1.Closing Argument — Defense (Part 2)

MR. AGNIFILO: Thank you, your Honor.

Good morning everybody.

MR. AGNIFILO: I have 30 or 35 minutes for you, then I'm going to sit down. I think Mr. Lesko is going to talk to you for a while. Then the parties will be done. Then later this morning his Honor is going to charge you on the law, then you'll start deliberations.

A couple of things. I think yesterday I said that Nicole was in Delegates, I think it was Jay. You can remember the testimony as well. But I think Jay said she was in Delegates.

Here is the point, how can it be forced labor if she's if she's getting paid, in this case from the person who actually brought her into DOS. India was in charge of Delegates, she's actually paying Jay for work.

One of the things that the Government mentioned in their summation, that came out in the evidence, is that people worked on Pam's memorial for free and they were not paid. The Government is going trying to say that is forced labor. Think about it. What we know from the testimony, I think, is that Pam is somebody everybody talked about, they seemed to love her, admire her, respect her. She dies tragically of cancer. This is not the kind of thing you expect to be paid for. This is what people in a community do to each other, for each other.

This is really what this was. Whatever other things you might conclude about what NXIVM was and what DOS was, it was people who lived together in a community. And everybody was very clear, even the Government witnesses who certainly weren't here to always say nice things about Keith Raniere or DOS or NXIVM, they all said we were a community, it was nice, I had friends, I cared for people. It seemed to be a nice thing.

Part of what I saying yesterday, one of the hardest things to do in this case is to imagine what life was like back in the day. But you know, because certain people told you about it.

Your job really is when you go in the back is to get down to certain essential truths. You're going to go back there and ask questions. What was DOS? What was it? What was it meant to be? What was it once it started? Was it sex trafficking, really? Was it sex trafficking, or was it something else? Was it forced, fraud or coercion being used to cause commercial sex, which is what part of the definition of what sex trafficking is. Was that what it was or was it something else? Was it about commercial sex? Was that anyone's idea?

When you listen to Keith talk in the tapes about the creation of DOS, is there any suggestion, inkling, hey, this is a way to make money. That is not what the evidence has been. That is not what the witness's have said, certainly that's not what the witnesses have said.

The only person I think who testified at the trial, who I didn't talk about yesterday and I'm going to talk about very briefly now, is Sylvie. There is a point I'm going to make with Sylvie's testimony. Sylvie testified, I think the first witness in the case, so going back now six weeks, I'm sure you remember what she said.

Basically she said that she was very close with Clare. Clare kind of brought her over. You can conclude Clare took very good care for her. Clare paid for her horse to be shipped from England to Albany. Clare did a lot of things to help her financially and whatnot.

She joins DOS; and is in DOS. And she talks about a single episode with Keith that I want to talk to you only briefly, because I'm going to ask a few questions once we go through it.

What she says is that Keith brings her upstairs, I think 2 Flintlock, goes down on her, performs oral sex on her. The way she described it is she manifested that she was enjoying it, that's what she says. And then I think what her testimony is, and this isn't exactly a quote but awfully close, she says I never had an orgasm before. Then all of sudden I had an out-of-body experience and then it ended.

Here's my question. What is that? Why is Keith doing this? And nothing else happens as part of that episode, and then nothing else happens again.

The only sexual connection between Sylvie and Keith is that. There is this one incident of oral sex where Keith performs sex on her, she appears to have an orgasm. There is nothing else. There is no intercourse. There is no other oral sex events. Then they never have another sexual encounter. What is that? And here's what I want you to think about. We went through the chats, the chats that Sylvie and Keith had. And you now have the Cami chats. You have a lot of evidence of a lot of written communication between Keith and other people. I suggest to you, if you could do such a thing, figure out what the ratio is of talking about sex or just talking about intense things and actual sexual contact. The ratio is like 100,000 to one.

Here is why I'm bringing this up. I think it's a fair question to ask: What is Keith trying to get? What is Keith searching for? Is it really sex?

Because I think there are a lots of things you heard in the evidence that show there were certain periods of time Keith couldn't have sex, okay. I think Nicole said that at different points. I think Nicole said, if I'm not mistaken, she and Keith had intercourse three times, a few times, some discreet amount of times. In one of the Camila chats, you'll remember it because how can you forget it, Keith is sort of berating her for being with this other guy. And there is talk about penis size and all this other stuff. And Camila writes, You haven't been -- I can't remember what she said -- you haven't been to your fullest in a long time, or something like that.

So I submit to you that what Keith is really after isn't exactly sex.

Let me tell you what I mean by that. So much in this case is about what opens people up. What stops them from being all self-contained. Some people like being self-contained, I'm happy being this way, I don't want to be meaningful with other people, I'm happy in this little space that I'm in. But some people aren't happy being like that, and some people want more than that. The question is, how do you get people out of themselves.

I think what you can find in the evidence that Keith is actually chasing after, I don't think he's chasing after sex, per se. What he's chasing after is this thing that happens between people who are attracted to each other. I think attraction causes you to kind of come out of yourself a little bit. I think attraction causes you to reach into the space between people and be not so much confined in yourself. Okay.

And I think this is something we've all experienced, I hope everyone in the world has. That you're attracted to somebody and all of a sudden things change. Everything changes, your view of yourself changes, things that you talk about in terms of yourself changes, things that you're interested in them change, they are interested in you. And all of a sudden you're having a discussion, you're having an interaction that people who aren't attracted to each other just don't have.

And so I think if you can kind of like take strands of this case, from all these different places in the case, if you can take strands of the case from the communications, from the chats, from what we know about the details of some of these intimate relationships, what I think the place you get is Keith is not really looking for the actual act of sex. He's looking for that -- he's looking for that thing. That kind of special, rare -- maybe not so rare, it shouldn't be so rare, that special thing that happens when people are engaged in each other in that way. Because that is what all the evidence in the case points toward.

You're going to get all the Camila chats when you go in the back. They are exhausting. They are exhausting in their length. They are exhausting in their breadth. It's constant. There is chats at times every three minutes for hours on end, day and night, talking about these. They are so intense and they are so unrelenting, that if you really sit down and read them in one sitting you leave exhausted. There is no sex in it. It's the connection. That's what he's chasing after.

And that seems to be what all this is moving toward. It's not because -- it doesn't make sense if he's Sylvie's Grand Master, okay, and he can have supposedly sex with Sylvie as much as he wants, presumably in any way that he wants, and the only thing, the one thing that he did was what we just talked about, it doesn't make sense that at the end of the day this is about sex for him. It doesn't. Because the evidence actually points away from that being the case. Now, it's sort of a subtle distinction. I'm trying to think of an analogy. Sex this is star. And around the star is this gravity. And there is a feeling, there is a feeling around sexual attraction that could have nothing to do with eventual sex, but there is an attraction. And the attraction makes two people different. And it makes people talk about different things in a different way. It makes you share yourself. It makes you share yourself in a way that you wouldn't ordinarily. Or you wouldn't go to a person that you weren't interested in. I think what you're trying to do is try to bridge that distance. Because you're attracted.

It's the real definition to the word. You're attracted to this person, you want them, you want to understand them, you want them to understand you. And in this the process something happens. That's I think what Keith is chasing after.

I think every single drop of evidence in this case points in that direction. And the point is, in terms of the charges, none of that amounts to commercial sex. It's just, commercial sex is on a different, is in a different universe from that, from what I'm describing to you.

And there is no evidence, truly no evidence that DOS was created with commercial sex in mind. Sex for value. That's just not what it was.

And it can't be like a gimmick. Like, well, there is sex and then somebody drove somebody to the airport and driving someone to the airport has value. There is sex and then somebody wrote a song for Pam's memorial.

No. That has to be a point. That has to be the point of this. It's clearly not the point of this. It's clearly not the point of this.

So why DOS? Why? One thing that has not really been discussed is the context. What is going on in Keith's life in 2015/2016. We know that Keith was very close to two -- lots of people -- but two in particular, Barbara Jeske, that's one of the long-term relations that he had, and Pam Cafritz.

Barbara Jeske dies in 2014, I think is the testimony at trial. And Pam Cafritz in 2014 has cancer, and she doesn't die until later.

Now, I think there is evidence in the record that Keith, and certainly evidence in terms if we look at the Government's chart here, woman, woman, woman, woman, woman, woman, woman, woman, woman, woman, woman, woman, a couple of guys on there.

Do you remember when Mark Vicente was testifying and he's talking about a conversation that he has with Pam Cafritz? And Pam Cafritz says, maybe you and Keith can be friends, he doesn't have a lot of male friends. Pam knows him the best. There is not a lot of evidence of him having male friends.

What seems to pretty clear is he relates better to women. He does. Not in a bad way, not in a negative way, not in a condescending way. I don't think there is anything in the case to suggest that Keith has a misogynist view of women.

NXIVM was run by women. I mean, Nancy Salzman ran NXIVM along with Keith. These women who had critical, important, long-term roles in his life all played tremendously central roles in NXIVM. So he put his great trust, his greatest of trusts, in these women. So there is no reason to think that somehow he has a view that women can't do the job; women can clearly do the job. And so I think that he just relates to women.

I think there is every reason to believe that his view of DOS of being something big, something transcendent, lots of different women, women who could do things for women's causes, things like that, is absolutely legitimate.

It wasn't just the subject of testimony, and it was the subject of testimony as something that Keith would say, it's on the tapes, it's on the tapes. Tapes that Keith had no reason to think would be played at his federal criminal trial, it's on the tapes. He wants DOS to be something bigger than just, I think, I don't know what Lauren Salzman said, 100 members, or 100-something members of DOS.

Let's stop there for a second. There is 100 members of DOS. You heard about sexual contact with what, a handful in DOS, in DOS and through DOS, a handful. Over 100 members. But getting back to the primary topic, I think he had every reason, and you have every reason to credit the testimony, that's what he wanted it to become. Not because he wanted them as sex partners. He was just doing in his life what he's been doing in his life for the last 20 years. I mean, he has sex with multiple women, as we all know that, it was one first facts we established in this case. Is this part of what he views as his legacy?

By the time DOS is created, he's in his early to mid 50s. I think he knows Pam is going to die. And then she ends up dying. Barbara Jeske just died. And he's thinking that some day I'm going to die. This person who was with me so long is soon to die, what does this mean for me, Keith Raniere.

I think DOS is created with the best of intentions. I don't think it's created for sex partners. I think it's created for the best of intentions. I think it's important that each of the groups are different. If it's the case that in Allison Mack's group, sex was more common. I think that's because of how Allison Mack viewed Keith Raniere. Not from a negative point of view, but possibly from a positive point of view. There is something about, I don't know, maybe he's safe; maybe because we're not going to get married; maybe because he's not going to want to you know settle down with me; maybe because this is something that so many other people have done; maybe it's somehow safe.

And I can experiment, and maybe that's of interest to some people. Maybe that's something at one point of your life you would say, that's a nice to have a safe place where I can be sexual without strings attached, without any consequences.

So I think it's individual. It's not across the board.

At one point there is a tremendous shift in perspective and virtually every witness who was with Keith testified in one form or another to this tremendous shift and perspective that each of them went through. They say things like, at the time I thought; but now looking back at it I think. That's the shift of perspective. How did this come about?

I suggest it comes about because of a series of steps. Jay leaves DOS. And remember, when Jay leaves DOS she takes a lot of collateral that she could get her hands on with her, because she wants that as her safety net. She take it is with her. At around the same time Mark Vicente leaves NXIVM.

Now Mark Vicente is a very important figure in NXIVM. He really was in many ways for a long time like Keith's number two guy. He's very high up in the organization. I think he has a lot of respect and I think him leaving NXIVM was a real blow.

And he leaves NXIVM, and then a lot of things start happening, and a lot of people start talking to each other. I'm not saying it's bad that they spoke to each other, it's utterly natural that they spoke to each other. But it's important in terms of the shift in perspective.

Vicente understandably is concerned, worried, something about the fact that there is this thing going on in the form of DOS, that he knows nothing about because he's pretty high up in NXIVM, so why doesn't he know about it. It makes sense that he's suspicious of it right off the bat.

Also it sounds bad. It sounds bad. We don't know exactly what Jay told him. We know he was talking to everybody. At one point he testified that he had spoken to over 20 people. So we don't know exactly who he spoke to, but we can assume that he spoke to over 20 women. And so it makes sense that he's going to be concerned about this. And he's going to be worried about it and going to think something nefarious and terrible is going to happen.

He then contacts Catherine Oxenberg, India's mother. And I think this brings it to another level. Because, quite understandably, Catherine Oxenberg being a mom is going to be very concerned about what is happening with her daughter. And at this point India is still in DOS. India is still in NXIVM. India is not seeing the world the way Mark Vicente is seeing the world, and she's still in it.

I think a battle ensues, you can see this from the evidence, of who's side is everybody going to be on. Are you going to stay aligned with DOS and NXIVM; or are you going to come to Mark Vicente and other people and kind of renounce DOS. I think what happens, is what often happens in discussions or arguments, both sides dig in. Vicente I think becomes convinced this is evil. He used the world evil a few times on the witness stand. This is not a matter of opinion, this is not a matter of interpretation, this is not a matter of one's own decision. This is sheer and pure evil. We're trying to figure out who is going to jump on that side of the argument and who is not going to jump on that side of the argument.

Everybody starts talking. Jay is talking. Sarah Edmondson is talking. Suki is talking. Vicente is talking to all of them.

Then on June 2, 2017 Vicente calls Franco Parlato. He once worked for NXIVM. Franco Parlato stopped, he was in a sort of legal dispute with someone and now is a great NXIVM critic, and a blogger. Vicente speaks to Franco Parlato. I think what his testimony is that Catherine Oxenberg spoke to Franco Parlato first, so now Vicente is speaking to Franco Parlato.

The reason all of this is relevant is because this is all how it leads to the tremendous change in perspective. There is no middle ground anymore. It's black or it's white. It's evil or it's good. It's only a matter of what side you're going to be on. I think you guys saw that in the testimony.

A few people, I think Nicole was one of them, would say, would treat this subject with a certain amount of gray. There was some good, there was bad. There was some things that I really liked, there were some things that weren't for me.

But there is a real strain in the testimony in the black and the white. I think neither one is really valid when a witness comes in here and is like it's bad, it's evil, it's terrible. That's not really that helpful to you because I think it's just too bias. It's just not an authentic genuine helpful view point.

MR. AGNIFILO: But this battle is going on. Now, at one point, if you remember when Nicole was testifying, Nicole said that she had a conversation with Frank Parlato and Parlato said, "I have your collateral." We don't know if Parlato did, we don't know if Parlato didn't but we know from Nicole that that's what Parlato said. And he also said what Nicole said Parlato said is go talk to law enforcement, all right.

Here's what you can take from these two aspects of Nicole's testimony, there's a force out there pushing people to one side or the other and in this case Parlato is pushing people to the, you know, Vicente-Catherine Oxenberg side and I'm not for the purpose of this discussion saying one is right and one is wrong, just for the purpose of what I'm talking to you about right now I'm just saying it's two very diametrically opposed camps, okay, and Nicole ends up kind of going that direction but much later in the fall.

The way that this plays itself out in terms of I think what you see in the trial evidence is that there's this tremendous change in perspective because once Keith's motives aren't trusted, the entire nature of DOS indelibly changes and what I mean by that is so much of DOS was about trust, you know, so much of it was about trust, you can give us your collateral but you have to trust that we're not actually going to release it. So much is about vulnerability and about trust and it turns out that when you play with vulnerability and trust, you're playing with fire because while everyone trusts everybody and while everyone is together and on the same page it's okay, okay, but soon as something happens there's this tremendous shift in perspective.

And I've been straining for an analogy because this is not -- what happened in this courtroom is not a situation that I think a lot of people can relate to because it didn't happen to you and the only thing that comes to mind is this, and it's an analogy, you guys will consider it for what it's worth: Let's say you have a very strict father, all right, and your father is like you have to get A-s and if you don't get A-s your father sends you up to your room and he keeps you in your room and he says, you know what, you study, you study hard and if you want to get out of your room you bring an A home next time and you go to your room and you study and you miss your friends outside who are playing baseball because you're in your room studying and you do that throughout your high school and college years and you end up, I don't know, being a lawyer, right, and then your father passes away and you look back at your father with this joy in your heart, okay, this gratitude because my father loved me so much that he pushed me to get good grades and I got good grades and now today I'm a lawyer and thank you, dad, you know, thank you, dad, for being hard on me. That's one perspective.

Let's say an angel who has supreme credibility comes from heaven and says to you, you have to know this, your father actually didn't love you, he couldn't stand the sight of you and by making you go upstairs to study was the only way he knew to just get you away from him because he couldn't stand being around you. That change -- you will not view your father the same way again. If you believe that, if you believe that, everything has just changed for you, your entire past has just changed for you and do you remember, and I don't know if you guys saw the movie, some of you mentioned the movie The Sixth Sense. If no one saw the movie, I'm not going to bother. I'm not sure if you guys saw the movie. But it's about perspective changes, it's about perspective changes and a little thing changes your whole perspective, what you thought was true, I thought my father loved me, wanted what was best for me and now I see something different about him and I don't trust him anymore and because I no longer trust my father, I view my childhood differently, it's not the same childhood I thought it was. That's what happened here. That's exactly what happened here. Because there are great forces, they're great, listen, the federal government has come in and these are, you know, very fine FBI agents and Assistant U.S. Attorneys and they represent the Department of Justice and they've basically said this is bad, this is bad, this is a bad thing. And before that, you know, you had people, Mark Vicente I think had a lot of credibility and he said this is bad, this is evil, don't -- you shouldn't trust Keith, don't trust him, everything you thought, don't think it anymore because it's all different. And so there's this tremendous change in perspective not because the past has changed but because there's this change of perspective in the present.

And one of the ways that you know the first perspective which I suggest to you is the only perspective because it's the perspective at the time, it's the perspective as these events were happening, the only way you know the actual perspective is through the written communications at the time and you should trust them, you should trust the emails, trust the text messages, trust that stuff because that is how everybody felt then, that is how everybody felt before the change in perspective and the change in perspective pretty much changes everything. But it's not what people were feeling or going through at the time. All right.

I want to talk a little bit about Camila. In some ways I think Camila is the most important person at this trial because she wasn't at this trial, she wasn't here. Neither side brought her as a witness. She didn't testify. If you believe Daniela, Daniela says that she spoke to Camila during the trial. So, we have -- if you believe Daniela, you have every reason to think that Camila knows about the trial but she's not here. So, we have to figure out what Camila means and how Camila figures into all of these events without Camila actually ever coming here and telling us herself her experience or how she feels about these events.

Here's what I think the evidence shows. I think Keith Raniere had a very long-term, intense, loving relationship with Camila, all right. He's not charged with having had sex with her under age so it's not something that I'm even going to talk to you about one way or the other. But I think what the evidence shows is that they are very much emotionally connected and that they have been for a while.

And I think what you see in the Camila chats, and I would encourage you to take some time and read through them and get more of a flavor for all of them, is that Camila stands up to Keith, Camila is not a shrinking violet, Camila is not someone who's just getting run over, you know, by the Vanguardness of Keith Raniere. She's not. She pushes back, she puts him in his place. When he gives her a hard time about things, she knows how to stand up for herself and you will see that time and again in the chats.

You will also see, I suggest, something about Keith that I think that you see in other evidence as well. There's this notion every once in a while that somehow Keith is like, you know, this -- the Wizard of Oz behind the curtain, this powerful figure. I think if you actually look at the evidence in this case, what you see is the exact opposite. We hear about Keith having an argument with a woman and hiding in a bathroom, okay. We have Keith just being out of his mind with jealousy and anger because Camila -- I'm not sure anger -- read the chats for yourself, I'm not sure it's quite anger. It's unrelenting, it's how could you do this, but how could you do this, but how could you do this, and tell me about this detail, tell me about this detail, and Camila is like, stop it already, I don't want to be -- no, tell me about this detail, I want to know about this detail, this painful agonizing detail, tell me about this detail. He's just beside himself. That's not power. I think that's the exact opposite.

At one point when Nicole was testifying I was asking her about that last meeting she had with Keith, I said, did he seem sad? And I was talking about at the time did he seem sad. And she says something like, well -- and I said, what, he's always sad? And she says, yeah, you know. He's not mighty, he's not great, he's not godlike, he's none of those things. He sits there and he creates curriculum, that's his greatness. There's nothing high and mighty about him and I don't think he looks to be high and mighty, I think he looks to have relationships with people that are of a certain type and with a certain level of intensity and you'll see that in the chats.

All right. The photos. The government says they were from two particular dates in 2005, and here's my question, there's no indication that those photos -- well, let me back up. The photos were printed out by the government. There's no evidence that the electronic information that led to the photo ever resulted in a photo from Keith's doing.

The state of the information is this, from what I understand, there was a hard drive, there was a Western -- whatever it was, the hard drive with the blue circle, all right. There was a hard drive and at one point it seemed to have been hooked up to a Dell computer or some other computer and that Dell computer or the other computer is no longer around. So, what seems to have happened is that these photos were taken from the camera with the serial number as they said, went into the Dell computer, the Dell computer had a backup, went to the backup and then the Dell computer is gone because it's probably obsolete because this is back from 2005 but the photos were found by the FBI on this hard drive, okay, which I think at the time that the FBI found the hard drive it wasn't connected to anything. So, it's just there. I mean, you know, it's a very large device, it has a lot of stuff in it and some of the stuff in it are these photographs, not just photographs of Camila but photographs of a lot of different people.

But the Camila photographs are completely different to the extent that they constitute contraband, they're illegal, they're illegal in of itself if they're pornography and, you know, if you find, and the judge is going to instruct you on what the definition of all of these things are, they're not sort of the same thing at all and what I mean by that is the government hasn't charged this as just Keith made these photographs or possessed these photographs, they've charged this that he made these photographs and possessed these photographs as part of his involvement in a racketeering -- his involvement in an enterprise, as part of his involvement in an enterprise.

There's no evidence that these photographs were ever looked at. There's no -- and I keep saying photographs, the electronic images that could be made into a photograph, they are on a camera, they go into a computer, they go to a hard drive, that's it, that's it. They're not sent anywhere, they're not shared with anybody. You know, the FBI CART examiner, I thought he was very good at what he does, he's very smart, he's very experienced, you know, there's no testimony that these were ever sent anywhere. They seem to have been on a camera, they went to a computer, they went to a hard drive, that's it. They weren't shared, they weren't viewed, no evidence of any of that.

How do they play a role in a racketeering enterprise? How do they play a role? How are they part of the common purpose? How are they part of Barbara Jeske's common purpose or Allison Mack's common purpose or Mark Vicente's common purpose or Jim Del Negro's common purpose or any of the common purpose of any of the people on this little bull's-eye chart here? It's not the common purpose of anybody. It's Keith. It's Keith in his private life, you know, it's not Keith as some head of being in the inner circle and that's what they charged.

And like I said yesterday, they charged an enterprise and they have to prove an enterprise and there's two aspects of this, there's the enterprise aspect and then there's something called there has to be a pattern of racketeering activity, all right. So, for the enterprise aspect, we talked about it a little bit yesterday, common purpose. No one knows about it. No one knows about it. Nobody knows about it. Keith seems to know about it. Camila seems to know about it. Nobody else knows about it. It's an absolute drop dead secret. The other thing is in the pattern of racketeering activity is that the acts have to be related, all right. So, all of the eleven acts that are in the racketeering charges, they have to be related in one form or another. And the government might say, well, they're related because, you know, Camila is in DOS or they're related because there are other photographs, but there being other photographs doesn't mean that somehow the fact that these are, you know, alleged child pornography is like anything else in the case, and I'm going to give you another analogy.

You and I go to a bank, say you and I are friends, we go to the bank. You go with me to the bank the first time, go the second time, go the third time. The fourth time you and I go to the bank I rob the bank. You didn't know I was going to rob the bank. I'm using the same personnel to go to the bank. Maybe you even told me where the bank was. But there's a certain central fact that you didn't know and it's such a central basic fact that you don't know that it defeats any commonality, any common purpose that we might have and that is the case with these photographs.

So, I suggest to you that the photographs in and of themselves really defeat the enterprise element that you have to find beyond a reasonable doubt because there's no common purpose to them with anything else and they're not related in terms of any of the other racketeering activity.

Now, ultimately you have to find that the government has proven the charges beyond a reasonable doubt. For you to find a racketeering act, you all unanimously have to find that the racketeering act was proven beyond a reasonable doubt. You have to find the existence of an enterprise and the other elements of the racketeering statute beyond a reasonable doubt. And I don't submit that you can do that.

If you listen very closely to His Honor's charge and you listen to the elements very closely and you really link the elements to the evidence, you may very well conclude that a lot of what you heard in the evidence in this case was repulsive, disgusting, offensive, all of those things, but we don't convict people in this country for being repulsive or offensive. We convict people in this country because Congress passes a statute with certain elements and that statute with the elements that Congress passed is violated and the proof of that violation is proven to a jury like yourselves beyond a reasonable doubt.

So, I'm going to sit down in about three minutes and I'm never going to have the chance to speak to all of you again so let me end on this note, the attention that you've paid has been remarkable. The demands that we put on you have been remarkable as well. You've all been here every day early and on time and really helped us out a tremendous amount and I just want to say thank you. I want to say thank you for your attention, thank you for trying so hard and you really do I think have one of the hardest jobs to do that I can imagine because I can't imagine the courage that it would take after sitting through the evidence at this trial and acquitting Keith Raniere, I can't imagine the courage that that would take because everything in your innermost being might say to you, I can't do that, that was wrong, so many things that he did were wrong, so many things that he did offended me and I can't do that. But if you go back, and you get instructed by Judge Garaufis, and you really sit down and you go through the elements of the actual charges and you say, you know what, I don't like DOS but I don't think it is about commercial sex, I don't like DOS but I don't think the coercion or the fraud was for the purpose of causing commercial sex, you have to find him not guilty of those counts. You would have to check not guilty all the while thinking, gosh, I wish I didn't have to but that is part of your duty is to follow the judge's instructions in terms of proof beyond a reasonable doubt and listening to every element of every offense. You might find so many things about him distasteful but a lot of them, most of them aren't part of the charges and so when you get that jury summons, you know you're doing something that's monumentally important in terms of really serving your country but you're also doing something that's monumentally difficult and that you're really now a part of our system, you're an extension of the court, you're an extension really of our society, of our community, you know, and what our rules are is that unpopular ideas aren't criminal, disgusting ideas aren't criminal, disgusting lifestyles aren't criminal, specific things that violate tangible crimes passed by Congress are criminal and nothing else. So, again I just want to thank you for all of your time and attention.

Thank you, Judge.