Omar Rosales moves fast.
The former NXIVM student, and attorney was first to write a book about NXIVM — American Cult: Nxivm Exposed.
Now, he is first to bring a class action lawsuit against NXIVM – suing one of its High Rank – Sara Bronfman-Igtet.
Utilizing Frank Report and Artvoice to announce he was seeking clients who have taken NXIVM courses, Rosales is pursuing a legal theory that everyone who took the NXIVM courses were deceived into taking it – because Raniere – the fountainhead of the teachings – egregiously lied about his credentials and accomplishments.
Rosales is suing deep-pocketed Sara Bronfman-Igtet as the main defendant.
Rosales has two named plaintiffs – Isabella Martinez and Gabriella Leal, who took NXIVM courses – to lead in this class action suit.
While Rosales alleges many crimes that Bronfman-Igtet participated in, the lawsuit is a civil lawsuit brought in New York State and is meant to recover class fees and tuition plus damages paid by plaintiffs and others who paid for Executive Success Program (ESP) and NXIVM classes sold as “Intensives”.
Former students are invited by Rosales to get in touch with him and join the lawsuit.
Here are a few excerpts from the complaint.
Defendant [Bronfman-Igtet] uniformly misled Plaintiffs and the Class that they would participate in classes that were equivalent to a ‘practical MBA’ to achieve success in business and in life. Part of the fraud committed to induce the purchase from ESP, was the claim that the program was developed by ‘one of the World’s Smartest Men’ – Keith Raniere.
… [T]he classes were designed (and known by the Defendant) to be another Multi-Level Marketing scheme to defraud students out of millions of dollars with classes that had no end, no graduation, no certification, and no credential. Moreover, the student-
victims’ tuition was used to fund a criminal enterprise run by Defendant and her indicted co-conspirators.
4. Defendant set out to leverage false claims about her co-founder and partner, Keith Raniere (who proclaimed himself as “Vanguard”), to sell classes that promised to give students the keys to success in business and life. Defendant also
developed and distributed marketing materials claiming that her associate Keith Raniere:
1) was one of the World’s Smartest Men;
2) began talking in complete sentences by age one;
3) was an East Coast Judo Champion at age twelve;
4) tied the New York State record for the 100-yard dash in High School; and
5) had a very rare problem-solving ability that allowed him to create a curriculum to assist others with their business
5. … Defendant repeated these claims. Defendant Bronfman-Igtet also personally paid for celebrity appearances and jet travel to induce student-victims to attend ESP classes and sign up for more ESP classes. … Defendant paid for the marketing event and trip to Albany, New York by the His Holiness the 14th Dalai Lama in April 2009, in order to give ESP and NXIVM credibility and legitimacy….
6. What the Defendant did not disclose, is that her co-founder Mr. Raniere had previously been sued by the New York State Attorney General’s Office for operating an illegal Multi-Level Marketing (MLM) business called “Consumers Buyline.” …
11. After Keith Raniere’s arrest, Mr. Raniere’s criminal defense attorney … Marc Agnifilo … in an interview on Dateline
NBC … announced … (on August 6, 2018), that Mr. Raniere’s qualifications and resume were fabricated. Thus, the students who enrolled in ESP and NXIVM courses did so under false pretenses… thus admitting the Defendant’s fraud and scheme to defraud Plaintiffs and class members of their money.
12. Although she was asked to appear in Federal Court to help secure her sister (and indicted co-Conspirator) Clare Bronfman’s $100 Million-dollar bail package, Defendant Sara Bronfman Igtet refused to appear in New York. … Defendant said he is nursing a young child and could not travel. Defendant then sent her Egyptian-born husband to post bond for Clare Bronfman.
However, her young children did not prevent the Defendant from traveling to Silver Bay, NY in Aug 2017 to coordinate and supervise Keith Raniere’s week-long birthday celebration and the ESP event known as “Vanguard Week” or “V-Week”….
13. Several Attomeys General and the U.S. Department of Justice are continuing their prosecution of the senior leadership of the Executive Success Program….
15. Plaintiffs seek damages and equitable relief on behalf of themselves and the Class, including… treble their monetary damages or a $1,000 damage award per class member; restitution; injunctive relief; punitive damages; costs and expenses, including attorneys’ and expert fees; interest; and any additional relief that this Court determines to be necessary or appropriate …
19. Plaintiff Isabella Martinez is a resident of the state of New York. Ms. Martinez learned about the Executive Success Program when she was told of the program by a friend. Plaintiff was given a marketing pitch developed by the Defendant. Plaintiff
was told that: Keith Raniere was one of the world’s smartest men, had a rare and unique problem-solving ability, spoke in complete sentences by age one, was an East Coast Judo Champion by age 12, and tied the State record for the 100-yard dash while in High School.
20. Based on Defendant’s misrepresentations and material omissions, Plaintiff Martinez purchased the $2,400 five-day intensive, which she attended in San Francisco, CA on November 18, 2016.
21. Plaintiff would not have paid for any of the ESP classes had she known the true nature of Keith Raniere’s qualifications: specifically, that all of Raniere’s purported qualifications were a lie.
22. Plaintiff Gabriella Leal is a resident of the state of New York. Ms. Leal learned about the Executive Success Program when she was told of the program by a friend. Plaintiff was given a marketing pitch developed by the Defendant. Plaintiff was told that: Keith Raniere was one of the world’s smartest men, had a rare and unique problem-solving ability, spoke in complete sentences by age one, was an East Coast Judo Champion by age 12, and tied the State record for the 100-yard dash while in High
23. Based on Defendant’s misrepresentations and material omissions, Plaintiff Leal purchased the $2,400 five-day intensive, which she attended in San Francisco, CA on November 18, 2016.
24. Plaintiff would not have paid for any of the ESP classes had she known the true nature of Keith Raniere’s qualifications: specifically, that all of Raniere’s purported qualifications were a lie.
26 …. Sara Bronfman-Igtet was a founder, board member, officer, director, managing member, principal, and/or controlling shareholder of ESP, NXIVM, and the associated shell companies. … Defendant and her sister aided in the creation of over 100 shell companies to mask overseas profits from NXIVM’s foreign operations … and to avoid … tax liabilities…
26. Defendant Bronfman-Igtet received revenues paid to ESP from Plaintiff and other Class Members through U.S. bank accounts and shell companies. Defendant used the proceeds to fund the criminal enterprise and Raneire’s crime spree….
29. Defendant Bronfman-Igtet and others, including … Keith Raniere, Nancy Salzman, and Clare Bronfman, devised and executed a scheme to make tens of millions of dollars by marketing ESP (Executive Success Program) as both: (1) a practical MBA; and (2) a learning institution with a faculty of qualified instructors and staff.
30. This scheme was fueled by an advertising campaign, selection of celebrities as spokespersons and recruiters for ESP (including Allison Mack and Kristin Kreuk), payment for celebrity appearances by the Dalai Lama, and the production and placement of main promotional videos on YouTube. … The YouTube videos stated that Keith Raniere (the developer of the ESP classes) was the one of the smartest men in the world, had a rare problem-solving ability, and was one of the world’s leading ethicists and philosophers. And though Defendant knew these claims to be false, Defendant continued to use these bogus qualifications as a
31. …. (a) Defendant Bronfman-Igtet reviewed and approved the ESP marketing materials before they were released, which featured Raniere’s bogus qualifications and claimed that the program was a practical MBA.
(b) Defendant used her vast wealth and resources to pay for marketing and advertising of the ESP program.
(c) Defendant used her private jet to provide travel for celebrities who fronted the ESP organization.
(d) Defendant paid for real estate, property, buildings, utilities, and expenses so that ESP could provide classes to student-victims.
(e) Defendant sent promotional and sales materials to student-victims through email.
(f) Defendant established more than 100 shell corporations to hide profits and avoid Federal income tax and state sales tax on the ESP classes.
(g) Defendant developed the marketing scheme to upsell student- victims to take more courses beyond the initial five-day intensive by claiming that student-victims needed additional classes to become fully integrated.
(h) Defendant helped to create the “Stripe Path” with the promise that the student-victims who achieve the highest rank (by taking classes and recruiting others) would be successful in business and in life.
(i) Defendant claimed that she is an “education entrepreneur with 15 years of experience in the field of human potential” – even though Defendant lacks a teaching certificate, lacks a college degree, and lacks a basic High school diploma.
(j) Defendant enforced the uniform deceptive portrayal of ESP, NXIVM, and NXIVM University through policies and procedures, including Marketing Guidelines, lesson plans, scripts, flashcards, nonsense scenarios (such as: Is it ethical to kill one person to save 10,000 people?), PowerPoint presentations, videos, and scripts that instructors were required to use. For example, the Marketing Guidelines were designed to “ensure brand, tone, and message across all of ESP’s marketing efforts.” The “tone” required by those Marketing Guidelines was to upsell more classes, encourage student-victims to recruit other victims, and portray Keith Raniere as an ethicist who was the one of the world’s smartest men with a rare problem-solving ability. Furthermore, to build brand legitimacy, ESP opened up a class center in Mexico and called it “NXIVM University” even though neither the classes, faculty, or school was ever accredited by any educational institution….
32. Defendant knew that these representations were false, that Keith Raniere and Nancy Salzman were actually con-artists who were running another illegal Multi- Level Marketing scam, and that Keith Raniere was not one of the world’s smartest men, but was instead using his position within ESP to have sex with women and children.
Defendant also created over 100 shell corporations to mask corporate profits and fund a lavish lifestyle filled with decadence, debauchery, and crime for Keith Raniere and her associates. …
ESP was never accredited by any educational group and there was no end to the courses. Rather, the courses were designed by Defendant as another Multi- Level Marketing scam and racketeering initiative to lure students to take more classes and go further into debt. In other words, the Defendant promised an Executive Success Program, but delivered neither Executives nor Success, but instead a long running criminal enterprise to fleece and rip-off consumers….
33. Though Defendant represented that ESP was led by the top leaders in industry, entertainment, athletics, and business, Defendant was aware that none of this was true. In fact, Defendant does not even have a High School degree, let alone a college
diploma. None of the instructors or staff of ESP were ever licensed by the State of New York or certified by any teaching institutions in New York or California.
34. Furthermore, although Defendant claimed in marketing materials that Nancy Salzman and Keith Raniere were among the world’s top ethicists, this claim was false. In fact, Salzman does not have a degree in ethics, philosophy, law, or English.
Instead, Salzman is a nurse. Furthermore, despite claims that he was the one of the world’s smartest men, it was revealed in 2018 by the FBI and U.S. Attorney’s Office that Keith Raniere barely graduated from Rensselaer Polytechnic University with a 2.2 GPA,
having failed math and science classes.
35. Though the entirety of Defendant’s marketing and advertising campaigns were centered around claims about Salzman and Raniere’s qualifications, none of these qualifications were true….
36. Although Defendant promised that student-victims would become successful in life, industry, business and love, none of that was true. The first level classes (known as “Intensives”) were designed to upsell students to take more classes. As students paid for these classes, portions of the fees went to the Keith Raniere and the Defendant as part of the Multi-Level Marketing scam.
37. Moreover, there was no end to the program. There was no final course, final exam, final certification, or graduation. Rather, this insidious scheme was designed to make student-victims take more classes and more classes – with no end.
38. The true goal of ESP for the Defendant and her cohorts was to extract as much money from student-victims, as quickly as possible, to finance Raniere’s criminal enterprise….
39. [S]student-victims were told they could achieve rank (called “sashes”) by recruiting additional students and taking more classes. And there was no end to the courses.
40. The courses included such nonsense topics as “Human Pain”. During the courses, student-victims were posed nonsense questions and bombarded with off-the-wall teachings including that rape was ethical and that fathers should have sex with their
41. The money that was obtained from student-victims was then routed through over 100 shell corporations created by the Defendant to avoid Federal and state tax liabilities. Defendant and her associates would also claim that Keith Raniere was
penniless and a pauper, and that had evolved beyond a material lifestyle. However, Defendant re-routed the funds taken from student-victims to support Raniere’s lavish lifestyle that included $2,000 custom tailored-suits, Italian loafers, Villas in Puerto
Vallarta, Private Jet Travel, 10-day long birthday celebrations held in resorts, drugs, and a harem of sex partners….
53. … Defendant’s associates including Keith Raniere, Clare Bronfman, Nancy Salzman, Allison Mack, Lauren Salzman, and Kathy Russell are all under Federal indictment for racketeering conspiracy in case no. 1:18-CR-204 in the Eastern District of New York.
54. Defendant Sara Bronfman-Igtet exercised substantial control over the affairs of the ESP enterprise, through among other methods and means, by the following:
(a) Providing the initial operating capital and holding an approximately 51% ownership stake;
(b) Creating and approving marketing and advertising materials, which featured her name and likeness;
(c) Recruiting celebrities such as the Dalai Lama, Allison Mack, and Kristin Kreuk, to appear on behalf of the enterprise and bring legitimacy to the enterprise;
(d) Providing her private jet for use by the enterprise;
(e) Selecting the names of shell companies to be used by the enterprise;
(f) Purchasing real estate for use by the enterprise;
(g) Hiring construction companies to build facilities for the enterprise;
(h) Regularly reviewing financial records of the enterprise;
(i) Negotiating and authorizing others to negotiate significant contracts, including employment contracts on behalf of the enterprise; and
(j) Organizing events on behalf of the enterprise including Raniere’s week-long Birthday celebration (known as “V-Week”) held in Silver Bay, New York.
55. Defendant Bronfman-Igtet was a knowing and willing participant in the scheme, and reaped revenues and/or profits therefrom. Approximately 16,000 student- victims went through the ESP course and each paid a minimum of $2,400 per training.
Thus, the enterprise was able to bring in at least $40-$80 Million dollars….
Read the entire complaint – https://frankreport.com/wp-content/uploads/2018/09/2018-09-04-rosales-Martinez-v-Bronfman-Complaint.pdf