the actions I admitted to were not violations of the policies cited.
14. On June 9, 2022, I filed a Central Office Administrative Remedy Appeal. I complained that the responses I received failed to address the three issues that I had initially raised in my grievance.
15. I never received a response to the Central Office Administrative Remedy Appeal.
16. On July 26, 2022, I was assaulted while walking to a table with my food in the dining hall.
17. I did not fight back.
18. I was placed in disciplinary segregation for having been assaulted.
19. I was given a disciplinary ticket for “fighting” and have had my privileges revoked and was placed in segregation “pending investigation”.
20. I have had no contact with Mr. Withers prior to his assault on me.
21. After the assault, I was placed in the SHU.
22. I was dizzy for several days and could not get out of bed.
23. While in the SHU, I was not able to get grievance forms.
24. The counselor only comes through one time per week, and if I am not able to get their attention while they are passing my door, I am not able to communicate with them.
25. On August 19, 2022, I submitted an informal complaint on plain paper to the counselor.
26. I did not get a receipt.
27. I believe that I was given a disciplinary ticket as retaliation for the recent publicity that my case has received as a result of my efforts to challenge my conviction.
28. I have done everything in my power to pursue administrative remedies for these acts of retaliation.
29. I have filed official administrative remedy forms about the retaliation.
30. The responses did not address the issues I raised, including retaliation.
31. I have difficulty obtaining official forms, so I have submitted administrative grievances on plain paper.
32. I have no way of knowing if the grievance on plain paper was treated as a grievance, or if I will receive a response.
33. Due to these facts, I believe that submitting further grievances on the issue of retaliation would be futile.
34. I believe that submitting further grievances regarding retaliation would result in further retaliation against me.
