1.Lauren Salzman — Direct (Part 4)
244 linesTHE COURT: Let's have a sidebar here.
You may be seated in the rear.
(Continued on the next page.)
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(Sidebar ends; in open court.)
THE COURT: Appearances.
MS. PENZA: Moira Penza, Tanya Hajjar, Mark Lesko for the United States. Good morning, your Honor.
Also at counsel table are Special Agent Michael Wenniger and paralegal specialist Teri Carby.
THE COURT: Good morning.
MR. AGNIFILO: Good morning, your Honor. Marc Agnifilo, Teny Geragos, Paul DerOhannesian, Danielle Smith, and Keith Raniere, all present at counsel table.
THE COURT: Good morning. Please be seated, everyone.
I'm advised by Alternate 3 that she is ill yet again.
Is there any objection to excusing her from this trial?
MS. PENZA: No, no, your Honor.
MR. AGNIFILO: Not from us, Judge.
THE COURT: Very well. Juror Alternate No. 3 is excused from the trial.
Is there anything before we bring in the jury?
MS. HAJJAR: No, your Honor.
MR. AGNIFILO: Nothing from us.
THE COURT: Let's bring in the witness, please.
(Witness resumes the stand; jury enters.)
THE COURT: Please be seated.
Good morning, members of the jury.
(A chorus of good mornings.)
THE COURT: At this time, we're going to continue the direct examination of Lauren Salzman.
Ms. Hajjar, you may continue your direct examination.
I remind the witness that she is still under oath.
LAUREN SALZMAN, called as a witness, having been previously duly sworn, was examined and testified as follows:
DIRECT EXAMINATION BY MS. HAJJAR (Continuing):
MS. HAJJAR: Good morning, Ms. Salzman.
LAUREN SALZMAN: Good morning.
MS. HAJJAR: Ms. Salzman, yesterday you testified about e-mail sent between you and Daniella using the happymonk e-mail address.
LAUREN SALZMAN: That's correct.
MS. HAJJAR: I'm going to show you what's in evidence as Government Exhibit 908. This is Page 77 of that exhibit.
(Exhibit published to the jury.)
MS. HAJJAR: Do you recognize this e-mail, Ms. Salzman?
LAUREN SALZMAN: Yes, I do.
MS. HAJJAR: At the very top, where it says: Subject, Forward print --
LAUREN SALZMAN: Yes.
MS. HAJJAR: -- can you explain what that means?
LAUREN SALZMAN: Yes. After Dani went back to Mexico, I forwarded the e-mails that I had had with her while she was in the room to -- from an old e-mail address I was using to a new e-mail address I was using and printed them out and then kept everything that I had from that time period, Dani's letters and the e-mails we exchanged, all in a folder together. So, this was one of those.
MS. HAJJAR: These e-mails were printed and kept in one file?
LAUREN SALZMAN: Yes, I printed them and kept them in one file with the letters.
MS. HAJJAR: Your Honor, may I show something to the witness that's marked for identification?
THE COURT: Go ahead.
MS. HAJJAR: Ms. Salzman, I'm showing you what's marked for identification as Government Exhibit 1579.
Do you recognize this?
LAUREN SALZMAN: Yes I do.
MS. HAJJAR: What is it?
LAUREN SALZMAN: It's an e-mail that Kristin Keeffe sent to Dani's family and myself; subject, re final draft to Dani. And, basically, it's an e-mail that Kristin drafted that the family should send to Daniella. And she expresses that she forwarded it and that Keith and I had reviewed it. And, ultimately, her dad ended up sending it from the entire family, but it had been originally drafted by Kristin.
MS. HAJJAR: Your Honor, the Government offers Government Exhibit 1579 into evidence.
MR. AGNIFILO: We have no objection.
THE COURT: Government Exhibit 1579 is received in evidence and published.
(Government Exhibit 1579 so marked.)
(Exhibit published to the jury.)
MS. HAJJAR: Thank you, your Honor.
MS. HAJJAR: When you said the e-mail at the bottom, is that the e-mail from Kristin Keeffe?
LAUREN SALZMAN: Yes, it is.
MS. HAJJAR: Can you read that portion of the e-mail beginning with: Dear Dani?
LAUREN SALZMAN: Dear Dani, the family no longer has the heart to keep calling you out on your destructiveness and playing your games. Please sent 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 be based on a book that is 250 pages or more and must be a minimum of 10,000 words. 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.
MS. HAJJAR: And this report referred to in the e-mail, is that the book report that you've testified about?
LAUREN SALZMAN: Yes, correct.
MS. HAJJAR: And "legitimately return to Clifton Park," is that referring to Daniella's return to the NXIVM community, geographically where that is?
LAUREN SALZMAN: Correct.
MS. HAJJAR: And the "requested documents," is that a reference to the identification documents you testified to?
LAUREN SALZMAN: Yes, it is.
MS. HAJJAR: Can you read the portion of Kristin Keeffe's e-mail above "Dear Dani"?
LAUREN SALZMAN: Hi, all. Here is the final e-mail. Everyone is in agreement and has reviewed it, including L and K. I think this should come from the family.
MS. HAJJAR: And when Kristin Keeffe writes: Everyone is in agreement and has reviewed it, including L and K, who are "L and K"?
LAUREN SALZMAN: Lauren and Keith, myself and Keith.
MS. HAJJAR: Kristin Keeffe writes: I think this should come from the family.
Did you testify about a version of this e-mail that was, in fact, sent by one of the family members?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: And above that, can you read the e-mail that is in response to the e-mail we just discussed?
LAUREN SALZMAN: Marianna responded: Perhaps we should send it from Dad's account and sign Dad, Marvi, Hector, and Cami, question mark.
MS. HAJJAR: And then Kristin Keeffe's response to that?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What's the date of the e-mail chain?
LAUREN SALZMAN: February 29, 2012.
MS. HAJJAR: And Hector that's in the cc line, that's Daniella's father?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And Camilla is her sister?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Who is Fluffito?
LAUREN SALZMAN: Fluffito is Adrian, her brother.
MS. HAJJAR: Your Honor, at this time I'd like to continue to play the recording, Exhibit 495, and direct the jury's attention to 495-T. I believe where we left off was around Page 36, Line 38 or thereabouts. Maybe that's a little bit before, but we'll start there, if that's all right with your Honor.
THE COURT: What page are we on again?
MS. HAJJAR: 36, your Honor, I believe.
THE COURT: All right.
(Audio plays; audio stops.)
MS. HAJJAR: Ms. Salzman, when the Defendant said, Ideally, you should video what he does and everything so you can teach it, Lines 28, 29 on Page 43, do you know who "he" is, who that's referring to?
LAUREN SALZMAN: There was, like, a tattoo artist who did branding and scarification that they brought into teach them how to do branding.
MS. HAJJAR: Was that -- that person, was he involved after the first line?
In other words, was he involved in your branding or the branding of your slaves?
(Audio plays; audio stops.)
MS. HAJJAR: Ms. Salzman, do you know what the Defendant is referring to when he says, Line 40 to 45 on Page 44: Talking about the questionnaire thing, how's that coming?
Level one, level two, level -- how many levels?
LAUREN SALZMAN: That's a game.
MS. HAJJAR: Can you explain that further?
LAUREN SALZMAN: That the idea was to be able to have these different questionnaires to gather information on different -- various people in a variety of different subjects. But to say, like, Do you want to play a game? And if you want to play the game, I can dare you to do things. And some of those things might be to provide information or questionnaires and that you can ascend through a series of levels in a relatively short amount of time and, ultimately, get to a place where you're collateralized in a life vow.
So, it was a type of screening process and information gathering for the slaves or for prospects.
MS. HAJJAR: And on Line 43, when it says, It's ready for you to go over, who said that?
LAUREN SALZMAN: Nicki.
MS. HAJJAR: And "for you to go over," is that referring to the questionnaire?
LAUREN SALZMAN: I believe so, yes.
MS. HAJJAR: Have you seen a physical copy of the questionnaire at any point?
LAUREN SALZMAN: At least part of one, yes.
MS. HAJJAR: In the context of DOS?
LAUREN SALZMAN: Yes.
(Audio plays; audio stops.)
MS. HAJJAR: At this point, your Honor, I'd like to play Government Exhibit 496 and direct the jury's attention to 496-T.
THE COURT: All right.
(Audio plays; audio stops.)
MS. HAJJAR: Ms. Salzman, the date that's stated on this recording, what is that date?
LAUREN SALZMAN: June 12, 2016.
MS. HAJJAR: And is it Nicki Clyne that says: The first step is possibly send them a note that says, Do you want to play a game?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And is this the same game that you were referring to earlier in your testimony?
LAUREN SALZMAN: Yes.
(Audio plays; audio stops.)
MS. HAJJAR: Ms. Salzman, when the Defendant says, You guys are not thinking about this in an organized, directed fashion. You can rent my brain to do it or you can do it with your brain. I would prefer that you do it with your brain.
Is that similar to comments you've experienced in your relationship with the Defendant?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: Where he would have some idea but he would want us to go and develop the idea, and if we came back with an ill-formed concept or an idea that was different, he would frequently say things like, I don't think you're really thinking about it enough.
I can think of at least one example of a time where I said, Well, I spent ten hours on this.
And he said, Well, then, you should have spent 100.
So, somehow if we need more help or more direction or we're not coming up with the right idea, that it was our laziness or failure or ineptitude, it would progress to making it very difficult for him because of those things.
It's hard to sometimes figure out what the specific thing was that he wanted and the ideas that we would present. Like in the example with some of the e-mails with Dani yesterday, he would say, Well, you think about.
I would come back with what I think about, and he would come back with, Or don't do it.
So, it was clear he had something he wanted. But if we weren't coming up with it and coming up with it ourselves, then that was the wrong answer.
(Continued on the following page.)
(Audio played.) (Audio stopped.)
EXAMINATION CONTINUES BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, when the defendant, on line 33, says: How quickly can someone become a lifer, do you understand what he means by lifer?
LAUREN SALZMAN: Somebody, yeah, who's fully collateralized in the life of obedience.
MS. HAJJAR: In DOS?
LAUREN SALZMAN: In DOS.
(Audio played.) (Audio stopped.)
MS. HAJJAR: Do you understand what that means, Ms. Salzman, when the defendant says -- this is line 14 on page 7: A lifer is willing to do anything worth a dare?
LAUREN SALZMAN: Yeah, well, a lifer is committed to being a lifetime vow of obedience to do whatever is asked. So it's anything.
(Audio played.) (Audio stopped.)
MS. HAJJAR: Ms. Salzman, on line 34 of page 7, when the defendant mentions Sylvie, was Sylvie a DOS slave to your knowledge?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Whose master was she under?
LAUREN SALZMAN: I believe Monica Duran.
(Audio played.) (Audio stopped.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, when Daniella Padilla says, on line 4: With joining like the whole thing; do you know what she's referring to?
LAUREN SALZMAN: I think she's referring to the circle and being involved in the collateralized life out under Keith in a circle with the other women who also were in the same position.
MS. HAJJAR: And who is being referred to in this exchange?
LAUREN SALZMAN: Camila.
MS. HAJJAR: And what follows when the defendant says: Talk to her in a way that explains there's reservations with different people here.
Can you explain this exchange?
LAUREN SALZMAN: I think it's -- it's asking Daniella to go address the fact with Cami that her relationships between all the women in the circle, some of the women who were in the circle had reservations with her joining the group because their relationship had issues in them, and they haven't grown to the point where that isn't so yet, and to see where Cami is at with it. But ultimately, the intent is Cami is going to be in the circle and how to get her from Point A to Point B in the group from where they -- from Point A to Point B of being okay with it; getting Cami okay with it, getting the group okay with it and making it happen.
MS. HAJJAR: What do you understand the defendant to be asking here?
LAUREN SALZMAN: Daniella to go talk to Cami about it, so that whatever the issues are, they can be resolved so she can be in the group.
(Audio played.) (Audio stopped.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, do you have an understanding as to what's being discussed here?
LAUREN SALZMAN: They're discussing that they're gonna learn to do the branding process, and then just making jokes about if they're doing it at Loretta's house, her mom or sister could walk in.
(Audio played.) (Audio stopped.)
MS. HAJJAR: Ms. Salzman, when the defendant says, lines 21-22: Like even having the organization is something that could be really important. I imagine, for example, we could change the presidential vote in the United States in four years.
Do you have an understanding as to what the defendant is referring to by "organization"?
LAUREN SALZMAN: DOS.
(Audio played.) (Audio stopped.)
MS. HAJJAR: Ms. Salzman, on line 30, when the defendant refers to "they're," how many are there that are like on the fence, do you have an understanding of what is being referred to there?
LAUREN SALZMAN: How many women they're trying to enroll that haven't decided to join or take -- or become collateralized in a lifetime vow of obedience.
MS. HAJJAR: So on the fence , meaning on the fence about joining DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Who is Ceci?
LAUREN SALZMAN: Ceci is someone that Loretta was enrolling.
MS. HAJJAR: Was she in DOS?
LAUREN SALZMAN: Yes. I don't know if she was ever totally fully collateralized, but she was.
(Audio played.) (Audio stopped.)
BY MS. HAJJAR:
MS. HAJJAR: Do you have an understanding of what the defendant means, on line 45-46: She's a good one to do because she's powerful?
LAUREN SALZMAN: Because she's related to someone who used to be president of a country.
(Audio played.) (Audio stopped.)
MS. HAJJAR: Ms. Salzman, who is saying: For her to give me strong collateral, I basically have to go to Mexico to sign something.
LAUREN SALZMAN: Rosa Laura.
MS. HAJJAR: And do you know what she's referring to?
LAUREN SALZMAN: That probably she needs to sign some paperwork for Ana to be able to legitimately transfer some material property or business or something like that, an asset.
MS. HAJJAR: And is that strong collateral, is that what's meant by strong collateral?
LAUREN SALZMAN: Yes.
(Audio played.) (Audio stopped.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, between lines 21 and 25 of this page, page 14, when the defendant says: And you have the assignment with respect to the crafts and the circles, and the people that are in now, do you have an understanding of what he is referring to?
LAUREN SALZMAN: Well, whatever he assigned them to do with respect to organizing the crafts and the circles, which I think we've talked about in the prior tape that we listened to -- or that we heard in the prior tape, that they were to come up with the various crafts and organize how a circle would work and what the numbers were of people who could participate in them.
(Audio played.) (Audio stopped.)
MS. HAJJAR: Your Honor, I would like to play the last recording, Government Exhibit 497, and direct the jury's attention to the transcript.
THE COURT: All right.
(Audio played.) (Audio stopped.)
MS. HAJJAR: Ms. Salzman, who are the voices on this recording?
LAUREN SALZMAN: Allison Mack and Keith.
MS. HAJJAR: And what's being discussed?
LAUREN SALZMAN: They're discussing the branding ceremony.
MS. HAJJAR: And what's the date that's said on this recording?
LAUREN SALZMAN: It says January 9th, I'm not sure what year that is.
MS. HAJJAR: When were you branded?
LAUREN SALZMAN: I was born -- I was branded on January 10th, 2017.
MS. HAJJAR: And when the defendant says each of the seven strokes having a certain ritualization, do you have an understanding what he's referring to?
LAUREN SALZMAN: Yeah, there are seven lines in the brand. So doing some sort of ritual where after each line something is done, which ended up being what the branding ceremony became.
(Audio played.) (Audio stopped.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, when the defendant says, page 4, line 1: The person should be branded -- should be completely nude, was that true of your DOS slaves and other DOS slaves?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And when the defendant says: You guys did it and you weren't completely nude because you had an outsider; do you have an understanding of what he's referring to there?
LAUREN SALZMAN: Yes, that the first line was branded by another person, like the guy who taught them to do the branding or the guy they hired to do the branding and wasn't a part of DOS, so that they were clothed, but if it were somebody who was an insider, they would not have.
(Audio played.) (Audio stopped.)
MS. HAJJAR: Ms. Salzman, directing you to line 9 through 11 of page 4, when the defendant says: You could also, of course, videoing it and videoing it from different angles or whatever gives collateral.
What do you understand him to be saying?
LAUREN SALZMAN: Videoing the naked branding ceremony could be used as collateral.
MS. HAJJAR: And were the branding ceremonies all videotaped?
LAUREN SALZMAN: Yes, they were.
(Audio played.) (Audio stopped.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, lines 20 through 25 on page 4, when the defendant says: Laying on the back, legs slightly or legs spread straight like, like feet being held to the side of the table; was that the position you were in when you were branded?
LAUREN SALZMAN: Yes, it was.
MS. HAJJAR: And what about for your DOS slaves?
LAUREN SALZMAN: All of them, yes.
MS. HAJJAR: When the defendant says: Hands probably above the head being held, almost like being tied down, like sacrificial whatever; was that the position you were in with your hands above your head?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And what about your DOS slaves?
LAUREN SALZMAN: The same.
(Audio played.) (Audio stopped.)
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, when the defendant says, between lines 29 and 37: And the person should ask to be branded, who is the person he's referring to?
LAUREN SALZMAN: The person being branded.
MS. HAJJAR: The DOS slave?
LAUREN SALZMAN: The DOS slave.
MS. HAJJAR: And when the defendant says: Please brand me, it would be an honor -- it should say: Please brand me, it would be an honor, or something like that, an honor I want to wear for the rest of my life; are those words familiar to you?
LAUREN SALZMAN: Yes, those were the words we were instructed to say before our branding ceremony, and all the slaves were instructed to say that.
MS. HAJJAR: Is that what you said before your brand?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And is that what your DOS slave said to you?
LAUREN SALZMAN: Yes.
(Audio played.) (Audio stopped.)
MS. HAJJAR: Ms. Salzman, when the defendant says on line 41: And they should probably say that before they're held down, so it doesn't seem like they are being coerced; did the DOS slaves say, Master, please brand me, before they were held down and branded?
LAUREN SALZMAN: Yes, they did.
MS. HAJJAR: And what do you understand the defendant to mean when he says: So it doesn't seem like they're being coerced?
MR. AGNIFILO: I am going to object to that, Your Honor.
THE COURT: Sustained.
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, you testified earlier about edits that were made to Sarah's branding video?
LAUREN SALZMAN: Correct, yes.
MS. HAJJAR: You testified that certain areas of dialogue were cut out?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And you testified one was kept in?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What was the one that was kept in?
LAUREN SALZMAN: Master, please brand me, it would be an honor, an honor I want to wear for the rest of my life.
(Audio played.) (Audio stopped.)
MS. HAJJAR: Ms. Salzman, the last -- those last lines, lines 11 through 16 and 20 through 23, when the defendant says: Although my body may be burned or tortured or whatever, my love is stronger and it is the love of purest beings to walk the earth that are able to hold love even above life itself.
Are those words familiar to you?
LAUREN SALZMAN: Yes, those words were incorporated into the branding ceremony.
MS. HAJJAR: Did you say those words when you were being branded?
LAUREN SALZMAN: They were said to me and I had a response to them.
MS. HAJJAR: What about for your DOS slaves?
LAUREN SALZMAN: Same thing.
MS. HAJJAR: So even though the defendant says you guys figure it out, these were verbatim incorporated into the branding ceremony?
LAUREN SALZMAN: Yes, everything was said -- on this walk was incorporated into the branding ceremony, including verbatim these words.
MS. HAJJAR: No further questions, Your Honor.
THE COURT: All right, please collect the books.
(Pause.)
THE COURT: Cross-examination.
MR. AGNIFILO: Thank you, Judge.