In a bombshell new motion in the case of the United States v. Keith Raniere, the prosecution team of Assistant U.S. Attorneys Moira Kim Penza, Tanya Hajjar, Mark J. Lesko, and Kevin M. Trowel is seeking to get Judge Nicholas G. Garaufis to approve allowing the testimony of the woman that readers of Frank Report know as Rhiannon.

This brave woman now wants to testify concerning Raniere’s infamous statutory rapes of her when she was 12 and 13 years old in the early 1990s.

Rhiannon first went on the record in 2012 – in James Odato’s expose, In Raniere’s Shadow, published in the Albany Times Union in February 2012.

The government argues that, according to Federal Rule of Evidence 414, they should be allowed to admit evidence of Raniere’s sexual abuse of Rhiannon, “including his repeated sexual intercourse with her when she was twelve or thirteen years old.”

Rhiannon is being identified as “Jane Doe X” by the prosecution and Raniere “has been provided with copies of all of Jane Doe X’s prior statements regarding Raniere’s abuse of her that are in the government’s possession,” according to the motion.

Will the judge allow Rhiannon to testify to what she said happened to her 28 years ago?

The crime is beyond the statute of limitations and you can bet the defense team will make a motion to block her testimony and any other evidence concerning the alleged rapes. They will also argue, you can bet, that it never happened.

However, the argument of the prosecution is simple: Even though Raniere will not be charged with raping Rhiannon, “Rule 414 states that ‘in a criminal case in which a defendant is accused of child molestation,’ a court ‘may admit evidence that the defendant committed any other child molestation.’”

Child molestation is defined in Rule 414 to include “contact between a defendant’s genitals and a child’s body or between a child’s genitals and a defendant’s body, where the child is under fourteen years old.”

Child exploitation and possession of child pornography form the basis for Racketeering Acts Two, Three and Four in the second superseding indictment against Raniere.

The prosecution argues that this is a “criminal case in which the defendant is accused of child molestation.”

They argue, “The defendant’s sexual intercourse with Jane Doe X [Rhiannon] when she was twelve or thirteen years old is ‘any other child molestation'” and is “admissible”.

The purpose for Rhiannon’s testimony is, the prosecution writes, to “demonstrate that the defendant ‘has a sexual interest in [teenage girls] and had the intent and desire to commit’ the racketeering acts with which he is accused related to Jane Doe 2.”

Jane Doe 2 – as readers know – is the 15-year-old Mexican girl whose sexually graphic pictures were found on Raniere’s hard drive which was seized by the FBI during a raid at of his sex lair, at 8 Hale Drive, one day after his arrest in Mexico in late March 2018.

The pictures were allegedly taken by Raniere in 2005.

Jane Doe 2 is the younger sister of Jane Doe 4, the woman Raniere is accused of holding imprisoned for 22-months in a room at 12 Wilton Court – a home owned by Nancy Salzman that was purchased with Clare Bronfman’s money.

Jane Doe 2 is now 29 years old and living in Guadalajara, still a member of Nxivm, and under the command of NXIVM Mexico leader Jack Levy, who controls her daily activities in Nxivm fashion. She is not expected to testify against Raniere.

In seeking to get the judge to allow Rhiannon’s testimony, the prosecution argues that “the evidence the government seeks to admit—the testimony of Jane Doe X—is no more prejudicial than the evidence of the crimes with which [Raniere] is accused. That evidence will include graphic nude photographs of Jane Doe 2 taken by the defendant when Jane Doe 2 was fifteen years old and documents indicating that the defendant began having sex with Jane Doe 2 when she was fifteen. Additionally, the probative value of Jane Doe X’s testimony is heightened because the defendant’s abuse of Jane Doe X and Jane Doe 2 occurred when both victims were around the same age, and Jane Doe X and Jane Doe 2 both had parents who trusted the defendant and left them unsupervised to be tutored or mentored by the defendant and cared for by women in the defendant’s ‘inner circle.’”

As readers know, Raniere told Rhiannon’s mother – who worked for him at Consumer’s Buyline – that he – known to be the world’s smartest man – would tutor Rhiannon in algebra and Latin.

His top inner circle pimp woman, the late Pam Cafrtiz – in order to lure the child to the home she and Karen Unterreiner shared with Raniere – hired 12-year-old Rhiannon to walk her dog twice per day.

In Jane Doe 2’s case, her Mexican parents had such trust in Raniere and Cafritz that they left their children in their care to raise as if they were their own.

Not only was Jane Doe 2 left in their care but also a brother and two sisters. Raniere wound up having sex with all three sisters.

Today, Jane Doe 2 and her older sister, as well as their father, are still devoted to Raniere. Her mother and her sister, Jane Doe 4 [who is expected to testify against Raniere about her imprisonment] and her brother have gotten off the Kool-Aid and now denounce the monster.