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2019 Federal TrialtranscripttranscriptLauren Salzman — Direct (Part 1) - Day 8 - 2019 Federal TrialLauren Salzman’s direct testimony covered her guilty plea, role in DOS, relationship with Keith Raniere, and admitted participation in Daniela’s confinement and obtaining DOS property.
Tanya HajjarMoira Kim PenzaMarc AgnifiloNicholas G. GaraufisLauren SalzmanMS. HAJJARCourt ClerkLauren SalzmanTHE COURTMR. AGNIFILOMS. PENZAdirectsidebar
3 pages·3 witnesses·1,763 lines
Fontanelli completed testimony about seized cash, including an unexplained difference between a count and deposit records. Welch addressed restraint-product orders and consent. Lauren Salzman began testimony about her guilty plea, participation in Daniela’s confinement and DOS extortion, and relationship with Raniere.
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DirectDirectLauren Salzman — Direct Lauren Salzman Tanya Hajjar

MS. HAJJAR: Thank you, Your Honor.

The government calls Lauren Salzman to the stand.

COURT CLERK: Please raise your right hand.

(Witness takes the witness stand.)

LAUREN SALZMAN, called as a witness, having been first duly sworn/affirmed, was examined and testified as follows:

COURT CLERK: Please have a seat.

And please state or spell your full name for the record.

LAUREN SALZMAN: Lauren Salzman, L-A-U-R-E-N, S-A-L-Z-M-A-N.

THE COURT: You may inquire.

MS. HAJJAR: Thank you, Your Honor.

DIRECT EXAMINATION BY MS. HAJJAR:

MS. HAJJAR: Good morning, Miss Salzman.

LAUREN SALZMAN: Good morning.

MS. HAJJAR: Are you familiar with an organization called NXIVM or ESP?

MS. HAJJAR: Were you a part of it?

LAUREN SALZMAN: Yes, I was.

MS. HAJJAR: How long were you a part of NXIVM?

LAUREN SALZMAN: Almost 20 years.

MS. HAJJAR: Who is the founder of NXIVM?

LAUREN SALZMAN: Keith Raniere.

MS. HAJJAR: Did Keith Raniere have a name or title within NXIVM?

LAUREN SALZMAN: Yes, he did.

MS. HAJJAR: What was that?

MS. HAJJAR: Do you know of an organization called The Vow or DOS?

MS. HAJJAR: Were you a member of that organization?

LAUREN SALZMAN: Yes, I was.

MS. HAJJAR: When did you join DOS?

LAUREN SALZMAN: In January 2017.

MS. HAJJAR: Who was the leader of DOS?

LAUREN SALZMAN: Keith Raniere.

MS. HAJJAR: Did he have any titles within DOS?

MS. HAJJAR: What were they?

LAUREN SALZMAN: Master, Grand Master and Supreme Master.

MS. HAJJAR: What did you call him?

LAUREN SALZMAN: I called him Master.

MS. HAJJAR: Who called him Grand Master?

LAUREN SALZMAN: So within DOS, there was a first line, and those first lines were directly under Keith. So they were -- he was their master and they were his slaves.

And then under them were their slaves, so he would be their grand master.

MS. HAJJAR: Were you a part of the first line?

LAUREN SALZMAN: Yes, I was.

MS. HAJJAR: Do you see Keith Raniere in the courtroom today?

MS. HAJJAR: Can you identify him by an article of clothing and where he is sitting?

LAUREN SALZMAN: He's sitting at the defense table in the blue sweater.

THE COURT: All right. Let the record indicate that the witness has identified the defendant.

MS. HAJJAR: Thank you, Your Honor.

MS. HAJJAR: How long have you known the defendant?

LAUREN SALZMAN: Twenty years.

MS. HAJJAR: Can you describe your relationship with him over the past 20 years?

LAUREN SALZMAN: Yes.

He was my mentor and teacher. He was -- we had a romantic relationship, a physical, sexual relationship from mostly between 2001 and 2008, or '9. And then not for a period of almost ten years, and then briefly in 2017, and he was my master.

MS. HAJJAR: Was your relationship with him important to you?

LAUREN SALZMAN: Very important to me. Yeah.

LAUREN SALZMAN: Um, he was my most important person. I mean, I respected him and trusted him and looked up to him; wanted to be like him. Um.

MS. HAJJAR: Has that relationship now ended?

LAUREN SALZMAN: For me, yes.

MS. HAJJAR: Did you see the defendant regularly in the past 20 years?

LAUREN SALZMAN: Yes, I did. On and off, yeah.

MS. HAJJAR: And can you describe to the jury in what context you saw the defendant?

LAUREN SALZMAN: Various contacts. Socially. Um, you know, whether going on walks. Hanging out with friends. Parties. Birthday parties. Holiday parties. At corporate events. Trainings. Courses that we ran. Many different contexts.

MS. HAJJAR: When you say "training" and "courses," is that in the context of NXIVM or ESP?

LAUREN SALZMAN: Yes, and some of the other companies. Jness. SOP.

MS. HAJJAR: And did you see the defendant -- did you have an opportunity to observe him with other people, too?

MS. HAJJAR: And which people?

LAUREN SALZMAN: Many people. I mean, friends. Colleagues. Partners. Students. Community members.

MS. HAJJAR: Have you committed crimes with the defendant?

MS. HAJJAR: Have you committed crimes with other members of NXIVM or DOS?

MS. HAJJAR: What crimes did you commit?

LAUREN SALZMAN: Um, so there's two groups, or two -- between 2010 and 2012, I, with Keith and Kristin Keeffe and a number of members of the family -- well, let me -- there's a women. Her name is Daniella, Dani, and so her family members, myself, Keith, Kristin and others, basically kept this woman in a room for two years under the threat that she would go back to Mexico if she didn't perform certain results of our product.

And then there was a separate group, myself and Keith, and others, the DOS group, received property, some of the property was damaging information; true or untrue. Some of it was material possessions.

And based on having that property, we extorted more property from the women within that group. And we collected that property based on material -- materially false information, false pretenses.

The group was secret and we concealed that Keith was -- was the founder of the group, was a member of the group, and participated in any way in the group.

And then the material that we received, we received it through WhatsApp, Telegram, like different apps, email and phone communications.

MS. HAJJAR: So with respect to the category of friends related to Daniella, Dani, when was that crime committed?

LAUREN SALZMAN: Between 2010 and 2012.

MS. HAJJAR: And as to the other types of crimes you described, was that in the context of DOS?

LAUREN SALZMAN: The other crimes were in context of DOS, yeah.

MS. HAJJAR: When did you commit those crimes?

MS. HAJJAR: And who did you commit these crimes with?

LAUREN SALZMAN: With Keith and the first line DOS masters; Allison Mack, Rosa Laura Junco, Daniella Padilla, Loreta Garza, Nicki Clyne. Camilla. Um, I think that's all.

MS. HAJJAR: Was Monica Duran part of that group as well?

LAUREN SALZMAN: Oh, yes, Monica Duran.

MS. HAJJAR: Can you describe to the jury what your position was in DOS?

LAUREN SALZMAN: I was a first line DOS member, and I was a slave with Keith as my master. And then I was a master with others under me. And as well as grand master, I guess.

MS. HAJJAR: The individuals you mentioned, with exception of Keith, did that group comprise the first line of DOS?

MS. HAJJAR: Did you meet with the first line of DOS?

MS. HAJJAR: How often while you were part of DOS?

LAUREN SALZMAN: Every time I was in town in Albany, we met three times a week, about ten hours a week.

MS. HAJJAR: And where were those meetings held?

LAUREN SALZMAN: Initially they were held at people's homes, and then later we bought a house and they were held at the house. It was considered the sorority house.

MS. HAJJAR: Were these meetings secret?

LAUREN SALZMAN: They were, yes.

MS. HAJJAR: Can you describe these meetings to the jury?

LAUREN SALZMAN: So the start of every meeting, we would take a naked photograph and -- as a group -- and send it to Keith. And the photograph had to be fully frontally naked and our brands had to show. We have brands. And we were to be -- look uniform and happy in the photographs, and then we would get dressed.

And depending on what the focus of the meeting was, we would cover different things; whether it was going over the work project that we were working on for the sorority, or checking in on them, doing work groups on them, taking consequences for failing in the work projects, or sometimes there could be other focuses.

MS. HAJJAR: When you say "sorority," do you mean DOS or The Vow?

LAUREN SALZMAN: DOS. Yeah, yeah.

MS. HAJJAR: Did the defendant sometimes attend those meetings?

LAUREN SALZMAN: Yes, he did.

MS. HAJJAR: Can you describe what happened in those meetings when the defendant attended?

LAUREN SALZMAN: When he would attend, we would all get undressed, totally nude, and sit on the floor below him, and he would usually sit on, you know, above, on a chair.

And depending on what the focus was, he talked to us about a number of different things; whether it was some idea for the sorority, you know, some philosophical concept, or asking us about the different various projects we were working on, or people within the sorority.

MS. HAJJAR: You said you and the other first line slaves removed your clothes.

Did the defendant remain clothed?

LAUREN SALZMAN: Remained clothed, yes.

MS. HAJJAR: What were some of the topics discussed at the meetings?

LAUREN SALZMAN: A book that we were working on, something called The Game. Enrollment or recruitment. A dungeon. Other things. Several things.

MS. HAJJAR: In the -- during these meetings, did the defendant discuss his vision for DOS?

LAUREN SALZMAN: Sometimes, yes.

MS. HAJJAR: When did you stop being part of DOS?

LAUREN SALZMAN: Depends, I guess, how you look at it.

In June 2017, DOS became public, and so a lot of the ongoing operations stopped. Most of them stopped at that time. And then we focused more on PR stuff.

And then in -- after New Years 2018, um, coming close to like more February, Keith wanted to do a reenrollment effort or a recommitment and get things going again.

So that never happened because he was arrested, and so formally I think everything ended at that point. So March 2018, end of March.

MS. HAJJAR: When you say "at that point," what are you referring to?

LAUREN SALZMAN: Keith's arrest.

MS. HAJJAR: Now, at some point after the defendant's arrest, did you plead guilty to federal crimes?

LAUREN SALZMAN: Here. In this room.

MS. HAJJAR: In this courtroom?

LAUREN SALZMAN: In this courtroom, yeah. In the Eastern District of New York.

MS. HAJJAR: What did you plead guilty to?

LAUREN SALZMAN: I pled guilty to racketeering; conspiracy and racketeering.

MS. HAJJAR: And what's your understanding of what racketeering is?

LAUREN SALZMAN: That racketeering is a group of individuals who participate in criminal activity.

MS. HAJJAR: What specific crimes as part of racketeering did you plead guilty to?

LAUREN SALZMAN: I pled guilty to harboring and trafficking of Dani and forced labor. And then to the DOS crimes, extortion and forced labor and wire fraud.

MS. HAJJAR: And when you say "Dani," is that Daniella, the woman you described earlier?

MS. HAJJAR: How old were you when you first met the defendant?

LAUREN SALZMAN: Twenty-one.

MS. HAJJAR: How old are you now?

MS. HAJJAR: When did you first meet the defendant?

LAUREN SALZMAN: I met him in 1998.

MS. HAJJAR: Were you in school at that time?

LAUREN SALZMAN: I was. I was a senior in college.

MS. HAJJAR: Where were you in school?

LAUREN SALZMAN: I went to school in Oswego State.

MS. HAJJAR: When did you graduate?

LAUREN SALZMAN: In June of 1998.

MS. HAJJAR: What did you do after you graduated?

LAUREN SALZMAN: I traveled in Europe with some friends for about six weeks, and then I came home to live with my mom.

MS. HAJJAR: What did you do after that?

LAUREN SALZMAN: I took a job doing some secretarial work for her and then started at ESP, Executive Success Program.

MS. HAJJAR: Can you describe that to the jury, when you say you started at ESP?

LAUREN SALZMAN: Yeah.

So my mom and Keith decided they were going to start a business, and it was going to be a human potential school. And when I graduated, my mom told me that they were going to teach classes that were going to be good for helping people achieve their goals, and basically for me figuring out what I wanted to do in this next stage of my life.

And she made a deal with me that if I came into classes for six months, then she would support me, no matter what I wanted to do after that.

So I came home and there was a six-week -- they wanted to do a six-week trial program for the courses that they were releasing, and they did it. There were 25 people in that original group, and so I participated in that first trial run of the classes.

And Keith came and taught all the classes two times a weeks, and I took them as a student.

MS. HAJJAR: Did you expect to stay in ESP after that trial period?

LAUREN SALZMAN: Not initially, but at the end of the six weeks, I decided I wanted to stay.

MS. HAJJAR: And did you stay?

MS. HAJJAR: Who else was involved with NXIVM at that time?

LAUREN SALZMAN: Well, Keith was, and my mom. And Toni Natalie, Barbara Jeske, Pamela Cafritz, Kristin Keeffe, Dawn Morrison. I think Karen Unterreiner might be a little bit later.

MS. HAJJAR: And your mother, what's her name?

LAUREN SALZMAN: Nancy Salzman.

MS. HAJJAR: How did you meet the defendant for the first time?

LAUREN SALZMAN: My mom had met him and he was helping her with some of the work that she was doing at Con Edison in the nuclear power plant, and she had been excited about meeting him and his group of friends, and she had wanted me to meet them all.

So initially I -- I think I was home on a college, like a vacation from school, on a college break, and so I stopped at National Health Outlet, which was a business that Keith and Toni were running at the time, and just met them briefly.

And then later my mom had a dinner party to introduce us to her new friend.

MS. HAJJAR: Can you tell the jury your first impressions of the defendant?

LAUREN SALZMAN: I thought he was a little strange. I mean, at the dinner party, everybody was very nice and very entertaining. But I was -- I felt awkward and uncomfortable around Keith at first.

MS. HAJJAR: Did your mother appear to admire him?

LAUREN SALZMAN: Very much. Yeah.

MS. HAJJAR: And did that affect your opinion of him?

LAUREN SALZMAN: It made me think that he was really smart and -- and especially when she would talk about her work at the nuclear power plant.

They were going through deregulation in Con Edison and she would talk about Keith was helping her implement a management system's program that he created and she would talk about -- like she would be in a meeting and she would run to the bathroom, and she would call him, and he would instruct her about what to do.

And she was really excited about the things that they were doing together and felt that it was really effective and she was getting good results at the nuclear power plant.

And so it made me think that he was really good at what he did; that he was really smart and had some really good -- and the way she described it -- innovative ideas.

MS. HAJJAR: Did the defendant show you attention?

MS. HAJJAR: Can you explain that to the jury.

LAUREN SALZMAN: Um, he would call and check in on me in the early days. I moved back home and was living with my mom. I didn't have a lot of friends that I was close to from high school, so I spent a lot of time alone. But he would check in.

And eventually like if I meet him for walks, and we would talk.

MS. HAJJAR: Can you explain the walks you're referring to?

LAUREN SALZMAN: He would just invite me to go for a walk and we would talk about all different things. Eventually I came to confide in him about struggles that I was having in my family, things that were going on in my life.

MS. HAJJAR: Where were you living at this time?

LAUREN SALZMAN: I was living at home with my mom at 7 Grand Hill Road in Clifton Park.

MS. HAJJAR: And at some point did the defendant encourage you move out of your mother's home?

MS. HAJJAR: Can you explain that further?

LAUREN SALZMAN: Well, yeah.

So another friend of ours had -- had come home and was also living at home with her parents, and so she moved out and he would encourage that, well, like Tori moved out, so like when are you going to move out?

But also at that time I think he inspired my mom to start charging me rent for living at home and -- so that I would be aware of, you know, what it was like to support myself.

And so that inspired also me to want to move out and be more self-reliant.

MS. HAJJAR: In the early years of NXIVM, where did the defendant live?

LAUREN SALZMAN: At 3 Flintlock Lane in Clifton Park.

MS. HAJJAR: Who did he live with?

LAUREN SALZMAN: He lived with Pam Cafritz and Karen Unterreiner and Kristin Keeffe.

MS. HAJJAR: I'd like to show you what's in evidence that --

I'll hold on, Your Honor.

I'd like to show you what's in evidence as Government Exhibit 12.

(Exhibit published.)

MS. HAJJAR: Do you recognize this person?

LAUREN SALZMAN: Yes. Pam Cafritz.

MS. HAJJAR: I'm going to show you what's in evidence as Government Exhibit 53.

(Exhibit published.)

MS. HAJJAR: Do you recognize this person?

LAUREN SALZMAN: Yes, Karen Unterreiner.

MS. HAJJAR: And Government Exhibit 34.

(Exhibit published.)

LAUREN SALZMAN: Kristin Keeffe.

MS. HAJJAR: What role did Pamela Cafritz play in the defendant's life?

LAUREN SALZMAN: I think she was Keith's closest person. She was his partner for over 30 years, and I think his most -- Pam believed in Keith, I think, more than anybody, more than anybody else, and was more supportive of everything that he did than anyone else.

MS. HAJJAR: Were they equal parties in that relationship, in your view?

LAUREN SALZMAN: I don't -- no. No, I don't think so.

LAUREN SALZMAN: I think -- I mean, in some ways I think Keith related with Pam like a parent; like correcting her or disciplining her at times.

But I think, in general, like Keith had a vision of how he thought things could be, and Pam supported that vision. So he was like the leader and she followed and supported.

MS. HAJJAR: At some point did another woman move into 3 Flintlock with the defendant?

LAUREN SALZMAN: Yes, Marianna.

MS. HAJJAR: I am going show you what's in evidence as Government Exhibit 26.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: That's Marianna.

MS. HAJJAR: Did Marianna have a nickname?

LAUREN SALZMAN: Yes, we called her Monkey.

MS. HAJJAR: And can you describe the relationship between the defendant, Pam Cafritz and Marianna?

LAUREN SALZMAN: Well, Pam and Marianna were, I think, best friends and pretty inseparable, in general.

And the three of them were kind of, a -- like a unit, to some degree. Like to a degree to the exclusion of others. It was the three of them.

MS. HAJJAR: A romantic and sexual unit, in your -- as best as you knew?

LAUREN SALZMAN: I mean, I -- I believe so.

MS. HAJJAR: Your Honor, if you wanted to break at noon, now would you a good time, I think.

THE COURT: All right. We're going to take a half hour for lunch.

All rise for the jury.

(Jury exits the courtroom.)

THE COURT: You may step down.

Please don't discuss your testimony with anyone.

Okay. Half an hour.

MS. HAJJAR: Thank you, Your Honor.

(Witness steps down.)

(Whereupon, a recess was taken at 12:06 p.m.)

A F T E R N O O N S E S S I O N

(Time noted: 12:30 p.m.)

(In open court; Jury not present.)

(Defendant enters the courtroom.)

THE COURT: Let's bring in the witness.

(Whereupon, the witness resumes the stand.)

THE COURT: Let's bring in the jury.

Ms. Hajjar, does the witness require the list?

MS. HAJJAR: I don't believe so right now, Your Honor.

THE COURT: Okay. Thank you.

(Jury enters the courtroom.)

THE COURT: Please be seated.

All right, Ms. Hajjar, you may continue with your examination of the witness.

The witness is reminded that she is still under oath.

DIRECT EXAMINATION (Continued) BY MS. HAJJAR:

MS. HAJJAR: Ms. Salzman, did there come a time where you and the defendant began a sexual relationship?

LAUREN SALZMAN: Yes, there did.

MS. HAJJAR: When did that begin?

LAUREN SALZMAN: In April 2001.

MS. HAJJAR: What was the date?

MS. HAJJAR: Who initiated that?

LAUREN SALZMAN: He did. But I was open to that.

MS. HAJJAR: And what happened on April 1st, 2001?

LAUREN SALZMAN: We began a sexual relationship.

MS. HAJJAR: Was that date later commemorated in any way?

LAUREN SALZMAN: Yeah, as an anniversary. We considered it our anniversary.

MS. HAJJAR: And the word "anniversary," was that used to describe the first date you had sex with the defendant?

LAUREN SALZMAN: Yes, that's correct.

MS. HAJJAR: Did you celebrate your anniversary with the defendant?

LAUREN SALZMAN: Um, when we celebrated it, I mean, generally we would spend time together or just acknowledge it as the date of the anniversary. Wish each other a happy anniversary.

MS. HAJJAR: What did the defendant's birthday? When was his birthday?

LAUREN SALZMAN: His birthday is August 26th.

MS. HAJJAR: And was that date celebrated?

LAUREN SALZMAN: We celebrated it as a community. In the early days, we had a Vanguard day, and then it became, you know, longer. We went away for a weekend retreat. So it was like Vanguard long weekend and then it became Vanguard week eventually.

MS. HAJJAR: When you say "we celebrated it as a community," are you referring to the NXIVM ESP community?

LAUREN SALZMAN: Yes, the NXIVM ESP community.

MS. HAJJAR: When you say you celebrated the defendant's birthday as part of Vanguard week, can you describe some of the ways you celebrated his birthday during that week?

LAUREN SALZMAN: Sure.

We created a corporate retreat. So there were many things that took place at the retreat. But on his birthday specifically, we would have a lot of birthday cakes for, you know, everybody at the retreat. And usually we would have some sort of performance or entertainment, sometimes a tribute performance.

And often then he would have a forum where he would speak to the community and they could ask him questions and he would answer them.

MS. HAJJAR: Were you involved in the preparations for Vanguard week?

MS. HAJJAR: Was this -- was Vanguard week sometimes referred to as V Week?

LAUREN SALZMAN: V Week, yes.

MS. HAJJAR: How long did it take to prepare for V Week each year?

LAUREN SALZMAN: A long time. I mean, it depends what you were preparing. But some of the preparations, you know, took months to prepare.

There were different things to prepare, so there was, you know, all the administrative work was one kind of bucket of things. I did a lot of the entertainments or activities during the week. And promote, you know, promotions. There were NXIVM organizational things, and then there were more social-based things. But it was a lot of preparation.

One year, I mean, I think I put probably, you know, a hundred to two hundreds hours of preparation work in for what took place there, and that was just me.

MS. HAJJAR: Were you aware the defendant celebrated an anniversary with Pamela Cafritz?

MS. HAJJAR: What date was that?

LAUREN SALZMAN: Valentine's Day.

MS. HAJJAR: Now, at the time you began your relationship with the defendant, did you openly or discuss it or acknowledge it?

LAUREN SALZMAN: No. He asked me not to.

MS. HAJJAR: Did you speak with your mother about it initially?

LAUREN SALZMAN: No, he asked me not to.

MS. HAJJAR: Was it difficult not to tell your mother about the relationship?

MS. HAJJAR: How long did you have a sexually intimate relationship with the defendant?

LAUREN SALZMAN: It was mostly between 2001 and 2008 or '9. And decreasing, you know, towards 2000, you know, '6, '7, '8, '9, so during that time.

And then we didn't for, you know, nine or ten years.

And then he initiated again just for a brief period after DOS became public in 2017.

MS. HAJJAR: And during that entire period of time from 2001 to 2017, were you in sexual romantic relationships with anyone besides the defendant?

MS. HAJJAR: And was that a requirement?

MS. HAJJAR: Can you explain that.

LAUREN SALZMAN: Um, yeah, well, for -- I mean, for me it was a monogamous relationship, and at one point in time he -- after we had stopped being intimate and weren't spending -- intimate sexually -- stopped spending a lot of time together, he had told me he had made the decision to put the relationship on hold.

But it was my understanding that that wasn't a permanent decision and so, you know, it was my understanding that if I had a relationship with somebody else, that would be leaving the relationship.

So I didn't, you know. I stayed.

MS. HAJJAR: You said you considered the relationship monogamous.

Was that monogamous on both sides?

LAUREN SALZMAN: No, for me.

MS. HAJJAR: Did you ever express wanting to have a relationship with someone else to the defendant?

LAUREN SALZMAN: Yes. I -- yes.

In 2013, I wanted to have a relationship with somebody else, and I was -- I discussed it with him and told him I was thinking of leaving the relationship.

MS. HAJJAR: What happened?

LAUREN SALZMAN: He told me that -- I mean, there were a couple of things that happened.

So he told me that if I stayed, he would reinvest in our relationship and that we would have children. And I asked him when? And he said, Soon. And I said, Soon like a year or soon like five years? But I wanted to say Soon, like a month or soon like five months, you know?

And he said, um -- between that time, within that time, a year to five years was his time -- estimated time frame.

And then we went on a subsequent walk where he said that I have -- I have been spending time with someone else. And I went -- that was not part of our community and that I had gone to high school with, and I shared a kiss with that person and I went and I came back and I told Keith and I said if you want -- I understand if you want to end the relationship, because I did this. And I was hoping that he would end the relationship, because I did that. And he didn't. And I said I was trying to get myself to a place where I felt strong enough to leave.

And so then he made the promise that if I stayed, he would invest and then I -- but then we had a subsequent walk where he told me that he had considered resigning as Vanguard because of what I had done.

MS. HAJJAR: Was that a big deal to you, resignation at Vanguard?

LAUREN SALZMAN: It was, yeah. It was a huge deal to me. Because -- and I couldn't make sense of why he would like leave the community without a leader because I had done this.

So then I thought, if I ever -- I just always thought of it like if I ever wanted to leave, or how I would leave, or I always had to be much more mindful that I would do something that would be so, um, lacking in such care for the community that I loved and cared about, that I could do something that would make it so that he wouldn't be the leader for them anymore. It was really upsetting for me. And I took it very -- I took it to heart.

MS. HAJJAR: During the course of your relationship with the defendant, was his approval important to you?

LAUREN SALZMAN: Yeah. It was like the most important thing to me; that he thought that I was doing well and that I was upholding -- I was a good person, that I was upholding the principles that we upheld within our community, and that we said we all shared.

MS. HAJJAR: When you say "upholding the principles of the community," is that a term that's used within the --

LAUREN SALZMAN: Yeah. Yeah. That's like -- that I was somebody who, um, made good moral decisions, or that I was like honest or had integrity or had a strong character.

I wanted to be that and I wanted his -- I looked at him and how he viewed me to determine whether I was that.

MS. HAJJAR: Did you check in with the defendant before making decisions in your life?

LAUREN SALZMAN: Yes. Most of my decisions.

MS. HAJJAR: Can you give some examples of that?

LAUREN SALZMAN: Sure.

Like if I wanted to go and visit my grandparents out of town. Or if I wanted to buy a house. Or plan a work trip out of town. I would check if it was -- if those things were, like created any difficulties for him, or he was on board for those decisions, if he thought they were good.

I checked with -- I mean, medical advice before like medical decisions. I checked most things.

MS. HAJJAR: Did you receive medical care without his permission?

LAUREN SALZMAN: I mean, basic medical care. Like annual medical care, you know, but not major medical care.

MS. HAJJAR: Before you began a sexual relationship with the defendant in 2001, did you have a discussion with him regarding your weight?

MS. HAJJAR: What did he tell you?

LAUREN SALZMAN: That he thought a good weight for me would be around a hundred pounds.

MS. HAJJAR: And how did he make that decision?

LAUREN SALZMAN: There was like a fasting thing going on during that time, like a bunch of the people in his group, his social group, were doing juice fast, so I learned what a juice fast was. And then I think one of the -- I think it was Pam or Barbara like said to me that I should ask Keith like when it was a good time to stop fasting.

And so I asked him and he -- I mean, basically saw me in my underwear and assessed whether there was fat on my body, and what a good weight would be, based on looking at me and my body constitution.

MS. HAJJAR: So he told you -- is it right that he told you you should be a hundred pounds after looking at you?

LAUREN SALZMAN: Yeah. Yeah.

MS. HAJJAR: You mentioned Pam. Is that Pam Cafritz?

LAUREN SALZMAN: Pam Cafritz.

MS. HAJJAR: You mentioned Barbara. What's her last name?

MS. HAJJAR: Now, at the time, did you consider the defendant an authority on your weight?

LAUREN SALZMAN: Yeah. I considered him authority on almost everything, on most things.

MS. HAJJAR: And to your knowledge, was that view shared by others in the community?

MS. HAJJAR: How was the defendant viewed within the community, the NXIVM community?

LAUREN SALZMAN: I think very well. Like very respected. That he was a incredibly moral person and -- and an adept thinker, very ethical, and he was, I think viewed -- like I wasn't the only one who checked with him on decisions. I think a lot of people did. And not even people close to him, like a lot of people would -- community members, would ask him about major things going on in their life.

Or like I remember somebody -- their family member was kidnapped in Mexico and they wanted to call Keith, you know, to figure out what to do.

MS. HAJJAR: Were there aspects of the NXIVM curriculum that reinforced that?

MS. HAJJAR: Can you explain that a little?

LAUREN SALZMAN: Well, tribute was a big thing within NXIVM in general. That it was good to recognize other people's strengths and accomplishments and to give recognition for that.

There were, similar to how you have like belts in martial arts, there's a ranking system with sashes that we would wear and so there was a progression, graduated rank, and he was at the top of that.

And -- and there were -- there's a module, a class that we teach in the basic curriculum, that we taught in the basic curriculum, that is called personal values and inventory trading, and it talks about like the graduated levels of contribution that you can make in like added value to the world.

And there are ten levels, and at the top of it is like the contribution that affected the changes. The nature of what it is to be human. Like it's such a value that all of your experience of humanity is different afterwards, and like electricity or the computer or something like that.

And so it was discussed in that class that the curriculum that he created, we called it the technology, the model, was this level ten invention. And so it conferred this really high level of respect and appreciation of value for what he had done. And that, yeah.

And so anybody who came and took that, those courses, you know, was made aware of the -- of how valuable we thought the contribution was, his contribution was.

MS. HAJJAR: And by extension him?

MS. HAJJAR: Were there certain myths about the defendant that were repeated within the community?

MS. HAJJAR: Can you describe some of them to the jury, please.

LAUREN SALZMAN: Yeah. Like that -- like a lot of times when there -- if there would be like a big -- if we were teaching like a big -- if we released like a new curriculum, and he gave us this curriculum and there would be like a big snowstorm or something, like a lot of times the weather, we would attribute to that these things happen around Keith a lot times. Or like if technology didn't work, it would be like technology acts funny around Keith. Like these kind of phenomenal things or there are these phenomena of -- but like, yeah, attributed to around him this stuff happens.

MS. HAJJAR: Did the defendant himself encourage or reinforce that in some way?

LAUREN SALZMAN: Yes, I believe so.

He would say that his technology was acting up and that he has those types of problems or -- yeah.

MS. HAJJAR: Did he attribute that to something specific?

LAUREN SALZMAN: Just that it was this unique thing about him where these things happen.

And, yeah. I mean, like that it was -- that it was something special about him.

And then, I mean, my perception of it and the way that people related with it, that it was something about his energy or his impact on the world somehow.

MS. HAJJAR: What about the weather?

LAUREN SALZMAN: Yeah. That -- yeah, like, um -- well, he told me this one story a few times that there -- that he was on a walk with somebody, and that they were behaving somehow in a way that wasn't good, and that it was -- he was trying to show them some point, and that it was raining, but that it wasn't raining on him. It was raining on them.

And that he pulled them to show them that the rain wasn't happening in here and that, you know -- and that that was to convince them or to show them something that he was trying to convey that there was something about him that was different or something about his perspective or the way he was viewing the world that was really important. And that he was proving it to them by demonstrating this point.

And he told me that story a number of times.

MS. HAJJAR: Did you --

LAUREN SALZMAN: And others, I think, heard that story as well. I've heard it from others.

MS. HAJJAR: Did you interpret that to be a metaphor or --

LAUREN SALZMAN: No, actually. Actually.

MS. HAJJAR: Did there come a time when the defendant took intimate photographs of you?

MS. HAJJAR: When approximately was that?

LAUREN SALZMAN: Somewhere before 2006. Like around 2005, I think.

MS. HAJJAR: So how old were you approximately, if you recall?

LAUREN SALZMAN: I think I was late 20s.

MS. HAJJAR: Where were those photographs taken?

LAUREN SALZMAN: At 8 Hale Drive.

MS. HAJJAR: Can you describe 8 Hale Drive to the jury, please.

LAUREN SALZMAN: Yeah.

8 Hale Drive is a townhouse that -- it's a two-floor townhouse that has -- we referred to it as the executive library, but it was modified so to have kind of an open concept. So like the -- when you first walk in, it's like kitchen/living room.

And he had a grand piano in there. And then you can go upstairs and there was like a trap door so that nobody downstairs could get upstairs. But you can go upstairs and there were a lot of bookshelves, and like a work station, table, white boards. And then a loft bed at the top.

And there was some exercise equipment, a hot tub, and a sauna in the bathroom.

MS. HAJJAR: Where at 8 Hale Drive were the photographs taken of you?

LAUREN SALZMAN: In the loft bed.

MS. HAJJAR: Can you describe what happened to the jury.

LAUREN SALZMAN: Yeah.

We -- I remember that we had been intimate and then afterwards he wanted -- he had a camera that was on the -- there was like a shelf above the bed, and there was a camera. And he took the camera and said that he wanted to take a picture of me. And I was very shy about that and didn't want to have a picture taken of me. And he was like, no, let me. It's going to be nice.

And so he took, I think, two pictures. But they were like -- they were looking up at me from like the angle of -- it's like an up-close crotch shot, like -- like vagina looking up where you could see my whole upper body and face.

MS. HAJJAR: Did you see the photographs at the time the defendant took them?

LAUREN SALZMAN: I saw one briefly. Quickly.

MS. HAJJAR: And did that photograph show what you just described to the jury?

MS. HAJJAR: Did you express concern to the defendant about someone seeing the photographs?

LAUREN SALZMAN: Yes. I said I didn't -- that I was concerned that some -- yeah, I was worried that somebody might see it and he was like nobody will see it. Don't worry.

MS. HAJJAR: What kind of camera did the defendant use to take these photographs?

LAUREN SALZMAN: Like a normal camera, like a camera with a flash. Not like phone camera, like a -- like a photographer's camera.

MS. HAJJAR: Did you ever see the photographs again?

MS. HAJJAR: Did the defendant ever give you instructions about grooming your pubic hair?

MS. HAJJAR: What did he tell you?

LAUREN SALZMAN: That he thought that if I -- that if I loved and cared for him, I would care for his preferences. So his preference was that it be natural. So not groomed. And not -- he thought that was loving, that I would keep it that way.

MS. HAJJAR: Did he tell you anything about what that preference is based on?

LAUREN SALZMAN: I don't know if it's the basis for the preference, but he said it held the pheromones and he liked that.

MS. HAJJAR: Did you ever ask him permission to change that, to change your pubic hair grooming?

MS. HAJJAR: Did there come a time where you had a conversation with the defendant about you accommodating other people?

MS. HAJJAR: What did he tell you?

LAUREN SALZMAN: He asked me -- we were on the phone and I was -- I think I was driving somewhere out of town, and he asked me how come I never talked about the times that I had sex to accommodate people.

MS. HAJJAR: And when you said "people," what -- who was he referring to as you understood it?

LAUREN SALZMAN: Other -- previous -- like prior relationships that I had had or people I had had sex with prior to him, was my understanding.

MS. HAJJAR: Did you engage in sexual activity with the defendant and other women?

LAUREN SALZMAN: Well, mostly Pam. Sometimes Barbara. Once Marianna and more limited interactions with Cathy and Siobhan.

MS. HAJJAR: Is that Cathy Russell?

MS. HAJJAR: Who initiated these sexual encounters?

MS. HAJJAR: Why did you participate in them?

LAUREN SALZMAN: Well, initially I participated in them because I was curious and I was -- I had questions regarding my sexuality, and I wanted to explore that. And then sometimes because Keith wanted to. Wanted that.

MS. HAJJAR: Were you ever approached about having a sexual encounter that you didn't want to participate in?

LAUREN SALZMAN: A few times.

MS. HAJJAR: From who?

LAUREN SALZMAN: Well, when I -- early in my relationship with Keith, Dawn approached me and said that she -- she was inviting me, if I wanted to have that with them.

Daniella also approached me, a different Daniella then the -- Dani Padilla. And then later Allison and also Kryslana (phonetic).

MS. HAJJAR: Daniella, that's Daniella Padilla?

LAUREN SALZMAN: Yes, correct.

MS. HAJJAR: Did she have a married name?

MS. HAJJAR: Did you ever have a conversation with Pamela Cafritz about her sexual interactions with the defendant and other women?

MS. HAJJAR: What did she say?

LAUREN SALZMAN: That there were periods of time where he wanted to do that every day. Or he had them doing that every day. And that she didn't always prefer to do it, or to do it with the people he wanted to do it with.

MS. HAJJAR: Was there something that happened with Dawn Morrison?

MS. HAJJAR: What happened?

LAUREN SALZMAN: We were -- well, we were at 3 Flintlock hanging out one night, and I can't remember the whole exchange, but Keith was like tickling me or it started out as tickling, roughhousing, but then tried to pull my pants off. And I didn't want them to come off. And I interpreted that as him initiating a sexual interaction, and I -- he was just very like persistent and forceable about it, and I had to say no several times, until he acquiesced to the no.

MS. HAJJAR: Did the defendant ever frame his sexual relationships in terms of personal growth?

MS. HAJJAR: Can you give some examples of that?

LAUREN SALZMAN: Like early on in our relationship he asked me how I would feel if he took on Dani and Monica. And taking them on, to me, meant starting a sexual relationship with them to help them grow.

And I mean not the clearest example, but the -- I think, generally, he related with it a lot that way. Like he would say that he was -- that sometimes the sexual relationships were very difficult, but he was helping them.

MS. HAJJAR: When you say "Dani," is that Daniella Padilla?

MS. HAJJAR: When you say "Monica," is that Monica Duran?

MS. HAJJAR: Did other women express unhappiness to you in their sexual relationships with the defendant?

LAUREN SALZMAN: Yes. Many. Most.

MS. HAJJAR: Can you name them? Some of them?

LAUREN SALZMAN: I mean, different people at different times for different reasons, but I think that generally the -- it was difficult to be in a relationship with somebody who had relationships with so many people.

But, yeah. Ivy. Barbara. Both Barbaras. And myself. Kristin. Marianna. Camila. Monica.

MS. HAJJAR: Were you ever asked to intervene?

MS. HAJJAR: Who asked you?

LAUREN SALZMAN: Keith. Kristin. Pam. Most often.

MS. HAJJAR: Can you explain that to the jury.

LAUREN SALZMAN: Sure.

That someone he was having a relationship with would be upset with him in some way, and sometimes maybe even be threatening to leave or wanting to leave or end the relationship, and we would be asked to help them. And help them ultimately was to work through whatever their upset was so that they would be happy with him instead.

MS. HAJJAR: So when you say "help them," what does that mean? What did you do?

LAUREN SALZMAN: Looked at why they were having an emotional reaction and I mean oftentimes it was -- like within the ESP model and the framework that we were working with, there was a lot of focus on it. It was believed -- we all believed that we are responsible for our own emotional reactions, and that if you have an emotional reaction to something, the thing that you're having the emotional reaction to is just triggering a reaction that you have inside yourself. It's not causing you to have that reaction, it's giving you an opportunity to see the issues that you struggle with.

And so, generally, if somebody had an emotional reaction to something, and in this specific case, something with Keith, we would look at the fact that they were having a reaction, and look at this as an opportunity to work it through and -- and the thought was that if you left the circumstance to be more comfortable, you would be covering up that issue and your opportunity to work it through.

So sometimes you would talk about that, like this is for your growth. This is an opportunity, how are you ever going to get through there issue if you leave?

MS. HAJJAR: Was the intention to persuade them to stay or to leave?

LAUREN SALZMAN: Stay. Stay. And work through whatever you have to work through so you stop having that reaction. So stay and feel happy. Be joyful.

MS. HAJJAR: Did you consider that reenrolling them?

LAUREN SALZMAN: No, but I think it was.

MS. HAJJAR: Can you explain that.

LAUREN SALZMAN: Well, at the time I considered that helping them. Or helping Keith with them. But I think often if somebody -- if they wanted to leave, we would reenroll them. And this is a good idea. This is for your growth. This is very helpful for you. Keith only has your best intent in mind, you know.

And how are you going to get through this if you leave? So it was reenrolling them in this idea of growth and this idea that this relationship is especially helpful and effective for growth.

And -- and essential. Because if you left it, you wouldn't have that same opportunity.

MS. HAJJAR: Did the defendant ever tell you in the context of these interventions that not to say that he had sent you?

MS. HAJJAR: Did that happen often?

MS. HAJJAR: Looking back now, do you have an opinion about what you were being asked to do?

LAUREN SALZMAN: Yeah. I mean, there were times -- I mean, there were lots of times I wanted to leave the relationship and somebody reenrolled me back into it or talked me back into it.

And there were times also where I was talking to somebody who wanted to leave and wasn't happy, wasn't either getting through the issue or finding a way to exist there in some kind of healthful way or healthy way, and I talked them back into staying.

And I do think some of them, it would have been good for them, healthier for them to not be there.

MS. HAJJAR: Were you ever accused of committing an ethical breach with the defendant?

MS. HAJJAR: And can you explain that, what that meant to you?

LAUREN SALZMAN: Basically that I had compromised my ideology or had done something that was not ethical and that was damaging or destructive in favor of being mindless or more comfortable or lazy.

MS. HAJJAR: Can you explain or describe some of the ethical breaches you were accused of committing.

LAUREN SALZMAN: Well, yeah.

One -- so one of them was we had to a corporate retreat at Pyramid Lake. And Keith released this writing project, and the writing project was something we didn't know about ahead of time. It was just something that he introduced there. And so it -- it was a very involved process and it took many hours, like we were there like ten hours, or something -- like it was a long -- a long process. And I wasn't enjoying the process and felt like I didn't have a choice to be there.

I didn't feel able to say I didn't want to do it or I didn't feel like that was acceptable as part of the leadership of ESP, and I was unhappy and -- and it was visible to others that I was having emotional -- a negative emotional reaction to being there. And then I was told that that was very damaging and destructive, and that I had changed people's perception of the writing project itself.

And -- and that I had hurt their perception of what a good leader is. Because if I'm a leader, and I'm acting in this really immature and damaging way, that it basically shows that I'm -- that our technology doesn't work, because look at how the lack of growth in me and that if this is acceptable in our leadership, then our leaders aren't respected. And that if this is how the leaders view the project, then it instructs other people how to view the project in a negative way.

MS. HAJJAR: So your ethical breach was that you didn't want to do the writing project.

LAUREN SALZMAN: And demonstrated emotional upset in front of other people about it.

MS. HAJJAR: What happened after you were accused of having committed an ethical breach in connection with the writing project?

LAUREN SALZMAN: I apologized and promised to fix it and -- I mean, generally the process of when you -- when there was a breach, you would, you know, humble yourself; you be humble and like confess, or commit. Like a -- be honest about what you had done and the damage about it and make a commitment and a plan to fix it.

MS. HAJJAR: Was there another ethical breach in connection with volleyball?

LAUREN SALZMAN: Yes. So -- yeah. Sorry.

So around 2011, at one point Keith had -- he had come around that time and said that he thought that it was a good -- it was a good time that we could start trying to have children, and then I would -- I jumped on someone. I was excited and roughhousing in volleyball and I jumped on someone, Mike Baker, and Keith said that, um -- he was like you straddled him like and that that communicated that I was open to having -- the way that I behaved with men was inappropriate and that I was communicating that I was open to have relationships with all these other men, and that I was really disrespectful to him.

Marianna thought that I was easy and that how could he have children with me if this is the way that I respect or treat him, and it's visible for other people and not sort of communicated to Marianna, and so he called that off.

MS. HAJJAR: Did you perceive roughhousing with Mike Baker to be some kind of sexual interaction or romantic interaction?

LAUREN SALZMAN: No. But then I thought that how could I have been so mindless that that's what I'm communicating and don't even know that I'm communicating that.

And so I must have something -- it must be a bigger thing, a bigger problem, than I understand, because I can't even see it.

MS. HAJJAR: When you say Marianna thinks you're easy or -- was that something Marianna said to you or the defendant?

LAUREN SALZMAN: No, it's something that he said.

And then I thought like if this was something you wanted to do last week, and then all of a sudden Marianna is going to voice it this opinion, and now you're going to change the whole thing, like I don't -- it created a certain type of animosity between me and Marianna that didn't exist before.

MS. HAJJAR: What happened after this?

LAUREN SALZMAN: Can you be more specific.

MS. HAJJAR: Yes.

What happened with respect to -- after you had had this conversation about the ethical breach, did you try to fix it?

LAUREN SALZMAN: Yes. I did.

And also I didn't -- I was aware then that the way that I was being perceived was communicating something that I didn't want to be communicating to the men, and I -- I didn't go to volleyball and -- the next volleyball. And then I got feedback that I should have gone to the next volleyball and acted differently, or like that I wasn't taking the breach seriously enough to have attended to it or been doing something about it.

So I cleared my schedule and stayed home for a whole weekend and came up with like a very involved seven-page plan about what were all the ways that I was behaving inappropriately, and how it affected everybody, like all the men who went to volleyball, and Marianna, and my mom, and Keith, and the community, and how everybody perceived me as a leader, and basically held this like -- just empowered the work that we were doing in the community and in the company and in the world. And I came up with this very involved plan about how to fix it.

MS. HAJJAR: Your Honor, may I show something to the witness for -- that's just marked for identification?

THE COURT: Go ahead.

MS. HAJJAR: I'm showing you what's marked for identification as Government Exhibit 1497.

Do you see that?

MS. HAJJAR: Do you recognize this?

MS. HAJJAR: What is it?

LAUREN SALZMAN: It's an email that I wrote to Keith where I'm telling him that I am apologizing and that I canceled everything not pertinent to the intensives I was teaching.

MS. HAJJAR: Ms. Salzman, just wait a minute.

Do you recognize this email? Is this something you wrote?

LAUREN SALZMAN: Yes, I wrote it.

MS. HAJJAR: Your Honor, the government offers it. This is Government Exhibit 1497.

MR. AGNIFILO: We have no objection.

THE COURT: All right. Government Exhibit 1497 is received in evidence.

(Government's Exhibit 1497, was received in evidence.)

THE COURT: It's published to the jury.

(Exhibit published.)

MS. HAJJAR: Thank you, Your Honor.

BY MS. HAJJAR:

MS. HAJJAR: Ms. Salzman, who is this email from?

LAUREN SALZMAN: Me. From me.

MS. HAJJAR: And who is it sent to?

MS. HAJJAR: And what's the date of this email?

LAUREN SALZMAN: March 13, 2011.

MS. HAJJAR: And the subject line?

LAUREN SALZMAN: Lauren Breach Plan Specific Steps 0311.

MS. HAJJAR: Is there a subject of the email that's above that, what you just read?

LAUREN SALZMAN: Oh, yeah. Lauren Amended Breach Plan 0311.

MS. HAJJAR: And above that, is there a subject line?

LAUREN SALZMAN: RE, a Sword in the Field.

MS. HAJJAR: Okay. And the thing that appear under that, are those attachments to this email? Do they look like attachments?

LAUREN SALZMAN: I don't see any attachments.

MS. HAJJAR: Okay. So these -- the following pages, what are these?

LAUREN SALZMAN: That's the -- yeah, the breach plan.

MS. HAJJAR: That's the breach plan.

LAUREN SALZMAN: All the consequent -- all the damage that I felt I had caused in the plan and how I was going to fix it.

MS. HAJJAR: Okay. Now, is this email, Government Exhibit 1497, was this in connection with volleyball, the thing you mentioned?

MS. HAJJAR: Okay. Can you read the text of that email up top.

LAUREN SALZMAN: Yes.

Read the email?

MS. HAJJAR: Beginning "I'm so sorry, Keith."

LAUREN SALZMAN: I'm so sorry, Keith. I canceled everything not pertinent to the two intensives coming up and the community project since Friday to try to figure this out. I hope you know how important it is to me. I'm sorry I didn't do it sooner.

I also did feel uncomfortable going and being around everyone before really resolving myself with how I was going to heal them -- with them and you. I also felt like until you saw that I had a solid plan, you might feel I would be a liability to have there. I certainly did. Given that the one time I showed up of my own accord, this year I created enough damage to thwart our plans together for the rest of our lives.

MS. HAJJAR: All right. And then the pages that appear after that, are these -- is that the solid plan that you're referring to in that email?

MS. HAJJAR: What did you intend to convey with this, with the documents that are attached to this email?

LAUREN SALZMAN: That I was willing to do whatever it took to fix it. And that I had thought that through in a very responsible and well thought-out way. And had real concrete steps for what to do to change it, to fix it.

MS. HAJJAR: So the top of this next to numeral 1, where you say: I have not respected my relationship. I defaulted on my commitment and was not honest about what I was doing or mindful about the effects.

Was this in connection with roughhousing with Mike Baker at volleyball?

LAUREN SALZMAN: It may have also been -- it may have been referring to a different relationship where I was -- had a flirtation with another person, and he asked me about it directly, and I sideswiped the issue.

And then when he asked me a second time, I was honest. So then I had been dishonest, and that came up again as an example when the Mike Baker thing happened.

MS. HAJJAR: So can you just explain why are you referring to that in the context of an email sent in relation to the volleyball incident you mentioned?

LAUREN SALZMAN: Because it was brought up as a pattern of how I relate with men and the ways that I disrespect the relationship and why we can't go forward and have children.

MS. HAJJAR: Can you read the paragraph you wrote next to numeral 3. Just that first part.

LAUREN SALZMAN: I'm perceived as easy or available for relationship or viewed as jumping from man to man, so not taken seriously. This degrades me and also sets a bad example in the organization and reflects poorly on Keith and his choice to be with me or have a child with me.

And then there was --

MS. HAJJAR: And paragraph 4 makes reference to Monkey.

Who is Monkey?

LAUREN SALZMAN: Marianna.

Do you want me to read it?

MS. HAJJAR: Can you read starting from, "it also may put us at risk"?

LAUREN SALZMAN: It also may put us at risk if Monkey leaves or does something destructive. It also disempowers me to be able to help Monkey, if needed, and it would put doubt about Keith's choice to have a child with me, given the way I have behaved.

MS. HAJJAR: Can you read the last bullet point on this page.

LAUREN SALZMAN: Also by healing this and becoming more functional, I could impact the perception that Keith only spends time with weak, disfunctional people.

MS. HAJJAR: At this time, did you have a view of yourself as weak or disfunctional? Are you referring to yourself there?

LAUREN SALZMAN: I'm not sure if I did think I was disfunctional.

And there was a perception of Keith, that spending time with weak and disfunctional people, who were also in addition to me.

MS. HAJJAR: Can you just read the first sentence next to numeral 7, number 7.

LAUREN SALZMAN: Mike, Ben, Jim and others don't see me as a respectable person for Keith to have a relationship or a child with. This reflects poorly on Keith and changes their internal representations of him.

Continue?

MS. HAJJAR: Can you read number 10.

LAUREN SALZMAN: I damaged the way others will view, relate with and treat our child, so I'm hurting someone who doesn't even exist yet.

MS. HAJJAR: All of these pages are in connection with your breach plan?

MS. HAJJAR: Are you familiar with a woman named Siobhan?

MS. HAJJAR: Who was Siobhan?

LAUREN SALZMAN: Siobhan was a proctor in ESP NXIVM, and a friend of ours.

MS. HAJJAR: And can you describe if proctor is a rank in the --

LAUREN SALZMAN: Proctors are rank, yeah.

The proctors like run throughout the educational programs. And their first -- like Level 1 where you can have a business with a person at that level of rank. They're like the managers.

MS. HAJJAR: Are you aware of Siobhan's sexual orientation?

LAUREN SALZMAN: Siobhan identifies as gay, yeah.

MS. HAJJAR: Was she married?

LAUREN SALZMAN: She was married and then divorced and now remarried.

MS. HAJJAR: And her first marriage, was that to a woman?

MS. HAJJAR: Was Siobhan's wife involved in NXIVM?

MS. HAJJAR: At some point did you become aware that Siobhan and her wife wanted to have children?

LAUREN SALZMAN: I did, yes.

MS. HAJJAR: And to your knowledge, did she and her wife take steps to accomplish that?

LAUREN SALZMAN: They did, yes. They went through fertility treatment, with an anonymous donor.

MS. HAJJAR: Did there come a time where the defendant spoke to you about Siobhan's decision to have children with an anonymous donor?

MS. HAJJAR: What did he tell you?

LAUREN SALZMAN: He told me that Loreta remembered that Siobhan at one time had asked him to be the donor. And that when Loreta reminded her about this, Siobhan went and victimized herself to her wife, like she was being pressured against her will to do this, and that that had changed Christine's, her wife's, perception or beliefs and perceptions about Keith.

And basically that she had thrown him under the bus to her wife, and this was damaging.

MS. HAJJAR: So let's take that slowly.

What did the defendant consider to be Siobhan's breach?

LAUREN SALZMAN: That she had victimized herself and spoke badly about him to her wife concerning Keith possibly be the donor.

MS. HAJJAR: Can you just break that down a little bit and explain it.

So what did she do to victimize herself, in the defendant's view, as he explained it to you?

LAUREN SALZMAN: That she felt forced and then spoke about him like he was forcing her to do it, and made her wife think that she had been forced and felt. And then Christine viewed Keith badly because of this.

MS. HAJJAR: Forced to do what?

LAUREN SALZMAN: To have Keith be the donor of their child.

MS. HAJJAR: Did the defendant tell you what would have healed Siobhan's breach?

LAUREN SALZMAN: Yes. That Siobhan would legitimately come and ask him to be the donor.

But then he said that he didn't intend to have the child with Siobhan. He wasn't going to have a child with Siobhan, but just that she had to legitimately ask.

But to me that didn't relate to the breach of throwing him under the bus to Christine. And if he hadn't wanted to be the donor, then why would it have been important to remind Siobhan about this in the first place?

MS. HAJJAR: Did the defendant make a comment about Siobhan and her choice not to have him as the donor for her children?

LAUREN SALZMAN: Yes, that he didn't understand -- he didn't understand why she wouldn't want to have him as the donor. And like why she would choose an anonymous donor over him, who she knew and had a prior relationship with.

And also that his children would have 50 percent off of the children's educational program that he created. And so that seemed to him a good thing.

MS. HAJJAR: What was the educational program he created?

LAUREN SALZMAN: Rainbow. Rainbow Cultural Gardens. It's a multicultural -- multicultural multilingual educational program that was expensive. So he said his children would have 50 percent off of that.

MS. HAJJAR: Were you asked to speak to Siobhan in any way regarding this?

MS. HAJJAR: What were you asked to do?

LAUREN SALZMAN: To help Siobhan resolve this breach.

MS. HAJJAR: And what did you do in response to that?

LAUREN SALZMAN: Met with Siobhan and tried to help her resolve the breach.

But I didn't really believe that what resolved the breach was her going to Keith and asking him legitimately to be the donor. So I tried to help Siobhan look at why she would victimize herself and speak badly of others.

MS. HAJJAR: In your discussions with Siobhan, did Siobhan say she wanted to have the defendant be the donor of the -- you know, the donor's sperm for a child?

LAUREN SALZMAN: No, she said she did not want him to be the donor of the child.

MS. HAJJAR: Did you suggest to Siobhan that she and her wife should offer to have the defendant's child?

LAUREN SALZMAN: I don't believe so. I -- no.

LAUREN SALZMAN: Because I thought it was ridiculous, and it didn't even seem to relate to really what the breach was.

MS. HAJJAR: Did Siobhan become aware she had committed an ethical breach against the defendant?

LAUREN SALZMAN: She was given feedback about it, at least by me and Pam, and I'm not sure if others.

MS. HAJJAR: What does it --

LAUREN SALZMAN: I believe she discussed it with Loreta, too, but...

MS. HAJJAR: What does it mean to give feedback in this context?

LAUREN SALZMAN: To alert her that her actions and behavior had caused some damage that she ideally would care about and want to correct.

MS. HAJJAR: What happened to Siobhan in terms of her employment?

LAUREN SALZMAN: Well, she didn't -- I mean, she never resolved the issue with Keith, to his satisfaction, and wasn't eligible to participate in, I think, new business opportunities that she likely would have, if she had.

MS. HAJJAR: And when you say "eligible to participate in business opportunities," do you mean because she had committed this breach with the defendant?

LAUREN SALZMAN: Yes, and didn't resolve it.

MS. HAJJAR: Did you ever discuss having children with the defendant?

MS. HAJJAR: Did you want a child with the defendant?

MS. HAJJAR: Can you explain those discussions? What discussions you had with him?

LAUREN SALZMAN: Well, we started -- I mean, I think I started talking about having children very -- I would say within the first five years of our relationship. I had expressed that I wanted to have children.

And when I starting getting closer to 30, I started pushing that I thought I wanted to do it sooner. And he had always said that we would do that, that that could be something that we could do.

And then I told you about what happened in 2011, so it was put off. And then I wanted to leave in 2013, and he said we would do it if I stayed, and then I stayed, and we weren't doing it.

And it was just this never-ending thing that got put off and put off and put off.

MS. HAJJAR: Did there come a time where the defendant told you he was considering having a child with someone else?

LAUREN SALZMAN: Yes.

In 2015 he told me he was considering having a child with Marianna. And asked me if I would -- and commit to staying with him, even with no relationship and no children.

MS. HAJJAR: Did he say anything else in that conversation?

LAUREN SALZMAN: Yeah. Well, yes.

He had said that he shared with me that there had been -- Marianna had had abortions.

MR. AGNIFILO: Your Honor, can we have a sidebar for a second.

THE COURT: Come up.

(Continued on the next page.)

sidebarsidebarSidebar Conference Held

(Sidebar conference.)

[REDACTED]

DirectDirectLauren Salzman — Direct Lauren Salzman Tanya Hajjar

(In open court; Jury Present.)

BY MS. HAJJAR:

MS. HAJJAR: Miss Salzman, when the defendant said that he was considering having a child with Marianna, how did you react?

LAUREN SALZMAN: I was very upset. It felt very hurtful and confusing to me.

MS. HAJJAR: What did you do?

LAUREN SALZMAN: I had a complete meltdown and I -- but then my emotional reaction became the -- you know, the reason that I am making things harder and creating more problems, and why there are so many difficulties with Marianna is a direct result of the fact that I behaved this way, and so then ultimately I went and apologized for my immaturity and bad behavior.

MS. HAJJAR: Did you --

LAUREN SALZMAN: And committed to stay with nothing. No relationship and no children.

MS. HAJJAR: Did you -- were you permitted to speak to anyone else about this?

LAUREN SALZMAN: Yes. But he asked me to please not to speak to my mother about it. And I asked who I can speak to about it, and he wanted -- he suggested Dani Padilla, and I didn't want to.

And I asked if I could have permission to speak to Rosa Laura and he said, Yes. And so I spoke to Rosa Laura about it.

MS. HAJJAR: What's Rosa Laura's last name?

MS. HAJJAR: Ms. Salzman, based on your own firsthand observations over the 20 years you've known the defendant, did the defendant have a special relationship of trust with certain individuals?

MS. HAJJAR: Did the defendant rely on those individuals to run organizations he created, like NXIVM or DOS?

MS. HAJJAR: Were you a member of this group?

MS. HAJJAR: Was this an informal group?

LAUREN SALZMAN: Yes, informal.

MS. HAJJAR: And at times was this group referred to as the "inner circle"?

MS. HAJJAR: Who were some of the individuals in the defendant's inner circle?

LAUREN SALZMAN: Pam Cafritz.

MS. HAJJAR: Is this a photograph -- I'm just showing you what is in evidence as Government Exhibit 12.

(Exhibit published.)

MS. HAJJAR: Is this Pam Cafritz?

MS. HAJJAR: Who else?

LAUREN SALZMAN: Barbara Jeske.

MS. HAJJAR: And showing you what's in evidence as Government Exhibit 31.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: That's Barbara Jeske.

Karen Unterreiner.

MS. HAJJAR: This is Government Exhibit 53.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: Karen Unterreiner.

MS. HAJJAR: Anyone else?

LAUREN SALZMAN: Kristin Keeffe.

MS. HAJJAR: I'm showing you again what's in evidence as Government Exhibit 34.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: That's Kristin.

Dawn Morrison.

MS. HAJJAR: Showing you Government Exhibit 40 in evidence.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: That's Dawn.

My mother, Nancy Salzman.

MS. HAJJAR: I'm showing you what's in evidence as Government Exhibit 51.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: That's Nancy, my mom.

Myself.

MS. HAJJAR: I won't show you your picture.

LAUREN SALZMAN: Barbara Bouchey.

MS. HAJJAR: Showing you what's in evidence as Government Exhibit 6.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: That's Barbara.

Cathy Russell.

MS. HAJJAR: Showing you what's in evidence as Government Exhibit 48.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: That's Cathy.

And then, um, Daniella.

MS. HAJJAR: Showing you what's in evidence as Government Exhibit 23.

(Exhibit published.)

LAUREN SALZMAN: That's Dani.

MS. HAJJAR: That's Daniella?

LAUREN SALZMAN: Yes.

Marianna.

MS. HAJJAR: Showing you again what's in evidence as Government Exhibit 26.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: That's Marianna.

Camila.

MS. HAJJAR: Showing you what's in evidence as Government Exhibit 21.

(Exhibit published.)

LAUREN SALZMAN: That's Cami, Camila.

MS. HAJJAR: Anybody else?

LAUREN SALZMAN: Loreta Garza.

MS. HAJJAR: Showing you what's in evidence as Government Exhibit 16.

(Exhibit published.)

MS. HAJJAR: Who is that?

MS. HAJJAR: Loreta Garza?

LAUREN SALZMAN: Yes.

Monica Duran.

MS. HAJJAR: I'm showing you what's in evidence as Government Exhibit 19.

(Exhibit published.)

LAUREN SALZMAN: Monica.

Ivy, I-V-Y, Navares.

MS. HAJJAR: Showing you what's in evidence as Government Exhibit 44.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: That's Ivy.

MS. HAJJAR: Anyone else?

LAUREN SALZMAN: Clare Bronfman.

MS. HAJJAR: Showing you what's in evidence as Government Exhibit 8.

(Exhibit published.)

LAUREN SALZMAN: That's Clare.

MS. HAJJAR: That's Clare Bronfman?

LAUREN SALZMAN: Yes, it is.

Jim Del Negro.

MS. HAJJAR: Showing you what is in evidence as Government Exhibit 17.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: That's Jim.

Mark Vicente.

MS. HAJJAR: Showing you what's in evidence as Government Exhibit 54.

(Exhibit published.)

MS. HAJJAR: Who is this

LAUREN SALZMAN: That's Mark?

Emiliano Salinas.

MS. HAJJAR: Showing you what's in evidence as Government Exhibit 49.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: Emiliano.

Rosa Laura Junco.

MS. HAJJAR: Showing you what's in evidence as Government Exhibit 33.

(Exhibit published.)

LAUREN SALZMAN: That's Rosa Laura.

MS. HAJJAR: Is your microphone off, Miss Salzman?

LAUREN SALZMAN: I'm sorry. I touched it.

That's Rosa Laura.

Nicki Clyne.

MS. HAJJAR: I'm showing you what's in evidence as Government Exhibit 15.

(Exhibit published.)

MS. HAJJAR: Who is that?

LAUREN SALZMAN: That's Nicki.

Allison Mack.

MS. HAJJAR: Showing you what's in evidence as Government Exhibit 39.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: That's Allison.

Daniella Padilla.

MS. HAJJAR: Showing you what's in evidence as Government Exhibit 45.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: That's Dani. Daniella Padilla.

Alex Betancourt.

MS. HAJJAR: Showing you what's in evidence as Government Exhibit 3.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: That's Alex.

Jack Levy.

MS. HAJJAR: Showing you what's in evidence as Government Exhibit 27.

(Exhibit published.)

MS. HAJJAR: Who is this?

LAUREN SALZMAN: That's Jack.

MS. HAJJAR: Your Honor, may I show something to the witness only?

THE COURT: Go ahead.

MS. HAJJAR: Ms. Salzman, I'm showing you what's marked for identification as Government Exhibit 362.

MS. HAJJAR: Do you see this?

MS. HAJJAR: Does Government Exhibit 362 reflect the members of the inner circle you described?

LAUREN SALZMAN: Yes, it does.

MS. HAJJAR: Your Honor, the government offers Government Exhibit 352 into evidence.

MR. AGNIFILO: No objection.

THE COURT: All right, Government's Exhibit 362 is received in evidence.

(Government's Exhibit 362, was received in evidence.)

MS. HAJJAR: May I publish it, Your Honor?

(Exhibit published.)

MS. HAJJAR: Miss Salzman, what distinguishes the members of this group from others in the NXIVM community?

LAUREN SALZMAN: I think their relationship with Keith, their belief in him, and their commitment to him and to helping him and his objectives.

MS. HAJJAR: How did the defendant gauge that?

LAUREN SALZMAN: I think by, in some ways, what the people were willing to do. In some cases, by what they were willing to give up.

I think there's different ways of gauging their commitment and their shared values.

MS. HAJJAR: How did he gauge your loyalty, your commitment?

LAUREN SALZMAN: I think there are different ways, but I mean, there were times where he would come to me and ask like if I ever came to you and asked you to do something and I didn't -- I couldn't tell you why, would you do it?

And he asked me that on several different occasions. Like would you do -- would you be willing to just do what I ask you and no questions? And I would say, Yes.

MS. HAJJAR: Was that true?

LAUREN SALZMAN: Yes. It was true.

MS. HAJJAR: Now, did the members of this group change over time?

MS. HAJJAR: Is there some significance to the order of individuals listed in Government Exhibit 362?

LAUREN SALZMAN: Yeah. General time frame.

MS. HAJJAR: What do you mean "general time frame"?

LAUREN SALZMAN: Like as you -- as you -- if you start at top with Pam, as you go clockwise, those were the people who were Keith's friends and, I guess, people who were loyal to him and committed to him when I first met him.

And then in time there are people who -- and it's not necessarily exact, but became closer, became more trusted then over time.

MS. HAJJAR: So the individuals that are listed in the top left corner of Government Exhibit 362, those were late comers to this group?

MS. HAJJAR: Relatively speaking.

MS. HAJJAR: Did some of the individuals in this group have sexual relationships with the defendant?

LAUREN SALZMAN: Yes. Most of them.

MS. HAJJAR: Can you identify the rank in the context of ESP, of the individuals depicted in Government Exhibit 362?

LAUREN SALZMAN: Sure.

So the rank in ESP, Keith is the high -- was the highest rank, and then my mom was second.

So that's my mom, and Keith, were the two honorary ranks. They fell outside the ranking system because they created the ranking system.

Then the next highest rank, and they wore purple sashes. They were the senior counselors. That was Pamela Cafritz and Barbara Jeske.

Sorry, where I touched it is a little bit off.

And then the next wore the greens. They were senior proctors. That was Dawn. Myself. Barbara Bouchey. Loreta. Emiliano. Mark and Alex.

And then were the proctors. Karen. At one point Kristin. Cathy. Monica. Ivy. Clare. Jim. Nicki. Rosa Laura. Daniella. Allison. And Jack.

And then Marianna was a coach. I think at one time Dani was a coach. And then Cami was a student.

MS. HAJJAR: Now, Pamela Cafritz. What was her background?

LAUREN SALZMAN: Pam came from a well-to-do family from DC. Her dad, I think, was a builder. And I think they were socialites.

MS. HAJJAR: And Clare Bronfman, what was her background?

LAUREN SALZMAN: Clare's family is independently wealthy. Her -- her family is the Seagram's -- Seagram's family. So also independent, you know, well-to-do.

MS. HAJJAR: And based on your observations, what role did Clare Bronfman play in the defendant's life?

LAUREN SALZMAN: I think that Clare is -- was a supporter of Keith, and I think she felt responsible for some of the bad media surrounding our organization and some of the -- and felt that part of rectifying that was to try to make that right; financially, legally.

MS. HAJJAR: What does that mean, try to make that right financially?

LAUREN SALZMAN: I think she felt responsible like she caused the bad effects and like she could fix it somehow by pursuing different legal initiatives and covered some of the costs that were incurred from that negative press or publicity.

MS. HAJJAR: Did she cover some of the cost?

LAUREN SALZMAN: I believe so.

MS. HAJJAR: And when you say "legal initiatives," do you mean on behalf of NXIVM or the defendant?

MS. HAJJAR: Now, Daniella and Marianna and Camila, the individuals on the lower right corner of Government Exhibit 362, were these individuals related?

LAUREN SALZMAN: Yes, they're sisters.

MS. HAJJAR: Where are they from?

LAUREN SALZMAN: From Mexico.

MS. HAJJAR: Can you tell the jury generally when they joined the NXIVM community?

LAUREN SALZMAN: They didn't all join at the same time, but generally probably between 2001 and 2002 or '3.

MS. HAJJAR: Did the defendant have nicknames for any members of this group that you're aware of?

MS. HAJJAR: Can you give the jury some examples?

LAUREN SALZMAN: Like Marianna was Monkey, or Dani was Bobo.

MS. HAJJAR: When you say "Dani," do you mean Daniella, or do you mean Daniella Padilla Bergeron?

LAUREN SALZMAN: Daniella.

Cathy we called Miss Cathy.

MS. HAJJAR: And these nicknames you just mentioned, were they used not only by the defendant but by the community?

MS. HAJJAR: Were there other private nicknames the defendant had for members in this group?

MS. HAJJAR: Did you have one?

MS. HAJJAR: What was it?

LAUREN SALZMAN: Lorn. Forlorn.

MS. HAJJAR: Can you spell that?

LAUREN SALZMAN: F-O-R-L-O-R-N.

MS. HAJJAR: And Lorn?

LAUREN SALZMAN: Lorn, L-O-R-N.

MS. HAJJAR: As a pun on your name?

MS. HAJJAR: Why did the defendant call you Forlorn?

LAUREN SALZMAN: Because I was sad and suffering.

MS. HAJJAR: Does suffering have a specific meaning in the NXIVM ESP community?

MS. HAJJAR: A different meaning than how you would usually use the word?

LAUREN SALZMAN: Well, yes, to some degree.

Like that suffering is like a pity party, or like it's when you're generating an upset over something, it was seen as -- suffering was seen as being indulging in sadness to make yourself feel better about something that shouldn't feel good, or to get attention or something, or to get off the hook for something.

MS. HAJJAR: Suffering was something indulgent.

MS. HAJJAR: Did there come a time when members of this group were excluded or pushed out of the inner circle?

MS. HAJJAR: Can you give some examples of that?

LAUREN SALZMAN: Well, Keith stopped speaking to Daniella and to Ivy.

MS. HAJJAR: When was that, approximately?

LAUREN SALZMAN: Somewhere between 2008 and 2010. I'm not exactly sure when. I think similar timing on both, but I can't be sure.

MS. HAJJAR: Did anyone else in this group voluntarily leave the group?

LAUREN SALZMAN: A number of people did, yes.

MS. HAJJAR: Like who?

LAUREN SALZMAN: Kristen left.

MS. HAJJAR: Kristin Keeffe?

MS. HAJJAR: When was that, approximately?

LAUREN SALZMAN: Somewhere near 2014, I think.

And then Barbara Bouchey left, I think, close to 2011; somewhere in there, 2010, 2011, I think.

And Mark Vicente left in 2017.

MS. HAJJAR: Now, over the period of time that you were a member of this group, what were some of the ways in which you communicated?

LAUREN SALZMAN: We communicated phone. Email. In person. You know, in the early days there weren't texts or anything, so, you know, we spent more time together in person. And then over the later years, through phone apps, group chats, that type of thing.

MS. HAJJAR: May I approach the witness, Your Honor.

THE COURT: Yes, you may.

(Counsel approaches the witness.)

BY MS. HAJJAR:

MS. HAJJAR: I'm showing you what's been marked for identification as Government Exhibit 361.

Do you recognize that?

LAUREN SALZMAN: Yes. It appears to be my contact list from my cell phone and email, from my iCloud.

MS. HAJJAR: Your Honor, the government offers it, Government Exhibit 361.

MR. AGNIFILO: No objection.

MS. HAJJAR: Yes, Your Honor.

THE COURT: All right, Government Exhibit 361 is admitted into evidence.

(Government's Exhibit 361, was received in evidence.)

THE COURT: And are you going into a discussion of this evidence?

MS. HAJJAR: No, Your Honor, and I just have two more questions on this topic.

THE COURT: Okay. And then we will be finishing it up.

MS. HAJJAR: Okay. Thank you, Your Honor.

BY MS. HAJJAR:

MS. HAJJAR: Miss Salzman, does Government Exhibit 361 contain the contact information for some of the individuals we've been discussing?

LAUREN SALZMAN: Yes, it does.

MS. HAJJAR: Your Honor, may I show one more exhibit for identification only to the witness?

MS. HAJJAR: I'm showing you what's been marked for identification as Government Exhibit 363.

Do you see this, Miss Salzman?

MS. HAJJAR: Okay. And does this exhibit -- let me go back.

You testified that some members of the inner circle comprised the first line of DOS.

LAUREN SALZMAN: That's correct.

MS. HAJJAR: And does Government Exhibit 363 reflect the first line of DOS?

LAUREN SALZMAN: Yes, it does.

MS. HAJJAR: Your Honor, the government offers Government Exhibit 363 into evidence.

MR. AGNIFILO: No objection.

THE COURT: All right, Government Exhibit 363 is in evidence.

(Government's Exhibit 363, was received in evidence.)

THE COURT: Publish it to the jury.

(Exhibit published.)

BY MS. HAJJAR:

MS. HAJJAR: Miss Salzman, does Government Exhibit 363 reflect each of the first line DOS slaves that you named earlier?

LAUREN SALZMAN: Yes, it does.

MS. HAJJAR: And based on your earlier testimony, each of these slaves were slaves of Keith Raniere?

LAUREN SALZMAN: Yes, that's correct.

MS. HAJJAR: Did each of these slaves have slaves under them?

LAUREN SALZMAN: Yes, at least one each.

MS. HAJJAR: Your Honor, I'm about to move to another topic.

THE COURT: All right, I think we'll wind it up for the week now.

Members of the jury, we're going to recess until Monday morning at 9:30.

Let me remind you that it is extremely important that you follow my instruction that you not discuss the case with anyone; not your family, friends, or business associates, and not with each other.

And in addition, you must not read, listen to, watch, or access any accounts of this case on any form of media; newspapers, TV, radio, podcasts, or the internet, or research or seek outside information about any aspect of the case.

Please do not communicate with anyone about the case on your phone, whether through email, text messaging, or any other means, or any blog, or website, or by way of any social media, including Facebook, Twitter, Instagram, YouTube or other similar sites.

You must not consider anything you may have read or heard about the case outside of this courtroom, whether you read it before or during jury selection, or during this trial.

Do not attempt to do any independent research or investigation of the case. Do not visit any of the locations identified on the questionnaire or discussed during the course of jury selection or during this trial.

If you are taking notes, please leave the notes in the jury deliberation room.

We will see you on Monday morning. Have a good weekend.

Thank you very much for your attention in the case.

All rise for the jury.

(Jury exits the courtroom.)

THE COURT: All right. The witness may stand down.

Do not discuss your testimony with anyone.

(Whereupon, the witness steps down.)

THE COURT: Everyone may be seated.

Is there anything else from the government for today?

MS. PENZA: No, Your Honor.

THE COURT: On the matter that we discussed at the sidebar, is there a reason for us to meet about that on Monday morning, or are you going to have discussions with the defense about that separately and apart?

MS. HAJJAR: Your Honor, I propose that we speak with defense counsel, and if there's something we need to raise with Your Honor, potentially, we will do so and inform your deputy.

THE COURT: All right.

MR. AGNIFILO: That's fine with us.

THE COURT: All right. So we're going to resume at 9:30 Monday morning.

Is there anything else from the defense?

THE COURT: All right. Very well.

Thank you, everyone.

Have a good weekend.

Have a good trip.

MR. AGNIFILO: Thank you, Your Honor.

THE COURT: All right.

* * * * *

(Proceedings adjourned at 2:03 p.m. to resume on May 20, 2019 at 9:30 a.m.)

Continue to Day 91.Exclusion of Collateral-Return Emails