4.Opening Statement — Prosecution

MS. HAJJAR: The defendant Keith Raniere claimed to be a leader but he was a con man. He targeted people who were looking to improve their lives. He drew them in slowly with promises of success, of money, of better relationships, and once he gained their trust, he exploited it.

The defendant said that he was a mentor but he was a predator. He targeted young girls, selecting some for special attention, but this was an excuse. He offered to mentor them to teach them and that was an excuse to groom them for sex. The defendant took advantage of these young women, emotionally and sexually. The defendant pretended to be a guru but he was a criminal and along with an inner circle of followers, he committed crimes, crimes of extortion, forced labor, sex trafficking, fraud, and the production and possession of child pornography, and that's why we are here.

As you have heard, my name is Tanya Hajjar. I'm an Assistant United States Attorney in the Eastern District of New York. These are my colleagues, Moira Penza and Mark Lesko and Terry Carby, a paralegal specialist with our office, and we're joined today by Special Agent Michael Weniger of the Federal Bureau of Investigation. Together we represent the United States in this case.

Now, during the course of this trial, you will learn that starting in 2003 and continuing until his arrest in March of last year, the defendant was the leader of a criminal organization in upstate New York and he relied on an inner circle of followers who supported him and promoted him and committed crimes for him. They forced others to do work for him. They tracked and monitored the e-mail accounts of his enemies. They tampered with material that was to be used for a court case, they helped him sexually exploit his victims all at his direction and all for his benefit.

This group became what the law calls a racketeering enterprise. They changed over time, the members of this group, but they all had the defendant in common. They served him and they were loyal to him. Why?

During the course of this trial, you will learn that some people really believed in the defendant. He created organizations that supposedly offered self-help programs. You will hear about one organization that was called NXIVM, spelled N-X-I-V-M, and you will hear about another organization called DOS or The Vow and all of these organizations were based on the defendant's so-called teachings. They were pyramid in structure with a rank and a hierarchy, and always the defendant was at the top. His followers called him "Vanguard." They called him "Grand Master."

Now, the defendant and his followers recruited people from all over the world including from here in Brooklyn, and in order to recruit, he sold himself as the smartest, most ethical man in the world. He compared himself to Einstein, to Gandhi, and he recruited millionaire heiresses, he recruited TV actresses. He drew in followers that put their trust in him and he used that trust for the things that he wanted: Sex, power and control.

The defendant maintained control over his followers and his criminal organization in several ways and one of them was by ensuring that no one questioned him. No one could challenge his authority. If they did, they were called "prideful," they were called "defiant," and they needed to be taken down a notch. They needed to be put into place. The defendant used shame and humiliation as ways to break people down.

Some of the people the defendant recruited were not U.S. citizens and so could not legally work or live in the United States and so the defendant made them dependent on him in other ways and used the threat of deportation as a way of getting them to do what he wanted. Another way the defendant maintained control was through isolation. He got his followers to move to his upstate, to his community in upstate New York, about a 30 minutes drive away from Albany. He isolated his followers from their family and from their friends, and if anyone spoke out against him, he told his followers to shun that person, to cut that person out of their lives and never speak to them again.

The defendant learned that these were powerful tools to exploit people and to use them to his advantage and I'm going to talk about a few of the ways, a few of the examples in which the defendant exploited people and committed the charged crimes to give you a sense of what the evidence will show, what it will prove beyond a reasonable doubt. One example involves a Mexican family that the defendant recruited to join his community in the early 2000s. The family had four children: Three daughters and a son. The defendant offered to mentor the children, to tutor them, and the parents wanted their children to learn from the defendant, to follow in his teachings, and so the family moved from Mexico to the defendant's community in upstate New York. But the defendant wasn't really interested in mentoring or teaching. Instead, he had sex with all three daughters and in order to do it, he turned family against family, sister against sister.

This is the middle daughter, Daniella. She was particularly ripe and useful to defendant. But when Daniella developed feelings for another man, the defendant punished her. He told her family that she had done something terrible, an ethical breach he called it, and that the only way for her to fix it would be to stay in a room without human contact and he turned Daniella's parents against her and got them to go along with this plan.

It started with a weekend in a little room with nothing in it but a mattress on the floor, some pens and some paper, but it turned into weeks. It turned into months. It turned into years. The door was unlocked but Daniella felt she couldn't leave. She was told that if she left the room, she would be taken back to Mexico, away from her family without her identification documents so she had no way of getting back.

Every few days, Daniella wrote letters and notes to the defendant, "I'm sorry," "I will be better," "I will be different," she wrote. "Will this earn your forgiveness?" "Is this sufficient?" A hundred times she wrote, "I'm sorry." It wasn't enough for the defendant. It could never be enough.

The defendant told Daniella's parents that she was a liar, that she should stay in the room for longer. He set up surveillance cameras outside the room so he can make sure she wouldn't leave. And when Daniella finally left the room, nearly two years had gone by, two years of this young woman's life wasted, and the defendant followed through with threats.

On his orders, Daniella was driven from New York to Mexico with little more than a few dollars and the clothes on her back and still, even then, it didn't satisfy the defendant. He maintained control of her identification documents and ordered her to do work for him even while she was in Mexico and he withheld those documents including her birth certificate in order to make her do it.

For this conduct, the defendant is charged with trafficking Daniella for labor and services.

The youngest daughter's name was Camila. The defendant had a nickname for her. "Virgin Camila" he called her. The defendant started having sex with Camila when she was just 15, the age she is in this photograph. At that time, the defendant was 45.

The defendant took graphic, naked photographs of Camila, close-up photographs of her private parts. These images are child pornography and possessing them and producing them is a crime. During the course of this trial, you will learn that these photographs of Camila were only part of the defendant's collection. He took dozens of explicit photographs of women's private parts that he kept in a folder on its computer which he labeled his studies, his souvenirs. And over the years, the defendant collected hundreds more of the same kind of photographs, graphic naked photographs, posed the same way that Camila's were.

MS. HAJJAR: Camila, yes. Thank you, Your Honor.

And you will learn that in the defendant's hands, these photographs didn't just serve his sexual needs. These photographs became instruments of coercion and of control. He used them to blackmail and to extort. He used them to increase his power.

In 2015, the defendant started an organization which was called DOS or The Vow and the defendant recruited women into DOS to serve under him as his slaves. That's what he called them, his slaves. These women recruited other women, women who didn't even know the defendant was the head of it all. They thought they were joining a women's-only group that was all about helping other women. They didn't know the defendant was their grand master.

It was through DOS that the defendant executed on a criminal plan involving forced labor, extortion, wire fraud and sex trafficking. It was a plan in which women pledged their commitment to him, a lifetime commitment, a lifetime of obedience. No matter what he said, he would be obeyed. And the defendant controlled these DOS slaves' lives, he controlled their schedule, their diet, where they went, who they saw.

How did the defendant keep them in line, keep them as his slaves? He demanded collateral, material that they could be extorted with. What is collateral? Collateral was a DOS slave's deepest, darkest secrets, accusations, true or false, against family members, her bank account, the deed to her house, graphic naked photographs that she would never want released. In the defendant's own words, it should be so distasteful to break the vow that a DOS slave would rather die than break it.

At the defendant's orders, dozens of other women were recruited into DOS and these women believed they were joining a women's empowerment group to make them happier, to make them stronger, to make them more successful. They trusted the women who recruited them. They had no idea, no way of knowing that these women were operating on the defendant's orders and were under his control.

The DOS slaves were told that they would have to get a brand to symbolize their obedience, to symbolize their commitment, and this brand was done with a cauterizing pen, a handheld surgical tool, that burned the skin and left a permanent mark on their bodies. This is what the brand looked like.

Now, the DOS slaves were told that the branding would be a bonding experience and a symbol of their empowerment, but what they didn't know, what was deliberately withheld from them was they were being branded with the defendant's own initials, a "K" and a backwards "R," "KR" for Keith Raniere. And in the defendant's words, he wanted his DOS slaves to be branded with his monogram.

After the DOS slaves were recruited, after they pledged their obedience, they were given assignments. The defendant gave them assignments that involved providing additional collateral, more naked photographs they didn't want to give but felt they had no choice. Some of the assignments involved doing work for the defendant's benefit and some of the assignments involved having sex with the defendant. I'm going to tell you about one of those assignments and a woman named Nicole.

This is Nicole. Nicole is an actress in her 30s who believed that she was joining a women's mentorship group when she agreed to join DOS and as collateral, she provided letters making damaging accusations against friends and loved ones. Once she was in DOS, she was told to meet the defendant, she was ordered to meet the defendant, and they met in a room where she was blindfolded and the defendant tied her to a table. Then a third person, someone Nicole didn't know, came into the room and began performing oral sex on Nicole and Nicole felt she couldn't say no. That third person, Nicole never found out who she was, but during the course of this trial, you will learn that the third person was Camila, the same girl the defendant victimized when she was just 15 years old. Now Camila had grown up. The same girl the defendant robbed of her innocence and of her childhood became a woman he used to victimize others. Year after year, the defendant's criminal organization grew as did his sense that he was unstoppable. If anyone criticized him publicly, the defendant fought back. He kept tabs on his enemies. He secretly monitored their e-mails. He hired private investigators. He filed criminal complaints to silence his victims. He filed lawsuits to intimidate his enemies. This was organized crime and Keith Raniere was the crime boss. Within the community, he was untouchable. His inner circle knew to carry out his orders and they became an extension of him. They did everything for him. They cooked his food, they paid his bills and they helped him commit crimes.

Through it all, the defendant maintained this charade. Even though he controlled virtually every aspect of his victim's lives, he said this was all about empowerment, about women's empowerment, but during this trial, you will learn the truth and the evidence will show that what the defendant wanted had nothing to do with empowering women and had everything to do with enslaving them, everything to do with satisfying his desire for sexual gratification, for power and for control.

MS. HAJJAR: The defendant is charged with an involvement in 15 years of criminal activity. He is charged in a federal indictment with racketeering charges, which basically means he is charged with committing a pattern of crimes as part of a criminal enterprise and those crimes include extortion, fraud, identity theft, sex trafficking and forced labor and production and possession of child pornography.

Now, over the next few weeks, we will present evidence to you that proves these charges beyond a reasonable doubt. So what is that evidence? You will see and you will hear the defendant in his own words. You will see e-mails and messages that he sent to his partners in crime and to his victims. You will see messages he exchanged with Camilla in which he said that it would be good for her to own a slave for him and that his slave should be branded with his monogram. You will also hear the defendant's voice in videos and in recordings. You will hear one recordings, for example, in which the defendant says that a DOS slave being branded should be completely nude and held at the table like sort of a sacrifice.

You will also hear from some of the victims and the witnesses themselves, some of the women the defendant exploited. You will hear from Daniella, the woman the defendant kept in a room, and you will hear from some DOS slaves, including Nicole, women the defendant had branded with his initials.

And you will also hear from some members of the criminal organization the defendant led, including some of his most-trusted associates. And these witnesses will give you an inside look at these organizations. These are people the defendant chose to use and employ for a specific purpose and you will see why he chose them.

You will see that the defendant surrounded himself with people who believed he was a good person, who trusted him, who chose to follow him rather than to do the right thing. And some of these witnesses committed serious crimes with the defendant and they are testifying pursuant to agreements with the Government. And listen carefully to their testimony and you will see it not only makes sense, it is supported by all the other evidence in this case.

Lastly, you will see physical evidence. You will see the photographs the defendant took of Camilla; you will see the camera that he took those photographs with; you will see the letters and the notes that Daniella wrote; you will see the photographs, the video, the vows of obedience the DOS slaves made to the defendant.

This evidence will come in witness by witness. It won't always come in clean chronological order, but you will see how this evidence fits together and it fits with the charges in this case. And when the case is done and all the evidence is in, we will have an opportunity to review it with you, and then we will ask you to hold the defendant accountable, hold him accountable for creating and leading a criminal organization, hold him accountable for defrauding and extorting his victims, for taking advantage of them sexually, for producing and possessing child pornography. We will ask you to return a verdict of guilty on all counts. Thank you.