2.Lauren Salzman — Direct (Part 3)
1,972 linesDIRECT EXAMINATION (CONTINUED) BY MS. HAJJAR:
MS. HAJJAR: Good morning, Ms. Salzman.
LAUREN SALZMAN: Good morning.
MS. HAJJAR: Ms. Salzman, you testified yesterday that there were videos made of the branding ceremonies for your DOS slaves; is that correct?
LAUREN SALZMAN: Yes, that's correct.
MS. HAJJAR: And after DOS was publicly exposed, did you participate in discussions about releasing any of these videos?
LAUREN SALZMAN: Yes, we did. I did.
MS. HAJJAR: Can you explain that further?
LAUREN SALZMAN: Yes. We discussed among first-line DOS masters and Keith the idea of possibly releasing the branding video or showing it to -- Keith was debating whether we should show it to possibly reporters or release it publicly to discredit from the allegations that were being made concerning what took place during the branding ceremony.
MS. HAJJAR: Were there discussions about editing the video?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain those?
LAUREN SALZMAN: Yes. We edited out the -- Keith said that he was considering whether we should show it to the media reporters or release it publicly. And I asked, What about, like, all of it, all the dialogue back and forth? And he said, Well, that part could be edited out and the -- it could be blurred. The nudity parts of it could be blurred, and so he instructed us to do that. And in the fall of 2017, so like around September, Nicki and I did that. We edited out the dialogue portions of the branding ceremony from Sarah's branding video specifically.
Those were -- that dialogue that was edited out were the things that we discussed yesterday in the book plus other concepts, but things like that I'm committing my labor, my material possessions, my body for unconditional use to my master and that that's my highest priority.
MS. HAJJAR: Those pieces of dialogue were removed from the tape?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Was one part of the dialogue kept in?
LAUREN SALZMAN: Yes. The part that said, "Master, please brand me. It would be an honor, an honor I want to wear for the rest of my life," which each DOS slave was instructed to say at the start of each ceremony.
MS. HAJJAR: And you testified, Ms. Salzman, that during your branding ceremony your arms were held over your head?
LAUREN SALZMAN: Yes, they were.
MS. HAJJAR: Was that something that was done with your DOS slaves as well?
LAUREN SALZMAN: Yes. I duplicated what was done with me.
MS. HAJJAR: When this was discussed with the defendant and the first-line DOS masters, were there concerns about showing the video to press and others?
LAUREN SALZMAN: Yes, there were several concerns. We thought that them seeing it might things worse. It looked weird. Also some people said it looked sexual in nature because everybody was naked and holding each other down. And so we thought it might make things worse, not better.
Also even though it showed laughing and joking, it still looked like what it was. It looked -- I mean, the branding ceremony is not a pretty process, and I don't think it's -- it's a very mainstream or common process. So I think it was viewed that it would look badly if people saw it, even if it showed inconsistencies.
MS. HAJJAR: At some point did you assist in creating a transcript of the video?
LAUREN SALZMAN: Yes, I did. Keith discussed several options that we could possibly show it to a reporter who could report on it. We could release it publicly so the public could see it. We could play the audio of it so it could be heard or there could be a transcript. And so I was instructed to just transcribe it and have all of these options ready. And so I did so taking out the same parts that we edited out of the video and leaving in the part about, "Master, please brand me. It would be an honor that I want to wear for the rest of my life."
MS. HAJJAR: And why was a transcript considered as opposed to the actual video?
LAUREN SALZMAN: Because the transcript was more neutral and they wouldn't see the part that looked scary or odd.
MS. HAJJAR: Are you aware if other branding ceremonies were videotaped, the ones of DOS slaves that were not yours?
LAUREN SALZMAN: I believe they were -- all were. That was part of the protocol.
MS. HAJJAR: Do you know where those videos are now?
LAUREN SALZMAN: I don't. I assume they're either with the top of the DOS masters or with Rosa Laura, who held all the collateral, as mine were with me, which is why I said that.
MS. HAJJAR: Around this time, did the defendant draft a position statement as to DOS?
LAUREN SALZMAN: Yes, he did.
MS. HAJJAR: May I show something to the witness alone, Your Honor?
THE COURT: Go ahead.
MS. HAJJAR: Okay.
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, I'm showing you what is marked for identification as Government's Exhibit 1321.
Do you see that?
LAUREN SALZMAN: Yes, I do.
MS. HAJJAR: What is that?
LAUREN SALZMAN: This is a draft of thoughts, were Keith's position statement that he e-mailed to the first-line DOS masters.
MS. HAJJAR: Your Honor, the Government offers Government's Exhibit 1321.
MR. AGNIFILO: No objection, Your Honor.
THE COURT: Government's Exhibit 1321 is received in evidence.
(Government's Exhibit Number 1321 so marked and received in evidence.)
MS. HAJJAR: Who wrote this e-mail, Ms. Salzman?
LAUREN SALZMAN: Keith wrote the e-mail.
MS. HAJJAR: And who was it sent to?
LAUREN SALZMAN: To Daniella Padilla, Monica Duran, Loreta Garza, Allison Mack, Rosa Laura Junco, Nicki Clyne, myself, and Camila.
MS. HAJJAR: And what is the subject of this e-mail?
LAUREN SALZMAN: A quick draft of thoughts for a position statement.
MS. HAJJAR: What is the date?
LAUREN SALZMAN: Wednesday, October 18, 2017.
MS. HAJJAR: At around the time that this e-mail was sent, had there been a New York Times article published?
LAUREN SALZMAN: Yes, there had, a few days before.
MS. HAJJAR: Did it feature Sara?
LAUREN SALZMAN: It did.
MS. HAJJAR: Can you read the text of this e-mail, please.
LAUREN SALZMAN: The shaming of these women, especially when men doing similar more drastic activities (see the Omega Psi Phi fraternity) are upheld -- is a primitive covertly misogynistic strike against the rights of women and women generally. If women choose to brand, pierce, mark, tattoo, or otherwise physically adorn themselves for any reason, they should be allowed to do so without shame or scorn. It is the nature of a free society.
This campaign is not only a campaign against the rights of women and alternative lifestyles, it is a campaign against freedom itself. Any society that upholds shaming people to comply with the norm -- it says "with," but I think it means -- will likely not advance and fall into despotism. As important as freedom of speech is freedom of expression. This campaign seeks to destroy that freedom. The women of the sorority chose to mark themselves as a stand of solidarity and a symbol to each other of mutual commitment. Should that be punished or scorned? Whether NXIVM, Keith Raniere, or anyone else associated with them likes or dislikes it, these women should have the freedom to express themselves. NXIVM, Keith Raniere and Associates uphold this right beyond personal opinions. Although this group has nothing at all to do with NXIVM or related company trainings, or corporate activities and many of the individuals involved have never been associated with NXIVM, Keith Raniere, or related companies at all, NXIVM, Keith Raniere and Associates strong support, I think it's strongly support their right to these consensual activities without shame.
To be clear, this sorority is autonomous, separate and distinct from NXIVM, Keith Raniere and Associates. NXIVM, Keith Raniere and Associates, although having little knowledge or authority in the issue, applaud the courage of these women who stand in opposition to primitive social norms and stand in solidarity with them in their right to freedom. The few women who undergo the rigorous consensual screening and invitation process making multiple promises and assertions in several stages, taking a life vow of secrecy and pledging like the founders of the U.S. Declaration of Independence, quote, their lives' fortunes and their sacred honor, end quote, to be a member of this group and then breaking such a vow is shameful. It is ultimately -- it ultimately reveals the character of the person, the vow breaker, as a liar. Any story based on the few liars who seek to shame their sisters because of their own dishonor is regretful. Imagine if our forefathers had done the same the moment times got difficult.
MS. HAJJAR: Ms. Salzman, you testified yesterday that you lied publicly within the NXIVM community about the defendant's involvement in DOS.
LAUREN SALZMAN: Correct. And outside the NXIVM community.
MS. HAJJAR: Did you lie and tell others this similar account to what's in this position statement?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: What's your view of this position statement now?
LAUREN SALZMAN: I think the position statement is a misdirection of what actually's going on. The New York Times article was not an attack on alternative lifestyles. It was asserting that the women have been coerced to do something against their will. And it wasn't even an attack on branding as a practice, it was an attack on the circumstances under which the women became branded within this organization and the nonconsensual nature of that given the collateral that established their lifetime view of obedience to obey everything that we said, including getting branded.
And in addition, so making it this campaign against freedom, we can all go, Oh, yeah, like let's fight for our freedom to express ourselves however we want and lose sight of what actually was going on, which is their very valid concerns and allegations to be made and the statements about Keith's involvement are not true.
MS. HAJJAR: Do you have an understanding as to why the defendant sent this e-mail to you and the other first-line DOS masters?
LAUREN SALZMAN: Like he wanted us to write position statements as well and instructed us to do that. But I think it was setting the precedence for how those position statements should go and what those position statements should convey, which is that he is separate, distinct, and aside from anything in the sorority and had little knowledge of anything going on there, even though he created the whole thing and had very intimate knowledge and involvement in what was going on there.
And in the position statement that we were instructed to write, I brought my position statement over to his house and he specifically edited it and added things to it to make it clearer that he had nothing to do with it.
MS. HAJJAR: The statement, The few women who undergo the rigorous consensual screening and invitation process, what did you understand that to be referring to?
LAUREN SALZMAN: The process of -- enrollment process basically where they are told that we have something to tell them, that they need to give collateral to keep it a secret, and that once they give the collateral, they're told four things about it. And then if they decide to join, that they then give more collateral. That all of that is a type of rigorous and consensual participation between people.
MS. HAJJAR: Do you agree with the characterization of this process as in the position statement?
LAUREN SALZMAN: No, I don't.
MS. HAJJAR: Can explain that?
LAUREN SALZMAN: Because once you have collateral over somebody's head, then the way they interact with the situation is entirely different. As well, we all were put in positions where the people who invited us into the sorority were people that we trusted, people that we looked to and looked up to, to lead us in ethical decision-making and in our growth and in a situation where somebody's saying this is -- this is what you need to do to grow. If you're really committed to growth, you would do this, you know. And the really committed people do this, and the people who are making the evaluation of who the really committed people are, are the people who are in the leadership roles to evaluate whether you're really committed or whether you're really growing. They're the people who put you up for promotions in the organizations that you're working in, and they're the people who either respect you or don't respect you, who take you seriously or don't take you seriously within your community. There was incredible pressure to make this choice. Even after the initial collateral was given and then more collateral was given after we already had the collateral, the first collateral. And once they agreed to a vow of obedience without knowing what they're going to have to obey, asking for more collateral, continuing to ask for more collateral, is something they feel they have to obey their collateral is subject to be released. So that is not consensual in the way that it appears, as it's being represented to be.
MS. HAJJAR: At the time the defendant wrote this e-mail to you, was he aware that DOS slaves had been recruited into DOS not knowing that he was their grand master?
LAUREN SALZMAN: He instructed it, of course he knew. And when asked to tell them that he was their grand master we were told no, by him.
MS. HAJJAR: At around this time did NXIVM, the company, hire a public relations firm?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And did the firm reach out to a reporter to run a story on DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Do you know the name of that reporter?
LAUREN SALZMAN: Vanessa Grigoriadis, I think.
MS. HAJJAR: Were you interviewed by that reporter?
LAUREN SALZMAN: Yes, I was.
MS. HAJJAR: And what did you tell her?
LAUREN SALZMAN: Same thing I told everybody. I -- mostly -- most of the subject of my interview with Vanessa related to NXIVM. But any statements that I would have made to her about the sorority contained all the misrepresentations and untruths that I've testified to so far. And I even represented things about Jness that I really have no experience or knowledge about because I was sent in really to be the spokesperson for both of these things, and I did that.
MS. HAJJAR: You mentioned Jness earlier in your testimony. Can you just remind the jury what Jness is?
LAUREN SALZMAN: Jness was a women's organization and it had a very specific gender focus, how are women, how are men, how do they relate with each other? That was the main curriculum and subject of the entire education of Jness.
MS. HAJJAR: What was your view of the Jness curriculum?
LAUREN SALZMAN: I really struggled with the Jness curriculum on a number of levels. I thought a lot of it was trying to normalize and legitimize Keith's polyamorous lifestyle and help lay a philosophical foundation for why we should all get on board for that. We should have these monogamous relationships where men get to have all these polyamorous relationships and that that's the nature of men and that this is something to be understood, you know, and promoted, and that was very difficult for me.
And there were also parts of the Jness curriculum that seemed to be advocating for -- but it doesn't matter -- that the most ethical and the most open-minded non -- nonvested and nonissue perspective would be not that you have your own children, but that you have the most genetically fit children. And so I thought that it was advocating for people to want to have children specifically with Keith because of his most genetically fit, you know, high intellect, ethical, compassionate perception as a human, that this was like how he was laying the foundation for people to think that that was a good idea and accepts that and want that.
I think a lot of -- you know, on retrospective, I think a lot of the Jness and the SOP and DOS curriculum was creating a community of people and kind of even an army of people to insulate and protect Keith and his views and legitimize and advocate for the lifestyle that he wanted to live. And a lot of us had real problems with it, and we were told that it was our issues and it was our indoctrination and it was -- you know, that was problematic and that had to go, but it was limited. It was fear based and, you know, it was incredibly restrictive and it was creating damage and thwarting our objectives as an organization and as a community.
MS. HAJJAR: Notwithstanding your comments to the reporter, had you had these feelings about Jness earlier when you first took their curriculum?
LAUREN SALZMAN: Yes. And I discussed them with different people. I went and had EMs about them with a number of people.
MS. HAJJAR: Can you --
LAUREN SALZMAN: I went to Keith, too, and said, Is this what you're advocating for? Like, is this what you think that everybody should be, polyamorous? And he said, No, I'm not, necessarily. I was thinking about it more like if people understood that men had these needs or whatever, there might be places where they could go to get those needs met like with prostitutes or something like that. I was like, Really? That's like -- is that what we're advocating now for? That all the -- that all the couples in our community now understand that men have these needs and they need to go get them met in other places? To me it was very difficult, you know.
And I -- and I chalked it up to obviously I'm having a big reaction to this so I need to look at why it's my issue, you know, and work it through and there's a lot that I can learn, obviously.
MS. HAJJAR: Ms. Salzman, you say, Obviously I had a reaction to this. It's obviously my issue. What are you talking about? Can you explain that?
LAUREN SALZMAN: Yeah. That -- I mean, within our curriculum, within the NXIVM curriculum, which was laid out first and then it carried over into Jness and SOP, the women's and men's curriculum and into DOS as well, that when we have emotions and emotional reactions to things and the circumstances, that that's a clue to something that's going on internally with us. But it's not the external circumstance that's problematic. It's our reaction to it, you know, that's indicative of some limiting belief or fear that is an opportunity for us to grow and that we should view it as that.
So when I had strong emotions and reactions to the things, I looked at it as I must be really limited. And when I went to go talk to other people about those things, they were like, Well, this is exactly why Keith put it in the curriculum, to give you this opportunity to grow through it.
MS. HAJJAR: Do you have that view now?
LAUREN SALZMAN: I think that there are things that are legitimately objectively good or bad, and there are things that are subjective. But there are things that are subjectively good or bad. And that it's a hundred percent normal to feel emotional about that. Even if there are limiting beliefs or whatever, it doesn't negate the fact that certain things are not good and that certain things are criminal.
MS. HAJJAR: Were other first-line DOS masters interviewed by the same reporter?
LAUREN SALZMAN: Yes. At least Allison, and I think possibly Nicki, too. But I'm not a hundred percent sure on that.
MS. HAJJAR: Did you subsequently learn something about what Allison Mack had said to the reporter?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: What was that?
LAUREN SALZMAN: There were a few things that I learned. One, was that she had said in -- she conveyed it as a moment of impulse. She took credit for coming up with the idea of the brand and then was like, I don't know why I did that. You know, I just felt special in the moment and I was, you know, and I said -- I said it. But that was false.
And that she also -- her accounting of it was that she characterized it as this wonderful opportunity for women to explore their sexuality and sensuality as women, which I specifically disagreed with.
MS. HAJJAR: Was Nicki Clyne interviewed by the reporter, to your knowledge?
LAUREN SALZMAN: Either she was or she believed she was going to be and we had discussions and made preparations for that.
MS. HAJJAR: Did she ask you for anything before she met with the reporter?
LAUREN SALZMAN: She did. She -- she asked -- she thought that it would be a good idea to have a visual representation of the brand and to show how each of the lines of the brand could legitimately represent the alternate story that we were laying out, which was the seven chakras, the four elements, Bar Alpha Mu, and there was another thing about triangles descending and ascending triangles and lines. And so I -- I agreed to do -- to draw this out and I grafted, I drew it on the graph paper where I just reproduced the brand each time in its entirety but highlighting the element that I was referring to and how it was each of the things, each of -- what it represented, the seven chakra or the four element or the Bar Alpha Mu. I highlighted how you could see -- each of those could be interrupted from the brand.
MS. HAJJAR: Can I show something to the witness alone, Your Honor?
THE COURT: Go ahead.
MS. HAJJAR: Thank you.
MS. HAJJAR: Ms. Salzman, I'm showing you what is marked as Government's Exhibit 436.
Do you see that?
LAUREN SALZMAN: Yes, I do. This is the -- the drawing that I made for Nicki to show Vanessa.
MS. HAJJAR: The Government offers Government's Exhibit 436 in evidence.
MR. AGNIFILO: No objection.
THE COURT: All right. Government's Exhibit 436 is received in evidence.
Publish to the jury.
(Government's Exhibit Number 436 so marked and received in evidence.)
(Government's Exhibit Number 436 is published to the jury.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, can you explain what you drew and why?
LAUREN SALZMAN: Yes. So in each of the diagrams you can see that I drew the brand as it exists. So it has the K-A-R. But I highlighted specific sections of it to misrepresent what it stood for. So at the top, I highlighted the line across which is the back of the K and showed how it was the bar. I showed the A in the subsequent one below and said that it was an alpha. And the R in the final one with the line at the A -- sorry. I didn't mean to draw on the screen -- I -- I represented as an M for Mu.
MS. HAJJAR: And this concept that the Bar Alpha Mu could be an explanation for the brand, who gave you that idea?
LAUREN SALZMAN: Keith.
MS. HAJJAR: And was this after DOS was publicly exposed?
LAUREN SALZMAN: Yes.
MS. HAJJAR: I show you the second page of Government's Exhibit 436.
Can you explain what -- what's drawn here, Ms. Salzman?
LAUREN SALZMAN: Yes. This page is me representing the brand as the four elements, so air, earth, water, and fire. And I drew the lines accordingly at the top. The back of the K was the horizon. The triangle in the A was the earth, the mountain. The R was the squiggly line representing the river or water element. And the brand itself because it was, you know, burned on, it was to represent fire.
MS. HAJJAR: And was this supposed to be another explanation for the lines in the brand?
LAUREN SALZMAN: Yes, it was.
MS. HAJJAR: Other than the defendant's initials?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Showing you the third page of Government's Exhibit 436.
Can you explain what you wrote here?
LAUREN SALZMAN: Yes. I'm showing how there are seven lines in the brand and that those seven lines could be interpreted to represent seven chakras. As well, below that the symbology of lines and triangles and that straight lines could be seen as representing an unwavering moral code, and triangles representing male and female principles, which were not actually part of the brand.
MS. HAJJAR: And was this another false explanation for what the lines in the brand stood for?
LAUREN SALZMAN: Yes, all of them are.
MS. HAJJAR: Prior to you meeting with the reporter, had the defendant travelled to Mexico?
LAUREN SALZMAN: Yes. He traveled to Mexico in October 2017, returned back to Mexico in November 2017 and never came back to the States until he was arrested.
MS. HAJJAR: Did you spend New Year's Eve with the defendant in Mexico?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: Can you explain that to the jury?
LAUREN SALZMAN: Keith went back to Mexico like in November, middle November, and within a short period of time cut communications and I didn't speak to him for a period of weeks. I can't recall if it was four or five or six, something like that, but was out of communication for some time. And at one point, he resurfaced and Loreta told me that I could get a prepaid phone and that I could communicate with him on the phone and through those communications on the burner phones. I -- he invited me to come and spend New Year's in Mexico.
MS. HAJJAR: And what is a burner phone, Ms. Salzman?
LAUREN SALZMAN: It's prepaid phone, basically, that you can buy in a store that is not linked to your person. So it's not traceable to you in any way like your e-mail address or your name or anything. It's untraceable. It's unlinkable to you.
MS. HAJJAR: What was the purpose of you buying a burner phone to communicate with the defendant around that time, November 2017?
LAUREN SALZMAN: Because he wouldn't communicate with me otherwise. He was communicating on those phones, and I was told if I wanted to communicate with him, I could communicate with him if I were to get a phone like that.
MS. HAJJAR: Did you subsequently learn the agents had visited the NXIVM center in Monterrey at around that time?
LAUREN SALZMAN: I did hear that, yes.
MS. HAJJAR: What did they do that you heard?
LAUREN SALZMAN: That they had come to the NXIVM center in Monterrey asking for Keith and that they left business cards.
MS. HAJJAR: After you spent New Year's Eve -- well, while you spent New Year's Eve with the defendant, did he tell you anything when you were there?
LAUREN SALZMAN: Yes. He told me that there were investigations in three countries into our opposition, the people who were oppositional to us, and making -- the allegations -- public and private allegations against us, and that we were going to win because the truth was on our side; and that he communicated a number of ideas for the upcoming coach summit. He told me that I could speak to Clare about getting a Proton mail address.
MS. HAJJAR: What is Proton mail address?
LAUREN SALZMAN: It's an encrypted e-mail address that also is not linked to you in any way, to your name, to your -- anything about you.
MS. HAJJAR: Where had you visited the defendant in Mexico?
LAUREN SALZMAN: On that trip I visited him in Punta Mita. That's near Puerto Vallarta, Mexico.
MS. HAJJAR: Before the defendant left for Mexico that second time, did you have an opportunity to observe him?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: And what did he do before he left for Mexico?
LAUREN SALZMAN: I went to see him at 21 Oregon where he was living at the time and he -- or he had lived, and he was baking up his devices. And he left some things behind, some money and some letters and some -- possibly other things, but I knew specifically about the money and the letters.
MS. HAJJAR: Was there anything else that he did with respect to his electronic devices at that time?
LAUREN SALZMAN: Yes. He had Nicki forward him from one e-mail account to another e-mail account a number of naked pictures and collaterals.
MS. HAJJAR: Which account to which account?
LAUREN SALZMAN: I had heard from Nicki that there was an account that -- she called it the Stevie account. I'm not sure of the address on it, but that's what she referred to it as. And she forwarded them from that account to Keith's Yahoo! mail account. She was sharing this because she was concerned about it because she felt it was a breach of security, and the idea had always been those things really need to be locked down and not made public.
But he instructed her to do it and she did it.
MS. HAJJAR: Was there anything else the defendant did before he left for Mexico?
LAUREN SALZMAN: Not other than leaving the letters and the money.
MS. HAJJAR: Can you explain the money?
LAUREN SALZMAN: The money was a Ziploc bag that appeared to be from Dawn Morrison, that she had a company that Keith had given her the idea for and he -- she paid him royalties as part of the -- like the tribute for the idea of the business. And he had -- it wasn't that much money, but he had not seemingly saved all the money that she had given him. So there were like little envelops of like $5, $10, $20. So he had saved it all in this Ziploc bag and it appeared to be over many years. And it was, you know, Dawn's handwriting and the dates and the amount on it. And so he left it with Nicki who then gave it to me.
MS. HAJJAR: The fact that the defendant did these things, does that give you any particular impression?
LAUREN SALZMAN: It gave me the impression he wasn't coming back or coming back anytime soon. If this is money that he had saved over a number of years for Dawn or for whatever reason, why now all of a sudden not keep that.
MS. HAJJAR: After you visited with the defendant in Mexico, did you return to the United States?
LAUREN SALZMAN: Yes, I did --
MS. HAJJAR: Why?
LAUREN SALZMAN: -- come back.
Well, I just came home and I was still living at home. I had responsibilities in New York. My family was all here.
MS. HAJJAR: Did you address the community after you returned to the United States?
LAUREN SALZMAN: I did, yes. And there was a coach summit that we ran immediately after that as well.
MS. HAJJAR: You testified --
LAUREN SALZMAN: A NXIVM coach summit.
MS. HAJJAR: You testified yesterday that you lied in a community meeting?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you describe that to the jury?
LAUREN SALZMAN: Yes. So Keith had been communicating since before the holidays -- so it was before I even saw him in Mexico -- directly and through other people that he felt that we had waited too long, we needed to address the community and address their concerns. And he didn't know why we had waited so long, and this was really problematic.
And so before we were going to meet with Vanessa, I heard through Clare several times and Nancy that Keith had spoken to both of them and said the same thing that I just said, like the community members needed to be met with, we had taken too long do it already and that it was important that they not read in the New York Times what we were going to say before they heard it from us directly.
And so that we needed to address the community first. And it was unclear who was the best person to do it. But the only two public people to speak about these things were myself and Allison. So Allison and I went before the NXIVM community the night before we were interviewed with Vanessa and communicated much of what Keith had communicated at V Week, what was in his position statement, what he had discussed with me in Punta Mita and answered questions that they had.
MS. HAJJAR: Where was the defendant at the time you addressed the community?
LAUREN SALZMAN: Somewhere in Mexico.
MS. HAJJAR: I'm sorry?
LAUREN SALZMAN: Somewhere in Mexico.
MS. HAJJAR: During this community meeting, did you say anything about having met with law enforcement?
LAUREN SALZMAN: Yes. Yes, I --
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: I can't recall my exact words. But basically that law enforcement or ex-law enforcement had vetted the situation, you know, that they had come in and done a thorough review of everything concerning the allegations, and found that there was no need for concern and that this was a very good thing.
MS. HAJJAR: Was that true?
LAUREN SALZMAN: We had met with some ex-law enforcement but -- what we told everybody -- it wasn't a thorough investigation because we misrepresented and lied about all the same things that I've been testifying for the last two days that we lied about. So it wasn't a thorough vetting or a thorough investigation.
MS. HAJJAR: So the individuals you described as law enforcement, those were individuals retained by NXIVM?
LAUREN SALZMAN: Yes, ma'am.
MS. HAJJAR: Were you honest with them?
MS. HAJJAR: What did you tell them?
LAUREN SALZMAN: I told them the same thing that I told everybody else, that the brand wasn't Keith's initials, that Keith wasn't involved. I represented it similar to Jness that he had come up with the tools and the curriculum and given us permission to use them but was not involved in the inner workings of anything and had little knowledge of what we were doing.
I said that Rosa Laura was my master not Keith. Test of Abraham, you know, that seduction assignments were never meant to be carried out, they were all just dares, that the women had come up with the idea for branding and that Keith -- the -- the -- Keith's initials were only in there as an afterthought as a tribute and not meant to be interpreted that way at all.
MS. HAJJAR: Did you provide these individuals with copies of the collateral?
LAUREN SALZMAN: I provided them with the compiled materials, at least one of them I provide the a compilation of the materials that represented examples of positivity and consent but leaving out anything that showed the opposite. And some of those pictures, as I testified yesterday, were pictures where the girls were instructed to look happy and like they wanted to be doing that.
MS. HAJJAR: Did you show them the contract you signed with Audrey that you testified about yesterday?
LAUREN SALZMAN: Yes, I did, as an example of consent.
MS. HAJJAR: Sitting here today do you believe that contract has any force?
LAUREN SALZMAN: No. And the contract -- it wasn't even complete. I think it was -- I don't know where -- where it came from. But one of the things was only like valid in the State of Maine, like it was -- it was -- in my opinion even with Audrey a symbolic contract.
MS. HAJJAR: At some point did the defendant release a public statement addressed to the NXIVM community?
LAUREN SALZMAN: Yes, he did. He released a statement on the NXIVM website, I believe.
MS. HAJJAR: And did -- what did that public statement contain?
LAUREN SALZMAN: It contained statements that he was not affiliated with the sorority, that he had little knowledge of it and that we had done a thorough review by ex-law enforcement and forensic psychologists and others, and that they had found that the women of the sorority were thriving and doing better, that this was an overall really good thing.
MS. HAJJAR: And these were the same things that you repeated at the community meeting?
LAUREN SALZMAN: Yes.
MS. HAJJAR: At some point had NXIVM retained a forensic psychiatrist?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did you speak with him?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What was his name?
LAUREN SALZMAN: Park Dietz.
MS. HAJJAR: Did you lie to Park Dietz as well?
LAUREN SALZMAN: Yes. We lied to everyone. The same story we told everyone. This was the party line on it. Keith was putting it out publicly. We all put it out publicly. It was all the same.
MS. HAJJAR: Are you aware if Clare Bronfman put out a similar public statement?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Was Clare Bronfman involved in legal efforts relating to DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did she ever ask you about DOS?
LAUREN SALZMAN: No. I asked Keith what she knew and he told me that she didn't want to know anything she didn't need to know.
MS. HAJJAR: Can you describe the role that Clare Bronfman played in defendant's life?
LAUREN SALZMAN: I think in some ways Clare was a benefactor. I think that she helped assist him in his legal initiatives. She was an NXIVM board member. She had a personal, you know, and I don't know totally the nature of their relationship, but I believe at one time at least you know, romantic relationship with him.
MS. HAJJAR: Was she dedicated to him?
LAUREN SALZMAN: Incredibly dedicated to him, incredibly loyal, incredibly dedicated.
MS. HAJJAR: At some point did the defendant discuss with you Clare Bronfman's financial support of him?
LAUREN SALZMAN: Yes.
I raised concerns at one point in time about things that were going on in the organization that I -- with Clare that I wanted to raise with Clare and he asked me to please not raise those things with Clare. And he said at some point we're going to be in a different place financially, but right now basically she's paying for everything, and please don't make a problem, don't raise it.
MS. HAJJAR: At some point did you become aware that NXIVM sent letters to certain DOS slaves in an effort to prevent them from speaking publicly?
LAUREN SALZMAN: Yes. I was aware that some cease and desist letters had been sent, yes.
MS. HAJJAR: Do you know who at NXIVM sent those letters specifically?
LAUREN SALZMAN: I believe they came from Alex Betancourt as representative of ESP Mexico.
MS. HAJJAR: Ms. Salzman, at some point did you have another conversation with the defendant about Nicole?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you tell the jury about that.
LAUREN SALZMAN: Yes. So Alex Betancourt, who was one of my closest friends, came to me at one point in time, I think, in like February 2018. And said that Emiliano, who is another one of our closest friends had come to him, had come to Alex and was upset because a women who had been one of Allison's former slaves had confided in him that she was tasked to have sex with Keith and that she felt forced to do that. And that Alex had suggested that Emiliano come and speak to me about it. And so Alex was giving me a heads-up that Emiliano was going to come raise the subject with me so that I was prepared to discuss it with him.
So I asked Alex, is it Souki, and he said no. And so I said, is it Nicole and he said yes. And so then I went to Keith to find out how to address this.
MS. HAJJAR: Why did you ask if it was Souki or Nicole?
LAUREN SALZMAN: Because I wanted to understand -- well, because they were the only two slaves of Allison's who had left and who were speaking, who were raising concerns or bringing -- raising that there had been issues and everybody else -- it could only have been attributed to them and I wanted to know who it was, so I understood what kind of a conversation I was walking into.
MS. HAJJAR: What happened after that?
LAUREN SALZMAN: I spoke to Keith and I told him about this, and asked him what to do, what should -- what do I tell Emiliano?
(Continued on the next page.)
DIRECT EXAMINATION (Cont'd.) BY MS. HAJJAR:
MS. HAJJAR: What did he say?
LAUREN SALZMAN: He told me that there had been no sex between him and Nicole and that he had given Nicole three trust tests and cited at least one that he had shown her a place in 8 Hale Drive which was the townhouse that was -- that he -- that was his, that he lived in, the executive library at one time, that he had shown her a bag of money and then left the money and later counted the money and saw that she had taken money and that he had given her three such tests and she had failed all of the tests and that she knew the truth, that she was misrepresenting the facts and that it would be good if Emiliano or somebody would bring this to her that she was not being truthful and urge her to tell the truth, change her story.
MS. HAJJAR: And how did you understand that direction to you, that it would be good if someone spoke to her?
LAUREN SALZMAN: He was telling me to do that. Keith's suggestions weren't suggestions because if you didn't do the suggestion, then there was feedback about why didn't you do the suggestion and how you were making his life difficult and why this is really problematic. So, he wanted me to go talk to Emiliano and get Emiliano to talk to Nicole and to get her to be on the other side of this.
MS. HAJJAR: Did you meet with Emiliano Salinas?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: What happened?
LAUREN SALZMAN: We did discuss it. I mean most of the subject of my meeting with Emiliano was he was leaving the organization and didn't want to be affiliated with NXIVM anymore and he and I were very close friends over many years and so that was very sad for me in the context of our relationship, so most of what we discussed was that but we discussed Nicole and what he communicated with me was that Nicole told him that --
MR. AGNIFILO: I'm sorry, I'm going to object to this as hearsay.
THE COURT: Sustained. Sustained.
MS. HAJJAR: Your Honor, may I just take one moment to confer with my colleague?
THE COURT: Sure.
(Pause while government counsel confer.)
MS. HAJJAR: Thank you, Your Honor.
THE COURT: Go ahead.
MS. HAJJAR: Ms. Salzman, without going into what Emiliano Salinas told you Nicole said, was whatever he said consistent with what you heard from the defendant in terms of what Nicole was saying?
LAUREN SALZMAN: More or less, yes, and I communicated to Emiliano that I thought Keith would like it if somebody would talk to Nicole and get her to change her story.
MS. HAJJAR: These were instructions you conveyed to him that you got from the defendant?
LAUREN SALZMAN: Yeah -- well, I told him that that's what I thought Keith would want. I didn't instruct him to do it and he wasn't going to do it, he was leaving ESP, but I didn't want to go back and tell Keith that I hadn't raised it so I communicated that I thought Keith would want that.
MS. HAJJAR: To your knowledge, did Emiliano Salinas approach Nicole?
LAUREN SALZMAN: No, not to my knowledge.
MS. HAJJAR: At this time do you know whether Nicole had ever spoken to the press or media?
LAUREN SALZMAN: I don't -- I don't know. I don't have knowledge that she spoke to the press or media.
MS. HAJJAR: Did you have a later conversation with the defendant about Nicole in Mexico?
LAUREN SALZMAN: I'm sorry, I was just trying to think if I had knowledge that she had spoken to the media.
MS. HAJJAR: Do you believe she did?
LAUREN SALZMAN: At one point I believe that there was something attributed to her that was anonymous but I don't recall what time period it was.
MS. HAJJAR: But it was anonymous.
LAUREN SALZMAN: It was anonymous. She was not publicly identifying herself in the press.
MS. HAJJAR: Did you have a subsequent conversation with the defendant about Nicole in Mexico?
LAUREN SALZMAN: I did, I wanted to know who the woman was who had performed oral sex on her while she was blindfolded and I had asked if it was Allison and he said it was not Allison and I asked who it was and he said it was Camila.
MS. HAJJAR: How did he express this to you?
LAUREN SALZMAN: That it was something that Cami was interested in exploring and -- I don't know if he thought it was -- I mean he expressed it to me on a walk, he was like smiling and laughing when he said it.
MS. HAJJAR: Prior to this had you been told about this -- how did you know to ask him that, when did you first learn --
LAUREN SALZMAN: Because Nicki had told me after interviewing India that Nicki had had to do this, she had had a test.
MS. HAJJAR: Let's back up, Ms. Salzman.
LAUREN SALZMAN: Yes.
MS. HAJJAR: When did you first hear about what had happened with Nicole?
LAUREN SALZMAN: It was in the summer following when DOS became public, I'm not sure specifically what month, but Nicki went to interview Allison's slaves to find out from a different perspective than Allison's what had taken place in the group because there were assertions of sexual relationships with Keith and coercion coming out of that group, so Nicki -- we all thought it was good but Nicki specifically went to find out what the other women's perception was of what happened.
MS. HAJJAR: What did you hear?
MR. AGNIFILO: I object.
THE COURT: Sustained.
LAUREN SALZMAN: Okay.
MS. HAJJAR: You testified, Ms. Salzman, that the defendant stated that Camila had performed oral sex on Nicole?
LAUREN SALZMAN: Yes, he did.
MS. HAJJAR: Did he express whether Nicole knew that Camila was -- had performed or -- that Camila had performed oral sex on her?
LAUREN SALZMAN: He did not and I didn't ask. I was more concerned with whether it had been him.
MS. HAJJAR: Did the defendant make an insulting comment about Nicole at this time?
LAUREN SALZMAN: Yes, he did.
MS. HAJJAR: What did he say?
LAUREN SALZMAN: I mean I had gone to him several times now about his relationship with Nicole which he had continued to misrepresent as non-sexual but then over time it started to be, well, it's different than, you know, that it kind of was sexual and then he said basically but she smelled funny which I thought was derogatory and placating that he was trying to somehow make me feel better that this is who he was choosing to have a sexual relationship with instead of me because he really didn't like it anyway.
MS. HAJJAR: Did your conversation with the defendant disturb you?
LAUREN SALZMAN: Yes. All of the things that I was learning were disturbing me and at the same time I compartmentalized all of them and I couldn't believe that these were the things and that it was -- that it could be what I was hearing or interpreting and at one point I even raised with him that I could see why other people were upset about the seduction assignments, like this was, you know, an upsetting thing and he was -- I said if I did this, like if I -- if you found out that I went and seduced some guy under a collateralized vow, I think you would have a problem with it. He was like, no, I wouldn't because I trust you. And I was like that's not believable to me. It wasn't believable to me what he was saying and I still couldn't come to grips with all the inconsistencies that I was seeing between what I -- what he was representing he was doing and what I -- all the information that I was getting about what was going on and I could not come to grips with this and I just kept shoving it aside and insisting that it's Keith, it's got to be good, it's got to be ethical, it's got to be right and going forward but it was -- it was starting to get to the point where I had real concerns.
MS. HAJJAR: Why did you stay?
LAUREN SALZMAN: It's a hard thing to explain but I mean I was with -- in NXIVM and with Keith as my teacher, as my mentor and as the person I looked to for how to be a good person and how to be effective and successful at negotiating the world for 20 years, I mean like almost half of my adult life. I never worked outside of NXIVM or outside of a company that my mom was the head of. I had never been on my own outside of this -- I had signed extensive noncompete agreements in my own field, so I didn't know -- when I considered or entertained the idea of leaving the relationship, I had to consider and entertain the idea of leaving NXIVM because I didn't see how I could leave the relationship and still exist in the same way in NXIVM and so that was very difficult and I couldn't really deal with the -- I couldn't figure out how I was going to make that work. I didn't want to be away from my mom or away from my sister and I -- but more than anything I didn't -- I wanted -- the things that I thought about Keith and all the things that he promised me to be true, I wanted to believe that all of this was for my growth and that this was -- that the relationship that he was saying we were going to have really was something that he meant and that he had promised it legitimately, that all the things that I had traded to try to prove to him that I was a good person and I was all the things that he would want me to be to feel proud to call me his partner and to have a child with me rather than saying that I was so far below his ethical standard that I couldn't even understand how far below I was which was something he said to me and like constant feedback about how I was responsible for all the problems that we were having or the failures that we were having and I needed to prove to him that I could be that. I needed -- and I thought that if I could prove that to him, then I could believe it about myself and I just couldn't justify how I -- everything and all the choices that I made in the last 20 years, if everything I was seeing was bad and so I told myself it wasn't and went forward continuing to support him and to try to prove that everything we did was not what the allegations were and it was getting harder and harder to think that what we had done was not what the allegations were.
MS. HAJJAR: Did you believe that if you didn't support the defendant that you would lose your contact with your family, your family members?
LAUREN SALZMAN: I believed that if I left this vow that I would be seen as somebody who was not -- who didn't keep their word and who didn't hold growth above all other things and if that happened, I couldn't maintain my role, my positions, my career in NXIVM as it existed and I had already lost a lot of things because he was saying that the leadership in NXIVM was responsible for a lot -- for our lack of success or our failures and so I had reason to believe that I would lose more things and that would affect my relationship with my family.
MS. HAJJAR: Did you believe that if you had spoken the truth about DOS at that time, what that would have meant?
LAUREN SALZMAN: It would have meant leaving my entire life. It would have meant -- yeah, it would have meant leaving, becoming somebody who was considered oppositional to NXIVM, on the outside, not on the inside.
MS. HAJJAR: What happened to people who were considered oppositional to NXIVM?
LAUREN SALZMAN: People don't -- people shunned them, they don't talk to them, you know, they speak about them saying that they're not doing the ethical or honorable thing, that they've broken their commitments and their vows, that they don't have good character or principles, you know, and that the good moral, noble thing is to uphold your word, uphold your commitments and stay committed to this vision and mission, you know, in the face of any adversities.
MS. HAJJAR: Ms. Salzman, you testified yesterday that you had wanted a child with the defendant?
LAUREN SALZMAN: Correct, I did.
MS. HAJJAR: And around the time that DOS was publicly exposed did you have renewed discussions with the defendant about having children?
LAUREN SALZMAN: I did. It was something I had wanted and had been pushing for for 12 years. It was something -- I mean I had wanted it forever but 12 years specifically we had been pushing for it. I had given up other opportunities to have children with other people who legitimately wanted to do that with me and he asked me not to do that so that we could do it. I was going to leave the relationship and he offered that if I stayed, we would do this and all this time he didn't do any of those things and then all of a sudden when DOS became public and Allison and I were the only people who were publicly outed and he was disaffiliating all connection with it, all of a sudden he's ready to go through fertility treatments with me which we did do and the entire focus during that time was whether Marianna was going to know or find out. It wasn't -- I said to him this is the one thing, the one thing of everything, all the things, this is the one thing that should be -- like I thought this would be the one thing that would be just us and he said, I know, I'm sorry. Basically it can't be because the higher priority is Marianna, you know, and I just find it -- and he didn't even finish the process of the fertility treatments.
MS. HAJJAR: Why not?
LAUREN SALZMAN: He needed to take a blood test and he didn't want to take it, he didn't take it and so it -- they weren't even -- I view it as a way of saying that he was going forward with his promise without really going forward with his promise. So, it's taking another step to defer this over just longer but to keep me doing what I was doing better than anybody else at that time which was going out to the whole world and legitimizing that this was good, that it wasn't what it was, you know, and to all the people in the community who respected me and trusted me and would believe me and to the press and to anybody who questioned us, I was sent to talk to everybody and I did it and I did it because I wanted to protect Keith and I loved Keith and he was saying this was the ethical thing to do, this was the noble thing to do and I couldn't believe that Keith wouldn't be telling me the ethical or noble thing to do and I was willing to put my own -- my own desires and my own what I hoped for to have for myself above everything else.
MS. HAJJAR: Did undergoing the process of the fertility treatments, starting that process affect your decision as to whether to stay?
LAUREN SALZMAN: Yes, and Rosa Laura and I had many conversations about it where she was like, see, it was all worth it, like see, he really was going to do it, all that doubt you had, all the questions, he's only doing that with you, he's not doing that with other people, like this is a special thing like and would always reassure me like see.
MS. HAJJAR: Did the defendant give you an explanation as to why he refused to take the blood test?
LAUREN SALZMAN: No, and there were many different ways that they told me that he could have taken the blood test, like he didn't even have to go in, they could have sent somebody to his house, he could have had whoever he wanted as his choice to do it, there could have been anybody who did it and he was like, you know, it's not even going to be an issue because at some point I'm -- we're going to have our own fertility clinic; he wanted to have a fertility clinic so it's not even going to be an issue. We weren't going to have a fertility clinic, he wasn't going to have a fertility clinic for years, like that was something that was so far in the future and he absolutely 100 percent knew when he made me the promise that if I stayed in the relationship we would have children because I had expressed it on many occasions that I was not interested in having children in my 50's and 60's even if we could legitimately get a surrogate to carry it, like that I didn't want to be 65 years old when my kid graduated from high school, that I wanted to have -- this was something I wanted to do now, you know, not something to put off for some imaginary fertility clinic that he was going to have in five or ten years.
MS. HAJJAR: How many times, Ms. Salzman, did you visit the defendant in Mexico around this time?
LAUREN SALZMAN: I think five total, four after the original trip on New Year's.
MS. HAJJAR: And you testified the defendant did not return to the United States during this period of time?
LAUREN SALZMAN: Correct.
MS. HAJJAR: At some point were you invited to a recommitment ceremony?
LAUREN SALZMAN: I was, yes.
MS. HAJJAR: Can you explain that to the jury please?
LAUREN SALZMAN: Keith said that he wanted us to make some time, the first nine DOS masters, not all of us, some of us but to come and visit him alone without anybody else who had accompanied us on the other trips like Clare, for example, or my mom or some of the SOP guys or Marianna and so Daniella Padilla started calling me and asking me about what the dates were of when this was going to be and communicating that he was disturbed that we weren't making it sooner, prioritizing it.
MS. HAJJAR: You said some of the first line DOS masters?
LAUREN SALZMAN: Correct.
MS. HAJJAR: Which ones?
LAUREN SALZMAN: Me, Allison, Nicki, Loreta -- me, Allison, Nicki, Loreta, Daniella.
MS. HAJJAR: Where were the others?
LAUREN SALZMAN: I don't know where Camila was, she went back to Mexico and I didn't see her again, I don't know exactly where she was. Monica I think was in Tampico with her family caring for her mother and Rosa Laura was in Albany.
MS. HAJJAR: Did you want to participate -- did you want to recommit to DOS at this time?
LAUREN SALZMAN: No, I didn't want to start with DOS again. Honestly I was relieved when we stopped doing it, when we stopped taking the naked pictures and at some point he said I don't know why you guys stopped that, you should be doing it, and Nicki and I had discussions about it like this is crazy, we don't want to be doing it and especially right now, everything is going public, we had reason to believe that there were going to be indictments or there was investigation into what was going on and we were incredibly concerned about it. He kept reassuring us there's nothing to be concerned about, this is going to go our way. It started sounding crazier and crazier that anything was going to go our way in this situation and I didn't want to and I didn't feel that that was really an option to not go forward.
MS. HAJJAR: You said you received a call from Daniella Padilla?
LAUREN SALZMAN: I received a few calls from Daniella Padilla initially for scheduling but then I was teaching an intensive in Mexico City and I received a call from Daniella and she said in that call basically that the reason that she was calling was because she wanted to talk about the recommitment ceremony and that she wanted to make sure that any reactions that anybody was going to have, any upset was handled now before we got there and then she communicated -- so, that was why she was calling, so that I could get upset now and not be upset later but that basically she thought that it would be really nice for us to do something special for Keith during the recommitment ceremony and basically the concept that she laid out, and I can't remember the words, I interpreted as group sex and I said to her -- I had an extreme emotional reaction and I said absolutely -- like no, I don't -- I do not think that part of my vow and part of my commitment with Keith to my growth has to do with having sex with you and she said, oh, no, that's not my understanding of it, my understanding is that it's going to be us pleasuring him and so I said absolutely not and I got off the phone with her and I started texting Keith and I said, is this what you want from me, this is what you think -- and I specifically called it our marriage even though I did not -- I perceived that we had an incredibly strange relationship, he kept referring to it like this is a life partnership and at one time he had said, you're going to be my wife, and I specifically referred to it that way because of what that meant; this is what you want our marriage, our relationship to be, and he said, no, this is not and our marriage will remain intact.
And then he called me and he said Daniella is crazy, that's why I didn't even talk to her for ten years, I don't know where this is coming from, but then he said, you know, you could -- look, you could be a junior member of the sorority like Rosa Laura or you can be really committed like Daniella, and I said, you think Daniella is more committed to me -- than me, you think Daniella is more committed than me, and he said, well, you're more committed to me but Daniella is more committed to growth, and I said, Daniella is committed to getting attention from you and having sex with you, and he said, well, she can use that to grow. And then he said, look, you -- you're -- you have control issues and they interfere with so many things that you do and your need to understand everything really thwarts things in a way that you can't even understand how much that thwarts things and then -- as if my asking about why this is something I need to do for my growth is a control issue and my need to understand and that that's thwarting and inappropriate to my growth.
And then he communicated a completely nonsensical sentence, the words of it did not make sense in a sentence and I said, I don't understand the words that you just used, the sentence that you said doesn't make any sense, and he said, I know and I should talk to you about this all the time -- like this all the time, like basically because my control is so bad he should never buy into any of my control and not answer any of the questions that I have, you know, and so -- and basically unless like you're going to be -- you're going to be willing to surrender to anything and everything, you're never going to get through this issue, and I said, there has to be a way that I can grow that isn't this, and he said, there isn't.
And in my mind I was like you just wrote a DOS manual that said you can choose anything to grow, like the master and surrendering is just one way, like you could study baseball and make that your life work and you could still get enlightened studying baseball, so how come all of a sudden if you can get enlightened doing anything including studying baseball, I have no way of growing except surrendering to a group blow job, and I left very disturbed and he said when we got off the phone -- he said right before I got off, he was like, so you're -- and then he cut himself off and he said, never mind. And I thought that he was going to say, so you're on board, like to go forward with whatever the recommitment ceremony is for the sex recommitment ceremony but I got off the phone and I called Daniella back and I was like --
MS. HAJJAR: Ms. Salzman, I'm just going --
LAUREN SALZMAN: I'm sorry, I'm sorry.
MS. HAJJAR: I'm going to go back and go through this a little bit.
When Daniella Padilla called you initially --
LAUREN SALZMAN: Yes.
MS. HAJJAR: -- you said she used the words "us pleasuring him"?
LAUREN SALZMAN: Correct.
MS. HAJJAR: Is that what you understood to be the sex act you were describing --
LAUREN SALZMAN: Yes.
MS. HAJJAR: -- which you envisioned the recommitment ceremony to be?
LAUREN SALZMAN: Correct, yes, this special thing we were going to do for him in the recommitment ceremony that we needed to discuss now so I didn't have an emotional reaction when the time came to do it.
MS. HAJJAR: You said you texted the defendant after that?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: What phone were you using to text him?
LAUREN SALZMAN: I had another prepaid phone that a friend had bought me in Mexico to use to communicate with him.
MS. HAJJAR: What phone was the defendant using, if you know?
LAUREN SALZMAN: I don't know specifically what phone it was, it was another I think prepaid phone, it had a 34 country code I believe.
MS. HAJJAR: You testified the defendant said you can be a junior member or you can be really committed like Daniella, is that Daniella Padilla?
LAUREN SALZMAN: Yes, correct.
MS. HAJJAR: What did you understand that to mean?
LAUREN SALZMAN: I understood it to mean that Daniella was on board for anything and in this case anything sexual and that that was the marker for whether you're really committed to growth and that if I wanted to be seen as somebody who is really committed to growth, that's what I needed to do to prove that.
MS. HAJJAR: What is what you needed to do to prove that?
LAUREN SALZMAN: Anything including group sex or anything else that was asked.
MS. HAJJAR: You said after this conversation you spoke again to Daniella Padilla?
LAUREN SALZMAN: Correct.
MS. HAJJAR: What did you -- what was that conversation?
LAUREN SALZMAN: I said to Daniella, Keith said that that was not what was asked or that he didn't instruct that, and Daniella said, I told you that he didn't instruct that, and I said, but then every other assumption that you made in the conversation including that you had an understanding from somewhere outside yourself implied that he did, and she said, you're right, I'm sorry, that's my mistake, and she fell on the sword basically for it, took responsibility for the whole thing.
MS. HAJJAR: Did you believe her?
LAUREN SALZMAN: No, absolutely not.
MS. HAJJAR: Did you speak to Nicki Clyne as well about the recommitment ceremony?
LAUREN SALZMAN: I did because I was very upset, so I left the phone call with Daniella and I called Nicki and Nicki said basically, look, this is something you're really upset about and obviously it's bringing up something for you and it would be good to just focus on getting through your issues, like don't think about what you don't know or any imaginary things that may not happen, just focus on getting through your issues, and I calmed down a little bit. And then she said, maybe it's not that you just have to do this -- that this is going to be -- because I was like this is the new thing, this is the new vow, this is what we do. She was like, maybe it's not a new thing, maybe it's just something you have to do once, you know, and once you do it, then you may never have to do it again, you don't know. And I was like I'm not going to think about it but I went back to going, okay, what's the bite size piece that I can deal with right now is just focusing on getting through my issues regardless of what happens in any other circumstance but in my mind I was going to the recommitment ceremony to find out the truth if this really was what it was supposed to be.
MS. HAJJAR: Did Nicki Clyne frame the fact that you didn't want to participate in this sex act as something -- as an issue you had?
LAUREN SALZMAN: Yes, clearly an issue that I had because I was having such an emotional reaction to it.
MS. HAJJAR: So, what did you decide to do after this conversation with Nicki Clyne?
LAUREN SALZMAN: I decided to believe Keith, hope that this was not what it was and go to the recommitment ceremony.
MS. HAJJAR: Where was it to be held?
LAUREN SALZMAN: It was in Chacala which is a small fishing village about an hour and a half outside of Puerto Vallarta and we stayed in a gated community there.
MS. HAJJAR: In Mexico?
LAUREN SALZMAN: In Mexico, yes.
MS. HAJJAR: Can you describe the trip; were there additional people present there besides the defendant and the first line DOS masters?
LAUREN SALZMAN: Initially there were, it was kind of like a -- Keith had invited a number of different people to come so there were -- some of our friends and their families were there but it was kind of like a work -- work vacation and a lot of the focus of it was on marketing and enrollment strategies for NXIVM given that most of our company had been effectively destroyed at that point.
MS. HAJJAR: So, what happened during the course of the trip?
LAUREN SALZMAN: So, a week before Easter they -- everybody left, everybody who had been on the trip left except myself, Loreta, Daniella, Nicki and Allison and we stayed to -- for this recommitment ceremony and we moved from the separate houses that we had all been living in into one house with Keith.
MS. HAJJAR: Had Clare Bronfman and Marianna, among others, been some of the people who had been present previously?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Were they aware of what was to take place?
LAUREN SALZMAN: No. Clare was aware that we stayed or she was aware at least some people were staying, I don't know if she knew exactly who, but Marianna was not aware of any of it.
MS. HAJJAR: So, what happened after that?
LAUREN SALZMAN: So, right before we had moved over to the house, to the new house, I went over to talk to Keith and he wasn't there or I couldn't find him and I couldn't find him anywhere and I couldn't find Daniella anywhere and there was -- his room to his bedroom door (sic) was closed so I assumed that they were together and I was feeling very upset about this and talking to Nicki about it and then we moved our stuff over to the new house and when we came over to the new house he asked me if I wanted to -- that he wasn't feeling well and he wanted to know did I want to take a nap.
So, we laid down and took a nap and I calmed down a little bit and felt a little bit better and a little bit better with him and when we woke up he wasn't feeling well, he communicated he wasn't feeling well and asked if I would bring him some food and I went to the kitchen and I had brought him some food. I went back to the kitchen to make myself a smoothie and Loreta came running into the kitchen and said the police are at the door, they're here for Keith.
MS. HAJJAR: What happened next?
LAUREN SALZMAN: I ran immediately to Keith's room and closed us in and tried to protect Keith and basically I tried to get him to leave, I was like you need to leave and I wanted him to get out -- I wanted him to go out a window and he didn't do that and he told me to call Jack and --
MS. HAJJAR: Who is Jack?
LAUREN SALZMAN: Jack Levy, a mutual friend of ours, and I didn't have a phone and I didn't know how to work his phone so I communicated that and he was in the phone trying to find how to call Jack and I was like -- honestly I just went into one mode which is like protect Keith and I put us on lockdown in this suite which was kind of ridiculous but I locked closed all the doors, all the blinds and I could see outside the window that federal police with machine guns and bulletproof vests, some of them wearing masks were like surrounding the property basically and I saw some of the women sitting across on a patio and --
MS. HAJJAR: When you say, "the women," who are you referring to?
LAUREN SALZMAN: Daniella and Allison and Nicki and basically they surrounded the whole property and they searched the whole property until they found that the only place they weren't able to search was the room that we were in and they came to the door and they were banging on the door and Keith was going to leave to go into -- there was like a walk-in, another room like a walk-in closet and he was going into the other room and I was like I don't -- I don't know what to do and he said, ask them if they have a warrant, and then he disappeared and went into the other room.
And so I went to the door and I asked them if they had a warrant and they said, open the door and we'll show it to you, and I said, if you show it to me, I'll open the door, like do that first, and we went back and forth a few times and they said, look, you know -- they were asking me if there were any other people with me and they were asking me if we had weapons and the whole time I just kept thinking like they could just shoot in this door and so I kept walking away from the door but then going back like to talk to them but I just kept considering that really like legitimately I might get shot right now and I kept interacting with them because my higher priority was making sure that Keith was okay.
And eventually they kicked down the door and they held me on the floor with four machine guns pointed at me and they were asking me is there anybody else in -- is there anybody else here with you, like are you alone, who else is here and I wasn't answering them and I expected -- this did not happen but I was expecting that they were going to start becoming aggressive, like I thought they were going to kick me and when I thought that was going to happen I called out Keith's name and at the same time in the room that he was in, the walk-in, there was a door on the other side and they were kicking down the door of that side but I called out -- I wasn't aware of that completely right then, so I called out his name and then he came out of the room and like for months after that I just like always felt like that was such a failure in myself that I hadn't been strong enough to not call out his name, you know, like that I didn't have the character to just protect him at all costs and I felt like I had let him down and then -- but they -- basically he came out, they put him on the floor too, they handcuffed him and then when he got -- they let him stand up and they let him see the piece of paper and basically he called out to me what the allegations were, that they were out of the Eastern District of New York, that he was being accused of sex trafficking and I can't remember what else and then they took him.
MS. HAJJAR: Were you surprised, Ms. Salzman, that the defendant went into the walk-in closet when Mexican law enforcement arrived?
LAUREN SALZMAN: I was so surprised. I -- because the whole -- like my whole -- everything we had done, like everything that I was teaching in NXIVM, everything that I was -- that I believed that I -- that I was learning in Jness and SOP and everything that I joined DOS to build all centered around the fact that we can live this principled life and that the highest principles that you can live are principles of love and love is when you do something lovingly without getting anything back and that you can die in many ways in your life but dying for a principle is like the most noble thing that you could do and I always wondered like in a moment where there was a situation, like if ever I was in, you know, this life or death situation or something would I be able to uphold my principles or would I just totally be a coward or would I forget and choose myself over somebody else, you know, but like in a situation -- like this was the most life or death situation that I was in, I mean they didn't obviously hurt me but I considered that they might. I chose what I believed we had been training for this entire time which was to choose love over everything including the possibility of losing my life and it never ever crossed my mind that if Keith and I were in the situation that he wouldn't choose the exact same thing, it never occurred to me that I would choose Keith and Keith would choose Keith because they were there for Keith, they weren't there for me and we all knew they were there for Keith so there was no need to send me to shield him or negotiate with them, he could have just protected all of us and just gone if he was going to not go out the window. Why, why would he do that, and it was -- yeah, it was shocking and then I put it aside, beat myself up over my lack of character and spent the next three months focusing on how to help Keith but when I was indicted and I had initially like three months very alone, you know, with a lot of time to think, it was one of the things I just kept going back to.
(Continued on next page.)
DIRECT EXAMINATION BY MS. HAJJAR: (Continued.)
MS. HAJJAR: What do you mean?
LAUREN SALZMAN: I mean that everything he taught us was this: Society of Protectors; this is what men are; this is what men do; this is what is noble; this is when women don't do; this is what women can't do, and then he didn't do it and I did it, and I was like, I cannot -- I can't even -- I could not make sense of how that could even be in any universe where he was who I believed he was.
MS. HAJJAR: Your Honor, I'm moving to a different topic. I know it's early, but it may be the right time for a break.
THE COURT: All right, let's take our midmorning break.
All rise for the jury.
(Jury exits.)
THE COURT: All right, witness may stand down. Please do not discuss your testimony with anyone.
(Witness excused.)
THE COURT: Please be seated.
Ms. Hajjar, about how much more do you have with this witness?
MS. HAJJAR: A few more hours. I believe the direct will continue after lunch, Your Honor.
THE COURT: You are going to go beyond lunch, in other words.
MS. HAJJAR: Yes.
THE COURT: All right.
And then the whole afternoon and perhaps --
MR. AGNIFILO: Yes, I would think so --
THE COURT: -- tomorrow?
MR. AGNIFILO: Yes, I would think the rest of the day and into tomorrow. Probably not until lunch. It depends -- well, I shouldn't say that. I would imagine about three or four hours.
THE COURT: All right. And then you know who the next witness is?
MR. AGNIFILO: We do.
THE COURT: And so just give me an idea since we're already going to be at Wednesday, how long is your next witness expected to take on direct?
MS. PENZA: Your Honor, I believe she'll be about a day and a half on direct.
THE COURT: A day and a half?
MS. PENZA: Yes, Your Honor.
THE COURT: Let me then ask this: Do you still anticipate that this is about a six-week trial, or are we working on something more robust?
MS. PENZA: We are making all efforts to stick to our original estimate.
THE COURT: All right, okay. Thank you. We'll take ten minutes.
(Defendant exits the courtroom at 11:15 a.m.)
(A recess in the proceedings was taken.)
THE COURT: All right, let's bring in the witness, please.
(Witness resumes the stand.)
(Defendant enters the courtroom at 11:30 a.m.)
THE COURT: All right, please bring in the jury.
(Jury enters.)
THE COURT: Please be seated, everyone. You may continue your direct examination of the witness, Ms. Hajjar.
DIRECT EXAMINATION BY MS. HAJJAR: (Continued.)
MS. HAJJAR: Ms. Salzman, you testified that at some point while you were at DOS, you had been told a story about how DOS began.
LAUREN SALZMAN: Yes.
MS. HAJJAR: What did that involve?
LAUREN SALZMAN: That I had understood that DOS began surrounding Cami's suicide attempt and that as part of ensuring that she would never do that again, she was asked to collateralize her life and that that was especially effective, and what I had understood was that Daniella, who was helping her, made the decision to do that as well and then they invited friends.
MS. HAJJAR: Daniella Padilla?
LAUREN SALZMAN: Yeah, that's what I had thought.
MS. HAJJAR: As you understood it, was Camila the first DOS slave?
LAUREN SALZMAN: Yes.
MS. HAJJAR: You testified, Ms. Salzman, that Camila was the youngest sister of Daniella and Marianna, right?
LAUREN SALZMAN: Correct, yes.
MS. HAJJAR: You testified that you were upset to hear of Marianna's pregnancy. Do you know what Camila's reaction to the pregnancy was?
LAUREN SALZMAN: It was very -- it was especially upsetting and devastating to Cami. She told me that -- that she had shared with -- that she told Keith --
MR. AGNIFILO: I will object to this, Your Honor.
THE COURT: Sustained.
BY MS. HAJJAR:
MS. HAJJAR: Did you have a conversation with the defendant about his relationship with Camila?
LAUREN SALZMAN: I had a discussion with Keith about Cami's reaction to Marianna's pregnancy.
MS. HAJJAR: And what did the defendant say about Camila's reaction to Marianna's pregnancy?
LAUREN SALZMAN: That she always knew this was an option. When she made the vow, he had told her this was always a possibility.
MS. HAJJAR: That what was always a possibility?
LAUREN SALZMAN: That Marianna might have a baby -- that he might have a baby with Marianna.
MS. HAJJAR: And before she made the vow, what did you understand him to be referring to?
LAUREN SALZMAN: To DOS. Like, when she agreed to be his slave and be fully collateralized in this vow, she had known ahead of time that there was a possibility that he might have a child with Marianna and that she said she wanted to do this anyway.
MS. HAJJAR: Did Camila become aware of the pregnancy after you did?
LAUREN SALZMAN: Yes, after.
MS. HAJJAR: Did you continue to see Camila at meetings of the first line DOS masters after this announcement?
LAUREN SALZMAN: To me or to her?
MS. HAJJAR: Did you continue to see her at meetings?
LAUREN SALZMAN: After -- after when?
MS. HAJJAR: Well, why don't you describe your observations of her at meetings as time progressed in DOS.
LAUREN SALZMAN: I think in the early days when I -- when I -- my early days of my enrollment in DOS -- and I had heard that Cami was kind of new to being a part of that group, but I found her much more engaged and enthusiastic, she was more connective with me and happier; and then after she found out about Marianna, it was very hard and she was not the same and she started talking about wanting to go back to Mexico and wasn't sure she wanted to stay.
MS. HAJJAR: Did she, in fact, at some point, go to Mexico?
LAUREN SALZMAN: She did, yes.
MS. HAJJAR: At some point after January 2017, did you have a conversation with the defendant about a successor?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: What did he tell you?
LAUREN SALZMAN: He told me that as long as he had been alive he had always had something called a successor and a witness, and this was the first time in his life that he didn't have people in those roles because Pam had died and, for some reason, Cami wasn't the successor. My understanding -- I thought it was because of the suicide attempt, and he didn't know if he was going to be living, like, that he -- he didn't know if he had a purpose anymore, like, he might -- his life purpose might have ended without this.
MS. HAJJAR: When the defendant said he had two roles, the witness and the successor --
LAUREN SALZMAN: Yeah.
MS. HAJJAR: -- what did you understand that -- him to be referring to?
LAUREN SALZMAN: I didn't know what they meant and I didn't really ask any questions about them. I just thought that it was some kind of, you know, mystical or energy thing that I didn't understand, and even for me it seemed very out there, but I didn't have any way to prove that it wasn't true, and if that was something that he believed in, I wanted to respect that he believed that this was a valid thing.
MS. HAJJAR: You mentioned two --
LAUREN SALZMAN: It was weird for me. I didn't understand it, but...
MS. HAJJAR: You mentioned Pamela Cafritz and Camila. What roles did those two individuals occupy in this concept as it was explained to you?
LAUREN SALZMAN: That Pam had been the witness and Cami had been the successor.
MS. HAJJAR: Do you have any understanding as to what that meant?
LAUREN SALZMAN: I really don't know what the witness was. I mean, it was never explained to me, but later my first-line DOS masters communicated that the successor was somebody who -- had to be somebody who was a virgin and that they were looking to find a replacement for Cami, and then Nicki later shared that Cami had had another relationship and that was why she wasn't the successor anymore.
MS. HAJJAR: What was the purpose of the virgin successor?
LAUREN SALZMAN: Honestly, I don't really understand. Rosa Laura tried to explain something to me once that I didn't understand.
MR. AGNIFILO: Objection.
THE COURT: Yes, the jury will disregard the answer.
BY MS. HAJJAR:
MS. HAJJAR: Did you speak to the first line DOS masters about efforts to find a successor for the defendant?
LAUREN SALZMAN: Yes. They told me that there had been efforts to find a successor.
MS. HAJJAR: Who told you that there had been efforts to find a successor?
LAUREN SALZMAN: I believe Daniella and Loreta and Rosa Laura.
MS. HAJJAR: That was Daniella Padilla and Loreta Garza?
LAUREN SALZMAN: Yes.
MS. HAJJAR: From the other first-line DOS masters, did you learn more about what those efforts entailed?
LAUREN SALZMAN: That Daniella and -- or Loreta were exploring possibly bringing or trying to get, like, sisters or cousins or people they knew in Mexico to come to Albany.
MS. HAJJAR: To do what?
LAUREN SALZMAN: To possibly fill that role.
MS. HAJJAR: To fill what role?
LAUREN SALZMAN: The successor role.
MS. HAJJAR: Did you learn from them what the requirements to fill the successor role were?
LAUREN SALZMAN: Nothing beyond that they were a virgin.
MS. HAJJAR: Did Rosa Laura Junco explain what the point of a successor was to you -- the purpose?
MR. AGNIFILO: I'm going to object, Your Honor.
THE COURT: You may answer that.
LAUREN SALZMAN: That she thought somehow it was, like, a person that would be so close to Keith that he would be able to, like, experience things through them, and I didn't know if she meant -- I couldn't conceptualize what she was talking about, whether she meant experience things through them currently or experience things through them, like, if he were to die, he would be able to still experience things through them while they were still here, and I couldn't make sense of what she was saying.
MS. HAJJAR: Did Rosa Laura express concern to you at any point about these efforts to find a successor?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain what her concerns were?
LAUREN SALZMAN: She was concerned that -- she ran a girls' program for teenage girls, an educational program, and she was concerned that communications she had with Keith about the successor may somehow link the girls' program to that.
MS. HAJJAR: Can you explain what you knew about the girls' program?
LAUREN SALZMAN: That it was a school for girls that -- I think it started for Rosa Laura's daughter and then other girls from Mexico were brought, mostly from the Le Baron community, to participate in an educational program that Rosa Laura was running.
MS. HAJJAR: Brought where?
LAUREN SALZMAN: To Albany where they came, you know, they were enrolled.
MS. HAJJAR: What were they supposed to do here? What were they supposed --
LAUREN SALZMAN: Study. Study. It was school. It was -- it was a girls' school.
MS. HAJJAR: Affiliated with NXIVM?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Ms. Salzman, I now want to direct your attention to the early 2000s when you testified that you first met Camila and her sisters.
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you describe NXIVM's initial expansion into Mexico?
LAUREN SALZMAN: Yes.
I was involved in teaching a course in Michigan and Edgar Boone took that course, he was a Mexican man from Monterrey, and he had run a human potential school in Monterrey before prior to taking our course and said that if he liked the course he would want to close down his school and work with us and bring our course to Mexico, which he did.
MS. HAJJAR: And can you describe where you first met Daniella?
LAUREN SALZMAN: I met Daniella in Monterrey, Mexico in 2001 and I taught an intensive down there at a museum, and she was one of the students in my -- in my course.
MS. HAJJAR: Where in Mexico was that?
LAUREN SALZMAN: It was in Monterrey.
MS. HAJJAR: And do you recall approximately when that was?
LAUREN SALZMAN: It was sometime in 2001. I just can't recall the specific date. It was after September.
MS. HAJJAR: How old was Daniella when you first met her?
LAUREN SALZMAN: Seventeen or eighteen.
MS. HAJJAR: What were your first impressions of her?
LAUREN SALZMAN: She was very bright and she, like, grasped the concepts that was teaching in the course very quickly comparatively to others, and most of the people -- I think almost all of the team that I had taught or most of the people I had taught up to that point had been adults, so she took to it much faster and more enthusiastically than most of my students.
MS. HAJJAR: Your Honor, may I show something to the witness. Mr. Reccoppa, may do that?
THE COURT: Fine. Go ahead.
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, I'm showing you what has been marked as Government's Exhibit 366.
Do you recognize this?
LAUREN SALZMAN: Yes, I do.
MS. HAJJAR: What is it?
LAUREN SALZMAN: It's a picture of myself and the staff who worked at that intensive that Daniella took at the museum.
MS. HAJJAR: I'm also showing you what's been marked as Government's Exhibit 367.
Do you recognize this photograph?
LAUREN SALZMAN: Yes. It's a photograph of the students and the staff from the intensive, same intensive, and Daniella is in the photograph.
MS. HAJJAR: Your Honor, the Government offers Government's Exhibit 366 and 367.
MR. AGNIFILO: No objection, Your Honor.
THE COURT: All right, Government Exhibits 366 and 367 are received in evidence, published to the jury.
MS. HAJJAR: Thank you, Your Honor.
(Government's Exhibit 366 and 367 received in evidence.)
THE COURT: Where was this again?
LAUREN SALZMAN: This was in Monterrey, Mexico.
THE COURT: Monterrey, all right.
BY MS. HAJJAR:
MS. HAJJAR: And are you in this photograph, Ms. Salzman?
LAUREN SALZMAN: I am, yes. I am second from the right in red.
MS. HAJJAR: And where are you in -- where are you at this intensive? Like, where this photograph was taken.
LAUREN SALZMAN: It was at a museum that we rented to space from to run the course.
MS. HAJJAR: What's the red object in the middle of this photograph?
LAUREN SALZMAN: It's an apple. It was an art piece that was in the museum, which I especially liked because of New York, and so we all just took our picture in front of the apple.
MS. HAJJAR: The individuals you've testified about, are any of them depicted in this photograph?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you indicate them?
THE COURT: You can circle.
LAUREN SALZMAN: Loreta and myself, obviously (indicating).
MS. HAJJAR: And that's the person that's directly to the right of that apple looking at the photograph?
LAUREN SALZMAN: Correct.
MS. HAJJAR: I'm going to show you now what's in evidence as Government Exhibit 367.
(The above-referred to exhibit was published.)
BY MS. HAJJAR:
MS. HAJJAR: Can you tell the jury what this exhibit depicts?
LAUREN SALZMAN: This is the students and staff that were present in that intensive, including Daniella.
MS. HAJJAR: And, Ms. Salzman, we didn't cover this in great detail, but what are the sashes around some individuals that are shown in this photograph?
LAUREN SALZMAN: White sashes indicate the students in the course; yellow sashes indicate coaches; orange sashes indicate proctors -- the proctors lead the curriculum and work running the programs in the different centers; and my sash was green, which was a senior proctor, so we were the higher level managers.
MS. HAJJAR: Can you indicate where you are in this photograph?
LAUREN SALZMAN: Yes. I'm down here at the bottom with Loreta
(indicating).
MS. HAJJAR: And you are wearing a green sash?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Is Daniella depicted in this photograph?
LAUREN SALZMAN: Yes, she is. Do you want me to --
MS. HAJJAR: Yes. Can you indicate where she is?
LAUREN SALZMAN: Sorry. Wait, sorry, is there a way to erase that?
MS. HAJJAR: Yes.
LAUREN SALZMAN: It didn't --
THE COURT: Go ahead, try again.
LAUREN SALZMAN: Above. The one above (indicating).
MS. HAJJAR: Who is the man that's directly to her left?
LAUREN SALZMAN: Omar Boone.
MS. HAJJAR: What is he wearing?
LAUREN SALZMAN: An orange sash. He's a proctor. And the man next to him is Edgar Boone, who also had a green sash at that time.
MS. HAJJAR: Can you describe what's hanging in the leftmost side of this photograph?
LAUREN SALZMAN: In the back?
MS. HAJJAR: Yes.
LAUREN SALZMAN: In the back was a wall indicating the progression of ranks of the sashes, and it's on the right, too. It's just not as clear in the photo. So it shows the progression, lowest rank to highest rank, from left to right.
MS. HAJJAR: Who was the highest rank at this intensive?
LAUREN SALZMAN: Edgar.
MS. HAJJAR: And after that?
LAUREN SALZMAN: Myself.
MS. HAJJAR: Did there come a time where Daniella's parents proposed having Daniella stay or go to the community -- to the NXIVM community?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you describe how that happened?
LAUREN SALZMAN: Sorry. Her father called me and basically said that she was supposed to go to Switzerland to study abroad for a year but wanted to know if she could come to Albany to study with us instead.
MS. HAJJAR: What was her father's first name?
LAUREN SALZMAN: Hector.
MS. HAJJAR: And her mother?
LAUREN SALZMAN: Adriana.
MS. HAJJAR: And the first names of her siblings?
LAUREN SALZMAN: Marianna, Camila, and Adrian.
MS. HAJJAR: Was Marianna the oldest sibling?
LAUREN SALZMAN: Marianna is the oldest, yes.
MS. HAJJAR: And Daniella was the second oldest?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And the third and fourth sibling, what orders were they?
LAUREN SALZMAN: Adrian and then Camila was the youngest.
MS. HAJJAR: What happened after you spoke to Daniella's father?
LAUREN SALZMAN: Well, what he was proposing was something we had never had. There wasn't a work study program for students in that way, so I brought the request -- I told him I didn't know that that would be possible, that I brought the request to Pam Cafritz to bring to Keith, and I heard back that that was something that they were willing to do and that Keith wanted to meet her.
MS. HAJJAR: How did Daniella arrive at the intensive in the first place? What was her introduction to NXIVM?
LAUREN SALZMAN: Her parents enrolled her.
MS. HAJJAR: And her parents had attended intensives before that?
LAUREN SALZMAN: Correct.
MS. HAJJAR: How many?
LAUREN SALZMAN: At least one. I remember seeing them on two occasions, but it could have been that they took a five-day and came back for the second half, or they could have been repeating, but I saw her parents on a few occasions before I met her.
MS. HAJJAR: Were Daniella's parents enthusiastic about NXIVM and ESP?
LAUREN SALZMAN: Yes. Very.
MS. HAJJAR: Were her parents enthusiastic about Daniella moving to the community?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did Daniella, in fact, come to live in the NXIVM community?
LAUREN SALZMAN: Yes, she did.
MS. HAJJAR: How old was she at the time?
LAUREN SALZMAN: Seventeen or eighteen.
MS. HAJJAR: At some point, did her siblings join her?
LAUREN SALZMAN: They did, yes. Marianna first and then the other two.
MS. HAJJAR: And where did her family live within the NXIVM community?
LAUREN SALZMAN: They had an apartment in Cohoes, which is a town, like, just one or two towns over from where the rest of us lived in Clifton Park.
MS. HAJJAR: Did she eventually move?
LAUREN SALZMAN: They did. They eventually moved to Clifton Park into Knox Woods, the development where a number of us were living at the time.
MS. HAJJAR: How old were Adrian and Camila at the time that they moved to the community?
LAUREN SALZMAN: I'm not a hundred percent sure, but I think Camila was maybe 14 and Adrian 16.
MS. HAJJAR: Did Adrian have a nickname?
LAUREN SALZMAN: Fluffy.
MS. HAJJAR: Were they in high school?
LAUREN SALZMAN: Yes. I believe they were in high school. I think originally they enrolled in Cohoes High School. I'm not sure if they transferred or not. I think Adrian graduated and Cami didn't.
MS. HAJJAR: Did Camila stay in high school, as far as you knew?
LAUREN SALZMAN: I don't think she stayed in high school, no.
MS. HAJJAR: What was your understanding of what Daniella was to be doing in the NXIVM community?
LAUREN SALZMAN: Initially what I thought she was going to be doing was coming to do, like, an internship with us or similar to, like, what her work -- her study abroad would be, that she would come and study with NXIVM instead, so I thought that she would become a coach and study the ESP curriculum, similar to the way everybody else did but maybe in a more condensed or expedited version -- like, version of it, so that she would have, like, full-time school like she would have had abroad.
MS. HAJJAR: Is that what happened?
MS. HAJJAR: What happened?
LAUREN SALZMAN: I'm not sure exactly what happened, but she started spending a lot of time with Keith and working with him.
MS. HAJJAR: Working with him how?
LAUREN SALZMAN: She was doing research for him and helping him by reading books on a variety of different subjects and summarizing them -- like, distilling them down to the most relevant or valuable aspects of the books to save him the time of having to read the whole book to get what the information was out of it.
MS. HAJJAR: So she distilled the concepts in the book to a more -- to an easier format or something?
LAUREN SALZMAN: That's what I understood she was doing.
MS. HAJJAR: Was this for the defendant, these reports of these books?
LAUREN SALZMAN: Yes. She was helping him, was my understanding, in doing research for him.
MS. HAJJAR: What kind of subjects were these books on?
LAUREN SALZMAN: I don't know all of the subjects. I remember one in particular, she was doing research on cryogenics because she had learned some interesting things about it that she shared with me, but I know, like, she -- at one point she was doing calculus problems -- I don't know if she was doing that on her own or for him, I know she later did that on her own -- but I think there were a variety of different subjects that she was studying.
MS. HAJJAR: And the output, the thing she was creating, was that so that the defendant didn't have to read the book?
LAUREN SALZMAN: Yes. And that he could use the information for whatever he was working on.
MS. HAJJAR: Did she spend time with the defendant, as you observed her?
LAUREN SALZMAN: Yes. I observed that she was spending time, and it seemed like she was spending more time than I had observed because there was a familiarity and comfortability [sic] that I didn't know when it happened.
MS. HAJJAR: Can you describe that?
LAUREN SALZMAN: Yeah. I mean, in the early days of, like, when I first met Keith and he was living at 3 Flintlock, I experienced it to be more of like an open-door policy where people were always coming and going there was a lot -- we spent a lot of group time together; and around the time that Dani came and Marianna, I think there were other things surrounding it, but it became less and less like that, and Dani started hanging around a lot and it became -- or -- I started seeing her when I would go over to Flintlock to see Keith, she would be there, and it became clear to me that they were spending a lot of time together. She started to lose weight and wear more revealing clothing. I remember she was wearing, like, a lot of miniskirts and things like that, so I started to assume they were -- they were or at some point they would have a relationship.
MS. HAJJAR: What was Marianna doing at this time?
LAUREN SALZMAN: I'm not sure exactly about the time frame of everything, but Marianna, when I met her, wanted to be a professional tennis player and Pam befriended her and the two of them were spending a lot of time together doing athletic stuff, and I think Keith was advising them or coaching them on how to coach Marianna to improve her tennis.
MS. HAJJAR: And this was Pamela Cafritz?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What about Adrian? What was he doing within the community?
LAUREN SALZMAN: Adrian went to high school at first, and then at some point he went to live with Mark Vicente and some other men in the community -- Ben Myers and Jim Delnegro -- but he was studying to be part of Mark's video team so he was learning filming and video editing.
MS. HAJJAR: And what about Camila?
LAUREN SALZMAN: Camila came to work in the rainbow program, which was the multicultural children's educational program and she was a Spanish teacher there.
MS. HAJJAR: Daniella and her siblings, did you have an understanding -- were they Mexican nationals?
LAUREN SALZMAN: That was -- yes.
MS. HAJJAR: Did you have an understanding of their visa status within the United States?
LAUREN SALZMAN: Initially, I didn't, but during this time, there were -- we had started teaching classes in Mexico and a lot of Mexicans were coming to the United States and taking a lot of courses with us, and so I started to learn that there's a certain amount of time that the Mexicans had to spend in Mexico to be able to qualify for their visa, so they were allowed to come to the states but only for a certain amount of time and there were restrictions.
So all the Mexicans that I was interacting with besides these -- Daniella and her siblings -- were having visa constraints that I didn't see them having, they never went back; and so I started asking Keith, like, What's going on with their visas, and he said, Don't worry about it, it's being taken care of. And then I went and asked Pam about it and Pam said, Well, they are getting visas through the father's, it's coming, so I thought that they were doing that or in the process of doing that.
MS. HAJJAR: Did you later learn anything about Daniella's status in the United States?
LAUREN SALZMAN: Yeah. There was some sort of incident where Marianna was upset about something and I was called and asked to help and I think Karen Unterreiner was involved and Karen called Daniella over to speak to Monkey -- to speak to Marianna, and Marianna basically was saying, I don't want to talk to any of you, and threatened that she was going to call the police if Dani didn't leave, and she did end up calling the police but hanging up. And I can't remember if they called back or they came, but we ended up having to deal with the fact that she had made the call, but I learned that the reason that call was threatening was because it put -- Daniella was not legitimately there; she was -- her status was illegal.
MS. HAJJAR: Did you become aware at some point that Daniella had made a land border crossing?
LAUREN SALZMAN: Yes, I did. There was a party that I attended at my mom's old house at 7 Grandhill Road in the early 2000s -- I can't quite recall the date, but at the party, I was there, my mom, Keith, Kristin Keefe, Kathy Russell, Daniella, and there were others, I just can't quite recall who, but Kristin Keefe shared that she and Kathy had brought Dani into the U.S. through a border -- a Canadian border -- the Canadian border.
MS. HAJJAR: Between approximately 2004 and 2006, did Daniella do work for the defendant?
LAUREN SALZMAN: I think so. Along the lines of what I was saying -- what I was sharing.
MS. HAJJAR: And did there come a time where the defendant stopped speaking to Daniella?
LAUREN SALZMAN: Yes. Somewhere between 2008 and 2010. I'm not exactly sure when -- the exact time.
MS. HAJJAR: And can you explain what happened?
LAUREN SALZMAN: He told me that they had had a fight, she had come into 3 Flintlock -- so into his house without being invited, just walked in -- and he closed himself in the bathroom and they were, I guess, arguing or something through the door and that at one point he had given her -- she wanted to know something and he said to her: If I tell you this information, I'm never going to speak to you again. Do you want to know this? And she insisted that yes, she did want to know this and so he wasn't speaking to her.
MS. HAJJAR: At some point, were you approached about meeting with Daniella to coach her in some way?
LAUREN SALZMAN: Yes. A few separate times. Closer to 2008, Karen had asked me if I would help her to meet with her --
MS. HAJJAR: Who is Karen?
LAUREN SALZMAN: Karen Unterreiner.
-- and so I had had a few meetings with her in those years; and then again later Karen approached me as well, closer to 2010, to help her again; and then Keith approached me finally to help her.
MS. HAJJAR: Did you learn anything about Daniella's relationship with the defendant?
LAUREN SALZMAN: I did.
So closer to 2008, I recall two times that she came over to my house and was upset and communicated that she was asking Keith whether they would have a relationship in the future and he wouldn't give her an answer about it and he wanted her to go work that out with somebody else, and that she had asked him if he felt good with her sexually and that he had told her no, and she asked him, did he feel good with anybody sexually and he had told her yes, and so she was -- this was upsetting to her.
And then another time she told me about Keith had invited her -- or told -- he wanted her --
MR. AGNIFILO: Your Honor, I'm going to object to this, Your Honor.
THE COURT: Yes, let's go to the next question.
MS. HAJJAR: Your Honor, may we have a sidebar on this issue?
THE COURT: Sure.
LAUREN SALZMAN: Your Honor, may I step out briefly to use the bathroom?
THE COURT: Yes, of course.
(Witness excused.)
(Sidebar.)
(Continued on next page.)
(In open court.)
(Witness resumes the stand.)
THE COURT: All right, you may ask your question.
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, how old was Daniella when she told you about her relationship with the defendant, approximately?
LAUREN SALZMAN: She was in her 20s. I'm not sure, 22, 24.
MS. HAJJAR: And when she told you these things about her relationship, was that prior to when the defendant approached you about a plan regarding Daniella?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And what did Daniella tell you just before the break? What did Daniella tell you about her relationship with the defendant?
LAUREN SALZMAN: The question that I --
MS. HAJJAR: Yes.
LAUREN SALZMAN: That Keith had wanted her and Marianna to both take a nap with him, and she -- this was upsetting, and I had understood that -- it to be, like, a naked nap, was how I interpreted it.
MS. HAJJAR: Did you understand, then, there to have been some sexual interaction with Daniella and the defendant at this time?
LAUREN SALZMAN: Yes.
MS. HAJJAR: After that point, did the defendant approach you with a plan regarding Daniella?
LAUREN SALZMAN: Yes, he did.
MS. HAJJAR: Okay. And what was the plan as to Daniella?
LAUREN SALZMAN: So this was later, like, in two thousand -- closer to 2010. He called me on the phone and said that there was a project and I should only take it if I really wanted it, and he told me that there were various problems with Daniella; that she had been -- among other things, she had been stealing from the family -- she wasn't working, didn't do the work that she had committed to do, she had said that she was going to lose weight but instead she had gained 40 pounds, and that she was stealing from the family -- stealing food and locking the family out of the house, these various things -- and so what he proposed was that Dani be given an ultimatum that she go in her room with no distractions and come up with a plan for how to fix this or -- and that -- or be sent back to Mexico.
MS. HAJJAR: These issues the defendant raised to you, those were things that he communicated to you?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And when the defendant approached you about this project, as you described it, was this after he had stopped speaking to her for some period of time?
LAUREN SALZMAN: Yes.
MS. HAJJAR: As you understood it, if Daniella didn't stay in the room, she would be sent back to Mexico.
LAUREN SALZMAN: Yes. That if she didn't meet the conditions of satisfaction to come out of the room and came out of the room, she would be sent back to Mexico.
MS. HAJJAR: Did you understand what the conditions of satisfaction were, as you put it?
LAUREN SALZMAN: I understood that it was a plan that -- to rectify what she had done, but when I asked specifically, like, what her breach was, Keith told me she knew what she did, she knew what it was.
MS. HAJJAR: When you say "breach," do you mean an ethical breach, like the concept you talked about before?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did the defendant acknowledge a relationship with Daniella?
LAUREN SALZMAN: No. We never discussed it.
MS. HAJJAR: Did you want to participate in this project?
LAUREN SALZMAN: I told him, no, I didn't want to take the project, but I asked him, Why do you think that I should take the project?
MS. HAJJAR: What did he say?
LAUREN SALZMAN: And he said that, Someday you might have a child -- which, in my mind, was someday we might have a child, because that was the whole plan that we were going to have children, and at the time also I was working in Mexico and kidnapping was a thing. Like, we knew a number of people who had been kidnaped or knew family members who were kidnaped, so he said, Someday you might have a child and somebody may call you on the phone and say to you, I have your child, like, basically I kidnaped your child and I'm going to kill them if you don't give me a million dollars and you're not going to know what to do, so you can learn to work with that personality now or you can deal with it then.
MS. HAJJAR: In the context of what he was telling you, who was the personality that he was describing?
LAUREN SALZMAN: Daniella, that Daniella is this type of personality that's manipulative to this degree and has, like, a sociopathology, and you can learn to work with that now or you may someday be in a situation where you are not going to be a good mom to our kid basically.
MS. HAJJAR: Did you believe him?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: What happened after that conversation --
LAUREN SALZMAN: And especially at that time, too, it was -- I thought that Keith understood everything about people's psychodynamics; if Keith observed something and I couldn't see it, it was because I didn't understand and needed to learn something.
MS. HAJJAR: So you have a different perspective now?
LAUREN SALZMAN: Well, I didn't observe directly the things that he was describing from Daniella, and I don't think that the things that were listed -- that she didn't complete book reports; that she gained weight instead of losing it; and that she was stealing food from her family when she was completely dependent on her family and an illegal alien in a country where she couldn't legitimately work -- raise to the level of going back to Mexico if she doesn't address them.
MS. HAJJAR: You mentioned book reports. Are these the distilled concepts from books that you described earlier?
LAUREN SALZMAN: Correct, yes.
MS. HAJJAR: In other words, it's not a high school book report where the purpose is for the student.
LAUREN SALZMAN: Correct. It was her helping Keith, like, as a research assistant.
MS. HAJJAR: Did you meet with the family after this conversation with the defendant?
LAUREN SALZMAN: I did. He told me -- Keith told me that he was going to call me back -- I agreed to take the project based on what he laid out, he told me he was going to call me back, and then he called me back and told me that the family wanted to go forward with this plan and the parents came over to my house and met with me.
MS. HAJJAR: The defendant told you that the family wanted to go through with this plan?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What happened when you met with the family?
LAUREN SALZMAN: Hector and Adriana came to my house and they told me that they felt that this was a good option because Daniella -- they didn't know how to handle her, basically; that they felt that it had gotten to the -- it had gotten out of control and they felt responsible for her being this way, and so they thought that this was a good option and that they were going to present her, basically, with the ultimatum that she would go into her room until she came up with something that was acceptable to them and -- or go back to Mexico.
And then there was an additional conversation that I had with Keith before they actually presented the plan to her that he said the family was concerned that she might extend the time in the room or view it as a type of vacation; and so in order to make it less comfortable and to inspire her to want to get out of the room quickly, they were going to remove anything comfortable from the room.
So the idea was that she would go into a room with nothing in the room except her bed -- like, bed on the floor, paper and pencil, and nothing else -- her clothes, you know, and not come out until she had met these conditions of satisfaction.
MS. HAJJAR: The defendant told you that the family had that concern?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What was the family's -- the members of -- what was their demeanor as they were discussing this with you?
LAUREN SALZMAN: That they seemed sad and ashamed about their participation, but that they felt that this was an important thing to go forward with, but there was trepidation; they weren't -- they were going to go forward with it, but they didn't seem -- they did not come across to me as super confident and secure in the choice or understanding of how their actions really related to what was going on with her and how this would fix that.
MS. HAJJAR: Did the defendant appear confident and secure in that choice?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did the defendant ask you to keep this project a secret?
LAUREN SALZMAN: Yes. He told me not to tell anybody about it, not to discuss it with anyone.
MS. HAJJAR: What about your communications with him about it?
LAUREN SALZMAN: When I would check in with him about it, he would suggest I come over and check in in person. He told me to: Better not talk on the phone, come over. Do you want to come over?
MS. HAJJAR: As to the initial plan, how long was Daniella supposed to stay in the room?
LAUREN SALZMAN: Keith told me initially he thought it would be, like, a weekend but that she might extend it to a week or ten days.
MS. HAJJAR: And what happened?
LAUREN SALZMAN: She stayed there for 18 to 24 months, somewhere in there, a year and a half to two years.
MS. HAJJAR: Can you describe how Daniella entered the room?
LAUREN SALZMAN: Yeah. Well, she -- so the parents gave her this option, she decided she did want to go -- that she didn't want to go back to Mexico, so she agreed to go into the room, and I think she also seemed sad about what was being presented, but she did go in.
MS. HAJJAR: Was it your understanding that if she went to Mexico, she would no longer be able to have contact with her family?
LAUREN SALZMAN: At some point, that became what my understanding was and hers. I think initially it wasn't, but I think it became that; that if she went back, she believed that they would -- she would lose her relationships with her family, and she was very concerned about that, losing their love, which to her was both the relationship with them and the love of their relationship and their support, which she had never lived without -- their financial support. She had never lived on her own without that.
MS. HAJJAR: What was in the room?
LAUREN SALZMAN: A bed on the floor and that's it. I mean, she had paper and -- access to paper and pen, pencil, and she was brought food three times a day. She was told that she was allowed to -- she could request food from her family members and they might honor those requests or not; she could communicate with them through notes; and the family said they were not going to communicate with her -- later some of them did, but that was it.
MS. HAJJAR: Was any furniture in the room?
LAUREN SALZMAN: No. Just the bed on the floor, mattress on the floor.
MS. HAJJAR: Was Daniella permitted to leave the room?
LAUREN SALZMAN: Only -- she was permitted to go in her room and the bathroom, which was a shared bathroom with the family.
MS. HAJJAR: Aside from her room and the bathroom, was she allowed to leave?
LAUREN SALZMAN: No, not if she wanted to stay in the United States.
MS. HAJJAR: And did you tell her that she would be -- that she would have to go to Mexico if she left?
LAUREN SALZMAN: Yes. I told her that, This was the agreement that you made, that you would complete this. If you want to stay, you complete this.
MS. HAJJAR: And did the defendant tell you that?
LAUREN SALZMAN: Yes. And he told me to tell her that she didn't have to stay in the room, she could just go back to Mexico.
MS. HAJJAR: Did Daniella have any human contact during the time that she was in the room?
LAUREN SALZMAN: Only with me and then later with some -- with her siblings at the end, only towards the very end.
MS. HAJJAR: What did she do during the day?
LAUREN SALZMAN: Different things: She -- she wrote to Keith every day, sometimes multiple times a day; she did exercise; she cleaned her room and the bathroom; she thought. Sometimes she did propose things that she thought could rectify whatever her infractions were that she had, you know, done or allegedly done, and that she -- and a lot of times she watched her sister outside the window, but sometimes she told me she wasn't doing anything and she had various -- there were different things she was going through in the room. She had different health struggles in the room, and emotionally it was very difficult for her at times. Sometimes she was more resolute about being there.
MS. HAJJAR: The things that Daniella proposed, did you bring them to the defendant?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What did he say?
LAUREN SALZMAN: It depended on the thing, but, I mean, there were different times where I would spend with her and I thought that we had made progress and he told me that she had just been manipulating me for hours and I couldn't see it. Other things that were proposed he said she was trying to get around having to really do what it took to fix it. Certain things she was expressing he told me were temper tantrums, but that a lot of this was just game-playing and that it was very difficult for him, basically, that I wasn't able to negotiate this or figure this out and that the family also was not able to negotiate this. You know, so I felt that somehow I was screwing it up in my ineptitude and my failure to be able to see what was going on, which he seemed to think was so obvious was thwarting the process somehow.
MS. HAJJAR: The things that the defendant said about Daniella game-playing, did that correspond to what you were observing?
LAUREN SALZMAN: It didn't initially, and then I came to see everything she was doing as game-playing, and I -- it's my experience that the family did, too.
At some point, almost everything that initially we had thought were her efforts and we had raised as her making legitimate attempts to meet the requirements, later, all of us, almost everything she said, we were like, No, no, that's not the measurable thing; no, you're not doing what's required, no, and we saw everything that she was doing at the end as game-playing.
MS. HAJJAR: You said that Daniell's siblings brought her her food.
LAUREN SALZMAN: Yes.
MS. HAJJAR: Could they interact with her when they did that?
LAUREN SALZMAN: No. The agreement was that they were not supposed to interact with her.
MS. HAJJAR: When you say "the agreement," what are you talking about?
LAUREN SALZMAN: They made an agreement with Dani that she was going to go in and they weren't going to communicate with her until she came out, but when Adriana, the mom, was communicating with her, Keith would tell me that that was not what was agreed upon and that Adriana was going back on what she said and that she was thwarting the process.
MS. HAJJAR: So when you say "the agreement," are you referring to the fact that if Daniella left the room, she would have to go back to Mexico?
LAUREN SALZMAN: Yes, and the conditions of that, which were that she was to go into the room with no contact with anybody but me.
(Continued on the following page.)
BY MS. HAJJAR:
MS. HAJJAR: Was Daniella sad?
LAUREN SALZMAN: Often she was sad, yes. It was really -- it was really -- those relationships were very important to her, and she -- it was very hard for her to not have communication with her family during that time. She expressed that she didn't know how to heal things if she wasn't interacting with them, and so she felt like she didn't know how to make things better without the relationships, and she didn't know if she could be okay or survive without the relationships emotionally or materially. So that all was very upsetting to her.
MS. HAJJAR: Did she tell you she wanted to leave?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did she tell you she was afraid?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Of what?
LAUREN SALZMAN: She was afraid of losing the relationships and she was afraid of what would happen if she went back to Mexico. She was afraid if she went back to Mexico, that she would lose the relationships. And she was afraid that she wouldn't -- didn't know how to survive without her family. And also she, I think, viewed failing, this is -- as she didn't want to lose the relationship with Keith either and she still very much wanted that.
MS. HAJJAR: Did you threaten her that if she left she would be sent to Mexico?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: And during this period of time, did you report to the defendant?
LAUREN SALZMAN: Yes. Every time I interacted with her, I did report to him.
MS. HAJJAR: And what did he tell you in these reports?
LAUREN SALZMAN: Similar to what I said before. I mean, that, you know, sometimes he would be thinking about what -- what should be done. And sometimes I would ask him for direction. Often he would say that I couldn't tell her what to do, but that there were these markers we needed to look for and everything that we presented as a marker was not a marker and not being a marker and was just more game playing.
MS. HAJJAR: Can you explain what that means?
LAUREN SALZMAN: Yeah. That there were measurable things that we were supposed to be looking for. And like at one time he was like, Well, if I was in the room I would be writing letters to everybody, you know, and doing things. But she was writing letters and she was also told that she wasn't supposed to be communicating with anybody. So there are contradictory signals, but she was writing him every day, sometimes multiple times a day. And often he didn't even read those letters. He asked me to hold the letters.
So I don't know how he would have known if there were markers if what I was communicating were not markers and there were these markers that could have been seen. And she was trying to write to him consistently, and he wasn't looking at what that was, how he would know if really she met the markers.
MS. HAJJAR: What happened to the letters that Daniella wrote to the defendant while she was in the room?
LAUREN SALZMAN: Well, initially, me or her family members would photocopy them for her to keep a copy and then I would take a copy to Keith, but he asked me to hold them. So I held most of them. And he gave some to Nicky after he was -- or after he left -- or when he left for Mexico. And then after he was arrested, I photocopied and made them available.
MS. HAJJAR: Were some of those letters unopened?
LAUREN SALZMAN: Most of them were unopened. So I opened them, you know, and provided them as material.
MS. HAJJAR: How long did Daniella stay in the room?
LAUREN SALZMAN: More than 18 -- around -- or more than 18 months. It could have been up to two years. She was in there forever -- I mean, a really long time.
MS. HAJJAR: How often did you visit her?
LAUREN SALZMAN: At first I visited her every day. And then I went less, once a week. And there were times, you know, and then less and less and there were times where I didn't go, honestly for -- for a month or more. Like I -- I was really mad at her for not figuring out whatever she was supposed to be doing to end this for herself and for all of us, and I was mad because I thought she was playing games and being manipulative with me and I couldn't figure that out. And I felt mad that now I was in a position to fail again and be the reason that nothing can move forward, or that I'm blamed for the bad things that are happening in the community or for the fact that we can't have a relationship or kids. And honestly, I was very incredibly discompassionate with her and I was unkind often. At time I punished her. You know, it was terrible.
MS. HAJJAR: How do you feel about participating in this now?
LAUREN SALZMAN: I think it's horrendous. I -- of every -- of all the things that I did in this case and the crimes that I committed, too, I think that this is the worst thing that I did. I -- I don't know what to say. I kept her in her room for two years, and I didn't even go visit her most of the time. And I wasn't that nice to her and it's awful.
And the family, they were close as a family when they came to us. And those relationships were incredibly severed through this and other things that happened. And I don't know how you can ever recover from that. And I don't -- it's something I really struggle to come to grips with and figure out how to fix. I think it's terrible.
MS. HAJJAR: Did the defendant give you instructions about what you were permitted to tell Daniella?
LAUREN SALZMAN: I wasn't permit to tell her anything. He told me not to tell her. I couldn't tell her what to do. I wasn't supposed to give her any information about what was going on, on the outside with anybody. She asked a lot of questions and he told me not to answer them.
MS. HAJJAR: Did the defendant ever tell you that Daniella should remain in the room for longer?
LAUREN SALZMAN: Yes. They had an agreement that they both told me about, that -- I don't know what the condition of the agreement was, but that she was not going to cut her hair, and this was like an agreement that they had. And she cut her hair while she was in the room. And he told me that she should come up with a way to fix that, and that a way to fix that was staying in the room until the hair grew back.
MS. HAJJAR: How long was her hair?
LAUREN SALZMAN: Long. Like down her back. I mean, maybe close to her butt and cut it up to shoulder length. She -- I mean, and she told me that that meant staying in room for three years, like that had taken three years to grow her hair that long, and she didn't want to stay in the room for three years, you know. And of course she didn't want to stay in the room for three years, but...
MS. HAJJAR: Did the defendant tell you to tell Daniella that she was to stay in the room until the hair grew back?
LAUREN SALZMAN: Yeah, as an option, that that was a way to fix that.
MS. HAJJAR: Did you tell her that?
LAUREN SALZMAN: I did.
MS. HAJJAR: What did she say?
LAUREN SALZMAN: She didn't want to do that.
MS. HAJJAR: Did the defendant ask you to take photographs of Daniella at any point?
LAUREN SALZMAN: Yes. He asked me to take photographs twice. Once when she cut off the hair because he wanted her to know that he was going to see it, and he thought that she would feel bad if he saw it and that would somehow inspire her to change something. And another time he thought she was lying about her weight loss, and so he wanted me to take a picture to see if she was.
MS. HAJJAR: Can I show to the witness alone, Your Honor?
MS. HAJJAR: Ms. Salzman, I'm showing you what has been marked for identification as Government's Exhibit 1244.
Do you recognize this exhibit?
LAUREN SALZMAN: I only see the e-mail -- the e-mail subject. I don't know if there's something attached.
Yes.
MS. HAJJAR: What is it?
LAUREN SALZMAN: It's the e-mail that I sent. It's an e-mail that I sent to Keith and a picture of Dani after she cut her hair.
MS. HAJJAR: Your Honor, the Government offers Government's Exhibit 1244 into evidence.
MR. AGNIFILO: No objection.
THE COURT: All right. Government's Exhibit 1244 is received into evidence and published for the jury.
(Government's Exhibit Number 1244 so marked and received in evidence.)
(Government's Exhibit Number 1244 is published to the jury.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, who wrote this e-mail?
LAUREN SALZMAN: I did.
MS. HAJJAR: And who is it to?
LAUREN SALZMAN: To Keith.
MS. HAJJAR: When was it sent?
LAUREN SALZMAN: January 15, 2011.
MS. HAJJAR: And what's the subject?
LAUREN SALZMAN: The subject is BoBo, which is Dani's nickname.
MS. HAJJAR: Daniella's nickname?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Is there a photo attachment to this?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And is this that photograph of Daniella that you said you took?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Why did you send this to the defendant?
LAUREN SALZMAN: Because he asked for it and he told me that he thought that if she did this process that she could have like some kind of breakthrough, like she would be able to have this new experience of herself, and this like rich, joyful, inner world that she couldn't experience as long as her whole focus was like entertainment and manipulation. And so I wanted her to be able to have that and I didn't want to be responsible for doing something that would screw that up or that I would be blamed for later. And I wanted him to feel there was somebody who was willing to do what it took to become somebody who could be a responsibile parent. But this was really -- I mean...
MS. HAJJAR: How often did you check in with the defendant about Daniella?
LAUREN SALZMAN: Whenever I went to see her. But there were times where I wasn't seeing her a lot.
THE COURT: Was Daniella living alone in this house?
LAUREN SALZMAN: No. Her family was there at different times. Her sister, Camila, was there almost the whole time. Her mother was there and actually went in the room next door for a number of months as well. And her father came and went. And Marianna was living with Keith and Pam, so she wasn't around a lot. And Adrian was living with Mark, so he wasn't around a lot either.
MS. HAJJAR: Did the defendant express concern about the family interfering with the project at any point?
LAUREN SALZMAN: Yes. He thought that they were interfering with the project.
MS. HAJJAR: How so?
LAUREN SALZMAN: Because Adriana was talking to her and sending her notes through the bathroom. And also at one point -- again, I was told that -- Keith told me that the family decided that Adriana would go into the second room. It was a two-bedroom condo, and Adriana and the -- the idea or the logic behind it was that Adriana was going to go in the second room under the same conditions as Dani so that Dani -- and Dani would know that her mother was in the room next door, which was supposed to inspire her to want to get out quickly to end the discomfort that her mother felt, which she should have known what it was like because she herself was experiencing discomfort.
So Adriana went into the room next door and --
MS. HAJJAR: Adriana is Daniella's mother?
LAUREN SALZMAN: Daniella's mother. And originally it was that she was going to go into her room with the same conditions as Dani. So she was going to be in a room without anything, like just with the bed and -- and nothing.
But within a short period of time, Adriana situation was very different than Dani's and Dani knew about this. So Adriana within a short period of time had many things in the room like exercise equipment or art supplies. At one point she had a pet fish, and she had -- she -- she was making Kombucha and like sprouting vegetables that she wanted to make for herself but also to take responsibility to feed herself and Dani so the family didn't have to do it. But she had candles and things. And so Keith called me and said that Adriana was supposed to be in the room under the same conditions as Dani and wanted me to address this with Adriana and ultimately enforce that Adriana go back to the conditions like Dani.
MS. HAJJAR: What happened with that -- what happened after that?
LAUREN SALZMAN: Well, I went and talked to Adriana about it, but I didn't enforce that she change it. But all of these things were viewed as thwarting the program. And Adriana would have -- the family had -- there was only one full bathroom in the house and the full bathroom was in between the two bedrooms that Dani and Adriana occupied. So the family if they wanted to use the bathroom, like to take a shower or something, had to go through one of the bedrooms. So they all went through Adriana's bedroom. And initially I was told they weren't going to be speaking to Adriana, but then eventually they would go and talk and so Dani could hear them all talking, so she knew that the family would visit in Adriana's room and these things.
So all of that was viewed as thwarting.
MS. HAJJAR: Ms. Salzman, the point of Daniella's mother being put in a room next to her, was what?
LAUREN SALZMAN: So that Dani would feel that her being in the room -- her extending her stay in the room or staying in the room not either going back to Mexico or getting done whatever she was supposed to be getting down there, was directly affecting other people and that she should care about that, you know, and do whatever needed to be done to either get back to Mexico or get her work done.
MS. HAJJAR: Care about that, meaning care about the fact that her mother was also in a room next to her?
LAUREN SALZMAN: Yes. That she was hurting somebody else's life with her actions.
MS. HAJJAR: What happened with Adriana?
LAUREN SALZMAN: Well, while Adriana was in the room, somebody that she was very close with and -- and up-close personal relationship of hers that was important to her, that person was killed and she left the room to go to the funeral. And then I can't remember if she came back to the room or she just came back to Albany or she went back to Mexico. But I do remember speaking to her again after that, and she didn't want to return to the room and she felt that she had a purpose that was not in a room. She wanted to go and be part of another organization that she felt like a consciousness raising human potential type of program. She wanted to go work with this group of people, something called The Book of Knowledge and do that.
MS. HAJJAR: After Daniella's mother left, did you tell Daniella anything about the length of time that she should stay in the room?
LAUREN SALZMAN: Yes. Well, then Keith started telling me that there was now an ethical issue, that Adriana had broken her commitment and that Adriana's broken commitment is exactly why Dani believed that she can behave however she wants and never have any consequences for her action and that Dani should take an ethical stance against the mother leaving and Dani should stay in the room until Adriana comes back. And at that time, then Camila and Marianna were permitted to go have meetings with Dani to decide what should be done about the situation with Adriana.
MS. HAJJAR: What did Daniella say when this was conveyed to her that she should stay in the room until her mother got back?
LAUREN SALZMAN: Well, at some point Dani thought that that was a good idea. But I find it incredibly problematic now because a lot of the time -- there were a number of occasions where Keith said to me, Cami feels very strongly about this. And Cami and Marianna were the ones interacting with Dani to make this ethical decision about what Adriana should do. And both Cami -- which I didn't know at the time -- but Cami and Marianna were both in a sexual relationship with Keith. So they're sent -- they're -- now all of a sudden, they're allowed to go speak to Dani to advise her about how long she should stay in the room, which they really don't know much about because they're not Dani in the room.
Marianna hadn't been interacting almost at all with the situation because she was just living with Keith, and Pam and none of them were interacting at the actual house. Cami was there, but those perspectives were highly influenced by Keith's perspective. All of our perspectives were highly influenced by Keith's perspective and all of us were in relationships with Keith where we wanted him to think that we would do the hard thing, the ethical thing and wanted him to see us as people who were willing to do that, which we were constantly getting feedback from him that we were failing at and advice about how we could do it better.
MS. HAJJAR: During this period of time, Marianna was living with the defendant?
LAUREN SALZMAN: Yes, she was.
MS. HAJJAR: And Adrian, where was he?
LAUREN SALZMAN: He was at the Twilight house. I can't remember the number, but with Mark Vicente.
MS. HAJJAR: Did Daniella tell you that she would watch Camila sometimes?
LAUREN SALZMAN: Yes, she did. She told me she would watch her outside the window. I think Cami had a garden or a bunch of plants that she would tend to outside and Keith's son Gaelyn would come over to the house, Cami was his teacher, so she would watch them or listen to them.
MS. HAJJAR: Camila was at that time taking care of the defendant's son?
LAUREN SALZMAN: Yes, correct.
MS. HAJJAR: Your Honor, may I show the witness an exhibit marked for identification?
THE COURT: Go ahead.
MS. HAJJAR: Ms. Salzman, I'm going to show you what has been marked for identification as Government's Exhibit 1238.
Do you recognize this exhibit?
LAUREN SALZMAN: Yes, I do.
MS. HAJJAR: What is it?
LAUREN SALZMAN: It's a chain of e-mails between Keith and myself in October 2010 concerning Daniella's birthday and whether the family could send her notes or communicate with her to acknowledge her birthday.
MS. HAJJAR: I'm going to show you what has been marked for identification as Government's Exhibit 1241.
Do you see that e-mail, that -- that exhibit?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What is it?
LAUREN SALZMAN: This is an e-mail that I wrote to Keith in November 2010 about Daniella writing a letter saying, Let me out of the room. I'm coming undone. And Camila intercepting the letter and me interpreting it as -- well, deciding when I was going to go interact with her, how I was going to handle it and asking his opinion.
MS. HAJJAR: I'm showing you what has been marked for identification as Government's Exhibit 1242.
Do recognize this e-mail?
LAUREN SALZMAN: Yes. This is Keith's response to the former e-mail.
MS. HAJJAR: Your Honor, the Government offers Government's Exhibit 1238, 1241, and 1242 into evidence.
MR. AGNIFILO: No objection.
THE COURT: Government's Exhibits 1238, 1241, and 1242 are received in evidence.
(Government's Exhibit Numbers 1238, 1241 and 1242 so marked and received in evidence.)
MS. HAJJAR: Thank you, Your Honor.
MS. HAJJAR: Ms. Salzman, as to Government's Exhibit 1238, starting at the bottom of this chain, who was that first e-mail from?
LAUREN SALZMAN: The first e-mail is from me to Keith.
MS. HAJJAR: And when was it sent?
LAUREN SALZMAN: It was sent on October 25th, 2010.
MS. HAJJAR: What's the subject line?
LAUREN SALZMAN: BoBo.
MS. HAJJAR: What was BoBo?
LAUREN SALZMAN: BoBo's Daniella's nickname.
MS. HAJJAR: And can you read the text of that e-mail?
LAUREN SALZMAN: Sure. It says, Doomp, which was a nickname that I called Keith, tomorrow is BoBi's birthday, and Hector is asking if the family can write her letters. I tend to think no but I wanted check with you. I know it's an important day for her and her family usually ignores it, which is usually upsetting for her. I think she has been working to heal her relationships with them and has been working, so I'm not sure if the feedback from them is positive or it's a suspension of the ethic of the process she's going through.
Can you share your perspective?
MS. HAJJAR: Tomorrow is BoBi's birthday, is that Daniella's birthday?
LAUREN SALZMAN: Yes, Daniella's birthday.
MS. HAJJAR: And are you asking the defendant permission for the family to acknowledge her birthday in some way?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What is the defendant's response?
LAUREN SALZMAN: I think you have to figure it out. Value ethic it. There are several options. It is not just black or white.
MS. HAJJAR: And when was that e-mail sent?
LAUREN SALZMAN: The same day, October 25th, later in the day, 2010.
MS. HAJJAR: And what did you send back to the defendant?
LAUREN SALZMAN: I tend to think that if they were to communicate in a way that didn't make it a special day with the suspension of cause and effect, it could be okay and potentially a rebirth of sorts. I'm not sure if they're capable of doing that.
MS. HAJJAR: Can you explain what that means, just plainly?
LAUREN SALZMAN: Yeah. I thought that there was a way that -- because what was going on in the family was something the entire family participated in, not just Dani, and that I thought there was a way that maybe they could acknowledge their -- her birthday and maybe set an example by taking responsibility for how they participated in the relationship that could be good for her and helpful for the process they were going through. Like it didn't have to just be that any communication thwarted the process and that she's entirely alone, feeling abandoned and forgotten again in the situation where she's already very isolated from them.
MS. HAJJAR: And so when you say, I tend to think that if they were to communicate in a way, it could be okay. Are you telling the defendant that your view would be that they could communicate with her on her birthday?
LAUREN SALZMAN: Yeah. He's saying you have to figure it out, and I'm saying this is what I think about it, yes. This is what I offer and believed could be good.
MS. HAJJAR: And what did the defendant respond?
LAUREN SALZMAN: Or they could not communicate, at least at first, and then some measurements and markers could be examined.
MS. HAJJAR: And what did you understand that to mean?
LAUREN SALZMAN: No, that your idea of communication is not what should be done in this situation and you need to look for measurements and markers, and when you see the measurements and markers, then maybe we can talk about communicating.
MS. HAJJAR: What were the measurements and markers?
LAUREN SALZMAN: I don't even know at this point, because everything she did was shot down and viewed as thwarting the process. There were a lot of things that she did propose, but I don't know what he was looking for, honestly, because he didn't read even a lot of the letters where she was making the proposals.
MS. HAJJAR: I'm going to show you what is in evidence as Government's Exhibit 1242.
Can you just describe what the bottom e-mail is from, what the bottom e-mail is?
LAUREN SALZMAN: Yes. Describe it or read it?
MS. HAJJAR: Well, who sent it?
LAUREN SALZMAN: I sent it to Keith on November 8, 2010. Daniella wrote a letter saying, Let me out. I'm coming undone. And Camila intercepted the letter and didn't show it --
MS. HAJJAR: I'm sorry, Ms. Salzman. Just before that. The subject is what?
LAUREN SALZMAN: BoBo/Cami.
MS. HAJJAR: And BoBi is Daniella?
LAUREN SALZMAN: BoBi, yes, BoBi/Cami. BoBi is -- I call Daniella BoBi, like just an iteration on BoBo.
MS. HAJJAR: And Cami is Camila?
LAUREN SALZMAN: Camila.
MS. HAJJAR: And what e-mail address are you using to communicate with the defendant?
LAUREN SALZMAN: Lauren@NXIVM.com.
MS. HAJJAR: Okay. Can you read the text of the e-mail?
LAUREN SALZMAN: Doomp, I'm going to sleep, but apparently BoBo wrote a letter that said, Let me out. I'm coming undone. Camila intercepted it and didn't show it to the parents because they are so reactionary. She instead texted me asking for permission to speak to BoBo. I told her no and explained I thought it was bad on a postulate level. I'm not going there tonight because of the letter, but I will stop by in the morning probably around 8:00 a.m. I plan to explain to BoBi that I think she's had a huge setback and this focus of letting me out of the room is totally in the opposite direction of healing the breach.
If there's anything that you think I should add or do differently, please let me know. If not and you're okay with what I'm planning, I will just report in afterwards.
I will call you before I go over there in the morning, but I have not been able to reach you mornings this week. If possible I would like to sleep through the night tonight, but if there's anything urgent you need to tell me about, best you can wake me up. If not, I'll be up around 6:30 a.m.
Love you.
MS. HAJJAR: And Doomp, what is that?
LAUREN SALZMAN: It's a nickname that I called Keith.
MS. HAJJAR: And when you write, Apparently, BoBo wrote a letter that said, Let me out. I'm coming undone. Camila intercepted it and didn't show the parents because they're so reactionary?
LAUREN SALZMAN: Uh-huh.
MS. HAJJAR: What was, Let me out. I'm coming undone?
LAUREN SALZMAN: That Dani was having -- was feeling emotionally not okay in the room and didn't -- and wanted permission to come out.
MS. HAJJAR: Let me out of the room?
LAUREN SALZMAN: Let me out of the room.
MS. HAJJAR: And when you write, Camila intercepted it and didn't show the parents because they are so reactionary, who is they?
LAUREN SALZMAN: The parents.
MS. HAJJAR: And when you say, they're so reactionary, what does reactionary mean as you meant it?
LAUREN SALZMAN: That they would take action on getting the letter by communicating with her in some way that would again be viewed as thwarting the process.
MS. HAJJAR: So in other words, that they would want to contact their daughter?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And thwart the defendant's project?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And so when you write, She instead texted me asking for permission to speak to BoBo, who is she in that sentence?
LAUREN SALZMAN: Cami.
MS. HAJJAR: So Camila asked you for permission to speak to her sister?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And when you write, I told her no, and explained why I thought it was bad on a postulate level?
LAUREN SALZMAN: Uh-huh.
MS. HAJJAR: What did that mean?
LAUREN SALZMAN: It meant that similar to the birthday, that the decision was that she was not -- that the family was not to speak to her and that if they did speak to her, she would learn that she could get upset and get things that she wanted.
MS. HAJJAR: And on a postulate level, that phrase, is that a term used in ESP?
LAUREN SALZMAN: Yes, it's an ESP term. Basically it means -- postulate is like your belief about how the world works. So if like she feels upset and then her parents communicate with her, then she has a belief that if she gets upset, they will communicate with her and that's how a postulate is formed.
MS. HAJJAR: When you write, I plan to explain to BoBi that I think she's had a huge setback and this focus of let me out of the room is totally in the opposite direction of healing a breach.
Just very plainly, what are you conveying to the defendant?
LAUREN SALZMAN: I'm conveying to him that similar to the way I described it before, she's having an emotional reaction and focusing on what she wants to get out of the experience instead of what she was trying to earn through the experience.
MS. HAJJAR: And so you're connecting her desire, her statement, let me out of the room to not being helpful to healing her breach, whatever that meant?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did the defendant respond?
LAUREN SALZMAN: Yes.
MS. HAJJAR: When?
LAUREN SALZMAN: The next day in the morning.
MS. HAJJAR: November 9, 2010?
LAUREN SALZMAN: Yeah, I'm sorry.
MS. HAJJAR: And what did the defendant write?
LAUREN SALZMAN: Hi, Honey. You do not want to buy into BoBo's tantrum or externalization. Likewise, you do not want to tell her what to do or how to be. You might try asking her the difference between being in the room for a day, dot, dot, dot, or as long as she has. From a present time perspective there is no difference except suffering and entitlement, dot, dot, dot, dot. Hope this helps.
Keith.
MS. HAJJAR: And when the defendant wrote, You don't want to buy into BoBo's tantrum or externalizations, what did that mean?
LAUREN SALZMAN: It meant that she wasn't -- that she was that her emotional reaction and communication that she was coming undone is a temper tantrum -- is simply a temper tantrum and her focus on what she wants to get from the outside world is her, you know, blaming that on the outside world or looking to the outside world to get something that's going to change how she's going to feel on the inside. And if you give her things or change the circumstances outside, then she won't be able to have this experience of being complete on the inside. So you shouldn't do that.
MS. HAJJAR: And by BoBo's tantrum, is he referring to fact that she's expressing, Let me out. I'm coming undone?
LAUREN SALZMAN: Yes.
MS. HAJJAR: After this, after Daniella said, Let me out. I'm coming undone --
LAUREN SALZMAN: Uh-huh.
MS. HAJJAR: -- how much longer did she stay in the room?
LAUREN SALZMAN: I believe at least three more months, maybe four.
MS. HAJJAR: When was this e-mail written?
LAUREN SALZMAN: November 9, 2010. I think she came out in February 2011 -- oh, no. She came out in February 2012.
MS. HAJJAR: So how much time had it been after she wrote --
LAUREN SALZMAN: Like a year -- no like, over a year and almost a half. I'm sorry.
THE COURT: All right. All right.
MS. HAJJAR: Yes, Your Honor.
THE COURT: We'll take our lunch break.
All rise for the jury.
(Jury exits the courtroom.)
(The following matters occurred outside the presence of the jury.)
THE COURT: The witness may stand down. Please don't discuss your testimony with anyone.
(The witness exits the witness stand.)
THE COURT: All right. I have a matter here at 1:00 so if you want to have a conversation, just take it into the hall. Thank you.
One hour for lunch.
(Lunch recess taken at 1:01 p.m.)
(Continued on the next page.)
A F T E R N O O N S E S S I O N
--oo0oo--
THE COURT: Do we have a witness?
(The witness resumes the witness stand.)
THE COURT: And bring in the jury.
(Pause in proceedings.)
(Jury enters the courtroom.)
(Jury present.)
THE COURT: All right. Please be seated.
All right. Ms. Hajjar, you may continue your examination of the witness. The witness is reminded that she is still under oath.
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, did there come a time where Daniella requested medical care?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain that to the jury?
LAUREN SALZMAN: She requested that she needed to go to the dentist. She started complaining that she was having a problem and wanted to go.
MS. HAJJAR: What happened after that?
LAUREN SALZMAN: I went to Keith to ask if I could take her -- or if she could go to the dentist and he said he would think about it. And it took six weeks for him to decide that she could go and, I mean, part of her tooth broke off before it was okay to take her.
MS. HAJJAR: During those six weeks did Daniella tell you that she was in pain?
LAUREN SALZMAN: Yes, she was telling me that she needed to go to the dentist.
MS. HAJJAR: Why did you wait six weeks before she went?
LAUREN SALZMAN: Because I wouldn't take her unless Keith said that it was okay for her to go.
MS. HAJJAR: Was she eventually permitted to go to the dentist?
LAUREN SALZMAN: Yes, I did take her.
MS. HAJJAR: Was she permitted to go alone?
LAUREN SALZMAN: No, I took her. I picked her up, I took her to the dentist, I waited while she saw him, I took her to my family dentist. And then I drove her home and she went back in the room.
MS. HAJJAR: Did she show you her tooth before she went to the dentist?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And could you see that it was broken?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Do you know who paid for the dentist, the dental care?
LAUREN SALZMAN: I don't recall.
MS. HAJJAR: Did there come a time where Daniella was permitted to use a cell phone for a period?
LAUREN SALZMAN: Yes.
When we went to Vanguard week, the whole family left and went up to Lake George and I left as well. So she was permitted to have a phone to communicate with me while I was gone in case of an emergency.
MS. HAJJAR: Was she left alone during that period of time?
LAUREN SALZMAN: Yes. But her family came home periodically throughout the trip.
MS. HAJJAR: And you said it was for V Week. Is that the celebration -- the annual celebration of the defendant's birthday?
LAUREN SALZMAN: Yes.
MS. HAJJAR: How did -- did you communicate with Daniella while you were away?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: How?
LAUREN SALZMAN: Via e-mail or texting through at phone.
MS. HAJJAR: Do you know what e-mail address she used to communicate with you during that period of time?
LAUREN SALZMAN: She used an e-mail address called Happy Monk. I think it was Happy Monk 55, but there was a number. Happy Monk something.
MS. HAJJAR: Your Honor, may I show the witness something for identification?
THE COURT: Go ahead.
MS. HAJJAR: Thank you.
MS. HAJJAR: Ms. Salzman, I'm showing you what has been marked for identification as Government's Exhibit 908R.
Do you recognize this exhibit?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And there's many pages. There are 80 pages of this exhibit.
LAUREN SALZMAN: Yes.
MS. HAJJAR: What is it?
LAUREN SALZMAN: They're e-mails that I exchanged with Dani. And I can't see the first page, but I believe the Happy Monk e-mail address. Yes, happymonk55@gmail.
MS. HAJJAR: Your Honor, the Government offers Government's Exhibit 908R into evidence.
MR. AGNIFILO: No objection.
THE COURT: Government's Exhibit 908R is received in evidence.
(Government's Exhibit Number 908R so marked and received in evidence.)
MS. HAJJAR: Now, Ms. Salzman, looking a one of the pages of Government's Exhibit 908, so Page 2, what period of time was Daniella communicating with you using the Happy Monk 55 e-mail address?
LAUREN SALZMAN: I think it started during that V Week and may have continued through after that.
MS. HAJJAR: Is that around August of 2011?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And when Daniella -- is that Daniella that writes to you from Keith I have once again taken his time and resources with the problems I create, essentially in taking your time?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And what e-mail address of yours was that sent to?
LAUREN SALZMAN: To Lauren@NXIVM.com.
MS. HAJJAR: Are there many similar e-mails in this collection of e-mails?
LAUREN SALZMAN: Yes, there are.
MS. HAJJAR: Can you describe just generally what the content of these e-mails were to the jury?
LAUREN SALZMAN: This one she was lifting the effect that -- the negative effect that she had created on the people in her life, her family, myself, Keith. She was also suggesting ways to address those problems. And I was responding, communicating with her.
MS. HAJJAR: Okay. Just looking at Pages 77 and 78 of Government's Exhibit 908, the bottom e-mail, Ms. Salzman, when was that sent?
LAUREN SALZMAN: On October 1, 2011.
MS. HAJJAR: What time was it sent?
LAUREN SALZMAN: 3:22 in the morning.
MS. HAJJAR: Who sent that e-mail?
LAUREN SALZMAN: Daniella sent it.
MS. HAJJAR: Can you read --
LAUREN SALZMAN: Can I read the e-mail?
MS. HAJJAR: One moment.
(Pause in proceedings.)
MS. HAJJAR: Actually read the -- can you read the e-mail, just tell me what the e-mail is on the top. Who sent that e-mail?
LAUREN SALZMAN: I did. I sent it to Dani.
MS. HAJJAR: Okay. Can you read the text of your e-mail?
LAUREN SALZMAN: Yes. The whole e-mail you sent this morning was very prideful. If you don't turn this around immediately I will cut contact with you for 24 hours. I refer you to my previously e-mail from September 19th. If the next time you communicate with me you demonstrate any blame, any more gameplaying or any further prideful, bratty or self-indulgent behavior, I will cut contact with you for 24 hours. If after the 24-hour period is up and upon re-establishing contact, you must demonstrate a massive turnaround of attitude and behavior or I will make a formal recommendation to Keith that you go back to Mexico. If there's any infraction beyond that point, I have the authority to end this entire program and you will just go back to Mexico. I am being generous in giving you an extra chance to rectify this. By 7 p.m. today send a responsible/nonprideful answers to my questions and measurable output of work in the vein that I am requesting. If you do not do this, I will cut contact with you in response to your prideful behavior and gameplaying of this morning.
MS. HAJJAR: When you write, If there's any infraction beyond that point I have the authority to end this entire program and you will just -- you will just go back to Mexico --
LAUREN SALZMAN: Yes.
MS. HAJJAR: -- was that true?
MS. HAJJAR: Why were you writing that to her?
LAUREN SALZMAN: Because whatever had happened earlier in the morning I checked it with Keith and he told me to tell her that. Tell her that you have the authority to end the whole thing and that you're going to make a formal recommendation to me that you just go pack to Mexico.
MS. HAJJAR: Why?
LAUREN SALZMAN: Why what?
MS. HAJJAR: Why did you convey that to her? What was the purpose of saying that to her?
LAUREN SALZMAN: To address whatever she had done and get her to turn it around.
MS. HAJJAR: What were you trying to get her to do?
LAUREN SALZMAN: I was trying to get her to do -- to not demonstrate whatever was being perceived as blame, gameplaying or being prideful or self-indulgent.
MS. HAJJAR: Were these things that the defendant told you --
LAUREN SALZMAN: Yes.
MS. HAJJAR: -- about her behavior?
LAUREN SALZMAN: Yes. And things that through my interaction with him I came to see as that.
MS. HAJJAR: The e-mail below that, that you read earlier, can you just read Paragraph 2?
LAUREN SALZMAN: I don't have an answer for this. It is not laziness, I just have nothing else to do.
MS. HAJJAR: And turn to Page 79 of Government's Exhibit 908. Can you read the e-mail you sent?
LAUREN SALZMAN: Yes. I am cutting communication with you. At the point in time when I reestablish it, I expect a dramatic turnaround with all items I've requested complete, including you list of effects and how to you plan the address and rectify each one and also how you plan to structure your days to make healing a higher priority than laziness and comfort. If you do not have this complete, I will make a formal recommendation to Keith that you go back to Mexico. If I see any further evidence of pride, blame, abnegation of responsibility, setting boundaries on what you will and will note do or any gameplaying, I will discontinue your program and you will no longer be permitted to stay here.
MS. HAJJAR: Can you explain this e-mail?
LAUREN SALZMAN: Yes. I discussed it with Keith and he told me to tell her that if she didn't do a dramatic turnaround with all the items that were requested and structure her day to make healing a higher priority than laziness and comfort, then I would make the recommendation to Keith that she would go to Mexico and she wouldn't be permitted to stay here.
MS. HAJJAR: What does it mean that you would make a formal recommendation to Keith?
LAUREN SALZMAN: It doesn't really mean anything, but it was what he said to tell her. Like that somehow if I recommended to Keith formally or informally but in this case formally that she should go back to Mexico that Keith would know -- would listen to me and that would be what would happen.
MS. HAJJAR: Did you believe you had the authority to determine when and if Daniella would be sent to Mexico?
LAUREN SALZMAN: No, absolutely not.
MS. HAJJAR: Who had that authority?
LAUREN SALZMAN: Keith. And I don't believe Daniella believed that I had the authority.
MS. HAJJAR: At some point, Ms. Salzman, was a surveillance camera installed?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: Keith called me and told me that Daniella was sneaking out of the room or there was reason to believe she was and that I should call Adrian to help set up a security camera. And so I did call Adrian and the who of us went over to the house together and set up a security camera.
MS. HAJJAR: And prior to the defendant telling you so, did you have reason to believe that Daniella was leaved the room?
MS. HAJJAR: What happened when you contacted Adrian?
LAUREN SALZMAN: He came and he brought -- Adrian was part of the video team, so he had, I guess, the technology or the know-how to get the technology to install a camera. And I went with him over to the house and while he set it up, I went into the room and talked with Dani and then I came out and the two of us found a place where we wanted to set it up or we thought would be a good place for it.
MS. HAJJAR: Was the surveillance camera footage checked?
LAUREN SALZMAN: Adrian checked it and he showed me parts of it one time. He said that he didn't find anything on it.
MS. HAJJAR: What does that mean?
LAUREN SALZMAN: No evidence of Dani leaving the room.
MS. HAJJAR: Are you aware if Adrian spoke to the defendant about the surveillance footage?
LAUREN SALZMAN: I believe his did, but I don't recall specifically.
MS. HAJJAR: Do you recall how the surveillance -- where the surveillance camera was and how it was positioned?
LAUREN SALZMAN: Well, I was reminded through the -- through this case that we put it behind a clock.
MS. HAJJAR: Ms. Salzman, you testified about letters that were written by Daniella while she was in the room?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did you keep some of those letters?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: She wrote Keith letters throughout the whole time she was in the room. And he asked me to keep them. And I did.
MS. HAJJAR: What did you do with them?
LAUREN SALZMAN: I kept them and then after he was arrested, I photocopied them and they became part of materials of the case.
MS. HAJJAR: Prior to that, had you read them?
MS. HAJJAR: At some point did you receive additional letters?
LAUREN SALZMAN: Yes. Nicki gave me letters that he had given to her when he left -- when he left to go to Mexico.
MS. HAJJAR: And what happened to those letters?
LAUREN SALZMAN: Nicki gave them to me and I combined them with the letters I already had.
MS. HAJJAR: Were some of those letters unopened?
LAUREN SALZMAN: I don't recall whether Nicki's were unopened but many of mine were unopened.
MS. HAJJAR: When you say they became part of the case, what do you mean by that; did you provide them to the Government?
LAUREN SALZMAN: Yes. And I send them through my counsel to Keith's counsel.
MS. HAJJAR: Did you eventually read the letters?
LAUREN SALZMAN: Some of them.
MS. HAJJAR: Your Honor, may I show something to the witness for identification?
Your Honor, may I approach the witness?
THE COURT: Yes, you may.
MS. HAJJAR: Ms. Salzman, I handed you a stack of papers which is marked for identification as Government's Exhibit 907. Do you recognize that exhibit?
LAUREN SALZMAN: Yes, these are Dani's letters to Keith.
MS. HAJJAR: Are these the letters that you provided to the Government?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Your Honor, the Government offers Government's Exhibit 907 into evidence.
MR. AGNIFILO: No objection. 1 through 522, the Pages 1 through 522?
MS. HAJJAR: I believe so.
THE COURT: All right. Government's Exhibit 907 is received in evidence.
(Government's Exhibit Number 907 so marked and received in evidence.)
MS. HAJJAR: And, Ms. Salzman, before the defendant was arrested did you have occasion to read those letters?
LAUREN SALZMAN: Yes. I mean, I -- I -- I didn't -- I don't understand the word, the use of the word occasion.
MS. HAJJAR: Did you read them?
LAUREN SALZMAN: No, I didn't read them.
MS. HAJJAR: You just maintained them?
LAUREN SALZMAN: I just maintained them.
MS. HAJJAR: Prior to Daniella being in the room, were you aware of a romantic relationship between Daniella and someone other than the defendant?
MS. HAJJAR: May I show something to the witness alone, Your Honor?
THE COURT: Go ahead.
MS. HAJJAR: I'm showing you what's marked for identification as Government's Exhibit 43.
Do you recognize this photograph?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Who is it?
LAUREN SALZMAN: It's as photograph of Ben Myers.
MS. HAJJAR: Your Honor, the Government offers Government's Exhibit 43 into evidence.
MR. AGNIFILO: No objection.
THE COURT: All right. Government's Exhibit 43 is received in evidence.
(Government's Exhibit Number 43 so marked and received in evidence.)
MS. GERAGOS: Your Honor, I think I just need to talk to Ms. Hajjar about the exhibit.
(Pause in proceedings.)
MS. GERAGOS: That's fine, Your Honor.
MS. HAJJAR: Who is the person depicted in Government's Exhibit 43?
LAUREN SALZMAN: Ben Meyers.
MS. HAJJAR: At any point did the defendant express negative views towards Ben Myers to you?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: Ben later -- so after Dani went back to Mexico I learned from Karen Unterreiner that Ben and Dani had had a relationship. And after that time Ben started dating my sister, and frequently -- and later became her husband but frequently, Keith would tell me that he thought that the relationship between Ben and my sister was destructive or that the two of them would never grow because it was too dependent and that my mother was promoting this relationship and it was bad for my sister, bad for Ben, bad for my mother, and that ultimately, Keith was going to be the one who was going to end up supporting Ben and Michelle's children if they ever had any because Ben and Michelle would not be capable of doing that on their own.
MS. HAJJAR: At some point, Ms. Salzman, did Daniella leave the room?
LAUREN SALZMAN: Yes, she did.
MS. HAJJAR: Can you explain what happened?
LAUREN SALZMAN: I believe that Cami called me and told me that Dani had come out of the room and that she said she that wanted to go back to Mexico. And I don't recall all the things that followed, but I did go over to the house to see her before she left and say good-bye to her.
MS. HAJJAR: What happened after that?
LAUREN SALZMAN: Her father and Kristin Keeffe drove her down to Mexico and Kristin said that she watched her cross the border and that she had been given an assignment that if she completed it during a certain period of time, which was relatively soon after she was dropped across the border with only -- with like $200 and with her father's accountant if she completed the assignment, which was to do book reports, that is she would have her immigration documents sent to her so that she could return to the U.S.
MS. HAJJAR: What was the assignment?
LAUREN SALZMAN: It had to do with doing a book report of a book of a certain amount of length within a certain amount of time and the book report, I think, had to do -- it may have had to be a certain number of pages but the book had to be a certain of number of pages and the report had to be within a certain period of time and then the date was changed and -- the due date was like -- was bumped up.
MS. HAJJAR: Can you explain to the jury what you knew of what happened to Daniella when she was --
LAUREN SALZMAN: When she went to Mexico?
MS. HAJJAR: Yes.
LAUREN SALZMAN: My understanding is that they drove her down to Mexico, that she crossed the border and her father had given her a certain number of Pesos that were like 200-ish dollars, maybe, give or take. And that they had left her with the father's accountant and that the accountant drove her to a city where -- I think she chose to city, but where she wanted to go. And they left her and initially that when her dad left he said that he would help her in any way that he could to -- to do whatever was needed to come back as long as she was willing do the work, he would support her. And then later that plan changed. And he didn't provide the documents, the document -- providing the documents and we all weighed in on it basically, but she was down there because she didn't have her documents, she didn't have, I think, her birth certificate, she didn't have a passport, she didn't have what she needed to be able to establish a work situation or get a visa or do any of the things she needed to come back. And so a lot of her time was being -- she was reporting that it was taking her so much time to be able to try to find work and find a place to live without the papers that she needed to do that. It was taking too much time to get what she needed to get the papers that she didn't have time -- she was so busy trying to survive that she didn't have time to do the book report and all of us interrupted it as her making up stories, being unwilling to do what she needed to do, and lying about what was going on.
And at one point she had like said that she -- you know, had gone to a festival or something and we all jumped on it like, well, instead of healing she was just going to a party but she had just spent two years in a room and lost her whole family and got shipped across the border with no papers and almost no money, I don't think it's -- for her to take time to process what happened and figure out what she was going to do I don't think is the way we were interpreting it at the time and I think at that point almost anything she would have done we were like, no, no, no. Nothing she did was -- was meeting the requirements.
MS. HAJJAR: Did she have the financial support of her family?
LAUREN SALZMAN: No. Her father withdrew the financial support and she was writing e-mails saying I don't understand why you said you would do this and I don't know why you changed and I don't -- I can't -- there's nothing I can do in the circumstance that I'm in to be able to meet the requirements that you're imposing without the papers to be able to even get a job to pay for what I need to pay for to get what is being asked.
MS. HAJJAR: And were her identification documents being withheld from her?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Do you know what documents they were?
LAUREN SALZMAN: I don't. She mentioned a birth certificate at least in one e-mail that I remember, but I don't...
MS. HAJJAR: What about the other family members, were they permitted to contact Daniella, Marianna and Camila?
LAUREN SALZMAN: I don't believe so. I mean, I don't think anybody -- she was communicating to or through, I believe, her father and I don't think anybody else was speaking to her. They took a stand against it.
MS. HAJJAR: Who was the book report for?
LAUREN SALZMAN: For Keith.
MS. HAJJAR: How did -- you said Kristin Keeffe and Daniella's father took her across the border?
LAUREN SALZMAN: Yes.
MS. HAJJAR: How? Can you describe what you know of that?
LAUREN SALZMAN: I know that they drove by car.
MS. HAJJAR: From New York?
LAUREN SALZMAN: From New York down to, I believe, Texas and then crossed at a border down there. I don't recall which border or what city. And Kristin watched her cross, as I understand. And along the way Kristin said that she searched Dani's things and found that Dani had stolen some money and things and then later Kristin reported that Dani had hacked into e-mail and Facebook accounts, but I don't know about that other than what Kristin said about it. So they were also asking her to turn over all passwords to all accounts.
MS. HAJJAR: Were you aware if Kristin Keeffe was in contact with the defendant on the way to Mexico?
LAUREN SALZMAN: Yes. I heard she was but I can't remember if Keith told me or Cami told me.
MS. HAJJAR: Your Honor, can I show something to the witness for identification?
THE COURT: Go ahead.
MS. HAJJAR: Ms. Salzman, I'm showing you what is marked for identification as Government's Exhibit 1484R.
Do you recognize this exhibit?
LAUREN SALZMAN: Yes, I do.
MS. HAJJAR: What is it?
LAUREN SALZMAN: This is a letter from Hector, Dani's father, to the family members just the siblings so Marianna, Adrian and Cami and Kristin and I are cc'd on the e-mail and it's -- the subject is Dani update, so it's an update about Dani.
MS. HAJJAR: What's the date of Government's Exhibit 1494R?
LAUREN SALZMAN: February 27, 2012.
MS. HAJJAR: I'm going to show you what's marked for identification Government's Exhibit 1484 -- 1485R.
Do you recognize this exhibit?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What is it?
LAUREN SALZMAN: It is an e-mail that I sent to all the people listed in the prior e-mail. So Adrian, Kristin and cc'd Hector, Marianna and Cami. And I -- in response to the Dani update.
MS. HAJJAR: Showing you what is marked for identification as Government's Exhibit 1486R.
Do you recognize this exhibit?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What is it?
LAUREN SALZMAN: It's an e-mail from Kristin Keeffe to all the same people that I listed prior and it -- the subject is RE: Important.
MS. HAJJAR: I'm showing you what's marked for identification as Government's Exhibit 1488R.
Do you recognize this exhibit?
LAUREN SALZMAN: Yes. This is an e-mail from Hector, Dani's father, to all the same people listed before, the subject RE: Important.
MS. HAJJAR: And showing you what's marked for identification as Government's Exhibit 1489R.
Do you recognize this exhibit?
LAUREN SALZMAN: Yes. It's an e-mail from me to all the same people, subject RE: BoBi.
MS. HAJJAR: Your Honor, the Government offers Government's Exhibits 1484R, 1485R, 1486R, 1488R, and 1489R into evidence.
MR. AGNIFILO: No objection.
THE COURT: All right. Government's Exhibits 1484R, 1485R, 1486R, 1488R, 1489R are received in evidence.
(Government's Exhibit Numbers 1484R, 1485R, 1486R, 1488R and 1489R so marked and received in evidence.)
MS. HAJJAR: Ms. Salzman, I'm going to show you now what's in evidence as Government's Exhibit 1485R.
Who was this e-mail from?
LAUREN SALZMAN: Mr. Hector, Dani's father.
MS. HAJJAR: And what is the date of this e-mail?
LAUREN SALZMAN: February 27, 2012.
MS. HAJJAR: And what is the subject?
LAUREN SALZMAN: Dani update.
MS. HAJJAR: And do you see where it says she had ten weeks to do three tasks while in Mexico?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you read those three -- the three things?
LAUREN SALZMAN: One earning her living down there. I just gave her 1660 Pèsos cash, around 128 US dollars and I paid the bus ticket to Merida; two, deliver book report results; three, getting her USA visa. I would pay the fees but Dani needed to do all the paperwork.
MS. HAJJAR: Showing you the bottom part of this exhibit. Can you just read the text that you see right here (indicating)?
LAUREN SALZMAN: Yes. She said she chose a book in Spanish called Sensations and Perceptions to start book report. KK, which is Kristin Keeffe thinks that she is still playing games with little or no conscience. KK has proof that Dani hacked the great head account. KK had changed the password previously.
MS. HAJJAR: Now these book reports, are these the assignments that you were referring to before?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Do you know what the great head account is?
LAUREN SALZMAN: It was an e-mail account of Dani's.
MS. HAJJAR: I'm showing you what is in evidence as Government's Exhibit 1488R. This is a series of e-mails. Can you read the bottom e-mail?
LAUREN SALZMAN: Dear Dani, The family no longer has the heart to keep calling you out on your destructiveness and playing your games. Please send a book report and all the e-mail accounts and passwords you had access to in the last year to me within 48 hours. This report needs to based on a book that is 250 pages or more and must be a minimum of 10,000 word. Thereafter you will need to send one new book report by midnight Eastern Standard time every seven days. If you do not complete these tasks without exception or excuse it will demonstrate to us a lack of care for the family and therefore we cannot support such difference in values. Additionally you need to legitimately return to Clifton Park by Wednesday, April 4, 2012, unfortunately we cannot consider sending you any of your requested documents. With Love, Papa, Marvy, Fluffy, and Cami.
MS. HAJJAR: What did you understand any of her requested documents to be?
LAUREN SALZMAN: That they weren't going to send her, her immigration documents, her birthday certificate or -- and whatever else they had.
MS. HAJJAR: Do you recall if this e-mail had been drafted previously?
LAUREN SALZMAN: Yes, I recall that Kristen Keeffe had drafted the letter previously.
MS. HAJJAR: This report needs to be based on a book that is 250 pages or more and must be a minimum of 10,000 words.
What is that describing?
LAUREN SALZMAN: The book that she would do the book report on.
MS. HAJJAR: That e-mail was sent on February 29, 2012?
LAUREN SALZMAN: This one in front of me?
MS. HAJJAR: The one that Daniella's father sent that you just read.
LAUREN SALZMAN: Yes, correct.
MS. HAJJAR: And did Daniella respond?
LAUREN SALZMAN: She did respond.
MS. HAJJAR: And can you read her response?
LAUREN SALZMAN: Papa, I don't have a book report now, I will not have it ready in 48 hours. I started working on the one I told you and it is about 600 pages long and in a large textbook like format so it doesn't fit my measurements and I started it just on Saturday. Also I have sent you all the accounts I had access to. There's nothing more I can send you. I didn't open a Facebook or Skype account yet as I said I would because it would be pointless since I have no money to pay the cyber to use them. Without my papers I cannot do anything about my visa at all. I'm so sad, I cry every time I'm alone. You haven't answered my constant questions about being able to write Keith and Cami and Fluffy and Marvy. I have so much I need to say to each of you, this really seems impossible now. Why won't you send me my papers? You said on the last talk you and Kristin had with me that you would help with me with my visa in every way you could. Sending me what I needed even economically and I'm not asking for anything but my papers. I will pay you for sending them if that is what you want. There is nothing I can do without them. I cannot renew my passport yet because I have no money. I cannot open a bank account to begin building the basis for a tourist visa because I have no proof of address. I cannot begin applying at Au Pair institutes because I have no proof of any education. I can do nothing. What is this? What did I had do? I have been trying to survive and just as I'm getting started what am I supposed to do? What do you want me to do?
MS. HAJJAR: When Daniella writes you have not answered my constant questions about being able to write Keith and Cami and Fluffy and Marvy, what did you understand her to mean?
LAUREN SALZMAN: That she was asking for permission to do that because she had been told she couldn't.
MS. HAJJAR: And what reference to her papers, what did you understand that to mean?
LAUREN SALZMAN: Whatever the immigration documents she had or that -- that her father had in his possession that she was asking for.
MS. HAJJAR: Now, on February 29, 2012, did Kristin Keeffe respond?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And can you just read the first paragraph?
LAUREN SALZMAN: Hi All, I think this is total fabrication. Dani has been stealing in mind about book reports since before Gaelyn was born. In all these years, she has never produced one book report that was adequately done and submitted in a straightforward fashion. Does she really expect us to believe that after all these years of not producing and now when she had a full time -- oh, I'm sorry, my screen went black -- now when she has a full-time job for the first time in her life, allegedly, she chose to do a book report on a book that is the three times the minimum length, a 30,000 word report? She is such a liar, it takes my breathe away.
Continue?
MS. HAJJAR: When -- at the bottom of the e-mail Kristin Keeffe writes, Whatever we decide to do I think it's really important everyone stay strong and holds the line. What did you understand that holding the line to be?
LAUREN SALZMAN: Not giving her what she was asking for and not changing the conditions under which she could have what she was asking for.
MS. HAJJAR: On February 29, 2012, did you respond?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: Can you read your e-mail?
LAUREN SALZMAN: I'm in agreement with all of you. Not one apology to anyone since she left. I think this is all gameplaying. In the least, she could send a well-formed outline of the steps it would take for her to legitimately get her papers and ask for an extension as needed. That's what a responsible person would do, figure out the data, make a proposal, keep everyone apprized of progress. Saying I can do nothing is a lie.
Also if is she wants to write people she could just write a letter, send it to Hector and request that he forward it. Victimizing herself when she's been totally passive other than to make requests and demands is not the behavior of someone who is making a proactive effort in any forward moving direction.
MS. HAJJAR: What did you mean by this e-mail?
LAUREN SALZMAN: Well at the time, I was looking at it that what she was saying was not as it was and that if she really was committed to come back and really committed to healing, she would be doing the things that I listed.
MS. HAJJAR: What was the steps it would take for her to legitimately get her papers? What did you mean by that?
LAUREN SALZMAN: Well, she did lay out the steps that it would take for her to list the demands -- we got per papers in the first e-mail.
MS. HAJJAR: What -- what does that mean?
LAUREN SALZMAN: Well, so there's two things. There's her getting the papers back from her father by doing his steps, which she was explaining why she wasn't able to do because she was laying out the legitimate steps it would take her in the circumstance she was in not being able to meet the deadline to get the request from her father.
MS. HAJJAR: What's your view now of this response?
LAUREN SALZMAN: I think that we were being incredibly abusive. Like the circumstances that she was left in were horrendous. She was describing to us what they were and everything she said -- and the whole time that she had been in the room she was writing things she could do. She wrote a letter to her mom or she wrote a letter to Keith or she wrote proposals to me. Everything that she did we told her -- we shot down and we told her it was manipulative or it was gameplaying or it was just trying to get something. So after you beat that into somebody until they finally submit and now they're asking permission of what's okay to do, all of a sudden saying, well, why are you asking for permission to everything? Why don't you just do it? Because everything that she had already done, we were saying, no, no, this is an example of a problem. This is an example of why you're in the room. This is bad behavior. So like at some point, nothing she could do was the right thing, and she got no help and was just cast out of the family.
MS. HAJJAR: Who told you her behavior was manipulative and gameplaying?
LAUREN SALZMAN: Keith consistently told me that until we all started to see it that way.
(Continued on the next page.)
LAUREN SALZMAN: (Cont'g.) When I look back and read the things she was writing there were legitimate attempts to do the things that were being asked, that we were saying no, no, no at the time.
MS. HAJJAR: After Daniella went to Mexico were her family members instructed to shun her; is that a concept that you're familiar with, shunning?
LAUREN SALZMAN: Yes, shunning is a concept that I am familiar with and they did shun her. I'm not sure how they came to shun her specifically but there were discussions, Keith did raise the idea that they not speak to the mother or Dani, Adriana or Dani until they healed these things and that they should discuss it and the result of their discussions was that they took that position.
MS. HAJJAR: What was your understanding of the concept of shunning, what role did it play in the community?
LAUREN SALZMAN: The concept of shunning was introduced into the community after a number of people had left the NXIVM organization and were publicly speaking to the media and making allegations of improper conduct within the community and Keith released a community project and this idea of shunning as this nonviolent way to deal with unethical behavior, that people could take a stand against it by boycotting it through shunning.
MS. HAJJAR: Were you ever asked to shun family members of yours?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain that to the jury?
LAUREN SALZMAN: During this same time frame of the community project, and I was head of the ethics division at the time, my father would not take a stand against the community members who left the community and were saying what was considered at the time disparaging things, making assertions of improper conduct against Keith and the community, and my dad wouldn't take a stand against that and for Keith and for NXIVM and Keith told me that he thought that my father didn't love me and if he really loved me, he would do this and that he -- he really thought about it and he thought he didn't ever love me and that, you know, to take an ethical stand against this through not speaking to him and cutting off the relationship was what was right.
MS. HAJJAR: When you say your father didn't stand up for the defendant, what do you mean, what did he do?
LAUREN SALZMAN: A number of people had left the community and written a letter saying basically if you don't give us certain things, we're going to go to the media and this was -- I was told it was an extortionate letter and that it was, you know, an extortionate act and that one of the women who was on the letter was not withdrawing her support from the letter and she was a good friend of my stepmother and my dad hired her to work in his medical spa and he didn't fire her.
MS. HAJJAR: And so --
LAUREN SALZMAN: Or -- he didn't fire her or get her to change her perspective and withdraw her support from the other women.
MS. HAJJAR: And so, the not standing up for the defendant was not firing this woman?
LAUREN SALZMAN: Correct, and at the same time as well or similar time my father had just started a medical spa and Keith had said that he -- at some point he wanted to have a medical spa and that he felt that my dad should have waited because if -- to do it with him and didn't know why my dad wouldn't do that because it was going to be a conflict of interest later.
MS. HAJJAR: You testified about letters that were sent to former DOS slaves at one point. Are you aware of other legal efforts that NXIVM took against those who spoke out publicly about NXIVM?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you describe some of those efforts?
LAUREN SALZMAN: Well, in the earlier days there was a lawsuit against a cult deprogrammer and one of our former members for theft of intellectual property but they were speaking out about the organization saying that we brainwash people and that our organization was harmful and a cult.
MS. HAJJAR: Who was that person's name, the cult deprogrammer?
LAUREN SALZMAN: Rick Ross.
MS. HAJJAR: Did you hear disparaging things said about Rick Ross in the wake of that?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What kind of things?
LAUREN SALZMAN: That Rick Ross was a criminal and that he had kidnapped a boy out of a Pentecostal religion.
MS. HAJJAR: Were these things being said within the NXIVM community?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Do you know what the basis for the lawsuit was? You mentioned a lawsuit.
LAUREN SALZMAN: That one of our members, Stephanie Franco, had taken our course materials which she had signed confidentiality agreements against or confidentiality agreements with respect to and she gave them to Rick Ross and he published them on the website.
MS. HAJJAR: So, the lawsuit was about the publication of NXIVM materials on a website?
LAUREN SALZMAN: Yes, that was my understanding.
MS. HAJJAR: Are you aware of a time where Kristin Keeffe was demoted from proctor to coach?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you describe that?
LAUREN SALZMAN: I don't recall specifically why she was demoted from proctor to coach but she came to coach class in Albany which was a specific class for our higher ranks and she publicly demoted herself a rank from the proctor rank, the orange sash to a yellow sash for some failure of misconduct.
MS. HAJJAR: And what happened at that meeting?
LAUREN SALZMAN: Keith came to the meeting with a scale and he put the scale under his chair and he told me laughing that he wanted Kristin to think that she might have to publicly weigh herself.
MS. HAJJAR: Were you ever asked to make contributions to a political campaign?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: Yes, I was told that we were making a campaign contribution and that I was asked if I would write a check for the campaign contribution and I would be reimbursed for it.
MS. HAJJAR: Were you reimbursed for it?
LAUREN SALZMAN: I believe so, yes.
MS. HAJJAR: Ms. Salzman, you testified at another point that you had a private nickname with the defendant, the defendant called you something specific?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you remind us what that was?
LAUREN SALZMAN: Forlorn.
MS. HAJJAR: I'd like to show you what's been marked for identification as Government Exhibit 1498.
Do you recognize this exhibit?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What is it?
LAUREN SALZMAN: It's a letter that I wrote to my mom and to Keith about an EM -- one of -- about a work project basically in our company that I was working on.
MS. HAJJAR: Your Honor, the government offers Government Exhibit 1498.
MR. AGNIFILO: No objection.
THE COURT: Government's 1498 is received in evidence.
(Government's Exhibit 1498 so marked in evidence.)
THE COURT: You may publish it to the jury.
MS. HAJJAR: Thank you, Your Honor.
MS. HAJJAR: Who is this email from, Ms. Salzman?
LAUREN SALZMAN: From me at my proctorinfo email address, so that was a work email address.
MS. HAJJAR: Who was it sent to?
LAUREN SALZMAN: My mother at her nycap address and Keith when he used to use Karen Unterreiner's old nycap email address.
MS. HAJJAR: So, the prefect@ e-mail address, is that your mother's email address?
LAUREN SALZMAN: Yes, correct.
MS. HAJJAR: And the other email address is the defendant's?
LAUREN SALZMAN: Yes, kunterre, it's Karen Unterreiner, he used that email address for a number of years.
MS. HAJJAR: Did you frequently communicate with the defendant using that email address?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: And you addressed the email Vanguard and Prefect?
LAUREN SALZMAN: Correct.
MS. HAJJAR: Is that the defendant and your mother?
LAUREN SALZMAN: Yes.
MS. HAJJAR: At the end did you sign that email with your nickname?
LAUREN SALZMAN: Yes, Forlorn.
MS. HAJJAR: Were you aware if Barbara Bouchey had a nickname?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What was her nickname?
LAUREN SALZMAN: It was Ja.
MS. HAJJAR: J-A?
LAUREN SALZMAN: J-A, Ja.
MS. HAJJAR: Ms. Salzman, you testified about various members of the defendant's inner circle?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did they live in the same general geographic area?
LAUREN SALZMAN: Yes, all within a few miles of each other.
MS. HAJJAR: Where was that?
LAUREN SALZMAN: In Clifton Park, New York; Clifton Park, Halfmoon, Waterford, all right around, like mostly a three-mile radius but in some cases extending a little beyond that, all within ten minutes of each other.
MS. HAJJAR: I'm showing you what's in evidence as Government Exhibit 176. Are you familiar with this area, Ms. Salzman?
LAUREN SALZMAN: Yes, I am.
MS. HAJJAR: And as to certain individuals that you've been discussing, I'd like to just go over where they lived in relation to each other.
Pamela Cafritz, do you know where she lived initially?
LAUREN SALZMAN: Initially Pam lived at 3 Flintlock Lane.
MS. HAJJAR: Is that depicted on Slide 6 of Government Exhibit 176?
LAUREN SALZMAN: Yes. Do you want me to mark it up?
MS. HAJJAR: Note it please.
LAUREN SALZMAN: Note -- it's there.
MS. HAJJAR: Where did she move after that?
LAUREN SALZMAN: She moved to 8 Hale Drive in Halfmoon.
MS. HAJJAR: And after that?
LAUREN SALZMAN: To 2 Flintlock Lane in Halfmoon.
MS. HAJJAR: And after that?
LAUREN SALZMAN: To 21 Oregon Trail in Waterford.
MS. HAJJAR: And when Pamela Cafritz lived at 3 Flintlock, who did she live with?
LAUREN SALZMAN: Keith, Karen and Kristin and then later Marianna moved in there.
MS. HAJJAR: And that's Karen Unterreiner an Kristin Keeffe?
LAUREN SALZMAN: Yes, correct.
MS. HAJJAR: What about Barbara Jeske, where did she live?
LAUREN SALZMAN: Barbara Jeske lived in another development at 1 Brigantine.
MS. HAJJAR: Was that nearby?
LAUREN SALZMAN: Yeah, it's like a mile away.
MS. HAJJAR: And Dawn Morrison, where did Dawn Morrison lived?
LAUREN SALZMAN: Dawn Morrison, -- I can't remember the name of her street but she lived in the same development as this, so she lived like a quarter of a mile from 3 Hale Drive.
MS. HAJJAR: Within Knox Woods?
LAUREN SALZMAN: Yeah, within Knox Woods, just around the corner from where I lived at 3 Hale Drive.
MS. HAJJAR: Showing you Slide 34 of Government Exhibit 176, where did your mother live?
LAUREN SALZMAN: My mother lived at 3 Oregon Trail.
MS. HAJJAR: Is that depicted on this slide?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Where did you live between 2004 and 2015?
LAUREN SALZMAN: I lived at 3 Hale Drive.
MS. HAJJAR: Is that in Knox Woods?
LAUREN SALZMAN: Yes, in Knox Woods.
MS. HAJJAR: What about Barbara Bouchey, where did she live?
LAUREN SALZMAN: Barbara Bouchey lived almost right across the street from Flintlock Lane on -- I think the street was called Washington Court or Washington Drive but it was just -- it was literally across the street.
MS. HAJJAR: Was that in Knox Woods as well?
LAUREN SALZMAN: All in Knox Woods, yeah.
MS. HAJJAR: What about Kathy Russell, where did she live?
LAUREN SALZMAN: Kathy Russell lived two or three miles away in an apartment complex, I think it's called Mohawk Terrace Apartments where Barbara Jeske had originally lived and then Kathy moved into her old apartment when Barbara moved to Brigantine, all within a three-mile radius.
MS. HAJJAR: And Daniella, Marianna and Camila, where did they live?
LAUREN SALZMAN: They lived at 12 -- well, originally they all lived at 12 Wilton Court, then Marianna moved into 3 Flintlock and then subsequently 8 Hale, 2 Flintlock and then 21 Oregon with Keith and Pam; Dani stayed at 12 Wilton Court and eventually Cami moved to 120 Victory Way, all in Knox Woods.
MS. HAJJAR: When Daniella was in the room what address was she at?
LAUREN SALZMAN: 12 Wilton Court.
MS. HAJJAR: What about Camila, where did she live?
LAUREN SALZMAN: Cami lived at 12 Wilton Court until she moved to Victory Way.
MS. HAJJAR: Monica Duran, where did she live?
LAUREN SALZMAN: Monica Duran lived on a street called Minuteman Court, it's right behind Hale Drive where I lived. It's in -- literally just right across the street in Knox Woods.
MS. HAJJAR: And Ivy Nevares?
LAUREN SALZMAN: Ivy Nevares lived on Grenadier Court, so half a mile away in the same development.
MS. HAJJAR: And Loreta Garza, where did she live?
LAUREN SALZMAN: Loreta Garza lived in 9 Hale Drive for a period of time and then she moved to a development right behind Knox Woods, so still a mile away.
MS. HAJJAR: Where did Clare Bronfman live?
LAUREN SALZMAN: Clare had a house on Button Road, so within five minutes drive.
MS. HAJJAR: And Jim Del Negro, where did he live?
LAUREN SALZMAN: I'm not sure the address specifically but I think it was in an apartment complex that was like within a mile or two of Knox Woods.
MS. HAJJAR: Emiliano Salinas, did he live in the same area generally?
LAUREN SALZMAN: Emiliano, yes, he bought a -- he lived in a condo that I owned on Minuteman Court, so near Monica, in Knox Woods for a number of years and then he moved to the same development as Loreta, like one mile away.
MS. HAJJAR: Where did Mark Vicente live?
LAUREN SALZMAN: Mark Vicente lived at the Twilight House, I can't remember the number, but then he moved closer to the same apartment complex I think as Jim Del Negro. Oh, and he lived for a period of time as well at 7 Generals Way.
MS. HAJJAR: Where did Nicki Clyne live?
LAUREN SALZMAN: Nicki Clyne lived on Hancock Way originally which was right next to Wilton Court, so similarly in Knox Woods over by Dani, and then she moved to the other side, I think she was on a street called Yorktown which was near Ivy, all in Knox Woods.
MS. HAJJAR: Did she eventually move to 9 Milltowne?
LAUREN SALZMAN: She did, she eventually moved to 9 Milltowne; when Rosa Laura bought the house for the sorority house, Nicki lived in it.
MS. HAJJAR: Where did Rosa Laura Junco live?
LAUREN SALZMAN: Rosa Laura Junco lived ten minutes away -- let me see --
MS. HAJJAR: Showing you Slide 34.
LAUREN SALZMAN: Yeah, I can't recall the name of the street, it's not on this one.
MS. HAJJAR: Okay.
LAUREN SALZMAN: But it took me ten minutes to get to her house.
MS. HAJJAR: And Daniella Padilla, where did she live?
LAUREN SALZMAN: Daniella Padilla lived over by Wilton Court, so over by where Dani lived and Nicki originally.
MS. HAJJAR: Where did Allison Mack live?
LAUREN SALZMAN: Allison Mack lived in 7 Generals Way and then she moved I think to Grenadier Court, I'm not sure if 127 was the number. I believe it was. Yes, 127 Grenadier.
MS. HAJJAR: And Alex Betancourt, where did he live?
LAUREN SALZMAN: Alex lived over by Rosa Laura, so within ten minutes.
MS. HAJJAR: And Jack Levy, where did he live?
LAUREN SALZMAN: Jack rented an apartment right across the street from Knox Woods just on the other side, so one mile away.
MS. HAJJAR: Were you aware of an instance in which someone outside the defendant's inner circle attempted to move into Knox Woods?
LAUREN SALZMAN: Yes, there was a man named Ed Kinnam who moved into Knox Woods and my mother -- Keith directed my mother to tell him that it was a security risk to be there for Keith and so he was asked to move out.
MS. HAJJAR: Did he move out?
LAUREN SALZMAN: Yes, he did.
MS. HAJJAR: Were you aware if the defendant attempted to stop a member of the inner circle from moving out of Knox Woods?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you describe that to the jury?
LAUREN SALZMAN: Nicki rented an apartment outside of Knox Woods about maybe a mile and a half, two miles away and she had told me that Keith called her and told her that it was a breach and she should live closer. She moved back into Knox Woods.
MS. HAJJAR: She moved back into the community?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Into Knox Woods?
LAUREN SALZMAN: Yes, back into the development.
MS. HAJJAR: Did there come a time where you became aware of certain allegations against an individual named Robbie Chiappone?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Who first alerted you to these claims?
LAUREN SALZMAN: Keith.
MS. HAJJAR: Were these claims reported to law enforcement right away?
LAUREN SALZMAN: Not right away, within six weeks.
MS. HAJJAR: And who reported them eventually?
LAUREN SALZMAN: I did with Alex and Robbie.
MS. HAJJAR: At some point after that were you tasked with checking in with Robbie every day?
LAUREN SALZMAN: Yes, tasked to assign Robbie to check in with me everything he was doing.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: That because of Robbie's conduct he was a potential liability to the community and if he was going to be allowed to continue to live near us all, he needed to be reporting in to me about everything he was doing and everybody he was with while he stayed in the community and before he left to join the military.
MS. HAJJAR: Did Robbie check in with you?
LAUREN SALZMAN: Yes, he was checking in with me.
MS. HAJJAR: What did the defendant tell you about what Robbie was telling you in his check-ins?
LAUREN SALZMAN: That he thought that Robbie was not being honest, was lying to me about what he was doing or who he was with and that it would be good to set something up to be able to catch him so that Robbie would know that we knew he was lying.
MS. HAJJAR: What did you understand that to mean, set something up so we could test him?
LAUREN SALZMAN: Well, he proposed that we arrange a meeting.
MS. HAJJAR: When you say, "he," Ms. Salzman, who are you --
LAUREN SALZMAN: Keith told me to arrange a meeting between -- to have Robbie -- Robbie and I went to the Shenendehowa track which was the high school track and walked around and staged a meeting that seemed accidental to Robbie but it was planned between Robbie and Nicole except that he didn't know that Nicole was Nicole, she used a false name, and Keith told me to do this, to have Robbie there so that he could have this meeting with Nicole that appeared to be accidental.
MS. HAJJAR: What was the purpose of the staged meeting?
LAUREN SALZMAN: To see if Robbie reported it to me.
MS. HAJJAR: And what happened?
LAUREN SALZMAN: I brought Robbie to the track, Nicole was there, I spent some time with him there and when I left I saw her approach him and the two of them have a conversation and I left.
MS. HAJJAR: Did you prearrange this meeting with Nicole?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: Is this the same Nicole who was the DOS slave you spoke about earlier?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And around what period of time was this?
LAUREN SALZMAN: This was -- I think it was in the fall of 2015.
MS. HAJJAR: What happened after you left Robbie and saw Nicole at the track, what happened after that?
LAUREN SALZMAN: I'm sorry, I think it was 2016.
MS. HAJJAR: So, in 2016?
LAUREN SALZMAN: 2016.
MS. HAJJAR: What happened?
LAUREN SALZMAN: What happened after the track?
MS. HAJJAR: Yes?
LAUREN SALZMAN: Keith alerted me that there had been subsequent communications and meetings between the two of them, that Nicole was with Robbie and a friend of his and asked me if Robbie was -- told me about it.
MS. HAJJAR: Did you interact with Robbie and Nicole together?
LAUREN SALZMAN: No, I did not.
MS. HAJJAR: And did the defendant tell you that Nicole was going to use a false name?
LAUREN SALZMAN: Yes, he did and that she set up a false Facebook account.
MS. HAJJAR: Did you have a subsequent conversation with the defendant about this?
LAUREN SALZMAN: I did because I was concerned based on the allegations that had been made against Robbie and based on my conversations with Keith that he was a liability and might be a danger to people within our community, I was concerned about Nicole spending time with him and so I was asking Keith does she know about Robbie and like is she -- I mean is she going to have sex with him or what's going to happen.
MS. HAJJAR: You asked him this because the allegations you had heard involved -- involved sex in some way?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What did the defendant tell you?
LAUREN SALZMAN: That she was not going to have sex with him but that she would if he asked her to, that she would if Keith asked her to, he said she would if I asked her to.
MS. HAJJAR: And at the time did you understand -- were you in DOS at the time?
LAUREN SALZMAN: I was not.
MS. HAJJAR: Did you understand what he meant?
LAUREN SALZMAN: No. It seemed strange to me and I didn't know that they had had any relationship, so that alerted me that they had some relationship where if he had asked her to have sex with another person, she would have done it.
MS. HAJJAR: At some point after that did you ask Mark Vicente to remove a video of Nicole somewhere?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: Can you explain that and why you did that?
LAUREN SALZMAN: Yeah. So, for the same reason that -- my understanding was that Robbie was a potential danger to people -- to women within our community and Nick had interacted -- Nicole had interacted with Robbie using a false name and he didn't know that she had any connection to our community, I was afraid that if he found out that she had a connection to our community, that might put her in danger, that he might feel tricked and upset and do something to her that could be potentially detrimental to her.
THE COURT: Can we just take a -- keep that thought, we're just going to -- one of the jurors needs to leave the room briefly so why don't we just wait.
JUROR: Thank you.
THE COURT: Take your time.
(Pause in the proceedings.)
THE COURT: If you want to stand and stretch, you can. I do. (Pause.)
(Juror reenters the courtroom.)
THE COURT: All right, let's continue then.
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, you were explaining why you asked Mark Vicente to remove a video of Nicole.
LAUREN SALZMAN: Yes, so my understanding was that the allegations against Robbie and the circumstances surrounding Robbie were a potential liability and danger to women within our community, women in general but women within our community at this time and that Nicole had engaged with him under a circumstance where he didn't know who she was and that was on purpose she had given a false name and he didn't know that she was part of our community and I thought that if he saw her -- she was in a V Week promotional video, if he saw her in V week video it might alert him to the fact that it had not been accidental, their meeting, and that she had lied about who she was and I thought it could put her at risk so I asked Mark to please remove her from the video in the unlikely but possible event that Robbie might see the video and recognize her.
MS. HAJJAR: All right. Ms. Salzman, I'm going to direct your attention to July 24th, 2018, were you arrested on that date?
LAUREN SALZMAN: Yes, I was.
MS. HAJJAR: What charges were you arrested for?
LAUREN SALZMAN: I was arrested for harboring, trafficking forced labor, wire fraud, an extortion and as part of a racketeering conspiracy.
MS. HAJJAR: And directing your attention to March 2018, did there come a time where you asked for a meeting with the government?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: Did you later meet with FBI agents and people from the U.S. Attorney's Office?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: Were you represented by a lawyer?
LAUREN SALZMAN: Yes, I was.
MS. HAJJAR: And at some point after that did you decide to start cooperating with the government?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: When did you first start meeting with the government?
LAUREN SALZMAN: I believe in March.
MS. HAJJAR: And in the --
LAUREN SALZMAN: I don't recall the date specifically.
MS. HAJJAR: And in the weeks and months that followed did you meet with federal agents and prosecutors again?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: And what types of things did you talk about in these meetings?
LAUREN SALZMAN: All the things that I've spoken about here in the last couple of days, the crimes that I participated in and ones that I knew about, some of them that the government was aware of and some additional ones that they weren't.
MS. HAJJAR: Did you tell the government about all the crimes that you committed or had knowledge of?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: And about crimes that other individuals committed?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: Including the defendant?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did you tell the government about crimes committed by people you cared about?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: Did you ultimately plead guilty?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: What crimes did you plead guilty to?
LAUREN SALZMAN: I pled guilty to racketeering and racketeering conspiracy.
MS. HAJJAR: Did that involve admitting participation in certain other crimes as well?
LAUREN SALZMAN: Yes, it did.
MS. HAJJAR: Where did you plead guilty?
LAUREN SALZMAN: Here in the Eastern District in this courtroom.
MS. HAJJAR: Before a judge?
LAUREN SALZMAN: Before Judge Garaufis.
MS. HAJJAR: And was that in March of 2019?
LAUREN SALZMAN: Yes, it was.
MS. HAJJAR: I may have misspoken, did you start meeting with the government prior to that?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: In that year, 2019?
LAUREN SALZMAN: Yes, correct.
MS. HAJJAR: After you pleaded guilty did you continue to meet with the government?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: In your indictment was there an enterprise alleged?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And did you plead guilty to being part of that enterprise?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: That enterprise was the defendant's inner circle?
LAUREN SALZMAN: Yes.
MS. HAJJAR: When you pled guilty did you do so pursuant to a written agreement?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Was that a cooperation agreement?
LAUREN SALZMAN: Yes, it was a cooperation agreement.
MS. HAJJAR: Your Honor, may I show the witness what's marked for identification as 3500 LS-6.
THE COURT: Yes, you may.
MS. HAJJAR: Thank you, Your Honor.
LAUREN SALZMAN: This is my cooperation agreement.
MS. HAJJAR: And turning to page ten of this agreement, is this your signature?
LAUREN SALZMAN: Yes, it is.
MS. HAJJAR: Your Honor, the government moves to admit 3500 LS-6.
MR. AGNIFILO: No objection.
THE COURT: All right, Government Exhibit 3500 LS-6 is received in evidence.
(Government's Exhibit 3500 LS-6 so marked in evidence.)
MS. HAJJAR: As part of this agreement, Ms. Salzman, did you make certain promises to the government?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: What were those promises?
LAUREN SALZMAN: To provide truthful and complete testimony and to assist with any aspects of the investigation that I was able to.
MS. HAJJAR: What do you hope to get in return?
LAUREN SALZMAN: A letter saying that I provided truthful testimony and helped in the way that I just described.
MS. HAJJAR: Did the government agree to do anything else aside from writing that letter in your cooperation agreement?
MS. HAJJAR: Do you know the maximum sentence that you face?
LAUREN SALZMAN: My understanding is it is up to twenty years.
MS. HAJJAR: On each --
LAUREN SALZMAN: On two counts.
MS. HAJJAR: Who decides your sentence?
LAUREN SALZMAN: Judge Garaufis.
MS. HAJJAR: Will the government recommend a specific sentence to the judge?
MS. HAJJAR: Has the government promised you anything about what your sentence will be in this case?
MS. HAJJAR: Do you know if your sentence depends on what happens in this particular trial?
LAUREN SALZMAN: I was told it does not, it's not, it's outcome independent.
MS. HAJJAR: What's your understanding of what happens if you fail to tell the truth today?
LAUREN SALZMAN: That all the agreements that I made are forfeit.
MS. HAJJAR: What happens to your cooperation agreement?
LAUREN SALZMAN: It's forfeit.
MS. HAJJAR: What does that mean?
LAUREN SALZMAN: It means that it is -- that I won't get the letter and that all of the things that -- all the additional crimes and things that I confessed to and shared with the government, told the government about, I could be prosecuted for in addition to the original crimes that I pled guilty to.
MS. HAJJAR: Are you hoping the judge will give you a lower sentence because of your cooperation?
LAUREN SALZMAN: Yes, of course.
MS. HAJJAR: Do you know when you'll be sentenced?
LAUREN SALZMAN: Right now I'm scheduled to be sentenced on September 11th.
MS. HAJJAR: As you sit here today, do you know what your sentence will be?
MS. HAJJAR: Ms. Salzman, you testified that at some point in the fall of 2017 there were efforts to aggregate DOS related materials?
LAUREN SALZMAN: Yes, correct.
MS. HAJJAR: The original copies of physical collateral and DOS materials, do you know where those are?
LAUREN SALZMAN: I don't, no. I had some materials, some collaterals on a hard drive that I left in Mexico with Nicki Clyne that I believe she left with Jack Levy and that I've requested to have back and have not been returned to me.
There were additional materials, collateral that I gave to Rosa Laura that I don't know what she did with, and I am not sure if all the DOS masters gave their collateral and materials to Rosa Laura or they have them themselves somewhere or what happened to them when they left Albany.
MS. HAJJAR: That hard drive that had DOS related materials?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Was there something written on it to indicate it was yours?
LAUREN SALZMAN: Skylar (ph).
MS. HAJJAR: What's Skylar?
LAUREN SALZMAN: It was a combination of Keith and my initials.
MS. HAJJAR: You mentioned that you purchased burner phones to communicate with the defendant?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Where are those now?
LAUREN SALZMAN: I left those phones in Mexico with Nicki when I left so I assume that Jack has them.
MS. HAJJAR: This is Jack Levy?
LAUREN SALZMAN: Yes. I also requested for them back.
MS. HAJJAR: Did Jack Levy at any point acknowledge that he had your electronic devices?
LAUREN SALZMAN: At one point in time he did or at least had access to them.
MS. HAJJAR: And you had made a request through your lawyers for the return of this material?
LAUREN SALZMAN: Yes, correct.
MS. HAJJAR: Have you received these devices back?
LAUREN SALZMAN: I have not, no.
MS. HAJJAR: Your Honor, I believe we're getting to the point where there will be recordings shown so it may be a good time for a break so we can --
THE COURT: All right, we can take our mid- afternoon break at this time.
All rise for the jury.
(Jury leaves courtroom.)
THE COURT: All right, we'll take our break. You may step down. Do not discuss your testimony with anyone.
(Witness steps down.)
THE COURT: All right, we'll take a break.
(Time noted: 3:25 p.m.)
(Recess taken.)
(Continued on next page.)
(continuing.)
(In open court.)
(Defendant enters the courtroom at 3:35 p.m.)
THE COURT: All right. Is there a stipulation or --
MR. AGNIFILO: We reached a stipulation.
THE COURT: And so are you going to put it in evidence?
MS. HAJJAR: Yes, Your Honor.
THE COURT: Okay, before we hear the tapes.
MS. HAJJAR: Yes.
THE COURT: Okay, let's ask the witness to come back.
Are we providing transcripts for the jurors?
MS. HAJJAR: Yes, Your Honor. We have put the binders on their desks.
THE COURT: Okay.
(Witness takes the stand.)
THE COURT: All right, please bring in the jury.
About how long will these tapes take to play?
MS. HAJJAR: I think about 45 minutes in total, Your Honor.
THE COURT: And you have more for the witness after that?
MS. HAJJAR: Very little, if anything. That should be about it.
THE COURT: All right. Well, if we end a few minutes early, we will start cross tomorrow morning.
MR. AGNIFILO: That's fine, Judge. That would be great.
THE COURT: All right.
MS. PENZA: If we are ending earlier, Your Honor, we would ask to keep the direct open until tomorrow morning just because there are a couple exhibits that we may just seek to admit.
THE COURT: All right.
MS. PENZA: But we don't expect anything tomorrow.
THE COURT: You don't expect any further testimony on direct.
MS. PENZA: Correct.
THE COURT: All right.
(Jury enters.)
THE COURT: Members of the jury, there are looseleaf binders on your seats.
JUROR: Missing one.
THE COURT: You are missing one?
UNIDENTIFIED SPEAKER: (Handing.)
THE COURT: All right, you may be seated.
Ms. Hajjar you may continue your examination of the witness.
I remind the witness that she is still under oath.
MS. HAJJAR: At this point, Your Honor --
THE COURT: I'm sorry?
MS. HAJJAR: Your Honor, may I read the stipulation that's been marked as Government's Exhibit 250?
THE COURT: Yes, you may do so.
MS. HAJJAR: The stipulation reads: It is hereby stipulated and agreed by and between the United States of America, by Assistant United States Attorneys Moira Penza, Tanya Hajjar, and Mark Lesko, and by the defendant, Keith Raniere by the undersigned counsel, that on or about October 18th, 2018, India Oxenberg provided the Government with thumb drives containing Government's Exhibits 494, 495, and 496, and on or about April 4th, 2019, Allison Mack provided the Government with a thumb drive containing Government's Exhibit 497.
Government's Exhibits 494, 495, 496, and 497 are admissible into evidence.
Your Honor, we would offer Government's Exhibits 494, 495, 496, 497, and the stipulation itself, which is Government's Exhibit 250, into evidence.
MR. AGNIFILO: We agree, Your Honor.
THE COURT: All right, Government's Exhibit 250 --
MS. HAJJAR: 250, Your Honor, yes.
THE COURT: -- and Government's Exhibits 494, 495, 496, and 497 are all received in evidence.
(Government's Exhibits 494, 495, 496, and 497 received in evidence.)
THE COURT: You may proceed.
MS. HAJJAR: Thank you, Your Honor.
DIRECT EXAMINATION BY MS. HAJJAR: (Continued.)
MS. HAJJAR: Ms. Salzman, you testified that you participated in meetings of the first line in DOS that were recorded.
LAUREN SALZMAN: Yes, that's correct.
MS. HAJJAR: And these recordings were of the defendant and the first-line DOS masters at the time?
LAUREN SALZMAN: Yes.
MS. HAJJAR: In these recorded meetings, did you discuss matters relating to DOS such as branding and enrollment?
LAUREN SALZMAN: Yes, we did.
MS. HAJJAR: Did you have an understanding as to who maintained these recordings?
LAUREN SALZMAN: It was my understanding that Loreta Garza maintained the recordings.
MS. HAJJAR: You testified that you personally reviewed some recordings relating to the DOS book.
LAUREN SALZMAN: Correct.
MS. HAJJAR: In those recordings, did you hear the defendant's voice?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: After you decided to cooperate and after you pleaded guilty in this case, did there come a time that you reviewed certain recordings?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And were those recordings of the defendant and other first-line DOS masters?
LAUREN SALZMAN: Yes, they were.
MS. HAJJAR: Were these recordings recorded prior to your recruitment into DOS?
LAUREN SALZMAN: Yes, they were.
MS. HAJJAR: And were the content of these recordings about DOS?
LAUREN SALZMAN: Yes, they were.
MS. HAJJAR: Now, Ms. Salzman, were transcripts made of these recordings?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And in the binder in font of you, there are transcripts that are marked Government's Exhibit 494T, 495T, 496T, and 497T.
LAUREN SALZMAN: Yes.
MS. HAJJAR: And for each of those exhibits, there's a transcript with the letter T attached.
LAUREN SALZMAN: Correct.
MS. HAJJAR: Did you review these transcripts?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: And to show that you reviewed them, did you sign and date them?
LAUREN SALZMAN: Yes. Those are my initials and the date that I wrote.
MS. HAJJAR: And are these transcripts fair and accurate transcriptions of the recordings?
LAUREN SALZMAN: Yes, they are.
MS. HAJJAR: When you were preparing these transcripts, were you able to make out every single word that was said?
LAUREN SALZMAN: Not every single word.
MS. HAJJAR: Did you indicate "UI" in these transcripts where words were unintelligible?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Your Honor, the Government offers 494T, 495T, 496T and 497T as aids to the jury.
MR. AGNIFILO: No objection.
THE COURT: All right. 494T, 495T, 496T, 497T are received in evidence as aids to the jury.
(Government's Exhibit 494T, 495T, 496T, 497T received in evidence.)
THE COURT: Let me just give you an instruction about these transcripts. You will be listening to the voice recordings and these transcripts are intended to aid you in understanding what's being said, but if there's any difference between what you hear and what you see on the transcript, the evidence is what you hear, so just bear that in mind. So if you hear a word and sounds like one thing on the recording and something else on the transcript, the evidence is the recording.
So having said that, let's move ahead.
MS. HAJJAR: Thank you, Your Honor.
I would like to play Exhibit 494, and I will direct the jury's attention to 494T.
THE COURT: Very well.
(Audio played.)
(Audio paused.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, who is speaking? Can you recognize that voice?
LAUREN SALZMAN: Yes. That's Keith.
MS. HAJJAR: That's the defendant?
LAUREN SALZMAN: Yes, correct.
MS. HAJJAR: Did you hear the other voice that was -- that you heard briefly?
LAUREN SALZMAN: I heard Daniella Padilla and Loreta Garza.
(Audio played.)
(Audio paused.)
BY MS. HAJJAR:
MS. HAJJAR: Rosa Laura, who is that?
LAUREN SALZMAN: Rosa Laura Junco.
(Audio played.)
(Audio paused.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, who are the other participants on this recording? Can you recognize their voices?
LAUREN SALZMAN: Yes. Loreta Garza, Monica Duran, and Daniella Padilla.
MS. HAJJAR: And the discussion of crafts, is that something you are familiar with in the context of DOS?
LAUREN SALZMAN: Yes, it is.
MS. HAJJAR: What is that --
LAUREN SALZMAN: A craft is almost like a committee.
MS. HAJJAR: And what were these committees doing?
LAUREN SALZMAN: They were heading up the different DOS objectives.
MS. HAJJAR: Can you explain that further?
LAUREN SALZMAN: Sure. Like, the collateral craft -- Rosa Laura was head of the collateral craft, so, like, the committee that dealt with collateral, so she was responsible for reviewing and cataloging and storing and rating the effectiveness or legitimacy of each of the collaterals.
(Audio played.)
(Audio paused.)
BY MS. HAJJAR:
MS. HAJJAR: This recording, Ms. Salzman, is this a recording of the defendant and other first-line DOS masters?
LAUREN SALZMAN: Yes, it is.
MS. HAJJAR: Were you involved in any DOS crafts?
LAUREN SALZMAN: I was going to be part of the ethics craft of putting in ethics protocols.
MS. HAJJAR: What were the other crafts?
LAUREN SALZMAN: I actually don't know.
MS. HAJJAR: Was one of the crafts collateral?
LAUREN SALZMAN: Yes. I knew of the collateral one, which I mentioned.
MS. HAJJAR: Your Honor, I would like to play Government's Exhibit 495 and direct the jury's attention to 495T.
THE COURT: Very well.
(Audio played.)
(Audio paused.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, do you recognize the voices on this recording?
LAUREN SALZMAN: Yes, I do.
MS. HAJJAR: And who is speaking?
LAUREN SALZMAN: Keith, Loreta Garza, Nicki Clyne, and Monica Duran.
MS. HAJJAR: And the prefatory language, June 12, 2016, Keith, Nicki, Moni, Laureis, Dani and Lola, who said that line?
LAUREN SALZMAN: Loreta.
(Audio played.)
(Audio paused.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, you testified about the word "lineage" in the context of DOS. What did that mean?
LAUREN SALZMAN: Lineage was each of the lines of subsequent women who are enrolled under a first-line DOS master, so my lineage included -- it was Keith and myself, and then the women I enrolled, the women they enrolled, the women they enrolled, and all the way down, that would be one lineage.
MS. HAJJAR: And the series of components that go with the brand, what does that refer to?
LAUREN SALZMAN: It refers to what I was describing before as the tattoo, the different elements that were going to accompany it, the individual symbols between master and slave, the symbol that indicated each line, possibly the enrollment number, those things.
MS. HAJJAR: You testified yesterday that there would be a number accompanied with the brand in some way?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Was that to be tattooed?
LAUREN SALZMAN: Yes. All of it was to be tattooed on top of the brand or around the brand, as I understood.
(Audio played.)
(Audio paused.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, one out of the each of seven of you, how many first-line DOS masters were there prior to your joining DOS?
LAUREN SALZMAN: Seven.
MS. HAJJAR: And you were the eighth?
LAUREN SALZMAN: Correct.
(Audio played.)
(Audio paused.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, do you know what's being discussed in this section of the recording?
LAUREN SALZMAN: The brand.
MS. HAJJAR: And when the defendant says, It's actually K-A-R --
LAUREN SALZMAN: His initials are -- the brand is his initials, K-A-R.
(Audio played.)
(Audio paused.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, "the common brand as a scarification," do you know what that refers to?
LAUREN SALZMAN: I think it just refers to the brand that everybody got. Not the brand that the first line got, the brand that everyone else got, so the inverted upsidedown brand.
MS. HAJJAR: You testified earlier that the first line got a slightly different brand.
LAUREN SALZMAN: Yes.
MS. HAJJAR: And a grandmaster has certain things. What did you understand a grandmaster to be in the context of DOS?
LAUREN SALZMAN: Someone who has a slave who has enrolled a slave.
(Audio played.)
(Audio paused.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, "the machine and figure out how to duplicate it," do you know what the defendant is referring to?
LAUREN SALZMAN: A machine to do the branding and being able to duplicate the branding process.
MS. HAJJAR: When the defendant says, "there's also the issue of Cami being in that or not," do you understand what he's referring to?
LAUREN SALZMAN: Whether Cami would join the group in learning how to do a brand.
MS. HAJJAR: And this is Camila?
LAUREN SALZMAN: Yes.
(Audio played.)
(Audio paused.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, you testified about this, but SOP, was that the men's organization the defendant created?
LAUREN SALZMAN: Yes. Society of Protectors.
MS. HAJJAR: And this "different areas of people who are field operatives, informational operatives," do you know what the defendant is referring to?
LAUREN SALZMAN: I do not.
(Audio played.)
(Audio paused.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, you testified about the size of the brand. How large was your brand?
LAUREN SALZMAN: My brand is probably almost two and a half inches by three inches.
MS. HAJJAR: And were you --
LAUREN SALZMAN: There was a mistake. I was told it was supposed to be an inch by an inch. There had been a mistake, so it ended up being not only larger, but skewed from the square to a rectangle.
(Audio played.)
(Audio paused.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, when the defendant says, "She knows her master, she knows a grandmaster, which is someone up in the lineage," do you have an understanding of what that means?
LAUREN SALZMAN: That she may be told that they are grandmaster is not who it is.
MS. HAJJAR: When the defendant says, "she probably doesn't know the full lineage, it's better not to" --
LAUREN SALZMAN: That they -- that she -- that everyone may not know everyone who is involved in the entire line.
MS. HAJJAR: Did you know everyone who was involved in DOS in different lines, in other words, recruited by different first-line DOS masters?
LAUREN SALZMAN: At some point, I had access to all of them, but when I was sharing with my slaves -- like, when I let them know who each other were enrolling, I was corrected and told that they were not to know that.
(Audio played.)
(Audio paused.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, the circles the defendant is referring to, what are those referred to in the context of DOS?
LAUREN SALZMAN: A circle is your sister slave. So the women who shared the same master as you can be put in a circle of sisters.
MS. HAJJAR: And are the individuals on this recording, except for defendant, part of the same circle?
LAUREN SALZMAN: Yes, correct.
MS. HAJJAR: That's the first line of DOS?
LAUREN SALZMAN: Yes, correct.
MS. HAJJAR: And you joined that circle as the eighth member?
LAUREN SALZMAN: Yes, correct.
(Audio played.)
(Audio paused.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, when the defendant is talking about the Knox Woods Homeowners Association, do you know what he's referring to?
LAUREN SALZMAN: What he's referring to as the Homeowners Association?
MS. HAJJAR: This incident he's referring to.
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you describe it to the jury?
LAUREN SALZMAN: Yes. There was a project or an organization called Plugged In, and they wanted to put -- that Keith founded and they wanted to install these -- I think they were satellites, but also could have video cameras on -- outside some of the homes that we owned in Knox Woods and asked some of us who owned homes in Knox Woods, Keith asked, and the guys who ran Plugged in asked if we could put them up in our homes. So I had one, like, at 3 Hale Drive, and the other condo that I owned, 7 Minuteman, but the Homeowners Association complained about it and didn't want us to have them.
And so at this time, we remember Keith talking about possibly wanting us to go to the Homeowners Association meeting. He said me -- he said he might ask me to go.
MS. HAJJAR: And when the defendant says, "might be able to just vote them out," what is he referring to?
LAUREN SALZMAN: I think the Homeowners Association.
MS. HAJJAR: Do you have an understanding of what Plugged in was, the defendant's company?
LAUREN SALZMAN: Some, not really an extensive understanding of it, but there were some concepts that I understand, like, that it would be a secure network so you could be online and have your phone in some kind of secure or encrypted type of communication with the other people who are in the network and also that there was an opportunity that you could, like, be plugged in, be online at all times, always be online with other people who were online, either, like, in an ear piece or have access to them on a consistent basis.
MS. HAJJAR: Was this actually developed?
LAUREN SALZMAN: Some of it was. It was a process, I don't think they ever finalized it.
(Audio played.)
(Audio paused.)
(Continued on the following page.)
BY MS. HAJJAR (CONTINUED):
MS. HAJJAR: Ms. Salzman, is this exchange about Camila?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And her enrollment into DOS?
LAUREN SALZMAN: About her becoming part of the circle versus being separate.
MS. HAJJAR: And the -- the person who says, I think out of everyone I'm the one that has the most doubt resistance about it.
Who said that?
LAUREN SALZMAN: Loreta.
MS. HAJJAR: Are you aware of Loreta's views about Camila? Did she express them to you?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you describe them to the jury?
LAUREN SALZMAN: Loreta owned and ran Rainbow Cultural Garden which was the children's educational program and Cami was a teacher in the program and Loreta felt that whenever there was some issue or disagreement concerning Cami that Keith always took Cami's side. And that Cami wasn't held to the same level of standards or requirements as other people, and it was upsetting and difficult for Loreta.
(Audio plays.)
(Audio stops.)
MS. HAJJAR: Ms. Salzman, when the defendant says or when Monica says readiness, penitences, contract, are these all concepts you discussed in the context of DOS?
LAUREN SALZMAN: Yes.
(Audio plays.)
(Audio stops.)
MS. HAJJAR: Ms. Salzman, the defendant says, Maybe if I were a different type of master I could tell you to just suck it up, what did you understand that to mean?
LAUREN SALZMAN: That he wants a certain objective and he's trying to get them to agree that they want the objective, too, yet they don't want the objective but he wants them to want the objective and he's saying, Well, if I were a different type of master I would tell you to just suck it up, but I'm the kind of master that lets you choose, except there isn't really much of a choice because when they're saying they don't want to do it, it doesn't really stop and it starts to go into, well, it's all really hard for me. This is really hard for me and maybe I'm just not good enough as a master, you know, being the good kind of master that everybody wants is really, you know, just something that can't work. And everybody goes no, no, we want you to be bad, you know, no -- and they're saying if you want us to do it, just tell us and we'll do it, but you're asking us what we want and we don't want this.
MS. HAJJAR: So what's the objective in this context?
LAUREN SALZMAN: To get Cami into the group and into the branding class that's going to take place the following day.
(Audio plays.)
(Audio stops.)
MS. HAJJAR: Ms. Salzman, when the defendant says, There's a certain democratic process of sorts and then this is an order. This isn't is democracy, what do you think him to be referring to?
LAUREN SALZMAN: He's making a distinction between a democratic process where everybody gets to weigh in and decide together versus an order and he's saying that he's not giving the order right now but this is a democratic process, but the democratic process is a problem because they're being resistive and having problems and not being like men and just sucking it up. And if you were in the Army like a man you would just suck it up and do it because I'm expressing the want for it and I shouldn't have to give the order.
MS. HAJJAR: Your Honor, it's past 5:00. There is some more to the recording, but it might make sense to break here for the day.
THE COURT: Yeah, I think it would be worthwhile to break for the day because there's a substantial amount in this particular recording and you can start with it first thing in the morning and finish the other two recordings after that.
MS. HAJJAR: Thank you, Your Honor.
THE COURT: All right. Members of the Jury, we're going to break for the day. I'm going to remind you that it's extremely important that you follow my instructions that you not discuss this case with anyone. You know, you can sit down. I have more to say. Now come on.
Do not discuss the case with anyone, not your family, friends or business associates and not your fellow jurors. In addition, you must not read, listen to, watch or access any accounts of this case in any form of media such as newspapers, TV, radio, podcasts, the Internet or research or seek outside information about any aspect of the case. And even though I say this every day I don't want you to think this is ordinary. Each day it's important that I remind you. So I just want you to understand that this is as important as anything else that you hear or read or see in this courtroom during this trial. Because what we're trying to do here is to have a fair trial and that you not be impeded by some outside influences. So even though it's rote, it's essential and I just wanted you to know that. And I feel very strongly about it. I've been doing this over 19 years now and this is a very important part of any trial.
So do not communicate with anyone about the case on your phone, whether through e-mail, text messaging or any other means, through any blog or website or by way of any social media, including Facebook, Twitter, Instagram, YouTube or other similar sites. Do not consider anything you may have read or heard about the case outside of this courtroom, whether you read it before or during the jury selection process or during the trial and do not attempt any independent research or investigation on the case and do not visit any of the locations, again, defined on the questionnaire or discussed during the course of the jury selection process or during the trial.
So again, on behalf of the parties, I want to thank you for your attention today and every day. Have a good night's seep. We'll see you tomorrow morning at 9:30.
All rise for the jury.
(Jury exits the courtroom.)
(The following matters occurred outside the presence of the jury.)
THE COURT: All right. The witness may stand down. Please do not discuss your testimony with anyone.
(The witness exits the witness stand.)
THE COURT: All right. Everyone may be seated.
Is there anything else from the Government?
MS. HAJJAR: Not for today, thank you, Your Honor.
THE COURT: Anything from you, sir?
MR. AGNIFILO: Yes, Judge. We -- we cannot reach agreement on the admissibility of one particular exhibit which relates to pages from a journal that Camila maintained and so what we're going to do, Your Honor, is we're probably going to submit a short, we'll keep it very short, short letter brief by hand in a couple of hours. The Government --
THE COURT: All right. That's fine, I'll look at it.
MR. AGNIFILO: All right.
THE COURT: And take it up tomorrow morning if we need to.
MR. AGNIFILO: And there's one other thing.
THE COURT: You said one thing.
MR. AGNIFILO: Well, that was the first thing.
THE COURT: Oh, there are two things.
Go ahead.
MR. AGNIFILO: There's still going to be more on this sort of abortion question that we couldn't resolve, so we'll raise that as well.
MS. PENZA: So we gave 48 hours notice, Your Honor, regarding the next witness who does intend to offer testimony regarding various abortions for probative value in this case.
THE COURT: Abortions that the witness had or abortions that others had that she knew about?
MS. PENZA: Your Honor, I would rather not say on the record unless there's --
THE COURT: All right.
MS. PENZA: Until there's a ruling, so I'm happy to have a sidebar if that would be helpful.
THE COURT: No, no. Let's not do anymore on it. There's going to be a submission.
MR. AGNIFILO: Yes.
THE COURT: And then there's going to be a submission. When is your submission?
MS. PENZA: I did not know we were writing on this, but I'm happy to respond to it.
THE COURT: Well, you don't have to write on it.
MS. PENZA: No, we well but if they were not getting that until tonight.
THE COURT: Tomorrow.
MS. PENZA: We'll do it tomorrow.
THE COURT: All right. Well, we can all --
MS. PENZA: It sounds like we might -- I don't know where we're actually going to get in the next witness' direct tomorrow, so I think we can probably -- I'll speak to Mr. Agnifilo regarding how many hours he know expects with -- maybe he knows how, but I think we will probably be going into the afternoon with Ms. Salzman. And so if that's the case, then I don't think there's any need to resolve those issues until Thursday.
MR. AGNIFILO: If we go into the afternoon I don't think we'll go deep into the afternoon. I'm still thinking 3 to 4 hours.
THE COURT: All right. So you'll have your next witness ready to go tomorrow afternoon.
MS. PENZA: Yes, Your Honor.
THE COURT: All right. And we'll try to deal with the questions that are being raised in your submission sometime tomorrow.
MR. AGNIFILO: Thank you, Judge.
THE COURT: Okay. Anything further?
MS. PENZA: Not from the Government.
THE COURT: Okay. Thank you everybody.
MR. AGNIFILO: Thank you, Judge.
THE COURT: See you tomorrow.
(Matter adjourned to Wednesday, May 22, 2019 at 9:30 a.m.)
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