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NXIVM— Case Archive
evidenceevidencephysicalphotographvideoaudiodigitaldocumentdemonstrativetestimonystipulationother2019 Federal TrialEvidence1260 distinct evidence records referenced across 205 proceedings.

Evidence

Records, recordings, images, and other material introduced or discussed at trial.

1,260 items·1,541 mentions

Key Evidence (12)

Government Exhibit 550

Digital Evidence

Government Exhibit 550 was identified during Brian Booth's testimony as a hard-drive directory tree displaying the Studies folder and photograph listings.

Government Exhibit 204

Documents & Records

Government Exhibit 204 was a box recovered from Nancy Salzman's residence containing labeled folders and loose documents, including purported financial information.

Government Exhibit 503

Digital Evidence

Government Exhibit 503 was a hard drive that Christopher Mills identified as a device he believed was made by Western Digital.

Government Exhibit 524

Digital Evidence

Government Exhibit 524 was the LEXAR media card that Christopher Mills identified as having been found inside the camera marked Government Exhibit 520.

Government Exhibit 725

Documents & Records

Richard Guerci's summary schedule, Government Exhibit 725, covers activity on Pamela Cafritz's American Express account ending in 42002.

Government Exhibit 907

Documents & Records

Government Exhibit 907 contains letters and proposed plans Daniela wrote to the defendant while confined in a room.

Government Exhibit 1008

Documents & Records

Government Exhibit 1008 contains the ESP Mission Statement discussed during Sylvie's testimony.

Government Exhibit 1404

Documents & Records

Government Exhibit 1404 contains DOS book text that Lauren Salzman read and explained during her testimony.

Government Exhibit 1527

Digital Evidence

Government Exhibit 1527 contains an email Daniela sent herself with a compilation of selected key-log information from James Loperfido's computer.

Government Exhibit 520

Physical Evidence

Government Exhibit 520 was the Canon camera bearing serial number 1420908348 that Christopher Mills identified during his Day 20 testimony.

Government Exhibit 605

Other

Government Exhibit 605 contains 57 DVDs produced in the Stephanie Franco litigation, including 35 recordings described in production correspondence as unedited.

Government Exhibit 497

Audio Evidence

Government Exhibit 497 contains a recording of Allison Mack and Keith discussing the branding ceremony.

Physical Evidence (58)

Government Exhibit 520 — Mills identified the camera as the one found in the bag designated evidence item one, with Government Exhibit 524 as its internal card; both exhibits were admitted on Day 20. The camera bore a marking stating that it was made in Japan. Booth could not charge its battery or power it on, and his examination of the camera itself was physical rather than internal.
4 mentions
A couple of hard drives at 8 Hale used for digitized media; Daniela believed she had configured one for backups — Daniela discussed maintenance of the computer and backups at 8 Hale during her Day 13 direct testimony.
1 mention
All Saints boot-sized shoebox and its $390,180 in currency, evidence item number 63, packaged into four bags — Fontanelli identified a boot-sized All Saints shoebox found in a crawl space as evidence item 63. He described its currency as divided into four bags totaling $390,180.
1 mention
Apple MacBook seized from Nancy Salzman's kitchen counter as evidence Number 13 — Fontanelli identified the Apple MacBook as the computer seized from Nancy Salzman's kitchen counter and shown in a search photograph. It was marked as Government's Exhibit 205 for identification and displayed to the jury.
1 mention
Basement utility-room safe, found broken open — Fontanelli described a safe against the wall of a basement utility room, approximately three feet by three feet. He testified that it had already been broken open when found during the search.
1 mention
Bedroom-closet bag containing $109,727, evidence item number 65 — Fontanelli identified a bag found at the rear of a bedroom closet as evidence item 65. He testified that the corresponding currency count form and deposit slip both showed $109,727.
1 mention
Binder at issue in the litigation — Valenziano agreed that litigation involving Stephanie Franco in two federal districts was over a binder. He testified that she was sued in August 2003 and dismissed on March 15, 2018.
1 mention
Blackberry phone that appeared to Fontanelli to be an older model — During cross-examination on Day 8, Fontanelli confirmed that a BlackBerry phone had been seized and said it appeared to be an older model.
1 mention
Books on approximately five bookshelves, some of which were seized — Mills estimated that there were approximately five bookshelves of books. He testified that some books and some electronic devices were seized, but not all the books.
1 mention
Brand remaining on Nicole's body, which she later learned represented Keith's initials — Nicole testified that branding was intensely painful and that she initially tried to regard the symbol as representing strength. She said she later learned it represented Keith's initials and still had the brand on her body.
1 mention
Burner phones Salzman left in Mexico with Nicki and requested back through counsel; she assumed Jack had them — Lauren Salzman testified that she had not recovered her phones despite requests through counsel. She assumed Jack had them, rather than stating that she knew their whereabouts.
1 mention
Camera and modem-connected equipment installed at 7 Generals Way through Plugged In — Mark Vicente discussed the camera equipment during his direct testimony on Day 3.
1 mention
Camera identified in the evidence by its serial number — In closing argument, Agnifilo described photographs as apparently passing from a camera identified by serial number through a computer to a backup hard drive. He qualified his account of the hardware and argued that no evidence showed the images were viewed or shared.
1 mention
Camera recovered from the defendant's library — During rebuttal, Lesko pointed to camera information in Government's Exhibit 504B6 and identified it with the camera recovered from the defendant's library. He discussed that information alongside folder dates and image metadata.
1 mention
Camera the prosecution said Raniere used to photograph Camila — In her Day 1 opening statement, Hajjar said jurors would see the camera she alleged Raniere used to take the photographs of Camila. Her statement previewed anticipated evidence rather than reporting its admission.
1 mention
Cannon camera — Booth testified that no photographs had been taken of the box containing the camera and storage device. He emphasized that his notes reflected only his own access to the camera and reported receiving it on June 10, 2019.
1 mention
Canon EOS 20D camera referenced in the photograph metadata and serial-number comparisons — Booth testified that the Canon serial numbers were consistent across the many images he had checked. He did not expressly say he checked every image.
1 mention
Cash recovered from Nancy Salzman's home and a photograph of that cash — During closing argument, Penza displayed a photograph of cash recovered from Nancy Salzman's home and described approximately $550,000 stored in shoeboxes and another bag. She argued that the money belonged to Raniere despite his claimed lack of assets.
1 mention
Cash Vicente recalled seeing handed over at an executive-board meeting — Vicente recalled seeing a large amount of cash handed over at an executive-board meeting. He thought Nancy Salzman received it but could not say whether Emiliano Salinas or Alex Betancourt handed it over.
1 mention
Cauterizing pen Danielle was learning to use for branding — Nicole testified that Keith put Danielle in charge of branding new DOS members. She said Danielle was branded first and was learning to use a cauterizing pen.
1 mention
Computers used by Marianna at Flintlock that Daniela said she infected; she thought one was a Mac and the other a large PC — The computers were tentatively described as a Mac and a large PC during Daniela's Day 13 direct testimony.
1 mention
Dell computer or other computer described as an intermediate storage device — Agnifilo described a Dell or other computer as an apparent intermediate device between a camera and a backup hard drive. He said the computer was no longer around and suggested it had probably become obsolete.
1 mention
Dell desktop computer at 8 Hale that Daniela maintained and said she saw Keith use — Daniela described maintaining the computer and backups at 8 Hale. She said Keith provided his password for a scan during which she discovered photographs of naked women.
1 mention
Edgar Bronfman's office desktop computer — Stephen Herbits discussed the office desktop computer during his direct testimony on Day 7.
1 mention
Electronic devices and over half a million dollars in cash that the government said were recovered from Nancy Salzman's home — During a Day 5 admissibility discussion, Penza said electronic devices and over half a million dollars in cash had been recovered from Nancy Salzman's home at 3 Oregon Trail. The defense objected to admission through Fontanelli; no ruling appears in that discussion.
1 mention
Hard drive with the blue circle — In closing argument, Agnifilo described the blue-circle hard drive as apparently holding backups from a Dell or other computer, including photographs of Camila and other people. He qualified his description of the hardware and argued that no evidence showed the images were viewed or shared.
1 mention
Hard drives in Loperfido's office — Loperfido testified that a court order permitted copying all hard drives in his office to look for information about Mr. O'Hara in connection with a lawsuit.
1 mention
James Loperfido's laptop, on which Daniela said she installed surveillance software while Kathy Russell distracted him — The laptop was identified with Daniela's reported installation of surveillance software while Kathy Russell distracted Loperfido.
1 mention
Key logger reportedly placed on Loperfido's laptop — Loperfido denied authorizing or observing installation of a key logger on his laptop. He testified that he learned of its reported placement only when someone told him much later.
1 mention
Large engraved patent plaques presented onstage at a V week — The plaques were identified as large engraved patent plaques associated with an onstage presentation at a V week.
1 mention
Large professional camera stored at 8 Hale that Daniela identified as the camera Keith used to photograph her — The camera was described as stored at 8 Hale and identified by Daniela as the camera Keith used to photograph her.
1 mention
LEXAR CF2 GB card from the camera; LEXAR MEDIA, FAT16 partition designation — Booth confirmed that the LEXAR CF2 GB card was the card in the camera he analyzed. He explained that LEXAR MEDIA, FAT16 was its partition designation and that the file path described the directory structure where items were located.
1 mention
Loperfido's laptop computer — Loperfido said he brought his laptop whenever he traveled to Albany for NXIVM work and sometimes left it unattended. He denied permitting or observing anyone place a device on or in it.
1 mention
Necklace with a supposedly permanent clasp that Monica put on Sylvie — Sylvie said Monica put the necklace on her in connection with a commitment vow Sylvie had written and Monica had approved. She described its clasp as supposedly impossible to undo and recalled that Monica called the necklace a dog collar.
1 mention
Nicole's phone, which she said she gave to the government — When asked whether she provided her WhatsApp messages to the government, Nicole said she thought so because she had given the government her whole phone.
1 mention
Old BlackBerry phone (seizure item 34) — During cross-examination on Day 8, Charles Fontanelli confirmed that seizure item 34 was another older-model BlackBerry phone.
1 mention
Pam Cafritz American Express card and its continued use after her death — In rebuttal, Lesko argued that Raniere continued using Cafritz's American Express card after her death and paid its balance from a Key Bank account. He characterized that use as part of an effort to maintain the appearance of having no income or assets while avoiding taxes.
1 mention
Pamela Cafritz's American Express card ending 2002 — Donato confirmed that charges reflected in 35 receipts were made to Cafritz's American Express card ending 2002. Each occasion involved treatment of Raniere, sometimes together with Marianna.
1 mention
Plastic bag containing $10,000, from which Nicole described authorized withdrawals — Nicole said Raniere produced a plastic bag containing $10,000 after she described financial difficulties associated with DOS. She said she used authorized amounts for $1,000 in rent, train and bus travel, and a $1,000 package of EMs.
1 mention
Previously discussed recovered box, evidence item number four — Fontanelli confirmed that the previously discussed box he recovered was designated item number four.
1 mention
Projection equipment Loperfido brought to V Week and operated, which he associated with a nonprofit he helped establish — Agnifilo emphasized that Loperfido obtained and projected a film without stopping it. Loperfido denied knowing its subject beforehand and said he obtained it at Russell's request.
1 mention
PSP used to access her father's Facebook account — Daniela acknowledged guessing her father's Facebook password and using his account without permission.
1 mention
Refurbished Dell laptop Daniela said she bought in Troy using $500 from Pam for the hacking work — The computer was described as a refurbished Dell laptop that Daniela said she bought in Troy with $500 from Pam for hacking work.
1 mention
Table to which Nicole said her wrists and feet were tied — Nicole said she was told to undress and get onto a table, where her wrists and feet were tied to different sides. She described the table as cold.
1 mention
The box of materials found in Nancy Salzman's house, including handwritten notes attributed by the defense to Kristin Keeffe — Agnifilo described a box found in Nancy Salzman's house and attributed its handwritten notes to Kristin Keeffe. He urged jurors to examine the notes, citing references to her son and material about Rick Ross as reasons for his attribution and interpretation of her activities.
1 mention
The brand India said was applied with a cauterizing pen and bore Raniere's initials — India said at sentencing that a cauterizing pen applied the brand in an extremely painful procedure lasting 30 minutes and requiring months to heal. She described it as bearing Raniere's initials and said she might have to live with it permanently.
1 mention
The brand Sarah Edmondson said she had removed through plastic surgery — Edmondson said during her sentencing statement that the brand bearing Raniere's initials was gone because she had it removed through plastic surgery.
1 mention
The camera examined by Stephen Flatley and Booth — Booth confirmed that he examined the camera in June and that Stephen Flatley had looked at it before him.
1 mention
The defendant's phone, which Penza alleged was being hidden in Mexico; Agnifilo said he did not have it and did not know its whereabouts — Penza alleged that the defendant's phone was being hidden in Mexico. Agnifilo said he did not have the phone and did not know where it was.
1 mention
The mark bearing Raniere's initials that Camila described on her body — Camila said Raniere had asked whether his initials on her body would keep her from being with other people. She said covering the mark had not removed the pain and shame it recalled.
1 mention
Two blindfolds placed on Nicole — Nicole said the defendant placed two blindfolds on her after telling her to put her clothes back on. She recalled that one was tighter and left marks beneath her eyes, while the other was tied around it.
1 mention
Two Dell laptops in a box next to Government's Exhibit 204 — Fontanelli confirmed that two Dell laptops were in a separate box next to Government's Exhibit 204, identified in questioning as item number four.
1 mention
Two external hard drives, another Dell computer, a western digital passport hard drive and additional thumb drives listed among the seized property — During cross-examination on Day 8, Charles Fontanelli confirmed that the property receipt listed two external hard drives, another Dell computer, a Western Digital Passport hard drive, and additional thumb drives seized from the residence.
1 mention
Two hard drives on a shelf and another large LaCie hard drive on the desk, identified in the video — During his direct testimony on Day 4, Mark Vicente identified two hard drives on a shelf to the right of Raniere's seating area. He also identified a larger hard drive on the desk, describing it as resembling a LaCie drive.
1 mention
Two laptops Herbits carried when traveling with Edgar Bronfman — The two laptops were referenced during Stephen Herbits's direct testimony on Day 7.
1 mention
UGG shoebox and currency, evidence item number 64; conflicting count and deposit amounts were stated — Fontanelli described the UGG shoebox as stacked above another shoebox inside a bag in the crawl space. He stated a total of $50,637 when discussing item 64's currency count form, but identified $15,670 in its deposit records. His examination provided no explanation or correction for the difference.
1 mention
VHS machines and combo decks purchased for the copying project — The copying equipment was referenced during Mark Vicente's direct testimony on Day 3.
1 mention
Ziploc bag of money in small envelopes that appeared to Salzman to contain Dawn Morrison's royalty payments — Salzman described small envelopes containing amounts such as $5, $10, and $20, bearing what she identified as Morrison's handwriting, dates, and amounts. She said the collection appeared to span many years.
1 mention

Photographs (166)

Government Exhibit 120 — On Day 3, Mark Vicente identified the previously admitted photograph as 7 Generals Way, where he had lived and where the basement served as Moving Pixels' postproduction facilities.
3 mentions
Government Exhibit 39 — On Day 20, Jay identified Allison Mack when counsel displayed the photograph, which was already in evidence.
3 mentions
Government Exhibit 518-A through 518-U — Booth confirmed that the photographs appeared in his report for the V110205 folder. On Day 23, the court admitted the set without objection and permitted the images to be shown to the jury alone. In closing argument, Penza cited metadata dates of November 2, 2005, for Exhibits 518-A through 518-N and November 24, 2005, for Exhibits 518-O through 518-U.
3 mentions
Government Exhibit 8 — Mark Vicente identified Clare Bronfman in the photograph during direct testimony on Day 2.
3 mentions
Defense Exhibit 328 — The court admitted the Fiji photographs after objections concerning bathing-suit images and cumulative value. On redirect, Vicente reduced his estimate of DOS members in one photograph from five to four he was pretty certain about and identified Danielle as the person who performed branding ceremonies.
2 mentions
Defense Exhibit 341 — Vicente said he did not know who took the photograph, although defense counsel had suggested India. He testified that he believed the photograph showed he was being spied upon.
2 mentions
Defense Exhibit 941 — Nicole identified Souki after examining the original photograph, and the exhibit was admitted without objection on Day 20. On Day 23, Michael Weniger identified Valerie in the photograph during questions about her place in Allison Mack's DOS line.
2 mentions
Government Exhibit 1106-A — Jelonek recognized the image as a still from her video, and the court admitted it without objection on Day 16. Rees later described similarities in the lamp's base, structure, and handle behind the light.
2 mentions
Government Exhibit 1106-B — Jelonek recognized the image as a still from her video, and the court admitted it without objection on Day 16. Rees described similarities in the tripod's coloring, gray upper section, and gray handle, and confirmed that no camera was mounted on it.
2 mentions
Government Exhibit 147 — Jelonek identified the photograph as her condominium at 120 Victory Way during her Day 16 direct testimony. During Mark Vicente's Day 4 direct testimony, the same exhibit number was associated with a photograph of Danielle.
2 mentions
Government Exhibit 148 — During her Day 16 testimony, Jelonek first identified Government Exhibit 148 as the front door of 120 Victory Way and later identified a woman under the same exhibit number as Kathleen O'Sullivan. The testimony did not resolve those differing descriptions.
2 mentions
Government Exhibit 15 — The photograph was identified as Nicki during Lauren Salzman's direct testimony on Day 8 and as Nicky during Mark Vicente's direct testimony on Day 4.
2 mentions
Government Exhibit 159 — Vicente identified the photograph as Apropos when Government Exhibit 159 was published during his continued direct testimony on Day 3.
2 mentions
Government Exhibit 17 — The photograph of Jim Del Negro came up during Mark Vicente's direct testimony on Day 3 and Lauren Salzman's direct testimony on Day 8.
2 mentions
Government Exhibit 180 — Fontanelli identified the exhibit as the full set of photographs from the March 27, 2018 search of 3 Oregon Trail, with selected images presented during his testimony. During cross-examination, counsel identified a two-page receipt listing seized devices and cash as the exhibit's last two pages.
2 mentions
Government Exhibit 31 — The photograph of Barbara Jeske came up during Mark Vicente's direct testimony on Day 3 and Lauren Salzman's direct testimony on Day 8.
2 mentions
Government Exhibit 34 — Salzman identified Kristin Keeffe when Government Exhibit 34 was published during her Day 8 direct testimony. The photograph also came up during Mark Vicente's direct testimony on Day 3.
2 mentions
Government Exhibit 429 — Salzman identified the images as photographs of Audrey's brand, which she described as Keith's initials, and said they showed its healing over time. She testified that she initially required daily brand photographs and reduced the frequency to weekly after six weeks.
2 mentions
Government Exhibit 448-R — The exhibit contains redacted versions of the photographs in Government Exhibit 448, and both sets were admitted without objection. During Jay's testimony, public monitors were turned off for its display; she said the blurred private areas had not been blurred in the photographs she copied.
2 mentions
Government Exhibit 45 — The photograph of Daniella Padilla came up during Mark Vicente's direct testimony on Day 4 and Lauren Salzman's direct testimony on Day 8.
2 mentions
Government Exhibit 49 — The photograph of Emiliano Salinas came up during Mark Vicente's direct testimony on Day 3 and Lauren Salzman's direct testimony on Day 8.
2 mentions
Government Exhibit 50 — The photograph of Lauren Salzman came up during Mark Vicente's direct testimony on Day 3 and Day 4.
2 mentions
Government Exhibit 516-A — A stipulation identified Monica Duran as the person depicted in Government Exhibit 516-A. During Brian Booth's testimony, the associated EXIF date and time were read as October 18, 2005, at 20:33:09. The photograph was also described during Michael Weniger's testimony as containing what appeared to be an older-model VCR.
2 mentions
Government Exhibit 53 — Salzman identified Karen Unterreiner when the photograph was published during her Day 8 direct testimony. The photograph also came up during Mark Vicente's direct testimony on Day 3.
2 mentions
Government Exhibit 56 — Jay identified India Oxenberg in the photograph during her Day 20 direct testimony. The photograph also came up during Mark Vicente's direct testimony on Day 4.
2 mentions
Government Exhibit 929 — The court admitted Government Exhibit 929 by consent on Day 12, and Daniela identified the person depicted as her sister Camila. During closing argument on Day 26, Penza described the exhibit as a redacted image and relied on that identification in discussing the sexual-exploitation allegations.
2 mentions
1164 — The presentation during Maegan Rees's resumed direct testimony on Day 17 was suspended when Exhibit 1164 would not display.
1 mention
1189 — Maegan Rees confirmed that Exhibit 1189 corresponded to the May 30, 2016 creation date in the metadata she read during her Day 18 testimony.
1 mention
1190 — Maegan Rees described a large brown table, two lamps, a stepstool, a tripod holding a camera, blinds, apparent dark curtains, an apparent brown towel and a floral rug. She compared several objects with video imagery and described similarities without an unqualified identification of the location.
1 mention
1400-198 — The court admitted Exhibit 1400-198 without objection as part of a group of exhibits. In its later handling of the graphic image, the court allowed limited discussion and a general description by Rees but barred display to the jury.
1 mention
502-A-34 — Counsel described the displayed image as dark and asked Mills whether he could see a blue light. Mills said he could not.
1 mention
502-A-52 — When asked whether the calculator pictured in 502-A-52 was one he had taken, Mills said he believed so.
1 mention
Camila photographs and their underlying electronic images — During closing argument on Day 27, Agnifilo distinguished government-printed photographs of Camila from their underlying electronic images. He described the images as stored on a backup hard drive and argued that no evidence showed they had been viewed or shared.
1 mention
Defense Exhibit 150 — The photograph depicts Salzman and Pam Cafritz at New Year's in Fiji. Defense Exhibit 150 was offered without objection, marked, and shown during Salzman's cross-examination on Day 11; the exchange contained no express ruling receiving it in evidence.
1 mention
Defense Exhibit 151 — The photograph was described as showing Salzman, Daniella Padilla, Nicki Clyne, Marianna, and Omar Boone in Fiji. The court received Defense Exhibit 151 without objection during Lauren Salzman's cross-examination on Day 11.
1 mention
Defense Exhibit 152 — The Chacala photograph was described as showing Salzman, Keith, Marianna, Nicki, Keith and Marianna's son, and Norma. The court received Defense Exhibit 152 without objection during Lauren Salzman's cross-examination on Day 11.
1 mention
Defense Exhibit 153 — The photograph depicts a Jness meeting. The court received Defense Exhibit 153 without objection during Lauren Salzman's cross-examination on Day 11.
1 mention
Defense Exhibit 156 — The photograph was described as showing Salzman with Loretta Garza, Daniella Padilla, Nancy Salzman, Nicki Clyne, and Kerstin Ohlander. The court received Defense Exhibit 156 without objection during Lauren Salzman's cross-examination on Day 11.
1 mention
Defense Exhibit 301 — The photograph depicts Vancouver Center participants together.
1 mention
Defense Exhibit 302 — Vicente identified himself in the middle of the photograph, holding Sarah and a drink in his left hand. He agreed that everyone was smiling and identified Sarah as wearing a blue dress.
1 mention
Defense Exhibit 303 — The photograph depicts Vicente, Lauren Salzman, Val Ward, and Adrianna Castilaso.
1 mention
Defense Exhibit 304 — Vicente tentatively dated the photograph of four people to 2009.
1 mention
Defense Exhibit 597 — The photograph depicts Daniela and her father at the beach.
1 mention
Defense Exhibit 598 — The photograph depicts Daniela running a 16K race.
1 mention
Defense Exhibit 600 — The photograph depicts Marianna and Daniela outside a hotel identified as Daniela's workplace.
1 mention
Defense Exhibit 601 — The photograph depicts Daniela and Marianna inside a hotel.
1 mention
Defense Exhibit 603 — The photograph depicts Daniela at a restaurant she visited with Marianna and her father.
1 mention
Defense Exhibit 604 — The photograph depicts Marianna, Daniela's father, and Daniela at a hotel.
1 mention
Defense Exhibit 942 — Nicole identified India, Michele, and Allison in the photograph. The court admitted Defense Exhibit 942 without objection, and the photograph was shown.
1 mention
Defense Exhibit 943 — Nicole individually identified India, Michele, and Allison in the photograph. Defense Exhibit 943 was admitted without objection and shown during her cross-examination.
1 mention
Explicit photograph Keith took on Sylvie's phone and sent to Monica through a secret Telegram chat — Sylvie testified that Raniere positioned her for an explicit photograph on her phone and sent it to Monica through their secret Telegram chat so it would appear to come from Sylvie. She recalled deleting it with Monica's permission, unsuccessfully trying to retrieve it when Monica later requested it, and being told they would have to do it again.
1 mention
Explicit photographs Sylvie said she sent Raniere, including photographs of her genitals; she said her father later discovered photographs through linked iCloud access — Sylvie described sending Raniere explicit photographs, including images of her genitals, and said her father later discovered photographs through linked iCloud access. She recalled receiving permission to stop sending photographs and being told the next step would be in person.
1 mention
Explicit photographs the prosecution alleged Raniere took of Camila — In her Day 1 opening statement, Hajjar alleged that Raniere took explicit photographs of Camila and kept them as part of a larger collection. She previewed the photographs and the camera she said he used as evidence the government would present.
1 mention
Government Exhibit 1010 — The photograph depicts a sash display on a training-room wall.
1 mention
Government Exhibit 1199-A — The photograph shows Jelonek's phone displaying 518-859-5004, which she associated with the woman renting 120 Victory Way. Jelonek testified that she continued contacting the tenant at that number, and the court admitted the photograph without objection.
1 mention
Government Exhibit 123 — The photograph of 8 Hale was discussed during Mark Vicente's direct testimony on Day 3.
1 mention
Government Exhibit 123-A — The wider photograph of 8 Hale was discussed during Mark Vicente's direct testimony on Day 3.
1 mention
Government Exhibit 126 — Lauren Salzman identified Exhibits 126 and 127 as photographs of the sorority house where the group began meeting. Both photographs were already in evidence when shown during her Day 9 direct testimony.
1 mention
Government Exhibit 127 — Lauren Salzman recognized Exhibits 126 and 127 as showing the same sorority house. Exhibit 127 was already in evidence when discussed during her direct testimony on Day 9.
1 mention
Government Exhibit 132 — The photograph of the Twilight Drive entrance signs was discussed during Mark Vicente's direct testimony on Day 3.
1 mention
Government Exhibit 133 — The photograph of 13 Twilight Drive was discussed during Mark Vicente's direct testimony on Day 3.
1 mention
Government Exhibit 157 — The photograph of Apropos's front was discussed during Mark Vicente's direct testimony on Day 3.
1 mention
Government Exhibit 164 — The photograph of the building exterior and sign at 455 New Karner Road was discussed during Mark Vicente's direct testimony on Day 3.
1 mention
Government Exhibit 165 — The entrance photograph was discussed during Mark Vicente's direct testimony on Day 3.
1 mention
Government Exhibit 166 — The photograph of Nancy Salzman's parking plaque was discussed during Mark Vicente's direct testimony on Day 3.
1 mention
Government Exhibit 167 — The alternate-angle building photograph was discussed during Mark Vicente's direct testimony on Day 3.
1 mention
Government Exhibit 169 — The wider photograph of 457 New Karner Road was discussed during Mark Vicente's direct testimony on Day 3.
1 mention
Government Exhibit 170 — The photograph of the front of 457 New Karner Road was discussed during Mark Vicente's direct testimony on Day 3.
1 mention
Government Exhibit 172 — Mark Vicente recognized the photograph as a road-facing view of the front of the building. He identified Hayner's Sports Barn in Halfmoon as a location where volleyball games were held for several years.
1 mention
Government Exhibit 173 — Mark Vicente identified the photograph as a wider view of the same building shown in Exhibit 172. He testified that the building contained two volleyball courts, batting cages, and other facilities.
1 mention
Government Exhibit 175A-1 and Government's Exhibit 502A-34 — During closing argument, Penza described Exhibit 175A-1 as showing the defendant with a hard drive behind him in February 2012 and Exhibit 502A-34 as showing the drive recovered in 2018. She argued that the drive appeared in the same location in both images.
1 mention
Government Exhibit 179 — Charles Fontanelli recognized the photograph as another angle of a room where he had seen Raniere seated in a video. He explained that a pillar and its power outlet identified the chair, but he did not recall the other occupants.
1 mention
Government Exhibit 1806, 1807, 1809, 1811, and 1812 — During closing argument, Penza identified Exhibits 1806, 1807, 1809, 1811, and 1812 as examples of intimate photographs women provided as DOS collateral. She did not display them again but said jurors could request them during deliberations.
1 mention
Government Exhibit 19 — The photograph identified as Monica was discussed during Lauren Salzman's direct testimony on Day 8.
1 mention
Government Exhibit 24 — The photograph identified as Adrian appeared during Mark Vicente's continued direct testimony on Day 3.
1 mention
Government Exhibit 28 — Jay identified Michele in the photograph when Government Exhibit 28 was shown during direct testimony on Day 21.
1 mention
Government Exhibit 32 — The photograph identified as J appeared during Mark Vicente's direct testimony on Day 6.
1 mention
Government Exhibit 33 — The photograph identified as Rosa Laura appeared during Lauren Salzman's direct testimony on Day 8.
1 mention
Government Exhibit 352 — The image was described during Mark Vicente's direct testimony on Day 6 as having been sent to him after May 20, 2017.
1 mention
Government Exhibit 366 — Lauren Salzman identified herself and the staff from the museum intensive Daniela attended. The court admitted the photograph without objection and authorized its display to the jury on Day 10.
1 mention
Government Exhibit 367 — Lauren Salzman identified Daniela among the students and staff pictured at the museum intensive. The court admitted the photograph without objection and authorized its display to the jury on Day 10.
1 mention
Government Exhibit 4 — The photograph of Edgar Boone appeared during Mark Vicente's direct testimony on Day 3.
1 mention
Government Exhibit 43 — The photograph identified as Ben Myers appeared during Lauren Salzman's direct testimony on Day 10.
1 mention
Government Exhibit 448 — The court admitted the original photograph set and its redacted counterpart without objection on Day 6. Lesko requested display of the redacted versions to the jury, court, and counsel, with screens positioned to prevent gallery viewing.
1 mention
Government Exhibit 46 — Mark Vicente identified Keith Raniere in the photograph during direct testimony on Day 2.
1 mention
Government Exhibit 48 — The photograph identified as Cathy appeared during Lauren Salzman's direct testimony on Day 8.
1 mention
Government Exhibit 5 — The photograph of Omar Boone appeared during Mark Vicente's direct testimony on Day 3.
1 mention
Government Exhibit 502-A-24 — Christopher Mills testified that the March 27, 2018 photograph showed a second-floor office with a long desk or table, computers, chairs, and a whiteboard. He described apparent drawings of furnishings elsewhere in the room, along with equations, words, and letters on the board.
1 mention
Government Exhibit 502-A-42 — During cross-examination on Day 20, Christopher Mills confirmed that the pictured items were addressed to Monkey and had hearts beside the name.
1 mention
Government Exhibit 502-A-46 — During cross-examination on Day 20, Christopher Mills confirmed the pictured location beneath the desk and identified the depicted object as Government Exhibit 560.
1 mention
Government Exhibit 502-A-51 — During cross-examination on Day 20, Christopher Mills said he believed the pictured object had been on top of the desk. He could not read the wording counsel pointed out.
1 mention
Government Exhibit 508 — During direct testimony on Day 23, Brian Booth confirmed that he dated the image's creation to December 2005 based on its EXIF data.
1 mention
Government Exhibit 508-A through -F, 509-A through -O, 510-A through -L, 511-A through -L, 512-A through -I, 513-A through -P, 514-A through -P, 515-A through -KK, 516-A through -H, 517-A through -O, and 519-A through -HH — The photograph series was also reflected in Government Exhibit 505. The court initially overruled the adult-image objection subject to the direction and volume of testimony, recognized a continuing defense exception, and later admitted the enumerated series over renewed objection.
1 mention
Government Exhibit 508-E — The parties stipulated that the photograph depicts Lauren Salzman. Brian Booth matched it to IMG_0207.jpg and read EXIF information identifying a Canon EOS 20D and an original date and time of December 26, 2005, at 3:01:40 a.m.
1 mention
Government Exhibit 509 — On Day 23, Brian Booth confirmed that his testimony about the image's creation date was based on EXIF data indicating November 2005.
1 mention
Government Exhibit 509-A — The identity stipulation identified Angel Smith in the photograph. Brian Booth read its original EXIF timestamp as November 10, 2005, at 20:22:18, and identified the camera as a Canon EOS 20D.
1 mention
Government Exhibit 509-D — Michael Weniger's direct testimony on Day 24 included the photograph, which was described as showing Angel Smith and what appeared to be an older-model Nokia telephone.
1 mention
Government Exhibit 510-G — The identity stipulation identified Barbara Jeske in the photograph. Brian Booth read an original EXIF timestamp of October 30, 2005, at 18:01:14, and confirmed that the digitized timestamp matched.
1 mention
Government Exhibit 511-F — The identity stipulation identified Dawn Morrison in the photograph. Brian Booth confirmed the corresponding metadata and read its original timestamp as October 17, 2005, at 22:02:00.
1 mention
Government Exhibit 512-C — The identity stipulation identified Daniela in the photograph. Brian Booth read its original EXIF timestamp as October 19, 2005, at 19:33:09.
1 mention
Government Exhibit 513 — The stipulation identified Exhibit 513-B as depicting Barbara Bouchey. For the Tab B image discussed under Government Exhibit 513, Brian Booth read an original EXIF timestamp of October 17, 2005, at 16:53:22.
1 mention
Government Exhibit 514 — The stipulation identified Exhibit 514-A as depicting Loreta Garza. Brian Booth confirmed that the EXIF data for the Tab A image discussed under Government Exhibit 514 indicated October 29, 2005.
1 mention
Government Exhibit 515-A — The identity stipulation placed Pamela Cafritz on the left and Marianna on the right. Brian Booth read the photograph's original EXIF timestamp as October 20, 2005, at 16:20:13.
1 mention
Government Exhibit 517-A — The identity stipulation identified Kathy Russell in the photograph. Brian Booth identified the camera as a Canon EOS 20D and read an original EXIF timestamp of October 19, 2005, at 18:54:09.
1 mention
Government Exhibit 518-F — The court allowed Exhibit 518-F to be shown to jurors with redaction tape during Michael Weniger's direct testimony on Day 24.
1 mention
Government Exhibit 530 — Michael Weniger could not recall the photograph's exact date and estimated 2017 or 2018. The court allowed jurors to view it with redaction tape on Day 24.
1 mention
Government Exhibit 54 — Lauren Salzman's direct testimony on Day 8 included the photograph labeled Government Exhibit 54.
1 mention
Government Exhibit 671 — Michael Weniger described the image as a family photograph of the kind typically taken at the beginning of DOS first-line meetings. He identified six women and noted that Camila and Lauren Salzman were absent; he said the photograph predated Salzman's involvement.
1 mention
Government Exhibit 859 — Sean Welch identified the pictured shackles as the fifth item on the invoice examined during his Day 8 testimony. The court admitted the exhibit without objection.
1 mention
Government Exhibit 912 — Daniela testified that the photograph was taken somewhere in Cohoes, New York, while Camila attended school there. She estimated that Camila was perhaps 13 or 14 years old.
1 mention
Government Exhibit 915 — Daniela identified the image as showing her whole family and thought it might have been taken in 2004.
1 mention
Government Exhibit 916 — Daniela identified the birthday photograph during her Day 12 testimony and explained that her family took the quinceañera celebration seriously.
1 mention
Government Exhibit 917 — Daniela identified Cami on the left and herself on the right during her Day 12 direct testimony.
1 mention
Government Exhibit 918 — Daniela identified Cami on the left and Fluffy on the right during her Day 12 direct testimony.
1 mention
Government Exhibit 921 — Daniela identified her mother on the left and Cami on the right, describing the photograph as taken at the same moment as the Tampico photographs from around 2004.
1 mention
Government Exhibit 922 — Daniela identified Cami on the left and her father on the right during her Day 12 direct testimony.
1 mention
Government Exhibit 925 — Daniela associated the family photograph with the shop where her father manufactured tools and estimated that she was about ten years old.
1 mention
Government Exhibit 926 — Daniela testified that she made the image using Photoshop-like software and identified, from left to right, Cami, herself, Fluffy, her mother and her father.
1 mention
Graphically nude photographs of Camila returned by Google for Camila's Gmail account — Rees testified that she reviewed photographs Google provided in response to a search warrant for Camila's Gmail account and confirmed that some depicted Camila graphically nude.
1 mention
Group photograph recognized by Vicente — Vicente recognized the group photograph during questioning on Day 6.
1 mention
Images Booth examined — During his Day 23 redirect testimony, Booth said the images he examined did not come from Facebook or another company.
1 mention
Images from Camila's Gmail account reflecting an injury — Rees confirmed that she reviewed injury images from Camila's Gmail account dating from around the time of messages discussing an injury after April 26.
1 mention
Images in the red binder and V110205 — Booth testified that the red-binder and V110205 images consistently had EXIF dates of November 2 or November 24, 2005, notwithstanding differences in file-system timestamps. He separately agreed that a displayed Government Exhibit 504-B example showed November 5, 2005; the exchange did not explain the differing date references.
1 mention
Individual genital photographs taken by Allison during the Berkshires trip — Nicole testified that Allison announced an assignment to take close-up genital photographs during the October 2016 trip and photographed her. Nicole said she was angry and understood that the photographs were being sent to Keith.
1 mention
Instagram photographs of potential recruits shown to Allison and India — Jay testified that Allison and India commented on potential recruits' appearance when viewing Instagram photographs. She said attractiveness was not her own selection criterion and that Allison, rather than particularly India, showed interest in that category.
1 mention
Intimate photographs Salzman said Raniere took of her around 2005 — Lauren Salzman testified that Raniere took intimate photographs of her with a camera that had a flash, rather than a phone. She said she worried someone might see them, received his assurance that no one would, and never saw the photographs again.
1 mention
Joint Exhibit 175-A-1 — Christopher Mills testified that the whiteboard writing appeared largely unchanged from what he saw on March 27, 2018. He also indicated the drive above the monitor, directly left of the whiteboard drawings.
1 mention
Naked group photographs called family photos — Nicole testified that Allison introduced family photos during group meetings and that she later saw Allison send a picture to Keith. She said Allison told the women to look happy because Keith could judge their state of mind from their faces.
1 mention
Naked photographs Agnifilo previewed and characterized as exercises in vulnerability rather than sexualized images — In his opening statement, Agnifilo previewed naked photographs and argued that they concerned vulnerability and acceptance of one's body. He characterized the images as nonsexual and said the photographs were taken with the subjects' knowledge.
1 mention
Naked photographs Camila said Raniere took of her when she was 15 — At sentencing, Camila said Raniere took naked photographs of her during secret meetings when she was 15. She said sexual contact occurred at every meeting, including those involving photographs, and described being photographed as an enduring memory.
1 mention
Naked photographs Daniela said Raniere took of her at Flintlock around 2005 despite her reluctance. — Daniela testified that Raniere insisted on photographing her naked at Flintlock despite her reluctance. She recalled his instructions about removing clothing and positioning herself, and said the camera was very close, although she did not know whether he also zoomed in.
1 mention
Naked pictures of 15-year-old Camila discussed by the court — During its sentencing analysis, the court stated that Raniere took naked photographs of Camila when she was 15. The court also referred to the lasting impact she described from being photographed.
1 mention
Nude collateral photographs Sylvie said she took on Monica's camera after Monica requested a full-frontal photograph — The photographs were identified with Sylvie's account of using Monica's camera after Monica requested a full-frontal image.
1 mention
Nude group photographs sent to Keith at the start of DOS meetings — Lauren Salzman testified that each DOS meeting began with a nude group photograph sent to Keith. She said the photographs had to show the women's brands and that the women were expected to appear uniform and happy.
1 mention
nude photographs — The court discussed keeping nude photographs outside the jury room while making them available if jurors requested them. It asked counsel to identify which materials should be handled that way.
1 mention
Nude photographs reviewed during the DOS investigation, some of which were collateral — Michael Weniger testified that most of the nude images were intimate close-ups, while some also included the woman's face. He confirmed that some, but not all, of the photographs he reviewed were collateral.
1 mention
Nude photographs Salzman gave Rosa Laura on a USB drive; she believed there were three — Lauren Salzman testified that she took what she believed were three nude photographs and gave them to Rosa Laura Junco on a USB drive. She said Junco suggested photographs after rejecting her earlier collateral and assured her that the images would be kept securely and unseen.
1 mention
photo of Albert Einstein — Charles Fontanelli confirmed that he could see the Albert Einstein photograph when counsel pointed it out during cross-examination.
1 mention
Photograph binders containing all images, with the Government proposing to direct jurors to 11 images — The Government proposed directing jurors to 11 images in binders containing all the photographs. The judge said he would ask jurors to turn only to the designated pages.
1 mention
Photograph Hajjar identified as showing Camila at age 15 — During her opening statement, Hajjar identified the photograph as showing Camila at age 15. She used that identification while alleging that Raniere began having sex with Camila at that age.
1 mention
Photograph identified by counsel as Bates numbers 1718, showing the basement utility room, boxes and safe — Charles Fontanelli identified the photographed area as a basement utility room containing the water heater and other house equipment. Counsel also asked him about boxes, storage cabinets, and the locked safe visible there.
1 mention
Photograph Nicole recognized as herself with her broken arm — Nicole identified herself in a mirror photograph wearing a hat and sweater with her broken arm visible. She explained that the camera's appearance in the image showed that she had taken it in a mirror.
1 mention
Photograph obtained from Camila's Google account showing the wooden table and surrounding objects — Penza described a photograph obtained from Camila's Google account showing a wooden table moved from its usual position and what she argued was a tie used to restrain Nicole. She said its date matched Nicole's account of the encounter. Her further claim that a camera recorded Nicole without her knowledge was an inference, not proof that a recording was recovered.
1 mention
Photograph of the next witness's sister that the prosecution expected to introduce — Before the next witness testified on Day 12, Penza said she expected to introduce a photograph of the witness's sister. The court agreed that sketch artists should not sketch the sister from that photograph.
1 mention
Photograph of the table and its date metadata — In rebuttal, Lesko argued that the table photograph's metadata confirmed May 31 as the date Nicole described being restrained. He placed that date shortly before DOS became public and began to unravel.
1 mention
Photographs in the Studies folders, identified through initials, nicknames, and image comparisons — Weniger explained that photograph identifications used folder initials or nicknames and comparisons with other available images, and were not all immediate. He described recurring intimate close-ups and some images that included faces.
1 mention
Photographs Jay supplied as monthly collateral — Jay testified that she supplied photographs she described as sexy or unattractive as collateral due on the first of each month. She initially submitted monthly collateral to India and later uploaded it directly to Dropbox.
1 mention
Photographs of brands Jay saw before the matter reached the media — Jay testified that she saw photographs of brands shortly before the matter reached the media, after having physically seen Audry's brand.
1 mention
Photographs of Camila discussed in Agnifilo's account of his trial defense — At sentencing, Agnifilo said he had not substantially disputed the photographs at trial. He explained that his defense had argued they remained on a device and were never sent or shown to anyone.
1 mention
Photographs of evidence that Hajjar believed had been provided through Special Agent Christopher Mills — The photographs were discussed during Brian Booth's cross-examination on Day 23.
1 mention
Photographs of Jane Doe 2 that the court found constituted child pornography — The court found that Raniere took photographs of Jane Doe 2 constituting child pornography on at least two occasions. It also found, by a preponderance of the evidence, that he took the photographs during an ongoing sexual relationship through which he groomed her for the offense.
1 mention
Photographs of naked women Daniela said she found on the 8 Hale computer, including Monica Duran; she did not recall seeing photographs of herself — Daniela testified that she discovered nude photographs while scanning the 8 Hale computer after Keith supplied his password. She did not recall seeing photographs of herself.
1 mention
Photographs of the defendant hanging on a basement wall — Charles Fontanelli identified photographs of the defendant hanging on a basement wall while describing an image of the room during his Day 7 direct testimony.
1 mention
Photographs proposed for admission by consent for the next witness; consideration deferred — The court deferred consideration of proposed photograph admissions for the next witness until after Sylvie's testimony on Day 2.
1 mention
Photos Nicole asked Allison to destroy and delete — In the email discussed during her testimony, Nicole asked Allison to destroy and delete all photographs and Dropbox collateral received over the year. She described wanting to leave the situation and protect herself and her family.
1 mention
Possible photographs documenting the condition of items during examination — Brian Booth initially thought he had directed photographs to be taken but could not recall whether his assistant took them in this instance or whether prosecutors received any. The court directed a search after prosecutors said they did not possess any examination photographs she might have taken.
1 mention
Pregnancy-test photograph recovered from Camila's Gmail account — Rees confirmed that the pregnancy-test photograph had metadata dating it earlier than the two other images whose metadata appeared in Government Exhibit 1191.
1 mention
Proposed nude photographs with sensitive portions pixelated or blocked out; the court authorized jury-only publication — The prosecution proposed using nude photographs with sensitive portions pixelated or blocked out. The court authorized display to the jury but not the public, and defense counsel did not object to that procedure.
1 mention
Regina's initial nude photograph and a requested replacement showing her entire front — Sylvie's direct testimony on Day 2 addressed Regina's initial nude photograph and a requested replacement showing her entire front.
1 mention
Replacement explicit photograph taken after Sylvie deleted the first photograph — Sylvie testified that Keith took another explicit photograph after she could not retrieve the deleted original and Monica said they would have to repeat it. Sylvie thought the positioning was similar, and she waited for Monica's permission before deleting the replacement from the chat.
1 mention
Single binder containing approximately 18 charged images described by the prosecution as child pornography, proposed for display during the remaining testimony — The prosecution proposed displaying a single binder containing approximately 18 images it described as child pornography. Over a defense objection, the court allowed the agent to display the binder and then pass it for optional further viewing; the planned display did not occur during that examination.
1 mention
Two nude photographs in the July 6, 2016 message series — Sylvie's redirect testimony on Day 2 addressed the photographs associated with that message series.
1 mention
Ultrasound image recovered from Camila's Gmail account — Rees confirmed that the ultrasound image had metadata dating it earlier than the two other images whose metadata appeared in Government Exhibit 1191.
1 mention
Ultrasound photograph with metadata, which the government said was obtained from Google by search warrant for Camila's Gmail account — The government said the photograph came from Google's response to a search warrant for Camila's Gmail account and that accompanying metadata showed when it was sent. The court allowed the ultrasound and pregnancy-test materials after the defense raised an objection concerning unfair prejudice.
1 mention
Wrist-injury photographs, which the government said came from Camila's Gmail account with contemporaneous messages; ruling deferred pending review of the messages — The government said contemporaneous messages from Camila's Gmail account explained the photographed injuries. The defense challenged their admissibility, and the court reserved its ruling pending review of the messages, expressing concern about unfair prejudice and whether the photographs were necessary.
1 mention
X-rays related to Camila's appendectomy obtained through a sibling — Michael Weniger's direct testimony on Day 24 included discussion of the appendectomy-related X-rays.
1 mention

Video Evidence (76)

Government Exhibit 605-B — Vicente said the excerpt at 1 minute 45 seconds likely showed a camera stop and restart during the original recording, while acknowledging that later alteration was possible. The court admitted the video on Day 3 subject to later authentication and connection to litigation production, at least as a demonstration of the described methods, with its use in deliberations remaining conditional.
3 mentions
Government Exhibit 605-C — Vicente testified that an excerpt appeared to combine cable jiggling with a static insert and additional jiggling to hide the static cut point. The court admitted the video on Day 3 subject to later authentication and connection to litigation production, at least as a demonstration of the described methods, with its use in deliberations remaining conditional.
3 mentions
What The Bleep Do We Know — Vicente said the film combined pseudo-quantum mechanics, neurobiology and the biology of emotions with animation and a narrative portion. He testified that, after its release, Nancy Salzman and Barbara Bouchey invited him and the other producers to a symposium, leading to conversations about NXIVM.
3 mentions
Government Exhibit 1103 — Sheila Jelonek identified the interior recording, which was admitted and played on Day 16, and said the refrigerator magnets' profanity surprised her. During playback on Day 18, Maegan Rees identified a door handle, blinds, and a table.
2 mentions
Government Exhibit 1106 — Jelonek identified a tripod positioned near the bed during playback of Government Exhibit 1106 on Day 16. On Day 18, Rees examined stills from the video and discussed the positions of a table, blinds, and a door handle.
2 mentions
Government Exhibit 605-A — The court admitted Government Exhibit 605-A subject to connection on Day 3, at least as a demonstration of the editing processes Vicente described, with further authentication required before a decision on deliberation use. Lesko later requested a portion of the video but moved to another exhibit after referring to a problem.
2 mentions
Government Exhibit 605-D — Vicente described portions of Government Exhibit 605-D as appearing to show cable jiggling, static inserts, and recording-machine pause or stop cuts. The court admitted the video on Day 3 subject to connection, at least as a demonstration, with further authentication required before deciding its use in deliberations.
2 mentions
Mark Vicente's video statement — Vicente appeared by video at sentencing on Day 29 and described psychological injuries that he attributed to Raniere, including damage to his self-esteem and belief in goodness. He asked that Raniere be held accountable.
2 mentions
20/20 broadcast about NXIVM — Nicole's cross-examination on Day 20 included discussion of the broadcast.
1 mention
2016 V Week promotional trailer from which Vicente removed Nicole — Vicente testified that Lauren Salzman asked him to remove the trailer after he posted it, and that he replaced a shot containing Nicole before reposting it. He said Raniere apologized and thanked him for making the change.
1 mention
A DVD demarcated Forbes that Franco's attorneys sought in discovery — Anthony Valenziano testified on Day 21 that his firm requested the DVD during discovery in approximately 2007 or 2008.
1 mention
Additional collateral video confession about kissing a female friend and receiving money from the friend's boyfriend — Jay testified that the fourth video was required because her earlier collateral did not cover each required category. She said she submitted the collateral pieces one by one rather than all at once.
1 mention
Allison's sex tape, which Nicole said Allison described as threatened with release by her master — Nicole testified that Allison told her that her master had threatened to release her sex tape unless she changed her behavior. Nicole said she did not then know the master's identity but later learned it was Keith Raniere; Allison did not explain what had prompted the threat.
1 mention
Branding video Agnifilo said he expected jurors would see — In his Day 1 opening statement, Agnifilo said he expected jurors to see a branding video. He asked them to examine whether the women appeared forced rather than treating branding itself as proof of coercion.
1 mention
Collateral video describing childhood molestation by Jay's uncle — Jay testified that one of her collateral videos described being molested by her uncle. She said she gave it to India, either through AirDrop or by text.
1 mention
Documentary arguing that taxes were unconstitutional — James Loperfido testified that he showed a documentary at V Week presenting an argument that taxes were unconstitutional. He said he considered its message one-sided and was not allowed to address the audience afterward.
1 mention
Documentary film project and footage supplied by Vicente — Vicente testified that he began documenting himself in June 2017 and that the documentary idea arose later that year. He acknowledged payment in 2018 for materials and footage, which he believed came from Noujaim Films, but denied being paid to appear in the film.
1 mention
Documentary film Vicente made in Mexico — Vicente testified that higher-ranking members criticized his Mexico documentary for not giving Raniere enough prominence. He said Raniere suggested Vicente appear in the film, after which others accused him of elevating himself over Raniere.
1 mention
Documentary mentioned by Souki — Nicole's Day 20 cross-examination included discussion of a documentary identified as one Souki had mentioned.
1 mention
Documentary shown at V Week, tentatively identified as "America, Freedom to Fascism" — The V Week documentary was tentatively identified as America, Freedom to Fascism. During cross-examination, Loperfido acknowledged obtaining and projecting the film but denied knowing its subject beforehand and said he obtained it at Russell's request.
1 mention
Film depicting the decapitation and dismemberment of women in Mexico, described in the prosecution's sidebar proffer — The prosecution's sidebar proffer described a film depicting the decapitation and dismemberment of women in Mexico and anticipated testimony that Vicente supplied it. The description was not Vicente's testimony, and the issue was deferred and then not pursued at that time without a final admissibility ruling.
1 mention
Film project documenting the movement in Mexico — During Vicente's Day 6 cross-examination, the court permitted reasonable inquiry into the Mexico film project and Raniere's relationship to its making. The court did not permit a broad discussion of the underlying program beyond direct examination.
1 mention
Government Exhibit 1003 — The video was discussed in connection with the development of Jness training material. It was played after the court arranged IT assistance for an audio problem.
1 mention
Government Exhibit 1004 and 1005 — The Jness disposition recordings were presented on CD during Sylvie's testimony.
1 mention
Government Exhibit 1104 — Jelonek confirmed that the clip showed a board listing foods and calorie counts and said she recognized a depicted person from newspaper photographs.
1 mention
Government Exhibit 1105 — Jelonek identified her boyfriend, Lonnie, in the clip and testified that the shades and curtains had been drawn when she entered. She explained that he was trying to bring light into the darkened premises.
1 mention
Government Exhibit 1107 — During playback, Jelonek confirmed that a stepstool stood at the end of the closet.
1 mention
Government Exhibit 175A — Mark Vicente described the six segments as unedited camera footage in which he appeared. The court admitted Exhibit 175A without objection, and the video was played during his direct testimony on Day 4.
1 mention
Government Exhibit 175B — Mark Vicente described the six segments as unedited camera footage in which he appeared. The court admitted Exhibit 175B without objection, and the video was played during his direct testimony on Day 4.
1 mention
Government Exhibit 175C — Mark Vicente described the six segments as unedited camera footage in which he appeared. The court admitted Exhibit 175C without objection, and the video was played during his direct testimony on Day 4.
1 mention
Government Exhibit 175D — Mark Vicente described the six segments as unedited camera footage in which he appeared. The court admitted Exhibit 175D without objection, and the video was played during his direct testimony on Day 4.
1 mention
Government Exhibit 175E — The video belonged to a six-part set that Vicente described as unedited camera footage, which the court admitted without objection.
1 mention
Government Exhibit 175F — The video concluded a six-part set of unedited camera footage admitted without objection during Vicente's direct examination.
1 mention
HBO documentary film about NXIVM — On redirect, Vicente said he hoped the HBO documentary would give people dignity after leaving NXIVM. He expressed concern about press coverage associating his name and those of women with the phrase sex cult.
1 mention
HBO project — Vicente connected a trip to Vermont with a film crew to the project that became the HBO project. He said an earlier possibility of creative involvement had changed and that he had no input into whether the filmmakers included him.
1 mention
Intensive tapes from which material was extracted for a legal case — Vicente identified a project involving extraction of material from intensive tapes and acknowledged knowing that litigation was underway. He said he had been told the case endangered the patent and described his later understanding that the tapes were intended for discovery.
1 mention
Intensive videotapes Vicente said were edited, degraded, and physically aged for a legal matter — Vicente testified that Raniere asked in June 2008 whether material could be removed from videotapes without appearing deliberately removed. Vicente acknowledged agreeing to the alterations and designing the process, and said he understood the tapes concerned a legal matter that threatened the patent.
1 mention
Jness video viewed earlier that day — Sylvie's Day 2 cross-examination included discussion of the Jness video identified as having been viewed earlier that day.
1 mention
Landlord's video of 120 Victory Way — During closing argument, Penza referred to a video the landlord took of 120 Victory Way. She discussed it alongside an apartment photograph while arguing that a camera had been pointed at Nicole during the encounter she described.
1 mention
My Tourette's — Vicente's Day 7 cross-examination included discussion of the film titled My Tourette's.
1 mention
Nicole's original video — An email displayed as Government Exhibit 664 included Nicole's request that Allison securely return her initial and hard-copy collateral, including her original video. Nicole wrote that she wanted to withdraw peacefully and move forward with her life.
1 mention
One video Fontanelli had viewed of Mr. Raniere sitting at a table — Fontanelli recalled a video showing Raniere seated at a table and explained that a pillar and distinctive power outlet helped him recognize the chair's location. He did not recall the other occupants or whether the video concerned Jness.
1 mention
Recording of the first SOP Complete training used as a template — Vicente described the first SOP Complete training as the template for later sessions. His testimony addressed a six-day format involving group discipline and physical consequences.
1 mention
Recordings of Salzman's branding and her recruits' branding ceremonies, discussed but not played — Salzman testified that Loreta filmed her branding and that each of her recruits' branding ceremonies was also filmed. She was uncertain who filmed Jimena's ceremony and said filming later stopped using her phone.
1 mention
Recordings of the women's branding procedures — Nicole confirmed that each woman's branding was taped while describing the required request for branding and the women's positioning on a massage table.
1 mention
Sara's branding videotape, left on a hard drive in Mexico — Salzman said she left Sara's branding recording on a hard drive in Mexico, while expressing uncertainty about the whereabouts of other branding recordings.
1 mention
Sarah Edmondson's video statement — Edmondson appeared by video at sentencing and described attempts to blackmail and enslave her. She also said she had the brand removed through plastic surgery.
1 mention
Sarah's branding video, edited by Salzman and Nicki to remove obedience commitments while retaining the request to be branded — Salzman testified that she and Nicki edited Sarah's branding video around September 2017 at Raniere's instruction. They removed commitments involving labor, possessions, and bodily obedience while retaining the prescribed request to be branded.
1 mention
Sarah's edited branding video — Salzman confirmed that dialogue had been cut from Sarah's branding video but that the request to be branded as a lifelong honor remained.
1 mention
Sex tape of Jay and her then-boyfriend submitted as collateral — Jay testified that she submitted a sex video involving herself and her then-boyfriend as additional collateral. She said the videos were sent to India by AirDrop or text message.
1 mention
Sexually explicit video of Nicole alone, prepared as collateral — Nicole confirmed that she alone appeared in the sexually explicit video prepared as collateral. She said making it felt freeing under her belief that nobody would ever see it, while preparing the letters was much harder.
1 mention
SOP Complete videos Vicente described making to embarrass participants — Vicente recalled making videos intended to embarrass participants and expressed shame about enforcing practices he later regarded as misogynistic.
1 mention
Staged video making Val appear to use cocaine, using sugar or flour — Jay testified that she helped stage a video using sugar or flour to make Val appear to use cocaine. She identified it as collateral Val provided and said she forwarded the video to India.
1 mention
Staged videos Salzman filmed of Sarah making false statements about family relationships and abuse, designed to appear candid — Salzman testified that she filmed Sarah making false statements about family relationships and abuse. They staged the recordings to appear candid because Salzman believed that presentation would make the statements more believable if released.
1 mention
The Mission, used as an example of healing an ethical breach — The film came up during Daniela's direct examination on Day 14.
1 mention
The movie in Vermont — Vicente acknowledged traveling with a film crew to Vermont specifically to seek access to a film screening. The questioning distinguished that movie from the project subsequently discussed as an HBO project.
1 mention
The Source videos featuring Mr. Raniere — Nicole testified that The Source classes discussed videos featuring Raniere. She said Allison Mack frequently referred to his contributions and called him Mr. Raniere.
1 mention
Tourette's film — Prosecutors objected to discussion of the film's Tourette's subject matter as irrelevant and beyond direct examination. They distinguished those objections from questions about Vicente's attempts to contact a filmmaker.
1 mention
Tourettes video — Vicente confirmed that his Vermont trip concerned the Tourette's video. The court sustained an objection when counsel asked him to describe that connection further.
1 mention
V Week promotional video from which Salzman asked Mark to remove Nicole to avoid revealing her community connection to Robbie — Salzman described asking Mark to remove Nicole from a promotional video because she feared discovery could put Nicole at risk.
1 mention
Vicente's Mexican documentary, identified as Encender EL Cocorazon — Vicente testified that Clare Bronfman and executive board members accused him of minimizing Raniere while editing his Mexican documentary. He said they pressured him over several years to give Raniere greater prominence in the film.
1 mention
Video Daniela said Raniere made using a camera facing the refrigerator to record Marianna eating a pie, then showed to Marianna. — Daniela testified that Raniere placed a camera facing the refrigerator and recorded Marianna eating a pie. She said he showed Marianna the video after she denied eating it.
1 mention
Video from three days of meetings that Susan Dones said contained Raniere stating he had people killed for his beliefs — Dones said she possessed video from three days of meetings in which Raniere stated that he had had people killed for his beliefs. She described being afraid of that statement.
1 mention
Video of a man having a design branded on his head — Nicole testified that she watched footage of swirling designs being branded onto a man's head while Danielle was learning to use a cauterizing pen. She could not recall whether this occurred before or after Danielle's own branding.
1 mention
Video of Sarah's branding ceremony that Weniger said he viewed on Mexico television — Weniger testified that he saw Sarah's branding ceremony on Mexican television during the trial. He said other participants' faces were blurred but Sarah's face was not.
1 mention
Video of the January 9, 2018 community meeting — The recording was discussed during Lauren Salzman's cross-examination on Day 11.
1 mention
video recordings allegedly altered for use in NXIVM Corp., et al Versus Ross Institute, et al — The Day 27 jury instructions described an allegation that Raniere conspired with others to corruptly alter or conceal video recordings intended for use in NXIVM Corp. versus Ross Institute. The alleged purpose was to impair the recordings' integrity or availability in that civil litigation.
1 mention
Video reviewed by Fontanelli showing the defendant seated at a table in Nancy Salzman's residence — During a photographic walk-through of Nancy Salzman's residence, Fontanelli identified a table in a sitting room behind the kitchen. He said the video he reviewed showed Raniere seated there with a pillar behind him.
1 mention
Videos of DOS branding ceremonies — Lauren Salzman confirmed that DOS branding ceremonies were videotaped and explained that recordings of the naked ceremonies could serve as collateral.
1 mention
Videos of personal secrets Jay supplied as monthly collateral — Jay testified that she provided videos revealing personal secrets as monthly collateral, initially to India and later directly through Dropbox. She said the monthly requirement had not been disclosed before she joined and would have changed her decision to join.
1 mention
Videotapes allegedly altered for production in federal litigation — During rebuttal argument, Lesko contended that videotapes had been altered and produced in federal discovery. He cited Vicente's testimony and a project memo to argue that Vicente knew the work involved litigation, although he learned later that it concerned the Franco lawsuit.
1 mention
Videotapes discussed in the alleged alteration and discovery scheme — In closing argument, Agnifilo emphasized Vicente's uncertainty about whether the altered tapes were those produced in discovery. He also argued that Vicente learned the specific litigation connection later from Kristin Keeffe and that some project references concerned digitization rather than alteration.
1 mention
Videotapes of 16-day Intensives that the Government was seeking to admit — During Day 3 voir dire, Vicente described cuts during ongoing speech rather than normal breaks between teaching topics. He believed the recordings were 16-day Intensive tapes but could not recall their year or say with absolute certainty which tapes had been altered.
1 mention
Videotapes of the 16-day intensive associated with the legal project — During Day 6 cross-examination, Vicente did not recall Raniere specifically saying that the tapes would be produced in litigation. He attributed his understanding of their discovery use to Keeffe in 2017 and additional reading he could not identify; that qualification did not withdraw his account of alteration.
1 mention
Videotapes of the other women's brandings — During Day 11 cross-examination, Lauren Salzman said she did not know whether the other women's branding videotapes remained in New York or had gone to Mexico.
1 mention
Videotapes produced in discovery in a federal lawsuit that the court said Mr. Raniere worked to alter — At sentencing, the court stated that Raniere had worked to alter videotapes produced in discovery in a federal lawsuit. The court described that conduct as an instance of his repeated obstruction of justice and disregard for the rule of law.
1 mention

Audio Evidence (24)

Government Exhibit 1002 — The recording captured an October 29, 2012 SOP meeting and was admitted and played in part during Mark Vicente's Day 6 testimony. The court received Government Exhibit 1002A on Day 7 as its replacement, following discussion of an agreed excerpts-only CD.
3 mentions
Government Exhibit 494 — The DOS recording was played during Lauren Salzman's Day 10 direct examination, with a corresponding transcript received as an aid and the recording controlling. During Day 26 closing argument, Penza played a passage and characterized the defendant's discussion of executing collateral as referring to its release.
3 mentions
Government Exhibit 495 — Playback of the DOS recording began during Lauren Salzman's Day 10 direct examination and resumed on Day 11. Counsel directed attention to the accompanying transcript, 495-T, which was received as an aid subject to the instruction that the recording controlled.
3 mentions
Government Exhibit 496 — Salzman identified June 12, 2016 as the date stated on the recording. She identified Nicki Clyne as suggesting an invitation to play a game and confirmed that it was the same game she had described in her testimony.
3 mentions
Government Exhibit 497 — Salzman identified Allison Mack and Keith as the voices discussing the branding ceremony when the recording was played on Day 11. She testified that the recording stated January 9 but that she was unsure of the year.
3 mentions
2012 SOP recording discussed by the defense as evidence of DOS's origins — During rebuttal argument on Day 27, Lesko described the 2012 SOP recording as addressing money pledged against recruitment commitments. He disputed the defense's reliance on that tape to explain DOS and contrasted it with Raniere's messages to Camila.
1 mention
Audio Bouchey said contained Raniere's account of her departure and an accusation that she tried to extort $2 million — During her sentencing statement, Barbara Bouchey said she had heard audio in which Raniere explained her departure and accused her of trying to extort $2 million. She disputed that account and described the money dispute as involving repayment of losses she attributed to his commodities trading.
1 mention
Audio recording of the defendant's conversation with Adriana concerning Daniela — In rebuttal argument on Day 27, Lesko recalled an audiotaped conversation between Raniere and Adriana, Daniela's mother. He characterized the conversation as an effort to secure Adriana's agreement to placing Daniela in the room.
1 mention
audio recordings received in evidence — During the Day 27 jury instructions, the court distinguished admitted audio recordings from accompanying transcripts. The court instructed that the transcripts were listening aids, not evidence, and that jurors' hearing of the recordings controlled any discrepancy.
1 mention
Audiotapes whose origins defense counsel proposed addressing through a stipulation — During procedural discussion on Day 10, Agnifilo said counsel expected to resolve questions about the audiotapes' origins through a stipulation to be read to the jury. No completed stipulation was presented during that discussion.
1 mention
Four recordings the government proposed introducing, described as conversations between the defendant and the first line of DOS before Ms. Salzman joined — Hajjar described four recordings of conversations between Raniere and first-line DOS members that predated Lauren Salzman's membership. Agnifilo questioned authentication through Salzman because she had not attended the conversations, while Hajjar proposed voice identification and possible testimony from a recovering agent. The court left admissibility unresolved during the Day 9 discussion.
1 mention
Government Exhibit 910 — The court admitted the recording without objection and instructed that the recording itself, rather than transcript Exhibit 910-T, was evidence.
1 mention
Ivy Nevares's audio statement — Ivy Nevares delivered her sentencing statement by audio transmission. She described alleged manipulation, restrictive eating demands, shunning, and exploitation during her personal and professional relationship with Raniere.
1 mention
Possible recording of a May 7, 2017 call with Keith Raniere — Mark Vicente's Day 7 cross-examination addressed a possible recording of a May 7, 2017 call with Keith Raniere. The court sustained questions characterizing recording as illegal or asking about California recording law; it made no finding of illegality.
1 mention
Previously played SOP audiotape involving Vicente, the defendant, and others — During redirect examination on Day 7, Mark Vicente clarified that collateral discussed on the SOP tape meant money forfeited if a promised action was not completed. He also confirmed hearing Raniere claim absolute say over SOP and testified that Raniere did have that authority.
1 mention
Recorded telephone call that Agnifilo said the government quoted without its full context — At sentencing, Agnifilo disputed the government's presentation of a recorded telephone remark about the judge being watched. He said the fuller statement referred to someone wise and Alan Dershowitz; the call was discussed rather than played, and no placement decision was stated.
1 mention
Recording discussed as describing the branding ceremony — After playback during closing argument on Day 26, Penza described recorded instructions for nudity, videotaping, positioning, and a prescribed request for branding. She argued that the ceremonies followed those instructions and that the request was intended to avoid an appearance of force.
1 mention
Recording the prosecution said captured Raniere describing how a DOS member should be held during branding — In her opening statement on Day 1, Hajjar said jurors would hear Raniere describe a DOS member being branded while nude and held at a table like a sacrifice. Her description previewed proposed evidence rather than documenting its admission or playback.
1 mention
Recordings Nicole was assigned to transcribe for Pam Cafritz's memorial — Nicole testified that she and others were assigned to transcribe recordings for Pam Cafritz's memorial. She estimated that her transcription took five or six hours and said Allison's early-morning deadline required her to remain awake for 23 hours straight.
1 mention
Recordings of conversations about creating DOS — During closing argument on Day 26, Agnifilo described recordings of Raniere discussing DOS's creation with several women. He acknowledged that Raniere's concepts shaped the group deeply, while arguing that the conversations also showed him asking the women to develop their own ideas.
1 mention
Recordings of Pam transcribed for her memorial — Nicole testified that Allison assigned her to transcribe recordings of Pam speaking about life for the memorial. She did not recall thinking about payment and said her frustration concerned the short deadline, staying awake for 23 hours, and the work's use as a DOS assignment.
1 mention
Recordings of the defendant discussing DOS and branding procedures — Lesko described recordings in which the defendant discussed women's positioning during branding and having them request the brand before it was applied.
1 mention
Tapes about the creation and intended scope of DOS — Agnifilo cited recorded discussions of DOS's creation and intended expansion into a larger women's organization. He argued that the tapes did not suggest a money-making purpose.
1 mention
The October 29, 2012 SOP meeting recording — Agnifilo described an SOP meeting recording in which Raniere discussed commitment and collateral in the context of the men's group.
1 mention

Digital Evidence (221)

Government Exhibit 550 — The directory tree obtained from the hard drive was admitted without objection and displayed to the jury on Day 22. Booth identified the Studies folder as coming from the hard drive and testified that associated Photoshop album files had dates and times matching the image EXIF data. In a separate Day 28 procedural discussion, Penza tentatively identified a glossy photograph of adult Camila with a scar as Exhibit 550 and requested that it be sent to the jury with redaction tape, without defense objection.
7 mentions
Government Exhibit 503 — Mills identified the drive's serial number as WCAS81365334, and the court admitted Government Exhibit 503 without objection on Day 20. Brian Booth testified that a forensic image of the drive was created and analyzed using AD Lab. On cross-examination, Booth could not identify who had accessed its information and said he did not know Raniere or what Raniere knew about the images.
6 mentions
Government Exhibit 524 — Christopher Mills identified Government Exhibit 524 as the card found inside the camera marked Government Exhibit 520, and the court received both exhibits in evidence on Day 20. Brian Booth prepared a report concerning the card's metadata and testified that the card arrived in an unsealed cellophane bag in the box with the camera. On Day 23, Booth agreed that access dates for specified JPEG files appeared to have changed after collection, but he could not identify who accessed the card on September 19, 2018.
5 mentions
Government Exhibit 1527 — The email and attachment compile selected information captured from James Loperfido's computer. Daniela described selecting and organizing key-log excerpts but disclaimed knowledge of printing the exhibit. She called emailing the information to herself a mistake and said such files ordinarily went by USB rather than email.
4 mentions
Government Exhibit 619 — Joseph Waala's email states that 35 requested course tapes had been converted to DVDs and were being produced exactly as kept in the ordinary course. On cross-examination, counsel read another paragraph asserting that a tape had been unintentionally misplaced rather than destroyed; that assertion did not independently establish what happened to it. Valenziano acknowledged that the correspondence predated his involvement in the litigation by five years.
4 mentions
Government Exhibit 1397R — Mark Vicente's June 30, 2008 project memo lists duplication of tapes requested by Keith and aging and weathering of master tapes among its tasks. The memo also discusses new machines and cleaning up the house.
3 mentions
Government Exhibit 1401 — Charles Fontanelli identified the CD as a full, true and correct copy of Google's search-warrant return for the Oakhaven account. During cross-examination, Michael Weniger reviewed a selected March 11, 2009 email from Richard Marier on behalf of Canaprobe to Clare and Kristin concerning searches and invoicing.
3 mentions
Government Exhibit 1515 — Kristin Keeffe's November 3, 2005 email to Daniela contains two email addresses Daniela identified as hacking targets. On cross-examination, Daniela acknowledged Keeffe's target-address email but said Keith had already conveyed the targets to her.
3 mentions
Government Exhibit 1518 — Daniela's November 6, 2005 email sends the defendant keylogging websites and information about the Magic Lantern program. The prosecution described the email as reporting her research into obtaining usernames and passwords to access email accounts.
3 mentions
Government Exhibit 1539 — The November 2008 email chain includes Daniela's email to Keith with an OutlogFile.txt attachment that she identified as raw keylogger output from Marianna's computer. Daniela explained that logs capture individual computer actions, can contain application-generated noise, and do not establish successful account access merely because credentials were typed. The court admitted the exhibit over the defense's preserved objection that disclosure of the private captured content was unnecessary and unduly prejudicial.
3 mentions
Government Exhibit 1554 — The three-page email exchange contains immigration lawyer Jonathan Ware's recommendations concerning Adrian and Camila, including departure for Mexico and applications for dependent status contingent on approval of Hector's petition. The court admitted the exhibit without objection during Daniela's Day 13 testimony. On cross-examination, Daniela acknowledged receiving the forwarded emails and not following up with Ware or her father about her own status.
3 mentions
Government Exhibit 1701 — Camila's email to Raniere counted 30 full moons together. Rees interpreted that interval as approximately two-and-a-half years, reaching back to approximately September 2005; her estimate came from the documents rather than eyewitness knowledge. During procedural discussion, the court questioned how the unanswered message could provide context for Raniere's statements.
3 mentions
Government Exhibit 1779 — The email attaches a text file of WhatsApp chats between Camila and the participant identified as Unknown Caller. Selected passages discussed collateral, lifelong obedience, branding, and finding someone bound by a collateralized lifetime vow. An October 1, 2015 message proposed that Camila recruit and groom someone for Raniere's sexual use.
3 mentions
Government Exhibit 504-B — The exhibit contains only the EXIF data portion of Brian Booth's report, not the complete report. During direct examination, Booth discussed November 2 and November 24, 2005 dates and a camera serial number. On redirect, he agreed that a displayed example showed November 5, 2005; the testimony did not explain the differing date references.
3 mentions
Government Exhibit 560 — Christopher Mills identified the gray or silver LaCie drive beneath a desk or table, and the court admitted it without objection on Day 20. On cross-examination, he could not recall whether the drive had been plugged into anything.
3 mentions
Government Exhibit 657 — The four-page email chain includes Nicole's February 10, 2016 disclosure of suicidal feelings and her later description of feeling better after meeting Allison Mack. Nicole identified that meeting as the first occasion when Mack mentioned collateral. The chain ends on February 13 with Mack offering reassurance and asking whether Nicole had finished her collateral.
3 mentions
Government Exhibit 659 — Government Exhibit 659 contains 11 pages of emails between Nicole and Allison Mack, including journal entries, with exchanges ending June 1, 2016. The court admitted it without objection during Nicole's direct testimony on Day 19. During cross-examination on Day 20, Nicole acknowledged positive journal language about a walk with Keith and explained that learning from an exercise requiring permission to eat did not mean she wanted to continue it indefinitely.
3 mentions
Government Exhibit 1238 — The email exchange concerns Hector's request for permission for the family to write Daniela birthday letters while she was confined to the bedroom.
2 mentions
Government Exhibit 1241 — Salzman's early-morning email to Raniere reported that Daniela had written a letter asking to leave the room and describing her distress.
2 mentions
Government Exhibit 1242 — Raniere's November 9, 2010 email suggested that Salzman ask Daniela about the difference between spending one day in the room and remaining there as long as she had.
2 mentions
Government Exhibit 1325 — Junco's October 4, 2015 email expressed concern that her feelings were keeping her daughter from Raniere and stated that she wanted him for both her daughter and herself. Raniere forwarded the message to a ProtonMail account on November 25, 2017. The court formally admitted the exhibit without objection on Day 23 after it had been read.
2 mentions
Government Exhibit 1353 — The exhibit contains messages exchanged while Daniela was being driven to the Mexican border. The court admitted it without objection on Day 2.
2 mentions
Government Exhibit 1399 — Fontanelli identified the exhibit on Day 7 as the full account copy provided pursuant to a search warrant. Selected emails were later examined during testimony about efforts to obtain purported banking information; Weniger questioned that information's accuracy.
2 mentions
Government Exhibit 1456 — Clare Bronfman's November 9, 2005 email told Raniere that she had been emotional during the previous night's strategy-team meeting regarding her father.
2 mentions
Government Exhibit 1504 — Daniela identified the attachments as systems-theory book outlines reflecting her progress, including unfinished work. During cross-examination, she explained that emails to herself preserved updated drafts.
2 mentions
Government Exhibit 1516 — Daniela identified a self-addressed email associated with password research and discussed testing code embedded in an image during cross-examination on Day 15.
2 mentions
Government Exhibit 1579 — The February 29, 2012 email chain contains a proposed family message demanding book reports, email-account information and Daniela's return to Clifton Park while refusing her requested documents. Lauren Salzman testified that Kristin Keeffe drafted the message, Salzman and Raniere reviewed it, and Daniela's father ultimately sent it for the family. The court admitted the exhibit during Salzman's testimony.
2 mentions
Government Exhibit 1588-B — Daniel O'Donnell described the exhibit as Google Play application-download records for an Android or Android-compatible device associated with the Gmail account. On cross-examination, he identified a Signal Private Messenger entry but qualified his understanding of it as a secure messaging application.
2 mentions
Government Exhibit 1588-R — O'Donnell explained that the redacted subscriber records contain information entered by the user when creating or maintaining the account. Maegan Rees later read the listed name as Camila and the email address as her Gmail account.
2 mentions
Government Exhibit 1591 — Daniela identified the exhibit as an early November 2008 email chain between herself and Raniere. In rebuttal closing, Lesko highlighted Raniere's requests for keylogging material and an overview of Facebook information Daniela had sent.
2 mentions
Government Exhibit 1806 — The court admitted Government Exhibit 1806 on Day 23. In closing argument, Penza included it among photograph exhibits she described as DOS collateral and argued were sexually gratifying to Raniere and damaging to the women if released.
2 mentions
Government Exhibit 1807 — The court received Government Exhibit 1807 as part of a group of government exhibits after defense counsel confirmed that the list was consistent with counsel's understanding.
2 mentions
Government Exhibit 1809 — The court received Government Exhibit 1809 as part of a group of government exhibits after defense counsel confirmed that the list was consistent with counsel's understanding.
2 mentions
Government Exhibit 1810 — The court received Government Exhibit 1810 as part of a group of government exhibits after defense counsel confirmed that the list was consistent with counsel's understanding.
2 mentions
Government Exhibit 1811 — The court received Government Exhibit 1811 as part of a group of government exhibits after defense counsel confirmed that the list was consistent with counsel's understanding.
2 mentions
Government Exhibit 1812 — The court received Government Exhibit 1812 as part of a group of government exhibits after defense counsel confirmed that the list was consistent with counsel's understanding.
2 mentions
Government Exhibit 1814 — The court received Government Exhibit 1814 as part of a group of government exhibits after defense counsel confirmed that the list was consistent with counsel's understanding.
2 mentions
Government Exhibit 1819 — Michael Weniger examined selected exchanges between Raniere and Kristin Keeffe from the period when Daniela was transported back to Mexico after her confinement. He explained the backup's incoming and outgoing message codes and said he had not reviewed every page of its approximately 2,000-page attachment.
2 mentions
Government Exhibit 301-R — The attached messages address sexual demands, weight targets, bulimia, housing and a vow of complete obedience. Camila's messages express fear and dependency and dispute Raniere's account of helping her. Rees also examined Raniere's description of their years together, which did not establish a legal marriage.
2 mentions
Government Exhibit 302R — Rees described recurring requests from Raniere for Camila's daily schedule and messages questioning changes to her hair. A separate exchange cited in closing included Raniere saying that he retained photographs from earlier in their relationship.
2 mentions
Government Exhibit 310-R — The August 6, 2016 cover email attaches WhatsApp messages, including an October 11, 2015 exchange about having children. Later messages describe Camila's search for a virgin successor and Raniere's demands that she find one. Rees said she had not reviewed messages extending beyond the late-2015 period under discussion.
2 mentions
Government Exhibit 357 — Lauren Salzman identified the Excel spreadsheet as a list of everyone enrolled in DOS when it was made. She testified that Rosa Laura tracked enrollment and Loreta helped put it into Excel in a shared Dropbox folder. The court received Exhibit 357 and its redacted version, Exhibit 357R, into evidence.
2 mentions
Government Exhibit 361 — Sheila Jelonek read telephone numbers from entries 604 and 273 that matched numbers in her rental-related information. The email address she read from Exhibit 361 differed in spelling from the address she gave after refreshing her memory, although the telephone numbers matched.
2 mentions
Government Exhibit 432 — The Telegram screenshots contain exchanges between Lauren Salzman and Audrey about work and rank. In closing argument, Penza described messages requiring work commensurate with Audrey's professional skills and invoking Salzman's high rank in ESP.
2 mentions
Government Exhibit 432R — Lauren Salzman's direct testimony on Day 9 and cross-examination on Day 11 addressed the chats. Exhibit 432R identifies the version of the Telegram screenshots with names redacted.
2 mentions
Government Exhibit 505 — Brian Booth identified the disc as an AD Lab report he created from bookmarked material in the Studies folder, with Exhibit 505-A serving as its paper printout. During his testimony, the digital report was opened to navigate files and examine photograph metadata, including metadata corresponding to Exhibit 508-E.
2 mentions
Government Exhibit 521 — The disc report contains images, files, and associated metadata from a camera media card. During cross-examination, Brian Booth reviewed its entry for JPEG 224 and confirmed a file-system modification date of March 9, 2006, and an access date of September 19, 2018.
2 mentions
Government Exhibit 650 — The screenshot shows Mack directing Nicole to keep contacting Keith until he responded as the next stage of her assignment. The court admitted and published the exhibit on Day 18. Nicole later explained that its thumbs-down reaction was added accidentally while she was retrieving the message to show the FBI, not when she received it.
2 mentions
Government Exhibit 658 — Nicole identified the forwarded Word attachment as her transcription of recordings for Pam Unplugged and estimated that the work took five to six hours. In closing argument, Penza noted that Nicole's accompanying message reported about five and a half hours spent on the first part.
2 mentions
Government Exhibit 669 — The biography claimed that Raniere took extensive graduate-level mathematics and physics courses and earned multiple degrees and minors. The prosecution compared those claims with transcript entries reflecting academic difficulties and a final 2.26 GPA. Weniger acknowledged apparent higher-level courses, and the comparison did not establish that every biographical claim was false.
2 mentions
1-B-16 — Booth identified 1-B-16 as the hard drive containing the Studies folder. He said he saw no attempted manipulation on the drive and no changes in the examined images' access, modification or creation dates as of its arrival at the FBI.
1 mention
1160 — The screenshot and associated metadata were referenced during Maegan Rees's resumed direct testimony on Day 17.
1 mention
1191 — Rees read creation dates of May 30 and May 31, 2016 from Exhibit 1191. She confirmed that the metadata concerned two images other than the pregnancy-test and ultrasound photographs discussed earlier.
1 mention
1400-134 — The email exchange requested more personal communication and included an August 29, 2010 response claiming surveillance and proposing use of a walkie-talkie. The court admitted Exhibit 1400-134 without objection, and Rees read it during her testimony.
1 mention
1400-151 — The messages include a complaint about infrequent writing, references to restraint with rope, and a correspondent's statement that efforts to damage their image appeared to be increasing.
1 mention
1400-197 — A March 1, 2011 message describes hunger, difficulty losing weight despite the recipient's stated expectations, and unsuccessful attempts to make contact; an April 16 message asks the recipient to open an attachment when alone.
1 mention
1400-202 — The court admitted the responsive email over defense objection during Maegan Rees's resumed direct testimony on Day 17.
1 mention
1400-23 — The court admitted the emails without objection, and Maegan Rees confirmed their sexual language about lollipops and obedient slaves during resumed direct testimony on Day 17.
1 mention
1400-25 — A March 5, 2009 message complains about screened calls; the next day's response gives reasons for not answering, uses slave terminology and describes an email-signature signal.
1 mention
1400-30 — One message reports that others believed the writer was still a virgin, and the March 8, 2009 response alludes to sexual experience the respondent could offer.
1 mention
1400-4 — The writer said permission apparently was needed for a haircut and asked for an answer to begin planning, while noting that the haircut was not yet affordable.
1 mention
1400-45 — A March 19, 2009 forwarded email questioned why another woman had retained text identifying the original sender and asked whether the recipient was withholding information or lying.
1 mention
1400-6 — A February 24, 2009 message sent within the same email account instructed the recipient to lose weight before cutting their hair, promised a reward, and deferred discussion of the relationship's potential and a liability issue to an in-person conversation.
1 mention
1400-62 — The court admitted the email chain over defense objections.
1 mention
1400-65 — The June 20, 2009 exchange used the same email address for sender and recipient and combined expressions of gratitude and support with sexual language, references to pinning and spanking, and master-slave terms.
1 mention
1400-99 — A March 20, 2010 email signed C expressed uncertainty about the relationship, complained of inconsistent communication, and sought a more equal partnership. A response rejected the writer's assessment.
1 mention
1700 series — The emails involved Lauren Salzman and members of Cami's family, including exchanges between Cami and Lauren. On Day 17, the court allowed the challenged emails following the government's co-conspirator-statement argument despite the defense's objection that Lauren had already left the stand.
1 mention
1753 — The email attaches a WhatsApp chat with an unknown caller. A March 12 passage attributed to Keith Raniere describes a spiritual successor and claims that interruption of that succession could shorten his life.
1 mention
1754 — Rees identified the attachment as additional WhatsApp messages between Camila and Robbie Chiappone and agreed that they resembled messages already reviewed.
1 mention
1767 — The text declares Camila's resignation from Rainbow Cultural Garden, relinquishes future positions and benefits, and directs money owed to her to Keith Raniere or his designee. Rees read it during questioning about emails relating to Camila's collateral.
1 mention
1775 — The email was sent August 9, 2015, and contains a letter dated August 8 addressed to Loreta Garza Davila. The letter states that personal issues require Camila's immediate departure from Rainbow Cultural Garden and permanent withdrawal from relationships with children and families under her care.
1 mention
1776 — The August 10, 2015 email names Daniela Padilla as executor of consequences for breaching a vow of love, loyalty and obedience to Keith Raniere. Its terms include delivery of a resignation letter, claims on Camila's property and assets totaling $1 million; Rees confirmed that the witness lines were blank.
1 mention
1777 — The August 18, 2015 email authorizes Daniela Padilla to distribute enclosed family-related text through Facebook or email if Camila breaches her vow. Rees also identified account information within the email.
1 mention
1784 — Rees confirmed that Camila and Keith Raniere exchanged many iterations of the letter by email. The displayed draft describes unwanted sexual contact and states an intention to avoid future interaction unless necessary.
1 mention
225 — The September 1, 2016 WhatsApp material includes a nude image repeated across pages and positive V Week messages. During Sylvie's Day 2 cross-examination, counsel used the WhatsApp materials for identification without offering them into evidence, and intimate-image display was restricted from jurors and the public.
1 mention
227 — The March 16, 2017 message thanks Grandmaster for helping Sylvie face fear and was identified during her Day 2 cross-examination.
1 mention
231 — The June 21, 2016 WhatsApp message includes a nude photograph and a request to spend time together. Counsel used the WhatsApp materials for identification without offering them into evidence, with intimate images withheld from jurors and the public.
1 mention
233 — The March 27 and 29, 2017 messages concern training, Knife work and offers of support, and were identified during Sylvie's Day 2 cross-examination.
1 mention
234 — The March 31, 2017 WhatsApp exchange concerns Ana Gaby's resistance to an instruction and includes messages attributed to her. The exchange was identified during Sylvie's Day 2 cross-examination.
1 mention
235 — The June 8, 2017 message expresses support for Grandmaster and mentions a medical appointment. The message was identified during Sylvie's Day 2 cross-examination.
1 mention
236 — The October 12 and 13, 2017 messages discuss medical care, work, Jness and travel wishes. They were identified during Sylvie's Day 2 cross-examination.
1 mention
237 — The November 2017 exchange concerns Pammie and discontinuing titles. The court's final ruling excluded Raniere's disputed statement as irrelevant while allowing questioning about Sylvie's response.
1 mention
238 — The messages dated November 26 through 29 and December 25, 2017 include unanswered check-ins and a Christmas exchange. They were identified during Sylvie's Day 2 cross-examination.
1 mention
275 pages of WhatsApp materials and phone printouts, including nude photographs, proposed by the defense for cross-examination — Agnifilo proposed using phone printouts to question Sylvie about photographs and claimed inconsistencies without necessarily offering the photographs themselves. Penza raised access, authentication, hearsay, and piecemeal-use objections, and the court required preliminary questions before document use. The court also said it would hold a hearing after trial; it made no obstruction finding in that discussion.
1 mention
307-R — The passages read from pages 15 and 16 discuss working with Nancy and discomfort about discussing the relationship. One participant describes the relationship as an extraordinary bond and speculates about how Nancy recognized it.
1 mention
308-R — Rees identified the exhibit as an email from Camila to herself attaching a WhatsApp chat with an unknown caller. Passages attributed to Keith Raniere request a lifelong vow of honesty, obedience and surrender, followed by extreme collateral and levels of punishment; Camila's responses include resistance and repetition of the requested vow.
1 mention
Allison Mack's e-mails, which the government anticipated the defense might seek to introduce — Penza anticipated hearsay objections if the defense sought to introduce Allison Mack's emails during Nicole's cross-examination. She requested advance review of defense materials to help address anticipated objections.
1 mention
Brain-study recordings and measurements collected during intensives — Mark Vicente's direct testimony on Day 3 addressed materials identified as brain-study recordings and measurements collected during intensives.
1 mention
Camila chats — During closing argument, Agnifilo characterized the chats as lengthy, intense communications between Camila and Keith. He argued that they showed emotional connection and Camila's willingness to push back, while emphasizing that she had not testified about her own experience.
1 mention
Carved JPEG on page 325 of the report, recovered from TN.4/cache beneath L102805 on the 1B16 drive — The image was identified as a carved JPEG recovered from the TN.4/cache directory beneath L102805 on the 1B16 drive.
1 mention
Chats between Keith and Cami reviewed in discovery — Lauren Salzman's cross-examination on Day 11 addressed chats between Keith and Cami identified as having been reviewed in discovery.
1 mention
Chats between Lauren and Audrey about Audrey leaving — In closing argument, Agnifilo described chats in which Lauren recognized that Audrey wanted to leave and recalled affectionate final exchanges. He relied on that account to challenge the government's extortion theory.
1 mention
Chats between Sylvie and Keith — Agnifilo referred to the written exchanges while discussing Sylvie's testimony about her sexual encounter with Keith.
1 mention
Collateral copied from Dropbox, including the four pictures referenced from direct examination and additional material — Jay testified that taking screenshots was her idea and that she copied whatever collateral was available during the time she had access to Dropbox. She said she intended to protect herself against possible use of her own collateral, not to display other people's material.
1 mention
Communications from Camila's Gmail account, which the government said were obtained by search warrant and were not challenged by the defense — Hajjar said the Gmail communications were obtained by search warrant and were not challenged by the defense, contrasting them with disputed communications from another account attributed to Camila. She argued that Camila's messages provided context for Raniere's responses.
1 mention
Contemporaneous emails and text messages — During closing argument, Agnifilo urged jurors to trust emails and texts written at the time of the events as expressions of participants' feelings then. He contrasted those communications with what he characterized as later changes in perspective.
1 mention
Data and information Agnifilo said supported his allegation of changes to NXIVM computer files from Vancouver — Agnifilo said he had data supporting his allegation that people accessing NXIVM's computer from Vancouver changed files to prevent credit-card billing. He offered that allegation as an explanation for seeking a computer-tampering investigation and acknowledged that no charges were brought.
1 mention
Defendant's biography on the NXIVM website, which the government said it would offer without objection — Penza said the biography praised Raniere for three RPI degrees and graduate-level mathematics and physics coursework. She stated that the government would introduce the biography without objection.
1 mention
Defense Exhibit 221 — The July 29, 2016 WhatsApp message includes a nude photograph and a request to meet. Counsel used the WhatsApp materials for identification during Sylvie's Day 2 cross-examination without offering them into evidence, and intimate images were withheld from jurors and the public.
1 mention
Defense Exhibit 222 — The August 3 and 4, 2016 WhatsApp messages include two nude images and requests to meet. Counsel used the WhatsApp materials for identification without offering them into evidence, with intimate-image display restricted from jurors and the public.
1 mention
Defense Exhibit 223 — The WhatsApp exchange discusses meeting, Rachel and being Keith's slave. During Sylvie's Day 2 cross-examination, counsel traced preceding pages to August 5, 2016, and used the exchange for identification only.
1 mention
Defense Exhibit 224 — The August 9 and 10, 2016 WhatsApp messages include two nude photographs. Counsel used the WhatsApp materials for identification without offering them into evidence, and intimate images were withheld from jurors and the public.
1 mention
Defense Exhibit 226 — The February 19 and 20, 2017 messages discuss Rosa Laura, John, fear and anxiety. They were identified during Sylvie's Day 2 cross-examination.
1 mention
Defense Exhibit 230 — The June 16, 2016 WhatsApp messages concern meeting Keith and Sylvie's relationship with John. Counsel questioned Sylvie about the WhatsApp materials on Day 2 without offering them into evidence.
1 mention
Defense Exhibit 232 — The November 25 and 27, 2016 messages discuss family travel, Jness and Pammie. They were identified during Sylvie's Day 2 cross-examination.
1 mention
Defense Exhibit 905 — After reviewing the communication on Day 20, Nicole said it appeared she had told Souki about a lengthy interview, although she did not remember doing so.
1 mention
Defense Exhibit 919 — Nicole reviewed phone-message material during cross-examination on Day 20. She acknowledged having felt that she suppressed her sexuality but described her work with two women as acting exercises involving character development and confidence.
1 mention
Defense Exhibit 922 — The message expressed a desire to have sex with Keith before branding and said it would be trickier afterward. Nicole acknowledged the wording but said she did not know why she had written it and did not remember sending it.
1 mention
Defense Exhibit 927 — Nicole vaguely recalled the Valentine's Day message and explained that she intended humor rather than sexual interest. The court allowed substantive questioning and an attempt to refresh her recollection, but directed counsel not to require her to supply its exact wording.
1 mention
Disc containing communications from Camila's Gmail account, identified by the government as already admitted — Hajjar clarified that the admitted disc contained only Camila's Gmail communications, not the other account's messages that she had not yet offered. The court allowed Camila's statements as necessary context for Raniere's responses, while the defense preserved its written objections.
1 mention
Discovery texts concerning Audrey's statement to Kristin about releasing collateral — The discovery texts were referenced during Lauren Salzman's cross-examination on Day 11.
1 mention
Disk containing the listed Google search-warrant return exhibits; Rees confirmed reviewing it and initialing its cover — Rees testified that she had reviewed the disk and initialed its cover. She confirmed that the listed exhibits contained information Google returned in response to the warrant for Camila's Gmail account.
1 mention
Displayed book-report submission to Karen Unterreiner and Nancy Salzman dated December 13, 2006; no exhibit number was stated in this exchange. — During her direct testimony on Day 12, Daniela confirmed that the displayed submission went to Karen Unterreiner and Nancy Salzman on December 13, 2006.
1 mention
Documents seized from a device to be addressed by upcoming witnesses — The defense requested time to review the documents, and the government proposed presenting them through a later agent. After the recess, the defense agreed not to object on the ground that they had not been retrieved from the device discussed by the intervening witness; that agreement did not establish blanket admissibility.
1 mention
Dropbox collateral — In the e-mail read during her direct testimony, Nicole requested deletion of the Dropbox collateral received during the year. She explained that she wanted to leave the situation and protect herself and her family.
1 mention
E-mails and messages the prosecution said Raniere sent to associates and alleged victims — In opening statement, Hajjar said jurors would see Raniere's e-mails and messages to associates and alleged victims. She specifically previewed messages with Camila about owning a slave for him and branding a slave with his monogram.
1 mention
E-mails and text messages that Agnifilo urged jurors to compare with witnesses' later accounts — In opening statement, Agnifilo urged jurors to compare anticipated testimony with contemporaneous e-mails and text messages. He argued that some participants' perspectives had changed after a split involving Mark Vicente.
1 mention
E-mails between Keith and Clare discussed by Agnifilo as trial evidence — During sentencing argument on Day 29, Agnifilo cited e-mails between Keith and Clare as reflecting a belief that others were trying to undermine them. He acknowledged that the communications might also reflect paranoia.
1 mention
E-mails between Keith and Kristin discussed by Agnifilo as trial evidence — During sentencing argument on Day 29, Agnifilo cited e-mails between Keith and Kristin as reflecting a belief that others were trying to undermine them. He acknowledged that the communications might also reflect paranoia.
1 mention
Email chain between Nancy Salzman and another woman, offered by the government as an example of alleged enterprise communication practices and challenged by the defense as hearsay — Penza described an e-mail chain containing a woman's statements and Nancy Salzman's responses. The defense objected that the exchange was hearsay, while the government maintained that it offered the chain for its pattern of communication, not its truth.
1 mention
Email exchange about India's assignment and Allison Mack's requested trainer payments — The exchange discussed an assignment for India to pose nude for a photograph and Mack's request for overdue Source trainer payments. During closing argument, Penza highlighted Raniere's response to the payment request with a question about India.
1 mention
Email from Federico Valenzuela Pena to Emiliano Salinas that defense counsel said discussed Rick Ross, the Branch Davidians, and the Waco siege — Agnifilo described the e-mail as discussing Rick Ross, the Branch Davidians, and the Waco siege. He cited it while objecting to wholesale admission of collected materials and requesting individualized evidentiary review.
1 mention
Emails and attached raw keylogger data concerning Marianna's accounts — During closing argument, Penza reviewed e-mails in which Daniela provided Raniere with Marianna's Facebook credentials and attached raw keylogger data. She also discussed correspondence about installing keyloggers on devices Marianna used.
1 mention
Emails involving Daniela's father about her conduct and return to Mexico — Agnifilo discussed e-mails in which Daniela's father expressed frustration and accused her of stealing from him and accessing his Facebook account. He also emphasized that Daniela directed requests for her documents to her father.
1 mention
Emails sent from Camila's Gmail account to Keith Raniere-related addresses — Rees testified that emails sent from Camila's Gmail account to Raniere would have been included in the search-warrant return. She did not know whether messages were recovered from Raniere's email account and confirmed that she had not performed that search.
1 mention
Exhibit 1781 — During Maegan Rees's testimony on Day 17, a highlighted entry on page 39 was read as an October 10, 2015 message giving the address 120 Victory Way. Rees identified the attachment as Spanish-language WhatsApp messages between Camila and Daniela Padilla.
1 mention
Facebook messages in which Sylvie's father raised their linked iCloud access and reported finding photographs — The Facebook messages were referenced during Sylvie's continued direct testimony on Day 1.
1 mention
Facebook page, email address, and alternate phone number for the Sam Suite persona — Nicole testified that Raniere devised the Sam Suite name and instructed her to create a Facebook page, an e-mail address, and an alternate phone number. She said she was initially supposed to give Robbie only the e-mail address.
1 mention
Frank report blog discussed in connection with reporting about DOS — Sylvie's cross-examination on Day 2 included discussion of the blog.
1 mention
Frank Report stories about DOS, including a report about women being hit with paddles — The stories were referenced during Sylvie's direct testimony on Day 2.
1 mention
Government Exhibit 1400 — The government described the Yahoo-account communications as exchanges between Camila and Raniere and argued that their contents and message chains demonstrated authorship. The defense challenged authentication and hearsay and raised due-process concerns about introducing extensive intimate communications without testimony from the correspondent.
1 mention
Government Exhibit 1419 — During rebuttal argument on Day 27, Lesko directed attention to Exhibit 1419 alongside Exhibit 1543 while discussing coded references in emails related to the Edgar Bronfman keylogging allegations.
1 mention
Government Exhibit 1501 — Daniela identified the July 6, 2005 email as notes she typed while Keith discussed website ideas and then sent to herself. She described it as an early example of her work documenting him.
1 mention
Government Exhibit 1503 — Daniela identified the March 23, 2005 spreadsheet as a catalog she created with book titles, authors and other identifying information. She explained that she updated and resent the catalog as more books arrived.
1 mention
Government Exhibit 1505 — Daniela identified the July 2, 2005 document as another version of her library catalog. She explained that she repeatedly updated the spreadsheet and sent it to the defendant as the collection grew.
1 mention
Government Exhibit 1511 — Daniela identified the document during her Day 12 testimony as a book report she submitted to Nancy Salzman on April 24, 2006.
1 mention
Government Exhibit 1516, Government Exhibit 1517 — During closing argument on Day 26, Penza cited the emails as examples of Daniela's November 2005 keylogger research. She described a white-dress JPEG attachment as an image Daniela had identified as a keylogger test.
1 mention
Government Exhibit 1530 — The June 22, 2008 email transmitted recovered conversation history with an XML attachment described as approximately 50 pages of chats. Daniela testified that she recovered chats and sent them to Keith.
1 mention
Government Exhibit 1541 — During rebuttal argument on Day 27, Lesko identified Exhibit 1541 as an email from Clare Bronfman to the defendant discussing her father. He referenced it in his discussion of the Edgar Bronfman keylogging allegations.
1 mention
Government Exhibit 1543 — During rebuttal argument on Day 27, Lesko described Exhibit 1543 as a collection of emails relating to the alleged keylogging of Edgar Bronfman. He also directed attention to coded references to friends in the email discussions.
1 mention
Government Exhibit 1578, 1535, 1534, 1563 and 1603 — During closing argument on Day 26, Penza cited these emails when discussing monitoring of Daniela's program after her kiss with Ben Myers. She described the correspondence as including sexual questioning and threats to send Daniela to Mexico without family contact, identification documents or money.
1 mention
Government Exhibit 1580 — Daniela identified an email sending Keith an answer to a brain teaser and described their exchanges as playful when she was 17 and he was in his forties. The series also included a July 1, 2003 message directing her to use another email address.
1 mention
Government Exhibit 1583 — Daniel O'Donnell identified the first page as Google subscriber information for clarewbronfman@gmail.com, with a recovery address of clare@nxian.net and an apparent creation date of September 8, 2011. The court admitted Exhibit 1583 without defense objection.
1 mention
Government Exhibit 1583-A — Daniel O'Donnell recognized the exhibit when it was shown to him alone on Day 15 and confirmed that it contained data from clarewbronfman@gmail.com. He said he had briefly reviewed its contents and associated account information.
1 mention
Government Exhibit 1587 — O'Donnell identified subscriber information listing Emiliano Salinas and an account creation date of June 12, 2009. The court admitted Government Exhibit 1587 without defense objection.
1 mention
Government Exhibit 1587-A — O'Donnell confirmed that he had reviewed the exhibit and that its contents included data associated with thebeacon2009@gmail.com.
1 mention
Government Exhibit 1588 — The court received Government Exhibit 1588 without objection alongside Exhibits 1588-R, 1588-B and 1588-C.
1 mention
Government Exhibit 1588-A — O'Donnell testified that he had reviewed the exhibit before testifying and that Google kept its records in the regular course of business.
1 mention
Government Exhibit 1588-C — O'Donnell testified that the profile listed the first name Camila and that users provide Google Plus profile information. The court admitted the exhibit without objection.
1 mention
Government Exhibit 1606 — The exhibit was described as a July 22, 2009 disclosure containing screenshots and an MP3 attachment characterized as a recorded live feed.
1 mention
Government Exhibit 1607 — The exhibit was described as a further disclosure of correspondence between Daniela and Ben.
1 mention
Government Exhibit 1743 — The attachment contains dated WhatsApp messages between Camila and a user identified as Robbie Chiappone. Rees testified that the messages indicated a romantic or sexual relationship.
1 mention
Government Exhibit 1744 — Rees described the attachment as hundreds of pages of messages between Camila and Unknown Caller. Selected messages read aloud included references to Vanguard and Keith.
1 mention
Government Exhibit 1779-534 — Penza described messages in which Raniere said Rosa Laura could help Camila find a successor by befriending young candidates and shepherding them over time.
1 mention
Government Exhibit 1782 — Rees described an email chain forwarded from a Yahoo account of Camila's to KeithRaniere@yahoo.com and then to Camila's Gmail account on January 29, 2016. She confirmed that the attachment contained chats between Camila's account and Unknown Caller.
1 mention
Government Exhibit 1825 — Harrington identified materials for a Yahoo account attributed to Camila and a second identifier he tentatively recalled as IMK-1000-A at Yahoo.com. The court admitted the exhibit without objection.
1 mention
Government Exhibit 301 — The excerpts included demands that Camila desire Raniere more than R and lose weight. Rees interpreted the letter B in one exchange as referring to bulimia.
1 mention
Government Exhibit 301, 301-R, 302, 302-R, 305 to 308, 305-R to 308-R, 310, 310-R, 527 to 534, 1145, 1147 to 1158, 1160 to 1162, 1164 to 1166, 1183 to 1191, 1701 to 1737, 1739, 1742 to 1746, 1748 to 1756, 1764, 1767 to 1777, 1779, 1781 to 1782, 1784 and 1789 — Rees testified that she had reviewed the disk and initialed its cover. The court admitted the offered Google-return exhibits without objection and clarified that Exhibits 1112 to 1123 had not been offered and were not admitted.
1 mention
Government Exhibit 446-R — Jay identified her screenshot of India's invitation to upload collateral to the Collateral iTribe Dropbox folder, which said uploads would be taken offline. Jay testified that she was told to submit collateral on the first of the month and that it would be deleted within 24 hours.
1 mention
Government Exhibit 502-A — Mills identified the disk as containing all the search photographs, and the court admitted it without objection.
1 mention
Government Exhibit 504 — The disc contains a report with graphic images redacted, and Government Exhibit 504-A was identified as its hardcopy printout.
1 mention
Government Exhibit 506 — The report concerns bookmarked items from the Western Digital hard drive described as suspected child pornography.
1 mention
Government Exhibit 510 — Daniela's email stated that seven sections were complete but that she had omitted three sections until she could understand and summarize them precisely. She testified that Nancy Salzman required her to submit reports because she had not been completing them as requested.
1 mention
Government Exhibit 728 through 759 — The court admitted the email chains without objection during Richard Guerci's testimony on Day 21. The chains included requests to pay Cafritz's American Express balance that Bronfman forwarded to Raniere for review and approval, including his June 14, 2017 approval.
1 mention
Government Exhibit 734-35 — During closing argument on Day 26, Penza described the June 2017 request and Raniere's response approving payment, seven months after Cafritz's death.
1 mention
Government Exhibit 854 — Welch testified that the order did not ship and was likely canceled because its billing and shipping information did not match. He acknowledged that customers could also cancel orders and that additional information was unavailable after an email-system change.
1 mention
Hard drive marked Skylar containing DOS materials and collateral, left in Mexico with Nicki and not returned to Salzman — Salzman said she had not recovered her hard drive despite requests through counsel. She believed Nicki had left it with Jack.
1 mention
Image selected by Clare Bronfman into which Daniela said she embedded surveillance software for an attempt to access Edgar Bronfman's computer — The image was referenced during Daniela's direct testimony on Day 13.
1 mention
images contained in digital files stored on a Western Digital hard drive — During the Day 27 jury instructions, the indictment was read as alleging possession of images on a Western Digital hard drive between November 2005 and March 2018. The instructions stated that the government alleged the images depicted Camila and required proof of knowing possession and awareness that they portrayed a minor engaged in sexually explicit conduct.
1 mention
IMG_0078 and its associated EXIF metadata and file attributes — Booth favored the October 18, 2005 EXIF date over the differing file-system dates. He did not identify how the image acquired its earlier 2003 creation date.
1 mention
IMG_0208, compared with IMG_0207 for differences in EXIF time and focal length — During his direct testimony on Day 22, Booth explained that the focal-length difference between IMG_0208 and IMG_0207 indicated an adjustment to the camera lens.
1 mention
Jelonek's email to a prosecution colleague about the warranty contact information, shown to refresh her memory — Jelonek testified that she had e-mailed unfamiliar contact information from the furnace warranty to a prosecution colleague. The court permitted counsel to show that e-mail only to her to refresh her memory.
1 mention
July 6, 2016 messages — Penza addressed the exchange during Sylvie's Day 2 redirect while questioning her about message screenshots.
1 mention
Keith's text quoting Man's Search for Meaning — Nicole's Day 20 cross-examination included discussion of the text identified as quoting Man's Search for Meaning.
1 mention
Keylogging emails involving Daniela and Kristin Keeffe — During closing argument, Agnifilo described emails between Daniela and Kristin Keeffe about keylogging, including an exchange providing email addresses. He argued that these emails did not show Raniere's involvement in the Loperfido or Bronfman episodes.
1 mention
Marianna's Facebook keylogs emailed by Daniela to Keith — Agnifilo described Daniela emailing Raniere captured keystrokes from Marianna's Facebook activity. He contrasted those emails with the evidence concerning the Loperfido and Bronfman keylogging.
1 mention
Materials from another e-mail account attributed to Camila, identified as the 1400 series and not yet offered — Hajjar stated that she had not yet offered the other account's messages and argued that they supplied context for Raniere's responses. The court said it would rule on any Camila statement lacking a contextual connection to his statements if the issue was raised.
1 mention
Message exchange labeled July 21, 2015 — Sylvie's redirect examination on Day 2 included discussion of the dated message exchange.
1 mention
Messages between Mr. Raniere and Camila quoted by the court — At sentencing, the court described messages imposing obedience and conditions on sexual encounters. The court also recounted Camila's message expressing fear and uncertainty about what Raniere wanted her to say.
1 mention
Messages requesting an explicit photograph — The exchange contains repeated requests for a sexually explicit photograph and a response agreeing to provide one. The messages were read during Maegan Rees's resumed direct examination on Day 17.
1 mention
Messages Sylvie deleted — On Day 2 recross-examination, Sylvie acknowledged deleting messages despite remembering Keith telling her not to delete them.
1 mention
Messages with Camila that the prosecution said concerned owning a slave and branding with Raniere's monogram — Hajjar said the anticipated messages would describe Camila owning a slave for Raniere and branding that slave with his monogram. Her Day 1 statement previewed evidence rather than establishing its admission.
1 mention
Music Daniela digitized into FLAC files for the executive library at Keith's request — Daniela's direct testimony on Day 13 included discussion of the executive library's FLAC music files.
1 mention
Naked photographs and collateral that Nicki reportedly forwarded from the Stevie account to Keith's Yahoo! account at his instruction — Lauren Salzman testified that Nicki described forwarding nude photographs and collateral from an account she called Stevie to Keith's Yahoo! account at his instruction. Salzman said Nicki expressed concern that the transfer breached security because the material was supposed to remain protected.
1 mention
Nicole's emails and journal entries concerning her relationships and DOS — During closing argument, Agnifilo discussed Nicole's emails and journal entries, including a May 25, 2016 entry sent to Allison Mack. He argued that the writings supported his interpretation of Nicole's relationship with Raniere and her experience in DOS.
1 mention
Nicole's own e-mails, which the government anticipated the defense might seek to introduce — On Day 20, Penza anticipated hearsay objections if the defense sought to introduce Nicole's own emails. She requested advance review of proposed cross-examination materials to streamline objections.
1 mention
NXIVM course information Agnifilo said was published on a website — During sentencing argument, Agnifilo said NXIVM course information had been published online and suggested that the publication might violate intellectual-property rights. He offered that dispute as an explanation for litigation.
1 mention
October 1, 2015 text messages Nicole attributed to Raniere and a first-line slave, concerning women serving him sexually — In her sentencing statement, Nicole described October 1, 2015 messages she attributed to Raniere and a first-line slave about obtaining women devoted to serving him sexually. She said reading the messages after his arrest caused profound distress and altered her understanding of her experience.
1 mention
Other people's collateral copied from Dropbox and given to Jay's ex-boyfriend — Jay testified that she gave her ex-boyfriend copies of other people's collateral so the material would exist somewhere other than with her if something happened to her. She described this as a safety measure based on uncertainty about how far others might go.
1 mention
Pregnancy-test material with metadata, which the government said was obtained from Google by search warrant for Camila's Gmail account — Hajjar said the pregnancy-test material was obtained from Google by search warrant for Camila's Gmail account and had metadata showing when it was sent. The court allowed the material during evidentiary discussion on Day 17.
1 mention
PSA files associated with the images — Booth described PSA files as Photoshop album files generated by Adobe Elements that retain information about associated images and file structure. He testified that their dates and times matched the images' EXIF creation data, approximately dating to 2005.
1 mention
Purported WhatsApp messages between April 8 and April 18, 2016 — Sylvie could not recall whether the messages displayed in one color were hers or the other participant's.
1 mention
Salzman's WhatsApp account of a 2002 incident involving involuntary administration of Valium, submitted and rejected as initial collateral — Salzman testified that her proposed collateral described a 2002 incident in which a woman was given Valium against her will, implicating Salzman and people important to her. She said Rosa Laura Junco rejected the account because releasing it would also implicate Raniere.
1 mention
Screenshots the court asked the defense to retrieve — After Nicole was excused and the jury left for an afternoon break on Day 20, the court asked the defense to retrieve the screenshots.
1 mention
Secret Telegram chat Monica asked Sylvie to create for their communications and readiness drills — The chat was identified as a channel Monica asked Sylvie to create for their communications and readiness drills.
1 mention
Selected correspondence copied from Edgar Bronfman's account into text files and passed to Keith, later through Kristin — Daniela's Day 13 direct testimony included discussion of selected account correspondence in text-file form.
1 mention
Selected emails copied from James Loperfido's account into text files and delivered on USB drives to Keith or Kristin — The material was identified during Daniela's Day 13 direct testimony as text-file copies of selected emails on USB drives.
1 mention
Separate WhatsApp messages between Camila and Keith Raniere reviewed from the KeithRaniere@yahoo.com account — On Day 18, Rees distinguished these messages from the WhatsApp messages previously reviewed from Camila's Gmail account.
1 mention
September 27, 2016 WhatsApp screenshot — Sylvie agreed that her messages appeared in white and messages attributed to the defendant appeared in green. The exchange also addressed capitalization of Grandmaster and Master.
1 mention
Several months of text messages defense counsel proposed using during Nicole's cross-examination — Before Nicole's cross-examination, Agnifilo described several months of text messages he proposed using as impeachment material to show the relationship as it existed at the time. Penza sought advance review and questioned whether the proposed use would introduce inadmissible hearsay.
1 mention
Telegram message screenshots that the defense offered as communications between the witness and the defendant — The defense offered Telegram screenshots as contemporaneous communications about an intimate relationship with Raniere, while the prosecution challenged authentication, completeness, and hearsay. The court found that the witness had not authenticated the collection and did not permit wholesale admission on the foundation presented, but allowed questions about particular messages to refresh recollection, with counsel bound by her answers.
1 mention
Telegram messages associated with Nicole's deleted account — Nicole said she purposely deleted her Telegram account shortly after leaving DOS and consequently could not provide its messages to the government. She said she had not anticipated the later case and would have provided them.
1 mention
Text messages between Lauren Salzman and another person that Agnifilo said the defense introduced at trial — During sentencing argument, Agnifilo said the defense had introduced messages between Lauren Salzman and someone who wanted to leave. He described the exchange as ending affectionately.
1 mention
Text messages between Nicole and Souki — Nicole said the messages did not discuss the content of her FBI interviews. She also confirmed agreeing to the government's request not to discuss that content with others.
1 mention
The Cult Education Institute website and database, formerly RickRoss.com — Ross described launching the public database in 1996 under RickRoss.com and later moving its portal to CultEducation.com. He said it offered articles, court documents, research papers and a public message board.
1 mention
The February 2015 email Nevares said Kristin Keeffe sent about Raniere hoping Nevares would commit suicide, and Raniere's response — In her sentencing statement, Ivy Nevares said Keeffe emailed her in February 2015 alleging that Raniere hoped she would commit suicide. Nevares said she forwarded the email to Raniere, who responded by disparaging Keeffe.
1 mention
The forwarded email chain concerning immigration status and an immigration lawyer — In closing argument, Agnifilo described an email from Daniela's father about addressing immigration-status issues, with an immigration lawyer included in the chain. He said Daniela received the forwarded email and acknowledged taking no action.
1 mention
The Frank Report article identifying Nicole as a sex slave of Keith Raniere — The article was described as identifying Nicole as a sex slave of Keith Raniere.
1 mention
Threatening text messages Keeffe said she received while in hiding, which she later attributed to Michelle — Keeffe said threatening messages from an initially unknown sender claimed knowledge of her identity and threatened to expose her to Raniere. She said the messages prompted her to flee with friends, and she later attributed them to their colleague Michelle.
1 mention
Thumbs.db databases on the Western Digital hard drive — Counsel questioned Booth about omitted Thumbs.db findings and a proposed timing discrepancy. Booth said the databases had been processed, but he had not reviewed each one or noticed the suggested discrepancy and would need to inspect it before assessing it.
1 mention
Two email-account collections described as The Beacon, The Beacon 2009, and Oak Haven, with the prosecutor uncertain of the exact addresses; one contained under 100 pages and the other about 500 pages — Penza described two email-account collections using the names The Beacon, The Beacon 2009 and Oak Haven, while expressing uncertainty about the exact addresses. One contained fewer than 100 pages and the other about 500; the court reserved its admissibility decision pending review.
1 mention
Two emails recovered from Nancy Salzman's laptop that the government said included Kristin Keeffe's reimbursement invoices — Penza sought to introduce two emails recovered from Nancy Salzman's laptop that she said included Kristin Keeffe's invoices seeking reimbursement. The court agreed to review the materials without making a final admissibility ruling at that hearing.
1 mention
USB drive with files Daniela recalled handing to Kristin — Daniela recalled handing Kristin files on a USB drive during her cross-examination on Day 15.
1 mention
Vow Kayla reportedly saw on Allison Mack's computer — The reference concerned a vow Kayla reportedly saw on Allison Mack's computer. The court restricted other people's reported statements to their effect on Vicente, not their truth.
1 mention
Weill website listing Hughes's faculty title — Counsel asked whether Weill's website placed the word voluntary next to Hughes's name. Hughes said she had not checked the website, while explaining that her faculty position was unpaid and required neither research nor publication.
1 mention
WhatsApp chat concerning reports of vehicles to Raniere — Weniger cited a WhatsApp chat when asked about evidence of Raniere's paranoia. He said community members regularly reported sightings of vehicles to Raniere.
1 mention
WhatsApp chats exported to Camila's Gmail account — Rees testified that the exported chats were found in Camila's Gmail account and could be read as attachments without retaining WhatsApp's encryption. Her testimony identified the account but did not identify the person who exported the chats.
1 mention
WhatsApp exchanges with Raniere concerning Sylvie's assignment and photographs; Sylvie said she had deleted the messages and was recounting them from memory — Sylvie said the messages were deleted and she could not reproduce their exact wording, while also qualifying dates and sequence. She said one response made her wonder whether Raniere knew of the assignment, but she did not know whether he did.
1 mention
WhatsApp message from the defendant encouraging Jay to return for the T-shirt company — Jay testified that Raniere contacted her on WhatsApp and encouraged her to return sooner if she was serious about starting the T-shirt company.
1 mention
WhatsApp messages reviewed from Camila's Gmail account — Rees said she believed that all the WhatsApp messages reviewed the previous day came from Camila's Gmail account.
1 mention
Zip drive India said contained collateral, retrieved from Allison's apartment — Jay said India asked her to retrieve a zip drive from Allison's apartment and warned that it contained collateral. Jay testified that she collected the drive from a table and brought it to India.
1 mention

Documents & Records (612)

Government Exhibit 204 — The box contained labeled folders, loose documents, handwritten notes and electronic communications, including purported financial information about named individuals. Weniger testified that the vast majority of people with folders had criticized NXIVM or Raniere; he believed most, if not all, of the banking information was untrue, but expressed uncertainty. He did not establish ownership of the contents or authorship of the handwritten notes.
6 mentions
Government Exhibit 725 — The schedule was admitted on Day 21 and lists transactions, purchase amounts, payments or credits, payment sources, and a running balance calculated by Guerci. On Day 22, Guerci testified that charges from November 7, 2016, the date of Cafritz's death, through February 8, 2018, totaled approximately $135,000. During redirect, he testified that, based on his knowledge, the listed $4,457 purchase of a cashmere sweater and Donegal blazer was not an allowable estate-administration expense.
5 mentions
Government Exhibit 907 — Daniela identified the stack as letters she wrote to the defendant, including requests to leave the room and reports of tooth pain. Cross-examination also addressed an attached plan that she described as an effort to repair damage she had done.
5 mentions
Government Exhibit 1007 — Government Exhibit 1007 was admitted without objection on Day 1. Sylvie identified it as coaching papers for introducing ESP's Rules and Rituals, including promotion, the Mission Statement, confidentiality, and group exercises. She explained that the exercises helped participants feel more comfortable with organizational practices such as titles and recitation.
4 mentions
Government Exhibit 1008 — Government Exhibit 1008 was admitted without objection on Day 1. Sylvie identified the Mission Statement and discussed passages addressing victimhood and the ethical control of wealth and resources. She understood the victimhood teaching to mean that people create what happens to them and said she had recited it repeatedly.
4 mentions
Government Exhibit 1404 — Government Exhibit 1404 was admitted without objection during Lauren Salzman's direct testimony on Day 9. Salzman initially identified it as the book and later as Chapter 1, reading instructions to further and honor one's master. She explained that the text defined individual words to prevent alternative interpretations.
4 mentions
Government Exhibit 204-A — The materials include a November 10, 2003 check for $2,500 and two $5,000 checks dated July and December 2004 from Edgar Bronfman. Ross attributed the July check to a legal defense fund concerning Landmark Education. He did not recall the other two checks and offered tentative explanations involving fundraising letters.
4 mentions
Government Exhibit 548 — The medical records describe appendix surgery on January 9, 2007, and subsequent treatment of an intraabdominal abscess. Rees read these details during direct testimony on Day 18, when Government Exhibit 548 was admitted without objection.
4 mentions
Government Exhibit 721 — Government Exhibit 721 was admitted without objection on Day 21 and includes account records and a bank authentication affidavit. Guerci said the bank information provided did not appear to show signing authority for Raniere and that he had not received a signature card for him. On cross-examination, Guerci confirmed that Raniere signed his own name on the reviewed checks and that, to his knowledge, the bank processed them.
4 mentions
Government Exhibit 1071 — The curriculum raised questions about sexual contact between adults and children and instructed head trainers not to offer an opinion, leaving students to develop their own views. Government Exhibit 1071 was admitted on Day 23.
3 mentions
Government Exhibit 1822 — The chain begins on August 26, 2009, and includes discussions of different levels of information and Canaprobe-related inquiries. It also includes Keeffe's August 27 email describing concerns about people near her home.
3 mentions
Government Exhibit 521-A — Booth explained how the report's display name, evidence path, and identifying fields matched the card he analyzed. Counsel reviewed an excerpted copy on Day 22 and questioned him about JPEG Image 231's access date on Day 23.
3 mentions
Government Exhibit 710 — Donato identified 35 receipts covering Raniere's treatment, sometimes together with Marianna's, from November 16, 2016, through November 8, 2017, after Cafritz's death. The payments ranged from $145 to $285, and Donato testified that the post-death charges were never declined.
3 mentions
Government Exhibit 722 — The records include an American Express certificate of authenticity and account statements. During cross-examination, Guerci reviewed pre-death travel charges for Cafritz, Raniere, and Marianna and confirmed that several spending categories also appeared after Cafritz's death.
3 mentions
Government Exhibit 724 — The documents identify Raniere as sole beneficiary through Cafritz's living trust and address his relinquishment of the executor role to Rosa Laura Junco. Guerci agreed that the resignation did not surrender Raniere's beneficial interest and that he had reviewed no document doing so.
3 mentions
Government Exhibit 762 — The declaration addressed Raniere's inability to access more than $400,000 by December 30, 2016, to satisfy the fee order. Its statement was narrower than counsel's later characterization that he had no assets.
3 mentions
Government Exhibit 853 — The invoice lists Daniela Padilla for billing and Alex Martin for shipping at 9 Milltowne in Waterford. Lauren Salzman recognized the shipping address as associated with the DOS house and recognized Padilla's name, but said she had not seen the document before.
3 mentions
495-T — The court received the transcript as a listening aid, with the recording controlling. On Day 11, counsel directed attention to approximately page 36 as playback resumed during Lauren Salzman's direct examination.
2 mentions
496-T — The transcript was received as a listening aid, subject to the instruction that the recording controlled. Counsel directed jurors to 496-T when Government Exhibit 496 was played during Lauren Salzman's direct examination on Day 11.
2 mentions
Ashana Chenoa's driver's license — The defense discussed the distinction between Ashana Chenoa's identity and the name Lisa Chenoa used in border-crossing records. In rebuttal, the prosecutor argued that the shared surname and birth date were sufficient despite the different first name.
2 mentions
Defense Exhibit 1002-A — Jay's card thanked Keith for changing her life and perspective and described plans to visit family in California and write poetry. The court admitted the card and envelope over objection during her cross-examination on Day 21.
2 mentions
Defense Exhibit 332 — The court treated the document as hearsay and did not admit it, but Vicente reviewed it and said his recollection was refreshed. During a later discussion, the parties disputed whether the government had already received it.
2 mentions
Defense Exhibit 607 — The email was admitted without objection and later compared with a same-date communication from someone Daniela had contacted about obtaining passwords. Daniela agreed that the dates matched but could not confirm that this person was the friend Kristin meant.
2 mentions
Defense Exhibit 945 — Booth identified the document as the digital camera's package sheet and said there was no separate document for the data device when asked about Exhibit 524. The court admitted Defense Exhibit 945 without objection.
2 mentions
Government Exhibit 1009 — The court admitted the statement without objection on Day 1. Sylvie's direct examination on Day 2 addressed the website denial alongside her account of Keith's involvement in the group.
2 mentions
Government Exhibit 1108 — The certificate gives November 7, 2016 as Cafritz's death date, and its second page contains a custodian-of-records declaration. The court admitted the exhibit without objection during Richard Guerci's direct examination on Day 21.
2 mentions
Government Exhibit 1271 — Nicole identified the message as her first email to Raniere and said she followed directions to thank him for creating The Source. The court admitted and published the email, and Nicole testified that he did not respond.
2 mentions
Government Exhibit 1272 — Nicole's April 17, 2016 email described feeling scared and heavy-hearted about continually confronting her fears. She testified that Allison pressured her to obtain an answer and suggested asking a question, but Raniere did not respond to this email.
2 mentions
Government Exhibit 1273 — The email described Nicole's discomfort with contacting someone she did not know at another person's request and said Allison would have to take a cold shower if Nicole did not obtain a reply. Nicole testified that Raniere did not respond to this message.
2 mentions
Government Exhibit 1275 — Raniere addressed Allison's cold shower, questioned Nicole's commitment to obtaining an answer, and thanked her for persisting after receiving three emails. Nicole said she was unsure which of her messages had prompted his response.
2 mentions
Government Exhibit 1326 — The document rates collateral by the areas of life affected, proof of authenticity, and potential harm from disclosure. Its scoring system assigns levels to different forms of information and applies multipliers based on the anticipated effect on a person's life.
2 mentions
Government Exhibit 1356 — The schedule included preparation for Nicole's mother's visit. Nicole testified that Mack wanted her to email plans for the next day after she joined The Vow, but clarified on cross-examination that she did not consistently do so.
2 mentions
Government Exhibit 1357 — The email chain, ending March 31, 2016, contains Nicole's journal reflections about time with her mother and anxiety about losing her ability to choose and think independently. Allison's response told her that she could not reverse her commitment. Nicole acknowledged both positive and doubtful writings during cross-examination.
2 mentions
Government Exhibit 1378 — The two-page email chain contains Nicole's expressed desire to pursue freedom and love despite fear, followed by Raniere's discussion of discipline, commitment, and pain. The court admitted the exhibit without objection on Day 19.
2 mentions
Government Exhibit 1383 — Clare Bronfman's email to Danielle listed allocations of 70 percent to the mentor and 10 percent each to the place owner, corporate, and Keith. Weniger said he believed the document related to exo/eso, which he described as a company operated by Danielle under NXIVM.
2 mentions
Government Exhibit 1395R — The July 12, 2008 email exchange between Mark Vicente and Ken Kozak addressed completion of a videotape-copying project and progress on VHS and mini-DV copies. In closing argument, Penza described the exchange as addressing copying and Nancy Salzman's review of the tapes.
2 mentions
Government Exhibit 1405 — Sylvie's November 30, 2012 email to Clare Bronfman and Keith Raniere included a training log with notes about pain, disrupted sleep, fatigue, and anxiety. Sylvie identified the displayed version as redacted to remove her last name.
2 mentions
Government Exhibit 1406 — Clare Bronfman's response suggested that Sylvie examine fears associated with being unable to run or exercise. Sylvie testified that she had reported difficulty completing training sessions because of pain and declining performance.
2 mentions
Government Exhibit 1407 — Sylvie's December 3, 2012 email to Keith Raniere and Clare Bronfman described fatigue, weakness, chest pain during attempted exercise, and antibiotic treatment for an abscess. She asked about substantially lighter training, and the attached log was examined during her testimony.
2 mentions
Government Exhibit 1409 — Clare Bronfman's email relayed Raniere's suggestion that Sylvie continue exercising as long as it did not hurt. In her December 4, 2012 response, Sylvie said she had been hurting for weeks; she testified that the advice made her feel her earlier reports of pain had been dismissed or unread.
2 mentions
Government Exhibit 1410 — Sylvie's December 5 email to Clare Bronfman relayed medical advice to reduce training while an abscess healed and described exhaustion, loneliness, and uncertainty about elite athletics. The email also said people inside and outside ESP had advised rest and healing before major decisions. Sylvie testified that she wanted Bronfman to understand her experience because she felt unsupported.
2 mentions
Government Exhibit 1411 — Clare Bronfman's response characterized Sylvie's language, weight, and eating patterns as a return to a robotic perspective. Sylvie testified that she understood the response as criticism of changing course from athletics and that it left her feeling cornered.
2 mentions
Government Exhibit 1469 — The email contains a document described as a transcript of sorts of an October 24, 2012 Jness forum. Government Exhibit 1469 was identified as already in evidence during Charles Fontanelli's Day 7 testimony.
2 mentions
Government Exhibit 1473 — Carly's July 4, 2017 email concerned her resignation and requests about refunds and collateral. The court barred its admission because of its specific accusations against Raniere but allowed questions about collateral-return demands and use of the document to refresh recollection. The email was shown to Lauren Salzman for that limited purpose.
2 mentions
Government Exhibit 1480 — Clare Bronfman's email to Loreta Garza included attachments discussing possible prosecutorial connections and efforts to obtain prosecution. The text portrayed Steve Herbits and his connections as powerful opposition; these were Bronfman's assertions, not findings about those individuals.
2 mentions
Government Exhibit 1484R — During cross-examination, Lauren Salzman acknowledged that Hector's email told her and others that his daughter had stolen from him and hacked his Facebook account. The direct-examination exhibit references were inconsistent, although the admission list included Government Exhibit 1484R.
2 mentions
Government Exhibit 1485R — The email chain concerned book reports, return conditions, and a shortened deadline. Government Exhibit 1485R was initially identified as Salzman's response to Hector's update, but later questioning used that label for Hector's update; the conflicting references remained unresolved.
2 mentions
Government Exhibit 1486R — The correspondence concerned Daniela's book-report deadline and Kristin Keeffe's response to the family group under the subject RE: Important. Counsel examined the document during Lauren Salzman's testimony on Day 10 and Day 11.
2 mentions
Government Exhibit 1488R — The email series addressed book-report requirements, withheld documents, and Daniela's stated inability to meet the demands. During cross-examination, counsel examined Salzman's agreement with the family's assessment of Daniela.
2 mentions
Government Exhibit 1491-R — The three-page November 2008 email chain contains redacted correspondence between Stephen Herbits and Clare Bronfman. The court admitted it without objection during Herbits's Day 7 testimony, and Weniger later discussed it as part of the correspondence presented through Herbits.
2 mentions
Government Exhibit 1492-R — The two-page November 2008 document contains Clare Bronfman's message about loan information and Herbits's response. The court received the exhibit without objection during Herbits's Day 7 testimony.
2 mentions
Government Exhibit 1493-R — The two-page December 2008 email exchange concerns Rick Ross and advice Herbits had previously given. The court admitted the redacted exhibit without objection during Herbits's Day 7 testimony.
2 mentions
Government Exhibit 1494-R — The December 2008 email chain discusses resolving the Ross dispute before the Dalai Lama's planned visit. The court received the redacted correspondence without objection during Herbits's Day 7 testimony.
2 mentions
Government Exhibit 1495-R — Edgar Bronfman's January 6, 2011 email denied supporting Rick Ross. The denial addressed a funding allegation and did not establish that the alleged support occurred.
2 mentions
Government Exhibit 1496-R — Herbits's January 19, 2011 email to Clare and Sarah Bronfman, copying Edgar Bronfman, addressed alleged charitable funding of Rick Ross. Herbits reported receiving an answer that no payments had been made; his account was not an independent audit.
2 mentions
Government Exhibit 1510 — Daniela's email to Nancy concerned General Systems Theory and stated that three chapters were beyond her. The court admitted Government Exhibit 1510 without objection on Day 12, and counsel discussed the email during Daniela's Day 15 cross-examination.
2 mentions
Government Exhibit 1514 — Leonardo's October 31, 2005 email concerned not receiving an email from Daniela. During cross-examination, Daniela identified him as someone she had contacted to find a person who could obtain passwords for hacking into computers.
2 mentions
Government Exhibit 1544 — Daniela identified Exhibit 1544 as an early November 2008 email chain between herself and the defendant. The defense conceded that content had been obtained but opposed disclosure of the private key-log content as unnecessary and unduly prejudicial; the court admitted the exhibit over the preserved objection.
2 mentions
Government Exhibit 1559 — The email exchange includes a January 7, 2009 discussion of a party and figurines placed inside rosca bread. During cross-examination, Daniela confirmed her written account of telling Megan Mumford that she wanted the ring rather than the thimble, while expressing uncertainty about whether Ben heard the conversation.
2 mentions
Government Exhibit 1589 — The December 2008 email chain includes requests for pictures and attached photographs. During Daniela's testimony on Day 14, she identified displayed photographs as pixelated versions, and the court directed screen positioning after Penza requested publication only to the jury and counsel.
2 mentions
Government Exhibit 1816 — Michele's November 19, 2016 email to Allison Mack distinguishes collateral already submitted from material prepared but not yet submitted, including letters, intimate images and inheritance documents. Michele also listed Souki's submissions and wrote that Souki owed five more pieces beyond outstanding submissions, plus another piece in December.
2 mentions
Government Exhibit 1827 — In the email chain, the defendant stated on December 21, 2016 that he did not yet have money for the proposed gift and suggested that Pam's estate might provide it. Weniger testified that he believed Clare Bronfman's assistant ultimately transferred Bronfman's funds to Marianna.
2 mentions
Government Exhibit 1829 — The exhibit combines a $525,000 check dated February 3, 2017 with Clare Bronfman's January 30, 2017 Notice of Gift. Weniger discussed it in connection with funds transmitted to Marianna, said he believed Bronfman's funds were ultimately transferred, and was uncertain where the exhibit had been obtained.
2 mentions
Government Exhibit 3500 LS-6 — Lauren Salzman's signed cooperation agreement was discussed alongside her hope that cooperation would reduce her sentence. She said no sentence was promised, the judge would decide it, and the government would not recommend a specific sentence. She understood that false testimony could forfeit the agreement and expose additional confessed conduct to prosecution.
2 mentions
Government Exhibit 418 — Audrey's email concerned her July 7, 2017 request for the return of collateral and its July 10 forwarding. The court barred its admission because of specific accusations against Raniere but allowed its use to refresh recollection during Lauren Salzman's testimony.
2 mentions
Government Exhibit 504-A — The hardcopy printout of Government Exhibit 504 contains a forensic report with an evidence list and image metadata. It was addressed during Brian Booth's direct examination on Day 22 and cross-examination on Day 23.
2 mentions
Government Exhibit 530-R — Rees used qualified language to identify an abdominal scar in the account photograph and distinguished it from patterned scarring on the left leg, noting that she was not a medical examiner. The court allowed a glossy, unredacted copy to be passed among jurors because details were difficult to see on the displayed copy. In closing, Penza referred to Exhibit 530-R as appendectomy records.
2 mentions
Government Exhibit 539-18 — The annual gynecological examination form contains a notation indicating five years with a partner. On cross-examination, Butler acknowledged that Ms. Fuller made the notation and that Butler had not personally asked the sexual-history questions.
2 mentions
Government Exhibit 608 — The exhibit includes the Forbes cover depicting the defendant and Michael Freedman's article Cult of Personality, dated October 13, 2003. The court admitted it over defense relevance and prejudice objections, instructing jurors that it was offered to establish steps taken by people interested in or involved with the case, not for the truth of its assertions.
2 mentions
Government Exhibit 617 — The July 1, 2008 joint discovery letter from Anthony Sylvester to Magistrate Judge Mark Falk includes NXIVM counsel's representation that recordings were produced unedited. Valenziano identified the letter and its jointly supplied responses, and the court admitted it over objection.
2 mentions
Government Exhibit 618 — Valenziano identified a July 1, 2008 email from Joseph Waala and an attached cover letter producing materials, including 35 DVDs contained in Government Exhibit 605. The court admitted Government Exhibit 618 over objection.
2 mentions
Government Exhibit 651 — Nicole identified the February 10, 2016 email as containing Source and personal journal sections requested by Allison Mack. The personal section described suicidal feelings, uncertainty about her identity, and career concerns; Nicole confirmed that it accurately reflected her feelings at the time.
2 mentions
Government Exhibit 653 — Mack sent the email after the October 2016 Berkshires trip and requested written weekly commitments. The email specified calorie limits and permission requirements for eating after 5 p.m., including a 500-calorie limit for India and Mack's commitment to remain under 600 calories until reaching 106 pounds.
2 mentions
Government Exhibit 664 — Nicole testified that she emailed Mack on October 20, 2017 to request the physical return of her collateral after leaving DOS. When shown the forwarding information, she tentatively agreed that Mack had forwarded the request to Clare Bronfman and Raniere, but said she had not previously seen that portion of the chain.
2 mentions
Government Exhibit 665 — The court admitted an April 20, 2016 email chain involving Nicole and Mack about an agency meeting Mack arranged for her. Later testimony also used the label Government Exhibit 665 for a four-page document that refreshed Nicole's recollection of an incident date as May 31, 2016; no new admission of that document was stated.
2 mentions
Government Exhibit 668 — The proposed exhibit consisted of the front page rather than the article's full text. Weniger identified Raniere on the cover and described coverage extending over several days, while qualifying his recollection of the series length.
2 mentions
Government Exhibit 670 — The court admitted Raniere's RPI transcript over defense objection. Weniger identified a final GPA of 2.26 and entries for failing grades, probation, and academic dismissal, while also acknowledging that the transcript appeared to include higher-level courses.
2 mentions
Government Exhibit 705 — The summary covers account activity from May 17 through October 31, 2018. The government did not pursue admission after an objection and agreed to use it only if needed to refresh recollection; during cross-examination, Guerci estimated approximately 20 paid law firms and individual lawyers.
2 mentions
Government Exhibit 718 — The court admitted the American Express records without objection. Guerci identified XR LLC transactions for $922.74 and $1,730.90 and confirmed that the latter amount corresponded to a credit shown on the statement.
2 mentions
Government Exhibit 726 — Guerci prepared the schedule from Pamela Cafritz's KeyBank account records for November 1, 2016 through June 29, 2018. He calculated $736,856.49 in disbursements and $695,661.96 in deposits; he could not determine who made the scheduled debit-card transactions.
2 mentions
Government Exhibit 727 — Guerci identified the schedule as a summary of checks signed by Raniere on Pamela Cafritz's KeyBank account during the November 1, 2016 through June 29, 2018 period. He testified that the summarized checks totaled $328,305.84, and the court admitted the exhibit without objection.
2 mentions
Government Exhibit 761 — Guerci identified the exhibit as a collection of Kathy L. Russell's American Express statements covering January 14, 2003 through January 14, 2006. The court admitted the collection together with the separate January 15, 2005 statement labeled Government Exhibit 761-A.
2 mentions
Government Exhibit 801 — The admitted redacted two-page exhibit includes a Department of Homeland Security certification and a vehicle encounter under Lisa Chenoa's name at the Lewiston–Queenston Bridge crossing on December 24, 2004. Guerci did not identify the person actually encountered, and additional pages presented during cross-examination were not admitted during that exchange.
2 mentions
Government Exhibit 851 — Welch identified the May 26, 2017 order as listing Daniela Bergeron, totaling $922.74, and having shipped. His examination connected the invoice's restraint products with corresponding product descriptions, but did not establish who personally placed the order.
2 mentions
Government Exhibit 908R — The collection includes emails concerning Daniela's time in the room, threatened loss of contact, and return to Mexico. Salzman testified that an email's claim that she could end the arrangement was untrue because Keith held that authority; on cross-examination, she described Daniela's changing wishes and the use of fears as leverage.
2 mentions
National Intimate Partner and Sexual Violence Survey — Hughes described the CDC-sponsored survey as an ongoing representative study and said that, depending on the years examined, it indicated that 1 in 4 to 1 in 5 women had experienced sexual assault during their lifetimes.
2 mentions
Verdict sheet — The form called for separate verdicts on each count and findings on alleged racketeering acts and specified subparts. The court instructed the foreperson to sign and date the completed form and notify the Marshal.
2 mentions
Written jury charge — The charge exceeded 130 pages and covered jury duties, the elements of the charged crimes, and deliberation rules. Before delivery to the jury, the court said it would verify corrections, including the addition of the word common.
2 mentions
$525,000 check to Marianna — Weniger said he did not know of anything improper about the gift to Marianna.
1 mention
1396 — Vicente initially explained the email's senior recipients by reference to purchasing authority. He withdrew that explanation after acknowledging that he had mistakenly assumed he wrote the email and said Chris's reasons should be checked.
1 mention
1483-11 — Fontanelli identified the already-admitted document as a deposit slip during his Day 8 direct testimony. When counsel returned to it, he read $390,180 as the amount for the cash previously discussed.
1 mention
1789 — The email described its writer acting under a master's directions, wanting to stop, and accepting consequences for disobedience. The testimony did not identify the master.
1 mention
326 — Vicente recognized the January 5, 2016 letter and described it as critical of the entire system. He said its praise of the technology reflected both his belief at the time and an effort to mitigate punishment.
1 mention
327 — The court sustained the objection to admitting the district-attorney letter. During questioning, Vicente described group drafting, reliance on others, and uncertainty about the factual basis of some statements.
1 mention
344 — The court excluded Exhibit 344 as hearsay, rejected the defense's argument for admitting it solely for its date, and directed counsel to continue with refreshed-recollection questioning.
1 mention
345 — Exhibit 345 was discussed during Mark Vicente's cross-examination on Day 7 and contains phone numbers with a highlighted line.
1 mention
3500-J-12 — Counsel used page three of 3500-J-12 to question Jay about her December 27, 2018 interview and payment for a marriage. Jay said $18,000 was the agreed payment rather than the amount she received, and she did not recall her exact interview wording.
1 mention
3500-MV-2 — Counsel used the FBI interview report labeled 3500-MV-2 during Mark Vicente's resumed cross-examination on Day 6 to question him about a November 2017 interview.
1 mention
3500-MV-58 — The court received Vicente's signed agreement with the government, Exhibit 3500-MV-58, without objection during his direct examination on Day 4. Vicente said he understood that he would not be prosecuted for statements to prosecutors and law enforcement or for his testimony unless he lied.
1 mention
3500-N, number one — Counsel used page 4 of the material labeled 3500-N, number one, during Nicole's cross-examination on Day 20 to question her about her first FBI interview.
1 mention
3500-N4 -- N1 — After reading a paragraph during cross-examination on Day 20, Nicole said she had confused Albany with Los Angeles and recalled being told Mark Vicente rented the house for her first five-day Los Angeles course, although she did not think he lived there.
1 mention
3500DF-12 — Counsel showed Daniela the report's fifth page during cross-examination on Day 16 and asked about visits to Stewart's and Walmart. Daniela said she remembered going out but remained uncertain about her destinations and did not recall making the statements counsel described.
1 mention
3500DF-21 — Counsel showed Daniela an underlined portion during cross-examination on Day 16 and asked whether she had reported taking money from her father's wallet to buy food. Daniela denied that characterization and described uncertain recollections and speculation about how she might have obtained money. The court sustained objections and instructed counsel not to read from documents that were not in evidence.
1 mention
3500EB-3 — During procedural discussion on Day 16, Agnifilo said 3500EB-3 attributed all information about the sisters to Butler's co-worker Judith Wilner. He raised possible hearsay concerns about Butler's anticipated testimony and distinguished personal knowledge from information relayed by Wilner.
1 mention
35800MV53 — After reviewing the document's fourth page during cross-examination on Day 6, Vicente acknowledged that he had a primary role in the film's production at the beginning and maintained that he later moved away from that role.
1 mention
494T — The transcript accompanies Exhibit 494 and was received as a jury aid during Lauren Salzman's direct examination on Day 10. The recording controlled over the transcript.
1 mention
497T — The transcript accompanies Exhibit 497 and was received as a jury aid during Lauren Salzman's direct examination on Day 10. The recording controlled over the transcript.
1 mention
56 letters submitted in support of Mr. Raniere — The court stated that it had read all 56 support letters and that many expressed genuine belief that NXIVM and Raniere had played a positive role in people's lives. The court also reviewed victims' letters and considered their statements.
1 mention
654 — Agnifilo described the email series as already in evidence and turned to its first email during Nicole's cross-examination on Day 20.
1 mention
A Forbes article written in 2003 — Valenziano testified that the 2003 Forbes article was part of NXIVM's case against Stephanie Franco. Her attorneys sought a DVD marked Forbes during discovery in approximately 2007–2008.
1 mention
a sheriff's identification card with the last name and date of birth of Ashana Chenoa — The indictment language read during the jury instructions alleged a conspiracy to possess a false sheriff's identification card bearing Ashana Chenoa's last name and birth date. The instructions required findings about the document's falsity, knowing possession, and intent to defraud the United States.
1 mention
Addendum to the PSR dated April 8, 2020 — The court listed the April 8, 2020 addendum among the sentencing materials it had reviewed, alongside the presentence report, objections, responses, and sentencing submissions.
1 mention
Additional border-crossing records that defense counsel understood to be attachments to Exhibit 801 — Guerci said he had neither prepared nor previously seen the additional document. Prosecutors requested review, and the court deferred a decision on admission; defense counsel indicated that admission could be sought through the defense case.
1 mention
Additional collateral letters, including damaging letters to John and commitments concerning income and having children — Sylvie testified that Monica required additional collateral, including letters intended to damage close relationships, a commitment involving an uncertain portion of her income, and a letter giving Monica purported authority over whether she could have children. Sylvie described choosing material whose disclosure would be most destructive to her.
1 mention
Additional handwritten pages, including a December 26 work log and entries concerning Ross telephone records — The handwritten entries discussed Ross's telephone contacts and a proposed subpoena for his Arizona phone. Weniger had not determined whether the handwritten notes in the box shared a single author.
1 mention
Alaska State Police file concerning Snyder, most of whose documents were also in the recovered box — The file came up during questioning on Day 24.
1 mention
Albany Times Union article in Government's Exhibit 204; counsel agreed to redact its full text while retaining the headline, date, and Dennis Yusko's byline — Counsel agreed to redact the article's full text while retaining its headline, date, and Dennis Yusko's byline. The agreement did not resolve or withdraw the defense's original objection to admission of the box.
1 mention
Alleged 2006 cease-and-desist letter from John Hochman's lawyer — Defense counsel asked Ross whether Hochman's lawyer sent a 2006 cease-and-desist letter directing removal of Hochman's report from Ross's website. Ross did not recall receiving it, allowed that he might have, and said the report remained online.
1 mention
Alleged suicide note discussed in the Christian Snyder account and Raniere's response to it — Vicente recounted allegations that Christian Snyder left a suicide note and described Raniere's claim that its reference to NXIVM undermined the story because NXIVM did not yet exist. Vicente presented this as part of a proposed film rebutting criticism of Raniere, not as independently established events.
1 mention
Allison's sexuality questionnaire completed by Jay and Nicole — Jay testified that she completed the questionnaire with Nicole in Allison's apartment, sent it to Allison, and did not learn what happened to it. Her later understanding that it supplied information to Keith did not rest on observing its transmission.
1 mention
Andre De Zutter study that defense counsel described as concerning 57 documented false allegations of abuse — Hughes did not have the De Zutter study before her when she acknowledged false-reporting research and answered questions about regret after sex and concealing other behavior.
1 mention
Approximately 20 or more articles apparently written by Keith Raniere, with a review questionnaire — Sylvie said Monica gave her access to approximately 20 or more articles apparently written by Raniere and a questionnaire for rating their quality and impact. She recalled spending one to two hours daily on the work over roughly two weeks.
1 mention
Approximately 250 pages of materials attached to the defendant's letter for possible use in cross-examining the Government's first witness — The court classified the approximately 250 pages attached to the defense letter as impeachment materials outside Rule 16's disclosure requirements, but ordered production after the first witness's direct examination. It accepted counsel's proposal to provide everything and identify the materials he intended to use.
1 mention
Ashana Chenoa border-crossing information received from Immigration and Homeland Security Investigation — During cross-examination, Weniger acknowledged that he had no immigration document for Kathy Russell comparable to the document for Ashana Chenoa.
1 mention
Ashana Chenoa's death certificate — In rebuttal, Lesko cited Chenoa's death certificate and driver's license as evidence that she was a real person. He used those documents while addressing the alleged use of her identifying information for Daniela's border crossing.
1 mention
Ashana Chenoa's driver's license and death certificate, and a CBP crossing record — Penza displayed Chenoa's driver's license, death certificate, and a CBP crossing record during closing argument. She argued that the documents showed Chenoa was a real person and connected her identifying information to the December 24, 2004 border crossing.
1 mention
Ashana Chenoa's obituary — Agnifilo cited Chenoa's obituary and driver's license in acknowledging that she existed. He distinguished that acknowledgment from his argument that the prosecution had not proved Raniere's agreement to use her identity.
1 mention
At the Feet of the Master passage or booklet Allison gave Nicole after she joined The Vow — Nicole described receiving a few-page passage or booklet from Allison after joining The Vow. She recalled material about caring for one's body and mind, and said Allison explained serving a master as a reflection of serving oneself.
1 mention
Barry Meier's notice to Mr. Raniere of a forthcoming New York Times article, offered by the government for timing rather than truth — Penza described Meier's notice as an opportunity for Raniere to comment before publication and placed it the day before Jay received a letter from a Mexican attorney. The court allowed the notice among the remaining disputed materials and stated that no one has an obligation to respond to the media.
1 mention
bias charge from our proposed instructions — The defense objected to removal of its proposed witness-bias instruction and offered to accept alternative wording. The court retained the existing charge, finding the proposal too specific and suggestive.
1 mention
Book called Master Cleanse raised by counsel; Sylvie said she had never seen or read it — Sylvie's Day 2 cross-examination included a reference to the book titled Master Cleanse.
1 mention
Booth's recent camera report — Booth testified that the government asked him to prepare another camera report and testify because Stephen Flatley, who had previously examined the camera, was on assignment in Ghana and unavailable.
1 mention
Border records showing Lisa Chenoa crossing on Christmas Eve — Lesko described the records as showing a Christmas Eve crossing under the name Lisa Chenoa. He argued that the matching last name and birth date identified the information as Ashana Chenoa's and answered the defense's concern about the different first name.
1 mention
Border-crossing records discussed in challenging Kathy Russell's reported crossings — Agnifilo argued that neither of Kathy Russell's alleged crossings appeared in the border records. He presented that absence as a reason to doubt Daniela's account, while acknowledging that Russell had been near the border.
1 mention
Box of folders that the government characterized as financial dossiers on perceived NXIVM enemies; the defense also described Kristin Keeffe's handwritten notes and to-do lists among the materials — The government described a plastic box recovered from Nancy Salzman's basement containing folders of purported financial information on perceived NXIVM enemies and others. The defense alleged that Canaprobe supplied fraudulent records and described Keeffe's handwritten notes and to-do lists among the contents. The court reserved an admissibility decision pending review.
1 mention
Bullet-pointed script about how a slave should view and respond to a master — Sylvie testified that Monica showed her a bullet-pointed script describing how a slave should regard and respond to a master. She said it also guided her in devising collateral that would be personally devastating if released.
1 mention
Camila's birth certificate, which Daniela said she had obtained before receiving her in Mexico — Daniela's direct examination on Day 15 included a reference to Camila's birth certificate.
1 mention
Camila's medical records obtained from McGinnis Medical Clinic — Michael Weniger's direct examination on Day 24 included a reference to Camila's medical records from McGinnis Medical Clinic.
1 mention
Camila's medical records, including a medical history form that the government said recorded five years with her partner when she was 21 — Penza said Camila's medical-history form stated that she had been with her partner for five years when she was 21. The government proposed testimony explaining the statement's relevance to medical treatment, while the defense questioned the hearsay basis for anticipated testimony. No ruling on the records appears in this exchange.
1 mention
Camila's written statement concerning how she believed her lawyer was compensated — The court expressed the impression, attributed to Camila, that her lawyer was compensated through Clare Bronfman's $13.8 million irrevocable trust. Agnifilo said he did not know how the lawyer was paid and later said that account was probably right.
1 mention
Canaprobe documents and correspondence about obtaining personal banking information — During closing argument, Penza cited Canaprobe documents and correspondence involving Kristin Keeffe and Raniere. She argued that the correspondence used coded language in efforts to obtain individuals' personal banking information.
1 mention
Canaprobe report alleging foreign bank accounts associated with Senator Charles Schumer — Weniger confirmed that Canaprobe sent Keeffe a report alleging foreign bank accounts associated with Schumer. He said he did not know whether the accounts described were real, rather than affirming that the report was false.
1 mention
Canaprobe report listing a purported Rick A. Ross Institute account at UBS in Jersey in the name of Ross Corp. — The report was displayed during Weniger's cross-examination and described as listing a purported Rick A. Ross Institute account at UBS in Jersey under the name Ross Corp. Counsel expressly separated that description from any determination whether the report was true or false.
1 mention
Canaprobe report on Frank Parlato sent to Kristin — Weniger agreed that Frank Parlato was another person on whom Canaprobe sent Kristin a report.
1 mention
Canaprobe report on Peter Skolnik describing a purported financial connection to Rick Ross — The report sent to Kristin Keeffe purported to describe a financial connection between Peter Skolnik and Rick Ross through a euro-denominated bank account. Weniger agreed that the report appeared to make that claim.
1 mention
Canaprobe's April 30, 2009 interim report on the Rick A. Ross Institute — Canaprobe's April 30, 2009 interim report purported to identify foreign bank accounts belonging to the Rick A. Ross Institute. Weniger agreed that this was what the report appeared to say.
1 mention
Canaprobe's August 10, 2009 report on Carlos Rueda, listing Rick Ross as an account beneficiary — Weniger identified the August 10, 2009 report as a Canaprobe report about Carlos Rueda sent to Kristin. He said he had no indication of the claimed financial relationship with Rick Ross, but could not call the account claim false because he had not investigated it.
1 mention
Canaprobe's October 1, 2009 report alleging money laundering by Rick Ross — The October 1, 2009 report emailed to Kristin Keeffe alleged that Rick Ross participated in international money laundering. Weniger acknowledged that the report made the allegation but said he had no evidence of such activity.
1 mention
CART examination notes concerning receipt and condition of the evidence — Booth described contemporaneous typewritten examination notes intended to allow examination steps to be recreated. He said those notes would document the Western Digital drive's packaging and whether it was sealed, but he did not have records of its condition in front of him.
1 mention
Cease-and-desist letters to former DOS slaves that Salzman believed came from Alex Betancourt as ESP Mexico's representative — Lauren Salzman testified that she knew cease-and-desist letters had been sent to certain DOS slaves. She believed the letters came from Alex Betancourt as a representative of ESP Mexico.
1 mention
Charmel's collateral letter to her children, which Salzman said would effectively sever their relationship — Lauren Salzman's direct testimony on Day 9 included a reference to a document identified as Charmel's collateral letter to her children.
1 mention
Chasm of Fire and chapter reports assigned by Allison Mack — Jay testified that Allison Mack assigned her to read Chasm of Fire, a book she described as a woman's journey to enlightenment. Jay said she had to send Mack a report after each chapter explaining its contents and her reactions.
1 mention
Check from Edgar Bronfman to the Ross Institute, described by Geragos at sidebar as already admitted — Cross-examination on Day 8 included a reference to a check identified as being from Edgar Bronfman to the Ross Institute.
1 mention
Check provided to Ross as a retainer for the proposed intervention arranged through Interfor — Rick Alan Ross's direct testimony on Day 22 included a reference to a check identified as a retainer for a proposed intervention arranged through Interfor.
1 mention
Checks issued to people Vicente described as independent contractors — Mark Vicente's direct testimony on Day 3 included discussion of checks identified as payments to people he described as independent contractors.
1 mention
Coach application containing detailed questions — Mark Vicente's Day 3 direct testimony included discussion of a coach application described as containing detailed questions.
1 mention
Collateral letter addressed to Sylvie's parents portraying her as a prostitute, following Monica's suggestion to use a stamped, addressed envelope — Sylvie's continued direct testimony on Day 1 included a reference to a document identified as a collateral letter addressed to her parents.
1 mention
Company books requested by executive board members but, according to Vicente, never provided — Vicente testified that the executive board never received the financial books it requested. He also acknowledged that the company's internal financial workings remained largely inaccessible to him.
1 mention
Confidentiality agreement with the producers — Vicente cited a confidentiality agreement with the producers when asked where filming had occurred, saying he was unsure whether he could answer. The court directed him to answer the question.
1 mention
Confidentiality and nondisclosure agreement required for the intensive — Vicente testified that participants had to sign a confidentiality agreement to receive the intensive's instruction. He described restrictions on discussing their experiences outside the class and recalled restrictions on using what they learned after leaving.
1 mention
Contract Salzman signed with Audrey and showed as an example of consent; Salzman now described it as incomplete and symbolic — Salzman testified that she showed others the contract she signed with Audrey as an example of consent. She later described it as incomplete and symbolic and said she did not believe it had any force.
1 mention
Cooperation agreement — During discussion of a defense letter on Day 28, Penza argued that Lauren Salzman's cross-examination had not been cut short and that rebuttal comments created no problem. She also stated that the cooperation agreement was in evidence.
1 mention
Copies of Ross's private bank statements, which he testified he received without requesting them and was told NXIVM investigators had obtained — Ross described receiving unsolicited copies of his private bank statements and being told that NXIVM investigators had obtained them. His attribution of their acquisition to those investigators was based on information communicated to him.
1 mention
Copies of Ross's private phone records, which he testified he received without requesting them and was told NXIVM investigators had obtained — Ross described receiving unsolicited copies of his private phone records and being told that NXIVM investigators had obtained them. He attributed the investigators' acquisition of the records to information communicated to him.
1 mention
Court Exhibit 5 — The jury asked whether Internet use for any purpose, email or chat communications within one state, and online research qualified as affecting interstate or foreign commerce.
1 mention
Court order to copy all hard drives in Loperfido's office — Loperfido testified that attorneys for Ms. Bronfman obtained a court order to copy all the hard drives in his office to look for information about Mr. O'Hara.
1 mention
Court's proposed charge, version of 6/14/19 — During the Day 25 charge conference, the court identified the June 14, 2019 version as the second draft, and both sides confirmed they had it. The court agreed to replace a reference to Mr. Raniere on page 10 with the defendant for consistency.
1 mention
Damaging documents against her mother that India said she was instructed to write — In her sentencing statement on Day 29, India said Clare Bronfman and Nancy Salzman instructed her to write damaging documents against her mother and to sue her.
1 mention
Daniela's abortion clinic records — During rebuttal closing, Lesko addressed the defense's use of statements in Daniela's abortion clinic records to question her credibility. He argued that she gave false information at Pam Cafritz's and the defendant's direction to avoid raising concerns about her immigration status.
1 mention
Daniela's birth certificate — Daniela discussed her birth certificate during direct examination on Day 14.
1 mention
Daniela's birth certificate and replacement birth certificate — Daniela testified that her birth certificate had been among personal papers taken with her possessions, although she did not know who took them. She said a lawyer friend obtained a replacement through the Human Rights Commission.
1 mention
Daniela's birth certificate, which she said she ultimately obtained free through the Human Rights Commission — Daniela described obtaining a birth certificate through outside assistance after encountering difficulties securing work and services without identification.
1 mention
Daniela's handwritten sheet listing matters to make amends for, including entries beginning Pay back what taken — Daniela's handwritten sheet listed matters for which she was to make amends, including repayment entries naming stores. In closing argument, defense counsel argued that those entries indicated theft and challenged her explanation of the sheet.
1 mention
Daniela's immigration and government identification documents — The jury instructions described an allegation that Raniere and others knowingly concealed, removed, confiscated or possessed Daniela's immigration or government identification documents. The court explained the elements the Government had to prove beyond a reasonable doubt.
1 mention
Daniela's journal note and self-portrait — The prosecution displayed a journal note expressing Daniela's loneliness and suicidal thoughts alongside a self-portrait depicting herself as a failure. Counsel discussed them while describing the period after her conflict with Raniere.
1 mention
Daniela's requested identification documents — Lauren Salzman identified requested documents in an email as Daniela's identification documents. The message refused to send them while demanding book reports, email account information and her return to Clifton Park.
1 mention
Declaration from the secretary and general counsel accompanying the unofficial RPI transcript — The court noted a declaration from the secretary and general counsel accompanying an unofficial RPI transcript. Defense counsel questioned the transcript's provenance, and the prosecution said RPI had provided it in response to a subpoena.
1 mention
Defendant's ex parte letter, Docket No. 627 — The court reviewed the defense's ex parte letter concerning materials for cross-examination of the Government's first witness. It found the attachments outside Rule 16's disclosure requirements as impeachment evidence, but nevertheless ordered production at the end of direct examination because the distinction from case-in-chief evidence was blurred.
1 mention
Defendant's objections to the PSR dated March 11, 2020 — The court identified the defendant's March 11, 2020 objections to the presentence investigation report among the materials it had reviewed for sentencing.
1 mention
Defendant's sentencing memorandum dated September 19, 2020, including remaining PSR objections — The defendant's September 19, 2020 sentencing memorandum incorporated remaining objections to the presentence report. Counsel said the Guidelines objections began on page 65 and that the defense had nothing to add orally.
1 mention
defense counsel's Daubert motion — At the end of Day 3, the court allowed the Government to respond to the defense's Daubert motion by Monday morning.
1 mention
Defense Exhibit 161 — Sylvie sent Nancy Salzman the August 28, 2012 email about Jness. The court admitted it over objection after foundational questioning during Sylvie's cross-examination on Day 2.
1 mention
Defense Exhibit 174 — The email addresses Jness alongside dietary and training information. The court admitted Defense Exhibit 174 without objection during Sylvie's cross-examination on Day 2.
1 mention
Defense Exhibit 340 — Vicente requested project timelines from his crew in the July 12, 2008 email. The court admitted it without objection during his resumed cross-examination on Day 6.
1 mention
Defense Exhibit 343 — The court directed counsel to show Vicente the questionnaire without characterizing it and then ask whether it refreshed his recollection. The government did not oppose that use but objected to calling the questionnaire typical.
1 mention
Defense Exhibit 605 — The court received the email without objection during Daniela's cross-examination on Day 15.
1 mention
Defense Exhibit 606 — The court admitted the email without objection during Daniela's cross-examination on Day 15.
1 mention
Defense Exhibit 608 — Daniela could not identify the friend mentioned in Kristin's emails. The court admitted Defense Exhibit 608 without objection during her cross-examination on Day 15.
1 mention
Defense Exhibit 609 — The court received the reply without objection during Daniela's cross-examination on Day 15.
1 mention
Defense Exhibit 612 — The court admitted the email without objection during Daniela's cross-examination on Day 15.
1 mention
Defense Exhibit 620 — Daniela identified the two-page email during cross-examination on Day 16, and the court admitted it without objection.
1 mention
Defense Exhibit 621 — Daniela confirmed the email's sender, recipient and date during cross-examination on Day 16. The court admitted it without objection.
1 mention
Defense Exhibit 622 — Daniela identified the email during cross-examination on Day 16, and the court received it without objection.
1 mention
Defense Exhibit 628 — Daniela confirmed that she sent the email during cross-examination on Day 16. The court admitted it without objection.
1 mention
Defense Exhibit 636 — The defense offered the chain to show continued contact rather than the truth of Raniere's statements. The court refused admission but allowed questioning and use to assist recollection; Daniela said she did not remember the exchange.
1 mention
Defense Exhibit 641 — Daniela identified the single-page email during cross-examination on Day 16, and the court admitted it without objection.
1 mention
Defense Exhibit 642 — The defense presented the email during Daniela's cross-examination on Day 16, and the court admitted it without objection.
1 mention
Defense Exhibit 644 — Daniela confirmed the email's sender, recipient and date during cross-examination on Day 16. The court received it without objection.
1 mention
Defense Exhibit 645 — The court admitted the email without objection during Daniela's cross-examination on Day 16.
1 mention
Defense Exhibit 665 — Daniela acknowledged that the short email contained a heart and conveyed her love. The court admitted it without objection during her cross-examination on Day 16.
1 mention
Defense Exhibit 807 — The defense presented the proposed instruction while renewing objections to Hughes's qualifications, testimony scope and notice on Day 18. The court overruled the renewed objection and qualified Hughes, but no separate ruling on the proposed instruction was stated.
1 mention
Defense Exhibit 815 — Hughes identified the document as only part of her contract and used it to recall a $19,000 compensation ceiling during cross-examination on Day 18. She did not testify that this amount had been paid.
1 mention
Defense Exhibit 929 — Nicole acknowledged that the email expressed growing trust, missing Raniere and anticipation of seeing him. The court admitted and published it over the government's objection during cross-examination on Day 20.
1 mention
Defense Exhibit 936 — Nicole acknowledged grateful language in her departure email but described pressure and a wish not to upset anyone. The court sustained the government's objection to admission, although questioning about the email continued.
1 mention
Defense Exhibit 960 — Brian Booth identified the document as an evidence sheet for the Western Digital drive. The court admitted it without objection during his cross-examination on Day 23.
1 mention
Defense Exhibit 961 — Booth reviewed the notes during cross-examination on Day 23 and confirmed that they included photographs taken in the case. He explained that his notes reflected his own access to the camera.
1 mention
Defense filing concerning the objection to Dr. Hughes as an expert — The defense asked to reference its filing when renewing its objection to Dr. Hughes as an expert. The court permitted that reference and a brief continuing objection, but not a speaking objection.
1 mention
Defense letter dated June 9 concerning a good-faith jury instruction — The court identified a June 9 defense letter seeking a good-faith instruction and asked counsel to discuss the request among themselves. The Government confirmed that it had seen the letter.
1 mention
Defense letter requesting a good-faith instruction — The defense requested a good-faith instruction for wire fraud and the intended tax offense. The court agreed to include language addressing those issues but reserved its choice between the parties' proposed wording.
1 mention
Defense letter submissions — The defense letters concerned Lauren Salzman's cross-examination and prosecution rebuttal comments. Counsel maintained that cross-examination had been unfinished when the court stopped it; the court denied the motion, whose precise requested relief was not stated in the exchange.
1 mention
Defense proposed charge concerning the trust — The defense proposed an immediate instruction on evaluating the trust and its legal-fee arrangements. The court agreed to a narrower instruction recognizing that third-party payment of legal fees is permissible, without endorsing every aspect of this particular arrangement.
1 mention
Defense proposed limiting instruction for Dr. Hughes's testimony — The defense requested a limiting instruction alongside Dr. Hughes's testimony, and the Government objected to the proposed wording. The court allowed submission of the proposal for the record but declined a contemporaneous instruction, deferring instructions until the final charge.
1 mention
Defense sentencing memorandum — Defense counsel cited the sentencing memorandum's discussion of the Mexican Peace Initiative while arguing that Raniere had benefited people. Counsel also referenced its account of alleged computer access in responding to the court's questions about litigation against former members.
1 mention
Defense written motion listing Exhibit 1701 among the challenged 1700-series documents — The defense's written motion expressly listed Exhibit 1701 among its hearsay objections to the 1700-series documents. Counsel argued that the exhibit contained Camila's standalone assertion without a response, and the court confirmed that the objection appeared in the motion.
1 mention
Defense-proposed limiting instruction concerning statements made to Mr. Vicente — The defense proposed limiting certain statements to their impact on Vicente rather than their truth. The court settled on individualized instructions addressing his state of mind and the statements' effects, with the prosecution to identify the relevant speakers it did not allege were coconspirators.
1 mention
Degrees of memory of child sex abuse among women survivors in therapy — Hughes acknowledged an article titled Degrees of memory of child sex abuse among women survivors in therapy and identified the underlying work as her dissertation. She agreed that interviews about child sexual abuse in clinical settings cannot be generalized to nonclinical populations.
1 mention
Deposit printout for item 64, with a stated total of $15,670 — Fontanelli identified the deposit printout for item 64 and confirmed a total of $15,670. His examination gave $50,637 for the count form but $15,670 for the deposit records and final summary, without explaining the difference.
1 mention
Direct-examination transcript, page 667, starting at line 20 — The transcript passage contained Vicente's testimony that health benefits were generally accepted within NXIVM, although members were instructed not to make such claims. Defense counsel read it during argument over proposed cross-examination concerning a Tourette's film.
1 mention
Document 137 in the civil case file, which counsel said was on Pacer but not in evidence — The document was identified by its civil-case filing number, 137, during Michael Weniger's cross-examination on Day 24.
1 mention
Document concerning high and low tides in Resurrection Bay — The document addresses high and low tides in Resurrection Bay.
1 mention
Document listing Denny's Restaurant charges for 12/24 and 12/29 — The document lists Denny's Restaurant charges for 12/24 and 12/29.
1 mention
Document used to question Vicente about the date of his first FBI contact — The document was identified as Exhibit 3500-MV-1 during Mark Vicente's resumed cross-examination on Day 6.
1 mention
DOS policies and collateral formulas — Lesko referred to DOS policies and formulas assigning relative weights to collateral during rebuttal closing argument. He contrasted those materials with the SOP recording discussed by the defense.
1 mention
DOS recruitment questionnaires, part of which Salzman had seen — Salzman testified that she had seen at least part of a physical questionnaire in the context of DOS. She understood the recorded discussion of questionnaire levels to concern a proposed game.
1 mention
DX800 — Hughes identified herself as one of the article's three authors during cross-examination on Day 18. She disputed counsel's use of nonclinical terminology and explained that the article referred to people with abuse experiences who were not in treatment.
1 mention
e-mail — Valenziano acknowledged that he was not a party to the e-mail and was not working on the case at the time. Agnifilo then objected to the e-mail; no ruling was recorded in that exchange.
1 mention
E-mail correspondence between Allison Mack and the Defendant concerning India, cited by the Government in support of the commercial-sex nexus — Hajjar cited e-mail correspondence between Allison Mack and Raniere concerning India while opposing the defense's motion to dismiss sex-trafficking allegations for insufficient evidence of commercial sex.
1 mention
E-mail that Penza said attaches nude photographs and was still being located — Penza said the government was still looking for an e-mail that attached nude photographs while preparing evidence to send to the jury.
1 mention
E-mails the defense sought to use during Nicole's cross-examination — Agnifilo argued that additional e-mails would complete the narrative presented during Nicole's direct testimony and show her state of mind at the time. Penza maintained that the government's e-mail chains had been offered for their effect on recipients and objected to the defense's proposed use as hearsay.
1 mention
Edgar Boone's poetry book that Vicente recalled reading and discussing — Vicente recalled reading and discussing Boone's poetry book. He testified that Boone was accused of failing to credit Raniere for ideas in the book, an attribution Vicente disputed because he believed some ideas long predated Raniere.
1 mention
Email from Joe J. O'Hara that the government said it was not seeking to admit — The court identified an e-mail sent by Joe J. O'Hara, and Penza stated that the government was not seeking to admit it.
1 mention
Emails and a memo concerning video projects, including The Never Ending Project — Agnifilo discussed e-mails and a memo concerning video projects during closing argument. He proposed that references to The Never Ending Project concerned digitizing old tapes rather than altering discovery materials.
1 mention
Emails concerning DOS experiences and requests for collateral back — The e-mails concerned negative DOS experiences, alleged false pretenses, and requests for collateral to be returned. The defense raised a confrontation objection to testimony about the statements, while the court stated that it had kept the documents out and would review the testimony before deciding how to respond.
1 mention
Ethos questionnaires described in the production e-mail — A production e-mail read during Valenziano's testimony stated that previously sought Ethos questionnaires had been located and were being provided in the NXIVM litigation.
1 mention
Examples of Jness curriculum among the proposed laptop emails and attachments, which the government said were not offered for their truth — Penza described examples of Jness curriculum among proposed laptop e-mails and attachments and stated that the teachings were not offered for their truth. The defense objected on hearsay grounds, and no final admissibility ruling was recorded in the discussion.
1 mention
Exhibit list — The parties agreed that exhibits could go to the jury before the exhibit list was finalized. The court authorized sending the list afterward once both sides agreed to it.
1 mention
Exhibit showing that Nicole's request for collateral had been forwarded — Nicole recalled seeing in the exhibit that her request for collateral had been forwarded. She also testified that she never received her collateral back.
1 mention
Existing jury instructions, including page 124 on wire fraud and pages 73 and 75 on the fifth element of the identity-theft racketeering act — Counsel consulted page 124 on wire fraud and pages 73 and 75 on the identity-theft racketeering act while debating a jury question about Internet use and interstate commerce. The court adopted a supplemental Internet-use instruction and directed the jury to apply it to the original charge rather than replace that charge.
1 mention
Expert-witness notice for Dr. Hughes — The defense argued that offender behavior and the broader category of coercive relationships exceeded the expert notice's scope. Lesko responded that the notice expressly covered victim-perpetrator dynamics involving abuse, coercion, or dependence.
1 mention
Faculty handbook concerning the voluntary faculty title — Counsel asked Hughes whether the faculty handbook treated voluntary faculty status as a specific title. Hughes acknowledged her voluntary status and explained that her position was unpaid and did not require research or publication.
1 mention
Fake ID Daniela said she used to enter the country — The identification document was described as a fake ID that Daniela said she used to enter the country.
1 mention
Fake Mexican national identification card arranged for Camila to travel by plane within Mexico — Daniela acknowledged arranging a fake Mexican national identification card for Camila. She clarified that it was intended for air travel within Mexico, not departure from the United States, and said the idea was hers.
1 mention
Fake sheriff's identification used for Daniela's border crossing — Penza argued that Daniela used a false sheriff's ID containing another person's identifying information to cross the Canadian border into the United States. She described the card as part of a plan arranged by Raniere and others.
1 mention
False identification card described as a sheriff's ID, bearing Daniela's photograph and another person's name — The card was described as a sheriff's ID bearing Daniela's photograph and another person's name. At a sidebar, the court directed clarification of Daniela's understanding and noted that an employee-ID characterization had not been established on direct examination.
1 mention
False sheriff's ID bearing Daniela's photograph and the name Lisa Chinoa, which she said Kathy Russell supplied for the border crossing. — Daniela testified that Kathy Russell supplied a homemade-looking sheriff's ID bearing Daniela's photograph and the name Lisa Chinoa. She said Raniere devised the border-crossing plan, that she understood Kristin and Siobhan were working on the ID, and that the card was presented to a border agent during the crossing.
1 mention
False sheriff's identification using the name Lisa Chenoa and Ashana Chenoa's birth date — During rebuttal, the government described the false sheriff's identification as using Lisa Chenoa's name and Ashana Chenoa's birth date for Daniela's border crossing. It argued that Raniere directed a plan using a real person's identifying information.
1 mention
FBI report concerning the December 5, 2017 meeting — The report concerned the December 5, 2017 meeting and was identified during cross-examination as Exhibit 3500-MV-5.
1 mention
FBI report recording a 2009 or 2010 date for Raniere's discussion of videotape alterations — The report was described as placing Raniere's discussion of videotape alterations in 2009 or 2010 and was identified as Exhibit 3500-MV-5.
1 mention
Fee agreement signed by the woman presented to Ross as a concerned mother at Interfor — The agreement was described as signed by a woman presented to Ross as a concerned mother at Interfor. Ross said he later learned the proposed intervention was staged, but did not identify how he learned that.
1 mention
Fee card for three summer courses — Alternate No. 4 provided a fee card showing payment for three nondegree summer courses at Queensborough Community College. The court discussed her obligation to serve despite enrolling after jury selection.
1 mention
Forbes article that Daniela recalled containing Edgar Bronfman's characterization of ESP and featuring Keith on the cover — Daniela recalled the article as containing Edgar Bronfman's characterization of ESP and featuring Keith on the cover.
1 mention
Frank Parlato's articles — Herbits tentatively identified Parlato's articles as a possible source of his understanding of litigation involving the Bronfmans. He said he stopped reading them to avoid confusing his memories with newly learned information.
1 mention
Furnace warranty bearing Jelonek's name and the property address, with an unfamiliar telephone number and email address — Jelonek testified that the furnace warranty bore her name and the property address but listed a telephone number and email address unfamiliar to her. She said the furnace had been installed while she was in Florida.
1 mention
General order of forfeiture provided in the docket — The government requested attachment of the docketed forfeiture order, explaining that it allowed amendment pending review of Raniere's financial situation. The court granted the request.
1 mention
Government Exhibit 1005T — The court admitted the transcript during Sylvie's direct examination on Day 2, subject to the defense reviewing its copy and raising issues later.
1 mention
Government Exhibit 1101 — The exhibit contains rental agreements for 120 Victory Way between Sheila Jelonek and Kathy O'Sullivan. Jelonek identified a twelve-month term beginning August 1, 2011, and confirmed that the tenancy continued during 2014 even though she could not locate that year's lease.
1 mention
Government Exhibit 1102 — Jelonek identified the document as the thirty-day notice she delivered to end the tenancy. She later annotated it to memorialize a one-month extension through the end of August, and the court admitted the exhibit.
1 mention
Government Exhibit 1214 — The admitted email correspondence begins in November 2008 with Clare Bronfman asking Steve Herbits about his involvement in resolving a situation. The exchange includes her allegations of prejudice and efforts to damage NXIVM's reputation.
1 mention
Government Exhibit 1244 — The January 15, 2011 email includes a photograph of Daniela after her haircut and was identified during Lauren Salzman's direct testimony on Day 10.
1 mention
Government Exhibit 1267 — The admitted September 10, 2015 email from Rosa Laura Junco to Keith Raniere proposes a schedule and costs for a girls' school program. Weniger said the proposed schedule included the names Lauris and Carlotta.
1 mention
Government Exhibit 1274 — The email references J.K. Rowling's talk The Fringe Benefits of Failure. Nicole testified that she chose a favorite talk after Allison suggested sending Raniere something she cared about.
1 mention
Government Exhibit 1277 — The defense showed Nicole her April 21, 2016 reply to Raniere without displaying it to the jury and questioned her about saying she would not be easily scared away. When the defense offered the email, the court sustained the prosecution's objection without stating a basis.
1 mention
Government Exhibit 1287 — The admitted chain contains correspondence between Nicole and Allison Mack that Mack forwarded to Raniere on October 20, 2016. Mack subsequently described Nicole's unhappiness, listed possible responses ranging from increased control to releasing her from The Vow, and requested guidance.
1 mention
Government Exhibit 1321 — Salzman identified the admitted October 18, 2017 email as a draft position statement Raniere sent to first-line DOS masters. The draft defended the women's branding as consensual expression, asserted separation from NXIVM and Raniere, and criticized members who broke their secrecy vows.
1 mention
Government Exhibit 1327 — The admitted document includes a January 13, 2017 cover email from Rosa Laura Junco to Raniere with eight chapters attached separately. Weniger confirmed that the document was also sent from Raniere's Yahoo account to his ProtonMail address.
1 mention
Government Exhibit 1358 — The admitted July 20, 2016 email from Allison to Nicole links an article-rating document, refers to a Dropbox invitation, and requests daily reports about articles read. Nicole confirmed that she continually reported her review progress to Allison.
1 mention
Government Exhibit 1358 and Government's Exhibit 1360 — During closing argument on Day 26, Penza cited Government Exhibits 1358 and 1360 as examples of article-editing work. She argued that Nicole and Sylvie spent hours reviewing Raniere's articles for potential curriculum use or publication.
1 mention
Government Exhibit 1359 — The admitted July 24, 2016 email from Allison asks Nicole to delete an old article folder after receiving a new link. Nicole recalled that the articles were re-uploaded but did not remember why the replacement was necessary.
1 mention
Government Exhibit 1360 — The admitted July 26, 2016 email from Allison sets August 15 as Nicole's deadline to read, rank, and rate all the articles. Nicole testified that the suggested pace of two articles daily would have required approximately three to six hours.
1 mention
Government Exhibit 1362 — The email between Nicole and Allison concerns the articles and was admitted during Nicole's direct testimony on Day 19.
1 mention
Government Exhibit 1364 — The admitted September 5, 2016 email from Allison to Nicole and India attaches an article Nicole understood Raniere to have written. Nicole identified it as an example of the continuing weekly article-reading assignments associated with their Monday meetings.
1 mention
Government Exhibit 1367 — The admitted email invites Nicole to edit a Dropbox folder labeled collateral. Nicole identified the folder as the place she uploaded collateral and confirmed that monthly collateral had been introduced by November 23, 2016.
1 mention
Government Exhibit 1368 — The admitted November 25, 2016 email from Nicole to Allison Mack lists collateral provided to that point. Nicole testified that Mack required the list to identify whom the collateral damaged and how damaging it was, with a specified submission time.
1 mention
Government Exhibit 1372 — The admitted email from Allison Mack includes a recruitment spreadsheet called Prospects for the lifetime agency. Nicole testified that they were required to enter names of people they considered potentially suitable or interested in joining DOS.
1 mention
Government Exhibit 1377 — Nicole identified the admitted document as a phone note tracking travel spending after Keith asked her to account for money taken from a bag. She explained that its displayed November 27, 2017 date could reflect a later edit rather than the note's creation.
1 mention
Government Exhibit 1396R — During his Day 3 direct testimony, Mark Vicente identified the email as sent by Chris to Nancy Salzman.
1 mention
Government Exhibit 1398 — The two-page document was described as a transcription or summary of Raniere's film-concept conversation with Vicente. Vicente could not identify whether he or Pam Cafritz created it and did not recall reviewing it when created, but believed it accurately reflected or summarized the conversation. The court admitted it over objection.
1 mention
Government Exhibit 1403 — Salzman sent Raniere her edited Chapter 1 of the DOS book for review and requested feedback. She identified the attachment during her Day 9 testimony, and the court received the exhibit without objection.
1 mention
Government Exhibit 1427 — Clare requested help understanding her responsibilities and sought business instruction and advice. Raniere's response referred to being enslaved for eternity and asked what she wanted to achieve in her life.
1 mention
Government Exhibit 1429 — Clare described damage she believed she had caused and asked Raniere for help repairing it. His response said healing must come from her and her father and suggested seeking further instruction from Michelle or Nancy.
1 mention
Government Exhibit 1433 — The correspondence includes Edgar Bronfman's letter to Clare and her proposed response. Nancy Salzman forwarded the communications to Raniere.
1 mention
Government Exhibit 1435 — The email introduces its sender as Keith Raniere and gives the kunterre email address. Michael Weniger testified that the account bore Karen Unterreiner's name but was used by Raniere.
1 mention
Government Exhibit 1443 — Nancy Salzman forwarded Raniere a message in which Edgar Bronfman questioned the group's financial arrangements, lengthy sessions and leadership titles. Weniger testified that Nancy was guiding Clare's relationship with her father.
1 mention
Government Exhibit 1455 — During his Day 23 direct testimony, Michael Weniger identified the email as a message in which Clare discussed her father and said she had met with him.
1 mention
Government Exhibit 1457 — Michael Weniger identified the email during his Day 23 direct testimony as another message in which Clare reported to Raniere regarding her father.
1 mention
Government Exhibit 1463 — Fontanelli confirmed that the document was recovered from the Apple laptop displayed in court, and Penza described it as already in evidence.
1 mention
Government Exhibit 1464 — Fontanelli confirmed that the document was recovered from the Apple laptop displayed in court, and Penza described it as already in evidence.
1 mention
Government Exhibit 1465 — Fontanelli confirmed that the document was recovered from the Apple laptop displayed in court, and Penza described it as already in evidence.
1 mention
Government Exhibit 1466 — Fontanelli confirmed that the document was recovered from the Apple laptop displayed in court, and Penza described it as already in evidence.
1 mention
Government Exhibit 1467 — Fontanelli confirmed that the document was recovered from the Apple laptop displayed in court, and Penza described it as already in evidence.
1 mention
Government Exhibit 1472 — Fontanelli confirmed that the document was recovered from the Apple laptop displayed in court, and Penza described it as already in evidence.
1 mention
Government Exhibit 1482 — Weniger described searching contributor names and a selected timeframe on the Federal Election Commission website. He reviewed results showing multiple $2,300 contributions to Hillary Clinton's campaign.
1 mention
Government Exhibit 1483 — The forms list bill denominations, quantities and totals for cash from two shoeboxes and a bedroom bag, counted on March 28, 2018. Fontanelli read $50,637 for the UGG shoebox count form, while its deposit records and the final summary used $15,670; his examination did not explain the difference.
1 mention
Government Exhibit 1483-12 — Fontanelli read the printout as identifying Bank of America U.S. Treasury in Lindhurst as the destination for the $109,727 deposit. He had not personally made the deposit.
1 mention
Government Exhibit 1483-13 — The summary lists $109,727 from a bag, $15,670 from an UGG shoebox and $390,180 from a larger shoebox. Fontanelli identified their total, $515,577, as the amount seized during the search. His earlier testimony gave $50,637 for the UGG shoebox count form, and the difference remained unexplained.
1 mention
Government Exhibit 1483-7 — On Day 8, Fontanelli identified the slip as showing $109,727, matching the currency count form for cash found in a bedroom bag.
1 mention
Government Exhibit 1483-8 — During his Day 8 direct examination, Fontanelli read the document's combined total for the four bags as $390,180.
1 mention
Government Exhibit 1483-9 — Fontanelli identified the already-admitted slip as the deposit record for item 64 and read its amount as $15,670. His earlier reading of the corresponding count form gave $50,637, and the examination did not explain the difference.
1 mention
Government Exhibit 1489R — The email was addressed to the family group and was identified during Lauren Salzman's direct testimony on Day 10.
1 mention
Government Exhibit 1491 — Weniger confirmed that the exhibit included Clare Bronfman sending the defendant a draft response. The court admitted the exhibit during his direct testimony on Day 23.
1 mention
Government Exhibit 1492 — The court admitted the exhibit during Weniger's direct testimony. Weniger described the email group as largely exchanges between Herbits and Clare Bronfman, often including or being forwarded to the defendant for guidance.
1 mention
Government Exhibit 1493 — The court admitted the exhibit during Weniger's direct testimony. Weniger described the email group as largely exchanges between Herbits and Clare Bronfman, often including or being forwarded to the defendant for guidance.
1 mention
Government Exhibit 1494 — The court admitted the exhibit during Weniger's direct testimony. Weniger described the email group as largely exchanges between Herbits and Clare Bronfman, often including or being forwarded to the defendant for guidance.
1 mention
Government Exhibit 1495 — The court admitted the exhibit during Weniger's direct testimony. Weniger described the email group as largely exchanges between Herbits and Clare Bronfman, often including or being forwarded to the defendant for guidance.
1 mention
Government Exhibit 1496 — The court admitted the exhibit during Weniger's direct testimony. Weniger described the email group as largely exchanges between Herbits and Clare Bronfman, often including or being forwarded to the defendant for guidance.
1 mention
Government Exhibit 1497 — Salzman identified the following pages as her plan describing the damage she believed she had caused and how she intended to correct it, and she connected the email to volleyball. The court admitted and published the exhibit without defense objection on Day 8.
1 mention
Government Exhibit 1498 — The letter concerned a company work project and was discussed during Lauren Salzman's direct testimony on Day 10.
1 mention
Government Exhibit 1514-A — The underlying email came from Leonardo Icaza and was associated by Daniela with her early search for someone who could obtain an account password.
1 mention
Government Exhibit 1517 — The November 6, 2005 email included an image attachment that Daniela associated with software-embedding tests.
1 mention
Government Exhibit 1519 — The November 7, 2005 email was discussed during Daniela's direct testimony on Day 13.
1 mention
Government Exhibit 1520 — Daniela sent herself the November 7, 2005 email to collect research on masking senders and deleting messages.
1 mention
Government Exhibit 1521 — The email chain was forwarded through Loretta Garza to Daniela and was discussed during Daniela's direct testimony on Day 13.
1 mention
Government Exhibit 1522 — Daniela sent herself the November 24, 2005 email, which was discussed during her direct testimony on Day 13.
1 mention
Government Exhibit 1523 — The December 17, 2005 message was an email Daniela sent herself and discussed during her direct testimony on Day 13.
1 mention
Government Exhibit 1525 — The exchange concerned obtaining software without a traceable purchase. Government Exhibit 1525-A provides its translation.
1 mention
Government Exhibit 1525-A — The underlying exchange with Farouk Rojas concerned obtaining software without a traceable purchase.
1 mention
Government Exhibit 1526 — Daniela initially associated the attachment with successful deployment, then said it might instead be an infected test file. Her identification remained tentative.
1 mention
Government Exhibit 1529 — Daniela sent the June 26, 2007 email to an address used by Keith with the subject “About VC.” She explained that the message warned about Camila's phone alarm reminding her to take a birth-control pill.
1 mention
Government Exhibit 1532 — The June 10, 2008 chain discussed alleged damage and sexual details and was addressed during Daniela's direct testimony on Day 14.
1 mention
Government Exhibit 1533 — The thread invoked The Mission as an example of resolving an ethical breach and was discussed during Daniela's direct testimony on Day 14.
1 mention
Government Exhibit 1534 — The June 11, 2008 thread discussed alleged damage to Keith, ESP and Daniela's work.
1 mention
Government Exhibit 1535 — The June 10–11, 2008 chain also addressed sexual questioning and perceptions of imposed consequences.
1 mention
Government Exhibit 1536 — The June 11–12, 2008 chain discussed how Daniela's behavior appeared to Ben.
1 mention
Government Exhibit 1537 — The June 17–18, 2008 chain addressed what others knew and a plan with talking points for Ben.
1 mention
Government Exhibit 1538 — The chain ended June 21, 2008 and also discussed recovery of deleted chat histories.
1 mention
Government Exhibit 1540 — Daniela identified the exhibit as an email chain between herself and the defendant from early November 2008. The chain contained a key-log report and an anniversary reference.
1 mention
Government Exhibit 1555 — The November 27–28, 2008 exchange also addressed a monk-like life and was discussed during Daniela's direct testimony on Day 14.
1 mention
Government Exhibit 1556 — In the November 28, 2008 exchange, Daniela disputed Keith's characterization of her isolation.
1 mention
Government Exhibit 1557 — The thread also discussed the effect of Daniela's conduct on her family and was addressed during her direct testimony on Day 14.
1 mention
Government Exhibit 1562 — The exchange discussed perceptions that Keith had imprisoned Daniela and was addressed during her direct testimony on Day 14.
1 mention
Government Exhibit 1563 — The continuation discussed whether later monk-like behavior would appear coerced and was addressed during Daniela's direct testimony on Day 14.
1 mention
Government Exhibit 1570 — The email was forwarded to Adrian on October 23, 2017, and was identified during Daniela's direct testimony on Day 15.
1 mention
Government Exhibit 1571 — The email was forwarded to Adrian on October 19, 2017, and was identified during Daniela's direct testimony on Day 15.
1 mention
Government Exhibit 1572 — The email was forwarded to Adrian on October 19, 2017, and was identified during Daniela's direct testimony on Day 15.
1 mention
Government Exhibit 1575 — The July 22, 2009 email from Keith has the subject line Final and includes disclosure and reporting instructions. It was identified during Daniela's direct testimony on Day 14.
1 mention
Government Exhibit 1577 — The email was forwarded to Adrian on October 23, 2017, and was identified during Daniela's direct testimony on Day 15.
1 mention
Government Exhibit 1590 — The August 29, 2005 email from Kristin Keefe to Daniela copies Nancy Salzman and reports on legal matters and investigative activities.
1 mention
Government Exhibit 1592 — Daniela identified the exhibit as an early November 2008 email chain between herself and the defendant. The correspondence discusses key logs and difficulty arranging travel to check an account safely.
1 mention
Government Exhibit 1593 — The February 19, 2007 email has the subject Update-O and reports on reality checks, a book report and proposed consequences.
1 mention
Government Exhibit 1594 — The email exchange with Lauren Saltzman discusses consequences, walking and returning to Mexico.
1 mention
Government Exhibit 1595 — The email contains a 17-page, single-spaced book report concerning Stephen Wolfram's work.
1 mention
Government Exhibit 1596 — The May 4, 2008 check-in email records fasting and daily weights and includes a report on The Art of Systems Thinking.
1 mention
Government Exhibit 1600 — The December 9, 2008 email exchange concerns Daniela's request for friendship without sex.
1 mention
Government Exhibit 1603 — The March 1, 2009 email includes Keith's bracketed responses to Daniela's expressed wish for independence.
1 mention
Government Exhibit 1604 — The May 2009 email chain discusses fasting, weight, the term tubby and Daniela's use of Benadryl.
1 mention
Government Exhibit 1608 — The June 24, 2009 email connects vulnerability and love with providing photographs.
1 mention
Government Exhibit 1609 — The June 2009 email requests pictures with meaning behind them.
1 mention
Government Exhibit 1610 — The email was forwarded to Adrian on October 19, 2017, and was identified during Daniela's direct testimony on Day 15.
1 mention
Government Exhibit 1612 — The March 1, 2009 email expresses Daniela's wish for education, work, self-sufficiency and a life apart from Keith.
1 mention
Government Exhibit 1613 — The June 27, 2009 email discusses pictures that would show Daniela's face and private parts together.
1 mention
Government Exhibit 1614 — The email was forwarded to Adrian on October 19, 2017, and was identified during Daniela's direct testimony on Day 15.
1 mention
Government Exhibit 1702 — The June 4, 2008 email from Camila's account included apparent scans of a Mexican passport and border-crossing identification card. Rees testified that both documents showed her date of birth and that the passport was issued on May 23, 2008.
1 mention
Government Exhibit 1797R — Vicente identified a memo bullet about duplicating tapes Keith requested as referring to extracting material from intensive tapes. He described initially understanding the project as patent-related and later learning that the material was for discovery in an actual case.
1 mention
Government Exhibit 1801 — In the March 5, 2017 exchange, Valerie offered to check her email at 4:00 a.m. and respond to a nighttime text. Raniere replied that he would text her and meet outside, likely around 4:15 a.m. or later.
1 mention
Government Exhibit 1803 — The March 4, 2016 correspondence includes Raniere asking for news about India in response to Mack's email about The Source money. Mack reported that India had changed her flight despite financial concerns and should contact him about meeting again to complete an assignment.
1 mention
Government Exhibit 1805 — Raniere asked whether India knew she was to undress while he remained clothed and let him take a revealing photograph with her phone for immediate transmission to Mack as proof. Weniger confirmed that Mack responded enthusiastically and that the exchange preceded the flight-change email by one day.
1 mention
Government Exhibit 1817 — Mack's November 23, 2016 email directed recipients to upload monthly collateral to a shared Dropbox folder, label it with their initials and submission date, and notify her immediately. She instructed them not to use other submission methods and said she would download the material to a secure external drive.
1 mention
Government Exhibit 1818 — Mack's November 24, 2016 collateral questionnaire requested information by 7:00 p.m. the following day. The examination compared it with The Game and placed it a little more than a month after Rosa Laura Junco sent that document to Raniere.
1 mention
Government Exhibit 1824 — Harrington identified the warrant copy during his direct testimony on Day 22. The court admitted it without objection.
1 mention
Government Exhibit 1826 — Harrington identified subscriber records listing a name, birth date, and alternate contact information for the account. The court admitted the exhibit after the government agreed to a small redaction requested by the defense.
1 mention
Government Exhibit 1828 — Mack's March 4, 2016 email described a sexual encounter and feelings of vulnerability. Weniger identified Raniere as a recipient and said he believed the other recipient was Daniela Padilla.
1 mention
Government Exhibit 204, 204A, 1399, 1401, 1463 through 1469, and 1472 — Defense counsel noted earlier hearsay and reliability objections, including the absence of a witness, without renewing them. The court confirmed that it had overruled those objections and admitted the identified exhibits on Day 7.
1 mention
Government Exhibit 356 — Salzman identified the contract during direct testimony on Day 9. The court admitted both Exhibit 356 and its redacted version, Exhibit 356R, without objection.
1 mention
Government Exhibit 356R — Salzman described the February 10, 2017 agreement as providing for $1 million in nondisclosure damages, assignment of Audrey's property, permission to release her collateral publicly, and a liability waiver concerning DOS participation. She identified listed property including a car, bank funds, retirement accounts, and home furnishings.
1 mention
Government Exhibit 357R — Salzman identified the redacted spreadsheet as a list of DOS members enrolled when it was prepared and discussed enrollment dates shown beside names. She explained that yellow highlighting indicated members who had supplied secrecy collateral but not the second collateral required for the vow.
1 mention
Government Exhibit 358 — Salzman explained that the chart listed first-line DOS masters, enrollment counts below them, and readiness reporting by line. It distinguished Raniere's formal readiness group from drills that also included people being prepared to join it.
1 mention
Government Exhibit 359 — Salzman said she kept the chart on her phone to remember whom she had to check on when members failed to respond during readiness drills. She believed the displayed copy came from her phone.
1 mention
Government Exhibit 365 — The records include a listing describing a full basement at 9 Milltowne Drive, a maintenance notice addressed to Stinka, LLC, and sale documents bearing signatures Fontanelli identified as Nicole Clyne's.
1 mention
Government Exhibit 368 — The deed is dated October 25, 2018, and transfers the property from Stinka, LLC to another individual. Fontanelli identified Nicole Clyne's signature and confirmed that she signed as a member.
1 mention
Government Exhibit 369 — The deed is dated April 14, 2017, and identifies Stinka, LLC as the purchaser. It lists the company's address as 9 Milltowne Drive in Waterford, New York.
1 mention
Government Exhibit 370 — The deed is dated April 2, 2014. Fontanelli confirmed that it lists Rosa Laura Junto's residence as 21 Oregon Trail in Waterford, New York.
1 mention
Government Exhibit 371 — The document lists 557 Englemore Road in Clifton Park, New York, as the address to which the Department of State would mail process on behalf of Stinka, LLC.
1 mention
Government Exhibit 373 — Bronfman's message described the photograph as showing Bouchey's appearance about eight months earlier. A forward to Alejandro Betancourt characterized it as the most recent information on Bouchey.
1 mention
Government Exhibit 374 — Weniger confirmed that the photograph showed a January 18, 2016 timestamp and appeared to depict Keeffe unaware she was being photographed. He dated the email to May 29, 2017, and believed Keeffe had left the NXIVM community in 2014.
1 mention
Government Exhibit 376 — The May 8, 2017 email from Clare Bronfman to Ricardo Olmedo Gaxiola described an older photograph and noted Natalie's naturally dark hair. A forward to Alejandro Betancourt said her hair could be blonde or dark.
1 mention
Government Exhibit 414 — Salzman said she asked Charmel to hold Audrey's property rather than take it personally because she perceived a conflict of interest. The court admitted the paperwork and companion Exhibit 414R without objection on Day 9.
1 mention
Government Exhibit 414R — Salzman identified the authorization, said she witnessed it, and testified that she understood it to have added a signatory to the account.
1 mention
Government Exhibit 425R — Salzman did not recognize the specific first page but identified subsequent pages as Audrey's tracking materials and said the first page likely tracked enrollment stages. The court admitted the exhibit after defense review and a statement of no objection.
1 mention
Government Exhibit 426 — Salzman testified that she sent the February 10, 2017 email with Keith's edited version attached and invited Nicki and Rosa Laura to discuss his comments.
1 mention
Government Exhibit 427 — Salzman testified that Keith added and removed words and highlighted his changes to guide her editing of the rest of the book.
1 mention
Government Exhibit 428 — The court barred admission of Exhibit 428 and two companion emails because they contained specific accusations against Raniere. It permitted questions about collateral-return demands and allowed the documents to refresh recollection if needed.
1 mention
Government Exhibit 428-R — Salzman dated Kristin's collateral-return email to the end of September 2017. The email was shown to refresh her recollection, not admitted during this examination.
1 mention
Government Exhibit 436 — Salzman's drawings presented the DOS brand as representing Bar Alpha Mu, the four elements, seven chakras, and other symbolism rather than Raniere's initials. She identified all these explanations as false, and the court admitted the drawings.
1 mention
Government Exhibit 444 — Jay identified the exhibit as a multipurpose journal combining personal writing with assignments from The Vow. She explained that a passage about her mother was punishment journaling assigned after she exceeded her calorie limit and incorporated India's explanation.
1 mention
Government Exhibit 446 — The four-page set of Dropbox and collateral-related materials sent by J was discussed during Mark Vicente's direct testimony on Day 6.
1 mention
Government Exhibit 447 — The court admitted the Spanish-language letter subject to connection through J's testimony and said it would strike the document without that connection. The connecting testimony did not occur during Mark Vicente's Day 6 examination.
1 mention
Government Exhibit 447, pages 1, 2, 4 and 5 — The correspondence asserted that Mexican authorities had issued directives against Jay and warned of possible enforcement measures, including arrest. The court admitted pages 1, 2, 4 and 5 of the replacement five-page exhibit, not page 3.
1 mention
Government Exhibit 502 — Mills identified the photo log as listing photograph numbers and the locations where the photographs were taken. The court admitted it without objection during his direct testimony on Day 20.
1 mention
Government Exhibit 505-A — Booth confirmed that the large paper document reproduced the AD Lab report on the disc marked Government Exhibit 505, which concerned bookmarked material from the Studies folder.
1 mention
Government Exhibit 511 — The email concerning The Art of Systems Thinking was displayed during Daniela's cross-examination on Day 15.
1 mention
Government Exhibit 539 — Butler identified the exhibit as a copy of Camila's medical records from McGinnis Women's Medical Care. The court admitted the records over the defense's renewed objection on Day 16.
1 mention
Government Exhibit 539-11 — Butler identified Pamela Cafritz as Camila's emergency contact when discussing the registration form during her direct testimony on Day 16.
1 mention
Government Exhibit 539-22 — Butler confirmed that the May 19, 2008 entry documented no domestic violence, no STD or HIV risk, and certainty about terminating the pregnancy.
1 mention
Government Exhibit 539-24 — Butler confirmed that the May 14, 2008 record documented no domestic violence, no STD or HIV risk, and a wish to terminate the pregnancy.
1 mention
Government Exhibit 539-25 — Butler confirmed that the May 14 note documented a significant other's awareness of the pregnancy, a denial of nonconsensual activity, a wish to terminate, and an extended review of options.
1 mention
Government Exhibit 540 — Butler identified Pamela Cafritz in Daniela's nearest-relative field, and the court admitted Daniela's medical records over the defense's renewed objection on Day 16.
1 mention
Government Exhibit 549-68 — Counsel showed the call notes with page 69 during Butler's direct testimony on Day 16 and described them as already in evidence.
1 mention
Government Exhibit 549-69 — The call notes were shown with page 68 during Elizabeth A. Butler's direct examination on Day 16, and counsel described them as already in evidence.
1 mention
Government Exhibit 549, page 9 — Butler read entries stating that Daniela lived in Mexico, was visiting for two to three months, was considering college in the United States, and reported one lifetime partner. Those entries reflected the medical history recorded on the form, not independently verified facts.
1 mention
Government Exhibit 609 — The report was identified during Rick Alan Ross's direct examination on Day 22.
1 mention
Government Exhibit 610 — The analysis was identified during Rick Alan Ross's direct examination on Day 22.
1 mention
Government Exhibit 611 — The document was identified during Rick Alan Ross's direct examination on Day 22.
1 mention
Government Exhibit 620 — Ross traced the critical reports discussed during his Day 22 testimony to Franco's notes.
1 mention
Government Exhibit 652 — Nicole confirmed that Mack sent her Padilla's email address and phone number on February 28, 2017. The email was published during Nicole's direct examination.
1 mention
Government Exhibit 656 — Nicole said Raniere drafted most of the message she sent to Robbie under her Sam Suite persona, with minor changes from her. The court admitted the chain without objection and ordered it published to the jury.
1 mention
Government Exhibit 660 — Nicole identified the document as an example of the signed credit-card authorizations she uploaded as monthly collateral for Allison Mack. The court admitted it without objection.
1 mention
Government Exhibit 661 — Nicole identified the document as an example of the signed credit-card authorizations she uploaded as monthly collateral for Allison Mack. The court admitted it without objection.
1 mention
Government Exhibit 662 — The December 18, 2016 authorization gave Mack permission to use Nicole's Virgin America Visa and assigned Nicole responsibility for all charges. Nicole identified it as uploaded collateral and confirmed that she provided the account information, which was redacted in the displayed document.
1 mention
Government Exhibit 663 — Nicole identified the document as an example of the signed credit-card authorizations she uploaded as monthly collateral for Allison Mack. The court admitted it without objection.
1 mention
Government Exhibit 667 — Nicole said Mack requested the contracts around March or April 2017 as monthly collateral, but she never signed them. The contracts included a risk waiver, a publishing agreement, nondisclosure and noncompete provisions, and a property-transfer agreement; the court admitted and published them without objection.
1 mention
Government Exhibit 704 — Guerci identified the documents as certified bank records for the trust. The court admitted Exhibit 704 without objection, but it was not published because it needed redactions.
1 mention
Government Exhibit 722-2 — During cross-examination, Guerci confirmed that the statement showed the earlier account number ending 2-41004. Counsel compared that number with the later number ending 42002 used in Guerci's charting.
1 mention
Government Exhibit 723 — The supplemental production contained three checks and a certificate of authenticity, and the court admitted it without objection. Guerci described checks payable to American Express from Cafritz's KeyBank account, signed by Raniere, including $12,546.70 dated November 23, 2016 and $1,265.68 dated December 29, 2016.
1 mention
Government Exhibit 761-A — The statement listed a $44.50 Sunoco transaction in Little Falls on December 4, 2004 and a $26.36 Sunoco transaction in Clifton Springs on December 24, 2004. Guerci clarified that he reviewed Exhibit 761-A but did not prepare it.
1 mention
Government Exhibit 803 — The two-page exhibit included a State of Alaska certification and the license, which listed April 11, 1978 as Chenoa's birth date. The court admitted and published the exhibit during Guerci's direct examination.
1 mention
Government Exhibit 804 — The certificate listed January 2, 2003 as Chenoa's death date and April 11, 1978 as her birth date. Guerci read the stated cause of death as head and neck injuries that appeared to have resulted from an automobile crash.
1 mention
Government Exhibit 805 — Guerci confirmed that the obituary reported Chenoa's death in a car accident in Portland, Oregon and listed April 11, 1978 as her birth date. The court admitted and published the exhibit.
1 mention
Government Exhibit 852 — Welch identified Exhibit 852 within a group of website order records maintained in XR LLC's regular course of business. The court admitted the group without objection on Day 8.
1 mention
Government Exhibit 855 — Welch identified the product as a $159 device worn around the neck. The website advertised tone, vibration, and 15 levels of static stimulation; the court admitted the description and authorized its publication.
1 mention
Government Exhibit 856 — Welch confirmed that the descriptions in the group containing Exhibit 856 fairly and accurately represented products depicted on the websites. The court admitted the exhibit without objection and authorized publication on Day 8.
1 mention
Government Exhibit 857 — The website described a platform and crisscrossed rubber straps designed to tighten around a person under their body weight. Its description cautioned about installation and weight-bearing capacity and disclaimed warranties or assurances of suitability or safety; the court admitted the exhibit and authorized publication.
1 mention
Government Exhibit 858 — The website description advertised leather cuffs attached to a suspension bar designed to hang from a ceiling or supportive frame, and Welch matched the kit to the fourth item on the invoice.
1 mention
Government Exhibit 860 — Welch identified the advertised sling as the sixth item on the first invoice, priced at $79.95, and read its description of adjustable padded wrist cuffs and thigh restraints.
1 mention
Government Exhibit 861 — The website description advertised seven adjustable body straps, which Welch identified as the last item on the first invoice, priced at $29.95.
1 mention
Government Exhibit 862 — Welch identified the description as part of a group matching products on the second invoice, Government Exhibit 853, and the court admitted Exhibit 862 without objection.
1 mention
Government Exhibit 863 — Welch matched the advertised collapsible steel cage to the second item on the second purchase order and read its description of three separately accessible doors and upright or horizontal positioning.
1 mention
Government Exhibit 864 — Welch identified the product as the third item on the second purchase order and read its description of a tail-shaped anal plug with remote control and five vibration modes.
1 mention
Government Exhibit 864 and Government Exhibit 863 — During closing argument on Day 26, the prosecution cited the exhibits while discussing equipment for a dungeon and described them as examples of items Daniela Padilla bought for the defendant.
1 mention
Government Exhibit 865 — Welch matched the product to the fourth item on the second invoice and read its description of a muzzle-style mask with uncovered eyes, three adjustable straps and a removable ball gag.
1 mention
Government Exhibit 866 — Welch identified the kit as the final item on the second purchase order and read its description of under-the-bed nylon straps with adjustable padded wrist and ankle restraints.
1 mention
Government Exhibit 905 — The court admitted the newsletter copy during Daniela's direct testimony on Day 15.
1 mention
Government Exhibit 906 — The court admitted the newsletter translations during Daniela's direct testimony on Day 15.
1 mention
Government Exhibit 907-105 — Daniela identified her handwriting and the September 30, 2010 date when the letter was displayed on Day 15. She confirmed that the attached plan addressed a job, personal growth and fixing ethical breaches.
1 mention
Government Exhibit 907, page 109 — The handwritten plan attached to Daniela's letter to Keith lists stores and repayment entries. Daniela acknowledged her handwriting but did not confirm the alleged store thefts, explaining that the list could contain exaggerated entries.
1 mention
Government Exhibit 908 — During her Day 11 direct testimony, Salzman explained that the email's forwarding header reflected her practice of forwarding and printing exchanges with Daniela from her time in the room and keeping them with Daniela's letters.
1 mention
Government Exhibit 910-T — The transcript accompanied playback during Daniela's Day 15 direct testimony. The court instructed that the recording itself was evidence and controlled over any difference in the transcript, which served only as a jury aid.
1 mention
Government Exhibit 924 — During Daniela's Day 15 direct testimony, the court admitted the journal pages and drawings after the defense withdrew its objection.
1 mention
Government Exhibit 924-3 — During her Day 15 direct testimony, Daniela confirmed that she experienced the feelings described on the journal page before entering the room.
1 mention
Government letter containing a motion in limine — The court asked whether the defense intended to raise matters covered by the government's motion during cross-examination. Defense counsel sought a compromise and promised an answer by 7 p.m.
1 mention
Government letter responding to the defense's good-faith request — The government offered good-faith language specific to wire fraud and the intended tax offense while opposing a generalized instruction. The court agreed to include language for those two issues but reserved its wording.
1 mention
Government sentencing memorandum addressing the 3553(a) factors — Hajjar described the memorandum as a lengthy submission addressing the Section 3553(a) factors. She declined to repeat those arguments during her oral sentencing presentation.
1 mention
Government sentencing memorandum discussing Raniere's recorded telephone statement — Agnifilo argued that the memorandum omitted qualifying language from Raniere's recorded telephone statement about the judge being watched, including a reference to Alan Dershowitz. The call was discussed rather than played, and no placement decision was stated.
1 mention
Government-submitted verdict sheet — The court directed a change to the verdict sheet's description of Racketeering Act Six. The revised wording would refer to conspiracy to alter records for use in an official proceeding rather than conspiracy to obstruct justice.
1 mention
Government's letter filed under seal concerning the protected-name procedure — The government proposed protecting certain individuals' last names while using full names for others. The defense objected that the distinctions and terminology reflected the government's sex-trafficking theory.
1 mention
Government's response to the defendant's sentencing memorandum dated October 9, 2020 — The court listed the government's October 9, 2020 response to the defendant's sentencing memorandum among the materials it had reviewed for sentencing.
1 mention
Government's responses to the defendant's PSR objections dated March 25, 2020 — The court included the government's March 25, 2020 responses to the defendant's presentence-report objections in its list of materials reviewed for sentencing.
1 mention
Government's sentencing memorandum dated August 27, 2020 — At the sentencing hearing, the court named the government's August 27, 2020 sentencing memorandum among the submissions it had reviewed.
1 mention
Guerci's schedule concerning the trust created by Ms. Bronfman to pay defense legal expenses — During redirect examination, Guerci confirmed that he had prepared a schedule related to the trust created by Ms. Bronfman to pay defense legal expenses.
1 mention
Handwritten editing instructions with time codes and words surrounding the requested cuts — The instructions were described as handwritten directions listing time codes and words surrounding requested cuts.
1 mention
Handwritten legal-investigation notes from the recovered box — Pages of handwritten notes from a box recovered at Nancy Salzman's house discussed proposed subpoenas and records concerning Ross. Weniger said he could not determine whether the handwriting was Kristin Keeffe's, despite her apparent control over some documents in the box.
1 mention
Hard copy of the Forbes article approved for the government's demonstrative use, without admission of the article — The government proposed using a hard copy of the Forbes article for demonstrative purposes without admitting the article itself. The court approved that limited use.
1 mention
Hector's letter supporting Mr. Raniere and criticizing Daniela — Hector's letter praised Raniere's help with a marathon and accused Daniela of lying and stealing. The court rejected the letter's criticism of Daniela and described the letter as disgraceful.
1 mention
Herbits's seven-page memo recommending a public relations approach — Herbits testified that he wrote a seven-page memo after reviewing documents and recommended promoting NXIVM's merits rather than pursuing litigation before the planned Dalai Lama visit. The court permitted questioning after finding no privilege at that point, based on representations about third-party distribution and the absence of a privilege assertion by Clare Bronfman.
1 mention
Income tax returns Loperfido prepared for companies and individuals, including Nancy Salzman and, he believed, Pam Cafritz — The returns were described as ones Loperfido prepared for companies and individuals, including Nancy Salzman and, he believed, Pam Cafritz.
1 mention
India's statement letter describing Nicki and Allison Mack as a couple and praising their wedding ceremony — Jay described finding India's letter among collateral in a Dropbox folder. She said the letter praised Nicki and Allison Mack as a couple and their wedding ceremony, but she did not know them to be genuinely married.
1 mention
Initial intensive questionnaire and the survey Vicente later found while researching narcissistic personality disorder — Vicente qualified the questionnaire comparison as almost exact. The court permitted testimony about his evolving understanding as a fact witness, while the prosecution expressly did not offer him as an expert on the questionnaire.
1 mention
Initial investor-visa application that Sylvie said was abandoned after a response finding insufficient supporting evidence — Sylvie believed Clare and the lawyers submitted an initial application that drew a response finding insufficient evidence of her visa eligibility. She said the visa effort was then abandoned and that she had retained ownership of her horse.
1 mention
Intake forms and written disclosures of personal secrets in a Level 2 intensive — Vicente discussed written personal-secret disclosures while describing education that encouraged revealing secrets. He distinguished his later criticisms from his initial belief in the program.
1 mention
Interim report on Peter Skolnik dated August 27, 2009 — The report was displayed during Weniger's redirect examination on Day 24, and he confirmed that it reflected the date August 27, 2009.
1 mention
Interview transcripts Jay was required to prepare, which she believed were for Pamela Cafritz's memorial — Jay testified that she was required to prepare transcripts she believed were for a memorial. She said the work took several hours and that she was not paid.
1 mention
January 2016 letter to Nancy Salzman and the executive board expressing concerns about the company — Vicente said he sent Nancy Salzman and the executive board a January 2016 letter listing concerns about the company. In describing his letters, he cited poor treatment of people, devotion to Raniere and fear of senior members, and said his criticism was largely ignored.
1 mention
January 2016 letter to Nancy Salzman expressing concerns about the company — Vicente distinguished the letter sent to Nancy Salzman alone from another sent to her and the executive board. In discussing the letters, he described a gap between the company's humanitarian claims and its treatment of people, and said his concerns were largely ignored.
1 mention
Jay's card to Keith — Agnifilo characterized Jay's card to Keith as affectionate while acknowledging her testimony that she had written strategically. He argued that she might nevertheless have meant some of its sentiments.
1 mention
John Hochman's report — Ross said Hochman's report followed a proposal to obtain outside opinions about the training. He did not recall a 2006 cease-and-desist letter directing its removal and testified that the report remained on his website.
1 mention
Joint defense agreement — The court allowed Diaz or Agnifilo to request a sidebar before Lauren Salzman answered a question potentially covered by the joint defense agreement. The procedure was intended to resolve privilege questions before an answer entered the public record.
1 mention
Journal entries on topics assigned by India — Jay testified that she wrote journal entries at India's request and that India selected the topics.
1 mention
Judge Scanlon's decision — The court said it would review Judge Scanlon's decision while considering the scope of asserted privilege. The government said it had seen a redacted version that did not address every potential topic of Lauren Salzman's examination.
1 mention
Jury note announcing that deliberations had concluded and a verdict had been reached — On Day 28, the court read the jury's note announcing that deliberations had concluded and a verdict had been reached. The court then directed that the jury and alternates be brought in.
1 mention
Jury note requesting paperwork — The court read the jury's request for paperwork on Day 28 and proposed responding immediately by delivering the materials. The court also said it would verify corrections before sending the written charge to the jury.
1 mention
Kathy Russell's accounting working papers, including supporting bills and ledger sheets — Loperfido described Russell's working papers as excellent and said she supplied bills and ledger sheets to substantiate profit-and-loss entries. He distinguished his praise of her thoroughness from his assessment of her honesty, which he questioned.
1 mention
Kathy Russell's credit-card receipt for gas in Clifton Springs, New York — Agnifilo cited the gas receipt as evidence that Russell was in the region near Niagara Falls. He maintained that her presence in the area did not resolve his doubt that she had entered Canada.
1 mention
Kathy Russell's credit-card records, including a Clifton Springs purchase — Weniger's testimony distinguished Russell's credit-card records, which indicated travel toward the border, from immigration documentation. He had no immigration document for Russell comparable to Ashana Chenoa's.
1 mention
Kristin Keeffe's letter mentioning Steve Coffey — During sentencing argument, Agnifilo said Keeffe's letter to the court mentioned Steve Coffey. Counsel described Coffey as an independent lawyer who made many of the litigation decisions under discussion.
1 mention
Large number of Forbes magazines containing articles about NXIVM found in garage bins — Fontanelli testified that bins on garage shelves at 3 Oregon Trail contained a large number of Forbes magazines. He confirmed that the magazines contained articles about NXIVM rather than about the criminal case.
1 mention
Letter alleging computer tampering and reporting consultation with four experts — Agnifilo described a letter alleging computer tampering and reporting consultation with four experts. He said he considered the current material insufficient for a Rule 33 prosecutorial-misconduct motion, declined to file one and was still examining the issue.
1 mention
Letter concerning Hughes's testimony forwarded to her by email — During Hughes's Day 18 cross-examination, the court sustained an objection to identifying the attorney who had forwarded the letter to her.
1 mention
Letter from Mr. Diaz — The court said it had received a letter from Diaz but had not received one from NXIVM's counsel explaining the corporation's privilege claims.
1 mention
Letter from Nancy Salzman and Barbara Bouchey inviting Vicente and the other producers to a symposium — Vicente recalled receiving the invitation toward the end of 2004 or perhaps in 2005. He said the prospect of a symposium with scientists he admired prompted him to respond and later meet Salzman and Bouchey in Los Angeles.
1 mention
Letter Mr. Vicente wrote that defense counsel described as using a hateful word — Agnifilo referred to Vicente's letter while the court asked whether matters raised in the government's motion in limine would be pursued during cross-examination.
1 mention
Letter pledging Nicole's grandmother's wedding ring as collateral; Nicole retained the ring — Nicole testified that she pledged her grandmother's wedding ring in a letter as collateral if she broke her word, but Allison allowed her to keep the ring provided she behaved.
1 mention
Letter supporting the defendant from Camila's father — During sentencing, the court said it had a supporting letter from Camila's father in its file while questioning defense counsel about Raniere's control over Camila and her father.
1 mention
Letter the women were instructed to read before being branded — Nicole testified that Allison produced a letter shortly before the branding that the women had to read aloud, pledging their lives to their master, promising not to speak negatively about her, and committing to help build what she wanted.
1 mention
Letter to Jay from a Mexican attorney, described by the government as threatening and already in evidence — During a Day 23 evidentiary discussion, Penza described a letter to Jay from a Mexican attorney as threatening and already in evidence. She said Jay received it the day after Barry Meier contacted Raniere about a forthcoming article.
1 mention
Letter to the District Attorney regarding Barbara Bouchey — Vicente described the letter concerning Barbara Bouchey as part of a letter-writing campaign involving pressure from upper ranks and prescribed bullet points. He did not recall Raniere or Nancy Salzman specifically directing him to write and could not explain how he would have calculated the claimed business damages.
1 mention
Letters about Nicole's family — In an email read during her testimony, Nicole requested the immediate return of letters about her family that Allison held as collateral, explaining that she wanted to leave quietly and protect herself and her family.
1 mention
Letters and notes the prosecution said Daniela wrote during her confinement — In opening statement, Hajjar said Daniela repeatedly wrote apologies and requests for forgiveness to Raniere while confined in a room. She told jurors they would see the letters and notes, previewing evidence rather than announcing its admission.
1 mention
Letters between Dani and Raniere that Agnifilo said jurors would see concerning her time in the room — In opening statement, Agnifilo said jurors would see many letters between Dani and Raniere from her time in the room. He described differing expressions about whether remaining there helped her or caused distress.
1 mention
Letters containing damaging accusations that the prosecution said Nicole supplied as collateral — In opening statement, Hajjar said Nicole supplied letters making damaging accusations against friends and loved ones as collateral when she joined DOS. These statements previewed the prosecution's allegations rather than establishing the accusations as true.
1 mention
Letters crediting Keith Raniere and Nancy's work on the Tourettes project — At sentencing, Agnifilo described letters from people who credited Keith Raniere and Nancy's work on the Tourette's project with relieving their symptoms. He presented those accounts as the letter writers' claims.
1 mention
Letters describing work associated with the Mexican Peace Initiative — At sentencing, Agnifilo described letters from people in Mexico concerning efforts associated with the Mexican Peace Initiative. He said the accounts addressed attempts to stop kidnappings and improve community life, which he attributed to Raniere's inspiration.
1 mention
Letters in support of the defendant — At the outset of sentencing, the court included letters supporting the defendant among the materials it had reviewed.
1 mention
Letters Nicole prepared as collateral about family members and an ex — Nicole testified that she prepared false collateral letters about family members and an ex after Allison said she could lie. She said the letters had to be signed, enclosed in envelopes, and addressed for delivery that would hurt the subjects if she broke her word. Allison assured her that no one would see them.
1 mention
Letters submitted for and against Keith Raniere — At sentencing, Agnifilo said he had read the letters submitted by the prosecution and defense. He acknowledged the pain expressed in them while arguing that they also reflected a community whose members had once trusted Raniere.
1 mention
Letters to Keith written while Daniela was in the room — Daniela described daily efforts to write words to Keith that would secure her release while she remained in the room.
1 mention
Letters Toni Natalie described receiving from Raniere using Milton's Paradise Lost — In her sentencing statement, Natalie said Raniere sent letters drawing on Milton's Paradise Lost and begging her to return. She characterized the letters as gaslighting and said they cast her as Lucifer and him as God.
1 mention
List of individuals whose identities are to be protected — The court ordered the government to provide the defense and each witness with a list of people whose identities were protected from public disclosure. After the government placed the list at the witness chair, the court directed that it receive a Government exhibit number for the record; no number or admission was stated.
1 mention
Lyrics to Children Will Listen from Into the Woods — The song lyrics were discussed during Daniela's direct examination on Day 14.
1 mention
March 10, 2018 email to people in the lower ranks — During cross-examination about the March email, Vicente acknowledged writing that more than 20 women were talking and comparing notes, and said he believed he had spoken with over 20 women.
1 mention
Mark Vicente's January 2016 letter to the executive board — Lauren Salzman recalled Vicente's letter but initially said she did not remember its contents. She agreed that he remained in NXIVM for a year and a half after writing it and ultimately resigned rather than being expelled.
1 mention
Materials about NXIVM printed out by Sylvie's father — Sylvie testified that her father showed her printed website material about NXIVM before she went to work for Clare Bronfman. She recalled his concern that Bronfman was in a cult but said she did not remember reading the material carefully and remained willing to try the job.
1 mention
May 14, 2008 patient history form listing no present method of birth control — During cross-examination, Butler confirmed that the May 14, 2008 patient history form listed no present method of birth control. The questioning did not establish who completed the form.
1 mention
Medical record containing a notation about how long Camila had been sexually active — The court required a foundation for the notation about how long Camila had been sexually active and said it would give a limiting instruction if necessary. After the defense raised a multiple-hearsay objection, the court allowed the statement because it was part of a medical record.
1 mention
Memorandum with a to-do list beginning June 30, 2008, which Vicente associated with the legal project — The memorandum carried exhibit label 1397 and was discussed during Mark Vicente's resumed cross-examination on Day 6.
1 mention
Michele's email to Allison Mack, described by the government as listing collateral and demands directed to Souki; defense counsel accepted its co-conspirator characterization — Penza described Michele's email to Allison Mack as listing Michele's collateral and further collateral demands directed to Souki. Defense counsel accepted its characterization as a co-conspirator statement and did not object; the court subsequently allowed the remaining disputed materials to come in.
1 mention
Mr. Flatley's notes, provided to defense counsel — Hajjar confirmed on Day 23 that defense counsel had received and reviewed Mr. Flatley's notes.
1 mention
Ms. Donnelly's notes, copied for defense review — Hajjar reported that Ms. Donnelly's notes were being copied for defense counsel and later confirmed that counsel had reviewed them.
1 mention
New York Times article about DOS — The article came up during Sylvie's direct examination on Day 2.
1 mention
New York Times article reporting Sara's allegations — The article was discussed during Lauren Salzman's cross-examination on Day 11.
1 mention
Nicole's departure letters to Allison and India — The letters came up during Nicole's direct examination on Day 19.
1 mention
Nicole's written impact statement, which she said the court had read — During her sentencing remarks, Nicole said the court had heard her testimony and read her written impact statement, so she would keep her oral remarks brief.
1 mention
Notarized collateral letter admitting an indiscretion during a relationship — Jay testified that the notarized letter disclosed an indiscretion during a relationship and that she handed it to India. She understood notarization as indicating that the statement was true.
1 mention
Notes attributed to Kristin Keefe by Geragos during the sidebar argument — The notes came up during Charles Fontanelli's cross-examination on Day 8.
1 mention
Notes drafted by Virginia Donnelley — Booth testified that Virginia Donnelley drafted the notes provided to him by DerOhannesian. He described her as a special agent and CART examiner in training whom he was training.
1 mention
NXIVM nondisclosure and confidentiality agreements — Sylvie testified that she signed many NXIVM nondisclosure agreements and understood them to prohibit sharing what she learned or reproducing course materials. She said she would not have felt comfortable violating them.
1 mention
October 2017 New York Times article, described by the government as the article in which Sara showed her brand — During Day 23 legal discussion, Penza identified the October 2017 New York Times article as the one in which Sara showed her brand. She discussed Barry Meier's advance contact with Raniere about the forthcoming publication.
1 mention
Page from the Alaska missing-person report concerning Ms. Snyder — The report page came up during Michael Weniger's cross-examination on Day 24.
1 mention
Pages from a journal maintained by Camila, whose admissibility remained disputed — Counsel planned submissions concerning Camila's journal pages, and the court planned to address the admissibility question the following day without ruling on Day 10.
1 mention
Pages from the contents of Government's Exhibit 204 that Geragos sought to show Fontanelli — The court declined examination of the contents at that time because Fontanelli had testified only about the box and the names he observed. The court said another witness would address the matter, and cross-examination resumed with folder labels.
1 mention
Pallorium emails to Kristin Keefe reporting investigative activity concerning Kristin Snyder — Weniger recalled Pallorium emails reporting investigative results to Kristin Keefe, including work in Key West and Palm Springs. He said the emails did not make clear who directed the work and only suspected that the subject was Kristin Snyder.
1 mention
Pam's credit-card records showing airline travel for Keith, Marianna, and Pam — In closing argument, Agnifilo said Pam's credit-card records listed airline travel charges for Keith, Marianna, and Pam. He argued that the charges showed Pam had financed Keith and Marianna's lifestyle before her death.
1 mention
Pam's will, described by counsel as already in evidence — Agnifilo said Pam's will was in evidence and referred to a trust naming Keith Raniere as beneficiary. He argued that Raniere would receive Pam's entire estate and therefore had no reason to loot it.
1 mention
Paper Daniela found among Camila's belongings that she described as expressing sexual dissatisfaction and a wish for a baby; she said Raniere told her to put it back. — Daniela testified that she found a paper among Camila's belongings that expressed sexual dissatisfaction and a wish for a baby. She said she brought it to Raniere, who told her he was taking care of the matter and instructed her to put it back.
1 mention
Papers, documents, letters, and other items addressed to Keith Raniere — Mills confirmed that he saw papers, documents, letters, and other items addressed to Keith Raniere during the search of 8 Hill Drive. His testimony identified their addressee, not authorship or ownership of the devices.
1 mention
paternity petition — Weniger recalled something about a paternity petition that counsel described as filed by Keith Raniere in Surrogate's Court. He expressly said he did not know whether it had remained pending for many years.
1 mention
Paul Martin's two reports — Ross testified that Paul Martin's second report referred to Lifton's criteria for assessing whether a thought reform program was ongoing. He confirmed that the Suttons paid Martin for expert-report work.
1 mention
Personal questionnaires at the first five-day intensive — Sylvie recalled personal questionnaires at the start of her first five-day intensive. She thought some asked about the worst thing that had happened or that she had done, and she described the questions as intense and overwhelming.
1 mention
Police report mentioned in the account concerning Christian Snyder; not produced or admitted here — Vicente mentioned a police report while describing a proposed film account concerning Christian Snyder. He acknowledged that the account involved allegations and said he thought a printed report existed somewhere but could not recall where.
1 mention
Possible New York Post coverage seen by Hughes — When asked whether she had seen coverage beyond The New York Times, Hughes said she might also have seen the New York Post.
1 mention
Post-it marked deletion on the exhibit — Agnifilo argued that a visible deletion note suggested an answer to Sylvie. Penza said she had not realized the Post-it was visible, and the court directed that it be kept off the exhibit.
1 mention
Prepared schedule listing trust deposits, disbursements, and payees — The government described a prepared schedule listing deposits, disbursements, and payees for the CDF trust, identified as Clare Bronfman's trust.
1 mention
Presentence investigation report dated January 29, 2020 — The court reviewed the January 29, 2020 presentence investigation report at Raniere's sentencing. Probation recommended a total offense level of 52, which the government supported, while Raniere proposed 37.
1 mention
Press article containing Edgar Bronfman's comment about his daughters joining a cult — The document was identified as a press article containing Edgar Bronfman's comment about his daughters joining a cult.
1 mention
Printed sex survey Allison gave Nicole, India, and Jay — Nicole testified that Allison gave her, India, and Jay a printed survey of about ten pages and required them to return it. She described intimate questions about first sexual experiences, views of sexuality, and sexual preferences.
1 mention
Printout of the ultrasound from Daniela's pregnancy — The document was identified as an ultrasound printout associated with Daniela's pregnancy.
1 mention
Prior defense filing, ECF 633 — The defense cited ECF 633 when renewing objections to Dawn Hughes's qualifications, the scope of her testimony, and notice. The court overruled the renewed objection and qualified Hughes as an expert.
1 mention
Proposed contract presented as a substitute for one month's collateral — Nicole recalled that Allison proposed a contract in place of one month's collateral, including restrictions on negative statements and a million-dollar payment if they spoke out. She said she did not remember all its language and that a planned review meeting and the contract requirement fell through.
1 mention
Proposed verdict form used to explain counts and racketeering-act findings — During closing argument on Day 26, Penza walked through the proposed verdict form's sections for racketeering, individual racketeering acts, racketeering conspiracy, and the standalone counts. She distinguished findings about completed acts from an agreement to commit racketeering.
1 mention
PSR description of DOS — The court recounted the PSR's description of DOS as a hierarchy with Raniere at its concealed apex. The description addressed recruitment, collateral requirements, and demands for service and additional collateral after joining.
1 mention
Psychological survey completed during intensive registration — Vicente described an in-depth psychological survey completed during intensive registration and said he later thought it was a narcissistic personality disorder survey. He did not know whether it had actually been sent for independent study, as participants were told.
1 mention
Public statement Salzman believed Raniere released on the NXIVM website denying affiliation with DOS and describing favorable outside review — According to Salzman, the statement denied Raniere's affiliation with DOS and claimed that a review by former law-enforcement personnel, forensic psychologists, and others found the women were thriving.
1 mention
Raniere's essays and accompanying review questionnaire — Nicole testified that she had to review roughly 50 essays written by Keith and answer a questionnaire about their content and clarity, understanding that they would eventually be edited and published. She described daily progress reports, a deadline, and approximately one and a half to three hours of work per essay.
1 mention
Raniere's lawyer's sentencing memorandum, which Nevares criticized — During her sentencing statement, Nevares said the memorandum ended her remaining sympathy for Raniere. She criticized what she regarded as his lack of remorse and blame directed at victims.
1 mention
Rape and Sexual Assault Among Adult Women — Hughes confirmed that she had published a book chapter entitled Rape and Sexual Assault Among Adult Women.
1 mention
Rational Inquiry patent application and representations about its status — The document was identified as a Rational Inquiry patent application alongside representations about its status.
1 mention
Recently signed immunity letter — Sylvie disclosed a recently signed immunity letter and described her understanding of its protections and exceptions, without reading its text. She said she had not expected immunity when she first met with the government.
1 mention
Reimbursement check Vicente believed Clare Bronfman sent him — Vicente testified that Clare Bronfman asked him to make a campaign contribution in his own name and reimbursed him, which he believed occurred by check. He estimated the amount at $2,000 to $3,000 but was uncertain about the campaign and year.
1 mention
Requested exit letter stating that Vicente's wife had no outstanding ethical issues with the company — Vicente understood that the requested letter would state his wife had no outstanding ethical issues with the company and would effectively hold it blameless. He did not believe she signed it.
1 mention
Richard Marier's May 25, 2009 email to Kristin concerning orders — The email was addressed during questioning about Canaprobe's correspondence with Kristin at the oakhaven account. Weniger agreed that Kristin was the general contact and that Clare Bronfman's occasional involvement generally concerned invoices or payment.
1 mention
Salzman's DOS position statement edited by Keith — The document was identified as Salzman's DOS position statement edited by Keith.
1 mention
Salzman's letters to her father about Nina — Salzman confirmed writing several letters to her father about the situation involving Nina. She testified that she tried to persuade him to fire Nina by withholding their relationship until he addressed the issue and took action.
1 mention
settlement agreement — Valenziano mentioned a subpoena for the settlement agreement and said Ms. Franco agreed to pay $1. He referred to three settlement components but did not provide a complete account of the terms.
1 mention
Statements for Pamela Cafritz's American Express account ending 42002 — Guerci testified that Pamela Cafritz was an authorized user of the account. He qualified his statement that there were no other authorized users by limiting it to the statements and information he obtained from American Express.
1 mention
Stephanie Franco's credit card charge slip containing confidentiality language — Ross described confidentiality language in very small print on Franco's credit card charge slip and said she became aware of it after being served. He thought he might have seen the slip once during the litigation but had not seen it before he was served.
1 mention
Stephanie Franco's NXIVM course materials and handwritten notes — Ross described extensive course literature, detailed study notes, and Franco's additional handwritten reflections as materials available to the report writers. He defended their reliance on those materials together with their prior experience.
1 mention
Stephanie Franco's signed confidentiality agreement, which Daniela said was sought for several weeks and, to her knowledge, never found — The agreement was described as having been sought for several weeks and, to Daniela's knowledge, never found.
1 mention
Stephanie Franco's three-ring binder of NXIVM course materials — Valenziano described the binder as containing coursework and reading materials Franco received at a NXIVM intensive. He said two professors used it to prepare critical articles later posted on Rick Ross's website, shortly before the lawsuit was filed.
1 mention
study notes conveyed to John Hochman and Paul Martin — Ross testified that Morris and Rochelle Sutton hired Hochman and Martin, and that he conveyed the study notes to them before they prepared their reports.
1 mention
Subpoena to Verizon Communications in the NXIVM case against Morris Sutton and Rochelle Sutton — The subpoena to Verizon Communications concerned NXIVM's case against Morris Sutton and Rochelle Sutton.
1 mention
superseding indictment — The final jury instructions described the superseding indictment as a charge or accusation containing seven separate counts. The instructions also stated that the indictment was not evidence.
1 mention
Sylvie's written vow to Monica — Sylvie testified that she was asked to write a lifetime commitment vow to Monica, who approved it. She said Monica later placed a necklace on her with a clasp supposedly unable to be undone.
1 mention
T-shirt business-plan email Jay prepared with Jacob and sent to Keith — Jay testified that the email outlined ideas involving charity, artists, and sustainability. She said Keith praised several ideas but discouraged the charity component because of concerns about charities' integrity.
1 mention
Table of purported financial relationships involving Birthright Holdings, Joe O'Hara, Rueda, Skolnik, Soares, Touretzky, and Ross entities — The table listed purported financial relationships involving Birthright Holdings, Joe O'Hara, Rueda, Skolnik, Soares, Touretzky, and Ross entities. During cross-examination, counsel questioned Weniger about Canaprobe's representations of connections involving Birthright Holdings and Ross entities, among others.
1 mention
The 96-page motion and declaration of innocence Barbara Bouchey said she read — Bouchey said she had read Raniere's 96-page motion and declaration of innocence. She criticized its characterization of witnesses and questioned why it did not mention her.
1 mention
The court's May 14th order, page 5, addressing Exhibit 1473 — Agnifilo directed the court to page 5 of its May 14 order concerning Exhibit 1473. Hajjar responded that the order had left open the possibility of the government establishing a theory of admissibility.
1 mention
The Denny's receipt from Niagara Falls dated Christmas Eve 2004 — In closing argument, Agnifilo described a Denny's receipt from Niagara Falls dated December 24, 2004, which he said Kristin Keeffe submitted for repayment. He contrasted the receipt with Daniela's uncertainty about the return trip to Albany.
1 mention
The disputed e-mail exhibit whose prior exclusion remained in effect — The defense argued that the email should be admitted to show the witness's contemporaneous state of mind, while the government objected on hearsay grounds. The court stated that its prior decision on the exhibit stood and acknowledged the defense exception.
1 mention
The government's letter concerning a proposed jury instruction — After Agnifilo said he had reviewed the government's letter and considered it acceptable, the court directed removal of one sentence from the proposed instruction at 123 and 124.
1 mention
The identification card in the name of Lisa Chenoa described in Daniela's crossing account — Agnifilo recounted Daniela's testimony that Kathy Russell gave her an identification card in the name of Lisa Chenoa for the border crossing. He questioned the relationship between that name and Ashana Chenoa and argued that the testimony did not establish Raniere's agreement to use another real person's identity.
1 mention
The indictment charging seven counts — The court's preliminary instructions outlined seven counts involving racketeering, forced labor conspiracy, wire fraud conspiracy, and sex trafficking offenses. The court stressed that these were allegations, that Raniere had pleaded not guilty, and that the final instructions would supply the controlling law.
1 mention
The longer written statement Kristin Keeffe said she submitted describing her history and harm — Keeffe said she had submitted a much longer statement describing her history and the harm she experienced. She explained that she could not address everything within her allotted speaking time.
1 mention
The New York Times article about branding that Jane Doe said helped her recognize what had happened — Jane Doe said that only after the New York Times article about branding appeared did she slowly begin to recognize what had happened to her.
1 mention
The New York Times headlines, snippets, and opening paragraphs about the case — Hughes testified that she read the New York Times daily and had seen some headlines, snippets, and opening paragraphs about the case, but had not had time to read all the articles.
1 mention
The NXIVM 9 letter and monetary demand — Lauren Salzman testified that nine women left NXIVM around 2009 and wrote a letter she was told was extortionate. She acknowledged a monetary demand and described the organization's belief that it was not made in good faith.
1 mention
The proposed instruction at 123 and 124, from which the court directed removal of one sentence — Outside the jury's presence, the court directed removal of one sentence from the proposed instruction at 123 and 124 after discussing the government's letter with defense counsel.
1 mention
The trust referenced in Pam's will, which counsel said named Keith Raniere as beneficiary — Agnifilo said Pam's will referred to a trust naming Keith Raniere as beneficiary. He argued that Raniere's claimed entitlement to the estate undermined the government's identity-theft theory concerning continued account use.
1 mention
Thought Reform and the Psychology of Totalism — Ross testified that Paul Martin's second report referred to the criteria in Chapter 22 of Robert J. Lifton's book to assess whether a thought-reform program was ongoing. Ross also said Lifton was not retained by the family.
1 mention
Threatening letter that the court said Mr. Raniere orchestrated sending to DOS victims through counsel in Mexico — At sentencing, the court stated that Raniere orchestrated a threatening letter sent through counsel in Mexico when DOS victims began speaking publicly. The court described the letter as part of his effort to silence them.
1 mention
Threatening letters that the prosecution described as having been sent to Sarah Edmondson and DOS victims — Hajjar described threatening letters sent to Sarah Edmondson and DOS victims alongside attempts to institute criminal charges. She argued that the defense justification had no basis in the evidence and had been rejected by the jury.
1 mention
Three articles critiquing NXIVM's practices and methods, posted on Mr. Ross' website — Valenziano testified that two professors used Stephanie Franco's course binder to prepare three articles assessing whether NXIVM's practices and methods were cult-like. He said the articles appeared on Rick Ross's website in late spring 2003, shortly before the lawsuit was filed.
1 mention
Three checks shown on cross-examination, payable to The Ross Institute — Ross recognized one $5,000 check but did not recall the other two or know where the checks came from.
1 mention
Three reports published on Ross's website, by Paul Martin and John Hochman — Ross testified that the reports relied on NXIVM materials and were not peer-reviewed. He said neither author took NXIVM courses or interviewed Michael Sutton or his family, and he defended their reliance on materials and prior experience.
1 mention
Three resignation letters sent to the executive board, Society Of Protectors leaders, and senior proctors — Vicente acknowledged that the career explanation in his resignation letters was only half true. He said he omitted his objections to the master/slave arrangement because he believed his life was in danger.
1 mention
Tompkins Maguire letter referencing subpoenas — The letter referenced subpoenas and arose during Michael Weniger's cross-examination on Day 24.
1 mention
Transcript accompanying Government Exhibit 497 — Hajjar directed the jury's attention to the accompanying transcript before Government Exhibit 497 was played during Lauren Salzman's Day 11 direct examination.
1 mention
Transcript of a recording that Vicente was still reviewing — The court approved having an agent sit with Vicente while he finalized the transcript, and defense counsel did not object. The exchange did not admit the transcript into evidence.
1 mention
Transcript of the California property case purchased and read by Herbits — Herbits described learning about litigation through a purchased transcript during his Day 7 direct examination.
1 mention
transcript of the LA case — Herbits said he first learned Frank Parlato's name from the LA case transcript, which he had read eight years earlier and had not reread. He denied the account that he represented Edgar Bronfman in giving Parlato instructions about the property.
1 mention
Transcript Salzman prepared of the branding video, omitting the same dialogue removed from the video — Salzman testified that she transcribed the branding video while omitting the same portions removed from the edited video. She retained the request to be branded and the accompanying expression of honor.
1 mention
Twilight Post document referring to tape duplication requested by Keith — During recross-examination, Vicente agreed that the cited passage referred to duplicating tapes at Keith's request, not editing or modifying them. His agreement concerned the document's wording and did not retract his testimony about tape alterations.
1 mention
Two Denny's receipts bearing handwritten dates of 12/24 and 12/29 and amounts of $48.74 and $101.49 respectively — The two receipts bore handwritten dates of 12/24 and 12/29, with respective amounts of $48.74 and $101.49, and arose during Michael Weniger's Day 24 cross-examination.
1 mention
Two-page document concerning Vicente's FBI account — The two-page document concerned Vicente's FBI account and was identified as 3500-MV-1 during his cross-examination on Day 7.
1 mention
typed documents containing the government's interpretation of audio recordings — The typed documents contained the government's interpretation of admitted audio recordings and were distributed or displayed to assist the jury in listening. The court addressed their limited use in the Day 27 jury instructions.
1 mention
Unidentified document with a highlighted paragraph six, shown to refresh Ross's recollection — The court permitted Ross to review highlighted paragraph six after he did not recall promising that Hochman's report would remain confidential. Ross subsequently denied the suggested promise; the exchange did not identify the document or establish its admission.
1 mention
Uniform Crime Reports compiled by the FBI — Hughes cited the FBI's Uniform Crime Reports alongside other data when testifying that sex crimes and crimes against women are among the most underreported crimes.
1 mention
Unnumbered message printouts offered as communications between Nicole and Keith Raniere — Nicole recognized some content in the printouts but declined to identify every message as her own, and one document did not refresh her recollection. The court sustained objections to questions quoting alleged sexual wording and deferred further discussion of the printouts until lunch.
1 mention
Unofficial RPI transcript; the government proffered subpoena provenance and relevance to the defendant's advertised academic credentials — Defense counsel challenged the unofficial transcript's relevance and provenance. The government proffered that RPI had returned it in response to a subpoena, and the court allowed it among the remaining disputed materials.
1 mention
Unsigned draft affidavit attributed to Michael Sutton — Counsel identified the draft as part of an admitted exhibit found in a box at Nancy Salzman's house, while Weniger did not specifically recall it. The court initially permitted reading with its unsigned status made clear and without treating its assertions as verified truth, then barred Sutton from testifying by affidavit.
1 mention
Val's notarized collateral letter alleging her sister was a terrorist — Jay testified that Val wrote and notarized a letter accusing her sister of terrorism while the sister was applying for a government office position. The letter came with an envelope addressed to that office, and Jay said she received it and handed it to India.
1 mention
Vanessa Grigoriadis's New York Times magazine article — The New York Times magazine article by Vanessa Grigoriadis arose during Lauren Salzman's cross-examination on Day 11.
1 mention
Verdict form — The foreperson handed the jury sheet to the clerk for publication of the verdict on Day 28. After the verdicts and findings were announced, the court directed retrieval of the form and polling of the jury.
1 mention
Vicente's campaign-contribution check — Vicente testified that he wrote a campaign check in his name at Clare Bronfman's request and that she reimbursed him, which he believed was also by check. He estimated the contribution at $2,000 to $3,000 but was uncertain about the campaign and year.
1 mention
Vicente's wedding album, which he identified Raniere examining in the video — At one minute and 23 seconds into the video, Vicente identified the book Raniere was examining as his wedding album. He testified that Raniere had not attended the wedding.
1 mention
Vicente's wedding vows — Vicente testified during his Day 6 cross-examination that he believed Raniere wrote his wedding vows but did not know for certain.
1 mention
Victim-impact statements cited by the prosecution as describing lasting harm — Hajjar cited the written statements alongside trial testimony and in-court accounts as descriptions of harm to victims and their families. She argued that the damage would last for the rest of the victims' lives.
1 mention
Victim-impact statements reviewed for sentencing — The court listed victim-impact statements among the materials it had reviewed for Raniere's sentencing on Day 29.
1 mention
Victims' letters and submitted victim impact statements, including submissions from more than 90 individuals — The court said it had reviewed victims' letters and received victim-impact statements from more than 90 individuals describing harm from Raniere's criminal conduct.
1 mention
Visa file filed on behalf of Marianna — During cross-examination on Day 24, Weniger was uncertain whether he had seen Marianna's visa file.
1 mention
Visa kept with Daniela's personal documents — The visa came up during Daniela's direct testimony on Day 14.
1 mention
Wedding vows Vicente said Raniere wrote for him and his wife — Vicente testified that Raniere offered to write his wedding vows and supplied them, he thought, on the wedding day. Raniere did not attend the wedding.
1 mention
Wells Fargo bank records proposed for admission without immediate publication to the jury, followed by redaction — The government proposed admitting the Wells Fargo statements without immediately showing them to the jury, questioning a witness about deposits, and then redacting them. The court accepted that procedure and allowed evidence of $14 million in deposits while restricting payee identities and individual payment amounts.
1 mention
Wilton Times newsletter Daniela drafted for her family — The newsletter came up during Daniela's direct testimony on Day 14.
1 mention
Written premarital contract addressing monogamy and time in Albany and New York City — Sylvie testified that she and John wrote a contract before marrying that included monogamy and an agreement to divide their time equally between Albany and New York City.
1 mention

Demonstratives (14)

Government Exhibit 176 — Charles Fontanelli testified that the presentation fairly and accurately depicted the proximity of various locations and included photographs taken by him and Special Agent Michael Weaver. On cross-examination, he identified slide 16 as showing 1, 2, and 3 Flintlock Lane and slide 41 as showing the Sports Barn.
3 mentions
Government Exhibit 362 — The court admitted the inner-circle chart on Day 8. On Day 11, Lauren Salzman agreed that it moved from older relationships beginning with Cafritz toward newer relationships ending with Levy.
2 mentions
Government Exhibit 363 — Lauren Salzman confirmed that the chart depicted Raniere and everyone who was a first-line DOS master. She explained that first-line members were enrolled directly under Raniere as their master.
2 mentions
DOS brand depiction presented during Hajjar's opening — Hajjar described the design as a K and a backward R for Keith Raniere. She alleged that women were not told they were being branded with his initials.
1 mention
Government Exhibit 1830 — Weniger prepared the presentation to categorize subjects named on folders containing purported financial information, including local and national press categories. The exhibit was marked for identification only, and slides were shown to the jury with defense consent.
1 mention
Government Exhibit 377 — Rees testified that the emailed export retained her test conversation's text but replaced an image with an omission notation because she chose to exclude media. The court admitted Exhibits 377 and 378 as aids to the jury.
1 mention
Government Exhibit 378 — The screenshots depict the menu containing the export-chat feature and Rees's text conversation with another user. The court admitted Exhibits 377 and 378 as aids to the jury.
1 mention
Government Exhibit 501 — The sketch depicts the residence's first floor, second floor, and loft. The court received it in evidence and permitted its display to the jury during Christopher Mills's direct examination on Day 20.
1 mention
Government's chart of the alleged enterprise — Agnifilo described the chart as largely depicting women and referred to it as a bull's-eye chart of alleged enterprise participants. He questioned whether Camila's photographs formed part of those participants' common purpose.
1 mention
GX180A — The court admitted slides 55 through the end as GX180A without objection on Day 8. Fontanelli described photographs of a basement utility room and safe, a rear bedroom, and money found in a bag in its closet.
1 mention
Map concerning properties in Clifton Park that the government said Investigator Fontanelli would address — The government said Fontanelli would address the property map.
1 mention
PowerPoint — The court allowed Hajjar to switch to the presentation after Government Exhibit 548 was received in evidence.
1 mention
PowerPoint planned for the Government's closing argument — Hajjar confirmed that the government planned to use a PowerPoint after the court asked counsel to arrive early to assemble and test electronic equipment for closings.
1 mention
The government's poster depicting the alleged enterprise — Agnifilo described the poster as depicting Raniere and a circle of people whom the government alleged formed an enterprise. He asked whether that grouping held together as an enterprise with a common purpose.
1 mention

Testimony References (16)

Daniela's testimony — Agnifilo reviewed Daniela's account of the border-crossing plan and challenged her reliability during closing argument. He also characterized her confinement as punishment rather than a means of obtaining labor.
1 mention
Daniela's testimony about Kristin Keeffe reporting to the defendant and obtaining his decisions — Daniela described Keeffe reporting developments, presenting options, and receiving decisions and instructions from Raniere, according to testimony Lesko read during rebuttal.
1 mention
Dr. Hughes's testimony about coercive dynamics in abusive relationships — Lesko recalled Dr. Hughes's explanations of isolation, surveillance, and coercive dynamics in abusive relationships. He also cited her testimony that leaving such relationships can be confusing and take time.
1 mention
Elizabeth Butler's anticipated testimony about a conversation with Pam Cafritz concerning medical care provided to Daniela and her sister — The defense sought to exclude Butler's account of a conversation with Cafritz about medical care provided to Daniela and her sister. The court found the conversation admissible, rejected exclusion under Rule 403, and said it would provide a limiting instruction.
1 mention
Jane Doe 8's trial testimony about the assignment to seduce Mr. Raniere — The court credited Jane Doe 8's account that she was assigned to seduce Raniere and permit a photograph proving completion. Although she ultimately refused a sex act, the court rejected the contention that she had misunderstood the assignment.
1 mention
Lauren Salzman's testimony about the defendant's control over Daniela's confinement — Lesko read testimony in which Salzman described reporting to Raniere after interacting with Daniela and seeking his direction. Salzman also said she waited six weeks for his permission before taking Daniela to the dentist despite Daniela's reported pain.
1 mention
Lauren Salzman's trial testimony concerning someone leaving — During sentencing discussion on Day 29, Agnifilo cited Salzman's testimony and messages involving someone who wanted to leave, arguing that people could depart when they wished.
1 mention
Mark Vicente's testimony about tape alterations and the lawsuit — Agnifilo highlighted Vicente's uncertainty about which altered tapes were produced in discovery and his later information from Keeffe about the Stephanie Franco lawsuit. Counsel also argued that references to a long-running project concerned digitization rather than alteration of discovery materials.
1 mention
Mark Vicente's testimony about the videotape alteration project and his knowledge of litigation — Lesko read Vicente's account of Raniere discussing removal of material from tapes for a case involving methodology and a patent. He distinguished Vicente's awareness of litigation at the time from his later knowledge that the specific lawsuit involved Franco.
1 mention
Ms. Salzman's testimony repeating Kristin's and Carly's statements about providing collateral and joining DOS — Before Salzman's direct examination resumed on Day 10, the court instructed jurors to disregard only the portion of her testimony repeating Kristin's and Carly's statements about providing collateral and joining DOS.
1 mention
Portions of Ms. Salzman's testimony repeating Kristin and Carly's statements about providing collateral and joining DOS — Outside the jury's presence on Day 10, the court struck specified portions of Salzman's testimony because the danger of unfair prejudice substantially outweighed their probative value, although the statements were not offered for their truth. The court announced an instruction directing jurors to disregard those portions.
1 mention
Proposed testimony about DOS statements made to Mr. Vicente — Counsel distinguished DOS statements offered for their truth as alleged coconspirator statements from other statements offered for their effects on Vicente. The court settled on individualized limiting instructions for the latter category, beginning with Debra's statements.
1 mention
Richard Guerci's testimony concerning the $14 million irrevocable trust created by Clare Bronfman to assist with others' legal fees — Guerci's testimony addressed a $14 million irrevocable trust Clare Bronfman created to assist with other individuals' legal fees. On Day 22, the court instructed jurors that the arrangement could be considered solely on the enterprise question.
1 mention
Testimony of Lauren Salzman, Daniela, and Mark Vicente cited by the Government regarding the enterprise and racketeering acts — Hajjar argued that Salzman, Daniela, and Vicente described an enterprise intended to promote Raniere and racketeering acts he committed through his position as its leader.
1 mention
Testimony of Lauren Salzman, Nicole, and Jay cited by the Government in support of the commercial-sex element — Hajjar cited Salzman's testimony about financial opportunities associated with access to Raniere and Nicole's testimony about receiving cash as a direct result of their sexual relationship. She also cited Nicole's and Jay's testimony when arguing that sexual assignments preserved financially valuable access for DOS first-line masters.
1 mention
The witness's answer about being groomed to join a harem, as characterized by defense counsel — Agnifilo argued that the witness's retrospective interpretation exceeded lay observation and improperly addressed another person's intent. The court overruled the initial motion to strike and said the government needed to establish when she formed that understanding and whether it affected her departure. The court acknowledged the renewed objection without expressly granting or denying it.
1 mention

Stipulations (3)

Government Exhibit 250 — The stipulation identifies India Oxenberg and Allison Mack as suppliers of thumb drives containing four recordings described as admissible.
1 mention
Government Exhibit 251 — The stipulation states that Adriana Aguilar provided the government with a thumb drive containing Government Exhibit 910 on or about April 20, 2018, and that Exhibit 910 is admissible in evidence. Government Exhibit 251 was admitted without objection.
1 mention
Government Exhibit 252 — The stipulation identifies people depicted in specified photographs from Government Exhibit series 508 through 517. It was admitted without objection and read to the jury during Brian Booth's direct examination on Day 22.
1 mention

Other (70)

Government Exhibit 3 — On Day 4, Mark Vicente identified the person shown in Government Exhibit 3 as Alex Betancourt and confirmed his membership on the new executive board. On Day 3, Vicente identified the person shown under that exhibit label as Rosa Laura Junco after describing a girls' program he recalled her running.
4 mentions
Government Exhibit 605 — Anthony Valenziano identified the 57-DVD collection as recordings produced in the Stephanie Franco litigation, and the court admitted it over objection on Day 21. He confirmed that production correspondence described 35 of those recordings as unedited. He expressed concerns about missing content and apparent jump cuts, but an expert assessment was considered too expensive and his testimony did not establish a technical finding of editing.
4 mentions
Government Exhibit 1005 — The Jness meeting video depicts Nancy Salzman reading training material and was played during Michael Weniger's direct testimony on Day 24. The court admitted Government Exhibit 1005 without objection on Day 1.
3 mentions
Government Exhibit 202 — Mark Vicente identified the portrait as a photograph that hung beside Nancy Salzman's photograph at NXIVM ESP headquarters at 455 New Karner Road. Sylvie also recognized it as a picture displayed at the center.
3 mentions
Government Exhibit 203 — Mark Vicente identified the photograph as Nancy Salzman's portrait hanging at NXIVM ESP headquarters at 455 New Karner Road. Sylvie also recognized it as a photograph displayed at the center, where Salzman was called Prefect.
3 mentions
Government Exhibit 26 — Lauren Salzman identified the photograph after testifying that Marianna had moved into 3 Flintlock with the defendant.
3 mentions
Government Exhibit 1002A — On Day 6, the court contemplated an excerpts-only CD once the parties agreed on its contents. On Day 7, the court admitted Government Exhibit 1002A without objection to replace the previously admitted Exhibit 1002.
2 mentions
Government Exhibit 12 — The photograph was presented as already in evidence during Lauren Salzman's direct examination on Day 8, when she identified Pam Cafritz.
2 mentions
Government Exhibit 16 — The image identifying Loreta Garza was addressed during Mark Vicente's direct examination on Day 3 and Lauren Salzman's direct examination on Day 8.
2 mentions
Government Exhibit 175 — Mills said the whiteboard visible in a still from the footage appeared largely unchanged from March 27, 2018. On cross-examination, he said he believed the blue light appeared only in Exhibit 175 rather than the search images being compared.
2 mentions
Government Exhibit 21 — The court admitted Exhibit 21 by consent on Day 8. The photograph was identified as Camila during Lauren Salzman's direct examination that day.
2 mentions
Government Exhibit 23 — The court received Exhibit 23 in evidence by consent on Day 8. The photograph was identified as Daniela during Lauren Salzman's direct examination that day.
2 mentions
Government Exhibit 27 — The court admitted Exhibit 27 by consent on Day 8. The photograph was identified as Jack during Lauren Salzman's direct examination that day.
2 mentions
Government Exhibit 40 — The court received Exhibit 40 in evidence by consent on Day 8. The photograph was identified as Dawn during Lauren Salzman's direct examination that day.
2 mentions
Government Exhibit 44 — The court admitted Exhibit 44 by consent on Day 8. The photograph was identified as Ivy during Lauren Salzman's direct examination that day.
2 mentions
Government Exhibit 47 — During her Day 21 direct examination, Jay identified Danielle Roberts in the photograph after naming Roberts among the people who lived with her at 7 Generals Way.
2 mentions
Government Exhibit 51 — Mark Vicente identified Nancy Salzman when shown Government Exhibit 51 during his Day 2 direct examination. The photograph was also identified as Nancy during Lauren Salzman's direct examination on Day 8.
2 mentions
Government Exhibit 6 — During Mark Vicente's Day 2 direct examination, the court and counsel confirmed that Government Exhibit 6 was already in evidence. Vicente identified Barbara Bouchey in the image.
2 mentions
Nicole's collateral — Nicole said she left after a conversation establishing that her collateral would not be released. On redirect, she testified that she had requested its return but never received it, and that the defendant had not contacted her about returning it.
2 mentions
13 — The already-admitted exhibit was displayed during Mark Vicente's direct testimony on Day 4, and he identified the person shown as Esther Carlson.
1 mention
20 — During his direct testimony on Day 4, Vicente identified Sarah in the admitted exhibit and confirmed that he had started the Vancouver center with her.
1 mention
Amanda's collateral, including allegations about family and partner abuse, sexually explicit photographs and a later video about her fiance — Lauren Salzman described Amanda's collateral as an account of alleged family abuse, sexually explicit photographs, and a video accusing her partner of abuse. Salzman thought the video could jeopardize his job and said later collateral could have led to Amanda's disbarment.
1 mention
Audrey's collateral, including nude photographs, a letter falsely accusing a former partner of domestic violence, videos and financial information — Lauren Salzman said Audrey provided nude photographs, a letter falsely accusing a former partner of domestic violence, and videos making potentially damaging claims about herself and others. Salzman also described a promised car and information for bank and investment accounts.
1 mention
Collateral from Jimena and Carola, including separate videos about a family member's addiction and an alleged affair; Salzman did not identify which woman supplied each item — Lauren Salzman described separate videos about a family member's addiction and an alleged affair without identifying which woman supplied each. She thought additional collateral included nude photographs and a transfer of part of a business if an agreement was breached.
1 mention
Compilation Salzman supplied to at least one retained former law-enforcement reviewer, selecting apparent positivity and consent and omitting contrary material — Salzman said she supplied at least one NXIVM-retained reviewer with a compilation selected to show positivity and consent while omitting contrary examples. She said some photographs depicted women who had been instructed to look happy and willing.
1 mention
Evidence of the irrevocable trust's existence — The court reaffirmed its earlier ruling allowing the fact of the irrevocable trust's existence to be introduced.
1 mention
Facilitator notes, student notes, training videos on iPods and tablets, and participant files kept at centers — The training videos were kept on iPods and tablets, and the written materials included both facilitator and student notes alongside participant files.
1 mention
Government Exhibit 1 — Hajjar offered Exhibit 1 before the next witness was called, Agnifilo confirmed consent, and the court received it in evidence.
1 mention
Government Exhibit 1004 — Penza offered Exhibit 1004 with a group of government exhibits before the first witness's testimony began, and the court received the group in evidence.
1 mention
Government Exhibit 102, 106, 107, 109, 113, 114, 119, 124, 125, 126, 127, 128, 129, 130, 131, 134, 135, 137, 138, 139, 140, 141, 143, 144 through 149, 153, 154, 155, 158, 160, 161, 162, 163, 168, 171, 174, 177, 176, 180, 365, 368, 369, 370, 371, and 1483 — Penza distinguished this consented group from a separate set admitted over defense objections. The court confirmed admission of the identified exhibits.
1 mention
Government Exhibit 1112 to 1123 — Hajjar clarified that the government had not offered these exhibits because of a recent ruling. The court then expressly confirmed that they were not admitted.
1 mention
Government Exhibit 122 — The depiction was displayed during Mark Vicente's direct testimony on Day 3.
1 mention
Government Exhibit 1392 — Penza included Exhibit 1392 in a group of offered government exhibits, and the court received the exhibits in evidence.
1 mention
Government Exhibit 1408 — Penza offered Exhibit 1408 with a group of government exhibits before the first witness's testimony began, and the court received the group in evidence.
1 mention
Government Exhibit 1413 — Penza offered Exhibit 1413 with a group of government exhibits before the first witness's testimony began, and the court received the group in evidence.
1 mention
Government Exhibit 1414 — Penza offered Exhibit 1414 with a group of government exhibits before the first witness's testimony began, and the court received the group in evidence.
1 mention
Government Exhibit 1445 — Penza included Exhibit 1445 in a group of offered government exhibits, and the court received the exhibits in evidence.
1 mention
Government Exhibit 1509 — The court received the exhibit alongside Exhibits 1504 and 1510 through 1512 without individually identifying its contents.
1 mention
Government Exhibit 1512 — The court received the exhibit alongside Exhibits 1504, 1509, 1510, and 1511 without individually identifying its contents.
1 mention
Government Exhibit 1601 — The court accepted the prosecution's clarification identifying Exhibits 1600 and 1601; Exhibit 1601's contents were not described during the examination.
1 mention
Government Exhibit 1605 — The examination did not describe the exhibit's contents.
1 mention
Government Exhibit 1820 — The court received the exhibit as part of a group offered by the government without individually describing its contents.
1 mention
Government Exhibit 1821 — The court noted the defense objection and received the exhibit in evidence without individually describing its contents.
1 mention
Government Exhibit 25 — The court received the exhibit with six other government exhibits before the next witness was called; their contents and material types were not described.
1 mention
Government Exhibit 30 — Jay recognized Nicole in the exhibit and described her as a friend who was in The Vow and served as Jay's Source ongoing class coach.
1 mention
Government Exhibit 38 — The court received the exhibit as part of a group offered by the government without individually describing its contents.
1 mention
Government Exhibit 58 — The court received the exhibit as part of a group offered by the government without individually describing its contents.
1 mention
Government Exhibit 59 — The court received the exhibit as part of a group offered by the government without individually describing its contents.
1 mention
Government Exhibit 9 — The court received the exhibit as part of a group offered by the government without individually describing its contents.
1 mention
Government Exhibit 913 — The court included the exhibit in its admission of Exhibits 912 through 923, 925, 926, and 929 without individually describing its contents.
1 mention
Government Exhibit 914 — The court included the exhibit in its admission of Exhibits 912 through 923, 925, 926, and 929 without individually describing its contents.
1 mention
Government Exhibit 919 — The court included the exhibit in its admission of Exhibits 912 through 923, 925, 926, and 929 without individually describing its contents.
1 mention
Government Exhibit 920 — The court included the exhibit in its admission of Exhibits 912 through 923, 925, 926, and 929 without individually describing its contents.
1 mention
Government Exhibit 923 — The court included the exhibit in its admission of Exhibits 912 through 923, 925, 926, and 929 without individually describing its contents.
1 mention
Information and photographs collected as collateral — During the Day 29 sentencing discussion, the judge described collecting information, true or possibly untrue, and photographs as a way to make people feel constrained to stay.
1 mention
Jay's collateral retained by DOS — On Day 21, Jay testified that DOS still had her collateral when she returned to Albany in late April to collect belongings. She said she was worried about its retention.
1 mention
Nicole's collateral, whose threatened release she said compelled her participation in DOS — In her Day 29 victim statement, Nicole said her collateral and the assertion that she could not leave the commitment constrained her responses to Raniere's demands. She said she would not have accepted the sexual circumstances or been in Albany without the threat of its release.
1 mention
Notes, audio recordings and videotapes Daniela said she made to document Raniere; she said she was instructed not to record legal discussions. — Daniela said she typed observations and emailed them to herself, then used tape recorders and a small video camera Raniere bought her to document his conversations and activities. She said she was instructed not to record legal discussions and eventually stopped recording them without being reminded.
1 mention
Other people's collateral described by counsel as given to Jay's ex-boyfriend — When counsel asked whether she had gone to police at the point he described giving other people's collateral to her ex-boyfriend, Jay said she had not.
1 mention
Photographs, video, and vows of obedience that the prosecution attributed to DOS members — Hajjar described these materials as part of the physical evidence the prosecution planned to present, including vows she said DOS members made to the defendant. Her opening statement previewed the materials rather than reporting their admission.
1 mention
Proposed disclosure of the total amount available for the defense, without individual firms' payment amounts — Lesko proposed disclosing the trust's existence and total defense funding without specifying payments to individual firms. Agnifilo expressed concern because the amount covered multiple parties, and the court encouraged counsel to resolve the presentation.
1 mention
Public statements supporting DOS that the prosecution described as following the collateral-return emails — The prosecution said NXIVM board members and others, including Raniere and Bronfman, issued statements supporting DOS after collateral-return emails were sent in July and September 2017. It argued that those statements denied concerns described in the emails despite recipients having notice of them.
1 mention
Recorded confessions and naked material Sarah reportedly described as collateral — Vicente connected his concerns to Sarah's reported fear of collateral release and distinguished DOS photographs from SOP financial commitments. The court limited her reported account to its effect on him, not its truth.
1 mention
Recordings and written materials developed from Raniere's meetings for The Source curriculum — The materials were described as recordings and written work developed from Raniere's meetings for The Source curriculum.
1 mention
Samantha's collateral letter and picture in an envelope addressed to her family — Sylvie's testimony addressed Samantha's collateral letter and picture in an envelope addressed to her family.
1 mention
Security camera installed by Adrian and Salzman, and footage Adrian reportedly said showed no evidence of Daniela leaving the room — Lauren Salzman's direct testimony on Day 10 included discussion of the security camera and related footage.
1 mention
Sexual-content collateral Jane Doe said she provided and Daniela Padilla used to blackmail her — In her Day 29 victim statement, Jane Doe said she supplied sexual-content collateral as a secrecy pledge before learning about DOS. She said Daniela Padilla later used it to blackmail her, and she left DOS despite fear that its release would harm people close to her. She said the collateral was not released.
1 mention
Tape described in the e-mail as lost rather than destroyed — During Anthony Valenziano's cross-examination on Day 21, Agnifilo read a July 2 email asserting that the tape had been unintentionally misplaced, not destroyed. That assertion represented the correspondent's position rather than independently establishing what happened to the tape.
1 mention
Unreleased position statements, favorable testimonials and a compilation of apparent consent that included photographs Salzman had required women to retake looking happy — Salzman acknowledged that the compilation used photographs she had required women to retake looking happy. She said the compilation omitted negative concerns.
1 mention
Unspecified impeachment material concerning Mr. Vicente, discussed for advance sharing — Lesko requested impeachment material that evening before anticipated cross-examination. Agnifilo said he would review the request while maintaining that the defense had no obligation to provide it.
1 mention