2.Lauren Salzman — Cross (Part 5)
2,263 linesCROSS-EXAMINATION BY MR. AGNIFILO:
MR. AGNIFILO: Good morning, Ms. Salzman.
LAUREN SALZMAN: Good morning.
MR. AGNIFILO: We've met before?
LAUREN SALZMAN: Yes, we have.
MR. AGNIFILO: I want to introduce myself anyway. My name is Marc Agnifilo, I represent Keith Raniere. I am going to ask you some questions today. If I ask you a question that you don't understand, please tell me that. And if you would like me to rephrase it or ask a different question, I'm happy to do that.
Now, you said in the beginning of your direct examination that Keith Raniere was the most important person to you?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You said he was your mentor?
LAUREN SALZMAN: Yes, he was.
MR. AGNIFILO: You said he was your teacher?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You and he had a romantic relationship?
LAUREN SALZMAN: Yes, we did.
MR. AGNIFILO: And you loved him?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And he loved you?
MS. HAJJAR: Objection, Your Honor.
BY MR. AGNIFILO:
MR. AGNIFILO: Did he ever tell you -- I'll ask it -- did he tell you that he loved you?
LAUREN SALZMAN: He has told me that.
MR. AGNIFILO: You wanted to have children with him?
LAUREN SALZMAN: I did, yes.
MR. AGNIFILO: You once wanted to share your life with him?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Now, Ms. Hajjar asked you whether your relationship with Keith has ended.
Do you remember her asking that question?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And your answer was: For me.
Do you remember giving that answer?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Can you explain that answer?
LAUREN SALZMAN: Well, I had hoped at one point in time I would be able to speak to Keith about the ending of our relationship, but that was not possible through this process, and so I was just communicating where I was at. He and I have not discussed where he's at or anything beyond that.
MR. AGNIFILO: Okay. Now, you and Keith had a life commitment, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And there is no indication from Keith that that's been broken?
LAUREN SALZMAN: You could say that, yes.
MR. AGNIFILO: Now, I think you said your first impression of Keith, when you first met him, was that he was a little strange.
Do you remember saying that?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Okay, what was strange about him?
LAUREN SALZMAN: I think Keith is kind of unconventional and unusual, umm...
MR. AGNIFILO: And -- I'm sorry, if you have more to say, just do it.
Then do you remember how old were you when you first met Keith?
LAUREN SALZMAN: Twenty-one.
MR. AGNIFILO: And do you remember the first time you actually met him?
LAUREN SALZMAN: I believe so, yes.
MR. AGNIFILO: Just tell us about that.
LAUREN SALZMAN: I believe that I met him at National Health Network. I was home on a -- either leaving for or coming home from a ski trip with a boyfriend and we just stopped in and said hi to Keith and Toni and my mom was there.
MR. AGNIFILO: Toni being Toni Natale?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: All right. Now, at this point, you said on direct examination that your mother worked at a nuclear power plant?
LAUREN SALZMAN: Yes, she was at Con Edison.
MR. AGNIFILO: And was she working with Keith at Con Edison?
LAUREN SALZMAN: Was she -- I'm sorry?
MR. AGNIFILO: You said -- let me ask a different question.
You said on direct examination that there was something going on at the nuclear power plant and your mother was calling Keith?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Okay, just tell us what was happening.
LAUREN SALZMAN: As I understood, he was helping advise her on how to do whatever work she was doing at the nuclear power plant.
MR. AGNIFILO: And do you know what work that was?
LAUREN SALZMAN: I know that they were going through a deregulation at the time and somehow she was doing some organizational development work with them.
MR. AGNIFILO: And so -- your mother admired Keith, you knew that your mother admired Keith when you first met Keith?
LAUREN SALZMAN: Yes, I did.
MR. AGNIFILO: And when you -- at one point, you were backpacking through Europe, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And then you returned back to where you were living in the Albany area?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: And did you have a lot of friends at that point in your life or were you spending more time by yourself?
LAUREN SALZMAN: I had some friends from college and some from high school, but I was spending a lot of time by myself.
MR. AGNIFILO: Okay. And would Keith come and check on you from time to time?
LAUREN SALZMAN: Yes, he would.
MR. AGNIFILO: Okay. And just tell us about that.
LAUREN SALZMAN: He would call and check in and see how I was doing.
MR. AGNIFILO: And at this point in time, what was the nature of your relationship with Keith?
LAUREN SALZMAN: He was my mother's friend and business partner, and he had started a school with her, and I was taking classes in that school.
MR. AGNIFILO: And that school was?
LAUREN SALZMAN: ESP, Executive Success Programs.
MR. AGNIFILO: And was the name NXIVM used yet at this point?
LAUREN SALZMAN: No, not at that point.
MR. AGNIFILO: So it was just Executive Success Programs?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And your mother Nancy and Keith started this, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And did they start it while you were in Europe?
LAUREN SALZMAN: Yes, I believe the idea for it was started while I was in Europe, and I called home and my mother told me they were going start a school.
(Continued on the following page.)
CROSS EXAMINATION BY MR. AGNIFILO: (Continuing)
MR. AGNIFILO: And it was a school, that was your understanding?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Okay. And in the earliest, earliest sort of conception of ESP, what did it do exactly?
LAUREN SALZMAN: We had weekly classes that Keith taught and it was a goal-setting program. Everybody got a coach and they could sign up for a membership like three months, six months or a year and take as many as classes during the week as they wanted and there were -- Keith usually ran two classes a week, but there would be two sessions of each class, so they could come to as many as they wanted.
MR. AGNIFILO: And you were living with your parents at the time; correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: At some point --
LAUREN SALZMAN: With my mother.
MR. AGNIFILO: With your mother. And at some point did Keith sort of cause you, inspire you to move somewhere else, to leave where you were living?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Just tell us a little bit about that.
LAUREN SALZMAN: He told me that a friend of mine, Jory, had moved out and started asking me when I was going to move out, and also I think he inspired my mom to, you know, start charging me rent in the house and help me to understand things come from somewhere and somebody's providing that and help me learn to provide that for myself.
MR. AGNIFILO: And did you have any feelings over the fact that Keith inspired your mother to charge you rent for living at home?
LAUREN SALZMAN: Well, at first, I, yeah, I didn't like that, but then I came to understand that -- it helped me understand what it would take to be self reliant.
MR. AGNIFILO: Now, at the time this was happening, when you moved out of the house with your mom, Keith was living at 3 Flintlock?
LAUREN SALZMAN: Yes, he was.
MR. AGNIFILO: And he was living with Pam Cafritz? You have to answer yes or no.
LAUREN SALZMAN: Yes, he was.
MR. AGNIFILO: Karen?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And Kristin Keeffe?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: So Keith was living with three women at the time?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And did you know or did you understand or believe that Keith had an intimate relationship with each of the three women at the time?
LAUREN SALZMAN: I came to over time, yes.
MR. AGNIFILO: You didn't know that right off the bat?
LAUREN SALZMAN: No, not initially.
MR. AGNIFILO: Did you notice there being tension at times between Pam Cafritz and Karen Unterreiner over Keith's attention?
LAUREN SALZMAN: Yes, I don't know when I came to know that, but, yes, I did at some point.
MR. AGNIFILO: You were asked on direct examination about Pam Fritz and your answer was she was Keith's closest person. Do you remember that question --
LAUREN SALZMAN: I believe she was. Yes.
MR. AGNIFILO: Just tell us a little bit about that.
LAUREN SALZMAN: Hum, she was the person who was around Keith the most and who he would bring with him to other meetings he had, even visiting other relationships that he had that she was supportive of and she befriended most of the women that he was in relationships with.
Pam was in some ways the earliest person to get along with of the bunch and I think that she helped build a type of rapport, so that was helpful to him. So he allowed her to be around him a lot and she wasn't disruptive in that way to whatever he was doing.
MR. AGNIFILO: Okay. And did you grow to have a relationship with Pam yourself?
LAUREN SALZMAN: Yes, I did.
MR. AGNIFILO: Just tell us a little bit about that.
LAUREN SALZMAN: Hum, Pam in some ways also was a mentor, an advisor to me. She was a close personal friend. We had an intimate and sexual relationship for some period of time.
I loved Pam very much. She was one of the closer friends I've had in my life.
MR. AGNIFILO: And it was a difficult time? You testified on direct that a period of time she became ill and it became apparent that she was going to pass away; is that right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: When did she become ill? Do you remember about?
LAUREN SALZMAN: It was about two years before she passed away. She actually, though -- I think she was an ill a little bit before that, but we didn't come to know it immediately. So, sometime maybe in 2014.
MR. AGNIFILO: Okay. Now, Karen Unterreiner, that was another person that Keith was living with way back in the beginning when you moved out from your mom's house?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Did you have an understanding that Keith and Karen Unterreiner had been together since he was in college?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And at Rensselaer Poly Technic Institute?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Keith had a very long term relationship with Karen Unterreiner as well?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Now, Kristin Keeffe, that was the third person that Keith was living with at the time?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: How well did you come to know Kristin?
LAUREN SALZMAN: Not as well as the others, but more or less I came to know Kristin.
MR. AGNIFILO: Now, in addition to living with Pam Cafritz and Karen Unterreiner and Kristin Keeffe, Keith was close with other women in the community, fair to say?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: One of them was Barbara Bouchey; is that right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Another was Barbara Jeske; is that right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Another was Donna Morrison?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: I think you mentioned this on direct examination. At one point prior to Pam Cafritz passing away, Barbara Jeske passed away?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Do you remember about when that was?
LAUREN SALZMAN: I'm not sure if it was 2014 or 2015, but before Pam.
MR. AGNIFILO: And at the time that Barbara Jeske passed away in 2014, 2015, you had an understanding that Keith and Barbara Jeske still together?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: At the time that Pam Cafritz passed away a few years later, you had an understanding that Keith and Pam Cafritz were still together?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: At some point, tell me if this is right, you started developing feelings, romantic feelings for Keith?
LAUREN SALZMAN: Yes, that's correct.
MR. AGNIFILO: At about 2000?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And at the time that you started to develop these feelings for Keith, how long had you known him? When did you first meet him in relation to when you first started to develop these feelings?
LAUREN SALZMAN: About a year.
MR. AGNIFILO: About a year?
LAUREN SALZMAN: Uh-hum.
MR. AGNIFILO: Okay. And what kind of time were you and Keith spending together during the year before you realized you had some feelings for him?
LAUREN SALZMAN: I can't recall specifically, but it's going to classes with him for a period of time, and I would spend social time with him. He and I would go for walks and I was invited to hang out at 3 Flintlock, so we were spending time together. He would come over to my mom's house while I was living there.
MR. AGNIFILO: And at some point did you see or conclude that he had feelings for you as well?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And I think you said that the first time that you had an intimate contact with Keith was April 1, 2001; is that right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And this was completely consensual on your part, am I right?
LAUREN SALZMAN: Yes, it was.
MR. AGNIFILO: You liked him? You wanted to be this way with him?
LAUREN SALZMAN: Yes, I did.
MR. AGNIFILO: Now, did you have concerns at the time, back in April of 2001, when you were starting to get involved with Keith, about his lifestyle, the fact that he was living with three women, that he seemed to be close with other women? Did any of that concern you?
LAUREN SALZMAN: Yes. Some of the things about it. It was difficult. I mean, I felt insecure, you know, but I also at that time believed that Keith's relationships were very selective and special, you know, and it was a small group of people that he was choosing to have them with, and, so I felt special to be part of that.
MR. AGNIFILO: And did you understand that there were certain rules, for lack of better word, that Keith had for people that he was in a relationship with?
LAUREN SALZMAN: Yes, that they not have relationships with other people.
MR. AGNIFILO: And tell me if this is right: One of them was that his partner would have to be honest and transparent?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Second is that his partners had to be monogamous and committed to him?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Third is that the partners had to inform Keith before leaving the relationship; correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: But one of the rules wasn't that Keith had to be monogamous in return?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And tell me if this is right, that was sort of the understanding going in, am I right?
LAUREN SALZMAN: That was the understanding go in, yes.
MR. AGNIFILO: So you knew when you started a relationship with Keith he was then expecting you to be fully committed, monogamous with him, but he wasn't planning to be monogamous with you or any of the other women he was with?
LAUREN SALZMAN: That's true.
MR. AGNIFILO: Can I ask you why did you choose to pursue this relationship with Keith given what you knew about him and what his conditions were?
LAUREN SALZMAN: Because I believed that Keith had a world view and a certain set of values and principles that were in line with things that I really admired and wanted to be like, wanted to have and uphold in my life and that relating with him and having him in my life would help me do that better.
MR. AGNIFILO: And what were those principles that you were admiring?
LAUREN SALZMAN: That he was humanitarian, that he had this vision for how we could all be, the word we used was interdependent but worked as a team as kind of a collective humanity and learned to be compassionate and care for each other and support each other in non-violent ways with ethics, and I wanted that.
MR. AGNIFILO: And how was it that you were able to see that?
LAUREN SALZMAN: Mostly through the teachings, the curriculums that he put out, my interactions with those, and how he would advise me in my life and with some of the struggles I had.
MR. AGNIFILO: And I think what you said on direct examination is that and Keith were in an intimate relationship between 2001 and about 2008 or 4th?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: During that period of time, was he ever inappropriately aggressive sexually with you?
LAUREN SALZMAN: In a situation with Dawn that I recounted earlier, I felt that was an example.
MR. AGNIFILO: Okay. And is that the one where he was sort of trying to pull your pants down?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And tell me if this is right. So you were with Keith and Dawn Morrison; right?
LAUREN SALZMAN: Uh-hum.
MR. AGNIFILO: Do you remember where you were?
LAUREN SALZMAN: In Flintlock 3.
MR. AGNIFILO: And you were clothed? You had pants on?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And Keith was trying to pull your pants down; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you didn't want to do that?
LAUREN SALZMAN: Uh-hum.
MR. AGNIFILO: Right? And you told him to stop; right?
LAUREN SALZMAN: A number of times, but he -- yes.
MR. AGNIFILO: And then --
LAUREN SALZMAN: Uh-hum.
MR. AGNIFILO: You told a number of times and he stopped?
LAUREN SALZMAN: Yes, he did.
MR. AGNIFILO: Other than that occasion which you told us about, was there ever any other time that he was inappropriately aggressive with you sexually or any other way?
LAUREN SALZMAN: It depends on what you mean by aggressive. But the general view of having emotional reactions or having emotions in reaction to actions or behaviors by other people was viewed as giving us an opportunity to work our issues. So there would be often situations that I would be in with Keith, usually with a lot of women around, and he would do things like touching each other's vaginas or stroking their breasts and doing these things very publicly among the group, you know, that were very uncomfortable and might be seen as a certain type of aggressiveness, but it was viewed as the reactions that we were having to them were things we needed to get through, so we stayed and participated in things that in any other circumstance we wouldn't have.
MR. AGNIFILO: Did you ever express to Keith at any point, other than the Dawn Morrison situation that we talked about, that there was something that he was asking of you or encouraging you to do of a sexual nature that you didn't want to do?
LAUREN SALZMAN: Well, I did communicate with him when different women would approach me to have group sex with him that that wasn't something that I wanted to do and especially when we stopped having a sexual relationship, why that was particularly upsetting to me. I did communicate that.
MR. AGNIFILO: So on a few indications -- let me make sure I have this right. There were occasions where you had sexual contact with Keith and another woman where you wanted to do that?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And then there were occasions where you just said women would approach you to possibly have sexual contact with you and Keith where you didn't want to do it?
LAUREN SALZMAN: And there were occasions where I went along with having sexual experiences with women with Keith that I didn't want to, but I did it anyway and didn't communicate overtly about it. I just emotionally expressed that I was not happy and then I would get feedback about my suffering.
MR. AGNIFILO: Okay. So you would tell Keith something along the lines of I really didn't want to do that or something like that?
LAUREN SALZMAN: I would act unhappy in the circumstance, but I would go through it anyway.
MR. AGNIFILO: Okay. Did you ever tell him, even after the fact, I didn't want to do that or I don't ever want to do that again or anything along those lines?
LAUREN SALZMAN: No, I didn't feel able to communicate that.
MR. AGNIFILO: I understand.
THE COURT: I'm sorry, what was that?
LAUREN SALZMAN: I didn't feel able to communicate that.
THE COURT: Why?
LAUREN SALZMAN: I didn't want him to be displeased with me.
MR. AGNIFILO: Putting the issue of sex and intimacy aside for a second, was he ever aggressive with you in any other way? I mean, did he ever yell at you, anything like that?
LAUREN SALZMAN: Yes, he has yelled at me.
MR. AGNIFILO: Okay. Has he ever touched you in a hurtful way, you know, anything, hit you, kicked you, slapped you?
LAUREN SALZMAN: Accidentally, not on purpose.
MR. AGNIFILO: The times when he would yell at you, would it be about something -- well, give me a few examples, if you can remember, of times that he would yell at you?
LAUREN SALZMAN: He would say that I was having -- you know, that a temper tantrum or my behavior was difficult for him and he wasn't going to talk to me about things if I was going to be like this.
One time he kicked me out of the house until I came back and apologized for my behavior, but generally it would take place in situations where I would express upset or frustration over the things that were going on with us or our relationship or the circumstances around us.
MR. AGNIFILO: And fair to say it wasn't easy being in a relationship with Keith, in part, because he had these other romantic interests?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And there were times when you didn't think you wanted to put up with that?
LAUREN SALZMAN: Yes. And, also, I mean, there were times we weren't relating, so I didn't feel like we were in a relationship because we weren't even interacting for years.
MR. AGNIFILO: Right. So I think after 2008 or 2009 your intimate relationship started to wane; correct?
LAUREN SALZMAN: Correct. And he told me he put it on hold.
MR. AGNIFILO: I think what you said on direct examination is after the fact he said he put your relationship with you on hold?
LAUREN SALZMAN: Yes. Then later he said he didn't see it that way, but he hadn't re-initiated.
MR. AGNIFILO: Right. And for the time after your intimate relationship with Keith had waned, when it had stopped or slowed down a lot --
LAUREN SALZMAN: Yes.
MR. AGNIFILO: -- you were aware he was still having intimate relations with other people?
LAUREN SALZMAN: Yes, I was.
MR. AGNIFILO: And that was hurtful?
LAUREN SALZMAN: It was painful.
MR. AGNIFILO: I think you said on direct examination that Keith was highly respected, highly regarded in your community?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And he was viewed as an authority on different topics?
LAUREN SALZMAN: Yes. And I think in large part because we had relationships with a lot of those people in the community and we edified him and the teachings and, so, he became highly regarded as well through what we were saying, to confer that on him where he didn't have relationships with a lot of those people.
MR. AGNIFILO: He didn't have relationships?
LAUREN SALZMAN: With a lot of those people directly.
MR. AGNIFILO: So people would say things about him. Fair to say it was almost like a myth around Keith?
LAUREN SALZMAN: To a degree, yeah.
MR. AGNIFILO: People said he could affect the weather?
LAUREN SALZMAN: Yes. He said he could, or these things happened around him and he could never explain them.
MR. AGNIFILO: Right. He told you the time he was with Toni Natalie, right? Am I having the story right, and it was raining?
LAUREN SALZMAN: I didn't know it was Toni Natalie. I heard the story with the rain.
MR. AGNIFILO: And it was raining on Tony and not on Keith, this is the story that he told?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And did he -- did he say it like as an interesting kind of quirky thing or did he -- was he conveying to you that because of some great force he wasn't being rained on?
LAUREN SALZMAN: I believe it was the latter, that there were these things that happened to him that he couldn't account for and that there was something really unique or special about him that that happened, therefore, we should really take seriously -- like the way he was saying it to me it wasn't raining on her because it -- I mean, it wasn't raining on him and it was raining on her because somehow her behavior, conduct was out of line and she wasn't listening to what he was saying and that what he was saying was so pertinent and so important, that it's not even raining on me, look, this is how you can believe what I'm saying, that what I'm conveying is so -- of such importance that -- and who I am is so different.
MR. AGNIFILO: You've seen it rain on him? He gets rained on like everybody else?
LAUREN SALZMAN: Of course.
MR. AGNIFILO: Now, I'm going to show you what has been marked in evidence as 362.
MR. AGNIFILO: This is already in evidence. I am going to put it up on the ELMO, if I could, Judge.
MR. AGNIFILO: Can you see that okay?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: All right. And I think that the way that the Government made this is it kind of goes from older relationships starting with Ms. Cafritz around to sort of newer relationships ending with Mr. Levy; is that right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: I think we already covered here that Pam Cafritz was in over a 30-year relationship with Keith Raniere?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Passed away in November of 2016?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Barbara Jeske involved even in a longer relationship than he was with Pam; right?
LAUREN SALZMAN: Yes. There were long periods of some of the relationships where they weren't active relationships but the women never left and he never ended the relationship or they tried to leave and he didn't want them to and ask specific individuals, like myself or my mom, to go in and intercede to help them to make the decision to stay.
MR. AGNIFILO: You've witnessed yourself, and I think this is what you're referring to, the fact that Keith seemed very afraid to have women leave him. Does that seem right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Just describe that for the jury.
LAUREN SALZMAN: He didn't ever want anybody leaving. I mean, he wouldn't end of the relationships even when they were over. And even -- I mean, to the extent that some of the women were having real emotional and addictive problems that were potentially life threatening, he wouldn't end the relationship to allow them to move on or to attend to that in a different way outside of those circumstances, which were very present for the reason that the person was struggling.
MR. AGNIFILO: All right. And so from what you were able to see --
LAUREN SALZMAN: I mean, he got us all to collateralize life vows to never leave no matter what.
MR. AGNIFILO: Right. I'm working in that direction.
LAUREN SALZMAN: Yeah.
MR. AGNIFILO: So never left Pam? Was with her until the day she died; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Barbara Jeske was with her until --
LAUREN SALZMAN: I have issues with the term with her. He didn't end the relationships.
MR. AGNIFILO: So when you say you have problems with regard to her, go ahead, tell us what you mean.
LAUREN SALZMAN: I mean that, and I have discussed this with Keith but, you know, in the last years of Barbara's life he wasn't interacting with her very much and in the time she was sick he didn't go to visit her almost at all.
So when you say with her, he never formally ended the relationship, but he wasn't actively participating in the relationship and those were things that I expressed to him and even concerns that I had because I observed the -- I observed Barbara, who wanted to have a child at one point in time, Pam as well, Karen too, where he said we are, we are, we are, and made a number of promises and those years passed by. And when -- at least a few of the women became past their fertile years, you know, he was like, oh, he had somehow misgauged this, or whatever, and I would express this to him on an ongoing basis, that I don't want our relationship to be like that, to not make me promises if he's not going to do that, that I saw this happen with other women. And even that I related more with Barbara and the way that he related with Barbara and that my concern was that we were going to have this relationship that was not active and in the end I would die alone, that he wouldn't come visit me either.
And, so, he was with them in that he never formally said I don't want to be in this relationship anymore. He wanted them to stay loyal and monogamous with him, but he wanted to be able to not have to invest further in the relationship and just go do other things that he wanted to do while they were still there waiting, hoping that it would change and feeling very feel emotional things or having issues with it, that he would, in my experience, not empathetic to and that he felt that they were -- they could just learn to be joyful and they should be able to just get over those issues and be happy no matter what the circumstance was.
And in some cases that he thought it was better for them to stay with him because if they left and had a relationship with someone else that relationship for some other reason would be very damaging or destructive to them, but that you could never compare it because they never did.
MR. AGNIFILO: Did he seem to really believe that?
LAUREN SALZMAN: Yes, I think so. I think he did.
MR. AGNIFILO: And what you just all of us, you saw that happen in realtime; correct?
LAUREN SALZMAN: Yes, I did.
MR. AGNIFILO: And --
LAUREN SALZMAN: And it informed my struggles about the relationship over time that I discussed with him.
MR. AGNIFILO: And you didn't leave him?
LAUREN SALZMAN: I didn't. Correct.
MR. AGNIFILO: All right. Now --
LAUREN SALZMAN: Which I also struggled with.
MR. AGNIFILO: Understood.
Dawn Morrison, another person I think you mentioned was in a relationship with Keith for a period of time; correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Do you know if Keith had a relationship of some sort with your mother?
LAUREN SALZMAN: Briefly, he did.
MR. AGNIFILO: Many, many years ago?
LAUREN SALZMAN: Yeah, before mine.
MR. AGNIFILO: And then there's yourself. Then there's Barbara Bouchey. And Keith had an intimate relationship with Barbara; correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: Kathy Russell the same?
LAUREN SALZMAN: The same.
MR. AGNIFILO: Daniella the same?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Marianna the same?
LAUREN SALZMAN: Uh-hum.
MR. AGNIFILO: You have you have to say yes or no.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Camila the same?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Monica Duran the same?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Ivy Nevares the same?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Loretta Garza the same?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: I think you said a couple of days ago Keith had a relationship with Clare Bronfman?
LAUREN SALZMAN: I believe so, yes.
MR. AGNIFILO: Jim Del Negro?
MR. AGNIFILO: Emiliano Salinas no?
MR. AGNIFILO: Mark Vicente no?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: Nicki Clyne yes?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Rosa Laura Junco, I think you said you didn't think he had a relationship with?
LAUREN SALZMAN: He told me no and she told me no.
MR. AGNIFILO: Dani Padilla Bergeron yes?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Allison Mack yes?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And Alex Bentancourt, Jack Levy no?
MR. AGNIFILO: So the only woman on this chart, if I have my memory right, that he did not seem to have a relationship with is Rosa Laura?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: What rank was Rosa Laura?
LAUREN SALZMAN: Rosa Laura was a proctor in the ESP. I'm not sure how many stripes she had.
MR. AGNIFILO: I mean, a pretty high level?
LAUREN SALZMAN: Yeah.
MR. AGNIFILO: And many of these relationships -- actually, did any of these relationships come after DOS was created, to your knowledge, or were all of these pre- existing the creation of DOS?
LAUREN SALZMAN: My understanding -- Allison told me that when Daniella enrolled her, she enrolled her into DOS and into a relationship with Keith, so they came contemporaneously.
MR. AGNIFILO: Other Allison Mack, fair to say that all of the romantic relationships that Keith had were before DOS was ever created?
LAUREN SALZMAN: Yeah. And Daniella, to some extent, through the creation of DOS, so, yes.
MR. AGNIFILO: So Pam, Barbara, Karen, Kristin, Dawn, Nancy, yourself, Barbara, Kathy, Daniella, Marianna, Camila, Monica, Ivy, Loretta, Clare, Nicki, all before DOS?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Fair to say Keith's lifestyle from when you knew him was that he had many relationships with many different women for extended periods of time?
LAUREN SALZMAN: Yes, and he would change the rules on it, I mean, to some degree. Like I said -- I mean, we discussed that I said to him initially, like when this started, I thought that it was this small select group of people and he said that's true and then at some point that changed. So, you know, he would change things and tell me several years after the fact or at different times. But, yes, what you're saying is correct.
MR. AGNIFILO: Right. And regardless of the individual rules at any point, it was pretty well known --
LAUREN SALZMAN: Yes.
MR. AGNIFILO: -- Keith had many relations with many different women and that this went back to the late '90s?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Now, fair to say Keith never said to you that your position in NXIVM was in any way independent on whether or not you had an intimate relationship with him?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: He never linked the two; right?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: He never said to you if you want to be a proctor, if you want to have an orange -- not scarf.
LAUREN SALZMAN: Sash.
MR. AGNIFILO: Sash.
-- orange sash or a green sash, you're better off if you have an intimate relationship with me? He never said it?
LAUREN SALZMAN: No, but the women who did were treated differently and the women who left were treated differently.
MR. AGNIFILO: So let's talk about that for a second. Marianna, Marianna had a child with Keith; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Marianna lived with Keith?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Marianna, I think at one point you said that you guys all went to Woodstock maybe in 2016. Do you remember this?
LAUREN SALZMAN: Yes, I do.
MR. AGNIFILO: Okay. And part of what was off putting for you about this trip is that a whole bunch of you went and it was like you were all kind of the guests of Keith and Marianna; right?
LAUREN SALZMAN: Yes. And that he was becoming public with their relationship in a way that he hadn't been before in front of her family, and, so, it hadn't been discussed and it was unusual.
MR. AGNIFILO: And so it seemed like he had sort of an especially public, close relationship with Marianna?
LAUREN SALZMAN: Or was making it so.
MR. AGNIFILO: Marianna never --
LAUREN SALZMAN: And very, very soon after Pam had died, you know, so.
MR. AGNIFILO: Marianna never preceded above being above a coach?
LAUREN SALZMAN: Marianna never proceeded being above a coach. When Marianna was a coach and Marianna was largely almost completely inactive in ESP, so not participating in any active programs, he wanted to promote her at V week and offered that she should be jumped two stripe levels and that wouldn't have been available to anybody else who was an inactive coach in the same way. So when the proctor group came back and said that they didn't agree because she wasn't even actively participating and didn't have the skill sets of any of the people who were in the rank he wanted to jump here to, he said well, if they don't like it, then I'll just jump her straight to proctor.
MR. AGNIFILO: And did he jump her to proctor?
LAUREN SALZMAN: No, but he jumped her to stripe level, so she got a promotion that nobody else outside of those circumstances would have gotten, would have received.
MR. AGNIFILO: How many levels were you higher than Marianna?
LAUREN SALZMAN: I was two ranks higher.
MR. AGNIFILO: Within the ranks, how many sort of sublevels are there?
LAUREN SALZMAN: There are four in each rank.
MR. AGNIFILO: So you were eight levels higher than Marianna?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And, so, Marianna, even despite the two levels of promotion, she still was a coach?
LAUREN SALZMAN: She still was a coach.
MR. AGNIFILO: Remind the jury, what is --
LAUREN SALZMAN: Honestly, the -- I mean, I was fired from an executive board position that almost nobody in the organization could fill the job function of because of allegations of nepotism coming from a former partner who left and was very public. Within six months, I was back on the board position because I was the only one doing that job. So there were these types of things where it wasn't commensurate necessarily with the work that was being done, what happened.
MR. AGNIFILO: So you rose through the ranks because you worked very, very hard, tirelessly, putting in long hours over many, many years to earn the position that you got; correct?
LAUREN SALZMAN: Correct. And to earn a relationship position with Keith that he told me if I did that I would be able to have.
MR. AGNIFILO: And when you say relationship position, what do you mean?
LAUREN SALZMAN: I mean that he told me the reason we weren't having children or we weren't having a relationship is because I didn't have a good work output or I hadn't lost weight or my state was very low or -- all these different things. So I focused on changing all of those things because he told me if I did being I would able to have that.
MR. AGNIFILO: So you were promoted professionally speaking?
LAUREN SALZMAN: Yes, I was.
MR. AGNIFILO: In NXIVM because of your hard work; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: But what you didn't feel that you received, which you feel you earned, was having a child and having that kind of relationship with Keith Raniere?
LAUREN SALZMAN: Yes. And also there were other things that were taken away or withheld and blamed on my failures, personally and professionally.
MR. AGNIFILO: And professionally, what do you feel was taken away from you?
LAUREN SALZMAN: Well, like, for example, when he introduced a community project, he was very vocal about the high ranks of ESP or thwarting the growth of the program, so they can't take leadership roles in the community project. But then when the community project was failing, I was asked to go in and please help and speak to the community, or when he released the Ultima program, the emphasis group was having trouble. We had infighting and various things and he said the Exo-Eso was working very hard and if we could be like them, you know, that was the way to be, we could really get things done.
But when they failed, basically their whole company fell apart because they didn't have the skills necessary to run it, he asked us again it go in and fix it. So there was a level of competence, capacity that I and others had that we were being asked to employ in the objectives that he was starting after he had specifically said we were not allowed to have the leadership positions because of how incompetent and ineffective we were and then no recognition of the fact that he had said we were the reason that the thing was going to fail in the first place, but that we were the ones who went and cleaned it all up at the end. So this is a very difficult thing to negotiate in terms of earning.
MR. AGNIFILO: And you mean earning, earning money or earning something --
LAUREN SALZMAN: No. I mean even evening the position. If I can't have the position because I am so ineffective that I'm going to screw it up, but when the person you gave the position to screwed it up, I'm going to go behind the scenes to help them so they actually can do the position that they do and I don't have the position because I was denied because allegedly I am so ineffective, then why am I the one being sent in to go help them run it, independent of money.
MR. AGNIFILO: Now, you talked about the NXIVM nine on your direct examination. Do you remember talking about that?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Just remind the jury what that is.
LAUREN SALZMAN: In around 2009, nine women left the organization. They left NXIVM and wrote a letter that I was told it was an extortionate letter and there were attempts to address this legally.
MR. AGNIFILO: And do you know --
LAUREN SALZMAN: And they were referred to as the nine, you know.
MR. AGNIFILO: And do you know if efforts were made to bring this to the attention of the district attorney in Saratoga County?
LAUREN SALZMAN: Yes, I believe there were. I mean, I didn't see the legal proceedings on it, but that's what I heard and that was my understanding, yes.
MR. AGNIFILO: And you said that you were told that the letter was extortionate?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Let me ask you just a few questions about that. Do you remember around the time that the letter was written there was talk of the Dalai Lama coming to the Albany area?
LAUREN SALZMAN: Yes, there was.
MR. AGNIFILO: Just tell the jury what was going on.
LAUREN SALZMAN: Keith was organizing an event called the World of Ethical Foundation Consortium and Sara and Clare Bronfman was part of that initiative. And he has an idea for this event, but... I don't know all of the details of what happened in the event, but the Dalai Lama was scheduled to come to Albany as part of this event. And I believe because of the media, the bad press or whatever was going on with us at the time, he cancelled the event.
MR. AGNIFILO: The Dalai Lama did?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And just for us all, who is the Dalai Lama?
LAUREN SALZMAN: The Dalai Lama is Tibet's spiritual leader.
MR. AGNIFILO: And do you recall that one of the people -- one of the members of the NXIVM nine --
MR. AGNIFILO: Your Honor, I might be in this subject here for about ten minutes. We can take our break. I know we have gone past our normal time.
THE COURT: We should take your break.
MR. AGNIFILO: That's fine.
THE COURT: All right. All rise for the jury.
(Jury exits the courtroom.)
(Continued on following page.)
(Continuing)
THE COURT: The witness may stand down, please. Do not discuss your testimony with anyone. Take a ten-minute break.
(Recess taken.)
THE COURT: Let's bring in the witness, please.
(Witness resumes the stand.)
THE COURT: Please bring in the jury.
(Jury enters.)
THE COURT: Please be seated.
You may continue your cross-examination, Mr. Agnifilo.
The witness is reminded that she is still under oath.
BY MR. AGNIFILO:
MR. AGNIFILO: Ms. Salzman, we left off and we were talking about certain aspects of the NXIVM 9 situation.
Now, do you recall that -- I think you testified on direct examination that following the NXIVM 9 situation, there were major changes done to the executive board; am I right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And is it true that Keith was essentially -- noticed the fact that certain problems had been missed for a very long time and had become bigger and bigger problems; is that a fair way to put it?
LAUREN SALZMAN: Can you be more specific?
MR. AGNIFILO: Sure, sure.
What was the problem? What was the problem, as you understood, as Keith expressed it at the time?
LAUREN SALZMAN: What I understood at the time was that there were allegations being made that all the people on the executive board were in relationships with Keith and having sex with each other and that it was incredibly nepotistic.
MR. AGNIFILO: And Keith -- I'm sorry, go ahead.
LAUREN SALZMAN: And that part of replacing the board was discrediting that.
MR. AGNIFILO: And, so, what happened to the board?
LAUREN SALZMAN: The whole board got fired, he created a whole new board, and then, eventually, I was back on the board because nobody on the new board was doing my job function. Karen Unterreiner stayed on the board the whole time.
MR. AGNIFILO: And your being on the board and being effective on the board had nothing to do with the fact that you had had or didn't have a relationship with Keith; correct, you were good at your job?
LAUREN SALZMAN: In that case, I actually got fired from the board for a period of time because I had a relationship with Keith, but, yes, I got back on the board because I was good at my job.
MR. AGNIFILO: Now, one of the situations within the NXIVM 9, I think you used the term "extortion," was that there was a monetary demand made, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And was there a belief within the organization at the time that that was not a good faith monetary demand?
LAUREN SALZMAN: Yes, there was. That wasn't a good faith monetary demand.
MR. AGNIFILO: And that the bad faith monetary demand was made at a time such that the Dalai Lama's visit could be interrupted?
LAUREN SALZMAN: Yes, it was interrupted.
MR. AGNIFILO: And following the situation with the NXIVM 9, I think you testified on direct examination certain people were shunned?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And "shunning" is basically sort of the community just turns their back on certain people, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And I think --
LAUREN SALZMAN: Doesn't communicate with them, doesn't support them.
MR. AGNIFILO: I think you said on direct examination that for a period of time your father was shunned; am I right about this?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And is that because he was connected with someone named Nina?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And do you recall writing a letter to your father about this situation?
LAUREN SALZMAN: Yes, I wrote several letters to my father about the situation.
MR. AGNIFILO: And what did you tell your father in these letters?
LAUREN SALZMAN: Urging him to please support me and Keith and -- or me, but it was NXIVM and me, and not support people who are trying to destroy us as an organization.
MR. AGNIFILO: And you believed that these people were trying to destroy NXIVM, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you were encouraging -- what was the situation between your father and Nina?
LAUREN SALZMAN: That she was an employee of his.
MR. AGNIFILO: And Nina was one of the NXIVM 9?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And what did you want your father to the do with Nina?
LAUREN SALZMAN: To either convince Nina to withdraw her support from the 9 or to fire her.
MR. AGNIFILO: And did he?
LAUREN SALZMAN: No, he didn't.
He didn't want to take a position. He wanted to be neutral. And, you know, Keith's point, and that was my point at the time too, was that is there isn't neutral because he's my father, so his vote counts in a different way than other people's votes, and I should take a stand on this.
MR. AGNIFILO: And the stand that you took is you tried to convince your father to fire this person Nina.
LAUREN SALZMAN: By leveraging the relationship, by withholding it from him.
MR. AGNIFILO: By withholding?
LAUREN SALZMAN: The relationship, our relationship, from my father.
MR. AGNIFILO: So, you were basically -- well, what were you doing?
When you say you were withholding your relationship with your father, describe to us what you were doing.
LAUREN SALZMAN: I stopped seeing him or being willing to talk to him unless he would talk about this and address it and take action on it, do what I was asking.
MR. AGNIFILO: And you described this yesterday as a form of shunning by NXIVM, correct?
LAUREN SALZMAN: Well, it came at the time of a community project. There were discussions about it between me and the other community members. And, so, it became part of that.
MR. AGNIFILO: But you made the decision on your own?
LAUREN SALZMAN: I made the decision with Keith.
MR. AGNIFILO: And at the time, how old were you?
LAUREN SALZMAN: You know, thirtysomething, early thirties.
MR. AGNIFILO: And this is your sort of adult relationship with your father, correct?
LAUREN SALZMAN: It's my adult relationship with my father based in counseling and advisement from Keith about a subject that Keith felt very strong about. And it doesn't look -- I don't view it the same way right now.
MR. AGNIFILO: But, so, I'm asking at the time. At the time, you believed that this person Nina was a member of a group of people that was going to be very damaging to NXIVM and was damaging to NXIVM, correct?
LAUREN SALZMAN: I believe that Nina got involved in the group and wasn't -- yes, that Nina was not withdrawing her support in the taking a stand against the 9 and my dad was hiring her.
MR. AGNIFILO: And you wanted to communicate with your father very clearly that: If you continue to work with this person Nina, I, your daughter, am not going to have a relationship with you.
Right?
LAUREN SALZMAN: Based on going for walks, many walks, with Keith, where he said, I don't think your father loves you. This is an example of not love. If he really loved you, he would do this, and I don't understand why he won't support us.
And my dad didn't want to take a stand that would put him in a position to be on the receiving end of a bunch of negative press associated with NXIVM and public scrutiny.
MR. AGNIFILO: Did Keith ever threaten you or say if you didn't write these letters to your father something bad would happen to you?
LAUREN SALZMAN: Keith, no, he never threatened me.
MR. AGNIFILO: So, you were doing this --
LAUREN SALZMAN: But if I didn't follow through on it, there would have been many more talks until I had been willing to uphold the ethical position or I would have been viewed as somebody who isn't willing to do the ethical thing or the good thing or the right thing. And others, for example, Rosa Laura or the Bronfmans, who had similar issues with their parents but were financially in a different place and were financial backers, were not put in positions to do that.
MR. AGNIFILO: And did you tell Keith you didn't want to take this position with your father?
LAUREN SALZMAN: No, I didn't.
But I did discuss with him over the years what it meant and why was it such an issue with me and why did he make such a point of it with me when he didn't push the others or make such a point of it with them.
MR. AGNIFILO: But fair to say you took this position with your father because that's what you wanted to do?
LAUREN SALZMAN: Yes, and part of my wanting to do that is more than anything else I wanted in the world was Keith's approval and that Keith thought I was a definition of a good person by doing the things that Keith laid out you had to do to be a good person.
And I did that time and time again.
MR. AGNIFILO: Did you talk to your mother about it?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And what was your mother's position?
LAUREN SALZMAN: Everyone's position within NXIVM who was loyal to Keith and viewed as supporting the mission had the same perspectives. And if they didn't, they wouldn't have been viewed as supporting the initiatives or the mission of NXIVM. They wouldn't have been in alignment with.
MR. AGNIFILO: Do you remember when Mark Vicente wrote a very critical letter to the executive board in January 2016?
LAUREN SALZMAN: I remember there was a letter he wrote. I don't remember the contents of the letter, but, yes, I do remember that.
MR. AGNIFILO: Do you remember that he said that the executive board was arrogant, that the old guard was punishing; do you remember those things?
LAUREN SALZMAN: As you're saying them, I recall vaguely that, yes.
MR. AGNIFILO: Did anything happen to Mark Vicente?
Was Mark Vicente kicked out of NXIVM the next day or anything like that?
LAUREN SALZMAN: Mark Vicente was viewed as a problem. And myself and a number of people were talked to on an ongoing basis about the problem of that and dealing with it. And Keith would bring up frequently if he had to do it himself, it was going to be a problem and that Mark was going to leave, so we had to go and do it and it was raising to the level of problem because we weren't doing it, we weren't getting our shit together and dealing with the problem of Mark.
So, when you start expressing those types of things, you become viewed as a problem, talked about within the organization, and others are sent to deal with the problem of you until you either change your perspective or it raises to the level that Keith has to deal with it and it can't be resolved.
MR. AGNIFILO: Mark Vicente was never kicked out of NXIVM, right?
LAUREN SALZMAN: No, Mark was not kicked out of NXIVM, but Mark was viewed as a problem and an issue for a long time before he was kicked -- before he chose to leave NXIVM.
MR. AGNIFILO: He remained for a year and a half after writing this letter where he told the executive board they were arrogant and the old guard that it was punishing?
LAUREN SALZMAN: That's true.
MR. AGNIFILO: And it wasn't until he resigned -- he left NXIVM because he resigned, right?
LAUREN SALZMAN: Yes, that's true.
MR. AGNIFILO: No one kicked him out, right?
LAUREN SALZMAN: That's true.
MR. AGNIFILO: I want to talk to you a little bit about Daniella. You talked about Daniella pretty extensively on direct examination.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You said that she -- you taught a course, was it in Monterrey, and she was in the course?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you said that you could see that she was very bright.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you said that rather than going to boarding school in Switzerland, she decided to come and take NXIVM courses in the Albany area.
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And at one point, she was in Albany; soon after you taught her in Monterrey, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Did you know what her immigration status was at the time?
LAUREN SALZMAN: No, not initially.
MR. AGNIFILO: Did you know what her status was when she first came to Albany?
MR. AGNIFILO: Do you know what kind of visa she had or even if she had a visa?
MR. AGNIFILO: You weren't involved in securing visas for people, right?
LAUREN SALZMAN: Correct, I was not.
MR. AGNIFILO: And you were not involved in securing a visa for Daniella, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: Now, you said at some point later, years later, Kristin Keeffe was at a New Year's Eve party at your mother's house and she had a conversation with you about Daniella?
LAUREN SALZMAN: She had a conversation with a group of people, yeah.
MR. AGNIFILO: I think what you said on direct examination is that Kristin Keeffe had brought Daniella over the Canadian border; am I remembering this right?
LAUREN SALZMAN: I didn't remember all the details of it, but, yeah, they were talking about Daniella crossing the border at that point, yeah.
MR. AGNIFILO: At the time, what was Kristin Keeffe's position in NXIVM?
LAUREN SALZMAN: I can't recall what her rank was in NXIVM, but I think -- at some point, Kristin worked on the legal team, but I don't know specifically at that time if that was true. She was a proctor at one point, then she became a coach or was inactive in NXIVM for a period, and then at one point she was working in legal.
MR. AGNIFILO: She was on the legal team, she was not a lawyer, correct?
LAUREN SALZMAN: Correct, Kristin was not a lawyer.
MR. AGNIFILO: Now, Daniella's father was named Hector, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Mother's named Adrianna?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And they had four children?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: That was Marianna, Daniella, Adrian -- who also goes by "Fluffy" -- and Camilla, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: I think you testified yesterday that during V-Week in 2011, Dani was given an e-mail access?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: I think you said she was using the happymonk55 e-mail address.
LAUREN SALZMAN: Yes, she was with me, yes.
MR. AGNIFILO: These are all in evidence. These are all 908-R, these are different entries in 908-R. I'm going to show you what's already in evidence, so the jury can see it, 908-R2, Page 2 of 908-R.
(Exhibit published to the jury.)
MR. AGNIFILO: And just so it's clear, this is from Daniella at happymonk55 to you from August 24, 2011, right?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: And V-Week is always the last -- sort of the end of August, correct?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: And then up on top, there's another entry and it's from Lauren Salzman to this NXIVM address from February 10, 2012.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Do you know what the two different dates signify?
LAUREN SALZMAN: One where I received the e-mail and the other where I forwarded it to myself to keep it.
MR. AGNIFILO: So, the e-mail that you received is the bottom date, that August 24, 2011 date.
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And happymonk55, which you know to be Daniella, says: From Keith, I have once again taken his time and resources with the problems I create, especially in taking your time. I use Cami to indulge and satiate, I reinforce Fluffy's issues and erroneous perception of himself.
Do you know what she's talking about here?
LAUREN SALZMAN: She's talking about the way that she -- the ways that she interacted with Keith and myself and her siblings that were damaging.
MR. AGNIFILO: And what was damaging about how she interacted with these people?
LAUREN SALZMAN: She's saying she took Keith's time and resources by creating problems, and that she was using Cami to indulge and satiate, and reinforcing her brother's perception that she's saying is erroneous, it's, like, false, false perception of himself.
MR. AGNIFILO: Did you have an understanding that part of the reason that Daniella received the punishment of going into the room was that she was stealing from people and from NXIVM itself?
LAUREN SALZMAN: Keith told me that, yes. And I had heard that she had stolen money from NXIVM and returned it, but yes.
MR. AGNIFILO: Thousands of dollars?
LAUREN SALZMAN: Yeah, she stole a couple thousand dollars from the admin office and then returned it.
MR. AGNIFILO: Was she working in the admin office for a period of time?
LAUREN SALZMAN: That was my understanding.
MR. AGNIFILO: And is it your understanding that it was cash -- you know, sort of NXIVM cash just kept in the admin office?
LAUREN SALZMAN: Yes, that was my understanding, or cash -- yeah, that was there in the admin office.
MR. AGNIFILO: And she stole that cash and then she basically confessed to having stolen the cash.
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: And in addition to stealing the cash, did she steal other things?
LAUREN SALZMAN: Keith told me, I mean, that she was, like, stealing food from the family and things.
Or at one point, he told me, or maybe Pam told me, that they thought she had stolen -- there was, like, at the Jness house, there was an honor cup for if you get a cup of coffee, you pay a dollar for the cup of coffee. They thought she stole the money from the honor cup.
And Kristin reported that she had money on her when they were driving her back to Mexico that she had stolen.
MR. AGNIFILO: We'll look at another page from this same exhibit. We're going to look at Page 7; 908, Page 7, still in evidence.
(Exhibit published to the jury.)
MR. AGNIFILO: I'm just going to look at the highlighted portion, which is in that third paragraph there: So, let me be superclear, I will not do anything --
THE COURT: Could you just slow down.
MR. AGNIFILO: Of course, absolutely.
THE COURT: Thank you.
MR. AGNIFILO: So, let me be superclear, I will not do anything I don't want to do. I will not choose based on what you suggest or say. I do, of course, hold your opinion and Keith's in very high regard and they are of great influence in my decisions. But what I do here now and anywhere anytime is ultimately my choice.
She wrote that to you?
LAUREN SALZMAN: She did write that to me, yes.
MR. AGNIFILO: Do you recall what the issue was at the time, why she wrote that to you, on August 27, 2011?
LAUREN SALZMAN: I don't recall specifically at the time, but she said, I had the issue of feeling controlled or manipulated.
So, now she's saying she feels not controlled and manipulated but it's her choice.
MR. AGNIFILO: And fair to say that on numerous occasions she would state to you that she wanted to stay in the room, that that was her choice.
LAUREN SALZMAN: She went back and forth: I want to, I don't want to; I want to, I don't want to.
MR. AGNIFILO: Sometimes she would say, I'm coming undone.
And I think we looked at some of those communications a couple days ago, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And then sometimes she would say, I'm going to stay here.
Right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And do you get the sense she was almost doubling down on herself, saying, almost indignant, I'm going to stay in the room.
LAUREN SALZMAN: Sometimes she would say that. Sometimes she would be determined to stay in the room.
But I mean, there is this issue of -- it was her choice to stay in the room and not go back to Mexico and lose her family and whatnot, but there is a thing about it where -- I mean, a big part of what Keith taught us in the technology that we worked with in the school is being able to take the thing the person fears and have it be the thing they need to do to get what they want.
And there's this thing of leveraging their choices. And if you understand a person's fears, then you understand a person's values or what they feel attached to or dependent on. There is leverage in the decision that isn't just something that would be present otherwise.
(Continued on the following page.)
EXAMINATION CONTINUES BY MR. AGNIFILO:
MR. AGNIFILO: Now, you said yesterday a few times that, by going to Mexico, she would have lost her family. Do you remember saying that?
LAUREN SALZMAN: Yes, she felt that. She believed that.
MR. AGNIFILO: The different members of this family would go to and from Mexico with some frequency, correct?
LAUREN SALZMAN: Yes, but if you look at really what happened, she went to Mexico and the entire family shunned her, which is what she was afraid of.
MR. AGNIFILO: We're going to get to that.
But the father, Hector, would go to and from Mexico, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: The mother would go to and from Mexico, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Various of the kids would go to and from Mexico, correct?
LAUREN SALZMAN: Yeah, I mean pursuant to their visa issues, but yes.
MR. AGNIFILO: All right, we can look at Page 4 of this same exhibit. I'll zoom in a little bit just so it's a little bit easier for all of us to read.
(Exhibit published.)
MR. AGNIFILO: So here she says, on September 11th, 2011:
Here is a thought: When faced by an ethical breach, if the ideal way to fix it conflicts with your "mission," I will not even go into this lie, then you still try to fix it in any other way possible, trying to preserve as much value as you can. You don't go and deny there is a breach by justifying it with your "mission," and make shit up about all of the destruction of value being necessary. You fight for what you care for, dammit, even if it -- USN, her family, falls in second place to your "mission."
Do you know why she keeps putting mission in quotes?
LAUREN SALZMAN: Because when Adriana left the room, so her mother was in the opposite room, and when Adriana went back to Mexico what she said is that her mission, like her life purpose, wasn't something that she could do within the room. So, she -- what she wanted to do was join this group in this thing called the Book of Life that she was saying was like her purpose, she wanted to be part of this group to raise the consciousness of humanity with this select twelve people, or whatever, and that's what she was gonna do because it was her mission.
So that's what Dani is referring to.
MR. AGNIFILO: All right, and just -- just -- I know you went through it a couple days ago, but just to review. So, Dani goes in the room first, right, and this is a room of the family's house -- I think the Court asked at one point whose house was it; it was the family's house?
LAUREN SALZMAN: Yes, correct. They were renting it.
MR. AGNIFILO: Right, they were renting it. And all the family members lived there at one point or another, correct?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: And I think you said there were two bedrooms up on the second floor?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And they shared a bathroom?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: Okay. And so Dani was in one of the bedrooms?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And she was there first?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And then Adriana, the mom, she went into the other bedroom?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: And she was there for a period of time?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: All right. And then I think we said yesterday that, at some point, the mom -- the mom had a romantic interest, who was this singer, right?
LAUREN SALZMAN: I didn't say who it was or the nature of their relationship, but yes, somebody who was close to her was murdered and she left.
MR. AGNIFILO: Right. And Facundo Cabral was his name, correct?
LAUREN SALZMAN: Yes, that's my understanding.
MR. AGNIFILO: And he was a well-known Argentine singer?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Okay. And he was shot to death in Guatemala?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Okay. And whatever the nature of her relationship with Facundo Cabral was, that's what prompted her to leave the room?
LAUREN SALZMAN: At that time, yes.
MR. AGNIFILO: Yes. And she went to the funeral of Facundo Cabral, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And then she never really -- she never came back?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: All right. And she said she joined this other group?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And Dani stayed in the room a while longer, even after her mother left, right?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: Okay. All right, we are just going to go through a few more of these, not too many.
All right, this is page 36 of that same exhibit.
(Exhibit published.)
BY MR. AGNIFILO:
MR. AGNIFILO: This is from HappyMonk55 to you, it's September 21st, 2011. She says:
Hey, so the consequence for my behavior toward you is going to be what I had set before for any prideful behavior; extend my time in the room for one additional week. To rectify it, I want to tell you that I am sorry. I was wrong and very disrespectful, and I will be setting additional more specific consequences for all the future destructive behavior that's included.
Do you remember what she was talking about?
LAUREN SALZMAN: (No response.)
MR. AGNIFILO: I know it's a long time ago.
LAUREN SALZMAN: I can't remember specifically what she had done, that I was telling her was prideful behavior, but she was saying this was going to be her consequence for that behavior, she was gonna fix it.
MR. AGNIFILO: Okay. And from time to time, she would give herself consequences, including vowing that she would stay in the room longer?
LAUREN SALZMAN: That's true.
MR. AGNIFILO: This is page 55 of that same exhibit. And this is -- I want to focus on an e-mail that you wrote to her, and you write to HappyMonk55, on September 27th, 2011:
I would like to see the results of the work you're doing. Can you send me a detailed mail? Also, with respect to being shitty with me last week, I think it's important that you don't defer your consequence to the nonspecific future, but rather absorb it now.
Do you recall what Dani had done that caused you to write that?
LAUREN SALZMAN: Yes. What she had done was saying that the consequence of how she was going to fix it was adding one week to the room at the end.
MR. AGNIFILO: Okay. And you conveyed to her that she wasn't respectful, nice, whatever that word summons here, what was the problem?
LAUREN SALZMAN: What was the problem of her being not respectful or nice?
MR. AGNIFILO: You say that she was shitty. What did she do?
LAUREN SALZMAN: I don't recall specifically what she did.
MR. AGNIFILO: Fair to say she fairly often would be disrespectful to you in these written communications, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you were trying to help her, correct?
LAUREN SALZMAN: Yes, I was trying to help her, and also I was... I think incredibly discompassionate [sic] and punishing with her often.
MR. AGNIFILO: But the idea was that there were certain things that she was supposed to do, that she could have done, if she wanted to get out of the room, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you were helping her see, in a sense, the error of her ways in terms of how she was acting; correct?
LAUREN SALZMAN: Yes, but also when -- it wasn't something that I felt was an error of her ways, I was willing to give feedback on anything Keith thought or enact any consequences Keith thought would be good, independent of whether it was my perception or not, and often I couldn't see the thing he was talking about and still would enforce those -- those things on her.
MR. AGNIFILO: Now, just talking about you for a second.
LAUREN SALZMAN: Uh-hum.
MR. AGNIFILO: Your beliefs. Did you believe that she should stay in the room?
LAUREN SALZMAN: I think it got really crazy that she was in the room for a very long period of time and I questioned whether this was something that was okay, even whether it was something that would have legal implication, which is even why I forwarded and saved the e-mails.
MR. AGNIFILO: Now, do you -- did you tell Keith that I think we should let her out, I think it's time, I think this has gone too far, we should let her out of the room?
LAUREN SALZMAN: I always questioned myself, not Keith. Even when I had questions about Keith, or doubts like that, I always went -- deferred to what Keith thought was better and I thought that it was me, my fears, my limitations or issues, and that he was Keith so he knew what was right or he knew what was ethical.
MR. AGNIFILO: But you didn't --
LAUREN SALZMAN: And often I avoided the whole situation altogether because I couldn't really handle what was going on there.
MR. AGNIFILO: You didn't bring it up to him, you didn't go up to him and say, hey, Keith, I think this has gone too far?
LAUREN SALZMAN: I didn't feel able to, no. I just avoided it. I left her in the room all alone for months at a time.
MR. AGNIFILO: Because at the time you thought that was the right thing?
LAUREN SALZMAN: Because at the time I couldn't handle any aspect of thinking it might not be.
MR. AGNIFILO: You could have just gone to Keith and ask -- did you think that Keith valued your opinion?
LAUREN SALZMAN: To a degree, but also -- I mean, commensurate with what was going on in the room was the NXIVM nine had left, Barbara had left, and there was a lot of feedback that I was getting from Keith about how I was directly responsible for that; my failures, my mom's failures had caused that, and I didn't want to be somebody who failed and caused hardship and destroyed the company, you know, or hardship that would destroy the company. And so I was especially focused during this time at doing a good job at whatever needed to be done.
MR. AGNIFILO: Now, the father and the mother were both involved in this situation, correct?
LAUREN SALZMAN: Yes, they were.
MR. AGNIFILO: And Hector, the father, was fully on board with Dani remaining in the room, correct?
LAUREN SALZMAN: Hector, the father, in my experience, is an incredibly weak personality and could have been enrolled to be on board if Marianna was on board, or if Cami was on board. Like if the whole family said we're not on board, then I think that Hector would not have been on board.
MR. AGNIFILO: But in terms of the interactions you had with Hector, weak-willed or not weak-willed, he said, as the father of his daughter, he supported her staying in that room, correct?
LAUREN SALZMAN: It's true, and he withheld her documents in the end as well.
MR. AGNIFILO: And the mother had concerns about it, but the mother was supportive of her being in the room as well?
LAUREN SALZMAN: Yes, that's true.
MR. AGNIFILO: And her two sisters were supportive of her staying in the room as well, correct?
LAUREN SALZMAN: They were -- they had issues with it, but they were.
MR. AGNIFILO: And her brother, Fluffy -- Adrian, had some concerns about it, but he wasn't objecting to her being in the room to you, correct?
LAUREN SALZMAN: Adrian had objections that he was voicing and there were times that Keith asked me to talk to the other -- the siblings, including Dani, to help Adrian reform his perspective and stop having those reservations.
MR. AGNIFILO: Okay, we are going to look at the next page, which is page 60 of that same exhibit, 908, which is in evidence.
This is an e-mail from you to HappyMonk55, which is Danielle, and the third paragraph there says: Please tell me by 6:00 p.m. today what consequence you will take on today for being an ass last week.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Do you remember what she had done that caused you to say that?
LAUREN SALZMAN: No, not specifically.
MR. AGNIFILO: Now, just so we're clear --
LAUREN SALZMAN: Probably something along the lines of what we're talking about.
MR. AGNIFILO: Are these things that Keith is telling you to say or are these things you are choosing to say of your own volition?
LAUREN SALZMAN: I mean, these are my words. There are some things he was telling me directly to say and the things that I -- that I am saying were informed by the things he was telling me directly to say.
So, he would say, for example, tell her you have the authority to shut the whole program down or tell her that, if she's gonna continue to do this, you're gonna cut communication with her, and then if she doesn't make a total turn around by the time you re-establish communication, that you're gonna make the formal recommendation to go back to Mexico.
So he and I would have these conversations and then that informed my setting these types of boundaries going forward.
MR. AGNIFILO: But the words "tell me what you're gonna do today for being an ass last week," those are your words?
LAUREN SALZMAN: Those are my words.
MR. AGNIFILO: I am going to show you another document that's already in evidence. It's Government's 1484-R. It was put into evidence yesterday.
So 1484-R, which is already in evidence, is a two-page document. I am going to zoom in on specific parts, Ms. Salzman.
You can see on the top there, there are a number of people on this e-mail chain. There's Hector, that's the dad, correct?
LAUREN SALZMAN: Correct.
(Exhibit published.)
BY MR. AGNIFILO:
MR. AGNIFILO: Aria, is that Marianna?
LAUREN SALZMAN: Marianna, yes.
MR. AGNIFILO: Cami is Cami or Camila, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: You're Lauren Salzman, obviously?
LAUREN SALZMAN: I am, yes.
MR. AGNIFILO: Kristin Keeffe is Kristin Keeffe?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: All right, so this is an e-mail chain that starts actually on the previous page. It starts actually at the bottom. Let me see if I can do it the way -- there we go, that works.
(Exhibit published.)
BY MR. AGNIFILO:
MR. AGNIFILO: All right, so we'll look at the whole thing. So 1484, this is from Papa, correct, it says Papa at the bottom there?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And we can see from the header that it's from Hector, who is the father, right?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: And Hector e-mails all these different people and he informs everybody that she has mama PSP -- I am reading right here (indicating): She has mama PSP and 1,000 pesos and 100 Euros she stole from me.
Right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: This is -- this is the father talking about his daughter Dani. Do you know what the reference to PSP is, do you know what that is?
LAUREN SALZMAN: I don't know what that is.
MR. AGNIFILO: Okay. Pesos is obviously Mexican currency, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And Euros is certain countries in Europe?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: All right. And he says very clearly here: My daughter stole these things from me; in this e-mail, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: He goes on to say: She also hacked my Facebook account. Right?
LAUREN SALZMAN: (No response.)
MR. AGNIFILO: That's what he says?
LAUREN SALZMAN: He said it, yeah.
MR. AGNIFILO: And he's saying it to you and others?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: He's informing you?
LAUREN SALZMAN: Uh-hum.
MR. AGNIFILO: That his daughter stole from him and Dani also hacked his Facebook account, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: He goes on to say -- I'm looking right here (indicating): Kristin Keeffe went to the border to see her crossing the border. My accountant was waiting for her across the bridge.
Right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: All right. And so, your understanding, I think you testified to this on direct, that when Dani chose to leave the room and go back to Mexico, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Which was her choice -- at some point, that's what she chose?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And how old was she at the time that she left the room about?
LAUREN SALZMAN: In her mid to late twenties.
MR. AGNIFILO: Okay, so a mid to late 20-year-old person chose to leave the room and she was driven by her father and Kristin Keeffe to the Mexican border, correct?
LAUREN SALZMAN: Yes. Yes, correct.
MR. AGNIFILO: And what the father is informing you of here is that he had his accountant waiting for her across the bridge, presumably on the Mexico side of a bridge that separates the two countries, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Now, Hector had a fairly successful business, didn't he?
LAUREN SALZMAN: That's my understanding, yes.
MR. AGNIFILO: Do you know what kind of business it was?
LAUREN SALZMAN: I'm not a hundred percent sure.
MR. AGNIFILO: Do you know if he was involved in any sort of drilling?
LAUREN SALZMAN: Yes, some sort of construction or something.
MR. AGNIFILO: Okay. Sagitta, S-A-G-I-T-T-A, I think, does that ring a bell?
LAUREN SALZMAN: Vaguely.
MR. AGNIFILO: Okay.
LAUREN SALZMAN: But I knew he had a company and that he was certainly successful at one time, yes.
MR. AGNIFILO: He was a successful businessman?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Right. And here, this successful businessman is telling all these other people my daughter stole from me and she hacked into my Facebook account, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: That's what he's saying?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: So he obviously made arrangements for her to be safe in Mexico because he had an accountant that he's associated with meet her over the border, right?
LAUREN SALZMAN: Well, he had -- he made arrangements for her to be safely transported from the border to a city and then left.
MR. AGNIFILO: Okay, at a certain point, his twenty-something year old daughter was going to have to fend for herself?
LAUREN SALZMAN: With a $126, or $128, and no papers or identification or history in any way, when she had never fended for herself before, and had just been kept in a room for two years and left her entire family in Albany.
MR. AGNIFILO: Because that's the decision Hector, the father, made after his daughter stole from him and hacked into his Facebook account, right?
LAUREN SALZMAN: True.
MR. AGNIFILO: It says here: She had ten weeks to do three tasks while in Mexico. This is the father writing this.
First thing is earning her living down there. I gave her just 1660 pesos cash, around $128, and I paid for the bus ticket to . is a city in Mexico, correct?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Objection, Your Honor.
May we have a sidebar?
THE COURT: All right.
(Sidebar held.)
(Continued on following page.)
(Sealed sidebar concluded.)
(Continued on the following page.)
(In open court - jury present.)
THE COURT: All right, let's continue.
MR. AGNIFILO: Thank you, Judge.
EXAMINATION CONTINUING BY MR. AGNIFILO:
MR. AGNIFILO: So, Hector writes that the three things that she has to do is she has to earn a living -- he points out that he bought her a bus ticket, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: -- deliver the book report results, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And getting her USA visa. He says, I would pay the fees, but Dani needs to do the paperwork, correct?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: And I'm just going to show you the bottom of this. Let's see if I can see it. Okay.
And at the bottom, it says: KK -- that's Kristin Keeffe, right? I'm looking two lines from the very bottom.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: -- thinks she is still playing games, with little or no conscience. KK has proof that Dani hacked the Greathead account. KK had changed the password previously.
Right, it says that?
LAUREN SALZMAN: It says that, yes.
MR. AGNIFILO: Okay. Now we will go to the next exhibit, which is 1485. Also in evidence.
MR. AGNIFILO: Give me one second, Your Honor.
(Pause.)
MR. AGNIFILO: Okay, 1485 is already in. This is 1485-R, which is already in evidence.
It's rebooting.
THE COURT: It's rebooting. Just give it a moment.
(Pause.)
MR. AGNIFILO: All right.
THE COURT: Okay.
BY MR. AGNIFILO:
MR. AGNIFILO: 1485, 1485-R is already in evidence. It's a two-page document, here is the first page, and it's an e-mail string that starts on the second page, so we are going to start on the second page.
Now, this is an e-mail from Marianna, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: All right. And Marianna writes:
Thank you for -- thank you very much for the time and concern you've put into this situation. I will always be grateful with you for trying to help. I know this shouldn't be surprising, but it is. I had been hopeful that she would stop the games once given a harsh consequence, ex. been in Mexico. I feel extremely sad about her decisions. I feel sad for the way it will always affect her, the family, the people that love her, and the ones that look up to her. This is tremendous. I've been thinking all day about it and I really -- and I don't really know what to say.
So that's the first e-mail and that's from Marianna, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: The next e-mail is on the first page, on the bottom of it, and it starts -- it's from Kristin Keeffe, do you see that there?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Okay. And Kristin Keeffe writes, at 2/27/12, 11:14 p.m.:
I am glad I can be a help here. I really feel you guys are family to me. I, too, am shocked and saddened. I have not been able to change my e-mail account passwords from a different computer, so Dani is probably reading these e-mails. I suspect that is why we received the optimistic "I'm working, everything is good, but I don't have time to write more" e-mails today. She read my e-mail from this weekend laying out the specific data on her behavior, and is now trying to act like everything is fine.
It might be wise to ask her when she is sending her first book report while deciding how to address everything else. To my knowledge, she has not submitted a single complete, adequately-done book report in all these years. She said she would do one book report a week, yet today is the eighth full day since she submitted to us that is what she would do. She may not be capable of building value in an honest, straightforward fashion. This is a very important test.
That's what she writes, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And then you write, Monday, February 27th, 2012, so it's the same day, just a little later in the day:
Nonetheless, I think we should send an e-mail with the new conditions of satisfaction as soon as possible. Time is running out if we are going to make a five-week window to come back.
Now, what are you talking about in that e-mail? What five-week window to come back are you referring to?
LAUREN SALZMAN: I think initially she was given a certain time period that she had to complete her book report and get her papers to be able to, I guess, legitimately come back into the Albany NXIVM community and with her family.
MR. AGNIFILO: Okay. And the next e-mail that's sent is later that same day, almost midnight that same day, February 27th, from Kristin Keeffe, and she writes -- I'm sorry, the next one seems to be from Hector. The next one is from Hector. We're working our way up. And it says: I agree about sending her the new time window. Should I send her the draft KK wrote?
And then Kristin writes: Hector, did you send the draft to M, C and F?
Marianna, Cami and Fluffy, right?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: In it I think we should change the 72-hour window for the first book report to a 48-hour window.
Right?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: So Kristin is looking to narrow the window --
LAUREN SALZMAN: Yes, she is.
MR. AGNIFILO: -- from 72 hours to 48 hours?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And then Fluffy, the brother, writes: How do we know she hacked your e-mail accounts, KK? Could I meet with you to double check that?
Let me stop there for a second. Fluffy -- does Fluffy have any familiarity with sort of how to check if e-mail accounts have or have not been hacked, do you know?
LAUREN SALZMAN: I don't know, but -- not to my knowledge.
MR. AGNIFILO: I personally wouldn't want to shorten her time because of something that might not be so. I hope this makes sense. If she is still playing games, her consequences will come to her and it's just a matter of time.
Right?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: So what Fluffy is saying here is, to Kristin, how do you know that she's hacking your e-mail account?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: We don't want to punish her by shortening her book report window from 72 hours to 48 hours, so if she's not going to do what she's not going to do, what's the difference between 72 hours and 48 hours, in essence.
Right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And then you write:
Independent of the e-mail account, she has done nothing toward getting back since she left. She has no measurable output of work. She's made several requests that Hector do work to provide her with the things she could get herself, but hasn't tried, and instead she's reported in about satiating and entertainment.
Okay, now, when you say here she's been reporting in about satiating and entertainment, what are you talking about?
LAUREN SALZMAN: That she went to the carnival or the festival.
MR. AGNIFILO: In Mexico?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: All right. And what your point here is, e-mail account aside, even if she didn't hack into any e-mail accounts she's done nothing that she was supposed to do in order to get back and she's going off to the carnival. That's what you're saying here, right?
LAUREN SALZMAN: That's what I'm saying, but we came -- I mean -- I think I was not right about that. I did a lot of shitty things when I was in my twenties. It took me a long time to figure out how to get my shit together, and I just don't think it raises to the level of keeping her in a room for two years and then disowning her and sending her back to Mexico with $120. Like...
MR. AGNIFILO: How old were you in 2012?
LAUREN SALZMAN: (No response.)
THE COURT: What was the question?
MR. AGNIFILO: How old was Ms. Salzman in 2012?
LAUREN SALZMAN: (No response.)
MR. AGNIFILO: Take a moment.
LAUREN SALZMAN: I don't know. It's not because I'm upset; I'm dyslexic and really bad at math. Sorry.
MR. AGNIFILO: It's all right.
LAUREN SALZMAN: I just --
MR. AGNIFILO: Tell me whenever you're ready.
LAUREN SALZMAN: I'm ready, I just can't do the math right at this second.
MR. AGNIFILO: Okay, I won't ask you again. That's all right.
How old are you now?
LAUREN SALZMAN: Forty-two.
MR. AGNIFILO: Okay, I apologize for asking.
All right, so it's seven years ago. Okay, so it's --
LAUREN SALZMAN: Thirty-five.
MR. AGNIFILO: Thirty-five, all right. Okay, so just going back to the e-mail, all right, you go on to say:
She failed to submit a concise plan for her book reports or send anything that indicates she is making any effort towards getting back.
That's how you felt at the time, right?
LAUREN SALZMAN: But if you read the e-mails that she was sending at the time, she's telling us what she's spending her time doing trying to get back and I'm completely disregarding it. So she was doing efforts to try to get back, that I was saying, no, that's not it. No, that's not good enough. No, no. Like she was doing stuff.
MR. AGNIFILO: But that's not what you're telling her in these e-mails?
LAUREN SALZMAN: I know. I understand.
MR. AGNIFILO: Right. And these are e-mails that are coming to you, you're reading her e-mails, right?
LAUREN SALZMAN: (No response.)
MR. AGNIFILO: You have to answer yes or no.
LAUREN SALZMAN: Yes, I -- yes.
MR. AGNIFILO: You're reading the e-mails. You're thinking about how to respond and you're responding, aren't you?
LAUREN SALZMAN: That's correct.
MR. AGNIFILO: And what you go on to say is:
I believe she knows this. Given that this is part of her game, I think it's important that we impose a consequence so that she actually has to earn something in an expedited fashion versus spending nine more weeks game playing.
That's what you wrote?
LAUREN SALZMAN: That is what I wrote.
MR. AGNIFILO: And these are your words?
LAUREN SALZMAN: That's correct.
MR. AGNIFILO: 1486-R, also in evidence.
(Exhibit published.)
BY MR. AGNIFILO:
MR. AGNIFILO: It's the first page, we start at the bottom. This is -- this first e-mail is Daniella addressed to her father, right?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And she writes:
Papa, I don't have a book report now and 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.
Did you have an understanding that, in addition to a page limit, that there were certain -- I don't know, font limits or different -- when she's saying measurements, do you know what she's talking about here?
LAUREN SALZMAN: I'm not sure exactly what she was talking about. I knew Kristin had suggested they give her like a certain page number and certain numbers of words, so I just interpreted it as that, but I'm not sure what the measurement refers to.
MR. AGNIFILO: Okay. So she's saying here she is not going to have a book report done in 48 hours, right?
LAUREN SALZMAN: Correct, that's what she's saying.
MR. AGNIFILO: Now, Hector seems to forward this e-mail along and then we have a response from Kristin, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And Kristen responds, February 29th, 2012 at 7:20 in the afternoon to Hector, to yourself, to Adriana, Cami and Marianna, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And Kristin writes: Hi all. I think this is a total fabrication. Dani has been stealing and lying about book reports since before Gaelyn was born.
Gaelyn is the son that Keith and Kristin have, correct?
LAUREN SALZMAN: Yeah, that's correct.
MR. AGNIFILO: In all these years, she's 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 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 three times the minimum length, a 30,000 word report?
She goes on to say: She is such a liar, it takes my breath away. Dani was told she would be helped with visa processing money only, that she would have to do everything else on her own. I discussed this with her at least six different times in our last 16 hours together.
That's what Kristin writes.
And what Kristin's referring to here that she -- obviously, she accompanied Hector in driving Dani to the border, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And what she's saying in this e-mail is that these are some of the things we discussed with her as we were driving down to the Mexican border, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: I am going to go on. Next one is 1487, 1488.
So 1488-R already in evidence.
(Exhibit published.)
BY MR. AGNIFILO:
MR. AGNIFILO: We pick up at the bottom of that first page, with the e-mail we just looked at from Kristin where she says this a total fabrication, right?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And then you respond later that same day, February 29th at 2:57 p.m., and you say:
I'm in agreement with all of you, not one apology to anyone since she left. I think this is all game playing. 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 apprised of progress. Saying "I can do nothing" is a lie.
These are your words, correct?
LAUREN SALZMAN: Correct, they are.
MR. AGNIFILO: And so, you're agreeing. You got Kristin's e-mail, right, the one below?
LAUREN SALZMAN: Yes, I did.
MR. AGNIFILO: You read it, right?
LAUREN SALZMAN: I did read it and, I mean, as I said yesterday, there were a lot of things that she had done and she had been apologizing a lot the entire time she was in the room. There were lots of things that everything she did we shot down. So when she finally stops doing it, and we're like, oop, now you're not doing anything, I just -- I just don't agree with how I was looking at it at the time.
MR. AGNIFILO: But you way you were looking at it at the time, when you wrote this e-mail at 2:57 on February 29th, is you said you agree with everyone?
LAUREN SALZMAN: It's true, I did.
MR. AGNIFILO: You agreed with what Hector wrote, right?
LAUREN SALZMAN: That's true.
MR. AGNIFILO: You're agreeing with what Kristin wrote below, right?
LAUREN SALZMAN: Yes, it's true.
MR. AGNIFILO: All the string of e-mails that we just reviewed, you're agreeing with all of it?
LAUREN SALZMAN: I did.
MR. AGNIFILO: Your Honor, this would be a good time to stop for the lunch break. I am about to switch subjects.
THE COURT: All right, we'll take our lunch break.
All rise, please.
(Jury exits.)
THE COURT: The witness may stand down. Please do not discuss your testimony with anyone. We will take an hour for lunch.
(Witness steps down and exits the courtroom.)
THE COURT: I would like the court reporter in the robing room.
(Continued on the following page.)
(Continued on next page.)
AFTERNOON SESSION 2:00 p.m.
THE COURT: Bring the witness in, please.
(Witness resumes the stand.)
THE COURT: Let's bring in the jury.
(Jury enters.)
THE COURT: Please be seated.
You may continue your cross-examination, Mr. Agnifilo.
MR. AGNIFILO: Thank you.
THE COURT: 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:
CROSS-EXAMINATION BY MR. AGNIFILO (Continuing):
MR. AGNIFILO: Good afternoon, Ms. Salzman.
LAUREN SALZMAN: Good afternoon.
MR. AGNIFILO: You said on direct examination that Keith would use nicknames for different people.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you said one of the nicknames Marianna had the nickname "Monkey"?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And Dani was "BoBo"?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And Kathy Russell was "Ms. Kathy"?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Were these nicknames meant to hurt these people's feelings or were they good-natured?
LAUREN SALZMAN: I think they were good-natured.
MR. AGNIFILO: And a lot of people in the community had nicknames, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Back in the day, you guys had a lot of fun together, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You did a lot of things together. You would go to V-Week together, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you would take these courses together, right?
LAUREN SALZMAN: Yes, we did.
MR. AGNIFILO: And you all lived in different houses but pretty close to each other, right?
LAUREN SALZMAN: Yes, we did.
MR. AGNIFILO: And you had picnics and barbecues and played Frisbee, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: A lot of volleyball, right, in the middle of the night when the gym was cheaper to rent, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: All that stuff.
I just want to show you not too many but a handful of pictures.
MR. AGNIFILO: These have been given to the Government, 150.
I'm going to show it for a minute just to Ms. Salzman, and, if there's not an objection, we'll put it into evidence.
THE COURT: Are these on the Elmo?
MR. AGNIFILO: Yes.
THE COURT: They are not in evidence?
MR. AGNIFILO: Not in evidence, yet.
THE COURT: Okay.
MR. AGNIFILO: Ms. Salzman, I'm showing you Exhibit 150. It's a little glary. I don't know if I made it better.
Can you see who that is?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: That's you and who?
LAUREN SALZMAN: Pamela Cafritz.
MR. AGNIFILO: Your Honor, we offer 150 in evidence.
THE COURT: 150, is this a Government exhibit?
MR. AGNIFILO: Sorry, it's Defense 150, Judge.
THE COURT: Any objection?
MS. HAJJAR: No, your Honor.
(Defense Exhibit 150 so marked.)
(Exhibit published to the jury.)
MR. AGNIFILO: Let me see if I can get rid of the glare.
MR. AGNIFILO: That's Pam Cafritz, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Any idea where you are there?
LAUREN SALZMAN: Yes. This is New Year's in Fiji.
MR. AGNIFILO: How many times did you go to Fiji?
LAUREN SALZMAN: Twice.
MR. AGNIFILO: What were the reasons you went to Fiji; was it a work thing, a pleasure thing, both?
LAUREN SALZMAN: It was a social thing. Pam was diagnosed with cancer and wanted to go to Fiji and spend time with the people who were close to her.
MR. AGNIFILO: And do you remember who went on that trip with you and Pam?
LAUREN SALZMAN: A number of people went on the trip. The first trip was much more people, but, yeah, this was a smaller group.
MR. AGNIFILO: I'm going to show you another exhibit.
MR. AGNIFILO: This is not yet in evidence, Judge, Defense 151.
MR. AGNIFILO: Ms. Salzman, you're in that picture?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And there are a number of other people in the picture with you?
LAUREN SALZMAN: Correct, yes.
MR. AGNIFILO: Your Honor, we offer it as Defense 151.
MS. HAJJAR: No objection, your Honor.
THE COURT: Defense Exhibit 151 is received in evidence.
(Defense Exhibit 151 so marked.)
(Exhibit published to the jury.)
MR. AGNIFILO: And you're wearing the white blouse?
LAUREN SALZMAN: Yes, I am.
MR. AGNIFILO: Who else is that in the picture with you?
LAUREN SALZMAN: From left to right, Daniella Padilla, Nicki Clyne, Marianna, and Omar Boone.
MR. AGNIFILO: And this is Fiji as well?
LAUREN SALZMAN: This is Fiji.
MR. AGNIFILO: I'm going to show you Defense 152 for identification, not yet in evidence.
You're in that picture?
LAUREN SALZMAN: Yes, I am.
MR. AGNIFILO: And others are in the picture as well?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: We offer it as 152, your Honor.
MS. HAJJAR: No objection.
THE COURT: 152 is received in evidence.
(Defense Exhibit 152 so marked.)
(Exhibit published to the jury.)
MR. AGNIFILO: Who is in the picture?
LAUREN SALZMAN: Myself, Keith, Marianna and Nicki.
MR. AGNIFILO: Is that Fiji as well?
LAUREN SALZMAN: No, that's in Chacala.
MR. AGNIFILO: That's Mexico?
LAUREN SALZMAN: Mexico.
MR. AGNIFILO: Do you know when that was taken?
LAUREN SALZMAN: That was taken probably somewhere between January and March.
LAUREN SALZMAN: 2018.
MR. AGNIFILO: 2018?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And it's hard to tell, they're a little -- hold on. You might not be able to tell. There are little sort of partial heads there.
Any idea or no?
LAUREN SALZMAN: Keith and Marianna's son and Norma.
MR. AGNIFILO: And Keith and Marianna's son is which head?
LAUREN SALZMAN: On the right.
MR. AGNIFILO: Without the colorful head thing.
LAUREN SALZMAN: Correct. That's Norma.
MR. AGNIFILO: And who's Norma?
LAUREN SALZMAN: Norma was a teacher in Rainbow. In this case, I think she was Keith's son's nanny.
MR. AGNIFILO: I have two more pictures. This is Defense 153.
Do you see yourself in the picture there on the couch?
LAUREN SALZMAN: Yes, I do.
MR. AGNIFILO: And there's a number of other people in there as well?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: We offer 153, your Honor.
MS. HAJJAR: No objection, your Honor.
THE COURT: All right. Defense Exhibit 153 is received in evidence.
(Defense Exhibit 153 so marked.)
(Exhibit published to the jury.)
MR. AGNIFILO: And this is you right here?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And can you tell who is to your left?
LAUREN SALZMAN: Pam is to my left.
MR. AGNIFILO: And can you tell who is to her left?
LAUREN SALZMAN: Karen Unterreiner.
MR. AGNIFILO: And to Karen's left?
LAUREN SALZMAN: In the back is Michelle Hatchette, next to -- on the same couch as Karen is Loretta Garza.
MR. AGNIFILO: And can you see who is sitting in front of the couch right here?
LAUREN SALZMAN: Diane Goodman.
MR. AGNIFILO: And here, right here?
LAUREN SALZMAN: Danielle Roberts.
MR. AGNIFILO: And can you tell who is on this side?
LAUREN SALZMAN: Gabby Baker.
MR. AGNIFILO: And can you tell who that is?
LAUREN SALZMAN: Pam Cafritz.
MR. AGNIFILO: And that is?
LAUREN SALZMAN: Karen Unterreiner, Loretta Garza, Daniella Padilla.
MR. AGNIFILO: And that's your mom sitting pointing?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: And this is the Jness room?
LAUREN SALZMAN: Yes it is.
MR. AGNIFILO: Would this have been a Jness meeting?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you went to Jness meetings?
LAUREN SALZMAN: Yes, I did.
MR. AGNIFILO: And the last this series of pictures is Defense 156 for identification.
Ms. Salzman, you're in that picture?
LAUREN SALZMAN: I am.
MR. AGNIFILO: And you're with five other people?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: We offer it as 156, your Honor.
MS. HAJJAR: No objection, your Honor.
THE COURT: Defense 156 is received in evidence.
(Defense Exhibit 156 so marked.)
(Exhibit published to the jury.)
MR. AGNIFILO: Who are the people on either side of you, Ms. Salzman?
LAUREN SALZMAN: To the right as we're looking at it is Loretta Garza, next to her Daniella Padilla, and then my mother Nancy Salzman.
MR. AGNIFILO: On the other side?
LAUREN SALZMAN: On the other side, furthest left is Nicki Clyne, and next to her Kerstin Ohlander.
MR. AGNIFILO: I want to take you back for one second to 152, which is already in evidence.
You said the woman with the colorful thing in her hair is Norma?
LAUREN SALZMAN: I believe so, yes.
MR. AGNIFILO: Was she a teacher of Arabic in Rainbow?
LAUREN SALZMAN: Yes, she was.
MR. AGNIFILO: Do you know if Keith's son was learning Arabic?
LAUREN SALZMAN: I believe so.
MR. AGNIFILO: And Rainbow Cultural Gardens -- we've heard something about it, so I'm not going to ask too many questions about it -- was sort of a language and cultural emersion program for children.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And lots of different languages were taught in Rainbow, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And the idea was that kids would be exposed to different languages at a very early age.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And how did Rainbow sort of interface with the mission of NXIVM, generally?
LAUREN SALZMAN: That the idea was that the children would have very early experiences and, thus, experiential reference points to people -- people of different cultures and experiences of the cultures themselves through the people and, thus, when they became older they would be -- I think Keith called them, like, citizens of the world. They would have a deep experiential reference point from early childhood of many different cultures and feel a part of them personally and a love for each of them.
MR. AGNIFILO: I want to turn our focus, if I could, to DOS. You said that you were told not to tell the slaves you brought into DOS that Keith created DOS.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Fair to say Keith created every part of the NXIVM curriculum, correct?
LAUREN SALZMAN: Yes, he did.
MR. AGNIFILO: Keith was behind every creative idea in NXIVM; fair to say?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: It was Keith's idea, for instance, to create the women's group, Jness?
LAUREN SALZMAN: Yes, that's true.
MR. AGNIFILO: It was Keith's idea to create a Jness room, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Keith created every module?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And tell the jury what a module is.
LAUREN SALZMAN: A module is just -- the two-hour practice sessions subject specific in NXIVM were called modules.
MR. AGNIFILO: And Keith created them all in different topics.
LAUREN SALZMAN: Yes.
When we did DOS, he specifically instructed that we were to tell people it was not part of NXIVM, it was separate than NXIVM, so, thus, interpreted separate from anything NXIVM related.
MR. AGNIFILO: For the moment, I'm just going to ask this series of questions.
Keith created every piece of course work in NXIVM, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: He created everything. If something had creative content in ESP or NXIVM, Keith created it.
LAUREN SALZMAN: Yes, that's true.
MR. AGNIFILO: And there were different sort of companies within NXIVM, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Ultima and things like that, did Keith create those as well?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: So, he created all the companies also.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Was there any precedent within your group for someone to create something that wasn't Keith?
MR. AGNIFILO: So, now the -- and did you call it "DOS" or did you call it the "sorority"?
If you were discussing it two years ago, what would you have called it?
LAUREN SALZMAN: After it became public, we started referring to it as the "sorority."
MR. AGNIFILO: And before that, you would call it "DOS"?
LAUREN SALZMAN: Yes.
That was a specific distinction Keith made because we hadn't formally called it a sorority. Once it became public and we started referring to it as the sorority, on a technicality it was true that he didn't have affiliation with the sorority. But it wasn't true because he still had association with it after that point.
MR. AGNIFILO: DOS borrowed concepts that were well known in other areas of NXIVM, correct?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: Readiness was a well-known concept, right?
LAUREN SALZMAN: Yes, among the people who had done the men's program, yes.
MR. AGNIFILO: SOP is the men's program.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Readiness was sort of a well-known concept.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And readiness was created by Keith.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And everybody knew that.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Collateral was a well-known concept in NXIVM, right?
LAUREN SALZMAN: Among those who took the higher level intensives, yes.
MR. AGNIFILO: Long before DOS was created, the concept of collateral was something that if you took the higher level intensive, you knew about it.
LAUREN SALZMAN: Yes. It wasn't used in this way, but yes.
MR. AGNIFILO: In terms of the higher level intensive, how was collateral used?
LAUREN SALZMAN: Collateral was used to back your word in the higher level intensives. And specifically in ethicists, we started referring to it more.
Where if, for example, like, you failed at something or you breached your ethic, like, you failed to uphold some value that you held dear to yourself, you might take on some penance. And that penance was something that could be corrective in nature but that you would back that with some collateral.
MR. AGNIFILO: And just for the jury's benefit, the term "higher level intensives," what does that encompass?
LAUREN SALZMAN: What is that?
MR. AGNIFILO: Yes.
LAUREN SALZMAN: So, when you first come into ESP, there's a basic curriculum. And the basic curriculum is considered level one curriculum and it lays out a basic philosophical foundation and certain emotional practices and skill sets, et cetera.
And then after you take that, you can qualify for what I'm referring to in this case as a higher level intensive. So, it's an intensive that's based in having an understanding of the earlier concepts. So, you take the concepts and now you're going to apply them to a bunch of things.
MR. AGNIFILO: How specifically is collateral used in the higher level intensives?
LAUREN SALZMAN: In terms of building your conscience.
MR. AGNIFILO: And how?
So, we're not talking DOS here, we're talking about higher level intensives within NXIVM. How does collateral build one's conscience?
LAUREN SALZMAN: Because you care enough to uphold some sort of objective or value -- like, let's say I want to be a caring person. So, I'm going to collateralize and I think that being caring is being nonpunishing, for example. If I were to be punishing to you, it wouldn't be caring. So, if I were to punish you, I may take on some sort of penance.
And that penance could be maybe trying on how it feels to be you being punished by me so that I can feel what that's like. And my humanizing you would help me understand and think about how you're going to feel before I'm going to do it, but I back it with some kind of collateral.
So, if I actually were not to rectify that, not to humanize you and to continue to treat you in a nonhumanitarian way, maybe I give up something that I really like. It could be maybe spending time with somebody in my life that's really important to me, it could be not watching TV, it could be giving up sugar, but something that's painful or uncomfortable as a consequence because it's that important to me that I want to uphold it, that I'd be willing to give something up if I were to fail.
MR. AGNIFILO: And this concept of collateral in the context of higher level intensives was created by Keith.
LAUREN SALZMAN: It was, yes.
MR. AGNIFILO: How about the concept that strong commitments build character, is that something that was in the NXIVM curriculum?
LAUREN SALZMAN: It started to be and then more fortified through SOP.
MR. AGNIFILO: So before that concept, the idea that strong commitments build character --
LAUREN SALZMAN: And ethicists as well.
MR. AGNIFILO: So, not talking SOP for a second, just the basic NXIVM curriculum, what role did that concept play, the concept being strong commitments build one's own character?
LAUREN SALZMAN: That if you make a strong commitment, your ability to uphold that commitment against whatever unknown factors could come up. Like, at the time you make the commitment, you might not know how difficult it's going to be to uphold the commitment, but the strongest commitment you're going to uphold no matter what the adversity is.
So, building that strong commitment also involves going through certain adversities that you might not predict ahead of time, and going through those adversities and upholding the commitment makes you stronger to be able to uphold the commitment.
MR. AGNIFILO: Thank you.
And how did that concept change or grow or become different in the context of SOP?
LAUREN SALZMAN: In SOP, they started talking about more becoming somebody whose word could be depended on. If you have a strong commitment, then I can count on you and you have my back.
So, before that, it wasn't -- it was viewed more independently, like you having that for yourself, where in the concept of SOP it became that people who have that strong commitment are more reliable and we could count on each other to have each other's back, but, also, that men have that more than women and women are not reliable or don't have that strong character commitment.
MR. AGNIFILO: Many of these concepts, the concept of collateral, the concept of strong commitment, all of those were part of the sort of DOS -- not curriculum per se, but what made up DOS, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And the people who were in DOS would certainly have known that Keith came up with all of those concepts that were in DOS, correct?
MS. HAJJAR: Objection.
THE COURT: Sustained.
MR. AGNIFILO: Let me ask you a different question.
These same concepts, these concepts we've been discussing, were all staples of DOS; major, major elements of the sort of DOS protocol, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And did anyone else in NXIVM participate in creating concepts like collateral, commitment, other than Keith?
LAUREN SALZMAN: No, but the way that we spoke about DOS specifically redirected them to think that it was other things, like Bhakti yoga, for example, and brought in practices that we linked to yoga on a regular basis and other things.
So, there was a lot of, I think, effort and intentional effort to demonstrate that this was not -- we borrowed things from many places, we took things from many places, NXIVM being one of them. But there were many others that are outside of NXIVM and that we had just specifically gotten permission from Keith to use these tools.
But we were using them among many tools that have nothing to do with what we do in ESP, including things that are very mystical or nonmeasurable, which was very anti-ESP. ESP was very anti-nonmeasurement and nonmysticism.
MR. AGNIFILO: ESP was all about measurability?
LAUREN SALZMAN: Measurability and nonmysticism, yes. So, having this yoga focus, energy focus, shifted the way it was perceived in DOS.
MR. AGNIFILO: And nothing had ever been created, no company, no concept, no major project, by anyone other than Keith?
LAUREN SALZMAN: That's true. Not within the NXIVM umbrella.
MR. AGNIFILO: Now, the first-line DOS masters knew that Keith was in the creation of DOS because he created it along with some of them, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And that's -- one of the recordings that we listened to yesterday afternoon and this morning were part of how DOS was created.
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: And certain DOS members who were not first-line masters also knew Keith was involved in DOS; isn't that true?
LAUREN SALZMAN: Yes, that's true.
MR. AGNIFILO: And some of your slaves knew that Keith was involved; isn't that true?
LAUREN SALZMAN: Came to know.
MR. AGNIFILO: Came to know.
LAUREN SALZMAN: But I never validated it, but yes.
MR. AGNIFILO: And at least one of your slaves recognized the brand was Keith's initials.
LAUREN SALZMAN: That's true, and had a number of problems with it because her father -- well, her father was a rancher, and she said, Basically, this is what we do to the cows, is we brand them with our initials and it shows that they are our property.
And it became -- it was an issue for her.
MR. AGNIFILO: And the brand itself had looked like a big K, didn't it?
I can show you. I'll show you what's already in evidence --
LAUREN SALZMAN: Yes, but it was flipped on its side upsidedown.
MR. AGNIFILO: It's 429, already in evidence.
(Exhibit published to the jury.)
MR. AGNIFILO: I'm going to show you 429.
That's the brand, right?
LAUREN SALZMAN: On its side, yes.
MR. AGNIFILO: So, here it looks like a K.
Some people thought it was an A and M; is that right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And it's not, right?
MR. AGNIFILO: You heard many people say Allison Mack's initials are in the brand, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And that's just not true.
LAUREN SALZMAN: It's not true. I mean, as Keith said, you can creatively see many letters in there.
MR. AGNIFILO: But one of your slaves saw the K and the R.
LAUREN SALZMAN: Yes, she saw the K and the R because the slave stencils were mirror image upsidedown -- I mean the slaves' brands were mirror image upsidedown, but the stencil was the right way. So, when the stencil was laying on the table sideways, she saw KR, big K, little R.
But it's flipped on purpose so they wouldn't see what it was.
MR. AGNIFILO: I think you said on direct that it was sort of a mirror image. So, if you were looking in the mirror --
LAUREN SALZMAN: You could see it.
MR. AGNIFILO: You would see the K and the R in the mirror?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: But you would be at a different angle where it's harder to make that out if you were looking down at it.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Now, you had six slaves, right?
LAUREN SALZMAN: Yes, I did.
MR. AGNIFILO: Did Keith ever sleep with any of your slaves?
LAUREN SALZMAN: No, not to my knowledge.
MR. AGNIFILO: Did Keith have sexual contact, to your knowledge, with any of your slaves?
MR. AGNIFILO: Did that even come up as a possibility?
Did Keith ever mention anything to you about possibly having sexual contact with any of your slaves?
LAUREN SALZMAN: Only to the effect of saying that if I commanded Sarah to have sex with or have children with somebody other than her husband she had to do it, but he was not specific about it.
MR. AGNIFILO: Let me ask you about that.
There was concern about bringing married people into DOS, correct?
LAUREN SALZMAN: I came to learn that there had been debate over that before I joined.
MR. AGNIFILO: And the concern was that DOS involved this sort of supreme commitment, correct?
LAUREN SALZMAN: I don't know specifically what the concern was. I wasn't part of those discussions. They had them before I came.
MR. AGNIFILO: Well, in terms of --
LAUREN SALZMAN: But it starts to become problematic to me if you make a life commitment to somebody that you intend to keep, like a husband or spouse or partner, and then you create this supreme commitment that came after and that supreme commitment that comes after involves violating the first commitment, and we call it "building your word." That is certainly inconsistent.
MR. AGNIFILO: Keith never said that Sarah had to have sex with anybody other than Nippy, her husband, right?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: The conversation that you and he had about it was a theoretical conversation, given the fact that she was a married person, right?
LAUREN SALZMAN: It was a theoretical conversation. I don't know given that she was a married person, it's just something he said.
And the content is just interesting now with all the information that's become more public.
MR. AGNIFILO: In fairness, you had a major change in perspective between the time were you involved in DOS and as you're sitting here today.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Major.
LAUREN SALZMAN: Major.
MR. AGNIFILO: 180 degrees.
LAUREN SALZMAN: It's true.
MR. AGNIFILO: And to your knowledge, no married person was ever told or asked that they should have sex with someone other than their spouse.
LAUREN SALZMAN: I don't know.
MR. AGNIFILO: You don't know of it happening, right?
LAUREN SALZMAN: I don't know of it happening.
MR. AGNIFILO: And in terms of your slaves, the only married person was Sarah; am I right, or was anyone else married?
LAUREN SALZMAN: No, three of them were married and one was engaged and then later married.
MR. AGNIFILO: And none of them were confronted with a choice or a direction or a suggestion that they should have sex with anyone.
LAUREN SALZMAN: Correct.
But I didn't come to learn until after I was in the case that there was a secret sex portion of DOS, which I did come to learn, and I wouldn't have wanted to support that had I known that that's what it was, whether they were married or not.
MR. AGNIFILO: We're going to get to all the stuff that you came to learn.
Now, you testified that you used encrypted applications when communicating in DOS?
LAUREN SALZMAN: Yes, we did.
MR. AGNIFILO: And these were highly private matters; right, very private communications?
LAUREN SALZMAN: Yes, they were.
MR. AGNIFILO: You wouldn't want them out in the world.
LAUREN SALZMAN: Yes, that's true.
MR. AGNIFILO: And maintaining the privacy of these communications was very important to you and everybody at DOS; is that right?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: Were you concerned in part because in past years people had hacked into the NXIVM computer?
LAUREN SALZMAN: After DOS became public and -- we were concerned about that, yes.
MR. AGNIFILO: Okay. Because --
LAUREN SALZMAN: And specifically because, to my knowledge, someone had accessed even the NXIVM computer right after DOS became public in an unauthorized way and, also, because...
I mean specifically for me, because Mark Vicente was saying things to myself and Alex Betancourt at the time like he was concerned that his phones were tapped or his computers were hacked. So, Alex and I at the time were wondering if his concern was because that was something he was doing, because it wasn't something that we knew of that we were doing. So, we didn't understand why he would be concerned about it. His raising it as a concern caused us to be concerned.
(Continued on the following page.)
CROSS EXAMINATION BY MR. AGNIFILO: (Continuing)
MR. AGNIFILO: So you were concerned about these confidential communications being accessed by people who had no business knowing; right?
LAUREN SALZMAN: Yes, and also because somebody who worked for Allison took pictures, she thought took pictures off of her computer when she wasn't authorized to do it.
MR. AGNIFILO: This is someone else in DOS?
MR. AGNIFILO: Someone else in NXIVM?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Okay. Gained access to Allison Mack's computer and removed content from her computer?
LAUREN SALZMAN: That's what Allison told me. Allison believed she took photographs of things on Allison's computer, which she wasn't authorized to be using Allison's computer.
MR. AGNIFILO: And one of the things you talked about was a concept of readiness. You talked about that quite a bit on direct examination.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Now, were the readiness drills meant to punish people?
LAUREN SALZMAN: I don't believe readiness was designed to punish, no.
MR. AGNIFILO: Readiness wasn't designed to make people exhausted and weak?
LAUREN SALZMAN: I don't believe that was the intent of readiness, to make them exhausted and weak, no.
MR. AGNIFILO: You wouldn't want exhausted, weak members, right?
That wasn't the point of DOS, to make them exhausted and weak?
LAUREN SALZMAN: I don't think the point was to make them exhausted and weak. I think through the work that they were doing, I certainly was doing -- I mean, with the book work and different things and doing all the other jobs and the things in DOS, I was exhausted a lot of the time.
MR. AGNIFILO: It was a demanding program?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Okay. It was meant to make people stronger; correct?
LAUREN SALZMAN: That was the theory, yes.
MR. AGNIFILO: Right. And readiness was all about preparedness; correct?
LAUREN SALZMAN: That was my understanding.
MR. AGNIFILO: And being responsive; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Being part of a well-oiled team that could mobilize quickly on literally a moment's notice?
LAUREN SALZMAN: Yes, and about making this the highest priority.
MR. AGNIFILO: Right. And DOS and NXIVM existed in parts of the world that weren't always safe, like parts of Mexico?
LAUREN SALZMAN: Yes, that's true.
MR. AGNIFILO: And both DOS and NXIVM had strong presences in Mexico; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you testified on direct examination that kidnappings were a very real concern for the folks living in Mexico?
LAUREN SALZMAN: That's true.
MR. AGNIFILO: And, in fact, some of the people in DOS were personally impacted by kidnappings?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And readiness was an important principle, important practice so that people could mobilize on a moment's notice and be able to respond to situations that could be emergent?
LAUREN SALZMAN: That's what it was meant to do, yes.
MR. AGNIFILO: And you testified on direct that readiness was put in motion in regard to someone who was missing in Europe?
LAUREN SALZMAN: Yes, this happened.
MS. HAJJAR: Objection, Your Honor. May we have a sidebar?
THE COURT: All right.
(Sidebar held outside the hearing of the jury.)
(Continued on the next page.)
(The following occurred at sidebar.)
THE COURT: What is the objection?
MS. HAJJAR: Your Honor, the witness was very clear there are two types of readiness: SOP readiness and readiness in the context of DOS. She has described them differently and the distinctions between them.
Counsel's question is asking about readiness without qualifying which one and I worry it's giving the witness, or misleading the witness because it sounds like -- we are talking about DOS readiness at times and then we are talking about SOP readiness at times.
The witness has been very clear these are distinct things and I don't want there to be any confusion about which one she's talking about when she talks about connecting to Mexico.
MR. AGNIFILO: First, this is an issue for redirect if she wants to go there. This was all covered on direct examination. She brought up the situation in Europe. It was -- you know, I'm just following up on the question.
MS. HAJJAR: Counsel can ask, but if it's confusing or misleading because it conflates two different types of readiness, we would just ask that the questions be posed in such a way as to make clear what she's talking about.
MR. AGNIFILO: I'm going to make this distinction in about two minutes, that DOS was sort of a hypervigilant readiness where people can go dark. So I'm getting to all that.
THE COURT: So why don't you make it now and let's solve the problem.
(Sidebar concluded.)
(Continued on the following page.)
THE COURT: All right.
MR. AGNIFILO: Readiness was a concept that started SOP; correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And while readiness was in SOP, do you recall if that's when this situation was going on with Europe and readiness helped find someone who was missing in Europe?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And do you know of another situation in Mexico where someone was having an issue with Mexican police and the SOP guys put out a readiness alert and they responded to the situation and brought peace to what could have been a dangerous situation?
LAUREN SALZMAN: That's what I heard, yes.
MR. AGNIFILO: And, now, the concept of readiness as it existed in SOP was incorporated and kind of magnified in DOS; is that fair to say?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And one of the differences was that in SOP the men had to all be ready all the time except they could, as they say, go dark from time to time?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: In other words, I'm -- I don't know, I'm --
LAUREN SALZMAN: Unavailable.
MR. AGNIFILO: I'm in the middle of a trial. I'm not ready. I'm not going to get back to you in a minute; correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And in DOS, you couldn't go dark; right?
LAUREN SALZMAN: Very rarely.
MR. AGNIFILO: It was sort of a higher -- to go dark, it had to be really something -- really, really an emergency?
LAUREN SALZMAN: Yes. And also in SOP the people chose to be in readiness, where in DOS you are in a collateralized vow of obedience and put in readiness.
MR. AGNIFILO: Right.
And just to be clear, having one's collateral released in DOS was not hitched to lack of readiness, right? If you weren't ready, you'd get a penance?
LAUREN SALZMAN: That's how we used it.
MR. AGNIFILO: The penances could be a cold shower; right?
LAUREN SALZMAN: Yes. But I could see how if somebody believed they were in a collateralized vow of obedience for life and weren't being obedient when they were told to be ready, that they might be afraid of that.
MR. AGNIFILO: Okay, but I'm just going to ask you how you actually used it. I'm not going to ask you anything about what somebody might be afraid for the time being. All right.
So, there were readiness problems all the time in DOS; right?
LAUREN SALZMAN: They were readiness problems, yes, all the time in DOS.
MR. AGNIFILO: Right. Did you ever say to one of your slaves you weren't ready, I'm releasing your collateral?
LAUREN SALZMAN: No, I never said that.
MR. AGNIFILO: To your knowledge, did anyone ever say --
LAUREN SALZMAN: But I did say to them if you guys don't get your shit together it affects my life and, like, I can be locked in a cage. I said that.
MR. AGNIFILO: Okay. And that is an extreme penance, but it's not the release of collateral; correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: So the penances could be sort of anything you guys wanted them to be, fair to say?
Let me ask you a different question. Some of the penances were cold showers, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Might have to go outside when it's cold?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Stand in the snow?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Then at some point paddling came into this; right?
LAUREN SALZMAN: Yes, and then it became -- I mean, Keith spoke about it on many occasions: The most committed people do this, the most committed people do this. And having Keith above you saying the most committed people are going to do the dungeon stuff, that affects you in a certain way.
And having me above people, when they looked at me as somebody who was most committed and head of not only promotions in ESP, but a high rank and somebody who is respected and had a lot of -- they cared about my opinion and that I thought that they were most committed affect their decision to do those things.
MR. AGNIFILO: Can I ask you a question? Did I ask you that?
I was going through different collaterals, right. I didn't ask you anything yet about cages or anything; right? Do you agree with me?
LAUREN SALZMAN: Not specifically.
MR. AGNIFILO: So why did you just say that?
LAUREN SALZMAN: Because I believe a lot of mistakes were made and unfortunately I think some of those mistakes were criminal, and I think that's why we're here, and I think trying to legitimize that nothing bad happened, it isn't true that nothing bad happened.
MR. AGNIFILO: Can I get back to asking you the different types penance?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: So people would do planks; right?
LAUREN SALZMAN: That was a type penance, yes.
MR. AGNIFILO: You know, you've got to go on your arms and keep your body parallel to the ground for a minute or two minutes, or whatever it is; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Now, I want to --
LAUREN SALZMAN: Paddling.
MR. AGNIFILO: Right. Right.
THE COURT: I'm sorry, I missed that.
LAUREN SALZMAN: Paddling.
MR. AGNIFILO: Paddling. We're going to get to that in a minute.
I want to talk about acts of care. You said one of the things that a slave in DOS would do would be acts of care for the master; correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: Did you have an understanding that part of the purpose of an act of care was to build character in the slave?
LAUREN SALZMAN: I was told that it was to learn to care.
MR. AGNIFILO: To learn to care for someone other than yourself?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And in this case, caring for your master?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You said some of the acts of care were -- would be sometimes go -- if you're going to the grocery store, do you need anything?
LAUREN SALZMAN: Sometimes.
MR. AGNIFILO: And things like that?
LAUREN SALZMAN: Well, and things way beyond that, but yes.
MR. AGNIFILO: Like what else?
LAUREN SALZMAN: Like Amanda was doing legal research for me. Jimena was creating sales protocols for DOS. Those are much higher level things.
MR. AGNIFILO: Right. And one of the principles was that you should try to do things at the highest level that you can?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Right. And I think the analogy you used is you wouldn't kind of -- if you have a lawyer, you wouldn't have them kind of like sweeping the street?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And that was part of the idea?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And these things -- I mean, part of the reason for doing these things is to teach the person doing them to care for someone other than themselves?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Now, you said that Keith wanted to recruit for DOS outside of NXIVM?
LAUREN SALZMAN: He did.
MR. AGNIFILO: He didn't just want NXIVM people in DOS; he wanted other people in DOS as well?
LAUREN SALZMAN: That's correct.
MR. AGNIFILO: And he didn't want DOS to be just another division within the NXIVM, I think that's what you said?
LAUREN SALZMAN: I don't know if I said it like that, but he wanted people outside of NXIVM.
MR. AGNIFILO: All right. And I think you said a couple of times that Keith wanted powerful and influential women in DOS?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And I think we even listened to the tape this morning where he says that, correct?
LAUREN SALZMAN: Uh-hum. Yes. Correct.
MR. AGNIFILO: All right. And he told you that he wanted people who were in DOS who could make DOS an influential force and grow?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And he wanted DOS to be possibly something that influenced policy one day?
LAUREN SALZMAN: Yes, I believe that. He said that.
MR. AGNIFILO: And he said he wanted DOS to be something that might even play a role in elections; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And DOS was -- he would also say that DOS was going to outlive him; correct?
LAUREN SALZMAN: I don't know. I never heard that statement.
LAUREN SALZMAN: But I heard the political things.
MR. AGNIFILO: That DOS was going to be possibly thousands or hundreds of thousands of people one day, did he ever say that?
LAUREN SALZMAN: Yes, that he wanted it to be that big.
MR. AGNIFILO: Right. And that DOS would kind of take on a life of its own? Did he ever sort of use that phrase, that I want DOS to take on a life of its own, just do whatever it is that it's meant to do?
LAUREN SALZMAN: I didn't hear that, but he did want a large number of people.
MR. AGNIFILO: And this was going to all be women, correct? The people that were recruiting into DOS were all women?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: So fair to say he wanted this to be a powerful, influential group of women for women; correct?
LAUREN SALZMAN: I do think he wanted a powerful union of influential women. There was a lot of theory of women for women.
MR. AGNIFILO: Theory of women for women? I just didn't hear what you said.
LAUREN SALZMAN: Yes, the theory of women for women.
MR. AGNIFILO: And he talked about it being a group that could kind of champion women's rights; correct?
LAUREN SALZMAN: Theoretically, but a lot of it came after it was exposed.
MR. AGNIFILO: And but even before it was exposed, he was talking about DOS possibly one day having political influences?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Okay. He talked about that on the tape this morning; right?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And at the time you believed in all this; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: I mean, I understand -- we're going to talk about that there was a change in perspective, but back in 2017, 2018, you believed this was a good thing?
LAUREN SALZMAN: I believed in the theory of it and the theoretical things we're discussing I believed were good, yes.
MR. AGNIFILO: Okay. You believed you could be involved in building something wonderful and important?
LAUREN SALZMAN: That's why I did it, because I wanted to do something that was good and important.
MR. AGNIFILO: Right.
LAUREN SALZMAN: And I wanted to grow.
MR. AGNIFILO: So you could do both things at the same time; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Grow as Lauren Salzman, right, through DOS?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you could also almost be part of history as this thing grows, this group of women, which seems to have never existed?
LAUREN SALZMAN: I mean, I wasn't thinking about it that way, but I specifically did want that and I chose women who could do things and were influential, at least within my sphere of influence and mine community and organization because I thought we could do good things together.
MR. AGNIFILO: You chose very capable people; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And when you chose them, you chose them to help you, to help them and to help DOS; correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: I want to talk for a little bit about the branding. The first person to ever discuss the branding with you, was that Rosa Laura?
LAUREN SALZMAN: Yes, it was.
MR. AGNIFILO: And at the time she was one of your best friends; correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You loved her?
LAUREN SALZMAN: Yes, I did.
MR. AGNIFILO: And --
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You could tell she loved you?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And she said to you that the branding was a way to symbolize overcoming pain for principle; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Now, was that a concept that had particular meaning for you?
LAUREN SALZMAN: Yes, it was.
MR. AGNIFILO: Tell the jury why that is.
LAUREN SALZMAN: I mean, I taught that concept as a principle within the curriculums that I taught. There was a specific curriculum called human pain, which is all about taking on pain, and we know the depth of our love through the pain that we take on, and I believed in that, but also the -- I really believed that in order to teach that and to be non-hypocritical and integrity with myself and the position that I was in that I had to live those principles, that I couldn't teach principles that I wasn't living.
And in my life -- and my life with Keith up until that point, there were many things that were difficult for me that I did on an ongoing basis, including the pictures that you put up where I'm appearing very happy and getting myself happy but in situations that were very counter to what I wanted for myself in my life and I was constantly making a practice to go into those situations and do things that were counter to my own interest to build this capacity for love in myself, that if I went and spent time with Keith and Marianna and their child and was happy there even though I was without that in my own life and I could watch that from the outside, the amount of pain that I felt over that, or hurt or disappointment or whatever, would help me become stronger, because I was willing to just uphold the principle of love for the sake of love and not because of anything beyond that.
And even part of my joining DOS was to prove that I was somebody who was willing to do whatever it took to uphold these principles and that all of the things that I had traded for all of the things that I had been promised was worth it somehow and I got in over my head honestly.
MR. AGNIFILO: Okay. And you wanted to be branded; correct?
LAUREN SALZMAN: I wouldn't say I wanted to be branded per se, but I ... I wanted to do what it took to be part of this group and to prove to Keith that I was the kind of person who was committed to growth and committed to him, and if branding is what it took, then I wanted to do that.
MR. AGNIFILO: Rosa Laura told you that you'd be a slave along with others and that the slaves share everything?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And that's an idea that appealed to you at the time; correct?
LAUREN SALZMAN: It was an idea that appealed to me at the time and at the time also Keith had told me that the idea was that I would always be part of this group and -- which in the tape you hear that they're deciding that there are going to be seven people in the circle because there are seven people in the group, so the idea was not really that I would always be part of it.
And when I got into the group and Rosa Laura was like this is amazing, you're going to love this, it's going to be great, all of a sudden I started realizing very real problems that all of them were having with the group and with the things going on in the group. So they enrolled me telling me something that was great, that they were all going to share and it was going to be wonderful, but that wasn't what they were experiencing and I think there was good reason also for them to suspect that I would have problems as well and that wasn't discussed ahead of time.
MR. AGNIFILO: So at one point you had a conversation with Allison Mack?
LAUREN SALZMAN: I had many conversations with Allison Mack, I'm sorry.
MR. AGNIFILO: No. Specifically, I think what you said on direct is you had some concerns about DOS and so you were asked to, or chose to speak to Allison Mack about DOS. Do I have this right?
LAUREN SALZMAN: I don't recall that.
MR. AGNIFILO: Allison was kind of really positive on DOS and so you had a conversation?
LAUREN SALZMAN: When I found out that Marianna was pregnant, I called Allison and said -- I don't know if that's what you're referring to.
MR. AGNIFILO: Go ahead. You say it.
LAUREN SALZMAN: We may have discussed it, but I called Allison and said I need you to remind me why I'm doing this, because basically I'm not okay with what just happened, which is I was enrolled in a collateralized vow and then afterwards told Monkey was pregnant when that was something that had been known for months and I thought it was wrong.
MR. AGNIFILO: Right. So the reason you called Allison is because you found out Marianna, Monkey, was pregnant?
LAUREN SALZMAN: Yes. And not because I found out Monkey was pregnant, because Keith invited me to DOS under the belief that he wanted to bring our relationship closer, which he knew to me didn't mean just knowing the secrets of who else he's having relationships with or the sorority and that -- and didn't share with me at the time that Marianna was pregnant, so got me to agree to stay in a collateralized life vow forever under the auspice of growth and building my word and then dropped the bomb about Marianna. And, so, it wasn't just that Marianna was pregnant; it called into question who Keith was to me.
MR. AGNIFILO: Understood. Did you think Keith in a million years would release that the collateral to hurt you?
LAUREN SALZMAN: I think that Keith would do what Keith thinks is right or ethical according to Keith. I don't think -- and if he thought the ethical thing to do was to release the collateral, he would do it.
I mean, when people left, he discussed whether we should release collateral and we decided not to commensurate with -- that it would look -- I mean, we decided not to and discussed that it would look bad to release it because it would validate the allegations that were being made. So I do think if the circumstances were different and those allegations weren't made, he might have released it. He was talking about building a craft of people who learned specifically how to release it and the ways to do that and the ways to make it look like we don't know where it came from.
MR. AGNIFILO: No collateral was ever released, not one time, not one piece?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: Ever?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: All the people that left DOS, not a single piece of collateral was ever released; correct?
LAUREN SALZMAN: Correct, but as far as I know only one person left DOS before it everything became public.
MR. AGNIFILO: Yes. And that person left before May 17th, before everything became public; right?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And that person's collateral wasn't released?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: Now, your own branding, who were you with?
LAUREN SALZMAN: I was with everybody in my circle except Allison. So Rosa Laura, Monica, Loreta, Daniella, Nicki, and Cami.
MR. AGNIFILO: And you said in the past that it was a bonding experience that you had with these other women. Is that true?
LAUREN SALZMAN: Based on what I was believing at the time, I did experience that, yes.
MR. AGNIFILO: So I'm only asking you your belief at the time. I mean, as it was happening, you are being branded in the presence of these other women, you felt close to them?
LAUREN SALZMAN: I felt close to them believing that they wanted to be with me and that they chose me and they had always wanted me to be with them, not that they're in a vow of obedience, that when Keith told them -- if Keith told them to enroll me, whether they wanted me there or not.
MR. AGNIFILO: But you -- at the time, when you were all together, you believed that it felt like a bonding experience to you?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Now, in terms of your own slaves, everyone was bonded -- branded, I'm sorry, on the same day; correct?
LAUREN SALZMAN: The five who were branded were branded on the same day; correct.
MR. AGNIFILO: The five were branded on the same day. And the order, it is Jimena was first, Audrey was second, Sara was third, Carola was fourth, and Amanda was last?
LAUREN SALZMAN: I believe so, yes.
MR. AGNIFILO: You said at one point there was a break because you got a text message or something?
LAUREN SALZMAN: Correct. Keith called a meeting of the first-line DOS masters, so there was a break.
MR. AGNIFILO: And I think one of the women was breast-feeding an infant and had to leave?
LAUREN SALZMAN: She went home to go do that.
MR. AGNIFILO: Who was it? Who went home?
LAUREN SALZMAN: Carola.
MR. AGNIFILO: Do you know when that happened? In other words, was it between Jimena and Audrey or between Audrey and Sara?
LAUREN SALZMAN: I don't recall whether it was between Jimena and Audrey or Audrey and Sara, but I thought Jimena went first and then we took the break. I'm not sure if we got through one or two before the meeting.
MR. AGNIFILO: All right. The way you remember it is that Jimena is branded. And I think what you said on direct is that Amanda had a very strong reaction, and what I mean by that is she was screaming?
LAUREN SALZMAN: Yes. Yes.
MR. AGNIFILO: She's being branded and she's screaming; right?
LAUREN SALZMAN: Yes, she was being branded and screaming.
MR. AGNIFILO: All right. Before the branding, a stencil is put on the place where the brand is going to go?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: For each of the women under you, that was in that hip area; correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: So, at that point, everyone in that room knew they were going to be branded?
LAUREN SALZMAN: They did know that they were going to be branded, yes.
MR. AGNIFILO: So there was no -- no one thought they were going to get a tattoo and all of a sudden they're held down being branded?
LAUREN SALZMAN: Correct. They all knew they were being branded.
MR. AGNIFILO: Not only that, after watching Jimena, everyone would have known this is painful?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Because there was no doubt that Jimena was reacting to experiencing pain; right?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And then after the Jimena branding, there is a break, right? Because Carola goes home to breast-feed her infant. You have to respond to a meeting. Now, at some point there's dinner; right?
LAUREN SALZMAN: The dinner was before we got to the branding ceremony.
MR. AGNIFILO: So this is --
LAUREN SALZMAN: We only had one break when I left.
MR. AGNIFILO: So this is what, about an hour long break between --
LAUREN SALZMAN: Yes, about an hour long. 45 minutes to an hour, yes.
MR. AGNIFILO: Okay. And everybody goes through with their brandings?
LAUREN SALZMAN: They did, yes.
MR. AGNIFILO: Now, I think you testified on direct --
LAUREN SALZMAN: But also -- I mean, Jimena, in the middle, said I don't want to do this, I don't want to do this, I want to stop, and I said you can't stop.
MR. AGNIFILO: She's the first person to go?
LAUREN SALZMAN: Uh-hum. Yes. So ... I did tell them they can't stop.
MR. AGNIFILO: After the branding had started?
LAUREN SALZMAN: After it had started.
MR. AGNIFILO: Right. And during the branding, Carola -- was it Carola who noticed that it was K and R?
LAUREN SALZMAN: She noticed it during the stenciling.
THE COURT: What did she notice.
LAUREN SALZMAN: She noticed, when we were laying out the stencils, that it was Keith's initials, KR.
MR. AGNIFILO: Now, you said that there was -- and all these brandings were videotaped?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And you believe some of the videotapes are somewhere in Mexico?
LAUREN SALZMAN: Well, I don't know -- I don't know if they were in Mexico or left here in New York. The people who had the videotape went to Mexico. Sara's branding, I left on a hard drive in Mexico.
MR. AGNIFILO: I was going to ask you about Sara's branding.
LAUREN SALZMAN: Yeah.
MR. AGNIFILO: And Sara's branding was videotaped as well; correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And then there was some talk, you testified on direct, of possibly releasing Sara's videotape to a reporter or to the media; correct?
LAUREN SALZMAN: That's correct.
MR. AGNIFILO: And that's because Sara was making public statements misrepresenting the branding; correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: She was saying that she was held down against her will; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: She was saying she didn't know she was going to be branded; right?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Objection, Your Honor.
THE COURT: Sustained.
MR. AGNIFILO: So, just in your own words, why were you going to release the video? I mean, because you said on direct examination you were going to release the videotape because of inconsistencies, and I'm asking you just to follow up on what you said on direct.
LAUREN SALZMAN: To ... show areas of positivity and consent and discredit Sara's allegations.
MR. AGNIFILO: Okay. And these were allegations made to, among other places, the New York Times?
LAUREN SALZMAN: Yes. Correct.
MR. AGNIFILO: There was a prominent New York Times article on this topic; correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you believed that what Sara had told the New York Times was false?
LAUREN SALZMAN: I believed aspects of what Sara told the New York Times were false.
MR. AGNIFILO: And at the end of the day, you guys decided that you would not release the videotape of Sara's branding to the media?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And none of the videotapes of the brandings, to your knowledge, have ever been released to anyone?
LAUREN SALZMAN: Yes. And we didn't release them because we didn't want it to be seen as collateral and that it was release of collateral. We didn't want anybody to be able to say that we had released collateral. It's on purpose that we didn't release it.
MR. AGNIFILO: Right. And so none of it has ever been released?
LAUREN SALZMAN: Uh-hum. Correct.
MR. AGNIFILO: I want to ask you a couple questions about what you call the sorority house on direct examination, the DOS house, sorority house. Rosa Laura bought the house?
LAUREN SALZMAN: That was my belief, that Rosa Laura bought the house and put it in the trust. But I don't know specifically. I didn't see any of the paperwork on it.
MR. AGNIFILO: It was a house on Milltowne Road?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: It was the idea that the first-line DOS people would maintain the house, pay to maintain the house?
LAUREN SALZMAN: That's what I was told. I think it was decided before I came and -- so then they bought the house and I was grandfathered into that.
MR. AGNIFILO: Okay. And I think you testified about an invoice. It is Government Exhibit 853 for certain sex toys and others things that were purchased by Dani Padilla; correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Do you know if Dani Padilla was into that kind of stuff?
LAUREN SALZMAN: I don't know. We had never discussed it outside of the context of DOS.
MR. AGNIFILO: Did she say in the context of DOS that she was into that kind of stuff?
LAUREN SALZMAN: We didn't really discuss it like that, more like she -- I mean, she was the one researching it, so I assumed she was into it.
MR. AGNIFILO: You didn't pay for any of it; right?
LAUREN SALZMAN: No, and I never researched things like that either.
MR. AGNIFILO: So Dani Padilla did the research; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Dani Padilla paid for it; right?
LAUREN SALZMAN: Yes, as far as I know.
MR. AGNIFILO: No one hit you up for hey, you're one-eighth share is something, right? No one asked you for a contribution?
LAUREN SALZMAN: No, but I have reason to believe that I would have been because that's what happened with other things.
MR. AGNIFILO: Right, but no one ever asked you --
LAUREN SALZMAN: Like they wanted the branding thing and we were asked to all contribute, you know, the branding machine. Before I joined, we were asked to contribute to that.
MR. AGNIFILO: But no one ever asked you to contribute to this?
MR. AGNIFILO: Do you know if Dani Padilla wanted these things for her own reasons?
MS. HAJJAR: Objection.
THE COURT: Sustained.
MR. AGNIFILO: Do you know why Dani Padilla researched these things and then paid for them and bought them to have under an invoice with her name?
LAUREN SALZMAN: She told me that they were for the dungeon, because when things went public, she said these things she ordered for the dungeon and thank God that they hadn't arrived yet and she was going to cancel them because she didn't want it to become public that we were making a dungeon.
MR. AGNIFILO: Did you and -- I'm sorry. Pardon me for asking a personal question. You and Keith never engaged in BDMS?
LAUREN SALZMAN: Correct, we did not.
MR. AGNIFILO: Did Keith ever tell you or ask you or suggest to you that you and he engage in BDMS activities?
LAUREN SALZMAN: Not outside of DOS.
MR. AGNIFILO: Now, how did paddling become a form of penance?
LAUREN SALZMAN: I think they were doing it before I got there, so I was grandfathered into that as well.
MR. AGNIFILO: All right. I am going to ask you a couple of questions about the DOS book. I think it's Exhibit 1404. It is already in evidence. So this is Government Exhibit 1404. I'm going to ask to use the ELMO, which I guess I can use. All right.
And just very quickly before we look at a few pages of this, you played some role in the editing and creation of the DOS book; right?
LAUREN SALZMAN: The editing of the DOS book.
MR. AGNIFILO: And the DOS book was supposed to be kind of the philosophies behind DOS, why there's DOS, how it works, why it is the way it is; correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: All right. So we are just going to take a look at this one section here. Under desire it says -- we are starting I think six lines down. "Some might say, oh, my highest value is civilization, but they sit on the couch all day long, so really comfort is their highest value. And they say well, I can't do anything about civilization but how much have they thought about it. Well, a little bit. And I just came to the conclusion I couldn't do anything. That's not making civilization your highest value. That's making comfort your highest value. Excuses your second highest value and civilization at best third.
Is this sort of outlook, you know, this sort of anti-laziness, go out and make things happen outlook kind of part of the overall DOS philosophy?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And DOS was a clearly demanding protocol? It was a tough program; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: A couple things. This is another passage from the book here. Master. It says, Your master is actually a very complex thing. Your master starts out as, like in yoga, your guru, your God, you're whatever it is as a person, the person through which you took the vow, but it becomes something much deeper. When you internalize that person, it is that person with you as you and you as that person.
Does that mean anything to you in the context of the master/slave relationship?
LAUREN SALZMAN: It's difficult for me to say because my relationship with Keith was very much like that before the master/slave relationship.
(Continued on following page.)
EXAMINATION CONTINUES BY MR. AGNIFILO:
MR. AGNIFILO: Meaning that you felt sort of devoted to him, committed to him that way?
LAUREN SALZMAN: And that everything I was doing I was -- I always had the filter of how is Keith gonna think about this? Is Keith gonna think this is good? Is Keith gonna think this is balanced? Is this gonna be a problem? Is this something that's healing? Is this something that's fixing? It was something that I carried around with me all the time.
MR. AGNIFILO: Now, you mentioned -- you mentioned before that DOS took on elements of yoga, and here it is, yoga is mentioned in this passage we just read, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Yoga was also the focus of like exo-eso and Ultima as well, am I right?
LAUREN SALZMAN: Well, it was a physical curriculum, but it had elements of -- like ESP in it, in terms of breaking things down into like physical, emotional and thought components and then separating a sense of self from those components through a physical practice.
MR. AGNIFILO: And you said, I think on direct examination, that you were describing the DOS book to your slaves at some point?
LAUREN SALZMAN: Yes, I read them parts of it.
MR. AGNIFILO: Right. And did you suggest to them that Keith had a role in creating the DOS book?
LAUREN SALZMAN: I told them that there was a supreme master and that if we had -- at the time I read them the book I told them there was a supreme master and that if we met our enrollment requirements, we would qualify for additional education.
So I alluded to it, I didn't tell them that.
MR. AGNIFILO: And the supreme master that you had in mind was Keith?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Right. I mean --
LAUREN SALZMAN: Keith was the supreme master.
MR. AGNIFILO: Right. But you didn't say the supreme master Keith --
LAUREN SALZMAN: Correct.
MR. AGNIFILO: -- to your slaves?
LAUREN SALZMAN: No, I didn't.
MR. AGNIFILO: But you were suggesting, were you not, that Keith had a role in creating the DOS book?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: The next page, continuing where we just were.
(Exhibit published.)
MR. AGNIFILO: You come to your master and people come to you as a master because their values are scrambled, in disarray. They recognize this and they want a unification.
Okay, unification is sort of a big concept in NXIVM, correct?
LAUREN SALZMAN: Yeah, I mean I can explain it if you --
MR. AGNIFILO: Yes, please.
LAUREN SALZMAN: Well, I think also the way that it's talking about in here is that, like, we have different values conflicts. Like sometimes I want something, but I just feel a different way, or -- so I don't end up doing the thing I want; or something that I think might be like really good that I want to do I can't follow through on. So I'm -- there's a disconnect between my body, you know, what feels good, what I feel motivated to do and maybe ideologically or theoretically what I would want to be doing.
And so, in this case, I mean when we talk about unification, it's having the alignment that, like, I'm able to do and feel good doing the things that I value and think are important.
MR. AGNIFILO: We are going to go, there is a section here Lesson 10. I think you might have looked at some of this when you were going through this with the Government.
Lesson 10, what does master mean; do you see that there?
LAUREN SALZMAN: Yes, sorry.
MR. AGNIFILO: That's all right.
And it says: There is an external form of your master who is the person, but ultimately how you embody that within you.
Right?
LAUREN SALZMAN: (No response.)
MR. AGNIFILO: And so tell me if this is your understanding of this:
The idea isn't so much that you're serving this master who is this other person, the idea is you're incorporating the whole concept of this devotedness into kind of who you are, right? It's really about you, it's not about serving your master, it's not about making your master's life better?
LAUREN SALZMAN: That's what -- yes, that's what the theory is.
MR. AGNIFILO: Okay.
LAUREN SALZMAN: That if you serve your master, eventually you learn how to serve something outside of your reactivity or body, like lower, what was viewed as lower values, to be able to overcome that, to uphold your higher values.
MR. AGNIFILO: And on the next page, I think it's a continuation of that same thought, it says in eastern philosophy:
In eastern philosophy there's one type of yoga called Bhakti -- is it Bhakti yoga?
LAUREN SALZMAN: That's my understanding, yes.
MR. AGNIFILO: -- Bhakti yoga which this is a form of, which is the yoga of worship, where someone can go and worship a guru that is a fool, a guru that is an asshole, a murderer, whatever it is and still reach enlightenment because you are reaching yourself through something in the outside world, but everything in the outside world is just a play of consciousness. We are tricking ourselves that something external is important to us. The thing, itself, isn't important to us. It's something on the inside that's important to us, that we're making the external thing be.
Right, that's that same concept, right, or is it not? I'm asking you.
LAUREN SALZMAN: Is it the same concept as what we were just discussing?
MR. AGNIFILO: Yes.
LAUREN SALZMAN: I mean I see it a little bit different.
MR. AGNIFILO: Go ahead, tell me the way you see it.
LAUREN SALZMAN: That -- I mean that, ultimately, you could become unified in yourself separate from what's going on in the outside. Right? And that the inside self is the most important thing than what's going on in the outside, but that doesn't make it good that you worship a guru that's a murderer or something like that.
MR. AGNIFILO: It might not be good as a thing in itself, but it could bring you -- the point here is it could bring you enlightenment, you could worship a guru that's a fool, but it is your devotedness, the state of your devotion that is the thing that's causing you enlightenment or to improve or to become more joyous or whatever you want to say it is?
LAUREN SALZMAN: I think that's the theory of that.
MR. AGNIFILO: That's all we have for the DOS book.
Yesterday you went through quite a number of chats with Audrey. It's a Government Exhibit, 432-R.
You can look, actually do it any way you want. I can put them on the screen or you have it in your book, but --
LAUREN SALZMAN: It's easier on the screen, if it's not a problem.
MR. AGNIFILO: Yes, that's fine. That's easier for me too.
Okay, so the first page of 432-R, which is in evidence.
(Exhibit published.)
BY MR. AGNIFILO:
MR. AGNIFILO: So the green writing, the green background with the blue writing, that would be -- that would be Audrey, right?
LAUREN SALZMAN: Yes, that's correct.
MR. AGNIFILO: So it says: Amanda and I want to do our mega penance from our readiness failure while we're in San Diego with you. Can you advise on what method instrument we should use?
And you say: Go to a sex store and get a paddle. They have leather ones. I sent Jimena a picture.
Did you think of this on your own or did you get this idea from somewhere else?
LAUREN SALZMAN: This is what we did in my circle. I came into the circle and they already had these paddles and that's what we used.
MR. AGNIFILO: And so you are suggesting to them they can do the same thing?
LAUREN SALZMAN: Correct. They can do the same thing because they chose to do the same penance that I was doing for their failure.
MR. AGNIFILO: And it was a readiness failure?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And here I think we might have covered this yesterday.
Audrey says: Spoke too soon. KF is having another freakout, asked me not to submit her collateral and to back out. I talked her down. She's processing through her reactions faster.
And you respond, and you have a response that goes from page 3 onto page 4, and you're basically saying, remind her that she made a life commitment?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And then on page 4, I don't know if we looked at this part yesterday, you say: Be gentle, but speak to her about this, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And part of what you're imparting here is you have to be tough because this person, you know, thinks the program is better for them, but is worried about the collateral; so you have to be tough, but you have to be gentle.
And those are the words that you're saying to Audrey here?
LAUREN SALZMAN: Yes; talk softly, but carry a big stick.
MR. AGNIFILO: Okay. Page 5 of the same exhibit.
(Exhibit published.)
MR. AGNIFILO: And you write here: The idea of creating weight for yourself is so that you can stack the odds in your favor towards growth and your ideals.
And weight is the collateral, correct?
LAUREN SALZMAN: That's correct, yes.
MR. AGNIFILO: You go on to say: We say "I want to grow to be my best self"; and then it quickly turns into "I want to grow to be my best self if it's not uncomfortable or scary"; and then it turns into, "I didn't really want that goal or ideal," which turns into "My life is fine the way it is," which is a lie... we lower the standard of our goals and dreams to match our low capacity for difficulty or discomfort, right?
LAUREN SALZMAN: Yes, that came from Keith telling me about a Burt Reynolds movie where he swam out to the water and was gonna drown and then he started making all these promises with God that he was going to do a whole bunch of things; and as he gets closer to shore, he's like, Nah, I really didn't mean any of those things.
MR. AGNIFILO: He says --
LAUREN SALZMAN: When he gets what he wanted --
MR. AGNIFILO: He says: God, if I get back to the shore, I'll give you everything I own?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And when he gets halfway, he says: God, I'll give you half of what I own?
LAUREN SALZMAN: (No response.)
MR. AGNIFILO: And then when he gets almost there: God, I'll give you a fourth of what I own.
I don't remember the name?
LAUREN SALZMAN: I had heard the story, and that was the -- yes.
MR. AGNIFILO: The philosopher, Burt Reynolds?
LAUREN SALZMAN: The philosopher Burt Reynolds.
MR. AGNIFILO: Okay, page 6.
(Exhibit published.)
LAUREN SALZMAN: I don't mean to make light of the subject we're talking about, just the story is funny.
MR. AGNIFILO: No, no, no, okay, page 6. This is you continuing and you're giving her advice.
The fact that you got scared immediately and want to quit is exactly the reason for the weight. No one is going to hurt you, punish you, do anything to you about this. It's for you. Right?
LAUREN SALZMAN: (No response.)
MR. AGNIFILO: And so, the fact that there's this collateral there and that it's a collateralized vow, is not meant to hurt people or punish people, it's -- it's for them. It's so they stick out the commitment.
That's the way you believed it, is that fair to say? You believed it to be that way at the time?
LAUREN SALZMAN: At the time I did, and Audrey left this conversation and went and told Kristin: You're putting me in a really bad position because I don't want to have to release your collateral.
MR. AGNIFILO: Audrey said that to Kristin?
LAUREN SALZMAN: Yes, And their text and discovery showing that. So even though I said that, that was going on.
MR. AGNIFILO: Right.
And fair to say, you've learned a lot, you've learned a lot, and we're going to come to this in a few minutes, you learned a lot through the discovery in this case, right?
LAUREN SALZMAN: I did, yes.
MR. AGNIFILO: And reading the discovery in this case caused you to have a change in perspective?
LAUREN SALZMAN: It contributed.
MR. AGNIFILO: I have about another 15 minutes of this. I can go as far as Your Honor wants me to.
THE COURT: We can take a short break now.
MR. AGNIFILO: Okay, that's fine, Judge.
THE COURT: Why don't we take our afternoon break.
All rise for the jury.
(Jury exits.)
THE COURT: All right, the witness may stand down. Please do not discuss your testimony.
(Witness steps down and exits the courtroom.)
THE COURT: How much longer do you have on your cross?
MR. AGNIFILO: It's going to be close, Judge.
THE COURT: It's going to be close to what?
MR. AGNIFILO: The end of the day.
THE COURT: The end of the day.
Well, yes?
MS. PENZA: Just in light of that, Your Honor, if it is likely to go to the end of the day, if I could let the witness whose been here all day go?
THE COURT: That is the reason I asked the question.
MS. PENZA: Thank you.
THE COURT: Because you will have something on redirect?
MS. HAJJAR: Probably very briefly, at least as of right now, Your Honor.
THE COURT: Very briefly. Well, if we can finish this today, then we can start with, but see --
MR. AGNIFILO: Yes, I want to try to finish today. I am going to try to finish today.
THE COURT: Okay, then we will try to finish this witness today. Alright?
MR. AGNIFILO: Thank you, Judge.
THE COURT: Okay, we will take a ten-minute break.
MS. PENZA: Thank you.
(Judge NICHOLAS G. GARAUFIS exited the courtroom.)
(Recess taken.)
(Judge NICHOLAS G. GARAUFIS entered the courtroom.)
(In open court - jury not present.)
THE COURT: Okay, let's bring in the witness, please.
(Witness resumed the stand.)
THE COURT: All right, please, rise for the jury.
(Jury enters.)
THE COURT: Please be seated.
All right, Mr. Agnifilo, you may continue your cross-examination; and the witness is reminded she is still under oath.
EXAMINATION CONTINUES BY MR. AGNIFILO:
MR. AGNIFILO: Ms. Salzman, at some point in the spring of 2017, Mark Vicente decided to leave NXIVM, is that correct?
LAUREN SALZMAN: Yes, that's correct.
MR. AGNIFILO: I am going to show you a chat from that time period. This is between you and Audrey.
THE COURT: And this is exhibit?
MR. AGNIFILO: Yes, Judge, this is Exhibit 432, and this particular page is 36.
THE COURT: And it is in evidence?
MR. AGNIFILO: It's in evidence.
THE COURT: Yes.
(Exhibit published.)
BY MR. AGNIFILO:
MR. AGNIFILO: And so you write here: Mark V did very little in comparison to what the women of the board do. And the women. Or he wouldn't have just left because his wife is playing the victim.
Now, what are you talking about here?
LAUREN SALZMAN: Audrey was saying that, basically, her confidence in the entire organization would shift -- was like shifted or shaken when Mark Vicente left. Like Mark Vicente was like all of our confidence somehow in the organization, and I was telling her that that was not the right way to be thinking about it.
MR. AGNIFILO: Okay. And around this same time period she sends you this?
(Exhibit published.)
MR. AGNIFILO: And she says: I also think my struggles with the circle are skewing my perceptions even more right now. I once respected the women in the circle so much, and I now see them as -- as a effing mess. One of them failed our readiness drill today and won't even let it -- and won't even own it, let alone take a penance.
What is she talking about here, do you remember?
LAUREN SALZMAN: She -- Audrey was very, like, hard-lined about certain things within the group and was trying to hold the line on certain things and wasn't really respected in that way by Jimena and Carola. And so when she was trying to enforce penances on them, they didn't take her seriously in that way and didn't even acknowledge that she had right to force that penance on them. And they discussed it with me separately.
MR. AGNIFILO: Got it.
Now, here you write to her: I'm losing some of the best friends I thought I had in my life and going in to clean up all their mess and the shitstorm of damage they are creating while pretending to be helping me transition to taking over their center. It's seriously a nightmare.
And she writes: How can I help you?
What are you talking about when you say your best friends, who do you mean?
LAUREN SALZMAN: Specifically, Sarah and Nippy, I was talking about.
MR. AGNIFILO: And Sarah managed the Vancouver center, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And Nippy was her husband?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And at this point in time Sarah is leaving?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Around the same time period, Audrey writes to you: I love you. I don't mistrust yours or anyone's intent. Trust is so important with DOS and where I feel shaky is not in intent, but in judgment from whoever is making all the these decisions.
Do you remember having this back and forth with Audrey around this time period?
LAUREN SALZMAN: Yes, I do. Generally, yes.
MR. AGNIFILO: Yes, and tell us kind of what was going on. Why were you concerned that she was mistrusting your intent?
LAUREN SALZMAN: Because she felt that I was lying to her, and I was.
MR. AGNIFILO: Lying to her about Keith's role in DOS?
LAUREN SALZMAN: Yes, and the other things she was hearing, like the branding was his initials and that there was seduction assignments, and eventually that he was having sexual relationships with some of the slaves.
MR. AGNIFILO: Now, at this point in time in the spring of 2017, everything is unraveling, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you guys are kind of panicking?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you're just trying to keep things afloat, fair to say?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Because people are leaving, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: There was some fear that some people from Vancouver were accessing your computer system, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And deleting orders and changing things around, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And all of this is going on pretty much at the same time, you know, in May and June of 2017, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: So Mark Vicente leaves, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Sarah leaves, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Your computers start getting accessed from outside, correct?
LAUREN SALZMAN: NXIVM computers, yes.
MR. AGNIFILO: From people in the Vancouver center, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Led by Sarah, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And at this point you're trying to just kind of keep things afloat, correct?
LAUREN SALZMAN: Correct.
(Continued on the following page.)
BY MR. AGNIFILO (Continuing):
MR. AGNIFILO: And you are telling people things that aren't true.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And Keith is encouraging you to tell things that aren't entirely true.
LAUREN SALZMAN: Keith is directing us to completely misrepresent his whole relationship with DOS and -- essentially, DOS.
MR. AGNIFILO: And the fear here is that this ship is sinking, correct?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: And the only chance you have of keeping this afloat is to try to distance Keith from DOS, correct?
LAUREN SALZMAN: It wasn't discussed with me why.
MR. AGNIFILO: But did you see that as a consequence?
Did you see, in other words, that you had a better chance of keeping the rest of the business going if Keith was not associated with DOS?
LAUREN SALZMAN: I didn't see it that way.
I didn't really understand the logic of what it was, I just took direction from him at that time about what to do. And there were a lot of discussions among us in the group trying to figure out what was going on and was he doing this just to try to make us stronger? Did he do this on purpose? Like, what was going on?
We really didn't understand the logic behind it and he didn't discuss it with us.
MR. AGNIFILO: One of the things that everybody was concerned with was that somehow their names would be out there in connection with DOS; right, that DOS would no longer be secret?
LAUREN SALZMAN: Yes, that was a concern at the time.
MR. AGNIFILO: In chats around the same time period, Audrey said: I outed you? I know I outed myself. I thought I just talked about me and Sarah.
Do you remember this part of this conversation?
LAUREN SALZMAN: Yes, I do.
MR. AGNIFILO: Tell us what's happening.
LAUREN SALZMAN: Audrey went and was speaking to Brian Elliot, who is my business partner in the San Francisco center and somebody she was close to. They had been housemates at one point in time, and she was a coach in mine and Brian's center. And Brian knew that I had been helping Audrey. He thought it was just in a coaching capacity as part of being the head of the center, but then the way she started talking about relating with me and Sarah and Sarah exposing DOS, Brian basically started coming to me and saying, I didn't know you were in DOS, or, I didn't know -- like, everything she was saying was helping Brian piece everything together and, essentially, she was giving Brian more information to fill in more pieces about things that were supposed to be secret.
MR. AGNIFILO: Around the same time period, Audrey -- you write to Audrey: Do you want to leave?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you're asking her do you want to leave DOS?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: She said: Leaning towards yes but have wanted to wait to talk to you further.
So, at this point, it's apparent to you that Audrey is having very, very serious thoughts about leaving DOS.
LAUREN SALZMAN: That's correct.
MR. AGNIFILO: You were asking her if she wants to leave DOS.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And she's saying: I'm leaning towards wanting to leave.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You don't threaten her collateral, correct?
LAUREN SALZMAN: No, but behind the scenes we were still trying to decide. And Keith said that we were still deciding about what was going to happen with collateral and whether ultimately it would be released. And he was coming up with distinctions under which it would be released; people who left and broke their nondisclosure agreement, people who left and were outing other members and attacking the group, like, different things and different conditions under which to release it.
So, it still wasn't even defined if we were going to release it, I was just saying that she could leave. But I knew we were discussing those things.
MR. AGNIFILO: Let me ask the same question again: Did you ever tell Audrey you were going to release her collateral?
LAUREN SALZMAN: No, I never told her that.
MR. AGNIFILO: That was my question.
You then go on to say: We can talk, but you can leave. If you think it was naive and you don't like it, then you can do that. I don't feel that way about it. But in either case, I think that the fear is poison. It's used as a weapon and it empowers destructive people to destroy more. Abuse of power exists because of people who are controllable through fear.
Here, you're talking about -- there was a group of people, Vicente, Sarah, and others, who were saying things about DOS that was causing people to become afraid, correct?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: And what you're saying here is that -- you say: Fear is poison. It's used as a weapon.
When you said these things, did you mean them?
LAUREN SALZMAN: Yes.
And it can be used as a weapon on both sides, from within DOS or outside DOS.
MR. AGNIFILO: Around the same time period, she asks: If my name comes out, what do I say to people? Do I deny it? Do I admit it?
Right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And the fear that she had and that others had was that their names were going to be released and they don't now how to deal with it. Here, she's asking you: If my name comes out, what do I know?
Right?
LAUREN SALZMAN: Yes, she was asking me that.
MR. AGNIFILO: Here, she writes to you: Is the thing about Allison's initials true?
Absolutely not.
I think we talked about this a few minutes ago. One of the rumors out there was it was Allison Mack's initials, which was false.
LAUREN SALZMAN: Correct.
MR. AGNIFILO: Then you say: Nothing about it being Keith or Allison's group is true whatsoever at all.
Your answer is true as to Allison Mack, correct?
LAUREN SALZMAN: Yeah.
And it's not Keith and Allison's group, it's Keith's group.
MR. AGNIFILO: But here, at this point, you are not telling anybody, because you're told not to, that Keith was the person who created the founding principals of DOS, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: Around the same time period, a little bit later, she says: Private thought. With all these conversations I'm having with people in Vancouver who feel they can't trust anyone in ESP, I'm starting to feel the same way. I'm ashamed to admit, but I still feel I can't trust you. But I recognize my own projection in that because I'm not trustworthy.
And then she says, Goodnight, Master.
LAUREN SALZMAN: Correct.
MR. AGNIFILO: At this point, she's saying that she doesn't know that she can trust you, correct?
LAUREN SALZMAN: Correct.
And rightly so, because I was lying to her.
MR. AGNIFILO: June 12, a few days later, she says: Good morning. I've spent a lot of time thinking about it, and I don't want to be in DOS anymore. I'm happy to talk about it more with you. I can meet any time before you leave for San Francisco. I will wait to tell Kristin or any of my sisters until we speak. I love you and feel tremendously lucky to have had this opportunity to grow with you. Also, I talked to Ian Zimmerman after sexy this morning. He told me Sarah --
LAUREN SALZMAN: That's her last name.
MR. AGNIFILO: I know. Sarah had a last name.
-- from Vancouver messaged him with links to the article. Do you have any idea who was the source of info to the press and if they would know the names in our circle?
She's telling you, I made up my mind. I spent a lot of time thinking about it. I don't want to be in DOS anymore.
That's what she says, right, on June 12?
LAUREN SALZMAN: On June?
MR. AGNIFILO: I think it said June 12. I'll show it to you again.
LAUREN SALZMAN: June 12, yes, thank you.
MR. AGNIFILO: Two days later, she says: Thinking of you and sending you love.
You say: I'm sorry I haven't responded to you. I haven't known what to say. This is one of the hardest weeks of my life and this was the moment you chose to not stay and stick up for me. I'm sorry if you feel I'm not a good leader because of this. It's a sad moment for me. I hope you can understand this. I'm trying to salvage my business and uphold what I believe we stand for. I understand if you don't want to be on my team anymore. I am saddened by that and will miss you.
That's what you write to her, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: She responds: My decision on leaving DOS was not meant to be a decision to not support you. I'm sorry you took it that way. I see the good in DOS and I see things I disagree with.
Correct?
LAUREN SALZMAN: Yes.
What she was concerned about was that there were no ethical checks on Keith.
MR. AGNIFILO: You say -- I'm sorry, she says to you: I love you and I'm sorry this is where we're at. I realize my choice to leave DOS changes the nature of our relationship and your desire to communicate with me. I'm sad about this, but I also understand and see how I participated. I plan to leave Albany soon and find a quiet place to regroup. I won't take part in the ugliness going on. I will always feel love and gratitude for you and will think and speak of you fondly. I will miss you so much.
That's what she writes, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Now, the "ugliness going on," what do you understand she's telling you there?
What's the "ugliness"?
LAUREN SALZMAN: That people who are raising allegations about DOS were doing things that were ugly, like, mean or disparaging. They were making -- it wasn't just that they brought allegations and allegations that were valid, but surrounding the allegations they would say things in anger or maybe make hateful comments or those types of things. So, it was viewed not just the concerns that they were raising but the whole thing as a hate campaign.
MR. AGNIFILO: Okay. Did you feel that they -- from your perspective, were they playing to people's fears?
LAUREN SALZMAN: I think some people played to people's fears, but I think they were also raising valid concerns. And it's like throwing the baby out with the bath water, because it was hard to see those valid concerns because of some of the ways that they were executing that. But they were raising them.
MR. AGNIFILO: There were a lot of articles by someone named Frank Parlato, correct?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: Do you know if Mark Vicente was feeding information to Frank Parlato?
LAUREN SALZMAN: I don't know specifically. I had assumed so, but I don't -- it's my assumption.
MR. AGNIFILO: Do you know what Frank Parlato's connection is or was to Kristin Keeffe?
LAUREN SALZMAN: I believe that they -- she had hired him through her legal capacity at one point in time as part of NXIVM.
I'm not sure exactly what happened. I think there was a parting on not good terms and he's not been favorable to us since. I don't really know the details of it.
MR. AGNIFILO: In the last of these chats that we're going to look at, you write to Audrey: I do understand and honor your choice to leave and I do still love you. I am sad that you chose to not stay and fight with me and for me, but Brian and I are still open to work with you and have you as part of our center, if you want to be. You do always have a place with us. I love you and will miss you. Please stay in touch.
Right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And that's how it ends. Audrey leaves, right, Audrey leaves DOS?
That's how she left DOS, what we just reviewed, correct?
LAUREN SALZMAN: Yes. I'm trying to think if she and I had any more communications after that, but, yes, that was how Audrey left DOS. And then there were other things as well, but yes.
MR. AGNIFILO: There was a lifetime commitment, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Collateralized lifetime commitment, right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And that's how it ends, with you telling her you love her, her telling you she loves you, nothing else, right?
LAUREN SALZMAN: Well, with her raising very valid ethical concerns, me completely dismissing them and thinking that she was leaving based on just wanting to choose comfort and not because there was a valid thing that she was raising that I totally missed, because she was saying, My concerns are that there are no ethical checks on Keith.
And I was -- and that she couldn't trust me. And I was saying: Like, if I made you the head of ethics of DOS -- because I was to be head of the ethical craft in DOS -- if I made you the head of ethics, the ethical craft of DOS, and you could put in your protocols, would that address your concerns?
And she said, No.
And, so, then I was like, well, then it's not about if there are ethics or abuses of, power. But I didn't see the thing about that there were no ethical checks on Keith. And I said to her, I'm open for a full ethical review of all of my conduct.
And I meant that. And she said, I don't -- basically, I can't take advantage of that because it's all within the same framework. So, I don't trust that it's actually an ethical review.
And I think that's a very valid concern to have had because it was all within the same framework and there were no objective outside parties looking at it. And when we brought outside parties in, we lied to them all so there was no capacity to have an outside ethical perspective.
So, we're saying I love you, but while I'm saying I love you, what I'm thinking you just want to get off the hook and you are choosing comfort and I made all these concessions and was willing to do everything ethical and you're the one who really doesn't want to uphold your word.
But that's not really what happened. She was raising concerns that I completely dismissed and missed.
MR. AGNIFILO: You didn't release anybody's collateral. Dozens and dozens --
LAUREN SALZMAN: That's true, I did not release anybody's collateral.
MR. AGNIFILO: Dozens and dozens and dozens of people left DOS. You didn't release any aspect of anyone's collateral, right?
LAUREN SALZMAN: And if we had, it certainly would have legitimized all of the things that we are here discussing.
MR. AGNIFILO: Let me ask you --
LAUREN SALZMAN: Yes, I did not release anyone's collateral.
MR. AGNIFILO: That was the question.
On January 9, 2018, you spoke at a community meeting; do you remember that?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: It was you and Allison Mack in front of a whole roomful of people, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And it's a videotaped event, correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you did most of the speaking?
LAUREN SALZMAN: Yes, I did.
MR. AGNIFILO: And you told the audience that huge injustices were happening; do you remember saying that?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: What were the "huge injustices"?
LAUREN SALZMAN: That they broke into our computer system was one of them that I thought was very unjust.
MR. AGNIFILO: Who's "they"?
LAUREN SALZMAN: Sarah and some other women from the Vancouver center.
MS. HAJJAR: Objection, your Honor. I object to this.
THE COURT: Beyond the scope?
MS. HAJJAR: Your Honor, may we?
THE COURT: You want a sidebar?
MS. HAJJAR: Yes.
(Continued on the following page.)
(The following occurred at sidebar.)
MS. HAJJAR: The objection is based on if counsel could establish a foundation for these questions.
Our view is everything this witness knows about these events are through hearsay, there's no firsthand observations of any of these events, and these were lies that were told to her. I don't believe counsel has set a foundation for these questions.
MR. AGNIFILO: We don't need to get into it, but we have forensic proof that Sarah's access ID was used to gain access to NXIVM's computers between June 5 and June 7, 2015, and they deleted a number of orders. They altered -- they absolutely committed computer hacking.
Now, the only question was: When you said huge injustices were being committed, what did you mean?
She gave that answer. The Government covered this community board meeting. And if it matters, I'll play the tape. I was trying to short circuit it, but I'm happy to play the recording, it's all on video.
But this is a fair question. They got into this topic on direct. I asked the witness, Why did you say that? and she gave an answer.
MS. HAJJAR: We did not get into this on direct, your Honor. If Mr. Agnifilo wants to prove up this supposed hacking, he can do so in his case in chief. But what he can't do is impeach this witness about something she heard that she's not even denying she said.
There's no foundation for the actual establishing that this hacking occurred, which is the tenor of Mr. Agnifilo's questions. She doesn't know that.
THE COURT: You can ask her how she knows it, if she knows.
MR. AGNIFILO: All right.
(Continued on the following page.)
(Sidebar ends; in open court.)
BY MR. AGNIFILO:
MR. AGNIFILO: What's the basis, Ms. Salzman, of your belief that Sarah and others from the Vancouver center hacked into the computers of NXIVM in early June?
LAUREN SALZMAN: I was told this, but I can't recall specifically from who. I think Keith or Clare.
MR. AGNIFILO: And to your knowledge, was there an investigation done, a forensic investigation, of the NXIVM server to determine why certain things in the NXIVM computer system were eliminated?
MS. HAJJAR: Objection.
THE COURT: Sustained.
MR. AGNIFILO: Just getting back to your answer when you said "huge injustices" were happening, you're saying that's what you were referring to in that sentence.
LAUREN SALZMAN: There were other things as well.
MR. AGNIFILO: Go ahead.
LAUREN SALZMAN: That the people who had left were using our client list to call -- the NXIVM client list to call the NXIVM active NXIVM members and unenroll them from NXIVM by sharing the allegations against us with them and their fears and concerns about them. And I thought that that was a huge injustice at the time.
MR. AGNIFILO: About 4 minutes and 50 seconds into the recording, you talk about the Me Too movement and you say, This isn't a good time to go against the public victim.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Why did you say that?
LAUREN SALZMAN: That was something that Keith and I had spoken about. In fact, when I wrote the position statement that he tasked us all to write for DOS and taking the position that he had no affiliation with it or whatever, he actually edited my position statement to talk about that, about that it's unpopular to go against a public victim but that Sarah -- what I was talking about was Sarah was publicly victimizing herself. So, if I took a position against her or anything that she said at the time, I would be seen as being abusive to a victim.
MR. AGNIFILO: You say at one point that mark left, Mark Vicente, Sarah left.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: The Vancouver center was dismantled.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And that only one person came to you to discuss what was going on.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Was that true?
LAUREN SALZMAN: Yes, Audrey. Audrey was the only one of those people who had come to me.
I mean, I guess it depends how you look at it. Mark had come to me with concerns over time much earlier, but I think he had decided to leave ESP before he actually did leave. And he and I did have a conversation where he did ask me about DOS and did ask me -- he called it the other stray path, and he told me he thought Allison -- he was calling her "Madam," that he thought she was recruiting young girls to have sex with Keith, and I wasn't considering that at the time when he said that.
So, he did raise those things with me, but at the time when I said that, that was Audrey.
MR. AGNIFILO: You were just talking about Mark Vicente?
LAUREN SALZMAN: Yes, I was talking about Mark Vicente.
But when Sarah came to me, she had already decided to leave.
MR. AGNIFILO: At one point you said, The Texas Chainsaw description of what I brand is isn't right.
Do you remember saying that?
LAUREN SALZMAN: Yes, I remember saying that.
MR. AGNIFILO: You said it was 25 percent fart jokes --
LAUREN SALZMAN: I was talking about Sarah's branding ceremony.
Jimena's branding ceremony was pretty rough.
MR. AGNIFILO: -- kissing, and 25 percent, This is an honor, thank you for pushing.
Do you remember that that's what you said?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Is that an accurate description?
LAUREN SALZMAN: I don't know if the percentage is accurate, but Sarah did say those things and there was joking in her branding ceremony.
MR. AGNIFILO: Okay.
LAUREN SALZMAN: And, honestly, I mean, it was -- you know, you're there with your friends and you're naked and you're holding each other down branding each other, so it's awkward and uncomfortable. And there was a tremendous amount of fear and reservation, especially after watching Jimena's branding ceremony, so I think sometimes that does inspire joking as well.
MR. AGNIFILO: Okay. You said, We made life commitments with our best friends.
Right, talking about the branding ceremony and DOS?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You also said --
LAUREN SALZMAN: And I made life commitments with them under false pretenses.
MR. AGNIFILO: I'm just asking about what you said.
Did you say that in the video?
When you were talking -- tell the jury, this community meeting, how many people were there?
LAUREN SALZMAN: There were 60 or 70, around 60 or 70 people from the Albany community, the local Albany community.
MR. AGNIFILO: And you didn't say to them you made life commitments -- that you made a life commitment under false pretenses.
That's not what you said at the community meeting, right?
LAUREN SALZMAN: Correct, I didn't say that. I'm saying that now.
MR. AGNIFILO: At the time, in January of 2018, what you were saying is you were making life commitments with your best friends and that it was a rewarding experience, correct?
LAUREN SALZMAN: Yes, I was saying that.
MR. AGNIFILO: You also said you were in a sorority in college and a lot of frat guys got branded.
LAUREN SALZMAN: That's true.
MR. AGNIFILO: That is true?
LAUREN SALZMAN: Yes. I mean a number of frat guys that I knew had gotten branded when I was in college.
MR. AGNIFILO: And of the brand, you said, It's a way of sealing my promise forever, to see that it's forever, to stand for something for my whole life. My body is a tool for that.
Right, you said that?
LAUREN SALZMAN: Yes, I did.
MR. AGNIFILO: And you also said If you didn't want to get branded, you didn't have to, right?
LAUREN SALZMAN: At the time that my girls were branded, I didn't know that, I thought everybody had to. But I did say that.
MR. AGNIFILO: And you said that because not everybody in DOS is branded.
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: People can join DOS and not get the brand, correct?
LAUREN SALZMAN: I didn't know that at the time that they were branded, but, yes, it is true that girls were in DOS and didn't get branded and stayed part of DOS.
MR. AGNIFILO: And you said that at the community meeting.
LAUREN SALZMAN: Yes, I did.
MR. AGNIFILO: You didn't want to get a brand, you didn't have to.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You said, I've never felt more connected to people than overcoming pain for a principle.
Do you remember saying that?
LAUREN SALZMAN: It looks different now, but I remember saying it.
MR. AGNIFILO: And when you said it, did you mean it?
LAUREN SALZMAN: Yes, when I said that I meant that.
(Continued on the following page.)
CROSS-EXAMINATION (Continuing) BY MR. AGNIFILO:
MR. AGNIFILO: You compared it to men in the military and being in boot camp. Do you remember making that comparison?
LAUREN SALZMAN: Yes. I don't know what it's like to be in the military and in boot camp. I was making the comparison because that's how Keith talked about it.
MR. AGNIFILO: Now I think it was the next day, the day after the community meeting, I think you said on direct you gave an interview to Vanessa Grigoriadis?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Who was Vanessa Grigoriadis?
LAUREN SALZMAN: She is a reporter and she wrote an article about us that was published in the New York Times.
MR. AGNIFILO: Fair to say you wanted an outlet? You wanted to tell the story, the story as you understood it to be, correct; you and the others in NXIVM understood it to be?
LAUREN SALZMAN: Keith thought it was important that we get media out there and that us having media out there would influence what happened legally, as well, and pushed for us to do the media. I was very -- had a lot of reservations about doing any media and especially....
MR. AGNIFILO: And Vanessa Grigoriadis was a fairly well-known journalist at the time and who had written issues with regard to men and women; correct?
LAUREN SALZMAN: I don't know that.
MR. AGNIFILO: You didn't know she that just published a book --
MS. HAJJAR: Objection.
THE COURT: Sustained.
MR. AGNIFILO: Did you think the New York Times would just write a puff piece for you?
LAUREN SALZMAN: My understanding was that, choosing Vanessa as a journalist, we would get at least a more neutral-type of a piece, but we lied to Vanessa.
MR. AGNIFILO: Let me -- I'm going to ask you questions and if you want to go off and answer something else, I can't stop you.
MS. HAJJAR: Objection.
THE COURT: If you want something struck, ask it to be struck, I will consider it. Don't give instructions to the witness.
MR. AGNIFILO: Very good, Judge.
THE COURT: Just direct your questions to me.
MR. AGNIFILO: Will do.
THE COURT: Ask for a sidebar, if you need.
MR. AGNIFILO: Yes, Judge.
THE COURT: Go ahead.
MR. AGNIFILO: You were looking for a neutral investigative journalist to write about the situation; right?
LAUREN SALZMAN: That's my understanding that that's what was looked for; it wasn't me looking for it, and I was pushed to participate in it, but that's what was looked for.
MR. AGNIFILO: And Vanessa interviewed a lot of people, right?
LAUREN SALZMAN: I don't know how many people Vanessa interviewed.
MR. AGNIFILO: And Vanessa wrote a very long article in the New York Times magazine; right?
LAUREN SALZMAN: That's true.
MR. AGNIFILO: And was it the idea that there were different blog sites that were publishing very biased, one-sided views and you wanted a more responsible investigative piece?
LAUREN SALZMAN: I don't know that. I wasn't involved in the decisionmaking, but I do know and we did discuss that if we had the hope of having any leverage legally, or politically, it would be through the media.
MR. AGNIFILO: Okay. You said a few times here today that, since the criminal case started, your perspective has changed on whether Keith and the NXIVM teachings and DOS were good or bad; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And at the time that you were in DOS, you thought that DOS was good; right?
LAUREN SALZMAN: At the time that I was in DOS there were a number of things, as I was in DOS longer and longer, that concerned me and that I had issues with; a number of them I raised with Keith and his answers concerned me more. And I overrode all of that and went full force ahead to convince myself that Keith was everything that he said he was; that DOS was everything the theory that I had made it into would be, and that my life still was going to work out in some happy way close to what I wanted it to be and what he was telling me it could be; I overrode my better judgment again and again and again.
MR. AGNIFILO: Fair to say you have been frustrated with Keith over the years?
LAUREN SALZMAN: I have.
MR. AGNIFILO: You have known him for about 20 years or so?
LAUREN SALZMAN: Yes. Yes.
MR. AGNIFILO: And you and he talked about having children, but you never had children?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: He continuously started relationships with other women?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You told him a few times you wanted to end your relationship with him?
LAUREN SALZMAN: Yes, that's true.
MR. AGNIFILO: And he reacted strongly when you said these things to him; correct, ending the relationship?
LAUREN SALZMAN: Well, he made a certain series of promises and threats at that time, so, you know, if you consider that strongly, then, yes.
MR. AGNIFILO: And the threat was that he was going to leave the community?
LAUREN SALZMAN: That he was considering resigning his Vanguard.
MR. AGNIFILO: So he said to you if you leave me I am going to resign?
LAUREN SALZMAN: I didn't say it like that, but.
MR. AGNIFILO: How did he say it?
LAUREN SALZMAN: I was -- it was under the discussion of my having kissed another person and he said he was considering whether resigning as Vanguard would be a good idea.
MR. AGNIFILO: And you didn't want him to resign as Vanguard?
LAUREN SALZMAN: Correct. I did not.
MR. AGNIFILO: You wanted him to stay the head of the community?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you wanted him to stay because you truly believed in the work that you were all doing together?
LAUREN SALZMAN: Yes, I did. At that time, I did.
MR. AGNIFILO: And you wanted him to stay because you truly believed that you would be better off with him, imperfect as he was?
LAUREN SALZMAN: That's just a funny way of saying it, but I wanted to believe that what he was telling me would be would be and that he was who I thought he was.
MR. AGNIFILO: You had family in the community; correct?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You had friends?
LAUREN SALZMAN: Yes. Yes.
MR. AGNIFILO: You had support; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You had ways of making money?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You didn't need Keith, did you?
LAUREN SALZMAN: Yes, I did. I felt I did. I absolutely felt I needed Keith. 100 percent, I felt I needed Keith. I did not feel that I would be okay in the community and could exist in the life that I was living if I left Keith.
MR. AGNIFILO: So you wanted Keith to stay as the Vanguard?
LAUREN SALZMAN: I wanted Keith to stay as the Vanguard and I felt completely dependent on him and our relationship for things to be good in my life.
MR. AGNIFILO: And part of it is you believed that you had a mission, right? That even pre-DOS, NXIVM, that what you guys were doing was like a mission; is that a fair way to put it?
LAUREN SALZMAN: I did. And at some point he came to me and said, I thought we had really failed in NXIVM to be able to uphold the mission and that he thought the real way we were going to accomplish things in the world were through these secret organizations.
MR. AGNIFILO: And the mission is something that you guys would talk about, you would call it a mission?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You guys watched the movie The Mission; right?
LAUREN SALZMAN: Yes, that's true.
MR. AGNIFILO: There was a -- there was a -- what are the two-hour things called?
LAUREN SALZMAN: Modules.
MR. AGNIFILO: Modules. There was a module called The Mission?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: What was the mission?
LAUREN SALZMAN: To raise the ethics of the world and ultimately that's why I'm sitting here, because I believed that in order to decide what's ethical and what's not the truth has to come out, and lying and covering up everything we did is not ethical and it is not the mission that I was enrolled in, and that is not the person that I wanted to be with or who was the leader I thought.
MR. AGNIFILO: But for a while you thought you guys were actually going to be doing something real and important and critical for the world?
LAUREN SALZMAN: Which is why I did it.
MR. AGNIFILO: Right. And now that mission is over?
LAUREN SALZMAN: It's over in that form. I mean, everybody can have their own mission in themselves to make the world a better place and to make it more ethical, and we all do that in our own way. And then, part of my doing that is telling the truth about what happened.
MR. AGNIFILO: Now, your perspective has changed. As you sit here today, many of the things you thought were positive and good for the world, you no longer view them that way; correct?
You view them as negative?
LAUREN SALZMAN: The things I thought were positive and good for the world I view as negative?
MR. AGNIFILO: Let me ask --
LAUREN SALZMAN: I still hold the same principles that I held before and I've had enough time away by myself, after I was indicted, to think about my own experiences and to be able to process them without other people talking me out of them or reframing them or leveraging my own fears or attachments, and it's -- and I decided to go forward the way I've always gone forward to uphold what I think is right and good and in the best way that I can.
MR. AGNIFILO: Part of what's happened is that, through the discovery process, you have learned more about Keith's relationships with other women; fair to say?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You have learned more about Keith's relationship with Cami, for instance?
LAUREN SALZMAN: That's true.
MR. AGNIFILO: And you always were concerned that Keith held Cami in sort of a special place in his heart?
LAUREN SALZMAN: I mean, I felt insecure about it, but that wasn't what was troubling to me. Learning that Cami and Keith had a special relationship is not what was troubling to me.
MR. AGNIFILO: But you've learned -- for instance, you've read the Cami chats, chats between Keith and Cami, you've read them?
LAUREN SALZMAN: Right.
MR. AGNIFILO: In discovery?
LAUREN SALZMAN: Yes. Yeah, where he says we're going to -- there is going to be the part of DOS that other people know and then there's going to be this other secret sex part of DOS where we're going to get slaves to pleasure us, slaves -- that was not what I signed up for.
MR. AGNIFILO: You didn't know that Keith and Cami had a relationship that you knew nothing about?
LAUREN SALZMAN: Well, I knew they had a relationship I knew nothing about, I just didn't understand the nature of some of it. But what was more troubling is not that they had a relationship that I knew nothing about, or even that it was as involved as it was -- I mean, it was Keith's consistent misrepresentations of things and that he made promises to me that I gave up real other opportunities of things that I wanted and that he knew that I wanted, and when he didn't fulfill those promises and he said -- Keith said, in the curriculum, that ultimately we want to make our words so strong, like so strong that when we tell people we will do something, it will be done. That it will be done. So he made me a promise, and then when I said you didn't uphold the promise, he said I didn't give my word. So that's like just one example.
And then he characterized the way -- the reasons for why he didn't uphold his word to me as being because it was so difficult that two of our best friends died of terminal illnesses and the void that that left in our community, and how much extra work fell on him and how hard it's been because of all of our failures and ineptitudes and the political situation. And then I found out, during that time, he started like twelve new relationships with people who were not compensating for those holes that were left in the organization, and many of them didn't even share really any of our values. And I didn't have a problem, I stayed with Keith despite all the other relationships, and that was something that he could have been honest with me about, and mischaracterizing and making me feel sorry for him because his life is so hard because we lost our friends and I can't get my shit together is not what was going on.
MR. AGNIFILO: I think you said on direct examination that you thought Keith changed when Pam passed away?
LAUREN SALZMAN: I don't know if I said that on direct examination, but I think that Pam's passing away relates to the start of DOS.
MR. AGNIFILO: In what way?
LAUREN SALZMAN: Because I think Keith was -- now had a whole bunch of people to meet his objectives and serving him, you know, in a way that Pam facilitated before. I think Pam facilitated a number of Keith's personal and romantic relationships and kept them alive throughout the years.
MR. AGNIFILO: In your --
LAUREN SALZMAN: Pam talked me back into my relationship with Keith over the years, many times, and Pam facilitated my relationship with Keith initially. And I think DOS took the place of that, in large part, because now you have slaves going out specifically looking for sexual relationships and personal relationships for Keith.
MR. AGNIFILO: But you'd agree with me that didn't -- your personal knowledge, that didn't happen. In terms of you and your slaves, that didn't happen, right? That's my question.
LAUREN SALZMAN: My personal knowledge of what was going on in the other groups, based on what the women were sharing --
MR. AGNIFILO: No, I'm talking about --
LAUREN SALZMAN: -- with me was happening.
MR. AGNIFILO: I'm sorry, I'm asking what you know --
LAUREN SALZMAN: I did not do that. I did not do that in my group.
MR. AGNIFILO: Let me just ask you the question.
I'm asking about what you know, what you know based on what you saw and what you saw other people doing with your own senses, eyewitness-type stuff; you didn't see any of that?
LAUREN SALZMAN: Well, if I don't believe anything that any of my friends say, then I didn't experience any of that. But most of my first-line DOS masters were telling me things that were gravely concerning to me that they were doing.
MR. AGNIFILO: I'm going to ask you the question again.
LAUREN SALZMAN: I didn't observe them doing it.
MS. HAJJAR: Objection, Your Honor.
THE COURT: Asked and answered. Next question.
MR. AGNIFILO: Keith had a child with Kristin Keefe; right?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: That's the same Kristin Keefe who was on the e-mails that we looked at earlier with Hector and you and all those folks; right?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: Kristin Keefe, you said, was in the legal sort of part NXIVM, she was in the legal department?
LAUREN SALZMAN: That was my understanding, yes.
MR. AGNIFILO: And from time to time, Kristin would write e-mails as though it was Hector; correct, she did that from time to time?
LAUREN SALZMAN: She would draft the e-mail and suggest that the family use it and then Hector would use Kristin's drafted e-mail, yes. That happened at least once that I know of.
MR. AGNIFILO: Right. And then sometimes Hector would send his own e-mails that was from Hector?
LAUREN SALZMAN: I believe so.
MR. AGNIFILO: And you said that Kristin told you, and a group of people, that she brought Daniella over the border; is that the same Kristin Keefe?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Did she leave the community suddenly?
LAUREN SALZMAN: Yes, she did.
MR. AGNIFILO: Okay. Tell the jury about that.
LAUREN SALZMAN: Kristin left the community with Gaelyn, their son, in I think around 2014.
I don't know specifically what you want to...
MR. AGNIFILO: And she just left like one day she was here and one day she was gone?
LAUREN SALZMAN: I think it was progressive. She was more and more upset. I remember concern that she was voicing upset she had, so I don't think it was completely out of the blue.
MR. AGNIFILO: Do you know if a box of her belongings was taken to your mother's house?
LAUREN SALZMAN: I don't recall. I don't know that.
But I don't think it -- I mean, the part about her leaving suddenly, I mean, I had conversations with Keith quite some time before she left where he wasn't sure he should spend time developing a close relationship with his son because of Kristin, and that if at some point he got close to Gaelyn, there might be some rift or separation between them that would be damaging to his son, so I think he foresaw that. And we saw that coming, I don't think it was suddenly.
MR. AGNIFILO: One of the things that we've done, yesterday afternoon and today, Government put in a number of transcripts corresponding to audiotapes.
LAUREN SALZMAN: Yes.
MR. AGNIFILO: 494 to 497, with the transcripts; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You were asked to listen, the Government asked you to listen to these recordings; right?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: You weren't involved in any of these conversations; right?
LAUREN SALZMAN: Correct, I was not. They happened before I was in DOS.
MR. AGNIFILO: Right. So the Government had you listen to a number of recordings of meetings that you weren't at?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: They asked you to make transcripts of the meetings that you weren't at; correct?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: So, these are meetings between -- these are meetings that you didn't even know took place; correct?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: You learned about these meetings for the first time when the Government gave you these recordings to listen to?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: In the last couple weeks?
LAUREN SALZMAN: Correct.
MR. AGNIFILO: And these are meetings between Keith, Monica Duran, Dani Padilla and Loreta Garza, right?
LAUREN SALZMAN: Yes, and I think there were some with Allison and Rosa Laura too.
MR. AGNIFILO: And there were some with Allison and Rosa Laura.
LAUREN SALZMAN: Yeah. Yes.
MR. AGNIFILO: And with the exception of Rosa Laura, Keith slept with all of those women?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: So here you are, listening to Keith talk to these women about DOS and the creation of DOS, you're not there, and you're listening to these recordings; correct?
LAUREN SALZMAN: Yes. Correct.
MR. AGNIFILO: Did you know that Keith was having -- and this is at a time when you and Keith are still talking about you possibly having children in the spring of 2016; correct?
LAUREN SALZMAN: Yes, but it was at a time when Pam was -- was -- it was at a time that Keith and I weren't interacting very much over the two years that Pam was sick and dying.
That was -- I'm sorry.
MR. AGNIFILO: No, it's all right.
So you were still holding out hope, as of June 2016 when these conversations are taking place, these meetings between Keith and these other women, you are still holding out hope that you might end up with Keith?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: So the Government plays these recordings for you; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Meetings you didn't know about; right?
LAUREN SALZMAN: Yes, correct.
MR. AGNIFILO: You just said before that one of your concerns with Keith is that he was with all these other women, you know, rather than being with Pam as she's dying, that he started I think you said twelve new relationships; correct?
LAUREN SALZMAN: Yes. I mean, one of my concerns though is that Keith was not being honest with me about what was going on, and he was mischaracterizing things and making promises to me that were influencing my life decisions when I could have gone in other ways and was expressing that I wanted to.
MR. AGNIFILO: One of the ways you know that Keith was lying to you is because you listened to these recordings; right?
LAUREN SALZMAN: I just listened to these recordings the day before yesterday for the first time.
MR. AGNIFILO: Right, you didn't know about?
LAUREN SALZMAN: Yeah.
MR. AGNIFILO: Were you surprised?
LAUREN SALZMAN: Was I surprised about the recordings?
MR. AGNIFILO: Yeah, were you surprised that Keith was having these kinds of interactions with these women, most of whom he was sleeping with?
LAUREN SALZMAN: No. Everything they were talking about is stuff that we talked about in DOS and that I knew already when I listened to that, except the fact that there were the seven of them and they planned it to stay the seven of them.
MR. AGNIFILO: I'm not talking about the content.
LAUREN SALZMAN: Oh, I'm sorry. I didn't understand the question.
MR. AGNIFILO: Let me ask you the question.
The fact that Keith is off with these women doing anything, in this case creating DOS, you didn't know that he was there? You didn't know he was with them at those times?
LAUREN SALZMAN: Yes, correct. I didn't know that.
MR. AGNIFILO: You know that now --
LAUREN SALZMAN: I knew there was some project that they were working on at one point in time. I didn't know what it was.
MR. AGNIFILO: But you know that now because the Government gave you the recordings to listen to of the meetings that you weren't in?
LAUREN SALZMAN: Well, yes. And also -- I mean, I knew it because when I joined DOS there was something that had been created over a period of time that seemed pretty extensive. There were a lot of things created and they had all been created and implemented in my absence, so I knew that I had come into something, that there had been things before. The relationships I learned about when I joined because -- I learned about when I joined, but it wasn't confusing to me that there had been time spent developing those things. The Government didn't teach me that. Like I didn't learn that from them, I knew that before.
MR. AGNIFILO: You didn't know the specifics of the conversations because you weren't there; right?
LAUREN SALZMAN: Correct, I didn't.
MR. AGNIFILO: So you heard conversations -- well, can I ask you a question, do you love Keith?
MS. HAJJAR: Objection.
THE COURT: We have been through this. Sustained.
MR. AGNIFILO: Judge? Judge, can we have a sidebar?
THE COURT: No, we can't have a sidebar. Move on.
MR. AGNIFILO: Did you love Keith in June of 2017?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Did you know he was having these kinds of conversations with these women?
LAUREN SALZMAN: Generally. Not specifically.
MR. AGNIFILO: Was it hard to hear his voice with their voices in these recordings that you transcribed?
LAUREN SALZMAN: That wasn't what made it hard.
MR. AGNIFILO: But was that hard?
MS. HAJJAR: Objection.
THE COURT: Asked and answered.
MR. AGNIFILO: I don't think she did. She said that's not what made it hard.
THE COURT: You said that's not what made it hard?
LAUREN SALZMAN: Yeah.
THE COURT: You may ask your question. I misheard the answer.
MR. AGNIFILO: I'm sorry.
THE COURT: You can ask the question.
MR. AGNIFILO: Yeah, okay.
MR. AGNIFILO: Was it hard to listen to the conversations?
LAUREN SALZMAN: The conversations sound different to me now than they did before and so I don't hear them the same way and that's difficult.
MR. AGNIFILO: At some point you realized -- let me back up.
You said -- I think it was just before lunch yesterday -- when Keith was arrested in Mexico, Mexican police came in and they had machine guns?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And they were pointing them at you?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You've been through a lot for Keith; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And one -- that's one of the things that you went through; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: And you didn't want to have to go through this criminal trial with him; is that fair to say?
LAUREN SALZMAN: I didn't want -- I didn't want to sit -- I didn't want to defend the things that I did that were bad and that were criminal as good. I didn't want to sit at the defense table and tell a false story about what happened. And when I found that I had done things that I believe are wrongful, and also criminal, I did exactly what Keith taught me to do, which is take responsibility for and figure out how to fix it.
MR. AGNIFILO: Now, you just said when you "found out" that you did things that were criminal, did you intend to do things that were criminal as you did them?
LAUREN SALZMAN: Some of them.
MR. AGNIFILO: Did you intend to commit a racketeering violation at the time that you did it?
LAUREN SALZMAN: I didn't know specifically it was a racketeering violation, but I knew things were illegal that I was doing and I did them anyway.
MR. AGNIFILO: Did you intend to commit extortion at the time that you did it?
MS. HAJJAR: Objection, Your Honor.
THE COURT: Sustained.
MR. AGNIFILO: Did you intend to commit extortion --
MS. HAJJAR: Objection.
THE COURT: Sustained.
MR. AGNIFILO: You said on direct examination that you committed extortion; right?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: Did they tell you to say that?
MR. AGNIFILO: Do you think you committed extortion?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: You do?
LAUREN SALZMAN: Yes.
MR. AGNIFILO: What did you do?
LAUREN SALZMAN: I took collateral from people who were afraid to not give it to me, because I already had their collateral, and they were calling it extortion at the time and I even discussed it with Keith and he was, like, it's not extortion, they agreed to it.
MR. AGNIFILO: Did you think it was extortion when you took the stuff? Were you doing it to scare them?
MS. HAJJAR: Objection.
THE COURT: You may answer.
LAUREN SALZMAN: I had concerns that it was problematic and I chose to go with what Keith said. If I didn't think it was problematic, I wouldn't have raised it.
MR. AGNIFILO: Did you intend to hurt anyone, did you intend to scare anyone?
MS. HAJJAR: Objection.
THE COURT: Sustained.
MR. AGNIFILO: Means you don't answer.
THE COURT: I'm sorry?
MR. AGNIFILO: No, no, I thought she was about to answer, so I told her not to.
MR. AGNIFILO: When you were in DOS, before anybody was arrested, were you doing things intentionally to break the law?
MS. HAJJAR: Objection.
THE COURT: That requires a legal conclusion.
MR. AGNIFILO: Was your intention to hurt people or was it to help people?
MS. HAJJAR: Objection.
MR. AGNIFILO: What was your intention when you were in DOS?
THE COURT: You may answer.
LAUREN SALZMAN: My intention was to prove to Keith that I was not so far below the ethical standard that he holds that I was -- I don't even know how far below I am. I was trying to prove my self-worth, and salvage this string of a hope of what I thought my relationship might some day be, and I put it above everything else; I put it above my friends and I put it above other people, helping them in their best interest. That's what I did when I was in DOS.