Government responds: Raniere photographed 15 year old girl’s ‘vagina & inner labia’; Allison Mack took nudes of adult women posed the same way & sent them to Raniere

Earlier this week, Frank Report featured a post about Keith Raniere’s most recent attempt to keep the jury from learning about – and quite possibly seeing – the pornographic photographs of the 15-year-old girl [Jane Doe 2] that were seized from the property at 8 Hale Drive.

In that post, we noted that Raniere’s lead attorney, Marc Agnifilo, has raised several interesting questions that the prosecution would need to address – and resolve – in order to be able to introduce those photographs at the upcoming trial.

Today, the prosecution filed its response to Raniere’s Second Motion To Suppress.

And it didn’t mince any words in making its case for being able to introduce the photographs in question as part of its evidence against him.

First, the prosecution pointed out that the Second Motion To Suppress was filed 14 weeks after the January 9th deadline set by the court for the filing of such motions.

Then it went on to document why that same motion is also meritless.


After reviewing Keith Raniere’s photo collection, the prosecution noted that “the emphasis on close-up images of the women’s vaginas is apparent”.

The presiding judge in the case, U.S. District Court Judge Nicholas G. Garaufis, will decide whether to grant an exception to the January 9th deadline.

But even if he decides to do that – which he might well do – it’s very unlikely he’ll grant the motion on its merits.

That’s because the prosecution’s responses to the questions raised by Agnifilo were so compelling.


The prosecution began by noting that the images Raniere is seeking to suppress were on a hard drive that had been seized pursuant to a March 26, 2018 Search & Seizure Warrant.

It then went on to reveal – for the first time – that it had also obtained a second Search Warrant – on February 22, 2019 – that allowed it to search that same hard drive for “additional images of child pornography”.

Next, the prosecution pointed out that the images that Raniere is seeking to suppress “are part of a collection including two digital images of a juvenile nude female exposing her vagina, including one in which the minor victim’s legs are open and her inner labia are visible”.

It also noted that Allison Mack “regularly required her ‘slaves’ to pose for nude photographs, including on one occasion close-up pictures of their vaginas, either as assignments or collateral” – and then sent those photographs to Raniere.

Allison Mack made women pose nude and sent the pictures to Keith Alan Raniere.


Aside from the timeliness issue, the prosecution’s contention is that the hard drive in question was properly seized pursuant to the original March 26, 2018 warrant – and that the pornographic photographs were properly seized in accordance with the so-called “plain view doctrine”.

In essence, the “plain view doctrine” holds that in the context of searches and seizures, things that are visible to a law enforcement officer who is legally in a position to see them can be seized without a search warrant – and are admissible as evidence.

The prosecution further argues that the agents who did the initial, cursory review of the hard drive in question “immediately recognized the minor depicted in the images and were aware, from other evidence, that Raniere had a sexual relationship with her beginning when she was fifteen”.


With respect to Raniere’s argument that the original Search & Seizure Warrant was limited to evidence concerning crimes that were committed “on or after January 1, 2015”, the prosecution noted that “evidence created prior to January 1, 2015 can constitute evidence of Raniere’s commission of crimes on or after that same date”.

It also notes that per Rule 404(b) of the Federal Rules of Criminal Procedure, evidence of entirely separate criminal acts that predate the charged crimes is also admissible.


Attached to the prosecution’s filing were two letters that describe some of the proverbial mountain of evidence that it has amassed against Raniere.

Some examples of that evidence include the following:
– Documents regarding NXIVM University;
– Documents concerning the Society Of Protectors (SOP);
– The SOP Compensation Plan;
– Security footage; and
– Collateral.


As noted in the earlier post, the prosecution also found pornographic photographs of eleven other females besides the 15-year-old girl, all of which were taken in 2005.

Two of those eleven women are known to be Lauren Salzman and Kathy Russell.

Lauren Salzman


Kathy Russell 

Based on information that was provided by a confidential source, Frank Report has now developed a list of the other nine women.

Whether the jurors are also going to be shown photographs of their vaginas and inner labia is shall we say an “open question”.

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Author: Artvoice

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