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2019 Federal TrialtranscripttranscriptJay — Direct (Part 1) - Day 20 - 2019 Federal TrialJay described joining a secret society presented as women-only mentorship, supplying collateral, and later learning its master-slave terminology. She also discussed her move to Albany and contact with Keith Raniere.
Mark LeskoMarc AgnifiloNicholas G. GaraufisJayMR. LESKOCourt ClerkTHE COURTJayMR. AGNIFILOdirect
9 pages·3 witnesses·3,011 lines
Nicole completed testimony amid disputes over contemporaneous messages and their admissibility. An FBI agent described evidence seized at 8 Hale Drive, and Jay began testifying about recruitment, collateral, and contact with Raniere.
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DirectDirectJay — Direct Jay Mark Lesko

MR. LESKO: The Government calls Jay, Your Honor.

COURT CLERK: Please raise your right hand.

JAY, called by the Government, having been duly sworn, was examined and testified as follows:

COURT CLERK: Please have a seat.

THE COURT: You may inquire.

MR. LESKO: Thank you, Your Honor.

DIRECT EXAMINATION BY MR. LESKO:

MR. LESKO: Good afternoon.

JAY: Good afternoon, everyone.

MR. LESKO: Jay, how old are you?

JAY: 29.

MR. LESKO: And where are you from?

JAY: I'm from Southern California.

MR. LESKO: Could you describe growing up in Southern California?

JAY: Yes, it was very sunny. I was raised by my grandparents, along with my two siblings, and I had a fairly rough and traumatic childhood, but there was also a lot of love.

MR. LESKO: Were you interested in modeling and acting as a child?

JAY: Yes.

MR. LESKO: Did you start modeling when you were in school?

JAY: Yes. I did some print work, so like taking photos for magazines and for different campaigns and things like that.

MR. LESKO: How old were you when you started modeling?

JAY: A little bit before 16.

MR. LESKO: And how far did you go in school?

JAY: I did some community college.

MR. LESKO: What's your profession?

JAY: I'm an actress, a model, as well as a writer.

MR. LESKO: What sort of work have you done as a model? Let's start with a model.

JAY: Different print ads, working for different clothing companies, also Grand Ambassador modeling.

MR. LESKO: How about acting? What sorts of acting work have you done?

JAY: I've had some small featured roles in major productions, as well as short films and I even have produced my own project.

MR. LESKO: So you have been in movies?

JAY: Yes.

MR. LESKO: Where do you reside?

JAY: Los Angeles.

MR. LESKO: So, I'd like to draw your attention to the summer of 2016, okay?

JAY: Okay.

MR. LESKO: Are you familiar with a company named NXIVM?

JAY: Yes.

MR. LESKO: What is NXIVM?

JAY: Well, NXIVM, what I thought it was, was a humanitarian personal development company.

MR. LESKO: Are you familiar with a program called Executive Success Program?

JAY: Yes.

MR. LESKO: What is Executive Success Program?

JAY: It was the personal development program that was supposed to be based under ethics and humanitarianism.

MR. LESKO: Was the Executive Success Program known as ESP?

JAY: Yes.

MR. LESKO: And was ESP under NXIVM?

JAY: Yes.

MR. LESKO: In the summer of 2016, did you attend an ESP course?

JAY: Yes.

MR. LESKO: What was that course?

JAY: I'm sorry?

MR. LESKO: What was the class? What was the course?

JAY: It was the five-day intensive.

MR. LESKO: Where did you take the five-day insensitive?

JAY: It was in Culver City at a rented space.

MR. LESKO: And that's in Los Angeles?

JAY: Yes.

MR. LESKO: How did you get introduced to NXIVM?

JAY: Well, I first learned of NXIVM because of my friend Rachel. She had several clients of hers that were coaches in the program, including India Oxenberg, who was also her friend. So, I heard about the program through Rachel, as well meeting India.

MR. LESKO: Had you known India before meeting her through Rachel?

JAY: Yes, we met once briefly.

MR. LESKO: And why did you take the ESP intensive, the five-day intensive? Why were you interested in taking that?

JAY: Because of my traumatic childhood and healing wounds, I've always been into personal development. And after the presentaton, I thought it was something that would be able to help me.

MR. LESKO: Was the five-day intensive part of a larger intensive?

JAY: Yes, it was part of the 16-day intensive.

MR. LESKO: And you just took the five-day in Los Angeles?

JAY: Yes.

MR. LESKO: Who taught that five-day intensive in Los Angeles?

JAY: Jim Del Negra.

MR. LESKO: Did you subsequently take the rest of the 16-day or the rest of the 11-day intensive?

JAY: Yes.

MR. LESKO: Where did you take the 11-day?

JAY: In Upstate New York, in Albany.

MR. LESKO: When did you take the 11-day intensive?

JAY: I took it in November of 2016.

MR. LESKO: And, so, why did you take the 11-day intensive after taking the five-day intensive?

JAY: Well, I really fell in love of with the five-day. I had a lot of profound shifts and I was really excited to complete the rest of it.

MR. LESKO: So, when you were first in the five-day intensive, did you become familiar with anybody named Keith Raniere?

JAY: Yes.

MR. LESKO: Who was Keith Raniere?

JAY: Keith Raniere was promoted as like the kind of guru, the guy who started NXIVM and created the curriculum. He was also promoted as master martial artist and one of the smartest men in the world.

MR. LESKO: And that was discussed during the five-day intensive in Los Angeles?

JAY: Yes.

MR. LESKO: Was there a specific title that people used to refer to the defendant?

JAY: Yes.

MR. LESKO: What was that title?

JAY: Vanguard.

MR. LESKO: Do you see Mr. Raniere here in the courtroom? Take a look around.

JAY: Yes.

MR. LESKO: Can you identify him by an article of clothing he is wearing?

JAY: Black sweater.

THE COURT: The witness has identified the defendant.

MR. LESKO: Thank you, Your Honor.

MR. LESKO: So, in addition to the five-day intensive and the 11-day intensive, did you take any other NXIVM courses or classes?

JAY: Yes.

MR. LESKO: What did you take?

JAY: I took The Source intensive, as well as a Jness weekend.

MR. LESKO: The Source intensive that you took, where was that located?

JAY: In Vancouver, Canada.

MR. LESKO: And who taught The Source in Vancouver?

JAY: Allison Mack.

MR. LESKO: Did anyone teach The Source with her?

JAY: Mark Hildreth.

MR. LESKO: Your Honor, I am going to show you an exhibit in evidence. If I could use the ELMO to show it to the jury.

THE COURT: Go ahead.

MR. LESKO: Thank you.

MR. LESKO: So I'm showing you Government Exhibit 39. Do you recognize that photograph?

JAY: Yes.

MR. LESKO: Who is that a photograph of?

JAY: Allison Mack.

MR. LESKO: And the Jness, you took a Jness class. What type of Jness class?

JAY: It was a Jness weekend.

MR. LESKO: Where was that located?

JAY: It was in Albany, at the home of Rosa Laura.

MR. LESKO: How much did the five-day -- did you pay for the five-day intensive?

JAY: Yes.

MR. LESKO: How much did it cost?

JAY: I'd say roughly around 5,000, give or take.

MR. LESKO: Was there a fee associated with the 11-day intensive?

JAY: Yes.

MR. LESKO: How much was that?

JAY: Give or take, upwards to almost like 10,000.

MR. LESKO: And was there a fee associated with The Source?

JAY: Yes.

MR. LESKO: How much was that fee?

JAY: 11,000.

MR. LESKO: And same question with respect to Jness, was there a fee for the Jness weekend?

JAY: Yes, it was $500.

MR. LESKO: So, starting with the five-day intensive, did you pay for that five-day intensive?

JAY: Yes.

MR. LESKO: And how did you get the money to pay for that intensive?

JAY: It was money that I had made from jobs that I was actually saving for a trip to Hawaii.

MR. LESKO: So, your own money?

JAY: Yes.

MR. LESKO: And did you pay for the 11-day intensive?

JAY: Yes.

MR. LESKO: How did you pay for that?

JAY: Initially, I could only afford to do the middle five-day, but after taking that, it was suggested that I stay by Keith, as well other people suggested that I just stay, and I was able to get a personal loan from a friend.

MR. LESKO: Okay. We will talk about The Source and Jness. In Jness, did you pay for Jness, the $500?

JAY: Yes.

MR. LESKO: Okay. And The Source program that you participated in, how did you pay for that?

JAY: I paid for the deposit and for the rest I was supposed to recruit people per Allison in order to pay for the rest.

MR. LESKO: Okay. Are you still in debt from the money that you paid to participate in the NXIVM programs?

JAY: Yes.

MR. LESKO: How much are you in debt?

JAY: Roughly a few thousand dollars.

MR. LESKO: Do you still owe your friend of yours part of that initial personal loan that you received?

JAY: Yes.

MR. LESKO: So when you went to -- you went to Albany in November of 2016; is that right?

JAY: Correct.

MR. LESKO: And that was to take, initially, the middle five-day intensive, but then you stayed for the full 11 days; is that correct?

JAY: Yes. That is correct.

MR. LESKO: So when you were Albany, where did you stay in November of 2016?

JAY: I stayed in the home that belonged to Allison Mack in the basement.

MR. LESKO: Do you remember the address?

JAY: 7 Generals Way.

MR. LESKO: So was India Oxenberg present during the initial five-day in Los Angeles?

JAY: Yes.

MR. LESKO: Was India Oxenberg present during the 11-day intensive in Albany?

JAY: Yes.

MR. LESKO: And I'm going to show you what's in evidence as Government Exhibit 56. Do you recognize that photograph?

JAY: Yes.

MR. LESKO: Who is that a photograph of?

JAY: India Oxenberg.

MR. LESKO: At some point during the 11-day intensive in Albany, did you take a walk with India?

JAY: Yes.

MR. LESKO: And what did the two of you discuss?

JAY: Well, on the walk she gave me a little bit of information about this group that she was a part of. She described it as a women's-only secret society. Her whole thing around it is that she said it was -- it helped her more in life than NXIVM and that it was a secret society to help women with mentorship program, so these women can build character and discipline and be these strong forces of light in the world.

MR. LESKO: And what was your reaction?

JAY: I was excited and it sounded like something interesting and something that I had been wanting.

(Continued on following page.)

EXAMINATION CONTINUES BY MR. LESKO:

MR. LESKO: Did India suggest that you might be the right sort of person for this secret society?

JAY: Yes, she said that she thought I would be perfect for it and that it would help me grow and reach my goals.

MR. LESKO: And did she give you of a lot of information about this secret society at that time?

MR. LESKO: Did she tell you that you needed to do something to find out more about this secret society?

JAY: Yes.

MR. LESKO: What did she say?

JAY: She said that because there's a lot of high-powered women in it, that it had to be very -- it had to be secret. So in order to find out more, you had to submit something, a piece of collateral in order to protect its secrecy.

MR. LESKO: Did she mention that the group was controversial in any respects?

JAY: Yes, she said that the way that they help people grow can be controversial to, like, I guess the average person, that it's kind of like a -- like a -- like a bad ass women almost boot camp kind of thing.

MR. LESKO: And did India explain to you what she meant by collateral?

JAY: She did.

MR. LESKO: What did she say?

JAY: Well, she had explained that because it's so secret, they needed a piece of collateral to protect its secrecy. And so that you needed three pieces of collateral to protect your word, so that way, say, if you didn't want to do it or as long as, you know, you never say anything, it's fine.

MR. LESKO: Did she describe the three pieces of collateral that were required?

JAY: Yes.

MR. LESKO: What were they?

JAY: It was something that had to be financial, family-related and reputation.

MR. LESKO: Could the collateral be fictional or made up?

JAY: Yes.

MR. LESKO: And at that point what was your understanding of the purpose of this collateral?

JAY: My understanding that it was merely to protect the secrecy of the group so if you learn about it, you just will never talk about its existence.

MR. LESKO: So did you decide you wanted to learn more about this secret society?

JAY: Yes.

MR. LESKO: And what was it about the secret society that appealed to you?

JAY: Well, for me, having had, like, a traumatic childhood and growing and wanting to be the best version of myself, I thought it would be something that would be great, as far as being with other women that wanted to be empowered, that wanted to help each other, and it just seemed like something that would be great for me.

MR. LESKO: Okay. So did you provide collateral?

JAY: Yes.

MR. LESKO: What did you provide initially?

JAY: Initially, I provided, like, video secrets, as well as a notarized letter.

MR. LESKO: So when you say video secrets, what do you mean?

JAY: Well, one of the secrets was a video of me sharing about being molested by my uncle.

MR. LESKO: So let's talk about that for just a moment.

When you say video secrets, are you talking about yourself making statements on a video?

JAY: Yes.

MR. LESKO: Okay. And these are about secrets about your life?

JAY: Correct.

MR. LESKO: And one of the videos was -- involved you telling about how your uncle molested you, is that right?

JAY: Yes.

MR. LESKO: And you -- did you give that to anyone?

JAY: Yes, I gave it to India.

MR. LESKO: And how did you give it to India?

JAY: I think I air dropped it to her or sent it to her via text.

MR. LESKO: So had you been, in fact, molested by your uncle?

JAY: Yes.

MR. LESKO: Are you okay?

JAY: Yeah, I'm okay.

MR. LESKO: How old were you?

JAY: I was 12.

MR. LESKO: And did this abuse, did it happen just once or was it a repeated abuse?

JAY: There was multiple times.

MR. LESKO: Was your uncle ever charged?

JAY: Not that I know of.

MR. LESKO: And how did this affect you?

JAY: Well, it created a lot of issues with trust, issues with males. It created, I guess, like a lot of emotional distortions. You know, different insecurities and different fears.

MR. LESKO: Now, you testified you had a tough childhood, right?

JAY: (Nodding.)

MR. LESKO: Could you describe your parents?

JAY: Yes. My parents, they -- I, basically, kind of had a reverse Cinderella childhood where when I was really little I had a really great upbringing. I was in a nice house and things like that and my mom was a nurse. And then it reversed, so I went from that to my parents being involved with drugs and my mom leaving when I was like five years old. And so, they were -- had their own journey and were involved with drugs, and I later ended up being raised by my grandparents who adopted me and my brother and sister.

MR. LESKO: Did your mom get arrested?

JAY: Yes.

MR. LESKO: Did she go to jail?

JAY: Yes.

MR. LESKO: Did your dad get arrested?

JAY: Yes.

MR. LESKO: Did he go to jail?

JAY: Uh-hum.

MR. LESKO: Was that for drugs?

JAY: Yes.

MR. LESKO: So this second piece of collateral, I think you mentioned, was a notarized letter, is that right?

JAY: Yes.

MR. LESKO: And what was in the letter?

JAY: In the letter, it was about me admitting an indiscretion that I had while I was still in a relationship with someone.

MR. LESKO: Did you provide any additional collateral initially?

JAY: Yes.

MR. LESKO: What else?

JAY: There was also a sex tape with me and my boyfriend at the time.

MR. LESKO: A videotape?

JAY: Yes.

MR. LESKO: And was there a fourth videotape?

JAY: Yes.

MR. LESKO: And what was on the fourth videotape?

JAY: On the fourth one was a video confession about me making out with one of my girlfriends and that her boyfriend gave me money afterwards.

MR. LESKO: And so why was the fourth videotape required?

JAY: Because the other ones didn't fall in each category, so it wasn't enough to learn more.

MR. LESKO: So this submission of the four pieces of collateral, did you do that all at once or was it a process? Was it -- did you submit them one by one?

JAY: I submitted them one by one. It was definitely a little bit of a process.

MR. LESKO: And were you discussing the collateral with India during this process?

JAY: Yes. Because it was really confusing and she -- she gave me examples for herself, like she would share, like, family secrets or she turned in family heirlooms and just explained that it just needed to be really weighted just to make sure that, you know, I would hold my word and never discuss the group's existence.

MR. LESKO: So was this collateral, the combination of collateral, was it significant for you?

JAY: Yes.

MR. LESKO: Do you know why the letter was notarized?

JAY: Yes. Because it had to be that it was, like, a true statement, I guess is what the reason behind the notarizing was for.

MR. LESKO: So at some point after all the collateral is submitted -- oh, I should ask you this:

How were the additional pieces of collateral submitted to India, were they submitted to India?

JAY: Yes.

MR. LESKO: And how were they submitted to India?

JAY: The videos, again, it was either air dropped or text messaged to her; and with the notarized letter, I just -- I gave it to her.

MR. LESKO: Okay.

At some point did you learn that you had been accepted into the secret society?

JAY: Yes.

MR. LESKO: And how did you learn that?

JAY: India just saying, I'm your mentor. And I was -- it was kind of already known, like, that I wanted to do it. And so, basically, I was in it, but I just needed to turn in all of the collateral to make it official.

MR. LESKO: Did India mention to you that the society had a name?

JAY: Not at that moment, but like a few days later or so she did call it The Vow.

MR. LESKO: And was that the actual name of the organization?

JAY: I had learned later that it was actually called DOS.

MR. LESKO: And did you learn, ever learn any other names for The Vow or DOS?

JAY: Yes, Allison would kind of joke around and called it The Agency.

MR. LESKO: And did you have an understanding as to why she called it The Agency?

JAY: Yes. It was because her slaves were all, like, actresses and models and were beautiful, so it was like a joke as if she's, like, running an agency.

MR. LESKO: Now, after you were accepted into The Vow, and we'll call it The Vow, okay, did India share with you a lot of information about The Vow?

JAY: Not right away, everything was kind of like a long, drawn out kind of process.

MR. LESKO: Okay. So what did you learn about The Vow initially after joining it?

JAY: Initially after joining, again, it's like everything was like concentrated and spread out.

So, to the best of my memory, but I learned a little bit later that the dynamic of what it was called, which was a master/slave dynamic.

MR. LESKO: Okay. Did she discuss the type of commitment that was required?

JAY: Yes, she said it's a lifetime commitment. So for me I just thought, great, it's like I'm gonna have sorority sisters and just be a part of my personal growth for the rest of my life is what I thought.

MR. LESKO: Did she explain that you would have a mentor?

JAY: Yes.

MR. LESKO: And was the mentor the master, is that how that worked?

JAY: Yes, but at first she said: I'm gonna be your mentor. So the name master/slave didn't come up 'til later.

MR. LESKO: And did you -- did India say that she had a meant other?

JAY: Yes.

MR. LESKO: Did you know who that was --

JAY: No -- I'm sorry.

MR. LESKO: -- initially?

JAY: I'm sorry; no.

MR. LESKO: The master/slave relationship, how did you learn that?

JAY: Pardon me.

We went on a walk and she told me. She prefaced me first and she just said, so I'm gonna tell you like what we're actually called. And she said, it's very controversial and it's meant to be shocking and it's meant to raise up different feelings. But she said it's kind of like in karate, you have your sensei and your master and your guru, and so she said, so I'm actually your master and you are actually my slave and that's just what it's called.

(Continued on the following page.)

BY MR. LESKO: (Continuing.)

MR. LESKO: When you first joined The Vow, did India give you any assignments?

JAY: Yes.

MR. LESKO: And what were the initial assignments?

JAY: Mainly just journaling.

MR. LESKO: And what do you mean by journaling?

JAY: She would give me journal assignments like contemplate what a wise woman is, contemplate the kind of woman you want to be, like what are those characteristics and things like that.

MR. LESKO: Do you keep a journal regularly?

JAY: On my own, yes.

MR. LESKO: And so did you know what she was referring to when she asked you to write journal entries?

JAY: Yes.

MR. LESKO: And did you do that?

JAY: Yes.

MR. LESKO: And who picked the topics?

JAY: India.

MR. LESKO: Did Allison Mack give you any assignments?

JAY: Yes.

MR. LESKO: What assignments did she give you?

JAY: Allison initially -- she first gave me an assignment to read the book Chasm of Fire.

MR. LESKO: And what is Chasm of Fire?

JAY: It's a book about a woman's journey to enlightenment and she goes to India and she meets her master who helps her break through different, like, patterns and mental things to gain enlightenment.

MR. LESKO: And were you required to do anything during your reading of the Chasm of Fire?

JAY: Yes.

MR. LESKO: What was that?

JAY: I had to -- after every chapter that I would read, I would have to basically kind of send her, like, a book report of what it was about and how I felt about it.

MR. LESKO: Were you paid for these reports?

MR. LESKO: So, when you joined The Vow were you told that men were part of the organization?

MR. LESKO: Would you have joined The Vow if you had been told that a man or men was involved in the organization?

JAY: Absolutely not.

MR. LESKO: Why not?

JAY: Because, no offense to men, but there are just some things that men don't understand that only women do and because of everything that I had been through and my mother not being present, I definitely wanted to form more bonds with women and it just made sense. It wouldn't make sense if there was a man running things.

MR. LESKO: So let's go back to the 11-day intensive in Albany in November of 2016, okay? During that 11-day intensive, did you meet the defendant?

JAY: Yes.

MR. LESKO: So, can you describe your first meeting with the defendant?

JAY: Yes. I had just arrived to Albany for the first time and India picked me and a few other students up from the bus station or the bus stop and we went straight to volleyball.

MR. LESKO: And what was volleyball?

JAY: Volleyball was a NXIVM activity that happened a couple of times a week.

MR. LESKO: And was the defendant playing volleyball?

JAY: Yes.

MR. LESKO: Okay. And what happened at volleyball?

JAY: Well, my first time attending, I went and that's when I first saw and met Keith and prior to that because I was so moved from the five-day and because I believed that it was an organization where people really wanted to do good, I had, like, this admiration for what I believed, like, Keith was doing.

So when I first met him, it was emotional -- kind of like this, and I introduced myself and said thank you for creating this curriculum and helping me. And I was overwhelmed with emotion and then he grabbed my hand and sat me down on the bench and we just kind of chatted and he, like, tried to console me and make me feel better.

MR. LESKO: I think you explained it a bit, but why did you get so emotional?

JAY: I'd say because the kind of person that I am is I really want to do good things in the world and I guess it was a surprise for me before taking the course to find people that actually -- that I felt actually wanted to do that. So for me it was really inspiring and encouraging and, so, because I had so much breakthrough with the curriculum, I attributed that, obviously to myself and to the curriculum, but to the fact that I thought Keith created it. I was just grateful.

So I had all of these emotions of thinking that, oh, I'm meeting someone who also wants to do good and, like, meeting all of these people that also want to do good and, so, it -- I was just really emotional.

MR. LESKO: So during the 11-day intensive, the program itself, did you -- were you ever involved in a discussion about a T-shirt company?

JAY: Yes.

MR. LESKO: Can you discuss that, please?

JAY: So during the intensive, because I'm a writer and I like to just come up with slogans for things, I kept coming up with these terms and someone said oh, you should put that on a T-shirt and other people were, like, that would be great. I was, like, okay, but I couldn't think of anything. So me and my friend off-the-cuff said let's start a humanitarian T-shirt line. My ex-boyfriend had a T-shirt company, so I was very well-versed in how to do that.

And, so, word got out that I wanted to start a T-shirt company and multiple people, Jim Del Negro, India, Allison came up to me, like, oh, you should talk to Keith. He has a T-shirt company. You should talk to Keith.

MR. LESKO: Did you end up talking to get about the T-shirt company?

JAY: Yes.

MR. LESKO: When was the first time you talked to Keith about the T-shirt company idea?

JAY: I approached him at volleyball and told him that I was referred to go to him to talk about this T-shirt company because I already had an idea and apparently he had one.

MR. LESKO: This was another volleyball session, not the first one you went to?

JAY: Correct.

MR. LESKO: And what was his reaction?

JAY: He said he did have a T-shirt company business and I should get his information from Allison.

MR. LESKO: And did you get the information from Allison?

JAY: Yes.

MR. LESKO: And do you remember what information you received?

JAY: His phone number to use WhatsApp.

MR. LESKO: And did you contact the defendant?

JAY: Yes.

MR. LESKO: How did you contact him?

JAY: Via WhatsApp, through a message.

MR. LESKO: And did you arrange a meeting with the defendant?

JAY: Yes.

MR. LESKO: And did you meet with him?

JAY: Yes.

MR. LESKO: And how did that happen?

JAY: It was -- we didn't set, like, an exact time. He just said different days that he would possibly be available and to just -- he'll see if I'm up because sometimes he takes, like, his walks late and so I just had my phone ready and then he messaged me, probably sometime after 1 a.m., and then I met him to go on a walk.

MR. LESKO: Okay. We'll talk about that walk in just a moment. Back to the 11-day intensive. After the 11-day intensive ended, did you leave Albany?

JAY: Yes.

MR. LESKO: And what was the next NXIVM class that you took?

JAY: The Source.

MR. LESKO: And that was in Vancouver?

JAY: Yes.

MR. LESKO: What was The Source?

JAY: The Source was an intensive program that was more geared towards artists, actresses or actors and performers.

MR. LESKO: And when did you take The Source?

JAY: In December of 2016.

MR. LESKO: During this time period, the November/December time period of 2016 were people trying to convince you to move to Albany?

JAY: Yes.

MR. LESKO: Who was trying to convince you?

JAY: India and Allison.

MR. LESKO: And what were they saying?

JAY: They basically just said that it would be a good idea for me to move to Albany so I could work on myself.

MR. LESKO: Did the defendant ever contact you?

JAY: Yes.

MR. LESKO: And how did the defendant contact you?

JAY: He messaged me on WhatsApp after I went back to Albany before I returned to L.A. and he said, if you're serious about starting this T-shirt company, the sooner you come back, the better.

MR. LESKO: And at this point you were in The Vow?

JAY: Yes.

MR. LESKO: So during this same time period, the end of 2016, were you still doing modeling work?

JAY: Yes.

MR. LESKO: And how would you characterize your modeling career at this point in time?

JAY: I would say that it was at a high point and ready for, like, a big transition and up-leveling. I had just gotten an agent. I was booking commercials and booking print jobs and I was basically ready to go to the next level.

MR. LESKO: So it was going well?

JAY: Yes.

MR. LESKO: And at this point did you decide to move to Albany?

JAY: I'm sorry?

MR. LESKO: Did you decide to move to Albany?

JAY: Not right away, but I did end up moving to Albany.

MR. LESKO: Was that an easy decision for you?

JAY: No, not at all.

MR. LESKO: Why not?

JAY: Well, first when India and Allison tried to convince me I wasn't into it because my career was doing -- going really well, although I did see that there could be some benefits to working on myself, but until Keith messaged me about the T-shirt company, I was kind of like, you know what, I can come back to my career. I'll be stronger internally. I can start this T-shirt company, make some money, like hang out with the trade.

MR. LESKO: So do you remember when you moved to Albany?

JAY: Yes.

MR. LESKO: What was that?

JAY: January 11, 2017.

MR. LESKO: And I think you just described it, but the reasons for moving to Albany was to work on yourself and the T-shirt company?

JAY: Yes. And I've always had an entrepreneurial spirit, so I thought it would be a good idea. I would have Keith mentor me on being an entrepreneur. Start a T-shirt company, make money and work on my internal being.

MR. LESKO: Did you take anything with you when you went to Albany?

JAY: Yes, most of my things, whatever I didn't sell or get rid of, and my cat.

MR. LESKO: What's your cat's name?

JAY: Nico.

MR. LESKO: Where did you live in Albany?

JAY: I lived in Allison's house that she owned at 7 Generals Way in the basement.

MR. LESKO: Is that where you stayed when you took the 11-day intensive?

JAY: Yes.

MR. LESKO: So during the time period that you lived in Albany did you travel back and forth to Los Angeles?

JAY: Yes.

MR. LESKO: And why were you doing that?

JAY: Because I couldn't make any money in Albany and I still had a lot of bills.

MR. LESKO: And were you making money in Los Angeles?

JAY: Yes.

MR. LESKO: How were you making money in Los Angeles?

JAY: It was ranging from booking print jobs, working different gigs, as well as -- yeah, that's it.

MR. LESKO: Were you working at poker games?

JAY: Yes, that's some of the gigs that I was working at.

MR. LESKO: What were you doing?

JAY: I was a poker host. So I would serve drinks, give people massages and also serve them food.

MR. LESKO: Now, when you say "print jobs" is that, is that advertisements with your photographs in them? Is that what print jobs are?

JAY: Yes. For instance, I did a coffee bean ad. So a picture of me with a cappuccino and they get put on buses or billboards and things like that.

MR. LESKO: And you would fly back and forth; is that right?

JAY: Yes.

MR. LESKO: And when you flew to New York, what airport did you typically arrive at?

JAY: Usually JFK.

MR. LESKO: And about how many times, if you can estimate, did you travel back and forth between New York and Los Angeles during this time period?

JAY: Several times.

(Continued on the following page.)

DIRECT EXAMINATION BY MR. LESKO: (Continuing)

MR. LESKO: And who paid for all this travel?

JAY: I did.

MR. LESKO: And after you got to Albany, did you actually make money?

JAY: In Albany?

JAY: Not really.

MR. LESKO: So did you attempt to make money?

JAY: I did attempt to make money.

MR. LESKO: And how did you do that?

JAY: I was working for India in her Delegates program.

MR. LESKO: What was Delegates?

JAY: Delegates was a company that India and Keith started. It's similar to Task Rabbit, so, basically, it's like a service providing people that need help with, like, assistance stuff or cleaning or giving people rides and things like that.

MR. LESKO: And generally speaking, who were the employees at Delegates?

JAY: There were people part of the NXIVM community, usually younger people. There were a few teenage girls from Mexico that were in it and a few other people in the community.

MR. LESKO: Do you know why the teenage girls from Mexico were in the community?

JAY: I'm not entirely sure, but they said they were there for some sort of special schooling.

MR. LESKO: And did those teenage girls from Mexico, did they attend any NXIVM programs while you were there?

JAY: The one that I am aware of was the Jness weekend.

MR. LESKO: And were sexual topics discussed in front of them?

JAY: Yes.

MR. LESKO: Do you recall their reaction?

JAY: Yes.

MR. LESKO: What was it?

JAY: They were really uncomfortable and other teenage girls were giggling, hiding, and kind of laughing.

MR. LESKO: Did you provide any services while you were working at Delegates?

JAY: Yes.

MR. LESKO: Describe them, please.

JAY: Well, when I was hired through Delegates, I would do things like run errands, drop off food. Also, I was hired to do reiki, and just different errands like that and cleaning.

MR. LESKO: What is reiki?

JAY: Reiki is an energy healing modality.

MR. LESKO: And describe it, please.

JAY: So, unlike massage, it's something where you have to get initiated into reiki and you use, like, energy from elements to help find people's elements and putting like, say, good energy into those areas to help people feel better.

MR. LESKO: So is it sort of like a massage?

JAY: Sort of like a massage.

MR. LESKO: Do you give massages professionally?

JAY: I am certified in Lomi Lomi, which is a massage, but I don't do that for a trade. But I can't -- I wouldn't consider myself to be a healer and able to do that.

MR. LESKO: If you had stayed in Los Angeles as opposed to moving to Albany, could you have made more money?

JAY: Yes.

MR. LESKO: While you were in Albany, did Allison Mack ever ask you questions about the defendant?

JAY: Yes.

MR. LESKO: What sort of questions would she ask?

JAY: At just really random times she would ask me so what do you think of Keith? How do you feel about Keith? Things along those lines.

MR. LESKO: And what was your reaction?

JAY: It was really awkward because it was just random. We would be driving so, she'd be, like, so what do you think about Keith? And I didn't really know what to say and I would say oh, he seems cool, he seems nice. It was just really weird.

MR. LESKO: While you were in Albany, did Allison or India ever tell you that the defendant had asked about you?

JAY: Yes.

MR. LESKO: And could you tell us about that?

JAY: Like say I would go and hangout with India and she would say oh, Keith was asking about you today and he was checking in on you and seeing how you were doing.

MR. LESKO: Were you encouraged to develop a relationship with the defendant?

JAY: Yes.

MR. LESKO: Who did that?

JAY: India and Allison and really within the community it was this kind of this thing where if you're lucky enough to have Keith as a mentor, it's life changing. You know, most people tried to foster a relationship with him.

MR. LESKO: And initially, after moving to Albany, did you have contact with the defendant?

JAY: Yes.

MR. LESKO: What sort of contact?

JAY: Well, messaging, and also I would see him at volleyball and sometimes we'd go on walks.

MR. LESKO: Did you ever run errands for the defendant?

JAY: I ran errand to the defendant but not for Keith.

MR. LESKO: What sort of errands?

JAY: I -- as part of the Delegates, I would have to drop off food. Almost every time that I worked Delegates I would end up having to drop off food for him.

MR. LESKO: Did you end up taking walks with him?

JAY: Yes.

MR. LESKO: After you delivered the food, did you leave right away or did you stay and talk with the defendant?

JAY: It was different every time. Usually I would chat with him for a little bit and then there also would be times where he would invite me inside and just chat inside the house for a little bit.

MR. LESKO: Do you have an understanding now of why you were having so much contact with the defendant after moving to Albany?

JAY: Yes.

MR. AGNIFILO: Object to the form of the question, Judge.

THE COURT: Sustained.

MR. LESKO: Why do you think you were having so much contact with the defendant right after moving to Albany?

MR. AGNIFILO: I object to the form the question.

THE COURT: Sustained.

JAY: I'm sorry, can you repeat that, please?

THE COURT: He will repeat it in a different form.

JAY: Okay.

MR. LESKO: This amount of contact with the defendant, was it usual or unusual for somebody who was new to the community?

JAY: Very unusual.

MR. LESKO: Do you have an understanding as to why this unusual level of contact was occurring with the defendant?

THE COURT: Overruled. You may answer.

JAY: Can you repeat that, please?

MR. LESKO: Do you have an understanding as to why this unusual level of contact with the defendant was happening?

JAY: Yes.

MR. LESKO: What was that understanding?

JAY: My understanding now is that I was being groomed to be a part of his harem.

MR. LESKO: Did you have an impression of how other people in the community perceived the defendant, other women in the community?

JAY: Yes.

MR. LESKO: What was that understanding?

JAY: He was very revered.

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