I read through this whole 189 page complaint. I am not a lawyer so it took me like a week to get through it. https://frankreport.com/wp-content/uploads/2020/01/1-Complaint-00207560xAADF6.pdf
I'm including my highlights below (just some copy pasta). I omitted stuff that was in The Vow, but I hadn't heard too much else and there were a few pieces I found particularly disturbing. There's some stuff in the complaint that I didn't know, and I thought you all might want to see without reading the whole damn thing.
This is my favorite line from the lawsuit: "no one ever became an executive or a success as a result of [ESP]."
Other highlight: "Raniere, along with Defendants Nancy Salzman, Allison Mack and Nicky Clyne, created another group called “TEN C,” which was aimed at procuring young women from college sororities for Raniere. Privately, with sexual partners, Raniere referred to himself as 'TEN C,' which stood for 'The Emperor has No Clothes.'”
These are all just quotes, and I left them in the order I found them in the document. Apologies it's long, though nowhere near as long as the orig.
Defendant Nancy Salzman was aware that Jane Doe 20 suffered from Obsessive Compulsive Disorder (“OCD”) and told her that Defendants’ system could cure her OCD, and that if Raniere approved, she would be eligible for this treatment, administered by Nancy Salzman and Porter. Raniere subsequently approved this treatment, after which Jane Doe 20 was subjected to nightly 4-hour long EMs and periodic questioning by Porter, who had also instructed her to cease taking medications prescribed by a previous doctor. Jane Doe 20 was subjected to extreme verbal abuse, and began to suffer severe physical and psychological problems, which Nancy Salzman and Dr. Porter insisted were a result of her failure to fully commit to Defendants’ system. Eventually, in addition to worsening physical ailments,Jane Doe 20 realized that she was in a serious psychiatric crisis, which included having persistent suicidal thoughts, and which Defendants dismissed and blaming on her own alleged failures. Fearing that she would take her own life, Jane Doe 20 fled back to Canada,went into hiding,and delayed seeking medical treatment, out of fear that if she told anyone about her experience Defendants would retaliate.
212.Jane Doe 20 eventually sought and obtained medical treatment and reported her experience to the New York State Department of Health, which refused to investigate her complaint.
- At some point, Raniere asked Mark to alter video tapes of an intensive so that it would appear less damaging in litigation. Mark was unaware of Raniere’s purpose and agreed in order to gain Raniere’s approval.
- Shortly after the successful completion of that editing project, he was asked to quell fears within the community after nine high-level members of NXIVM challenged Raniere and resigned. Thereafter,Mark was praised by the Inner Circle for his loyalty to NXIVM and Raniere,and he was invited to become a member of the Executive Board. 243.Mark Vicente was thereafter promoted to the rank of Senior Proctor and promised an opportunity to open his own NXIVM center. Vicente also took EMP training, believing that this would enhance his ability to work with NXIVM students and increase his income. However, while taking these trainings, the Defendants announced that all EMP students, no matter what level they had achieved, had to begin again at level 1 because of alleged changes in the curriculum, so he ceased pursuing that career path.
- Jane Doe 51 also enrolled her child in the Defendants’ RCG, relying on Defendants’ false representations that it was staffed by qualified teachers trained in both child education and NXIVM’s system. Jane Doe 51 was also told that enrolling her child in RCG was a condition of remaining part of the NXIVM community. Jane Doe 51 spent substantial sums of money to keep her child enrolled in RCG.
In fact, some students became Coaches without completing the requisite curriculum, so long as they had recruited enough new students. All along the Stripe Path, recruitment was a far more significant contributor to advancement than was successful completion of the curriculum.
To a member immersed in the Stripe Path, the program generated an appearance of progress and the sense that one was overcoming obstacles and “integrating,” but it was all a scheme to get people to keep spending money on NXIVM courses forever. No one graduated, no one ever achieved their initially stated goals or objectives, and no one ever became an executive or a success as a result of NXIVM’s teaching.
In fact, members were trained to reevaluate the goals with which they entered the program and replace those “shallow” goals that could never bring them happiness with NXIVM goals—achieving “integration” to help create a more ethical society.
The concept of “slavery” was also defined by NXIVM as the right to the product of someone’s efforts. Applied to Rational Inquiry, however, because members were allegedly getting something of extraordinary value, the free labor they provided to NXIVM was not considered slavery.
When a member was in “breach,” other members would approach her or him to offer “feedback,” which members were taught to think of as helpful critique, not understanding that as a function of the overall NXIVM system, feedback was an abusive technique, diminishing self-esteem and eroding self-confidence. “Feedback” as practiced in the NXIVM system reinforced the constant message that one was a failure, that any “breach” was his or her fault, that if he or she failed it could imperil the community, and that he or she had to heal this“breach,” no matter what it took for the personal cost, because the only other option was to leave. The very thought of leaving crippled members with unfathomable shame, along with the very real fear that he or she would be permanently cut off from the community that he or she had likely devoted years to becoming part of, in which he or she had made a significant financial investment, and on which he or she was dependent to earn a living.
Some of the other teachings of Jness included: (i) that a women’s expectation of equal pay was untenable, because it cost businesses money to train new employees when women quit their jobs to have children and because women could rely on their husbands to provide for them; (ii) that women did not have to compete for work because they could rely on their partners or families for support, whereas men would be criticized for doing so; (iii) that men should be paid to do men’s jobs, women paid to do women’s jobs,and that these gendered jobs were not interchangeable; and (iv) women were not entitled to equal rights, because women were protected and sheltered from the consequences of their actions by men.
Raniere eroded resistance to these ideas by acknowledging that there were injustices to women, but that considerations of equal treatment for women were outweighed by the injustices suffered by men
In another example, Raniere “tested” Jane Doe 18’s unquestioning fealty by instructing her to lick a mud puddle and to run face first into a tree. When Jane Doe 18 “failed” the test by not smashing her face into a tree, Raniere instructed her to restrict her food intake to 800 calories per day. She informed Raniere that she had low blood sugar issues, and that because he had her working 20 hours per day, she needed her strength and thus could not so severely restrict her caloric intake.
Raniere and his co-Defendants also created “Society of Protectors Complete,” which was an arm of SOP aimed at women. This group was also referred to in military terms, with women told they would be training to become NXIVM’s “navy seals,” a pretext used by Raniere and others to subject them to ridicule, humiliation and dehumanizing experiences that the women were told were necessary to toughen them up and help them overcome inherent weaknesses in the female character.
Raniere also created a group just for women of East Asian heritage, called “One Asian.”
Defendant Allison Mack, who on one occasion commented to her that sex was “no big deal,” and that it was “just like playing tennis.”
Raniere, along with Defendants Nancy Salzman, Allison Mack and Nicky Clyne, created another group called “TEN C,” which was aimed at procuring young women from college sororities for Raniere.
Privately, with sexual partners, Raniere referred to himself as “TEN C,” which stood for “The Emperor has No Clothes.” Ultimately, this effort to procure young women for Raniere failed. Subsequently, Mack and Clyne created and ran DOS with Raniere.
In the EMs, a subject was taught to always be open and compliant, even if that meant revealing his or her innermost secrets, fears, and shames. All of this was recorded by the EMP for use in later sessions, and for use by other high-ranking people in NXIVM for other purposes, including persuading people that they needed to take additional intensives lest they be hung up on their issue forever
Between 2010-2017, as part of ESP, Porter performed human subject research on approximately 200 subjects participating in courses through ESP. Between 2012-2017, as part of ESP, Porter performed human subject research on ten subjects diagnosed with Tourette’s Syndrome. Once again, he used EEG, GSR and a video recorder, this time to measure tic responses before and after EM sessions with Nancy Salzman. The claimed purpose of this exercise was to look for improvement after the EM session. Similarly, between 2012-2017, as part of ESP, Porter performed human subject research on two subjects diagnosed with Obsessive-Compulsive Disorder. Once again, he used EEG, GSR and a video recorder, this time to measure severity of OCD symptoms before and after EM sessions with Nancy Salzman
During the twelve or so years that RCG was in operation in the U.S., it was never licensed as a daycare provider. The RCG “school” in Miami was shut down after authorities began inquiring into its lack of proper credentials.
One tactic they employed was to intervene and interfere in the bankruptcy proceedings of members who had exhausted their life savings and become deeply indebted to NXIVM, either in pursuit of the Stripe Path or in unsuccessful attempts to open their own NXIVM centers, and who then filed for personal bankruptcy in order to discharge their debts.
In fact, at least one DOS member’s collateral was released in retaliation for her speaking out against Defendants, NXIVM and DOS. That collateral had been edited by Lauren Salzman and Allison Mack, at Raniere’s direction, to make it appear as if the DOS “slave” had asked to be branded. Indeed, Raniere directed the branding ceremony to include the recitation of a statement that Raniere told Defendant Mack would create the appearance that the brandings were consensual.