2.Lauren Salzman — Direct (Part 2)
1,904 linesDIRECT EXAMINATION (CONTINUED) BY MS. HAJJAR:
MS. HAJJAR: Good morning, Ms. Salzman.
LAUREN SALZMAN: Good morning.
MS. HAJJAR: Ms. Salzman, you testified on Friday that you were a first-line master in DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you tell the jury what that means in terms of the general structure of DOS?
LAUREN SALZMAN: Yes. So first line meant that we were -- that Keith was our master and we were enrolled directly under him. So we were considered slaves under him as our master. And then the second line would be the women that we enrolled who we were their master and they were slaves under us and it went down four lines.
MS. HAJJAR: And aside from the defendant, who was at the top, was everyone in DOS female?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Who initially recruited you into DOS in January of 2017?
LAUREN SALZMAN: Keith with Rosa Laura.
MS. HAJJAR: And is that Rosa Laura Junco?
LAUREN SALZMAN: Yes.
MS. HAJJAR: I'm showing you what's already in evidence as Government's Exhibit 363. Does Government's Exhibit 363 depict the defendant and everyone who was a first line master in DOS?
LAUREN SALZMAN: Yes, it does.
MS. HAJJAR: At the time you were recruited into DOS, were you aware of the defendant's role as your master?
LAUREN SALZMAN: Yes, I was.
MS. HAJJAR: Was that true of the other first -- of the other women in the first line of DOS?
LAUREN SALZMAN: That they were aware that he was their master? I believe so. I mean, they were all enrolled before me, so they all had him as their master prior to my enrollment. And when Rosa Laura enrolled me, she told me that he would be my master wherein under normal circumstances, because she was doing the enrollment, she would have been. She explained that my commitment would be with him.
MS. HAJJAR: Prior to joining DOS, were you aware of the defendant's sexual relationships with first-line DOS masters?
LAUREN SALZMAN: Some of them.
MS. HAJJAR: Who?
LAUREN SALZMAN: Nicky, Loreta, and Monica.
MS. HAJJAR: Did you later come to learn the defendant had sexual relationships with other first-line DOS masters?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Who?
LAUREN SALZMAN: Everyone except Rosa Laura.
MS. HAJJAR: I want to talk a little bit about the members in the first line starting with Camila. When did you first meet Camila?
LAUREN SALZMAN: I met Cami in the early 2000s. Her family had come to New York. Her sisters moved first and then the parents. They rented an apartment, and the two younger siblings, Cami and her brother joined soon after.
MS. HAJJAR: How old was Camila when you first met her?
LAUREN SALZMAN: I'm not a hundred percent sure, but I want to say around 14 -- 13, 14.
MS. HAJJAR: And you testified that Camila was the sister of Daniella and Marianna?
LAUREN SALZMAN: Correct.
MS. HAJJAR: And she was the youngest sister?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Where did she live?
LAUREN SALZMAN: Initially the family rented an apartment in Cohoes, which was like a town or two over from where the rest of us lived in Clifton Park. And then later they rented an apartment in Knox Wood, the development where all of us lived.
MS. HAJJAR: What about after that?
LAUREN SALZMAN: Where Camila lived? So she lived at 12 Wilton Court with her family for a period of time and then eventually moved to an apartment on Victory Way. I'm not sure of the number.
MS. HAJJAR: How did you know that?
LAUREN SALZMAN: After I was in DOS she would ask me to give her rides to the DOS house, so I would pick her up or drop her off outside.
MS. HAJJAR: Was there some secrecy as to where Camila was living at the time?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain that further?
LAUREN SALZMAN: Well, for the period of time when I think she was still living at the Victory Way house, there was a story about how she was actually living with Karen Unterreiner so there was -- there was some people who believed she was living with Karen and -- but she wasn't. And a lot of people didn't know where she was. I didn't know where she was living. I had asked Keith where she was living and he didn't share with me.
But around 2015 I moved around -- about half a mile away, and I had a personal assistant at the time named Lucy who was good friends with Cami and she and her friends had like a lot of, like, curiosity and speculation about what was going on with Camila. How come nobody could go to the house? Why they didn't feel the friendship was as open as they all had with the rest of their group of friends. And eventually Lucy told me that she figured out where Cami lived because she saw Keith coming and going from Cami's house. And I wasn't permitted to know or nobody told me. Keith didn't tell me. And until -- until -- Keith never told me, and eventually Cami told me herself where she was living after I was enrolled in DOS.
MS. HAJJAR: What about Daniella Padilla Bergeron, can you tell the jury a little bit about her background, where she was from?
LAUREN SALZMAN: Sure. So I met Daniella in 2001 in Monterrey, Mexico, at the first course that we taught down there. And Monterrey -- my understanding of Monterrey is that it's the wealthiest city in Mexico. It's a very conservative Catholic city, and everybody kind of knows each other. But she's from like an upper-class family in that community.
MS. HAJJAR: What was her rank in ESP?
LAUREN SALZMAN: She was a proctor.
MS. HAJJAR: And is that a relativity high rank?
LAUREN SALZMAN: Yes. It's the management level.
MS. HAJJAR: Now, as to Nicky Clyne, can you tell the jury a bit about her background?
LAUREN SALZMAN: Nicky came from Vancouver, Canada. Her mom was a teacher. Her parents were divorced, and she was an actress. So she comes, I think, more from a middle-class background than -- you know, childhood experience in the entertainment industry.
MS. HAJJAR: Is she a Canadian citizen or an American one?
LAUREN SALZMAN: Canadian.
MS. HAJJAR: What about Loreta Garza?
LAUREN SALZMAN: Loreta's family is from another city outside of Monterrey, but her grandmother was from Monterrey. I understand she moved there as a teenager and went to high school there, and then I believe studied abroad in Ireland for a bit, came back. And when I met her, she was working for a telecommunication company in Monterrey in the early 2000s. And then later, she moved to Albany and worked as my mom's personal assistant for a bit and then eventually Keith's assistant.
MS. HAJJAR: Rosa Laura Junco, what was her background?
LAUREN SALZMAN: Rosa Laura also was from Monterrey. Her family, as I understand, owns a large part of the print media in Mexico. They're a newspaper. They own a reputable newspaper called The Reforma. And very wealthy family.
MS. HAJJAR: Was she married?
LAUREN SALZMAN: Yes. When I first met her she was married, had three children. Was later divorced and then remarried and had another two children.
MS. HAJJAR: Did she have a daughter?
LAUREN SALZMAN: She has a daughter, yes.
MS. HAJJAR: And did the daughter have her name?
LAUREN SALZMAN: Yes. Daughter -- her mother and her daughter and she all had the same name.
MS. HAJJAR: Is there a nickname version for Rosa Laura?
LAUREN SALZMAN: Laureis. So sometimes, though, I called my friend Rosa Laura, Laureis. But her daughter was -- also was Little Laureis.
MS. HAJJAR: And what about Monica Duran?
LAUREN SALZMAN: I think Moni comes from Chihuahua or Tampico, Mexico. I don't know much about her background. But she joined ESP early on and I think began her relationship with Keith somewhere around, the time I did so I would say early 2000s, like 2001 or 2002. And she moved to Albany and, you know, lived in Albany with us for a couple decades.
MS. HAJJAR: And you called her Moni. Was that a nickname for her?
LAUREN SALZMAN: Moni. Yeah, short for Monica.
MS. HAJJAR: What about Allison Mack?
LAUREN SALZMAN: Ali's from California near Los Angeles. She was a childhood actress, so she grew up in the entertainment industry. Her father was a professional opera singer and her mother was her manager, as I understand, of her career.
MS. HAJJAR: When you joined DOS, were these other DOS masters already enrolled in DOS?
LAUREN SALZMAN: Yes. Yes, they all were.
MS. HAJJAR: And directing your attention to January or February 2018, did you have a conversation with Nicky Clyne about how she joined DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What did she tell you?
LAUREN SALZMAN: She told me that originally she had this commitment with Keith, and that she thought she was the only one who had that relationship -- like she was his slave and he was her master and that was a thing that she thought they were just doing together just them. And then later, she came to learn that there were others that she hadn't, you know, known about.
MS. HAJJAR: Did she struggle in particular with one other first-line DOS master?
LAUREN SALZMAN: With Allison. I mean, she struggled coming to learn Keith's relationship with Allison.
MS. HAJJAR: Did Nicky Clyne get married while you were a member of DOS?
LAUREN SALZMAN: Yes, to Allison.
MS. HAJJAR: At the time, who did you believe Nicky Clyne to be in a romantic relationship with?
LAUREN SALZMAN: Keith.
MS. HAJJAR: Did you write a letter in support of Nicky Clyne and Allison's -- their marriage?
LAUREN SALZMAN: I did.
MS. HAJJAR: Ms. Salzman, you testified that there were other DOS slaves under you --
LAUREN SALZMAN: Yes.
MS. HAJJAR: -- you recruited them. How many did you recruit?
LAUREN SALZMAN: Six in total.
MS. HAJJAR: And what were their first names?
LAUREN SALZMAN: Sarah, Audrey, Jimena, Corolla, Amanda, and Charmel.
MS. HAJJAR: Were you given instructions about what you could tell recruits into DOS?
LAUREN SALZMAN: Yes, I was.
MS. HAJJAR: What were those instructions?
LAUREN SALZMAN: That I was not to tell them about Keith's involvement.
MS. HAJJAR: Anything else?
LAUREN SALZMAN: And that -- yes. Well, kind of -- and in effect, not to tell them about his initials and the brand.
MS. HAJJAR: What were the requirements of being a DOS slave?
LAUREN SALZMAN: It -- it was total nondisclosure, so complete secrecy about anything happening in the group and a lifetime vow of obedience to your master.
MS. HAJJAR: How were these requirements enforced?
LAUREN SALZMAN: Well, initially there was a whole enrollment process. But the first thing that happened is that the person who would approach you to enroll you or -- or -- and this happened with me, this is what I did with others as well, would ask for collateral. And basically it was some sort of either material possession or it could have been information -- sensitive information, true or untrue. But the idea was that it was something valuable enough or damaging enough that would ensure a total commitment to secrecy; that you would rather -- that you would keep a secret like until you died than have this information come out or have this -- you know, lose this possession, whatever it was.
Then once you gave that collateral, you were told a certain number of things about the sorority, about the lifetime vow of obedience, the concept of the master and slave. There was an idea of a collar which was, I was told to be a chain -- a piece of jewelry that you would wear that symbolized a chain to your master. And ideally this would be a piece of jewelry that you could and would never take off. And the brand. And then if you decided you wanted to go forward and do this, you would collateralize all areas of your life. So more material possessions, more damaging information, as much as possible to secure your commitment that you would never leave and you would never speak about it. So the idea -- so the question about how it was enforced is the collateral backed it. In essence, your fear that if you were to go against what you had committed to, that collateral would be subject to forfeiture or release.
MS. HAJJAR: And throughout this process would the defendant instruct you that his role was to be concealed?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did you provide collateral to join DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Were there additional practices associated with DOS?
LAUREN SALZMAN: Yes. There were a number of different practices. There was a practice of checking in last thing before you went to bed and first thing in the morning. So you would say good night to your master before you went to bed, good morning to your master first thing when you woke up. Master -- you would call them master or M, but master was always capitalized as were all pronouns. So if you referred to them as you, the Y would be capitalized. He, she, they were always capitalized when referring to the master.
Also we did a daily active self-denial or doing something uncomfortable to build character, weekly acts of care. And then, of course, there were other tasks or assignments given.
MS. HAJJAR: Was readiness in DOS one of the practices as well?
LAUREN SALZMAN: Yes, readiness.
MS. HAJJAR: So you talked about communication in the context of DOS and good morning and good night. Can you explain exactly what you did and what others did in DOS?
LAUREN SALZMAN: In the communication? Most of what we did took place in the -- in encrypted applications that you would have on your phone. So mostly we used Telegram, and Telegram allowed for you to have a locked chat thread and between just two individuals. The group chats were not locked, but we used Telegram for everything.
So in a locked Telegram thread I can send you encrypted messages, and you could send me back encrypted messages, and it allows for the function that if I wanted to delete something in my chat, I could delete both my chat from my -- my phone and your phone. So this was the type of communication and the type of capacity that app had. But those threads were locked so -- and encrypted so you would have one with your master and then the same with any slaves you had. So we have individual chats, each of us. I had individual ones for each of my slaves, and then a group chat, and one with me and Keith.
We also communicated on Signal which is another encrypted app. But then I had group chats with my circle. So the eight first-line DOS women I had to chat with me and I had one with the group of all my slaves together with me and they had one individually without me.
MS. HAJJAR: And what was the purpose of using Telegram or Signal as opposed to just the normal SMS function or your phone?
LAUREN SALZMAN: That it was encrypted and more secrecy, more security.
MS. HAJJAR: Did you receive notifications in Telegram or in What'sApp if certain things happened?
LAUREN SALZMAN: Yes. Well, specifically I mean, for readiness drills we would -- we had special readiness threads. So we would receive an alert that we were having a drill.
MS. HAJJAR: Can you describe what these drills were in the context of readiness?
LAUREN SALZMAN: Yeah. The readiness drill -- originally readiness was something that we had done in SOP, which was the men's organization, so it was unfamiliar to us. But the way that we did it in DOS was different. So Keith would initiate a readiness drill by sending a question mark in a group thread to us and to the first line. The first line had 60 seconds to respond that we received the communication and transmit the readiness drill down to the second line. The second line had 60 seconds to report it back to us and us to report it to Keith and to get that communication down to the third line and the same with fourth line. So each line it was 60 seconds to get the communication down and back up that it had been completed.
MS. HAJJAR: Did your slaves know to whom you were reporting?
MS. HAJJAR: How often did you participate in these drills?
LAUREN SALZMAN: Frequently. I mean, and -- and Keith wanted us to be good at readiness, like effective and efficient at readiness and so until we got readiness done, we couldn't move on to certain other things. And when we failed at readiness, he wanted to know how we would fix it. So we were taking consequences for failing at readiness.
So what we started doing was practice readiness drills. So each -- he would initiate readiness drills, it could be every day, it could be a couple times a week, sometimes it was less. But we started to want to practice, and as we enrolled more and more people in readiness, it became more and more complex and there were more and more errors.
So at one point my group agreed -- when I say "my group," my circle of first-line DOS masters, that each of us you would initiate at least one practice drill throughout the week. So we were -- my group was running eight drills just with us, and then my slaves under me, I was -- I was duplicating everything that was going on with us. So when they had failures, similar to how Keith would ask us, what are you going to do to fix the failure, I would say to them, what are you going to do to fix the failure, so then they started running practice drills as well.
So for some of the people lower in the chain, there were a lot of drills.
MS. HAJJAR: When did the defendant initiate these drills?
LAUREN SALZMAN: Whenever. But frequently it was -- it was at times that we wouldn't be ready. Like I -- so that we would learn to be ready all the time. So it could be in the middle of the night. Sometimes it was concurrently at the same time as the SOP readiness drill which increased the probability that there would be failure because you're running drills with two groups, and the complexity of DOS readiness was there was a lot to do in a short amount of time in those minutes.
But sometimes it just -- could be just random like times you wouldn't expect.
MS. HAJJAR: Did the defendant sometimes initiate these drills in the middle of the night?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And did you make certain arrangements so you can be ready for the drill?
LAUREN SALZMAN: Yeah. Some people had several phones so that they wouldn't miss the drill. We had all -- our alerts on the phone turned up to, like, the highest level volume and the alert that would be most, like, most likely to wake you up out of whatever sleep that you were in. And then everybody had the different phone numbers you could be reached at. I had a landline plus a cell phone. And then we had a buddy system as well so that if somebody was missing in readiness, you would go looking for them, and that if they -- if they were missing, you were also accountable for their buddy. So there was a lot that was involved.
MS. HAJJAR: You said -- well, were readiness drills secret?
LAUREN SALZMAN: They were secret, which became very complex because there's a lot that had to be done. Sometimes people would be missing or you would have go looking for them.
You know, there was the four minutes that everything had to happen within tracking the time of that, tracking the number of people and keeping it secret from everybody else who was in NXIVM who you were spending a lot of time with because we were teaching intensive. So we were in classes together for long periods of time or different committees that we worked on together. Our whole social group of friends was within this community, so it was hard. It started to become hard to keep it secret. And also because a number of people who were in DOS were supposed to keep their enrollment or participation separate from each other and then they would be in the same place and receive the drill at the same time. So they started to identity who each other was and then report back that there had been breaches of that security, so to speak. And, you know, then there were complexity surrounding that because nobody was supposed to know who was in this group.
MS. HAJJAR: Were there consequences for failing at readiness?
LAUREN SALZMAN: Yes, we took consequences.
MS. HAJJAR: Your Honor, may I show something to the witness for identification only?
THE COURT: Sure.
MS. HAJJAR: Ms. Salzman, I'm showing you what's marked for identification as Government's Exhibit 359.
LAUREN SALZMAN: Yes.
MS. HAJJAR: Do you recognize that?
LAUREN SALZMAN: I do, yeah.
MS. HAJJAR: What is it?
LAUREN SALZMAN: This was the buddy system from my circle of first-line DOS masters.
MS. HAJJAR: Who created this?
LAUREN SALZMAN: Loreta Garza.
MS. HAJJAR: Did you have a copy of this personally?
LAUREN SALZMAN: I did, yes. This copy was, I think, from my -- I believe from my cell phone.
MS. HAJJAR: Why did you keep it on your cell phone?
LAUREN SALZMAN: Because I couldn't remember the buddy system and it needed to be easily accessible. It was complex because I was accountable for Cami, but if she didn't come, I had to go looking for her. But I also had to make sure that Dani was there. And if Cami and Dani didn't show up, I had to make sure Nicky was there. So I -- you know, there's eight of us, so to remember the order of them and make sure everybody was there checking on all the people while making sure the communication went up in under a minute and down, you know, in each of the lines and tracking the time was incredibly complex. It was a lot of things at once. So I had it there on the phone so that I could reference it easily to remember to do that part of it.
MS. HAJJAR: Your Honor, the Government offers Government's Exhibit 359.
THE COURT: Any objection?
MR. AGNIFILO: None, Your Honor.
THE COURT: All right. Government's Exhibit 359 is received in evidence, publish to the jury.
(Government's Exhibit Number 359 so marked and received in evidence.)
THE COURT: I have a question. Was it ever explained to you by anyone why these readiness drills were necessary in order to be part of this organization?
LAUREN SALZMAN: Well, what I had understood from the men's organization, from SOP, was that the readiness drills were to help us build discipline and be responsive and to create a very efficient responsive communications network to disseminate information very quickly. And in the context of the men's organization, we had used those drills, for example, somebody was kidnapped one time in Mexico, and so the communication network was -- was utilized in that case. Another person went missing in a foreign country, and so I had had prior experience of having this official and effective communication system.
But in DOS it was a little bit different where it was a lot more aggressive and there was less leniency in failures and more focus on us just being ready and responsive in discipline all the time. So I thought that it was part of us learning to be disciplined to be aware and to build these traits of characteristic in ourselves which we come to learn that we didn't have and men did have.
THE COURT: All right. Thank you.
BY MS. HAJJAR:
MS. HAJJAR: Looking back now, Ms. Salzman, do you have a view of the point of readiness in DOS?
LAUREN SALZMAN: The point of it? Like in part of the point of it was Keith's vision of this would be a very big organization at some point, and we would be able to -- to get communications out and move a lot of people in a short amount of time to do different objectives which were undefined, you know, in the theorizing of what that would be. But I think also there was just having us always be prioritizing this above other things and creating circumstances where we needed to choose this again and again over other things, set aside other things to make this the highest priority.
MS. HAJJAR: And when you say move a lot of people, the people you are referring to are DOS slaves?
LAUREN SALZMAN: DOS slaves, yeah.
MS. HAJJAR: Looking at Government's Exhibit 359, can you identify -- can you explain this to the jury and identify the people listed?
LAUREN SALZMAN: Sure. So Camila's at the top -- this is our buddy system. So Camila was at the top, and she was responsible for Daniella and Daniella was responsible for Nicky, Nicky was responsible for Loreta, Lola, as indicated in the chart. Lola was responsible for Rosa Laura, indicated as Laureis in the chart. Laureis responsible for Moni, Monica; Monica responsible for Allison and Allison responsible for me. So if one of us didn't show up to readiness, this told you who you were responsible to contact, to go looking for, to find them to show up for the readiness drill. But also you were accountable to make sure that the person they were accountable to in their absence was present, and if not, you could end up -- you could end up being responsible for the entire circle if you were the only one who showed up.
MS. HAJJAR: Was it acceptable in the context of DOS to be unavailable for a long period of time?
LAUREN SALZMAN: No. The -- in -- in SOP, the men's organization, there was the concept of being dark, so you could be dark or unavailable for a certain period of time. Some people would go dark at night, some people, you know, during business meetings, various family functions, do various things. In DOS the kind of tag line on it was that there was no dark in DOS, no dark.
So there were circumstances where it was acceptable, like if you are on an airplane and completely unreachable or something, to have a buddy take responsibility for your line. But if you were absent, they had to initiate their whole readiness drill plus your whole line's readiness drill in your absence. So it was -- for some people who had a lot of people in their organization, like I did, it was a sizable workload to off-load onto a buddy, you know, and especially if they had larger organizations, but there were times where that was necessary.
MS. HAJJAR: When you say you had a larger organization, are you referring to the network of DOS slaves under you?
LAUREN SALZMAN: Yeah. I had enrolled a number of people who had enrolled a number of people who were enrolling a number of people, so the group grew and readiness became more complex as the group grew.
MS. HAJJAR: Were there times that you reorganized your life or changed your schedule in order to be available for readiness drills?
LAUREN SALZMAN: Constantly. And some of them were difficult because if they came -- so you didn't want to go dark that often or I didn't, and we were trying to succeed at this and do it well. Like sometimes it would come -- like one time it came and I was driving and I had -- I crossed -- like be able to pull over, I had to cross over like four lanes of traffic to do it, and it wasn't safe to be doing all the time, not the way we were doing it.
MS. HAJJAR: As a DOS slave were you expected to ask permission of your master, in this case, the defendant?
LAUREN SALZMAN: Yes, for different things. But I already did that in my life with Keith. I mean, before I joined DOS I had already asked Keith for permission for most things in my life.
MS. HAJJAR: Did your DOS slaves ask permission of you?
LAUREN SALZMAN: Some of them asked for some things, yeah.
MS. HAJJAR: Did you perform work for the defendant in DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain what an active care was in the context of DOS?
LAUREN SALZMAN: Sure. We had -- we had had a community project in Albany for the Albany NXIVM community and we had within that community project guardians, and those guardians would do a caring act once a week to help the person who you were the guardian of. So the concept was familiar to me beforehand from this project of learning to care about somebody just for the sake of caring, like building that trait in yourself, not because you were going to receive anything back for it. So in DOS, that concept was brought and employed in doing acts of care, things that would be caring for your master every week. So you were -- we were assigned once we joined that -- that we would do the these weekly acts of care to build caring in ourselves and with the thought of contributing something that would help the master somehow in their life, in their work.
MS. HAJJAR: Were you required to perform acts of care?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And can you give some examples of what kind of acts of care were performed for the defendant?
LAUREN SALZMAN: So -- well, initially when I joined, I considered some of the things that I did to work with people in his life to help off-put his workload with those individuals, active care. So I would do counseling sessions with people or help in some of the different companies that he had founded. And then sometimes, I -- like if I was going to the grocery store, I would ask, Do you want -- I'm going to Whole Foods, do you want something? Later he would start to point out things that we had done that were uncaring. Like the time he had left volleyball and walked to his car and found the car cold. And so then we rearranged our schedule to make sure that somebody was always there in the middle of the night when he left volleyball to warm up the car. But I, like, brought drinks to volleyball and things that I knew he liked or wanted.
At one point I considered some of the other project work I was doing for DOS acts of care, but then later I was told that wasn't an act of care. Daniella came to the group at one point saying we were misunderstanding acts of care and we should be doing things that were more devotional in some way. But I didn't really understand that concept, and I didn't ever come to really understand what she was bringing.
MS. HAJJAR: What other work were you required to do for the defendant?
LAUREN SALZMAN: Well, when I first joined, Keith said he wanted me to help edit the book, the DOS book. So the book was like the philosophy behind the sorority. So reading the whole book, editing the transcripts of it, creating this book was incredibly time-consuming, and I think one week I probably spent 70 to 100 hours on this book, and it was something very important. He wanted it done in an expedited amount of time and would consistently check to make sure I was making progress and telling me that I was -- my work capacity was low. I wasn't getting it done in enough time.
MS. HAJJAR: Were you reimbursed, for example, for the groceries you purchased for the defendant?
MS. HAJJAR: Did you also purchase groceries for someone else?
LAUREN SALZMAN: Yes. Well, if I called him and asked him if I -- if he wanted me to get something from Whole Foods, he would say, Ask Marianna. So then I would call Marianna and get Marianna's grocery list. So I would buy groceries for him and Marianna.
MS. HAJJAR: Was that difficult for you?
LAUREN SALZMAN: Yeah, it was really difficult for me.
And then also when I was told that I could just leave the groceries in the garage, that was also really hard. They were -- I mean, he was living with Marianna and in many ways, I viewed that as who he chose to have a relationship with instead of me, you know. It wasn't to the exclusion of other relationships or anything, but that was like his main -- that was the person he lived with. It was a person I -- from my perspective, he spent most of his time for and with, and it ended up being somebody that he ultimately chose to have a child with, you know. So, yeah, it was really hard for me to get groceries for him and Marianna and leave them in the garage without even coming in to say, Hi, when they were both in the house.
MS. HAJJAR: Did your slaves do work for you?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did you discuss acts of care with the defendant at one point?
LAUREN SALZMAN: Yes. He came to -- well, he came to a meeting that I was having at my house. We were having a meeting to put -- to discuss ethics protocols for the sorority, and he came to the meeting and shared that he thought -- he was thinking that each week each slave would put in an hour of work, give an hour of work to their master or an hour of work and -- and an hour of work to their grand master. The concept was so that if you had six slaves and at some point he decided six -- there was something special about the number six. Like if we each had six slaves who each had six slaves under them, you would qualify for a special position and to receive special privileges. I don't recall specifically the privileges. But that if you had that you would have 40 hours, approximately 36, but approximately 40 hours of work per week for life from these individuals.
MS. HAJJAR: Did he discuss a monetary substitute for this work?
LAUREN SALZMAN: Yes. He shared that if they didn't -- he was thinking if they didn't want to do the hour, that they could pay dues, like some menial amount of money like $15 a week or $20 a week, something like that. But it was preferable -- it was preferable for them to do the work.
MS. HAJJAR: Ms. Salzman, when you said the sorority in the meetings earlier, do you mean DOS?
LAUREN SALZMAN: Yes. Whenever I say the sorority, I mean DOS.
MS. HAJJAR: Or The Vow?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Those organizations, all the names are the same?
LAUREN SALZMAN: Yes, same thing.
MS. HAJJAR: Was recruitment a focus in DOS?
LAUREN SALZMAN: Big focus.
MS. HAJJAR: How so?
LAUREN SALZMAN: Keith wanted us to grow and he wanted us to grow quickly. He was checking in on how we were doing with enrollment a lot, frequently, and wanted us to -- was very -- pushing for us to get to 100 people, and then pushed me specifically to get a hundred in my group alone in under six weeks and was constantly asking like where -- how many people do we have? Where are they in each stage of enrollment? And, like, What are your projections and when do you think we're going to get this number? How many more are we going to get in this period of time? And so he wanted us to be able to make those projections and have that information readily accessible whenever asked.
MS. HAJJAR: Did the defendant express a preference for enrolling people into DOS that were not part of the NXIVM community?
LAUREN SALZMAN: Yes. He wanted us to get new people. Very much wanted new people and people outside -- and people in positions of power and influence.
MS. HAJJAR: Was enrollment in DOS documented in some way?
LAUREN SALZMAN: Yes. We kept track of it in Excel spreadsheet and a DropBox folder.
MS. HAJJAR: Did the defendant ever instruct you to make sure you were tracking enrollment?
LAUREN SALZMAN: Yes. Tracking it and tracking it down to like even the minute that the person was enrolled and keeping track of the order of everybody as they were enrolled. The number and order were very important.
MS. HAJJAR: Were there certain stages of enrollment in DOS?
LAUREN SALZMAN: Yes. There were four, but that ended up being five stages of enrollment, which was somebody was a prospect. Then they were -- they had submitted that first collateral so they had made the commitment to secrecy. They were given basically the pitch, you know, come to learn about lifetime vow of obedience master/slave concepts, the collar and the brand. Then they had agreed to join after learning those things and then they were fully collateralized. So they were not considered completely enrolled until they were fully collateralized.
MS. HAJJAR: What does it mean to be fully collateralized?
LAUREN SALZMAN: That they had provided substantial collateral in all areas of their life of material possessions and information on them.
MS. HAJJAR: Was one requirement of DOS to get a brand?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did you get branded?
LAUREN SALZMAN: I did.
MS. HAJJAR: What was the brand of?
LAUREN SALZMAN: Keith's initials.
MS. HAJJAR: Did you know that at the time?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: And what about the slaves under you, did they know?
LAUREN SALZMAN: No. We were not allowed to tell them.
MS. HAJJAR: At any point did you or the other first-line DOS masters express concern about the fact that the brand was of the defendant's initials?
LAUREN SALZMAN: Yes, I did and others did as well. Keith said that it shouldn't matter. It wouldn't make a difference that it doesn't -- that nobody would know, and that we were being like just making problems or focusing on being negative, you know, about things that weren't really an issue. He didn't want to change it. He wanted it to be this way, and insisted, it would not be a problem, even though a number of us did think it was a concern.
MS. HAJJAR: At some point were you told about an additional tattoo that would be made to the brand?
LAUREN SALZMAN: I was, yes.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: My understanding was that the tattoo was to be -- so the brand is a scar. The -- and that the tattoo would go over the scar so it would be -- the initials would be retattooed over the scar, but then there would be additional parts of the tattoo. Like Keith had an idea that he wanted to have some kind of a nicer -- pretty design, but that it would have in it a special symbol of the lineage. So everybody who was under me in line, each of the eight DOS masters were considered a lineage. So each one would have their own unique special symbol that everybody in that line would have. There would be a special symbol, I think between the master and slave. So the girls that I enrolled would have a special symbol that they shared just with me. And then each of them would have a special symbol that they shared just with the girls that they enrolled. Our number of enrollment was part of that and there may have been other things that I can't recall possibly having to do with what area you were from or something. But I'm not a hundred percent sure about that.
MS. HAJJAR: Did you, in fact, get a tattoo over your brand?
MS. HAJJAR: Why not?
LAUREN SALZMAN: Because Keith never decided on the design.
MS. HAJJAR: You testified, Ms. Salzman, about meetings that you had with the first-line masters in DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Where were those meetings held?
LAUREN SALZMAN: Initially they were held at -- at different people's homes. Usually the homes that were least likely to have people notice that we were having meetings there and where we could take our naked pictures and nobody would know that we were doing that. But then later we bought a home. Rosa Laura bought it, that was the sorority house. It was on 9 Milltowne Drive in Halfmoon, and that was where we had all our meetings after that.
MS. HAJJAR: When the defendant was present at these meetings, were they recorded?
LAUREN SALZMAN: Yes, generally.
MS. HAJJAR: Who recorded them?
LAUREN SALZMAN: Mostly Loreta, but if she wasn't present, somebody else would.
MS. HAJJAR: Loreta Garza?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Later did you access a drive with recordings of these meetings?
LAUREN SALZMAN: Yeah, Loreta's drive.
MS. HAJJAR: Can you explain that to the jury?
LAUREN SALZMAN: There was -- she had a video that I needed to get off of her drive, and so I just saw that there were a number of things cataloged on the drive. Loreta was historian in NXIVM for a while and she was very good at technology and organizing information, and so I believe that drive was like the repository of where all the information was.
MS. HAJJAR: Did you have those recordings yourself?
LAUREN SALZMAN: I had access to recordings of the book, not all the recordings. The purpose of the recordings for the book was that he had given -- we called them downloads, but like an explanation of the concepts that were recorded and then those recordings were transcribed and that transcription was edited and it was becoming a book. So I was given access to the initial downloads, the initial recordings to be able to go listen to them, to clarify concepts in the book that I was editing.
MS. HAJJAR: You mentioned naked photographs you were required to take at DOS meetings?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did the defendant impose requirements about what the photographs should look like?
LAUREN SALZMAN: Yes. Well, generally, I mean, we were supposed to be uniform, so like all looking the same. So one time, like, Daniella had a baseball cap and we got feedback that either we all had to wear hats or nobody had to wear hats. Nobody should wear hats. So we were to be uniform, fully frontally naked, the brand should show, and we should appear happy in the pictures. Like if we weren't happy, we got feedback that we weren't happy and we needed to retake the picture.
MS. HAJJAR: When you got feedback, who gave you the feedback?
LAUREN SALZMAN: Keith.
MS. HAJJAR: Were the photographs sent to the defendant?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Who sent the photographs to the defendant?
LAUREN SALZMAN: Whoever took the pictures, I mean.
MS. HAJJAR: Did he respond?
LAUREN SALZMAN: Sometimes. Not always.
MS. HAJJAR: When the defendant gave feedback on the photographs, would you sometimes have to retake the photographs?
LAUREN SALZMAN: Yes. Whenever there was feedback given on the photographs, we incorporated the feedback and retook the picture with the feedback incorporated.
MS. HAJJAR: What does that mean, when you incorporated the feedback?
LAUREN SALZMAN: We made a change that was suggested. If we didn't look happy, we did a picture that was happier. If our legs weren't spread enough, we had to spread our legs more. Whatever the feedback was, we did it.
MS. HAJJAR: Did the defendant request explicit sexual photographs from you and the other first-line DOS masters?
LAUREN SALZMAN: Yes.
MS. HAJJAR: How often?
LAUREN SALZMAN: Sometimes -- I mean, from time to time, but it was enough that everyone knew that he preferred those types of pictures. And so generally our focus -- a lot -- generally we would tend to just take that picture at the onset like because it was viewed as preferable to him that we took a picture with our legs spread or up close vaginal pictures, that he liked that better and everybody in the group knew it enough that we would focus the pictures on that.
MS. HAJJAR: Did the defendant ever give you or the other first-line DOS masters feedback with regard to grooming of pubic hair?
LAUREN SALZMAN: Yes. He wanted to know -- he looked at a picture specifically of my vagina and said -- wanted to know why it looked groomed.
MS. HAJJAR: Were you aware based on your prior sexual relationship with the defendant of his preference in that regard?
LAUREN SALZMAN: Yes.
MS. HAJJAR: How did you feel about the photographs?
LAUREN SALZMAN: I had mixed feelings about the photographs. I mean, for me it was very uncomfortable. Like the elephant in the room for me was that he was having sex with a lot of these people and he wasn't having sex with me anymore, and so I felt very insecure about that, and I would have to, like, consistently set that aside to be able to do what was being done. And I would tell myself that it wasn't sexual because it was Keith's, and the reason that we were doing this was just so that we would learn to become comfortable with our bodies and that, you know. It was just about vulnerability. But I knew he liked certain things, and he was asking for those things and he was asking for those things from people he was having sexual relationships with, and as he had -- and when he had taken pictures of me when we were having a sexual relationship. So it was hard to keep that part of it out of it.
But I wanted to believe that that wasn't part of it. And then at the same time, I went -- some of my best friends in my hole life, and we're, you know, taking naked pictures three times a week, eventually you get very comfortable with everybody, you know, and I tried to make jokes or make it fun or try to think of like fun themes that we could do, like, to take the pictures which made it easier for me to do it and to feel okay doing it. And it made it more comfortable between all of us. But it was really difficult, and I didn't want to be doing it.
MS. HAJJAR: What was the effect on you of the requirement to look happy in the photographs?
LAUREN SALZMAN: Well, it was just fortified that we should always -- like if we weren't happy with some of the things that we were doing -- and this was true of anything, it wasn't just this. That it was -- that we had some issue and it was indicative of our issue, that we could choose to be joyful at any moment. And if we didn't have -- if we weren't choosing issues as the highest priority, then we would just be joyful with anything that we were doing.
So the photographs specifically for the reasons I just described were especially difficult. So then I was there pretending that I was happy taking sexual pictures with the people he was preferring to have sex with instead of me, and that -- it was -- sometimes it was very difficult. Like I tried to make it fun, and sometimes it was fun and I could have fun doing it. But a lot of times, it was just very painful and hard to put on a happy face for that.
MS. HAJJAR: You testified that you provided collateral to join DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: At some point were you required to submit additional collateral?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can explain that to the jury?
LAUREN SALZMAN: Well, initially, I -- I provided -- I was told that I need to provide something that would be, like, so significant that I would, like, rather die than share this information. So I provided the account of -- of an actual crime that I had been a party to and that implicated my parents, Keith, and a number of my friends. And I was -- that collateral was rejected, and so then I was asked to provide naked pictures instead.
MS. HAJJAR: And some time after that, after you had joined DOS, were you required to commit collateral on a monthly basis?
LAUREN SALZMAN: Yes. I was -- so after I -- I said I wanted to join, the idea was that you collateralized all areas of your life. So I had, you know, promised to -- all my material possessions, all my finances, you know, all of that. And then Keith said -- came to a meeting or asked at the meeting why we weren't submitting monthly collateral, as if it had been a thing? And I guess it had been before I came, but I was unaware of it, and I learned that we were supposed to be submitting monthly collateral. He said that the idea of it and the importance of it was to keep the collateral current.
So like if I -- and I think he gave an example of a car. I don't recall specifically, but like my impression coming away from that was like that if I had a Toyota or something now, maybe I'm not as successful in my life now or that Toyota is not going to be as valuable to me in ten years and maybe even in ten years I could afford a Mercedes or something. So the Toyota wouldn't have the same hold on me and ensure my secrecy and commitment. So we always had to keep the collateral current so that it would always have that influence, that effect that we would be unwilling to go against our commitment or -- our commitment of staying forever and being in total obedience and secrecy.
MS. HAJJAR: Did you submit monthly collateral?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: What were some of the things you submitted as monthly collateral?
LAUREN SALZMAN: I mean, we were taking naked pictures, up close vagina pictures three times a week. So I was told that wasn't consider collateral, but to me that was very weighty collateral because it was not something I would ever want anybody to see and there was a lot of it. But then I started promising more material possessions and things, but we were running out of what to do, and so we were asking each other and asking Keith for ideas of what you could do and when everything is already collateralized and he had suggested at one point like that, you know, we could get creative and he shared -- he said you could even stage crimes. He told me a story of somebody who had staged a break-in to make it look like they had, like, broken into Clare's house and taken something which she wasn't home, but really the whole thing was a sham. But it was this idea that we could have things like criminally -- you know, implications, criminal implications to our collateral.
MS. HAJJAR: So the defendant suggested that there would be videos of these staged crimes?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And those videos were collateral?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did the defendant express interest in a house that was specific to DOS?
LAUREN SALZMAN: Yes. He wanted us to get a house for the -- a sorority house.
MS. HAJJAR: Did he say anything about where it should be within -- what?
LAUREN SALZMAN: My belief was that it should be in walking distance. He wanted -- my understanding from the group, and they were looking for a house before I even joined, was that it needed to be in walking distance.
MS. HAJJAR: Did a house -- did someone purchase a house for this purpose?
LAUREN SALZMAN: Yes. Rosa Laura purchased the house that was in walking distance right behind the development where he was living and we could walk there.
MS. HAJJAR: Do you know who purchased the house and who paid for it?
LAUREN SALZMAN: I think Rosa Laura did. I mean, I haven't seen documents about it, but that was my understanding, that she purchased it and paid for it and put it in a trust. And that we -- we the eight first-line DOS masters were accountable for the expenses of it. So we paid monthly to cover the mortgage and Internet, electricity, all those things.
MS. HAJJAR: Did you start meeting at that house afterwards?
LAUREN SALZMAN: We did.
MS. HAJJAR: Okay. I want to show you what's in evidence as Government's Exhibit 126 and 127.
Do you recognize this exhibit?
LAUREN SALZMAN: (No audible response.)
MS. HAJJAR: Do you recognize this photograph, Ms. Salzman?
THE COURT: Hold on.
LAUREN SALZMAN: Nothing came up on the screen.
THE COURT: I'm sorry. Is this just for the witness?
MS. HAJJAR: No, Your Honor, it's in evidence.
THE COURT: Okay. Go ahead.
LAUREN SALZMAN: Yes.
BY MS. HAJJAR:
MS. HAJJAR: Do you recognize this?
LAUREN SALZMAN: Yes. I believe that's 9 Millhouse Drive, which is the -- or Milltowne, which was the sorority house.
MS. HAJJAR: This depicts the sorority house?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And this photograph?
LAUREN SALZMAN: Same.
MS. HAJJAR: May I have just one minute, Your Honor?
THE COURT: Sure.
(Pause in proceedings.)
MS. HAJJAR: Ms. Salzman, I'm going to show you what's in evidence as Government's Exhibit 851.
MS. HAJJAR: I'm sorry, Your Honor. One moment.
(Pause in proceedings.)
BY MS. HAJJAR:
MS. HAJJAR: I'm showing you what's in evidence as Government's Exhibit 853. Have you ever seen the document before?
MS. HAJJAR: Do you recognize this address?
LAUREN SALZMAN: Yes, 9 Milltowne Drive in Waterford.
MS. HAJJAR: Was this an address that was associated with the DOS house?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Do you recognize that name, Alex Martin?
MS. HAJJAR: Do you recognize this name, Danielle Padilla?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Ms. Salzman, were there penitences or punishments in DOS?
LAUREN SALZMAN: Yes, there were.
MS. HAJJAR: Can you explain that to the jury?
LAUREN SALZMAN: So penitence was a concept that we learned in the NXIVM curriculum, and it was the idea of taking on something painful of difficult to remind yourself of the importance and to build continuous self-awareness, in essence, of the importance of various things, whatever the important value was that you were seeking to uphold or actualize. And some of the penitences would be in line with, let's say, you were -- you know, mindless or late a lot, you might take a penitence of doing some sort of like a 15-minute reality check, just 15 minutes, just come, be conscious of where you are, what your time frame is, and build awareness so you would stop being late. But also maybe that you were late and took on a penitence like taking a cold shower, for example, standing barefoot in the snow, that would be so uncomfortable that you would think twice before ever being late again.
So when I joined the sorority, they had shared with me that some of the penitence they had been doing was for failure like waking up in the middle of the night and do burpees. But when we failed a readiness, they had been taking paddlings. So we were to paddle each other with a piece -- a leather strap, you know, naked butt for our readiness failures that we were doing.
(Continued on the next page.)
BY MS. HAJJAR:
MS. HAJJAR: Did there come a time where the defendant discussed paddling with you?
LAUREN SALZMAN: He called in to a meeting where we were paddling each other for our failures and we were taking penances for the readiness failures but then it became any item on our minute list with any of our projects or any of the things that we had committed to do that we were failing at we were taking paddling for, so we would take our naked picture and then everybody would take the number of whips that you -- that was commensurate with your failures and he called in and wanted to make sure that we were flicking our wrist hard enough or if you flick your wrist a specific way or if you really get the wrist into it, then it should really hurt and that's what the paddling should be, it should be something that really hurts.
MS. HAJJAR: Were taking penances or punishments optional in DOS?
LAUREN SALZMAN: No, because he -- I mean he was -- we're doing a vow of obedience and he's saying what are you going to do to fix it and you were required to fix it.
MS. HAJJAR: And were some of these ways including paddling ways to fix it?
LAUREN SALZMAN: Yeah, it was viewed as a way to fix it, to make sure it never happens again; if you get hit hard enough, you start thinking twice about screwing up readiness, not staying up all night if you needed to get something done or whatever the thing was.
MS. HAJJAR: Did you come to learn that the first line had been paddled by the defendant?
LAUREN SALZMAN: Daniella told me she had -- she told me that she had been paddled by him and it was so painful and it was something I hoped to never happen to me, it didn't sound like anything I ever wanted.
MS. HAJJAR: And this is Daniella Padilla?
LAUREN SALZMAN: Yeah. I was concerned about it.
MS. HAJJAR: Did Daniella Padilla tell you about another punishment the defendant gave her?
LAUREN SALZMAN: She told me that she was in a prideful state and that he was trying to help her break the state and she had been on the floor and that he kicked her and that was also something that I never wanted to be in the situation. These things started to become scary for me. I was concerned about failing.
MS. HAJJAR: And when you say "prideful state," what does that mean, what do you understand that to mean?
LAUREN SALZMAN: Not being vulnerable, not being willing to acknowledge failures or wrong -- like that she had failed or that she was wrong, that instead she was trying to be right or be arrogant and not be humble.
MS. HAJJAR: You testified, Ms. Salzman, about a dungeon in the context of DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did the defendant tell you about a dungeon?
LAUREN SALZMAN: Yes, and Daniella as well, that they were making a dungeon in the basement and he spoke specifically about a cage, that there would be a cage and he said it was for the people who were the most committed to growth, they could go and get locked in the cage and my understanding of it was it was a type of surrendering, that to go in and to get locked in and to not know when whoever was in charge of it was going to let you out which also was something that I didn't want to do, that was scary and that I was concerned that I would have to do to demonstrate that I was one of the people who was committed to growth or that it would become something that we were taking on like as a penance for something.
MS. HAJJAR: You say the basement?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Where is the basement?
LAUREN SALZMAN: Of 9 Milltowne Drive, of the sorority house.
MS. HAJJAR: What did you picture the dungeon to contain, what did you understand it to have?
LAUREN SALZMAN: Well, Daniella tell me at one point that she had ordered a bunch of things for it and all the things that she described were like BDSM sex torture things.
MS. HAJJAR: Like what?
LAUREN SALZMAN: Like handcuffs, she described the cage, nipple clamps. She talked about one thing that -- I didn't understand the concept specifically -- but like tied your wrists and ankles and had some kind of net or something, I don't -- you know, all things that were sexual in nature.
MS. HAJJAR: Did Daniella Padilla in fact order items for the dungeon?
LAUREN SALZMAN: She told me she did order them and that the weekend that everything about DOS became public she told me that she had ordered the things and she was going to cancel the order so it didn't become public that we had a dungeon or we were having the dungeon.
MS. HAJJAR: Did you have a conversation with the defendant about what would happen if you went in the cage or did you express to the defendant a concern?
LAUREN SALZMAN: It wasn't specifically about what would happen much beyond it was you were just in there until they let you out but what I -- you know, you would just be in there surrendering, it could be, you know, ten minutes, it could be an hour, it could be days, like you didn't know how long it would be and that was the whole point of surrender but what I imagined was like being in there and having to go to the bathroom or something and then having to go through like that type of a humiliation which I think was the point of surrender, being willing to go through things that were vulnerable or humiliating or being willing to go through whatever as an experience of complete surrender and so that's what I imagined and, you know, obviously not the kind of thing you're hoping to experience. I wasn't. I wasn't hoping to experience that. It wasn't something I wanted to do. And the fact that it was being linked with growth, like the most committed people to growth, so it became like if I didn't want to do it, then I was one of those people that wasn't committed to growth and that was a very hard thing to get my mind around and I didn't believe that you couldn't be most committed to growth unless you were willing to do BDSM things.
MS. HAJJAR: You testified about the game as well, the game as a concept in DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain what that was?
LAUREN SALZMAN: I wasn't as involved in the game as -- I worked on the book so the game was a different project but my understanding was that the game had different objectives. One of the objectives was like a screening process to find people who would be -- who would want to have a lifetime vow of obedience, that most people wouldn't want to have that but the game would be a filtering system to find the people who would want that but there might be other people who would want to be involved in the group to lesser degrees and so they could play at whatever level they wanted to play at but also it was a way of getting a lot of information -- personal and private information about people, as many people as possible was my understanding because we wanted to recruit as many people as possible but it would start out like a simple thing that I could just say to you at a party or a bar or something like, do you want to play a game, and then it would start out just really simple like, you know, it could be something like I dare you to do something and then you would do it and you would get something for that. So, it was a progressive thing, the more you gave, the more you got and you could go up different levels.
MS. HAJJAR: You say it was intended as a screening process for DOS, can you explain how that worked?
LAUREN SALZMAN: The people who wanted to go up the levels very quickly and were on board for all of those levels would be the kind of person who could be presented with the concept of this lifetime vow of obedience to a master and would want that. You could more quickly identify what kind of person would want that based on how they were responding and what they were willing to do in the game.
MS. HAJJAR: You testified about the DOS book and your efforts with the DOS book; can you explain what that was?
LAUREN SALZMAN: The book was, as I understood it, was the philosophy of the concepts of why have a master, why be a slave, like what are the benefits of doing that, why have a sorority or a group all collateralized, you know, with each other -- with their masters and with each other, why -- what it meant that you were making this commitment to serve a master and ultimately like that your master was supposed to your highest priority and that your main job as a slave was to always be thinking about them and thinking about how to move their life forward and that should be the highest priority always above all other things.
MS. HAJJAR: Who created the context of the DOS program?
LAUREN SALZMAN: Keith created it.
MS. HAJJAR: How did it become the actual DOS book, can you describe that process?
LAUREN SALZMAN: Well, before I was in the sorority he gave the ideas for it, so he would go to the meetings and share what the concepts were and they would be recorded and then those recordings were transcribed, I'm not sure by who but I assume the first line, and then those transcriptions were edited to make a book and when I came in Nicky and Rosa Laura most particularly were working on editing the book and Keith asked if I would help edit the book.
MS. HAJJAR: Did you hear the original recordings in the process of editing the book?
LAUREN SALZMAN: Some of them.
MS. HAJJAR: At what point would you consult the original recordings?
LAUREN SALZMAN: When something that was written didn't make sense to me, to hear how Keith said it gave me an understanding of what he was talking about.
MS. HAJJAR: So, for each -- did the book comprise chapters?
LAUREN SALZMAN: Yes.
MS. HAJJAR: For each of those chapters were the original contents in a recording that you could listen to of the defendant's voice?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did the defendant ever tell you what his plans were for the DOS book, what he intended for it?
LAUREN SALZMAN: I think he wanted it to be like a -- like what was -- he compared it to some of the other things that existed in like the field of like yoga, so it could be something like that, like understanding how to have a relationship with your guru or, you know, those type of yoga practices but the book would be very pretty and it would outline the philosophy, people could go and they could study the book but the book was supposed to be secret and that he had envisioned that it would be kept in like a secret location and that people could go but they would have to be like basically checked that they wouldn't record anything, they wouldn't copy it, they wouldn't take any pictures of it, you know, like screens to be able to go in and that the book could be like maybe chained to the wall or something, it would be secure so they couldn't take it, they couldn't copy it, there would be no evidence of it but they could go to these places and they could study this book.
MS. HAJJAR: Where would the -- did you have an understanding of where the book would physically be?
LAUREN SALZMAN: We talked about the idea of getting bigger and having different areas that would have chapters of the sorority, that each chapter might have a book.
MS. HAJJAR: May I show something to the witness for identification only, Your Honor?
THE COURT: Yes.
MS. HAJJAR: Ms. Salzman, I'm showing you what's marked for identification as Government Exhibit 1403.
Do you recognize this exhibit?
LAUREN SALZMAN: Yes, I do.
MS. HAJJAR: What is it?
LAUREN SALZMAN: It's an email that I sent to Keith of edits that I made in Chapter 1 of the book for his review.
MS. HAJJAR: Showing you what's marked for identification as Government Exhibit 426.
Do you recognize this exhibit?
LAUREN SALZMAN: Yes, I do.
MS. HAJJAR: What is it?
LAUREN SALZMAN: Keith sent back his comments about my edits, he edited it a little to show me the right path to be on and then this email is me forwarding his comments to Nicki and Rosa Laura.
MS. HAJJAR: I'm showing you what's been marked for identification as Government Exhibit 427.
Do you recognize this exhibit?
LAUREN SALZMAN: That's the email that Keith sent back to me with his edits.
MS. HAJJAR: Did each of these emails have attachments?
LAUREN SALZMAN: Yeah, they had Chapter 1 edited, my edits and then his edits and then that forwarded on.
MS. HAJJAR: I'm showing you what's marked for identification as Government Exhibit 1404.
Do you recognize this exhibit?
LAUREN SALZMAN: That's the book.
MS. HAJJAR: Your Honor, the government offers Government Exhibits 1403, 426, 427 and 1404.
MR. AGNIFILO: Can I have a second to talk to the prosecutor? There's two exhibits that are the same.
THE COURT: You want to talk to the prosecutor?
MR. AGNIFILO: Yes, yes.
THE COURT: Go ahead.
(Pause while counsel confer.)
MR. AGNIFILO: The mystery has been solved. No objection.
THE COURT: All right. Government Exhibits 1403, 426, 427 and 1404 are received in evidence.
(Government's Exhibits 1403, 426, 427, 1404 so marked in evidence.)
MS. HAJJAR: Thank you, Your Honor. May I publish them?
THE COURT: Yes, you may.
MS. HAJJAR: So, first showing you Government Exhibit 1403, who sent this email?
LAUREN SALZMAN: I did.
MS. HAJJAR: And when was it sent?
LAUREN SALZMAN: On February 9th, 2017.
MS. HAJJAR: What's the subject of the email?
LAUREN SALZMAN: Chapter 1, Word-By-Word, LS edit 4.
MS. HAJJAR: And is there an attachment to this email?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you read the text of the email please?
LAUREN SALZMAN: M -- which stands for master -- M, please find my stripped down version of Chapter 1, the word by word section. Please let me know if you think I am in the ballpark. Thank you, L.
MS. HAJJAR: Why are certain -- why did you capitalize the "Y" in You?
LAUREN SALZMAN: Because we capitalized all pronouns referring to our master.
MS. HAJJAR: And your master was the defendant?
LAUREN SALZMAN: Correct.
MS. HAJJAR: Showing you the subsequent pages, what is this, what is the attachment to this email?
LAUREN SALZMAN: This is Chapter 1 of the book.
MS. HAJJAR: I'm showing you Government Exhibit 426 -- 427.
Who sent this email?
LAUREN SALZMAN: Keith sent it back to me.
MS. HAJJAR: What date?
LAUREN SALZMAN: February 10th, 2017.
MS. HAJJAR: And what is the text of this email back to you?
LAUREN SALZMAN: What is the text, he said that he edited it a little, he edited my edits a little but that I'm on the right path he thinks.
MS. HAJJAR: And looking at the attachment, can you explain the edited text here?
LAUREN SALZMAN: He took out some words, added some words and what -- his edits are highlighted to give me an idea of how to carry that type of editing forward through the rest of the book.
MS. HAJJAR: And showing you what's in evidence as Government Exhibit 426.
LAUREN SALZMAN: This is an email that I sent to Nicki and Rosa Laura February 10, 2017 saying: Here's what I sent him and some comments he sent back. Let's discuss.
MS. HAJJAR: What do you forward?
LAUREN SALZMAN: His edited version.
MS. HAJJAR: When you say, "what I sent --
MR. AGNIFILO: I think our monitors are dark. I think the government's monitors are dark too.
THE COURT: We'll get it fixed.
MR. AGNIFILO: Thank you, Judge. I apologize.
THE COURT: That's all right. Thanks for letting me know.
MS. HAJJAR: And when you say, "what I sent him," who were you referring to?
LAUREN SALZMAN: Keith and it's capitalized because he's our master, he and him.
MS. HAJJAR: Your Honor, may we activate the PowerPoint?
THE COURT: Sure.
(Pause.)
THE COURT: You're not picking it up, are you?
MR. AGNIFILO: Not yet, Judge.
THE COURT: This is in evidence?
MS. HAJJAR: Yes, it's in evidence as Government Exhibit 1404.
THE COURT: Okay.
MS. HAJJAR: Do you see that, Ms. Salzman?
LAUREN SALZMAN: I do, yes.
MS. HAJJAR: And remind us what Government Exhibit 1404 is?
LAUREN SALZMAN: It's Chapter 1 of the book.
MS. HAJJAR: Can you read the first text that appears under Furtherance, Honor and Gratitude?
LAUREN SALZMAN: Your sole highest desire must be to further your master from whom all good things come and are related. You must honor and hold your master and lineage above all others in every way.
MS. HAJJAR: And can you explain how these chapters were broken up; what does it mean to be -- the lesson 1, Understanding Word-By-Word, what does that mean?
LAUREN SALZMAN: Each of the words in that sentence were defined so that we would totally understand the meaning of the sentence and it couldn't be misconstrued or misinterpreted in any way.
MS. HAJJAR: Can you read the highlighted text, Ms. Salzman?
LAUREN SALZMAN: I believe something must be so, I allow for no excuses. It is the ultimate foundation.
MS. HAJJAR: Was this concept, the concept of no excuse in DOS, a common one?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: Well, the concept came -- I mean came first from I think SOP, the men's curriculum, and possibly also Jness, the women's curriculum within our NXIVM umbrella but the idea was in any circumstance because of the way that men are brought UP and raised they have life experiences and certain cause and effect -- a relationship to cause and effect that women don't have and so that in any circumstance men have two options, they can either do the thing that's required or take a consequence for it but that women because of the way that we are raised and coddled by society and by men in particular, we have a third option, we can do the thing, take the consequence or victimize ourself, make an excuse and get off the hook and so this idea that women need to get rid of the third excuse was something that was -- we had already been spending time interacting with in -- within our community and curriculums. So then the idea that we wanted to become these women who were self-reliant and who were willing to be able to do what it took to be responsible, participating, contributing members of society that the men in our lives felt they could depend on and count on and respect, we wanted that and so the idea of no excuses was like get rid of that third option and learn to do whatever it takes to show up and do the job.
MS. HAJJAR: Do you have a view on that concept now?
LAUREN SALZMAN: Well, it started to become problematic when there were things that were valid concerns that were being raised and then we were told it was us making excuses and so things that were valid and of concern were turned back around and we were told it was our issue, you know, and that this is -- we're just being women, you know, and largely -- I mean in part there was this idea that we were having some kind of democratic process but the truth was if we had objections to different viewpoints, it was always because we were being women or we were having issues because men wouldn't have objections, they would just do it but that's not a democratic process and so that became difficult.
MS. HAJJAR: Turning to paragraph 10 in the book, can you read the highlighted portion?
LAUREN SALZMAN: Seeing how I can't move the object is blame. It's what we do internally with excuses. Women in particular are miraculous excuse finders. Why? Because it works. If a woman goes out in public and there's some sort of problem, she needs a bag carried or something terrible is happening, she has more options in our western culture to find excuses than men do.
And then -- continue?
If you find you cannot do something or you can't do something, that's not an excuse not to do it. Saying you can't do something is an immediate denial of potency. That is a practice you want to not do. You want to practice the opposite. You want to ask how can I do things in a way that I didn't think I could do?
MS. HAJJAR: And the phrase "women in particular are miraculous excuse finders," is that the same concept you were alluding to previously?
LAUREN SALZMAN: Yes.
MS. HAJJAR: This is under the chapters -- the paragraphs with numbers 11, 12 and 13; can you read the highlighted portion?
LAUREN SALZMAN: The most important lineage is, if you will, your slaves, your slaves's slaves, etc, and your master, your master's master, your master's master's master all the way up like that. They would say what would my master's master's master say. So, actually -- it is actually importing what your master and the lineage would say into all of your decisions, it's holding them above. Well, actually everyone is related, everyone is in my lineage. I could extend my lineage to every single person. So I don't have to hold anyone above anyone else. Everyone is equal, everyone is perfect, everyone is the same, we're all new age. Let's eat some crystals and all be happy. But that's not what this is saying, there are people who are in your lineage and directly of your concern and people that are not. People of the lineage and that lineage just like the master becomes internalized and you hold that above all others.
MS. HAJJAR: What is lineage in DOS, what does that mean?
LAUREN SALZMAN: Lineage is -- so, there are eight lines for the eight first line masters and anybody we enrolled under us. So, Keith at the top, then me, the women I enrolled, the women they enrolled, the women they enrolled, that makes one lineage. So, there are eight of them.
MS. HAJJAR: And the phrase, "What would my master's master's master say," for everyone in DOS who is that person?
LAUREN SALZMAN: Ultimately all the way up is Keith is the master's master's master's master.
MS. HAJJAR: So, these practices that come after the -- there are lessons and there are practices beneath it, what are the practices?
LAUREN SALZMAN: There were suggestions of something that you could do to build your internalized experiential understanding of the concept that was presented in -- the philosophical and theoretical concept that was illustrated in the chapter. Then there was a practice you could do so it could become practical and you could learn to be that and live that.
MS. HAJJAR: Can you read that second practice please?
LAUREN SALZMAN: Contemplate why your master is better than all other people, why they should be held above all others.
MS. HAJJAR: And was that put into practice in DOS, the concept of your master being better than all other people?
LAUREN SALZMAN: Yes.
MS. HAJJAR: So, this is under Lesson 10, What Does Master Mean, can you read the highlighted portion?
LAUREN SALZMAN: It is a conscience of fear, it is not the highest but ultimately they should be able to make a vow and it should be so distasteful to break the vow that they'd rather die than break their vow and that's a vow for everything. This is very physical manifestation of the vow with the brand, with all of this stuff that might really be the first and only thing that represents a forever until your last breath collateralized and on an ongoing basis more collateral is put into this thing so we have an example to build all other things from.
MS. HAJJAR: What is this describing?
LAUREN SALZMAN: It's describing that your collateral should be so distasteful that you would rather die than break your promise and that initially you're going to have this conscience, you're going to be so afraid that your collateral might be released that you will build a conscience about it, that you'll remember not to break it because you couldn't live with yourself if you did, you couldn't live with the consequences of that because it is so scary.
MS. HAJJAR: So, the practice under Lesson 10: Do one act of self-denial every day in honor of your master.
The act of self-denial, are those the self-denial acts you described earlier?
LAUREN SALZMAN: Yes.
MS. HAJJAR: So, under Lesson 16: Nature of Commitment, Nature of the Vow. What's the underlying principle, vision, motivation of the whole thing, what's the nature of the commitment.
Can you read the highlighted portion please?
LAUREN SALZMAN: That's why the master-slave relationship works so well, you submit, you surrender yourself to a master but it's the deeper principle that is symbolized through that person. This vow is more than that. When you make a vow to your master or when someone makes a vow to you, this is the deepest vow you can do, maybe as close a vow as being in the military where if you try to go AWOL they kill you which happens but even that, if you are a soldier out on war and you tried to escape and they kill you, that death is not necessarily as harsh a collateral as what we ask as collateral because people should say death isn't even a way out, it's how strong this commitment is -- that's how strong this commitment is.
MS. HAJJAR: And did you consider your commitment to be this strong, as strong as described in the DOS book?
LAUREN SALZMAN: Yes.
MS. HAJJAR: In that same section: Discipline is correction and obedience to that correction; can you explain -- was correction a concept in DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Could you explain that?
LAUREN SALZMAN: If we did something and we are given feedback that it was not caring or loving or considerate or mindful, we were to fix it. Anything that was pointed out should be corrected.
MS. HAJJAR: And underneath that: Obedience, it doesn't matter what the command is, it matters that you obey. It doesn't matter if you understand the command, it matters that you obey.
LAUREN SALZMAN: Yes.
MS. HAJJAR: Was that a concept in DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: This highlighted text: Making excuses about it, you can suffer about it, you can practice interpersonal games in a way that you get around it; what is this describing?
LAUREN SALZMAN: It is describing making excuses not to just obey, not to stay and uphold your word to keep everything completely confidential and be in this vow of obedience.
MS. HAJJAR: Are these the same excuses that you were describing earlier?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you read what's under Chapter 2?
LAUREN SALZMAN: Your greatest joy is to surrender completely all things in all ways without reservation completely exposed to your master and master's will. The best slave derives the highest pleasure from being her master's ultimate tool independent of use. By joyously offering all your decisions to be made or used by your master, you surrender your life -- my screen went black -- your life, mind, body and possessions for unconditional use.
MS. HAJJAR: Did this text under Chapter 2 have a role in the ceremony involving the branding that you described earlier briefly?
LAUREN SALZMAN: Yes, we specifically said that in the branding ceremony, that I -- that my greatest joy is to surrender completely all things in all ways, almost word for word this whole thing we read; I surrender my life, mind, body and possessions for unconditional use.
MS. HAJJAR: And this practice underneath that chapter of asking your master for permission with the greatest feeling of joy, challenge yourself to do that, the most valuable decisions would be the ones you're most afraid they'll say no to; was that also a concept in DOS?
LAUREN SALZMAN: Yes, regarding like asking for permission for something and you should ask permission about the stuff that you feel most specifically attached to, so that if they say no, you know, you were willing to surrender it even if they said no. That's how you know it was really particularly committed and obedient and surrender, that is the hardest thing and you're willing to give it up.
MS. HAJJAR: In Lesson 4, Without Reservation Completely Exposed, the text under that reads: So completely exposed means completely vulnerable without hiding anything, that there are no closets that are unopened, no little boxes, nothing unexposed, truly an open vessel.
LAUREN SALZMAN: Yes.
MS. HAJJAR: What did you mean by those words, "an open vessel"?
LAUREN SALZMAN: An open vessel, like totally open to be able to serve any purpose or any function no matter what it is without evaluating the function, without judging the function, without reacting to the function, just being willing to do the function.
MS. HAJJAR: Is that the DOS slave?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Under the practices under this chapter there's a practice involving sharing deepest fears, fantasies, secrets and thoughts; was that part of DOS?
LAUREN SALZMAN: Yes, some parts.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: That practicing sharing, that is a type of rooting out of pride or finding areas of fear and so exposing those would in theory being freeing and so that was a practice done to confess something, to be vulnerable and to be willing to be totally exposed to your master.
MS. HAJJAR: And looking back now, do you have a different view of this practice of confession, of sharing deepest fears?
LAUREN SALZMAN: Well, I think it -- I mean it makes you particularly vulnerable, you know, in situations. It makes you specific -- I think specifically vulnerable and more susceptible to be taken advantage of if abuses of power happen but also I mean some of those things too go back to the -- a lot of the things -- it didn't always have to but I think in general too that also it took a sexual connotation at different times.
MS. HAJJAR: What do you mean?
LAUREN SALZMAN: Your fantasies, like sometimes took a -- what are your -- like sexual fantasies component.
MS. HAJJAR: Okay. Lesson 8 is titled A Tool --
THE COURT: Can we take a break now?
MS. HAJJAR: Yes, Your Honor.
THE COURT: All right. Let's take the mid-morning break.
All rise for the jury.
(Time noted: 11:30 a.m.)
(Jury leaves courtroom.)
THE COURT: All right. The witness may stand down. Do not discuss your testimony with anyone.
(Witness steps down.)
THE COURT: All right. We'll take a ten-minute break and we'll try to fix the screens.
Thank you.)
(Recess taken.)
THE COURT: Bring in the witness please.
(Witness resumes the stand.)
THE COURT: Bring in the jury.
(Pause.)
(Jury enters courtroom.)
THE COURT: Please be seated.
Okay, Ms. Hajjar, you may continue your examination of the witness.
The witness is reminded that she is still under oath.
BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, before the break we were talking about some of the concepts including the concept of collateral in the DOS book. Were these concepts conveyed to your DOS slaves?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did you have occasion to ask them to read the DOS book as well?
LAUREN SALZMAN: I read portions of it to them.
MS. HAJJAR: Now, before the break we were at Lesson 8, A Tool. The tool doesn't have a want. The tool doesn't look at its use. The tool is just a good tool. The nature of being a sharp knife is to be sharp, it's not to care if it's being used as a murder weapon or being used for surgery.
In this context, what is the tool, what does that refer to?
LAUREN SALZMAN: The slave is the tool.
MS. HAJJAR: And the moment you start to care about the use, now you have your pride. To be a tool in a sense is saying no excuses.
What does that mean in the context of DOS?
LAUREN SALZMAN: It meant that whatever use your master had for you was to be done joyously and if you cared about what you were being asked to do or the why, it was your pride, your issues interfering with your success, effectiveness at being a good slave.
MS. HAJJAR: Were these principles just abstract or were they applied every day in DOS?
LAUREN SALZMAN: They were applied.
MS. HAJJAR: Lesson 10: Joyously offering all your decisions to be made or used by your master.
Under Lesson 10 there are these practices; can you read the practices please?
LAUREN SALZMAN: Spent time thinking of how you can proactively further your master with the current capacities you have. Choose to act on one thing that you would not have acted on otherwise.
And then number two is: What other capacities can you build to be able to further the master more. Make a plan on building those capacities and how that will further the master.
MS. HAJJAR: Can you explain that in the context of DOS, what that means?
LAUREN SALZMAN: That ideally you're looking to always make your master more successful, more effective, more potent in the world and so you should be always looking at how to proactively be doing that and if you're limited in your capacity to do that, then you should make a plan of how you can become unlimited so that you can further them even more.
MS. HAJJAR: Under the same lesson: You offer this as an opportunity for your master to use you as a tool. If you see yourself as a tool, the greatest door to opportunity, the greatest door for you is to be the tool, for you to be the vessel.
Can you explain what this means?
LAUREN SALZMAN: That the greatest -- that you should always be looking for these opportunities for your master to be able to employ you as a tool and that somehow in doing that, being like the vessel or the most open to that and the most willing to do that, to be the tool in any way or whatever it is and derive the greatest joy from that is the greatest opportunity for growth in yourself.
MS. HAJJAR: Was a DOS slave permitted to question the motives or the reasoning behind an order?
MS. HAJJAR: Lesson 11: Surrender your life, mind, body and possessions for unconditional use. What goes on within my body is personal to me and that too is the use of that as much as I can give over I do.
What does that mean?
LAUREN SALZMAN: It means that anything they want, your goal is to be able to serve them regardless of what it is and as much as you can, whatever goes on with your thoughts, your emotions, your body, your capacities, your work product, whatever it is, it is just all to serve them and to do that -- as much as you can do that, that's the goal.
MS. HAJJAR: And "them" is who?
LAUREN SALZMAN: The master.
MS. HAJJAR: Turning to Chapter 3, can you read the text at Chapter 3?
LAUREN SALZMAN: The joy of obedience is far greater than the distaste of any command. The harder the task required, the greater joy to complete. The harder the task completed, the greater proof to your master and yourself of your strength and commitment.
MS. HAJJAR: What does this mean?
LAUREN SALZMAN: It means that ideally you should be able to build joy in obeying and that that joy is far greater than anything you could be asked to do no matter how hard or distasteful it is, the joy should be better and the fact that it is harder or distasteful should make that joy more because you're proving to your master and yourself that you're that committed that you'd be willing to do anything, even really difficult and awful or distasteful ugly things, whatever they are.
MS. HAJJAR: Here's some examples of requests or commands here: If the master were to command you and say, at the bottom, take off all your clothes, run outside and jump up and down and say everyone, look at me, look at me, look at me, you would be taking off your clothes already and seeking to understand that, you're not worried that it's cold out, you're not worried that there's a public, you're not worried that the police might come, none of that is involved, that is your evaluation of it.
LAUREN SALZMAN: Yes.
MS. HAJJAR: What does that mean to you?
LAUREN SALZMAN: It means that you should be doing the command before you even question the command and that the objective is just to seek -- to understand how to do that command best, not to question why that command or any consequences of the command.
MS. HAJJAR: Did you convey these, the concepts expressed in the book, did you convey this concept to your slaves as well?
LAUREN SALZMAN: Essentially, yes. I don't know that I specifically read this part but, yeah, the concept of it, their job was to do that.
MS. HAJJAR: So, under Lesson 11, Pushing Beyond Indoctrination. You believe certain things are good and bad and that constrains, that circumscribes your life and they're just not true.
What does that mean?
LAUREN SALZMAN: It's a statement of our indoctrination, that like basically the way we're raised we come to believe certain things that are limiting, that certain things are bad which may not be bad or certain things are good which may not necessarily be good, getting hung up on the goodness or badness of it is constraining because we should be able to transcend our indoctrination because it can be limiting.
MS. HAJJAR: Was this a concept that was taught in NXIVM more broadly, this idea of social indoctrination?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Was this a concept the defendant taught?
LAUREN SALZMAN: Yes.
MS. HAJJAR: In this concept, the social indoctrination, that certain things are good and bad, is that something you are intended to get out of?
LAUREN SALZMAN: I don't understand.
MS. HAJJAR: Is a social indoctrination a bad thing in this concept?
LAUREN SALZMAN: Well, that certain aspects of social indoctrination can be limiting and so to transcend that would be to evolve beyond those limitations.
MS. HAJJAR: Can you give an example?
LAUREN SALZMAN: Sure. Like -- I don't know, you can think of like in any social custom but let's say, for example -- well, I don't know if you've ever had the experience where like as a child growing up you go over to eat at somebody else's house and their family does something like completely different than what your family does, so it just feels kind of awkward or uncomfortable, that's just like a simple example of you're indoctrinated in a certain way in your family and you may find as you come to grow that there are other ways to do things but there may be something that like maybe your religion says is bad, like getting divorced for example, you know, or your culture may say that that's really bad where another culture may not think that's bad; so, to realize that it is not bad in itself, it serves a function, you might be able to take advantage of that function where you didn't perceive it as an option before. That's just like a simple neutral example.
MS. HAJJAR: Did the defendant in the defendant's -- as he explained this concept, did it go further than that, did it go to things that were assessed as good and bad?
LAUREN SALZMAN: Yeah, I mean when we started getting into things more along the lines of like Jness curriculum when it was first introduced or SOP, then you start getting into more I guess you could call them like heated subjects, like people have more investment around, like having monogamous relationships, for example, like and in Jness then we started to introduce like the concept of men being more naturally polyamorous and women being more naturally monogamous, so somehow transcending our -- as women, our belief that we need to own our men and own the sex that they have as just as our own somehow this limiting belief and that if we could come to understand their more biological nature and some of the social constraints that have been put on them, them being men, in general that as women we would not be so fearful or controlling and we would come to accept and be really grateful for the things that they give us and not need to own them or put constraints on them to feel secure in our relationships.
MS. HAJJAR: Do you have a view on that concept now?
LAUREN SALZMAN: Well, I mean certainly through the curriculum it legitimized the lifestyle that I think Keith wanted to live and had a whole community of people who could understand that and support it or even defend and protect it against criticism or other consequences.
MS. HAJJAR: Is this the same concept, the same section, Unique Experience Breaking Through Your Indoctrination, is that the same social indoctrination concept you explained?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Chapter 4 is titled Quality; can you read the text under Quality?
LAUREN SALZMAN: You must give your master your very best at all times. All things done for your master must be of the highest quality you can offer.
MS. HAJJAR: And under Chapter 5 titled Aliveness, can you read that chapter?
LAUREN SALZMAN: As such, a good slave actively seeks to give her master a competitive advantage over all other people and in all situations. Always make your master increasingly more powerful, influential and capable through your actions and thoughts.
MS. HAJJAR: And this concept, did that take -- did that have practical applications in the context of DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: Well, we were always looking to be able to uphold our master, I mean in my case Keith, to help him, to edify him, you know, and help others see that -- like his good contributions and in essence we were -- I mean specifically in DOS, I mean not just the edification, I mean tribute was very prevalent and pervasive in ESP; in DOS especially we were seeking to find influential people to bring in to help increase the potency and the influence of the group and ultimately the group's objectives which were, you know, Keith was at the helm of that, they were his goals and objectives, his vision for the group. And in NXIVM it was part of that too, having powerful and influential people. It wasn't as much the objective but, you know, certainly you become more -- you have more capacity if you have more power and influence.
MS. HAJJAR: And by recruiting people of influence or power into DOS, did you see that as by extension making the defendant more powerful or influential?
LAUREN SALZMAN: I didn't think of it that way at the time but I do think that, I do think it is that.
MS. HAJJAR: Lesson 5 is Good Versus Bad and under that section I just want to -- I'll just read this paragraph to you, a little bit above that there's a highlighted phrase: The strongest bond that we can have as being for the good is a new bond that's created which is the vow. Criminals won't turn each other in because they're scared of being killed. The reason why people of the vow won't turn each other in, you can say that they are scared of the collateral but it is a collateral that they put up to certify that their bond is as good as any criminal bond, any bad bond.
What's the criminal bond, what's the bad bond?
LAUREN SALZMAN: The criminal bond is that if you -- it's like in -- I guess you could look at like criminal organizations or mafia organizations, why you don't rat on the people in the group, because you get killed if you do that.
MS. HAJJAR: So, criminals won't turn each other in because they're scared of being killed, that's the criminal bond, the bad bond?
LAUREN SALZMAN: That's the concept, yeah. I mean it says it, right, they're scared of being killed, that's the criminal bond.
MS. HAJJAR: So, the collateral that they put up to certify that their bond is as good as any criminal bond, any bad bond; what do you understand that to mean?
LAUREN SALZMAN: That the collateral is as scary as that or even more scary than that and we -- I mean we looked at it in the part we read before, where you're supposed to see it that death is not even a way out of it, so it's supposed to be stronger than even the fear of being killed if you were to violate the vow, that's how strong the collateral is supposed to be.
MS. HAJJAR: This is under Lesson 12, Powerful and Influential; if you're not always making your master, the time when you're not always, you're a minion for the bad, you're a minion for evil. Always make your master increasingly more powerful which means they're at a certain level of power, is that enough.
What does that mean?
LAUREN SALZMAN: Well, there are some concepts that were laid out a little bit before in the book that talk about that fear and comfort basically are vehicles for tools of hate or for evil because ultimately the reason we're being hateful is to be more comfortable or we're being hateful to get things that we haven't earned and so -- and that -- so, laziness, comfort, fearfulness breeds hate, these are the concepts that we lay out in the book before this but also that we've been taught within NXIVM. So, it's saying like that ideally you know that you're not breeding that by always being disciplined, always being vigilant, always working and so it links it up with the master in this context, if you're not always making your master, you know, increasingly more powerful, then you're being a minion for evil because you're being lazy about it or the only reason you wouldn't do it is either laziness or issues, fear, so somehow that breeds evil, you know, doing this is good and not doing this becomes evil.
(Continued on next page.)
DIRECT EXAMINATION (Continued): BY MS. HAJJAR:
MS. HAJJAR: Chapter 6 is titled "Creation."
Can you read the text under production potency and power?
LAUREN SALZMAN: That your master has your time and labor allows for more production. That your master has your vote allows for more potency. By recruiting others within your power you honor and increase your master's power.
MS. HAJJAR: Was the concept of time and labor associated with -- as to the DOS slaves, an important component of DOS?
LAUREN SALZMAN: Yeah, I mean the idea that's being communicated through this is that if you're putting in, let's say, 70 percent of your effort towards moving something forward, in this case moving the master forward. And then you take 30 percent off to be lazy, you just undermined all your own efforts.
So it starts to talk about that it has to be full time. It's a full-time commitment to be always making your master more potent.
And it ties directly to things -- so that was supposed to be the general mindset. And then there's specific time dedicated to furthering the master. And labor dedicated to furthering the master.
MS. HAJJAR: Under Lesson 2, Labor and Production. And maybe above that as well.
If you're serving the master at 49 percent of the time, you're not serving the master. It needs to be a hundred percent. It certainly has to be over 51 percent otherwise you're knocking yourself out, and the other half of the time, when you're not severing the master, you're serving other things. So the nature of this time is something you really have to value.
Is this a concept you conveyed to your slaves as well?
LAUREN SALZMAN: Essentially. I don't know if I laid it out exactly like that, but it's just like it says here. If you're undermining your own efforts, then you're not moving forward. So you should always move it forward.
MS. HAJJAR: Labor you might say are work. All that we do with the outside world, with our bodies, our emotions, and our thoughts. So most people who say, I can't do more, they're not looking correctly. There are a series of excuses.
The master shows you where you fail, which is the most important thing to increase your production, increase your net results to get you out of the 30-hour a week low-labor, low-wage job.
So that by having the outside perspective and the outside person, it can help you overall do so much more for the ultimate master, which is your ultimate purpose on this world, which is ultimately also being forced by the defendant.
The concept of productivity and that first stages of DOS was linked to slave productivity, was that something you conveyed to your DOS slaves?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: That ideally they should be seeking to provide the most value in the time and the labor that they're providing. They should do the highest value of jobs, basically, and that that contributes the most.
MS. HAJJAR: Can you give an example of that with respect to your DOS slaves in terms higher capacity worked?
LAUREN SALZMAN: Sure.
Like at one point I think I had a conversation with Audrey and she relayed she often would -- would -- she'd be grocery shopping so she would ask if I wanted anything or pick up some groceries, while she was out. Which I would pay her for the groceries but not the time she spent shopping.
And I conveyed to her that helping me -- or she offered to do things similar to that, like personal assistant work. And I communicated to her I have personal assistants, who do this low lever work, you should do the highest level of jobs.
So providing things like executive level assistance, you know doing -- and then later some of my slaves helped with that. Like Audrey helped do administrative type -- executive level administrative type work for DOS, or Jimena was helping with the sales process for DOS.
They're doing higher level, not just basic things my housekeeper can do.
MS. HAJJAR: In terms of labor you received in the context of DOS, was some of that labor qualified, like qualified in as specialized profession?
LAUREN SALZMAN: Yeah. I mean we reviewed legal contracts and did legal research, so in that sense.
MS. HAJJAR: And was -- was that work in the context of a requirement in DOS?
LAUREN SALZMAN: Well, it was her active care. She did it as her active care. So, yes.
MS. HAJJAR: You said that your master has your vote and allows for more potency. The holy trinity of time, labor, and vote.
What are each these things, the time, labor, and the vote in the context of DOS?
LAUREN SALZMAN: Well, your time, that you're contributing your time towards moving your master forward, and your efforts, your labor, and services.
The way that vote was used was actually self-referential that it was what you vote with or the way that you spent your time.
So as we, you know, just reviewed that, if you're spending, it has to be at least 51 percent of commitment or your undermining your own efforts. You have to be voting. Your vote has to be more than 50 percent for you to actually be voting for moving the master forward. That was how vote was used.
But I think there are more reliant obligations of voting we talked about. We won't have influence in the world, but there's way more votes for in the world and that could be worthy of, you know, a shock to who you elected in office.
MS. HAJJAR: If you're highest value is the master, by spending your moments doing things for the master, around the master, by the master, makes you purposeful, makes you annealed, makes your moments close to a hundred percent in a given direction highly effective, and it's a gift to your master and a highly effective slave.
That is this concept of being highly effective, a good thing in DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: To your master?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Ms. Salzman, you testified that enrollment was a focus in DOS.
This part of the book reads: Every person who becomes a slave should make a whole list of names of all the people they know, mother included, and who should be enrolled.
Is that enrolled in DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: The moment you recruit someone, you take your master's position into your own and you become one with the master because you are the master. So when you recruit someone, you give your master a gift.
Is this gift, in the context of that sentence, a reference to the DOS slave that you recruited?
LAUREN SALZMAN: I didn't see it -- I hadn't seen it that way. I thought it was the gift of becoming a master yourself. But, in essence, that slave is their slave, too. So it is can seen in that way.
MS. HAJJAR: So you when recruit someone, you give your master a gift.
How do you understand that sentence?
LAUREN SALZMAN: I had understood it by becoming a master yourself. But, in essence, it's a gift either way.
Because it makes them more potent, especially if you look at they're going to give an hour towards the -- you know, if my master has an objective and my hundred percent is to serve that objective, any slave I have serving me is serving that objective.
So whether they're serving my objective to serve that objective, or that objective directly, it's a gift. It goes to them any way.
MS. HAJJAR: Chapter 7 is Connection.
Can you read what's under secrecy?
LAUREN SALZMAN: Always make your master look good and be powerful and capable. Intelligently utilize the secrecy of your relationship with your master to be a confederate and to move your master forward.
MS. HAJJAR: What does that mean?
LAUREN SALZMAN: As it was explained to me, a confederate is somebody who is in on the secret but doesn't appear to be in on the secret.
So if you have like a magician who's performing an act and gets a volunteer from the audience, oftentimes that volunteer appears to be just like an audience member but actually they're part of the act and it's been planned ahead of time.
So the idea of using that in this case is two people who seemingly seem unrelated but who actually have the secret relationship where one of them is actively trying to move the other forward, it can be used as a powerful tool because a seemingly innocuous person is advocating for somebody who seems unrelated to. And so sometimes that carries more worth or for credibility than somebody who publicly has an allegiance to that person.
MS. HAJJAR: Is this something that you experienced with the defendant?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you give some examples of that?
LAUREN SALZMAN: So in -- yes, in ESP, in intensives, for example, you might have somebody who is running a mentor group, which is a mentor group you would have like a specific person who is there to help you and process you through your issues to resolve whatever you bring to the group that you want to work through. But behind the scenes, that person could be given a whole bunch of information about you that you wouldn't have known ahead of time.
So sometimes I would be sent in to mentor certain people and be given information about them that they didn't know that I had.
And in particular, before I knew about DOS, there was a DOS -- someone I came to learn was a DOS slave, who I was asked to mentor in the intensive, who I was told was felt that breaking their commitment was freedom, and that it would be good if I could be their mentor, which is an unusual thing because I was a very-high level person in NXIVM. So I didn't mentor very many people.
So I was asked to go in and mentor this person and help them learn that through commitment is where you really experience freedom.
So in that case I became a confederate, and that's something I wasn't even privy to, I believed to help get them to stay in DOS, and they ended up leaving.
MS. HAJJAR: Did the defendant task with approaching this?
LAUREN SALZMAN: Mentoring them through an issue about surrounded commitment.
MS. HAJJAR: And you later learned that at that time the person you were tasked to approach was, in fact, a DOS slave or had been?
LAUREN SALZMAN: And was -- and was deciding whether to leave DOS. And I was sent in to advocate for commitment is freedom not leaving the commitment is freedom.
MS. HAJJAR: So can you just explain how that relates to the concept of being a confederate?
LAUREN SALZMAN: In a sense I was advocating for their relationship with Keith and with DOS without even understanding it.
Had I had known, I would have been a known confederate, but I was an unknown confederate in that case.
But there -- I mean during the time of DOS, we had other companies. You know, a Keith started number of different companies and he began very publicly advocating for Daniella Padilla very publicly.
And then later I came to learn -- and it was questionable to me even at the time why is he advocating for her so publicly? And later I became to learn her DOS was going on during that time and at that time he was teaching her what confederacy was.
MS. HAJJAR: This concept of a confederate and confederates are very powerful strategically.
Are these the same concepts you described and performed?
LAUREN SALZMAN: Yes. Let's say, for example, like somebody would -- one of my slaves would say, why don't you go talk to Lauren? She would be a really good person to talk to. If you could see Lauren as a client, like my slaves or their slaves' slaves could even refer me business or something like that without even knowing that those people are doing that specifically to further my own career.
MS. HAJJAR: And that was part of --
LAUREN SALZMAN: It could be seen that they thought, yeah, yes, it could just be seen as them being -- having had a bit of experience with business. And so I'm a good person to go to for that business versus the secret relationship we had where they're committed to actually moving my business forward.
MS. HAJJAR: So in this lesson through a connection there's a paragraph: People of The Vow are reliable to people in The Vow. If there's a vow, and you're connected to them in some sort of task, you know they will execute if collateralized. Their word is collateralized ultimately by whatever collateral.
And do you know the collateral intent? How do you know? Because your collateral intent? So everyone of The Vow will act to a great degree reliable.
What does that mean?
LAUREN SALZMAN: It means that you can count on the trust of the people not to violate the commitment to secrecy and to the group because their collateral is so intense and you know it's so intense because your collateral is so intense, and you're afraid of the consequences of breaking your vow so you understand what kind of confidence you can have in them because you can imagine what it must be like for them because it's like that for you.
MS. HAJJAR: And the people here being DOS slaves?
LAUREN SALZMAN: DOS slaves. You can look at any other DOS slave and know how much you can trust them to stay and keep your secret to do whatever because they would never leave because it's so -- it would be so horrendous if they did, and you know that because it would be so horrendous if you did.
MS. HAJJAR: Where the text reads: You know you will execute.
What does that mean?
LAUREN SALZMAN: You know they'll come through no excuses because that what they're commanded to do, that's what their vow is about.
MS. HAJJAR: Chapter 8 under needs: Always be attentive to your master and your master's needs. Any hints to which you can attend, any need you can find should be met and satisfied without request or command. During everyday hour and moment, you must be actively moving your master forward personally and in the world.
Was that part of DOS as well?
LAUREN SALZMAN: Yes, all of this was.
MS. HAJJAR: Under attentive, again, these lessons break down the concepts in the first -- in the first part of the chapter; is that right?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And under attentive, the text reads: So you focus your awareness on the master. Ever see a hungry dog? Someone walks in the room with food, that dog sees nothing else. That is how you should he be a hungry dog for your master. Your master's voice, when the master's in the room. Your master's object. Anything of the master that you perceive. Master leaves a crumb on table, it's all about that.
What do you understand that to mean?
LAUREN SALZMAN: That you should be always paying attention to what they are, and anything they do, you should be aware of it.
And always looking to make it better, easier, more effective, more efficient, more productive, more influential, everything. They're the highest priority. Everything.
MS. HAJJAR: Ms. Salzman, did the defendant discuss an idea or any ideas about DOS in the future, the form it would take?
LAUREN SALZMAN: To a degree at times. I mean, I think he envisioned that it would have, you know, thousands or, you know, a million -- millions of people in it. That there would be actors, you know, so there would be different areas.
He spoke a little bit about having like an area have somewhere in the neighborhood of like 300 members.
And there were ideas for group meetings and how to conceal identities during group meetings. So that you could maintain the secrecy and the type of silent-ism of the group, but still have interaction with people who weren't part of the group.
MS. HAJJAR: Can you describe that further in terms of concealing their identity, what does that mean?
LAUREN SALZMAN: Like if you're going to attend a meeting and you would have a group meeting but everybody might be in masks, or you might have a pseudonym, or you might -- like the first line DOS members had different brands than everybody else. So that those brands you might possibly cover with something that looked more uniform to everyone else.
MS. HAJJAR: Did the defendant ever talk about effects DOS might have in the larger world?
LAUREN SALZMAN: Possibly that we might be able to have a candidate -- you know, a DOS candidate in like a high-level political office.
MS. HAJJAR: The DOS candidate needs -- in a collateralized vow?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Ms. Salzman, I want to go back to discuss your initial recruitment into DOS.
You testified that was in January 2017?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Who first approached you about DOS?
LAUREN SALZMAN: Keith first approached me.
MS. HAJJAR: And what did he say to you?
LAUREN SALZMAN: He said that he wanted to make our relationship closer. He wanted to bring our relationship closer. And he asked me what I was willing to do for my growth and for my commitment to him.
MS. HAJJAR: What did you say?
LAUREN SALZMAN: Anything. Anything. I'm fully committed to my growth and fully committed to you.
MS. HAJJAR: What did he say?
LAUREN SALZMAN: He told me that there was something that some of the other girls were doing. He was not specific about who the girls were and -- but that they wanted to invite me to something and that they were going to be approaching me.
He and I had conversations over the next like 24, 36 hours, so I'm not sure exactly in which they took place in which conversation. But we had a number of conversations concerning my enrollment over the next two days.
MS. HAJJAR: At the time, were you responsible for running a NXIVM Coach Summit?
LAUREN SALZMAN: I was, yes.
MS. HAJJAR: Just very briefly, what is a Coach Summit?
LAUREN SALZMAN: A Coach Summit is an opportunity for the coaches and the higher-level NXIVM ranks.
So the people who run the programs, who work with the students, who come in, who participate in the educational programs and who run those. Who run -- who work in the centers. Those are our coaches and proctors and senior proctors. These are the high ranks.
This was an opportunity for us to come together and we would put on a retreat once a quarter, but basically we had centers in three different -- mostly in three different countries. So it's a lot of people from a lot of different areas coming all together and setting their vision for what they wanted to do or achieve the next quarter. And how they could work together to overcome some of the limitations they were having or support each other better.
MS. HAJJAR: What was your role at this Coach Summit?
LAUREN SALZMAN: Well, I was an executive board member so the summits in recent years were run by the executive board. And I was bringing ESP to a higher level, like what you might consider like a vice president or a higher upper-level management position.
But in this case, two of our highest ranks and close personal friends had passed away, so they were the highest ranks in ESP so they were no longer with us. And then the next highest rank was inactive. And so this was the first Coach Summit where I was the highest active rank.
So it was very important to me to run it well and do a good job and have people feel I was the leader that they -- that they didn't feel that I had gotten my position through default because everybody died or went interactive, but actually that they felt confident in my leadership and felt glad that I was the leader. So it was -- it was especially important for me.
MS. HAJJAR: Were one of those individuals who passed away Pam Cafritz?
LAUREN SALZMAN: Yes.
MS. HAJJAR: So what happened after that initial discussion with the defendant?
LAUREN SALZMAN: Rosa Laura approached me, and we had a meeting in her car where she introduced the concept of collateral and me committing my first collateral. So for secrecy.
MS. HAJJAR: Did you have subsequent conversations with the defendant around this time too?
LAUREN SALZMAN: I did.
MS. HAJJAR: What did he say?
LAUREN SALZMAN: He told me that he had started a sorority. That there were seven members of founding members, and that they were going to invite me to be a founding member.
He told me that the intent was that -- which I believe I later found out was not true, but that they had always intended that I would be a founding member. And that he asked me if I could guess who the other members were.
He told me that the sorority had started because of a personal struggle that Camila had had surrounding a suicide attempt.
And I can't quite recall. But definitely those things.
MS. HAJJAR: You said he asked you to guess.
Did you guess?
LAUREN SALZMAN: I did guess. I wouldn't have guessed Rosa Laura. But once I knew Rosa Laura, I guessed the others.
Because there had just been a series of events of things going around me that I had been aware of with the other members, that once I understood there was a sorority, they made sense. So I was able to guess who was in it.
MS. HAJJAR: And those individuals, those were the women you've identified as the first line of DOS?
LAUREN SALZMAN: Correct, yes.
MS. HAJJAR: Did you propose -- did Rosa Laura, when she approached you, discuss collateral at that time?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Okay. And what happened after that?
LAUREN SALZMAN: I went home to come up with my collateral, and I came up with the collateral that I submitted to her. That was rejected.
MS. HAJJAR: Okay. So what form did that collateral take?
LAUREN SALZMAN: It was -- I sent it in a WhatsApp message.
MS. HAJJAR: And you said it was an account of a crime. You described that earlier?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Was this true?
LAUREN SALZMAN: Yes.
MS. HAJJAR: When had this occurred?
LAUREN SALZMAN: In the fall of 2002.
MS. HAJJAR: Can you explain what it was that you -- that happened and that you wrote down as part of your collateral?
LAUREN SALZMAN: That there had been a woman from Mexico who had come to take an ESP course, and in the -- in the days of the course she had what I would characterize as a psychotic episode, like a psychotic break.
And she -- in my opinion, she should have been hospitalized. But this was something that we hadn't -- we didn't see, we hadn't seen in this way to this extent and didn't know what to do about it.
So we started seeing bizarre things with her throughout the day. And then she showed up at volleyball where Keith was and became very agitated and physically violent to the people around her.
And he suggested that we should take her -- he told us to take her out of volleyball and that we can drive around in the car and try to calm her down, and then eventually told us to take her to a friend's house.
And so we took her a place where she could be safe and wouldn't hurt herself. Which we did.
And then he was communicating through my mom to me. And later he said it would be good if she could sleep. That he thought if she slept that she could have like a -- she would be able to -- she was overprocessing. She would be able to process and become lucid again. But that this was some type of like a spiritual crises or something. If she could get through, it could be very progressive for her.
And so we couldn't get her to calm down or to sleep. And he told my mom -- he told my mom that if she took Valium she could sleep.
And so my mother had a prescription of Valium that she had gotten from my father, which she gave to me, and in -- we wanted her to take the Valium, and she didn't take the Valium.
And then at one point she became physically violent. And two men who were there, one man restrained her so that she would stop hitting and kicking other people. And the other one basically pilled her like I pill my cat. I just took the Valium and put it right down her throat.
And then -- and she was expressing at the time that she felt hurt, like she was being hurt being held down, didn't want to be held down, and she wasn't liking what was going on. She wasn't -- most of what she was saying was pretty incoherent. That was not incoherent.
And then she slept for a little while, but then was up again. And there was concern that she wouldn't -- we were concerned that she would still be psychotic. So somebody put another Valium in some scrambled eggs and fed them to her for breakfast. And so eventually she did calm down and reset and went back to what would be considered normal.
But my collateral basically was laying all this out that this women had been administered prescription medicine against her will. That it implicated Keith, my mom, my dad, and all the friends who were there in this.
And it was the most damaging thing that I could think of that hurt the most important relationships in my life, and I thought would be the most -- and was true, and that would be the most weighted collateral. And it would hurt me, you know, so I thought it was the most substantial thing that I could come up with was this.
MS. HAJJAR: At any point was that women taken to a hospital?
LAUREN SALZMAN: She was not, no.
MS. HAJJAR: Did she know that she was being administered Valium in the morning?
LAUREN SALZMAN: I don't know. I never told her she was and she and I never discussed it, and no one ever told me she was, so I believe no.
MS. HAJJAR: Was there a concern about taking her to the hospital?
LAUREN SALZMAN: I believe there was a concern that if she went to the hospital, it would make NXIVM look bad. Like somehow we caused her to have that. That we have done that to her somehow.
MS. HAJJAR: You testified you chose this as your collateral because it was particularly damaging to you.
Why? Why was that?
LAUREN SALZMAN: Because it was criminal that I had done. And also because it was -- or that I participated in, and I was complicit, and it implicated the people who the most important to me in the same way.
MS. HAJJAR: And at the time was defendant one of the most important people to you?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did Rosa Laura Junco accept that collateral?
LAUREN SALZMAN: No, she rejected it.
MS. HAJJAR: Did she tell you why?
LAUREN SALZMAN: She told me that she rejected it because it would be a conflict of interest for Keith to release the collateral, because he would be implicated in the collateral.
So if I were ever to leave The Vow, he wouldn't be able to use it, because it would hurt him, so she didn't accept it.
MS. HAJJAR: And at that time, did you believe your collateral would be released if you violated The Vow?
LAUREN SALZMAN: Yes.
And to me that -- that whole thing speaks to if he's planning on releasing the collateral, but this one he couldn't release because it would hurt him, so I would be able to get off the hook. So I needed to submit something that wouldn't hurt him so he would be sure to feel good releasing it, if I ever break my vow.
MS. HAJJAR: Did Rosa Laura suggest something else as collateral?
LAUREN SALZMAN: She suggested naked pictures.
MS. HAJJAR: Did you ask her if she had taken any?
LAUREN SALZMAN: I did.
Because that wouldn't be something I normally would do. And it was just an unusual request and I felt very vulnerable doing something like that. Is that something you had done? Just so I know where it came from.
The only time I had ever done it was when Keith took pictures of me and I was very uncomfortable about that even with him.
So she said, yes, that she had done that. And for me that made a big difference because Rosa Laura was very conservative and came from a very conservative background.
So when she -- if she had done it, then I was like, well, okay, I mean if you've done it, you feel confident.
And I asked her, too, like what's going to happen to the pictures? And she said, Don't worry, they're going to be safe and secure. She was going to keep it in a box safe in her house and nobody was going to ever see it.
And I was like, okay, and so then I did that. I took, I believe, three pictures of myself that I put on a USB drive and I gave them to her.
MS. HAJJAR: After you gave Rosa Laura Junco the drive with the naked photographs, what did you do next, what happened next?
LAUREN SALZMAN: Then once I did that, she told me -- she gave me the DOS pitch. She explained to me the concept of the vow of obedience. That this is a lifetime vow of obedience.
I asked if it was to her, and she told me it was to Keith. And that -- she explained the concept that he would be my master and I would be his slave, and the idea that having a master in your life is to help you learn to become a master in your own life, and that we're all slaves of something. That we serve something in our life.
And we could learn to serve our issues, or we could learn to serve our principles. So that this was about learning to -- how to serve our principles with the highest value.
And she told me that there would be a collar, which initially I did interpret to mean like a BDSM collar. But then she told me that was not what she meant, that she meant a piece of jewelry that I wouldn't take off that symbolized my chain to my master.
And she explained that there would be a brand. And that the brand -- the idea of the brand was to memorialize on our body our promise to ourselves that we made for this lifetime commitment to our growth and to our master.
And this idea that to serve our highest principles ultimately at some point, if you're going to be noble in your life, if you look at people who have been noble in life, like they've gone against tremendous adversity. You know, it's not just everybody that we can say that amazingly noble person, there's just a few people, and most of us know who they are that walk the earth that we look at and pulled out as these respectable people who are upheld, incredible noble principles against adversity.
And they did so in the face of being sometimes murdered or persecuted or these types of things, and that to become that type of a person you have to go through experiences that are difficult or that are painful.
And this is something that we had studied in ESP and something I taught in my curriculum. I was very familiar with the concept. I was very enrolled in that idea of doing hard things to become somebody who could do hard things when it was most important in doing hard things to uphold your most -- your highest ideals.
And that going through the branding was an experience of overcoming pain for this principle. And the principle was this principle of love and of a sense of self.
And I was concerned about the brand, like I -- that was not something that I ever, you know, thought of. But when she gave me that explanation for it, like I don't have any tattoos, it was -- I would never have gotten something like that.
But when she explained it like that, the idea of overcoming pain for a principle was compelling to me.
MS. HAJJAR: You mentioned that you were enrolled in that idea. What does that mean?
LAUREN SALZMAN: Yeah. Yeah, you could say -- or I came to agree with it and support it. And I wanted to go forward with that. So I said, yes.
MS. HAJJAR: Was Rosa Laura branded at the time?
LAUREN SALZMAN: Yes, and she showed me her brand. And she asked me if I knew what it was and I couldn't -- I didn't know what it was and she pointed out it was Keith's initials.
MS. HAJJAR: But when you looked at it at first, you couldn't tell what it was?
LAUREN SALZMAN: Correct.
MS. HAJJAR: At some point later, did Rosa Laura Junco tell you anything about whose idea the brand was?
LAUREN SALZMAN: Yes. I mean I had -- my understanding was that the women had decided that they wanted to be -- some women who were not -- I was never told who the women were, but that the women had decided, like somebody wanted to get a tattoo at some point and then another person said that we should get a brand because even tattoos could be erased or there's some impermanence now. So a brand would be more permanent. And that the women had decided this.
And after Keith was indicted and arrested, arrested and indicted, I said something to Rosa Laura about it, and she said the women didn't choose it, why would we ever choose something like that? Who would choose that? And she basically said, you know, no, Keith wanted us to do it. That's why we did it. None of us would have ever come up with the idea that we would brand ourselves. That's crazy.
MS. HAJJAR: Initially were you told about the existence of other women in DOS aside from this initial group?
LAUREN SALZMAN: I believe I was told there were some but I wasn't told who they were. But not that I was being invited as a founding member, which is different.
MS. HAJJAR: And beyond the naked photographs, did you have to submit additional collateral?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And what kind of things did you submit as collateral?
LAUREN SALZMAN: Basically everything material I owned; my finances, my investment accounts, my two homes, two cars, all my art, anything that I owned. And then I believe I also made commitments that I, you know, would resign from my positions, these types of things. It was -- it was I would give up everything that I held dear to me --
MS. HAJJAR: And did you --
LAUREN SALZMAN: -- in my life.
MS. HAJJAR: -- in a document list all these things?
LAUREN SALZMAN: I did. I believe I sent it in a Telegram initially. Yeah, that's what I believe that.
MS. HAJJAR: Did you, in fact, get branded?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: And how soon after you agreed to join DOS were you branded?
LAUREN SALZMAN: Within like 48 or 72 hours. It was very quick.
MS. HAJJAR: When was your branding ceremony scheduled for?
LAUREN SALZMAN: January 10th, 2017.
MS. HAJJAR: Did it coincide with something in particular?
LAUREN SALZMAN: It was -- it coincided with the first night of Pam's memorial.
MS. HAJJAR: This is Pam Cafritz, the woman to who died a few months prior?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did you have a discussion with the defendant at the memorial service?
LAUREN SALZMAN: I did, yes. Yes.
MS. HAJJAR: Can you explain what happened?
LAUREN SALZMAN: He was asking me about the branding ceremony, like, so tonight is the night we're going to do? And he was like very excited about it.
And he was similarly excited like when he told me he started a sorority, he laughed about it. Like this was some really strange and unusual funny thing or -- but to me it wasn't because everything that we had done in 20 years were all things that Keith had started. So it wasn't a different type of thing in my mind. He started everything. So him started this was not unusual.
And I had been in a sorority in college that was cofounded by a man. So it wasn't like even to me that a man might found a women's organization. But his reaction to it was unusual. Because he wasn't usually emotionally expressive in that way about the different things.
And his enthusiasm and excitement about the brand also stood out, because it was -- like it stood out in contrast to -- we were at some memorial service, it was very somber and sad and serious. So his excitement and enthusiasm especially stood out to me.
MS. HAJJAR: Looking back now, do you see any significance as to the timing of your recruitment into the DOS?
LAUREN SALZMAN: Yes, I do.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: So, yeah, I mean there's a lot of background to it. So it's hard to explain it just concisely, but that -- I mean, Keith and I had a relationship, we had a -- prior to all of this. We had a romantic and sexual relationship for a period of time that tapered off slowly and it stopped at some point in time.
And so for the ten years prior, or almost ten years prior to my being invited into this, we hadn't had any relationship like that. And around -- there were things that happened around 2009, and I think on Friday when I was here I had talked about Barbara Bouchey left at some period of time and I thought it was a little bit later, but 2009 the Dalai Lama dame came to Albany, and Barbara left right at that time, so like around 2009.
And there was a lot of -- like Keith would frequently say that -- and his relationship with Barbara was very involved and very tumultuous in certain ways. And when she left she was very vocal and did a lot of like press. She did interviews about the things going on in ESP but she -- that were concerning to her.
And frequently Keith would say that if we had gotten our act together sooner this never would have happened. And specifically he said my mom was very problematic.
So there were a lot of things that happened that were stressing in the companies and in the community on the heels of this that he frequently would say that we didn't understand how important this stuff was and he told us and we weren't listening.
And so I, coming out of that time period, 2009, and during the time that he and I didn't have a romantic or physical relationship, I was trying to prove myself, you know, and make up for the failures of the past.
And around 2012 he -- somewhere in there he told me that at some point he had decided -- he had made the decision to put our relationship on hold five years prior.
And that was very difficult for me to understand because when he taught us things of having to do with agreements with other people, he always said that if you wanted to change the nature of an agreement with somebody you should go to the person and discuss it with them.
So the fact that he had made the decision to change our relationship five years prior and had never discussed it with me was something that I had never -- I couldn't even understand how that could have been.
And then I was like, well, if he made this decision to put our relationship on hold and I wasn't even aware of it, then I must be doing a very bad job. And so a lot of what I was doing was trying to compensate for these types of things.
And the -- when Barbara left, she was very vocal about feeling that there was nepotism within the high ranks of ESP and that the executive board was primarily made up of women who either were or had been in sexual relationships with Keith, and that this was of specific concern to her.
And that -- about a year before she left, Keith told the executive board that if we didn't get our act together, he was going to basically just fire us all and replace us with a new board.
So I went to Mexico and I started working to build our business in Mexico and every like probably six to eight weeks I was running a course fulfilling these Level 2 intensives, and I did this for a year, year and a half leading up to the Dalai Lama and trying to prove that I could keep my leadership role, was worthy of having this role, was making up for the failures of the past.
So then when it became some of the things -- Barbara's concerns were being expressed vocally among our membership and in the media, Keith fired the entire executive board and replaced it with new business. So lost my position anyways.
Within six months, I was back on the executive board, because nobody in ESP had did my role. And the new business building board had no connection to the product, which was the education or the people, which were our members, and the people who were buying the product. And that I performed a unique function. So then I got back on the executive board.
Fast forward a little bit to 2014. 2013 I wanted to leave the relationship. We weren't having a relationship any more in that way. But I was told I might be able to have it. He asked me if I would stay. He said he would invest in our relationship. If I did stay and we would have children within five years. 2014 he started Ultima, which was a new company, and that new company had a series of companies within it. And he took the ethics curriculum. And I was the head of the ethics board in NXIVM and one of only two people who taught that curriculum as it had existed prior. He took it and put it in the new company, Ultima. And he made Daniella the head, Daniella Padilla, the head of this new ethics curriculum.
So he took the ethics curriculum out of ESP, out of where I taught, and put it in the new thing and now Daniella was the head of it.
So by the time -- so Pam got sick in 2015, and around this time, you know, we took two trips to Fiji and -- because Pam wanted to see Fiji before she died and those trips were very Marianna centric. It was whatever Marianna wanted. The trip centered around Marianna.
And he told me on the trip that he was going -- thinking of having a child with Marianna to balance things out.
And to me this was like completely crazy because so much was centering around Marianna and I didn't understand how given Marianna more was going to balance everything out.
And in those two years that Pam was sick, I found myself very much on the outside. And when he told me Marianna was pregnant, or when he told me Marianna was -- he thinking of having a child with Marianna, on that same trip he asked me to agree to stay with no child and no relationship.
So I have now been 12 years waiting for a relationship and a child that we were -- by the time DOS came that never came. I had been cut out of several leadership roles in the organization. And in the two years Pam was sick, all of a sudden Keith was surrounded by a new group of people and had this new inner circle.
And in January, at New Years, I -- we did this New Year's process where we would get together and share all of our goals, and we did -- like what were the highs and lows of the last year. And I was in a group with Monica, Daniella Padilla and Loreta Garza and I shared that. At some point I -- and I don't know when it happened, all of a sudden I found myself on the outside of my group of friends. That like I don't -- that everything changed and now I wasn't part of the inner group any more.
And there had also been this vacation, this -- in December, so I'm going back -- I'm sort of jumping around a little, just a lot of things happened to inform why I think it's significant.
Keith and Marianna rented a house in Woodstock at Christmas time and they invited a bunch of us to go. And it was the most bizarre trip to me. It was like the coming out in a public forum of Keith and Marianna's relationships.
So it was like Keith and Marianna sharing a bedroom. Her dad was there. Her brother and his wife were there. And a bunch of my girlfriends, me and my mom, and Jim and Esther. It was such a weird group of people. But the whole thing was like Keith and Marianna as a couple, and everybody else there happy about it. But I didn't feel happy about it. And it was confusing to me. And I -- and it was upsetting to me, and I didn't understand it.
And then later -- so then he tells me all of a sudden, after 12 years, all of sudden I want to bring our relationship closer, gets me in a collateralized vow for like committed to growth.
I'm the head of the growth program of ESP, now I'm in a collateralized life vow backing my word for growth, and ten days later he tells me Marianna's pregnant, which he had known for three months.
And so I was -- I was like this -- oh, my God, like there's no way -- like he got me to stay because he thought I would leave if Marianna was pregnant. And he stole from me and himself the ability to know if I would have stayed no matter what without being a hundred percent collateralized vow.
MS. HAJJAR: How did he get you to stay?
LAUREN SALZMAN: By getting me to promise that through a collateralized vow -- my entire life was collateralized in this. And also I was -- I'm the head of the growth program of ESP. I said I would do anything for growth. I'm a hundred percent committed to growth. I collateralized my entire life and now all of a sudden I'm saying I don't want to do this with you because Marianna's pregnant? My life couldn't have existed intact any more. It couldn't -- it couldn't have. I couldn't have maintained the integrity of my whole life if I all sudden gone I don't want to do this.
And I hundred percent think that the timing on it is because of that.
MS. HAJJAR: Any significance to the fact that Rosa Laura Junco was the one that approached you?
LAUREN SALZMAN: Hundred percent significance.
Because when he told me, when we were in Fiji a year prior, and he told me Marianna -- that he was thinking of having a baby with Marianna and I was incredibly upset and distressed over it, I asked -- he told me he didn't want me to speak to my mom about it. And I didn't know who to talk to about it. And he said how about Daniella Padilla? And I did not want to talk Daniella Padilla about it. And he said who do you want to talk? And I said Rosa Laura.
And Rosa Laura was the person who a year earlier reenrolled me in staying in a relationship with him when he was choosing to have a baby with a Marianna and telling me I was going to stay with nothing.
So she had already been the one I wanted to go to, and the one I trusted and the one who had successfully reconvinced me that this was the best path for me because of my growth, because of the opportunity to be able to gain things through having her as my mentor and my teacher, staying in this relationship with him. That I would never be able to have him the whole rest of my life ever if I left.
And so she was hundred percent, I think related to -- a hundred percent related to why she was chosen to be to the one to ask me, and at the time when Marianna actually was pregnant.
MS. HAJJAR: At the time you learned of Marianna's pregnancy, did you question the defendant's motives in enrolling you into DOS?
LAUREN SALZMAN: Yes. And that I couldn't handle it. I was like there's no way he could have done that. And I stuffed it, I compartmentalized it, and hundred percent went full force forward with my conviction that DOS was not bad, that it was a growth program, that it was amazing, that this was for women, and for me to get through my issues, and I just did that.
MS. HAJJAR: You did tie your continued employment, your work with ESP, to staying committed to the defendant?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: Because I gave my word, which is a huge thing in our company, that I would be a hundred percent committed to my growth, and my growth was this collateralized vow of obedience.
So I left it, I would be breaking my word to commit to growth. How could I stay in the position I was in as the head of the growth program that taught the concept of collateral -- of discipline of word, of all these things if I was the person who didn't do it.
MS. HAJJAR: Looking back now, do you see significance about when DOS was created as to -- as related to Pam Cafritz, the woman you were describing earlier?
LAUREN SALZMAN: Yeah, I do.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: Because I think Pam -- Pam facilitated all Keith's objectives, whatever Keith wanted in many of his personal relationships, and especially my relationship with Keith was facilitated by Pam, you know, I -- that she reenrolled me in my relationship with Keith time and time again throughout the duration of my relationship with Keith. And at the time she died, I think she left, from her illness and her subsequent death, left a big hole of people who were that and would do that for him and DOS was doing that.
MR. LESKO: Your Honor, I'm moving to another topic now.
THE COURT: All right. We'll take our lunch break.
All rise for the jury.
(Jury exits the courtroom.)
THE COURT: All right. The witness may stand down.
(Whereupon, the witness steps down.)
THE COURT: Please do not discuss your testimony with anyone.
We'll take an hour for lunch. Thank you.
(Whereupon, a recess was taken at 1:00 p.m.)
(Continued on the next page.)
A F T E R N O O N S E S S I O N
--oo0oo--
THE COURT: Here we go.
All right. How much more do you have on direct of this witness?
MS. HAJJAR: Some time, Your Honor. It would likely be the end of the day.
THE COURT: To the end of the day --
MS. HAJJAR: On direct examination, yes.
THE COURT: -- at least.
MS. HAJJAR: At least.
THE COURT: Okay.
All right. Let's bring in the witness, please.
(The witness resumes the witness stand.)
THE COURT: And let's bring in the jury.
(Pause in proceedings.)
(The Jury enters the courtroom.)
(The Jury present.)
THE COURT: Please be seated, everyone.
All right. Ms. Hajjar, you may continue your examination of the witness.
I remind the witness that she is still under oath.
DIRECT EXAMINATION (CONTINUED) BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, you testified that you did get the brand --
LAUREN SALZMAN: Yes.
MS. HAJJAR: -- that the defendant told you about. When was that?
LAUREN SALZMAN: It was on January 10th, 2017.
MS. HAJJAR: And at that time did you have an opportunity to meet the entire first line that you described earlier?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: Who branded you?
LAUREN SALZMAN: A woman named Danielle.
MS. HAJJAR: Was she a doctor?
LAUREN SALZMAN: Yes.
MS. HAJJAR: At the time, did you have an understanding as to whether Danielle was a member of DOS?
LAUREN SALZMAN: Well, Danielle got excited that I was getting branded and she showed me her brand, so I learned she was a member of DOS.
MS. HAJJAR: Did you later learn something about the fact that she had shown you her brand?
LAUREN SALZMAN: Yeah. She was disciplined for it because it was an indiscretion. She wasn't -- she was supposed to keep it secret.
MS. HAJJAR: Was Danielle, as you understood it, under you in rank in DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: Danielle was enrolled by Allison, so she was second-line DOS and I was first-line DOS. So I was higher rank.
MS. HAJJAR: Can you describe the branding ceremony to the jury?
LAUREN SALZMAN: Sure. So we went to Allison's house. She was out of town, but we did it there. And when I arrived I saw -- this was the first time that I was together with all of the first-line DOS masters. So Rosa Laura told me that the first thing that they did was take a naked picture. So everybody removed their clothes and we took the naked picture. And then she read to me basically the concepts that are in the banding ceremony first, and they're similar concepts to what are also in the book. So basically about you're making the vow of obedience to the master, that you're surrendering your body, your property, all these things, all the concepts that we reviewed earlier and that there were responses that I was to say back. So she would read something to me and I would -- and tell me the response and I would say the response back. So we went through it once before the branding ceremony.
Then Danielle arrived and helped me put a stencil on where the brand would be, which is on the hip like in the bikini line, and then we went into a room where there was a massage table, and first I knelt down and there's a line that you read that she instructed me to read and that she instruct everybody who is getting branded to read, Master please brand me. It would be an honor, an honor that I want to wear for the first of my life. So that's how it starts. And then you get up and lay on the table, and my arms were held above my head. Then I had like all my circle around me, holding my legs and touching different parts of my body. I was clothed because I was above Danielle in rank, but normally everybody would be nude.
MS. HAJJAR: And the words you were -- the words you said, Master, please brand me. It would be an honor. Was that part of a script that was shown to you at that time?
LAUREN SALZMAN: Yes, it was. Yes.
MS. HAJJAR: Did the branding itself hurt?
LAUREN SALZMAN: Yeah, it was really painful.
MS. HAJJAR: Can be describe what it is exactly?
LAUREN SALZMAN: What it is? It's an -- it's electricity, but it's like a pen. It cauterizes the skin. So basically it -- it makes -- it does like a third-degree burn, so it creates a scar, ultimately creates a scar. Immediately it just burns the skin in a line. Once it goes across, the skin is dead so you don't feel it afterwards. It's only when it's making the line that it hurts, but it's incredibly painful. It's the most painful thing I've ever experienced.
MS. HAJJAR: Does it look -- in the branding ceremony does it feel like a burn; does it look like a burn?
LAUREN SALZMAN: It looks like a third-degree burn after you get it, yeah. I mean, it's -- it's raw skin that then becomes scabbed over and the scab falls off and then it scars. But it -- it's electricity so it shocks the skin as it goes across and it -- it feels -- it feels like what it is. It hurts a lot.
MS. HAJJAR: How long did the branding take?
LAUREN SALZMAN: It took -- it was -- the actual branding of the burning of the skin only took a few minutes, but the whole process took about like half an hour, 45 minutes to go through the -- the actual branding plus the script, the reading back and forth.
MS. HAJJAR: Was it videotaped?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Who videotaped it?
LAUREN SALZMAN: Loreta.
MS. HAJJAR: And after you were branded, did you then regularly meet with that first line?
LAUREN SALZMAN: Yes.
MS. HAJJAR: After you were branded, did you have a conversation with Allison Mack about having joined DOS?
LAUREN SALZMAN: Yes, I did. Yes.
MS. HAJJAR: What was that discussion?
LAUREN SALZMAN: Allison was very excited that I joined, and she -- she felt, like, excited to share everything that she had never been able to share that came with DOS. And her experience with DOS was a little bit different than mine, but what -- what she shared with me is that she never had a relationship with Keith until she joined DOS. So when Daniella enrolled her into DOS, she enrolled her also into a relationship with Keith or it happened contemporaneously, as I understood it. So Allison didn't really understand and I have never discussed with her what my relationship with Keith was, so she was very excited and enthusiastically -- like, Isn't this great? Like now not only do you have this master, but you have, you know, all these new sister wives and she was like so excited about that. And I was like, Number 1, I've had sister wives for 20 years; Number 2, this is not -- it's something that's -- it's been something that's been incredibly difficult for me, and then I'm -- I didn't know about some of these relationships, including Allison's, which I just learned about then.
So for me, it wasn't as exciting as it was for her. But she was -- I didn't share that with her because I didn't want her to not be enthusiastic or feel happy about her experience and I didn't want her to feel like she couldn't share things with me. But for me, it was really hard.
MS. HAJJAR: Did she mention children in this conversation?
LAUREN SALZMAN: I'm not sure if it was this conversations or after, but she was like, yeah, we're going to raise our babies together and we're going to do all these things. And I came to learn that she believed she was having children with Keith, Daniella also now is believing she was having children with Keith and for me, this was just a lot to learn.
MS. HAJJAR: And when you say, Daniella, this is Daniella Padilla?
LAUREN SALZMAN: Correct.
MS. HAJJAR: Did you have a subsequent conversation with Daniella Padilla?
LAUREN SALZMAN: Yes. Well, I went to Keith and was like, You're having babies with Allison and Daniella and he said no, not necessarily, you know, that's not -- and actually he acted like he didn't know really quite where they got that idea. And then I had a subsequent conversation with Daniella where Daniella was describing that she and Keith had discussed how they were going go about doing this because they were going to -- Daniella was going go to Marianna and ask Marianna for permission for Keith to be the donor. So to make it like to Marianna that it wasn't a relationship, that he was just going to be the donor. So then I went back to Keith and was like, we have to ask Marianna for her permission to have kids, to have you be the donor? And so then he acknowledged that he had had that conversation with Daniella which negated the first conversation where he said he wasn't discussing having children with them, and then didn't seem to understand why it would be a problem for me to ask Marianna this, why, you know, if he could be the donor.
MS. HAJJAR: Did you have discussions about recruitment of other slaves in these meeting with the DOS first line?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And you testified that you recruited slaves?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Who did you discuss potential recruits with?
LAUREN SALZMAN: With the first line and with Keith.
MS. HAJJAR: Were any prospects rejected?
LAUREN SALZMAN: Some.
MS. HAJJAR: Can you give us some examples?
LAUREN SALZMAN: Audrey wanted to enroll Siobhan and I discussed it with Keith, and he said he wasn't sure that that was a good idea. Clare's name was raised a bunch and he wanted to keep that separate.
MS. HAJJAR: Clare Bronfman?
LAUREN SALZMAN: Yes.
Christina was another one he was thinking about if it was a good idea. I mean, these are ones that came up directly with me. I'm sure there are others, but these are ones that either myself or people who I enrolled wanted to enroll.
MS. HAJJAR: Who had the final say about who could be enrolled and who couldn't?
LAUREN SALZMAN: Keith.
MS. HAJJAR: Did the defendant ever ask you for photographs of potential recruits?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did the defendant say anything about the marital status of the person that you should recruit for DOS?
LAUREN SALZMAN: Not that I should, but that he said initially it was going to be sorority for only people who were not married. And then eventually they decided or at some point they had decided to let in people who were married.
MS. HAJJAR: And when you recruited your DOS slaves, did you lie to them about the defendant's role in DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And what about the brand?
LAUREN SALZMAN: Yes. Well, I didn't tell them anything about the brand. They asked what it was, and I said it was a symbol, you know, and then during the branding ceremony, Carola saw the stencil and was like, KR, like she knew. She realized that it was Keith's initials, and I asked her to please not share that with other people.
MS. HAJJAR: Who did you recruit first?
LAUREN SALZMAN: Sarah.
MS. HAJJAR: And where did you initially approach Sarah about enrollment into DOS?
LAUREN SALZMAN: I approached her in Vancouver. I was staying in her home there.
MS. HAJJAR: Why were you in Vancouver at that time?
LAUREN SALZMAN: I was teaching intensive in her center.
MS. HAJJAR: About how soon after your enrollment into DOS were you recruiting Sarah?
LAUREN SALZMAN: Five days.
MS. HAJJAR: Was Sarah married?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And can you describe to the jury what the process was for recruiting her?
LAUREN SALZMAN: Sure. It was -- it was the same process that Rosa Laura did with me, that I approached her and told her that I was doing something I was very excited about. I wanted to share it with her. And that this might sound weird, but I needed a guarantee from her that she wasn't going to speak about this to anybody else, and I introduced the concept of collateral, which she provided me. And then when she provided it, I went through the four aspects of it, lifetime vow of obedience to me; master/slave concept; collar, which was the necklace; and branding, and she decided she wanted to go forward and provided more collateral.
MS. HAJJAR: Did you characterize DOS as a sorority for women?
LAUREN SALZMAN: I did, as a sorority for women.
MS. HAJJAR: What was the first piece of collateral that Sarah gave to you?
LAUREN SALZMAN: She gave me like a confession that she had written on a piece of paper basically confessing to things that would be embarrassing for her reputation if they were to be disclosed, things along the lines of sexual experiences or substance use.
MS. HAJJAR: What did you do after Sarah gave you that collateral?
LAUREN SALZMAN: I checked it with Rosa Laura.
MS. HAJJAR: What happened?
LAUREN SALZMAN: Rosa Laura didn't think it was strong enough and suggested naked pictures as well.
MS. HAJJAR: So what did you do after that?
LAUREN SALZMAN: I went back to Sarah and told her about the naked pictures and she agreed to take them, and we took them together, meaning I was with her in the room when she took a naked picture of herself. And Rosa Laura then said that I could go forward after that.
MS. HAJJAR: Did you tell her anything about whether you had taken similar photographs?
LAUREN SALZMAN: I did. I told her I had done it as well.
MS. HAJJAR: Did Sarah express any reservations about the branding?
LAUREN SALZMAN: Yes. Very similar to mine, that she had shared as well she had never gotten a tattoo and she had certain views about her body and caring for her body, and this kind of went against that. But I -- re-enrolled her in the idea that I shared with her the idea of paying for a principle and the memorializing your promise, and the -- the, you know, on your body forever was a promise forever. And so she agreed to do it.
MS. HAJJAR: When you say reenrolled her in that idea, you persuaded her to go along with it?
LAUREN SALZMAN: Yeah.
MS. HAJJAR: Did Sarah then agree to join DOS?
LAUREN SALZMAN: She did.
MS. HAJJAR: Did she provide additional collateral to you?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What different collateral did she give you?
LAUREN SALZMAN: We filmed a bunch of videos together, that the idea of them was to make it look like it is candid, like she didn't know that she was being recorded. But she was speaking negatively about family members, like, you know, saying things like that she only had a relationship with them to get her inheritance or that her husband, you know, was abusing her and her son. False statements, but that would have damaged those relationships were they to be released and also would damage the people in the video saying things about them that would have hurt their reputations.
MS. HAJJAR: Why was it made to look candid?
LAUREN SALZMAN: Just because if it were to ever be released, it wouldn't be believable that somebody would have just looked at a camera and made a video of themselves doing that, but it was more believable that she could have just shared it with a friend who happened to be recording it unbeknownst to her.
MS. HAJJAR: Did she give the videos to you?
LAUREN SALZMAN: I filmed them on my phone, so they were always in my possession.
MS. HAJJAR: Were these videos sufficient collateral?
MS. HAJJAR: Why not?
LAUREN SALZMAN: Because she had to fully collateralize all of the areas of her life to be considered fully in. So she never, in theory, completed the enrollment process.
MS. HAJJAR: Did the defendant discuss your recruitment of Sarah with you?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What did he say?
LAUREN SALZMAN: Oh, when I came back he was excited that I had enrolled someone, and he said, like, she's your slave now. And I said yes. And he said that means like -- and he had told me that before -- that that meant that she had to choose that relationship above all the other relationships in her life, like above her husband, above her child, and I had even discussed that with her. But I came back and he said that means if you tell her she has to have sex with another man, meaning another man not her husband, she had to do that. And if you tell her she has to have another man's child, that means she has to do that. And at the time I was like, yeah, I get it. Like you just need her really committed. She's committed. That was how I viewed it, but it doesn't look the same right now.
MS. HAJJAR: How do you feel now about it?
LAUREN SALZMAN: Well, I don't -- like why would that be the thing that would indicate commitment as opposed to anything else? Like if you told her she had to walk across hot coals, you know, she would have to do it. Like why sleeping with somebody or having their children, and given the fact that later I came to find out he was having sexual relationships with other people's slaves and some of those slaves were being -- that was planned before he met them or anything that they wanted to do. It was like known to other people that it was going to go in that direction and also that he was discussing having children with slaves, and it just was different. It looks different, like, given their assignments to seduce him and all of these things that came out later that I found out later, it looks different knowing all of those things.
MS. HAJJAR: You said that you also recruited Audrey?
LAUREN SALZMAN: I did.
MS. HAJJAR: How soon after Sarah was recruited did you recruit Audrey?
LAUREN SALZMAN: Like three weeks.
MS. HAJJAR: Where did you first approach Audrey?
LAUREN SALZMAN: Audrey was in Albany taking a course and she came to me and told me that she felt like she was losing her belief in herself to be able to grow and get through her issues and could I help her. And so I asked her -- I -- this was how I decided to help her. I offered her this option.
So I went through the same process.
MS. HAJJAR: Can you -- can you describe your rank in ESP and your role in ESP as it related to Sarah and Audrey?
LAUREN SALZMAN: Sarah and I were the same rank but I had more stripes so I was a higher rank in the same sash level. But Sarah was a green, I was a green. Audrey was a coach, so she was two ranks below and I was her center head as well.
MS. HAJJAR: What does that mean?
LAUREN SALZMAN: I was co-head of the San Francisco ESP center, so she was a coach in my center.
MS. HAJJAR: And did Audrey -- what happened after you approached Audrey? What did she do?
LAUREN SALZMAN: Audrey submitted naked pictures as her collateral and additional collateral as well.
MS. HAJJAR: Can you describe generally the additional collateral she provided?
LAUREN SALZMAN: Initially she provided a letter accusing a past relationship -- former relationship, a former romantic partner of violence, domestic violence basically and it was untrue but wrote it in a way that would have gotten him or could have -- most likely gotten him fired from his job which was a very good job. And then additionally she provided -- we filmed a number of videos similar to Sarah's videos where she told various stories that would discredit people who were important to her of alleged affairs that she had had with coworkers who were married saying that that's how she achieved the level of position in the company she was working. Things that would have been embarrassing or humiliating to other former boyfriends and also that she was -- she worked in a humanitarian organization and that basically saying that she was posing as a humanitarian to try to scam people out of money.
MS. HAJJAR: And before --
LAUREN SALZMAN: And then afterwards, too, Audrey provided a bunch of assets. She promised her car and she provided bank account information as well, investment accounts.
MS. HAJJAR: And before Audrey provided all this collateral did you lie about the defendant's role in DOS?
LAUREN SALZMAN: I would tell -- yes.
MS. HAJJAR: Did you give Audrey the impression that this was a women's group?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Were you at any point told you needed to enter into a contract with your both DOS slaves?
LAUREN SALZMAN: Yes. But -- at one meeting -- one DOS meeting right before I enrolled Audrey, Keith asked why the contracts weren't being used so I didn't know that there were contracts, so I came to learn that there was a contract and Rosa Laura said she had been trying to work on it with an attorney but it wasn't finalized.
So then my -- but my understanding was he wanted us to be using the contract. So with Audrey I used the contract but then later we were told we shouldn't use it until it was finalized. So Audrey and I did sign a contract but I don't think it's -- I don't know. Whatever stage it was in, we did -- she did fill out a contract.
MS. HAJJAR: Did you present her with a contract?
LAUREN SALZMAN: I did, yeah.
MS. HAJJAR: Okay.
LAUREN SALZMAN: Yeah.
MS. HAJJAR: Your Honor, may I approach the witness?
THE COURT: Yes, you may.
Does the defense have one.
MS. HAJJAR: They have each of the exhibits, yes.
THE COURT: I'm sorry.
MS. HAJJAR: Yes, they have each of the exhibits in this binder.
THE COURT: Okay. Thank you.
MS. HAJJAR: Ms. Salzman, I just handed you a binder. Can you flip to what has been marked for identification as Government's Exhibit 356 and 356R.
LAUREN SALZMAN: Yes.
MS. HAJJAR: Do you recognize this exhibit?
LAUREN SALZMAN: Yes. This is a contract with me and Audrey.
MS. HAJJAR: And is Government's Exhibit 356R a redacted version of Government's Exhibit 356?
LAUREN SALZMAN: It is, yes.
MS. HAJJAR: Your Honor, the Government offers Government's Exhibit 356 both --
MR. AGNIFILO: No objection.
MS. HAJJAR: -- 356 and 356R.
MR. AGNIFILO: No objection to either one.
THE COURT: All right. 356 and 356R are received in evidence.
(Government's Exhibit Numbers 356 and 356R so marked and received in evidence.)
MS. HAJJAR: Thank you, Your Honor. May I publish it?
THE COURT: Yes, you may.
MS. HAJJAR: This is Government's Exhibit --
Thank you, Your Honor.
THE COURT: Sure.
MS. HAJJAR: Ms. Salzman, I'm showing you Government's Exhibit 356R. And can you explain what this exhibit is, what this agreement is.
LAUREN SALZMAN: So there are different parts of the agreement. As I understood it, one part of the agreement is a nondisclosure agreement saying that -- and -- and saying that if Audrey speaks anything about this to anybody she owes me $1 million in damages, and then there's also that she was rightfully transferring her property to me so -- and gave me the right to release her collateral publicly. And a waiver that if she's damaged at all during the process of her participation in DOS for through her participation in DOS, that I have no liability, and then was also some noncompete part of it that I don't understand exactly what that is, but if she had learned any material or secrets or valuable information in the process of DOS that she wouldn't use that to earn an income or benefit herself.
MS. HAJJAR: And what is the date of this agreement?
LAUREN SALZMAN: February 10, 2017.
MS. HAJJAR: So turning to page, numbered Page 7.
Is that your signature?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Is that Audrey's signature?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And this paper that's titled nondisclosure/noncompete agreement, is that -- is that you and your address and Audrey?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And this page, that says assignment and transfer agreements --
THE COURT: You have to just push it down.
MS. HAJJAR: Okay.
THE COURT: Well.
MS. HAJJAR: It gets cut off, Your Honor, in the copy.
THE COURT: All right.
MS. HAJJAR: What is the date of that agreement?
LAUREN SALZMAN: February 10, 2017.
MS. HAJJAR: Turning to the last page, whose signatures do you see there?
LAUREN SALZMAN: Mine and Audrey's.
MS. HAJJAR: And under Exhibit 1A, can you read some of the things that are listed under Exhibit A property?
LAUREN SALZMAN: Sure. 2017 Toyota, a Prius, all assets in Wells Fargo checking, all assets in Wells Fargo savings, all assets in Capital One account. There are three Vanguard Roth IRA accounts that she transferred and personal home furnishes.
MS. HAJJAR: And your understanding of this contract was an assignment of this property to you in the context of DOS?
LAUREN SALZMAN: Correct.
THE COURT: Where did you receive this contract?
LAUREN SALZMAN: From Rosa Laura.
THE COURT: Rosa Laura.
LAUREN SALZMAN: Uh-huh.
MS. HAJJAR: At one point, Ms. Salzman, did you give instructions to Audrey about assigning one of these accounts to another of your DOS slaves?
LAUREN SALZMAN: I did. I didn't want to personally take position of her property because I thought that it was a conflict of interest and I didn't want her to think that I had made a lifetime commitment to her to get anything, so I asked Charmel to hold it but essentially it's the same thing because Charmel is a collateralized slave under me so in essence if I wanted to take the property I could have taken the property.
MS. HAJJAR: Can you flip to what's been marked for identification as Government's Exhibit 414 and 414R?
LAUREN SALZMAN: (Witness complies.)
MS. HAJJAR: Do you recognize these exhibits?
LAUREN SALZMAN: Yes. This is the paperwork to add Charmel as a signer on Audrey's Vanguard account.
MS. HAJJAR: Your Honor, the Government offers both of those Exhibits, Government's Exhibit 414 and 414R into evidence.
MR. AGNIFILO: No objection.
THE COURT: All right. Government's Exhibits 414 and 414R are received in evidence.
(Government's Exhibit Numbers 414 and 414R so marked and received in evidence.)
MS. HAJJAR: May I publish it, Your Honor.
THE COURT: Yes, you may.
MS. HAJJAR: Showing you, Ms. Salzman, what's in evidence as Government's Exhibit 414R. Is this the authorization you were referring to?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And did this have the effect of adding a signatory to this account?
LAUREN SALZMAN: Yes, that's my understanding.
MS. HAJJAR: Were you a witness to this?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And what's here under aged acknowledgment?
LAUREN SALZMAN: That's --
MS. HAJJAR: Is that --
LAUREN SALZMAN: Charmel.
MS. HAJJAR: You said, Ms. Salzman, that you also recruited Jimena and Carola into DOS.
LAUREN SALZMAN: Yes.
MS. HAJJAR: How did that happen, can you explain that process?
LAUREN SALZMAN: Jimena and Carola were in Mexico, so I did the same process with them that I did with the others just over Skype, so over video conference. Exactly the same way, I told them that there was something I wanted to tell them. I asked for collateral to keep the secret, they provided the collateral, and then I shared the for four elements of enrollment and they decided to join and submitted further collateral.
MS. HAJJAR: And what did they give you as collateral?
LAUREN SALZMAN: One of them gave me a video speaking about a family member having an addiction problem that would have been very damaging, hurtful to the family, the whole family.
Another one gave a video of an alleged affair that they had had on their spouse. And then later they gave additional collateral. I think one gave naked pictures, another one signed over part of their business to me if they were to default on their agreement. There were other things, I can't recall what those were among them.
MS. HAJJAR: How did they give these items to you?
LAUREN SALZMAN: Some they gave in person some they gave over Telegram.
MS. HAJJAR: Did you send those further along, did you send those on?
LAUREN SALZMAN: No, I held on to them.
MS. HAJJAR: Did you check the sufficiency of the collateral with anyone?
LAUREN SALZMAN: No. I asked -- you know what, at least one of two or them were in Spanish and so I asked Loreta if she would evaluate it for the weight and like to see if it was sufficiently meaningful that it would secure the agreement. And it was Loreta's sister so she -- I felt she would know so I sent it to Loreta to check.
MS. HAJJAR: Who else did you recruit into DOS?
LAUREN SALZMAN: Amanda and Charmel.
MS. HAJJAR: And who is Amanda, what was her background?
LAUREN SALZMAN: Amanda's an attorney in California. I don't know as much about her background but...
MS. HAJJAR: Did she provide collateral to you?
LAUREN SALZMAN: She provided collateral to me, yes. She was also a coach in my center in San Francisco as well.
MS. HAJJAR: What kind of collateral did she provide you?
LAUREN SALZMAN: She provided an account of alleged abuse in her family and then additionally sexually explicit photographs, a video accusing her partner of abuse and that could have gotten -- I think something that could have gotten him fired from his job and as well as something -- when later that could have gotten her disbarred.
MS. HAJJAR: Were you under particular pressure to recruit Amanda?
LAUREN SALZMAN: Well, I had scheduled the branding ceremony for the first four that I had enrolled, so I wanted to give Amanda the opportunity to be part of that. So I enrolled Amanda in an expedited fashion to try to get her to be part of that and she wanted to and so her enrollment was similar to mine, it took place in like 2 or 3 days from enrollment to branding.
MS. HAJJAR: And for each of these DOS slaves that you recruited did you conceal the defendant's role in DOS?
LAUREN SALZMAN: Yes, all of them.
MS. HAJJAR: Did your slaves --
THE COURT: Excuse me. What did you do with all this paperwork when you received it?
LAUREN SALZMAN: I kept it for a period of time and then -- but the -- the intent was that it would be held by someone who was in charge of securing the collateral, which was Rosa Laura, so eventually I transferred most of it to Rosa Laura either in person or on a locked hard drive and then at one point my hard drive was given back to me and the last I saw it was in Mexico. I had it last in Mexico with -- after Keith was arrested and then I came back to the States without it.
THE COURT: How did you end up having a hard copy of it on paper?
LAUREN SALZMAN: Went to Rosa Laura.
THE COURT: And to your knowledge where did she keep it?
LAUREN SALZMAN: In her safe, but then I don't know what she did with it after that.
THE COURT: The safe --
LAUREN SALZMAN: In her home.
THE COURT: -- in Albany?
LAUREN SALZMAN: Yes, in Albany was, understanding, but then at some point she left Albany, went back to Mexico, so I don't know if she took it with her or where it ended up.
THE COURT: Go ahead.
LAUREN SALZMAN: I think the intent was that it would be secure so that nobody would know where it was, so that it wouldn't be released.
THE COURT: Or who had it?
LAUREN SALZMAN: Correct.
THE COURT: Go ahead.
MS. HAJJAR: Thank you, Your Honor.
MS. HAJJAR: Ms. Salzman, did your slaves recruit their own slaves?
LAUREN SALZMAN: They did, yes.
MS. HAJJAR: And did they provide -- did their recruits provide collateral to them which was shown you?
LAUREN SALZMAN: Yes. Given to me ultimately.
MS. HAJJAR: Did Audrey recruit a slave?
LAUREN SALZMAN: She did, yes.
MS. HAJJAR: And did any DOS slaves express concerns about the collateral they submitted?
LAUREN SALZMAN: Yes. Her -- yes, in particular the slaves that she enrolled did.
MS. HAJJAR: Can you explain that further?
LAUREN SALZMAN: She submitted something that she felt went against something that she believed in, so she wanted to get it back. And she specifically said I would like to -- please don't turn it t in, I do want to have it back. There were other -- I mean, Amanda enrolled somebody, too, who submitted something and she afterwards was very upset that she had submitted it and really struggled with that.
MS. HAJJAR: Ms. Salzman, did you ever review a spreadsheet in connection with DOS enrollment?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Who prepared it?
LAUREN SALZMAN: Rosa Laura kept track of the -- the enrollment and at some point in time Loreta helped put it in Excel for us.
MS. HAJJAR: Where did you see it?
LAUREN SALZMAN: I saw it in the -- we shared a DropBox folder, so it was in an Excel Spreadsheet in the DropBox folder.
MS. HAJJAR: Can you look at what's marked for identification in your binder as Government's Exhibit 357 and 357R, and 358.
LAUREN SALZMAN: (Witness complies.)
MS. HAJJAR: Do you recognize this exhibit?
LAUREN SALZMAN: Yes. This is -- it's an Excel Spreadsheet that has a list of everybody who was enrolled at the time it was made.
MS. HAJJAR: And is Government's Exhibit 357R a redacted version of Government's Exhibit 357?
LAUREN SALZMAN: Yes.
MS. HAJJAR: I offer them, Your Honor, Government's Exhibit 357, 357R and 358.
MR. AGNIFILO: Can we have just one second, Judge.
THE COURT: 357 -- yes, I will.
But 357 and 307R.
MS. HAJJAR: And 358.
THE COURT: Okay.
(Pause in proceedings.)
LAUREN SALZMAN: I don't see 358.
THE COURT: There --
MS. HAJJAR: May I show something to the witness for identification only, Your Honor?
THE COURT: Go ahead, yes. Go ahead.
MS. HAJJAR: Thank you, Your Honor.
MS. HAJJAR: Do recognize this exhibit?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What is it?
LAUREN SALZMAN: It's a list of the first-line DOS masters and how many enrollments they had in each line below them that we used for readiness drills.
THE COURT: L1 is your line? Could you put that back.
MS. HAJJAR: Yes, of course.
LAUREN SALZMAN: Yes, L1 is my line. L1 is all the --
THE COURT: It's the master.
LAUREN SALZMAN: The masters yes.
THE COURT: On your level.
LAUREN SALZMAN: Correct.
THE COURT: Is there an objection?
MR. AGNIFILO: I don't know that we have the exact one that the Government's offering.
THE COURT: Well, here, wait.
(Pause in proceedings.)
MR. AGNIFILO: No objection.
THE COURT: All right. Government's Exhibits 357, 357R and 358 are received in evidence.
(Government's Exhibit Numbers 357, 357R and 358 so marked and received in evidence.)
MS. HAJJAR: Thank you, Your Honor. May I publish them?
THE COURT: Yes, you may.
MS. HAJJAR: So showing you, Ms. Salzman, what's in evidence as 357R.
So this is one of the charts you reviewed?
LAUREN SALZMAN: Correct.
MS. HAJJAR: Past enrollment?
LAUREN SALZMAN: Correct.
MS. HAJJAR: Okay. And does this -- does this spreadsheet reflect some of the participants in DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And can you just -- can you explain what these columns are starting with first that column that says, First?
LAUREN SALZMAN: Sure. First it shows that it's the first line, so it lists the first-line masters, Cami, Dani, Nicky, Loreta. And then on the subsequent pages are the rest of the first line. Rosa Laura, Monica, Allison, and myself.
(Continued on the next page.)
BY MS. HAJJAR:
MS. HAJJAR: And each of the names you read are the names of the first line DOS masters that we discussed before?
LAUREN SALZMAN: That's correct.
MS. HAJJAR: So, Cami in that column refers to Camila and Dani refers to?
LAUREN SALZMAN: Daniella Padilla.
MS. HAJJAR: Can you explain what this ID number column reflects, this one here?
LAUREN SALZMAN: ID number is the, in theory, it's the number of -- it's the order that they were enrolled. I was grandfathered in as number 8 so it's not completely in the order but I believe other than myself it's in order of the order of enrollment.
MS. HAJJAR: So, Camila has -- the number next to her is 1.
LAUREN SALZMAN: Yes.
MS. HAJJAR: And then Rosa Laura is 5?
LAUREN SALZMAN: Correct.
MS. HAJJAR: And you're 8?
LAUREN SALZMAN: Correct.
MS. HAJJAR: And does this reflect the slaves that are under you in DOS?
LAUREN SALZMAN: Yes, it does.
MS. HAJJAR: And which column is that in?
LAUREN SALZMAN: The slaves that are under me are the column listed -- titled Second.
MS. HAJJAR: What about the numbers in red that are at the top of the column, the 8, 38, 43, 13, what does that reflect?
LAUREN SALZMAN: It reflects the number of people who are enrolled in that line at that time.
MS. HAJJAR: Can you explain that; so, what does the 8 signify?
LAUREN SALZMAN: The eight of us first line and then 38 shows that we have collectively enrolled 38 people under us, and those 38 people in the next column had enrolled 43 people under them, and those 43 people had collectively enrolled 13 people under them in the column labeled Fourth.
MS. HAJJAR: So, at the time this spreadsheet was prepared what is the total number that the spreadsheet reflects?
LAUREN SALZMAN: 102.
MS. HAJJAR: The dates on the far left side, what do those dates reflect?
LAUREN SALZMAN: The date that the person was enrolled into DOS.
MS. HAJJAR: And so, looking at the names below you for Sarah and Jimena, do those roughly correspond to the dates in which Sarah and Jimena were recruited into DOS?
LAUREN SALZMAN: Sarah's column is blank but next to her name on the right is the date that she was enrolled.
MS. HAJJAR: Right here, right next to her name?
LAUREN SALZMAN: Oh, yes, correct, and Jimena as well and, yes, that's roughly the date they were enrolled.
MS. HAJJAR: What does the yellow highlighting mean, the asterisk at the top that says two asterisks means second payment is not complete?
LAUREN SALZMAN: It means they're not fully collateralized.
MS. HAJJAR: What does that refer to, second payment?
LAUREN SALZMAN: It refers to the collateral, that they haven't given the second collateral. So, they gave the first collateral for secrecy but not fully collateralized in the vow.
MS. HAJJAR: And is it right that Camila has only one slave under her?
LAUREN SALZMAN: Yes.
MS. HAJJAR: According to this spreadsheet?
LAUREN SALZMAN: Yes.
MS. HAJJAR: I'm going to show you what's in evidence as Government Exhibit 358.
Can you explain what this spreadsheet reflects?
LAUREN SALZMAN: Yes, this spreadsheet reflects the number of individuals in readiness, in the readiness drill. On the left it says M's readiness, these are the people who are in the formal readiness that was run by Keith. Our readiness reflected the people who were in our readiness. So, when we ran our drills we had additional people who were not formally in Keith's readiness because we were preparing them to be part of the formal readiness so the numbers sometimes were different.
MS. HAJJAR: Can you break this down a little bit?
LAUREN SALZMAN: Sure.
MS. HAJJAR: What does it mean that there are different numbers listed in M readiness versus R readiness and what do the numbers and letters mean here?
LAUREN SALZMAN: So, when there was readiness each line was required to check in. So, Keith would initiate readiness with a question mark and the first line, what we would respond, RM, ready master. So, he would list it with a question mark, we would respond RM. When the entire first line had checked in, there were eight of us in total in that line, so it was eight ready. Okay. So, in each line there was a number of people who were enrolled in that line and then there's how many are ready at the time that the readiness drill is elicited, right, so -- or initiated.
So, Cami when she would -- she'd check in, if you see here it says 2R 1M, it is line 2, 2 ready, 1 slave checking in master.
So, then if you go down, I drew over it, but if you look at Loreta's it says 2R8M, that means second line ready eight slaves master, eight slaves are ready in the second line. So, each of us was accountable for each of our lines. So, Cami only had one line so she would check in the second line just one person. Daniella had two lines so she would check in the second line five are ready, the third line looks like six are ready and subsequently.
So, I checked in second line six were ready, third line seven ready, fourth line two ready, that's how many I should be checking in on each readiness drill.
MS. HAJJAR: And the chart on the right, on the top right, do these reflect the total numbers attributable to each of the DOS masters?
LAUREN SALZMAN: At that time, yes.
MS. HAJJAR: How many slaves do you have at that time?
LAUREN SALZMAN: I had five. Oh, wait, I had six.
MS. HAJJAR: And what about their -- what about the total number under you?
LAUREN SALZMAN: Six plus nine, 15 at that time.
MS. HAJJAR: Sorry, Ms. Salzman, is there a 6 -- does L3 refer to the slaves under them, if I zoom in on this?
LAUREN SALZMAN: Oh, I see, the total; so, at this time -- oh, it's funny, okay, sorry. I was looking on the left and counting. Based on this column on the right it looks like I have 22 in my group and then -- 22 total in my group under me.
MS. HAJJAR: How many does Cami have in contrast?
LAUREN SALZMAN: Cami had herself and one, I had 21 plus myself.
MS. HAJJAR: So, although you were the last to join the first line, your -- the slaves -- you had the most slaves under you at this particular time?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Right?
LAUREN SALZMAN: I did.
MS. HAJJAR: Can you explain why that was?
LAUREN SALZMAN: I think some of it was the way that I was enrolled in such a quick amount of time, I had that was my understanding of how the process worked and how easy the process could be. I had the least experience and the least objections at the time so I was the most enthusiastic when -- at that time when Keith started pushing readiness and I think I have good capacity to enroll other people in my ideas. So, all of that kind of worked in my favor to be able to get a lot of people quickly.
MS. HAJJAR: What about in contrast, Camila or Nicki, can you describe their enrollment efforts?
LAUREN SALZMAN: I think they're different for each person. Cami was not very public in the community much at all and didn't have a lot of relationships, so when you're talking about going out and enrolling people that you're close with, she didn't have that many people that she was close with. Also, she wasn't in a leadership role or a coaching role or any of those things so I don't know that a lot of people would have looked -- and she was younger, I don't know that a lot of people would have looked to her for somebody who they felt could help them the most with their growth for their life.
And I'm not sure if that's the same exactly for Nicki but Nicki wasn't as high in the organization -- in ESP as me but generally my enrollment skills were better and I was more enthusiastic about bringing more people.
MS. HAJJAR: When you say growth in this context, do you include as part of advancing within ESP?
LAUREN SALZMAN: Well, your -- enrollment in your growth and your capacity to enroll others in your ideas usually was reflective in how far you were in ESP. So, there's growth -- there's your growth and how that relates to your promotions in ESP but particularly with the vow, it was a lifetime commitment of a vow of obedience for the purpose of growth.
So, if Cami was going to enroll somebody and say I'd like to be your master and help you with your growth, I don't know that people would have seen her as being the person who would be in that role or that they would look to and respect to help them with that because she hadn't demonstrated that she had that capacity.
MS. HAJJAR: At some point did you have your DOS slaves branded?
LAUREN SALZMAN: Yes, the five of them.
MS. HAJJAR: And can you describe their branding ceremony?
LAUREN SALZMAN: Yes. They had not known about each other. They knew there were other slaves but they didn't know who the other slaves were so I wanted to do an initiation ceremony for them where they met each other and learned who their sisters were in their circle.
So, I did that first, I invited them to my home and I had told -- Rosa Laura told me when I joined the sorority that there would be nudity as part of the sorority and I knew that in advance and I had told them that as well. So, they came to my house, I asked them to come in staggered times so they wouldn't know who each other were and I put them in different rooms of my house and I asked them to remove their clothes and blindfold themselves and then I led them downstairs to my living room where they sat in a circle and then they were able to take off the blindfold and see each other, who each another were, and I did a candle lighting ceremony with them, you know, to initiate them into their circle.
Then they got dressed. We all had dinner and we went over to Allison's house to do the branding. They took about an hour putting on their stencils, figuring out where they wanted the brands, etc., and then we went from there and their branding ceremony was similar to what I described in mine except they were fully naked all of them except me and Danielle.
MS. HAJJAR: What did you tell them about the brand?
LAUREN SALZMAN: I told them it was a symbol, an abstract symbol.
MS. HAJJAR: What about the size?
LAUREN SALZMAN: I had told them originally my understanding was the brand was supposed to be one inch by one inch and that's what I believed it would be. When I was branded there had been an error that was made somewhere and my brand is much larger than that, it's probably like two and a half inches by three inches and it was supposed to have been corrected by the time my girls were to be branded but it wasn't and so their brand is larger than that as well, I'm not sure exactly the measurements but it is bigger than an inch by an inch, but I told them it was going to be an inch by an inch believing that's what it was, that's the size that all the sisters in my circle, the first line DOS masters all have an inch by an inch and myself and only a few have a much bigger one and then Sarah and Audrey's was much bigger and the others in their circle were bigger than the inch by the inch?
MS. HAJJAR: Who was the first to be branded?
LAUREN SALZMAN: Jimena.
MS. HAJJAR: And was the branding filmed?
LAUREN SALZMAN: Yes, they all were filmed.
MS. HAJJAR: Who filmed Jimena's branding?
LAUREN SALZMAN: I don't recall specifically who filmed Jimena but I think it was Sarah because Keith texted me in the middle of it and she saw the text so after that they weren't filmed on my phone anymore or soon after that they weren't filmed on my phone anymore.
MS. HAJJAR: And the text you received, what was that regarding?
LAUREN SALZMAN: It was regarding a meeting of the first line DOS masters that Keith held in the middle of the branding ceremony, so I had to stop the branding ceremony to go to that meeting and then come back.
MS. HAJJAR: How did Jimena react?
LAUREN SALZMAN: Jimena, it was really very overtly emotionally expressive, like she responded very expressively to the pain.
MS. HAJJAR: What does that mean?
LAUREN SALZMAN: Like she was squealing and screaming and it looked horrendous. It was -- she demonstrated what she felt and her reaction was particularly intense.
MS. HAJJAR: At some point did she ask for some kind of cloth?
LAUREN SALZMAN: Yeah, she asked for or somebody offered her something to bite down on.
MS. HAJJAR: Did it look scary?
LAUREN SALZMAN: It looked really scary. What Jimena was demonstrating looked very scary. It was frightening to see, it scared the other girls.
MS. HAJJAR: You said that ceremony was interrupted at some point; what happened?
LAUREN SALZMAN: I had to leave to go to the first line meeting so, and Carola wanted to leave to go feed her daughter, her baby and so Carola and I left. I went -- I dropped her off to feed her daughter and then I went to the first line DOS meeting and then like an hour later we went back.
MS. HAJJAR: Who was next to be branded after Jimena?
LAUREN SALZMAN: Audrey went second.
MS. HAJJAR: And after that?
LAUREN SALZMAN: Sarah.
MS. HAJJAR: Your DOS slaves, were each of their branding ceremonies filmed?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What was Sarah's branding like, can you describe that?
LAUREN SALZMAN: Sarah was -- like Sarah did and told the other girls as well to use like yoga breathing to help through the process so she was much quieter, she did her yoga breathing, she handled it I mean comparatively much better than the other girls did and I was very proud of her at the time. In all of the branding ceremonies there was, you know, some degree of laughing and joking and different things to try to make it seem a little less awkward and -- but I was, you know, I coached them all through the process. So, there was that in the branding ceremony, me encouraging her, touching her, helping her through the process.
MS. HAJJAR: Who did the branding?
LAUREN SALZMAN: Danielle.
MS. HAJJAR: How do you feel about participating in the branding ceremony now?
LAUREN SALZMAN: I mean I feel like it was the start of the end of all of my relationships with these people, like it -- I don't feel good that I was dishonest about Keith's involvement or the initials, like I don't think it was right to brand his initials on people without them knowing that that's what it is -- what it was and at the time I didn't view it as -- that they were doing it only because I told them to do it or that they felt that they had to do it but ultimately they were my slaves and they were under a collateralized vow of obedience to me and if they didn't obey, their collateral was subject to be released, that was the agreement, and so had they decided they didn't want to do it or there was something about it that wasn't for them anymore, the notion that they really could have chosen out of it I think is really one that I hadn't considered at the time; like at the time I thought it was consensual and they wanted to do it but even if they didn't, I was their master and I told them to and you don't get to say if you tell them they have to have sex with somebody or have somebody else's child they have to do it but somehow they don't have to get branded if they decide they don't want to.
MS. HAJJAR: At the time that the defendant told you that about Sarah, about having sex with someone or having someone else's child, had she provided collateral?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Was she recruited into DOS at that point?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What happened after the branding ceremony?
LAUREN SALZMAN: We went back to my house and I took a group picture and then they went home.
MS. HAJJAR: Were photographs taken of the group?
LAUREN SALZMAN: Yes, I took a group photograph -- I took a group picture of them that night immediately following their branding and then later that week they met a few times and I asked them to take naked pictures of themselves and send them to me similar to what we did in my circle at every one of our meetings.
MS. HAJJAR: Did you give them any instructions about the photographs they were to take after the branding?
LAUREN SALZMAN: Yes, we had -- my group was meeting three times a week and we were taking these pictures and there was -- when we got feedback about changing it, we incorporated that feedback and sometimes we had left the meeting and had to rearrange our schedules to make it possible to get back together again and retake the picture and the girls that I had enrolled all lived in separate areas so specifically I wanted them to have that experience so I told them, I mean initially that they were to be fully frontally nude, the brand should show, you know, and they should appear happy in the pictures or I may not have told them happy initially but I corrected them and they had to get together later and rearrange their schedules to retake the picture and look happy.
MS. HAJJAR: When you say you thought it was important for them to have that experience, do you mean to replicate that, retaking the photograph if you didn't look happy?
LAUREN SALZMAN: To incorporate feedback that your master gave you and that was the feedback that I gave them, specifically to look happier.
MS. HAJJAR: Can you explain what incorporating feedback means, what that phrase means?
LAUREN SALZMAN: It means you're told something that you didn't perceive or you would have already done it, that's important, and so you fix it. Incorporate it is you make that change.
MS. HAJJAR: So, what was the change you requested for this photograph?
LAUREN SALZMAN: I requested them to look happy.
MS. HAJJAR: And did they retake the photograph looking happy?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did you require them to rearrange their schedules for this?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: Well, we had done that several times in my first line group based on feedback and requests that Keith had made or instructions we had been given and so my group had done that a number of times and I thought that he must have been doing it for a reason, that it was somehow important to prioritize this over other things as we had done and because they lived in the other outlying areas they wouldn't have that opportunity to do that, to make that choice or to have that experience again for another three or four months, so I wanted them to have that experience at least once so I required them to do that.
MS. HAJJAR: Again, when you say, "have that experience," what are you referring to?
LAUREN SALZMAN: Of prioritizing my request over everything else they were doing.
MS. HAJJAR: To make them rearrange their schedule in order to do it?
LAUREN SALZMAN: Yeah.
MS. HAJJAR: After your DOS slaves were branded did you ask them to continue taking photographs of the brand?
LAUREN SALZMAN: Yes, the instruction was that they would take photographs every day and send them to me and I sent those photographs to Danielle who was in charge of keeping all of the brand photographs.
MS. HAJJAR: You gave them instructions to send you the photographs every day?
LAUREN SALZMAN: I did every day and then after six weeks I told them they could do it once a week and eventually they stopped sending them. I think when things became public we stopped doing that, possibly earlier.
MS. HAJJAR: Your Honor, can I show something to the witness for identification only?
Thank you.
MS. HAJJAR: Ms. Salzman, I'm showing you what's marked for identification as Government Exhibit 429.
Do you recognize this exhibit?
LAUREN SALZMAN: I believe it's Audrey's brand.
MS. HAJJAR: And does it comprise many photographs of the brand?
LAUREN SALZMAN: Yes, it comprises the photographs from her branding through the initial six weeks.
MS. HAJJAR: Your Honor, the government offers Government Exhibit 429.
MR. AGNIFILO: We have no objection, Judge.
THE COURT: Government Exhibit 429 is received in evidence.
MS. HAJJAR: Thank you, Your Honor.
(Government's Exhibit 429 so marked in evidence.)
MS. HAJJAR: So, the images in this exhibit, Ms. Salzman, what are they?
LAUREN SALZMAN: This is Audrey's brand which is Keith's initials.
MS. HAJJAR: And are there a number of photographs in this exhibit?
LAUREN SALZMAN: Yes, there are.
MS. HAJJAR: What does it reflect over time?
LAUREN SALZMAN: It reflects how the brand healed over time.
MS. HAJJAR: Can you show the members of the jury so -- where is the brand, Audrey's brand located physically on the body?
LAUREN SALZMAN: On her bikini line.
MS. HAJJAR: Can you show the members of the jury where the defendant's initials were on Government Exhibit 429?
LAUREN SALZMAN: Yes, so this is K and then that triangle is the triangle of the A with the A and then the line, the middle line of the A becomes the back of the R and the R is reversed, it's backwards (indicating.)
MS. HAJJAR: And what initials does that stand for, KAR?
LAUREN SALZMAN: KAR, Keith Alan Raniere.
MS. HAJJAR: Now, does your brand and the brand of the other first nine slaves look like this?
LAUREN SALZMAN: Mine is upside down, mirror image of that.
MS. HAJJAR: Why?
LAUREN SALZMAN: Because it was the first line, you could see that it was his initials in all the first line masters and everybody below the first line had it flipped upside down and reversed I think to conceal it.
MS. HAJJAR: To conceal what?
LAUREN SALZMAN: The initials.
MS. HAJJAR: So, in your brand the fact that it contains the defendant's initials is more visible, more readily apparent than here?
LAUREN SALZMAN: More visible, yeah, if you're just looking at it directly but I always thought that that was suspicious because if you have the backwards one and you look at in the mirror, which is how you look at yourself all the time, it's the right way so I thought for sure they were going to see it but...
MS. HAJJAR: But they didn't?
LAUREN SALZMAN: No, and that was also why I was raising questions to Keith about it but, yes, correct, they didn't.
MS. HAJJAR: And did you ever ask permission to explain the initials, did you ask permission from Keith to disclose to your slaves the brand?
LAUREN SALZMAN: Not to explain the initials but I did -- I found out later that some people's slaves did know about his involvement and I wanted mine to know and I did ask for permission and he said maybe at some point but didn't give the permission so I couldn't tell them. So, I mean -- but I did have permission to read from (sic) them the book and so I told them that the supreme master had written the book for us and also that if we succeeded in our enrollment goals, we would qualify for additional curriculum and I was hoping that they would be able to connect the dots on that because it is almost exactly how the other organizations work and Jimena did. So, Carola knew about the initials and the brand and Jimena knew about Keith's involvement.
MS. HAJJAR: Did the others?
MS. HAJJAR: Ms. Salzman, these photographs depict the brand over time as it healed?
LAUREN SALZMAN: Yes, correct.
MS. HAJJAR: And for what period of time was Audrey sending you these photographs?
LAUREN SALZMAN: I think these reflect the first six weeks.
MS. HAJJAR: Did she send these every day to you?
LAUREN SALZMAN: Yes, they all did.
MS. HAJJAR: Did you send them anywhere else?
LAUREN SALZMAN: To Danielle.
MS. HAJJAR: Why?
LAUREN SALZMAN: I was told Danielle was the one who kept track of them.
MS. HAJJAR: This is the last image in that series.
About how long after the initial branding was this image sent to you?
LAUREN SALZMAN: This is probably up to six weeks.
MS. HAJJAR: You testified about acts of care?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And work that your slaves performed for you?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Was their work considered part of the vow of obedience to you?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And the monthly collateral, you testified that you submitted it and your slaves did, was that considered part of the vow as well?
LAUREN SALZMAN: It was considered part of keeping collateral current but, yes, when I told them to keep it current it was under the vow of obedience.
MS. HAJJAR: Did your slaves also track enrollment in DOS in some form?
LAUREN SALZMAN: They did, yes.
MS. HAJJAR: Can you explain that?
LAUREN SALZMAN: There were a number of things that I asked them to keep track of, who they were enrolling and in which stage of enrollment each of the candidates were, when they expected that those candidates would each move to the next stage of enrollment and be fully collateralized in the vow and then there were other things I asked them to track; their acts of care, I asked them to track that they were doing their daily act of self-denial, their good morning-good night and anything else they were checking in on I asked them to keep track of. I didn't necessarily need to see it but I wanted them tracking it.
MS. HAJJAR: Your Honor, may I show the witness something for identification only?
THE COURT: Go ahead.
MS. HAJJAR: Ms. Salzman, I'm showing you what's marked for identification as Government Exhibit 425-R.
Do you recognize this?
LAUREN SALZMAN: I don't recognize this specific page but this is -- the subsequent pages are things that Audrey put together to track the things that I just said and the first page indicates the different stages of enrollment. So, likely it was Audrey tracking all of those stages of enrollment.
MS. HAJJAR: And the initials on the left-most side, did those initials correspond to the first initial of your slaves?
LAUREN SALZMAN: Yes, they did.
MS. HAJJAR: Your Honor, the government offers Government Exhibit 425-R into evidence.
MR. AGNIFILO: One second, Judge.
(Pause.)
MR. AGNIFILO: Judge, may we approach for a second?
THE COURT: All right. You may approach.
(Continued on next page.)
(The following takes place at sidebar.)
MR. AGNIFILO: So, we got this this morning and we haven't really had a chance to look at it. My concern is if this witness didn't make it, I don't know whether the witness looked at it in some official capacity, otherwise it seems like it is a document made by Audrey.
I don't -- I mean since I haven't really had a chance to look at it because we've been on direct all morning, we just got it this morning, what I'd like, maybe the timing contributes to this, if I could have ten minutes to look at it over the break? I'm not going to stand on ceremony about it, I want to make sure there's no hearsay in here or something that's problematic.
MS. HAJJAR: I have no objection to taking ten minutes. This was provided to Ms. Salzman by her slave as a requirement of tracking enrollment within that circle. She's identified who these initials correspond to and what's in the chart and she can do so with more detail.
THE COURT: Well, we'll take our break and we'll come back.
MR. AGNIFILO: I mean if you want to bring -- I just don't know what -- what I heard her say, maybe I'm looking at the whole picture, this is something Audrey made and she wasn't fully familiar with it. If you have other questions to ask her, that's fine.
MS. HAJJAR: That's fine, I can ask her more questions about what are the circumstances were under which she reviewed this.
THE COURT: We're going to take a break in 10 minutes anyway.
MR. AGNIFILO: Do you have anything -- I don't want to mess your schedule up. Do you want to -- what do you want to do? Do you want to take our break now?
THE COURT: Would you like to take the break?
MS. HAJJAR: I'm fine to take the break now. Thank you, Your Honor.
THE COURT: That's fine, sure.
(End of side-bar.)
(Continued on next page.)
THE COURT: All right. We'll take our mid-afternoon break now.
All rise for the jury.
(Jury leaves courtroom.)
THE COURT: The witness may stand down. Please do not discuss your testimony with anyone.
(Witness steps down and leaves courtroom.)
THE COURT: All right. We'll take a ten-minute break. Thank you.
MR. AGNIFILO: Thank you, Judge.
(Time noted: 3:25 p.m.)
(Recess taken.)
(Continued on next page.)
(Defendant enters the courtroom.)
THE COURT: What's that?
MR. AGNIFILO: I haven't had a chance to read it.
THE COURT: All right, thank you. Let's call the witness back in. And we'll get the jury.
And so you are going to go until the end of the day, Ms. Hajjar?
MS. HAJJAR: Yes, Your Honor.
THE COURT: Okay.
Let's get the jury, please.
(Whereupon, the witness resumes the stand.)
(Jury enters the courtroom.)
THE COURT: Please be seated.
All right, Ms. Hajjar, you may continue the direct examination of the witness.
The witness is reminded she is still under oath.
Is there any objection to Government Exhibit 425R?
MR. AGNIFILO: No, Your Honor.
THE COURT: All right, Government Exhibit 425R is received in evidence.
(Government Exhibit 425R, was received in evidence.)
MS. HAJJAR: Thank you, Your Honor.
If I could publish it to the jury.
THE COURT: All right. Go ahead.
(Exhibit published.)
DIRECT EXAMINATION (Continued) BY MS. HAJJAR:
MS. HAJJAR: Ms. Salzman, I'm showing you what's in evidence as Government Exhibit 425R.
This is a spreadsheet to track the stages of enrollment and how much time they anticipated each person would be in each stage of enrollment.
And so at the top when it says: Prospect's first guarantee approach, Pitch to saying yes, Why first said yes, what does that mean?
LAUREN SALZMAN: That means the prospect is who do you have in mind to approach to join.
First guarantee means that they submitted the initial collateral for secrecy.
Pitch to saying yes is the -- when you're in the process of telling them about the four aspects to the vow.
That the lifer said yes, which is the stage four column, means that they've heard the four aspects of joining, which is The Vow of obedience, the master slave concept, the collar and branding and they said, yes, that they want to join after hearing that.
And then stage five is they have fully collateralized.
MS. HAJJAR: And they are six rows underneath those headers.
What do each of those -- those rows each a DOS slave of yours?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did Audrey prepare this at your direction?
LAUREN SALZMAN: Audrey offered to come up with a way to help track it, and I said, yes, that would be helpful to me.
MS. HAJJAR: Did you instruct that there needed to be tracking?
LAUREN SALZMAN: Yes, I asked him to track a number of different things.
MS. HAJJAR: And so what is -- what does this page of Government Exhibit 425R show, the second page, it says enrollment status tracking, what does this reflect?
LAUREN SALZMAN: It shows the different people that each of my slaves had in the stages of enrollment and when they anticipated each -- the dates that they would be moving through the different stages.
MS. HAJJAR: And are those dates reflected at the top?
LAUREN SALZMAN: Yes.
MS. HAJJAR: At the bottom where it says: Totals lifer, all including M, what does that mean?
LAUREN SALZMAN: It meant how many people that we would have fully collateralized in The Vow by each of those dates, including myself.
So it was how many we would have in our entire group; myself included, my slaves included, and their enrollments, and anyone below them included.
MS. HAJJAR: So at 45, the lower right-hand column would be by July 3rd that corresponds to dates, in other words?
LAUREN SALZMAN: That's what they were striving for, yes.
MS. HAJJAR: Can you describe what this page reflects in group accountability and the chart that's underneath that?
LAUREN SALZMAN: I believe this is -- these are the different things that they were tracking. So they were tracking their enrollment, a discipline that they were doing. I don't know if that was daily acts of self-denial or weekly active care.
I had asked them to notify me, so that was they were tracking. They were updating their goals, sending pictures and brands, doing their active care, and being accountable to the data in the spreadsheet, and they were adding their penances as a personal list.
And then for June, when they said "weight," weight was another word that we used for collateral.
So where they're saying monthly guarantee, that means the monthly collateral. And that they were reporting to me that they had submitted it. That they were fully collateralized and that were ready. So those were the things they were checking on.
MS. HAJJAR: And the "M" refers to you as master?
LAUREN SALZMAN: Yes.
MS. HAJJAR: The highlighted box here, take one spoon per person who fails.
Do you know what that refers it?
LAUREN SALZMAN: Audrey called it a spoon, but I think she was taking paddle penances if they failed for all the failures of the people in her group.
She had brought it to me and asked me -- she told me she wanted to do it and asked me if I was okay with her to do that and I said, yes.
MS. HAJJAR: Was that something you suggested?
LAUREN SALZMAN: I suggested that they take -- that they figure out how they wanted to deal with the readiness failures, and that I was taking on penances for their failures.
So when they had failed at readiness, I shared -- I was taking on penances for them. So they suggested that they would take the same penance I was taking. So once I suggested -- I told them I was taking paddlings for all of their failures, then they wanted to take that as their penance as well.
And then Audrey in this case was taking additional paddlings for the failures of her group members.
MS. HAJJAR: Did you continue to recruit other DOS slaves after the branding ceremony?
LAUREN SALZMAN: One more.
MS. HAJJAR: Who?
LAUREN SALZMAN: Charmel. I recruited her the week after the branding ceremony.
MS. HAJJAR: And did you recruit -- was the process of recruiting her similar to the recruitment process for the other slaves?
LAUREN SALZMAN: Yes, always the same.
MS. HAJJAR: What did Charmel submit as collateral?
LAUREN SALZMAN: Charmel submitted a letter to her children that would have effectively severed their relationship.
MS. HAJJAR: How did you communicate with your DOS slaves?
LAUREN SALZMAN: Through Telegram chats, program, the app -- it's the app on the phone.
MS. HAJJAR: Miss Salzman, can you flip in your binder to Government Exhibit 432 and 432R.
LAUREN SALZMAN: Yes.
MS. HAJJAR: Do you recognize these exhibits?
LAUREN SALZMAN: Yes, these are my Telegram chats with Audrey.
MS. HAJJAR: And is 432R is a copy of Government Exhibit 432 with certain names redacted?
LAUREN SALZMAN: 432R is 432 with names redacted.
MS. HAJJAR: Does it appear to be the same, those exhibits?
LAUREN SALZMAN: They appear to be the same, yes.
MS. HAJJAR: Your Honor, the government offers Government Exhibit 432 and 432R.
MR. AGNIFILO: We have no objection.
THE COURT: All right, Government Exhibit 432 and 432R are received in evidence.
(Government Exhibit 432 and 432R, were received in evidence.)
(Exhibit published.)
MS. HAJJAR: Miss Salzman, I show you the first page of Government Exhibit 432R.
Are these are your Telegrams chat with Audrey.
Are they screenshots of that chat?
LAUREN SALZMAN: Yes.
MS. HAJJAR: The Telegram chat is something on your phone?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Is that right?
LAUREN SALZMAN: Correct.
MS. HAJJAR: And whose phones are these screenshots from?
LAUREN SALZMAN: Audrey's.
MS. HAJJAR: And how can you tell?
LAUREN SALZMAN: Because they're conversations between me and Audrey that only existed on my phone and her phone.
And as evidenced by my picture in the right-hand corner, I'm the one who is speaking to the recipient. So these are on the recipient phone, which is Audrey's.
MS. HAJJAR: Can you tell based on the color of the messages which messages were sent and which ones were received?
LAUREN SALZMAN: Yes. Always the person who is -- on your own phone the message is green, and the person writing to you is white.
So I'm writing to her in white, and she's writing back to me in green.
MS. HAJJAR: So the first message: Amanda and I want to do our, quote, mega penance from our readiness failure while we are in San Diego with you. Can you advise on what method instrument we should use.
That's Audrey to you?
LAUREN SALZMAN: Correct.
MS. HAJJAR: And your response, can you just read your response, please?
LAUREN SALZMAN: Go to the sex store and get a paddle, which is what my group did. And they have leather ones. I sent Jimena a picture.
There's one in the mission by your house, I think. Mission is just an area of San Diego. I mean San Francisco. Sorry.
MS. HAJJAR: Did you send a photograph of the paddle?
LAUREN SALZMAN: I did.
MS. HAJJAR: Can you explain the context for this chat? Why were you in San Diego?
LAUREN SALZMAN: I was in San Diego -- I was invited, Allison was in a play in San Diego, and I went to see her in the play. And I invited Audrey and Amanda to come with me.
MS. HAJJAR: And when was this approximately?
LAUREN SALZMAN: In April of 2017.
MS. HAJJAR: Audrey uses -- capitalizes the "Y" in you?
LAUREN SALZMAN: Correct.
MS. HAJJAR: Why does she do that?
LAUREN SALZMAN: Because I'm her master and we capitalize all the pronouns.
MS. HAJJAR: And what was this paddling of penance for?
LAUREN SALZMAN: Failure of readiness.
MS. HAJJAR: Which meant what exactly?
LAUREN SALZMAN: That they failed to get all of the people in their line reporting in for readiness in the one-minute time from.
MS. HAJJAR: To your knowledge, did Audrey, in fact, get a paddling penance for failing?
LAUREN SALZMAN: Yes, she did.
MS. HAJJAR: How do you know that?
LAUREN SALZMAN: Because I saw her take it. I was in the room with her.
MS. HAJJAR: Were there other times where -- that Audrey was paddled or paddled others?
LAUREN SALZMAN: Yes.
Audrey and Charmel took a paddling penance that I was unaware that they were going to take it at the time, but they sent me videos of it.
MS. HAJJAR: So on page 2 of Government Exhibit 432, this is Audrey's text: We are here at the garden, whenever you're ready, we're happy to meet you, whenever it is most convenient.
And your response is: Are you rushing me?
LAUREN SALZMAN: Correct.
MS. HAJJAR: Can you explain the context for this chat?
LAUREN SALZMAN: Yes.
So we had arrived in San Diego, and Allison started pointing out areas where my slaves were failing that would be acceptable to her in her with her slaves were failing at.
So I was getting a lot feedback from Allison that I was not doing a good job as a master. And so when I received the text from Audrey about at being at the garden, whenever they're ready, Allison told me that she would have said are you rushing me, so I wrote: Are you rushing me?
I wanted to show Allison that I was a good master and willing to discipline my slaves and teach them how to be good slaves.
MS. HAJJAR: And the next message you write back: The stories and justifications need to stop. You believe your own BS and it makes and keeps you weak.
LAUREN SALZMAN: Uh-huh.
MS. HAJJAR: Sorry, master.
Is this the tone you would use with you DOS slaves?
LAUREN SALZMAN: At times.
And those are things, too, that Keith would say to us. You know, so that we needed to stop making stories and stop making excuses and stop making justifications. That we were making things harder and more difficult for him and -- by not being better at things.
And as time progressed that I was in DOS, it was more and more strict in those ways, and so I was more and more strict with them as well. Feeling that he felt that we were making things harder for him, and I would go and relay they were making things harder for me with him. But I didn't tell them about him.
MS. HAJJAR: Looking at page 3 of Government Exhibit 422.
Spoke too soon. She's having another freak out. Asked me to not submit her collateral and to back out. I talked her down. She's processing through their reactions faster. I think she's coming around.
What is -- this is Audrey's message to you?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And when she says that this person's having another freak out, asked me not to submit her collateral, what does that mean?
LAUREN SALZMAN: The person -- this person joined, and then would say I don't -- I don't want to be a member any more, but then would say that she did. She did want to stay. She just had a reaction that she was over it now and she wanted to stay. And that happened a few times.
So when she said she's having another freak out, it was her having an emotional reaction and not want to stay. And also she had submitted an additional collateral and she wanted it back.
MS. HAJJAR: Did she ask for it back?
LAUREN SALZMAN: Yes, she asked Audrey for it back.
MS. HAJJAR: Was she given it back?
MS. HAJJAR: This text on page 4 of Government Exhibit 432.
Secondly, she made a life commitment. The fact that she thinks she can back out because she is it uncomfortable is exactly the reason we are asking her to do this assignment.
Who sent this message?
LAUREN SALZMAN: I did.
MS. HAJJAR: And are you referring to the DOS slave that was just being discussed?
LAUREN SALZMAN: Yes, I am.
MS. HAJJAR: You mentioned before that the -- that weight was used as collateral sometimes.
LAUREN SALZMAN: Yes.
MS. HAJJAR: So looking at page 6 of Government Exhibit 432.
The idea of weight is to leverage your capacity to stick to your growth program. The fact that you got scared immediately and want to quit is exactly the reason for the weight.
What does "weight" mean in this context?
LAUREN SALZMAN: The collateral.
It means the idea of collateral is to leverage your capacity to stick to the program. The fact that you got scared immediately and want to quit is exactly the reason for the collateral so that you don't quit, you can't quit.
MS. HAJJAR: On page 8 of Government Exhibit 432 you write:
As far as I'm concerned with Kristin, she is in. She already decided. Telling her herself she's still deciding is a type of way she keeps the back door open.
What does that mean, "the back door open"?
LAUREN SALZMAN: The back door open is the third option I was talking about with the women earlier. That women feel that they can't get out of things. And we call that having back door.
MS. HAJJAR: And what was the purpose in this context when you say, She keeps the back door open. What's the purpose of the collateral?
LAUREN SALZMAN: So that there is no back door option any more.
MS. HAJJAR: There's no way to get out of it?
MS. HAJJAR: The second message on this page: This is a type of tantrum.
Is that word used frequently?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And can you explain how and why you use that word? That word "tantrum"?
LAUREN SALZMAN: Yeah. Because -- well, Keith taught us that these were types of emotional tantrums. That we could throw a tantrum, that we could have an overt emotional reaction to something and then get off the hook for that thing because of the emotional reaction. That people would let us off the hook for that.
And so we came to see those things, somebody having an emotional reaction to something and wanting to not do it as a type of tantrum to try to get off the hook.
MS. HAJJAR: In this context, the emotional -- when you say emotional reaction, in this context, are you referring to someone not wanting to -- their collateral -- not wanting to submit their collateral?
LAUREN SALZMAN: Yes, and them wanting to leave.
MS. HAJJAR: This is on page 9 of Government Exhibit 432. You say: So I recommend when you get here talking to her about that. Don't mention the guarantee.
What did you mean?
LAUREN SALZMAN: I meant that to discuss with her the fact that she said she wanted to do something and then she's trying to get off the hook for it. And then wanting to do it again. Like I want to, I don't; I want to, I don't. Discuss that with her but don't get into the collateral yet. Get her through that part and then we'll discuss what happens to the collateral.
MS. HAJJAR: Why?
LAUREN SALZMAN: Because it -- it was kind of a one step at a time thing. But get her through the first part, then you get her through the second part.
MS. HAJJAR: Explain that further, one step at a time thing?
LAUREN SALZMAN: Like that she was having emotional reaction not want to go do this, which she had had before, independent of the collateral. And was also having a reaction of wanting the collateral back.
And I saw it as a two-step process. Like first let's help her understand why she wanted to do this in the first place, or connect with what she wanted out of it in the first place.
And then talk to her about the collateral, which is precisely what she put down because she wanted that thing in the first place.
MS. HAJJAR: Why defer mentioning collateral?
LAUREN SALZMAN: I thought it was too much at once. She was having reaction and it was progressive.
But it was inductive as well. I said to Audrey: Give me the collateral any way. Turn it in any way. She said she doesn't want it, but she gave it with the intent -- at the time she gave it, she gave it with the intent to give the collateral, we're going to uphold that part.
Like sometimes she says yes; sometimes no; sometimes yes; sometimes no. We're going to honor the part that's yes. She gave the collateral when she meant yes. Give it to me and we're going to hold it and talk to her and see if she wants to we're stay or not. But ultimates the collateral is not subject to be released. But see if she wants to say first.
MS. HAJJAR: So it could be released back to her?
LAUREN SALZMAN: I'm sorry, it wasn't going to be given back. It wasn't going to be given back.
MS. HAJJAR: On page 10 of Government Exhibit 432, Audrey writes she writes -- that this person had asked whether her final collateral was submitted.
And on the following page you say: But turn in her collateral any way.
LAUREN SALZMAN: Yes.
MS. HAJJAR: I believe she's staying, but even if she doesn't, she shouldn't get it back.
LAUREN SALZMAN: Exactly.
MS. HAJJAR: Given with the intent to stay.
Is that what you're referring to?
LAUREN SALZMAN: That's what I'm referring to, yes.
MS. HAJJAR: The bottom of the following page, page 12, you say: She's asking because she's run by her viscera, but she knows it's bad to back out. She's just feels scared.
What's her viscera?
LAUREN SALZMAN: She wants to do what's more comfortable. Viscera is what feels better.
MS. HAJJAR: And when she's asking, because she's run by her viscera. In plain English, what does that mean?
LAUREN SALZMAN: It means I was looking at it like this: That she -- that she had this ideal that she wanted to grow, but it may not always be comfortable to grow.
And so you put down the collateral so that you'll grow even when not it's comfortable. But right now she's feeling uncomfortable, so she's saying I don't want this.
But that was the whole reason we did it in the first place. We joined this organization in this collateralized vow to help us when we felt uncomfortable push through and stay consistent.
So I was looking at it like that; like, so right now she's in the uncomfortable part saying I don't want this, but when she's not feeling uncomfortable, she's this is something that I want.
And so I was saying she's -- right now she's asking because she's feeling uncomfortable, but she knows it's bad to back out because we discussed it several times, and she agreed that she didn't want to be the kind of person who backed out when she got uncomfortable. So she's feeling scared right now and that's what's going on, and that's how I was framing it to Audrey.
And that's why I was making the decision to continue to keep the collateral because when she wasn't in the moment of feeling uncomfortable, she kept say she did want to stay.
MS. HAJJAR: Do you have a different view of this exchange now?
LAUREN SALZMAN: Yes. And also because subsequently she said every time she talked to me she felt like I kept talking her back into things she didn't want to. I thought that she was agreeing because she did want to do it not because I was pushing her in an area she didn't want to be pushed, and she didn't feel strong enough to say, no, or felt afraid because of her collateral. Because I had substantial collateral on her.
MS. HAJJAR: Turn to page 16. Is this the message you sent?
In theory, each act should be doing about an hour of work per week for their M as a normal contribution or act of care.
Is that something you considered?
LAUREN SALZMAN: Yes, after Keith came to a meeting and shared that that was what he thought should be, I communicated it to Audrey.
MS. HAJJAR: And what does that mean?
LAUREN SALZMAN: That means each slave should be doing about an hour per week of work for the master as in moral act of care, which should be going on any way.
MS. HAJJAR: And the following message: What generally helps me most is you considering where you can bring the most and highest level of skills you have to my life and objectives at the highest standard possible. I have an assistant. I have a cleaning lady. So that doesn't really help me that much and it's lowering the value of what you could be attributing to furthering me.
LAUREN SALZMAN: Correct.
MS. HAJJAR: Can you explain what you meant by that?
LAUREN SALZMAN: Yes. And this was a concept that we looked at earlier in the book, which is that ideally you want be to be providing most value at all times that you can to your master to be furthering them in the most valuable contribution way.
MS. HAJJAR: So what did that mean with respect to Audrey, as you were conveying this to her?
LAUREN SALZMAN: The highest skills that she could bring, she should bring. The work that she could do, she should do.
MS. HAJJAR: Turning to page 20. This is Audrey message to you: Master, may I eat extra today calories today. I felt really hungry for past two days since I got my period. Much stronger than usual. I have tried to pace my calories throughout the day; 100, 200 at a time, as you suggested, but I'm still feeling very hungry. Last night I had trouble falling asleep because of it. My period also stopped after one day. I don't know if this is related, but I think it might be.
Were these types of requests for -- was Audrey on a restricted diet in terms of her calories?
LAUREN SALZMAN: Audrey -- when Audrey first joined, she communicated that she didn't feel that she was meeting her health and fitness goals, and I asked her to track her calories to see how much she was eating. So she did that. And then I suggested -- or I told her to go down 100 calories. So she was on 1500 calories a day diet, I believe.
MS. HAJJAR: Did she have to ask you permission to eat more than that?
LAUREN SALZMAN: I did.
MS. HAJJAR: Did you refuse her?
LAUREN SALZMAN: I did.
MS. HAJJAR: And so the next message when you say: No, I don't think you need this, I believe your calories are already high.
LAUREN SALZMAN: Yes.
MS. HAJJAR: She was not permitted to eat the remaining calories she wanted?
LAUREN SALZMAN: Correct.
MS. HAJJAR: Turning to page 21. Are these three messages your messages to Audrey?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you read them, please?
LAUREN SALZMAN: I am pushing you on this because you're doing a very weenie version of a program that you think is a big deal. Your capacity for discomfort and self-denial is super low and this limits your capacity to even vision an ideology beyond a very low level of morality. You need to push against this to gain a sense of self.
Part of the masturbation denial is also denying the fantasy shit you link with it, which is counter growth for you overcoming self victimization and suffering.
I'm telling you this not as your master but as a green in ESP and head of stripe path. If you want to get a proctor, you must evolve this and the long circuitous road is not a good option.
MS. HAJJAR: The second message refers to masturbation denial.
Did you require Audrey to refrain from masturbation?
LAUREN SALZMAN: She suggested it as an option, and I said that she should take that option, that would be good.
MS. HAJJAR: In what context did she raise it as an option?
LAUREN SALZMAN: The context of -- I don't recall specifically, but absence of self-denial in getting over being led to the body.
MS. HAJJAR: Was that something you suggested?
LAUREN SALZMAN: Yes.
Yes, I mean I was -- at the time looking at it as she needed to overcome is exactly what I said. She didn't have a good capacity to do this and she should be doing this if she wanted to grow and if she was really committed to growth she would be doing this.
MS. HAJJAR: When you say: I'm telling you this not just as your M but as a green in ESP and head of the stripe path. If you get a proctor, you must evolve this?
LAUREN SALZMAN: Yes. I shouldn't have said that, but, yes.
MS. HAJJAR: What does that mean?
LAUREN SALZMAN: That I'm telling her as a green in ESP and as head of the stripe path, these are the requirements that we look for to see that you'll qualify to evolve. So if you're not getting passed it, you're not going to meet those requirements for promotion.
So she's saying she wanted to get promotion in ESP and she wasn't meeting the promotion and I wanted her to know that if she got through this, she would get that.
MS. HAJJAR: So by saying that, you are linking promotion in ESP -- professional promotion to her being a good DOS slave?
LAUREN SALZMAN: Yes. And it shouldn't have been linked.
MS. HAJJAR: What does that mean, it shouldn't have been linked?
LAUREN SALZMAN: More important, DOS was never a requirement for promotion in ESP and it should not have been factored into promotion in ESP, but I linked them in this conversation.
MS. HAJJAR: Why? Why did you do that?
LAUREN SALZMAN: Because I knew she wanted to get to proctor and I wanted her to get to proctor. I knew what was required for her to get to proctor.
So I thought if I told her this was important it would help connect it with a goal that she had, and help motivate her to do it.
MS. HAJJAR: Was your input important in terms of who was promoted within ESP?
LAUREN SALZMAN: Yeah, I was head of the promotion program.
MS. HAJJAR: What about the defendant?
LAUREN SALZMAN: Yes, ultimately I mean he did reject or override -- he could reject or promote anybody, whether we had suggested or denied promotions.
MS. HAJJAR: Turning to page 23 of Government Exhibit 432. You write: If you want to use that again for failure, penance should be modified to three hard whacks. If you snap the wrist right, it should really hurt. That's how you know you're doing it right. Please relay to all.
What are you talking about there?
LAUREN SALZMAN: I'm talking about what Keith told us should be how we paddle each other.
And I left the meeting where he told us how to paddle each other, communicate to Audrey specifically how they should be paddling each other.
MS. HAJJAR: Was that a direction?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Turning to page 26, you write: I don't think everyone handed in monthly guarantees. I didn't get anything from Charmel or Sarah for anyone below our line. Can you follow up with everyone? Audrey refers to bank accounts for May. And after that: What's your take of Amanda's.
What are you talking about here, you and Audrey?
LAUREN SALZMAN: Amanda submitted -- we're talking about monthly collateral that she submitted, which she said she -- the bank accounts were for May.
And that her take on Amanda's was Amanda had submitted a video and I wasn't able to watch the whole thing, but Audrey made the video with Amanda, so I wanted Audrey's take on it, whether Audrey thought it was strong enough. And I told Audrey to assess that without me watching the video.
MS. HAJJAR: So when you Audrey replied: It's good, I think. She basically says she's only marrying him to use him for his money because he had no other options.
What does that refer to?
LAUREN SALZMAN: What she said about her fiance in the video.
MS. HAJJAR: Amanda?
LAUREN SALZMAN: Correct.
MS. HAJJAR: And "it's good, I think" refers to strengthening the collateral?
LAUREN SALZMAN: Yeah.
That it should be sufficiently damaging to their relationship were it to come out.
MS. HAJJAR: Turning to page 29, you write: We haven't really started training you guys get.
What are you talking about?
LAUREN SALZMAN: Keith said that he hadn't really started disciplining us yet and so we didn't know -- we weren't doing things as we needed to be doing with the slaves because we hadn't been disciplining them yet. So I relayed that as well, that we hadn't started discipline. I hadn't started training them in disciplining them yet.
MS. HAJJAR: The next message down, you say: I have so much on my plate that I cannot keep up and I have not had time to discipline you guys properly.
Is that something the defendant told you and the other first line slaves as well?
LAUREN SALZMAN: Yes. And I did have so much on my plate that I wasn't able to keep track of what was going on with them.
And A lot of what I had on my plate were the things that we were doing in DOS.
MS. HAJJAR: Turning to page 48, you write: Good morning, with respect to your check in last night.
And then the message continues: Any efforts you put in here will come back exponentially. And once you build your organization here, you will have six Ss, plus however many brand Ss will devote time weekly, moving your life and projects forward.
What are you telling Audrey here?
LAUREN SALZMAN: I'm telling her that -- she was concerned that she didn't have enough time and obviously because of the things she was doing here, and I was telling her if she had six slaves who had six -- each had six slaves, she would have weekly time committed to her for life of help and support that would save her time with her life.
MS. HAJJAR: So when you write: Any efforts you put in here will come back exponentially.
What does "here" refer to?
LAUREN SALZMAN: In DOS.
MS. HAJJAR: The next page you write: Imagine if you have six people, who each have six, so 36 people, who each devote one hour of time per week to moving your life forward. That's a full-time employee's amount of work times for life?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What are you referring to here?
LAUREN SALZMAN: I'm referring to the same thing, that active care that Keith said, if you had everybody who you enrolled in one hour for their master and grandmaster, everybody would have almost 40 hours of week of full-time work.
MS. HAJJAR: And what's the point of telling this to Audrey at this moment?
LAUREN SALZMAN: Because she was upset she didn't have a lot of time because of the things she was doing in DOS.
MS. HAJJAR: And you're telling her she will benefit from being in DOS and having slaves to work for her?
LAUREN SALZMAN: Yes.
MS. HAJJAR: You write: Do you want to be a proctor? This is page 52. Do you see how you're antihumanitarian, anti-interdependence.
What are you talking about here?
LAUREN SALZMAN: That she was being -- that she was communicating things that were not humanitarian in nature or of a team perspective.
And she's saying she wanted to be a proctor in a humanitarian organization where the whole idea was that the hole is bigger than the sum of the parts. It was a whole team environment. And if she wanted to become a proctor in a humanitarian organization that was focused on -- on being part of a larger team, she needed to overcome the issues that made her not want to be around people and the antihumanitarian in the way she related with them.
MS. HAJJAR: Were you connecting her progress in terms of making proctor to her performance in DOS?
LAUREN SALZMAN: I didn't mean to, but I did it. Yes. It wasn't my intent, but I did that, yes.
MS. HAJJAR: Looking at page -- on page 53, you write: You will never be a proctor in this organization as long as you believe that helping others is not a high priority.
And Audrey says: No, I'm sorry, master, that is not what I'm intending to say.
Did Audrey want to be a proctor?
LAUREN SALZMAN: Yes, she did.
MS. HAJJAR: And then the following page, page 56: I just talked to KT. She had a full throttle tantrum about the guarantee. Flatly refused to do it and is painting this whole thing as bad in her mind.
What is she talking about there?
LAUREN SALZMAN: That Kristin doesn't want to submit her collateral. And that she is refusing to submit collateral. And believes that DOS is bad and that the whole collateralization is bad.
MS. HAJJAR: How did you respond to that?
LAUREN SALZMAN: I don't recall specifically, but I -- I likely told Audrey to just help her try to work with her and see if she can get her through it.
MS. HAJJAR: Miss Salzman, you testified that prior to joining DOS you were aware of the defendant's sexual relationships with the first -- with certain first line DOS slaves?
LAUREN SALZMAN: Yes, I was.
MS. HAJJAR: When you were first recruited into DOS, did you believe that DOS was sexual in nature?
MS. HAJJAR: Did you come to learn that there was a sexual component in DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Can you give some examples of that?
LAUREN SALZMAN: Well, naked pictures. Specifically up-close vagina pictures that I think are sexual in nature. Paddling, I thought was sexual, it had a BDSM component. The dungeon was all BDSM equipment that I was told about. Seduction assignments I think are sexual in nature. And having sexual relationships or interactions with a slave is certainly sexual in nature.
MS. HAJJAR: Did there come a time where you learned that other first line DOS masters had assigned their slaves to interact with the defendant?
LAUREN SALZMAN: Yes, I did.
I went to -- we were having a first line DOS meeting, and we were talking about where in each of the enrollment stages the five enrollment stages that we reviewed here each of the slaves were, or everyone in our -- where everyone in our organization was and our projections.
And Allison shared not only where everybody was in each of the five stages but that she had tasked a number of people to do something she called the assignment. And I had never heard about the assignment.
And so I was like, What's the assignment? And that she -- it turned out the assignment was that she had tasked them to seduce Keith was the assignment.
MS. HAJJAR: Did you understand "seduce Keith" to be a sexual act?
LAUREN SALZMAN: I interpreted it that way, yes, I did.
MS. HAJJAR: Was there more conversation about this assignment at that time?
LAUREN SALZMAN: Not right then, but later we had more discussions about it.
MS. HAJJAR: Did you have a conversation with the defendant about it?
LAUREN SALZMAN: I did. I went to him and asked him about it. And he told me that the purpose of the assignment was that they -- for women to be able to have an experience with a man where the man could abuse power but didn't, and that he thought that that would be a good experience for them to have, a growthful experience for them to have.
MS. HAJJAR: And how did you take that?
LAUREN SALZMAN: I felt -- I felt concerned about it, and I still felt that it was a type of abuse of power. Because I couldn't imagine being a man and having a woman come and do things to try to seduce you and you not having some sort of experience of power in that situation.
But also if I imagine going to try to seduce a man who I didn't have any sexual relationship with, especially if that man didn't take me up on the offer, I would then have feelings toward that man. I would have feelings towards them once I tried to seduce them, even if didn't have those feelings before, especially if he didn't take advantage of the situation, I would like him more.
So I couldn't imagine that not changing the interaction he was having with the slaves. But then I needed to believe also that he would never do that and that it was just him not abusing power and giving them a good experience and so then I --
MS. HAJJAR: What does that mean?
LAUREN SALZMAN: -- compartmentalized it and move forward believing this is all good, and DOS is good and it can't be anything or what I'm imagining they are, because it's just my fears that are running and...
MS. HAJJAR: Did you believe the defendant when he said that there would be -- no sexual interaction would take place?
LAUREN SALZMAN: I wanted to believe him. I wasn't sure.
MS. HAJJAR: Did you have a later conversation with Allison Mack in San Diego?
LAUREN SALZMAN: I did.
Allison and I -- I can't recall the specific words that she said in those -- in the conversations we had in San Diego. But it came away from the conversations with her believing that Keith was having sex with all her slaves, based on all the assumptions that she was using and the way she was talking about things during the time we were there.
MS. HAJJAR: What happened after that?
LAUREN SALZMAN: I came home and said to Keith: Are you having sex with Allison's slaves? And he said: No.
And I said: Why does she think you are? And he said: Because I didn't correct her.
MS. HAJJAR: What did you understand that to mean?
LAUREN SALZMAN: I understood it to mean that he was trying to be truth -- like be right on the technicality.
Because in my mind the next question was: Well, how did she get that impression in the first place? So I didn't ask it, because I believe he knew what I was asking and specifically chose not to tell me truth about it.
And so I believed that either he was lying to me in that moment or he was lying to Allison, but in either case he was lying to somebody about this.
MS. HAJJAR: So what did you after you spoke to the defendant?
LAUREN SALZMAN: I went back to Allison.
MS. HAJJAR: And what did you say?
LAUREN SALZMAN: Is he fucking your slaves, is what I said.
MS. HAJJAR: What did she say?
LAUREN SALZMAN: She said: Just Nicole and Suzy. But we're going to start working with India and Jay.
And I said to her: When you say working, do you mean fucking? And she said: Yes.
(Continued on next page.)
BY MS. HAJJAR (CONTINUED):
MS. HAJJAR: What did you do after that?
LAUREN SALZMAN: I suppress my feelings about it and continued forward.
MS. HAJJAR: Did you later come to learn that Allison's slaves were not the only ones to get the seduction assignment?
LAUREN SALZMAN: Yes. I can't remember the time frame, but at one first-line DOS meeting, I said something but -- along the lines that Allison had been the only one who had assigned people this assignment, and Nicky said no, she's not. And then I learned that other people have been tasking their slaves to do assignment.
MS. HAJJAR: At some point did you learn that Nicky's slaves had been tasked to that assignment?
LAUREN SALZMAN: Yes, I just contact recall when. But yes, I did.
MS. HAJJAR: Did you subsequently raise Nicole's name with the defendant again?
LAUREN SALZMAN: Yes, I did.
MS. HAJJAR: What was your conversation with him?
LAUREN SALZMAN: What he had said when I -- also when I had asked him about the seduction assignment, was that it wasn't always going to be him doing the seduction assignment; that at some point, somebody else was going to be doing the seduction assignment. And Cami and I had a conversation about it at one point in time and I went to him and said Camila and I were talking about who was going to be run the seduction assignment, and he said Nicole was going to be heading that testing.
MS. HAJJAR: Now, at some point after these conversations was the existence of DOS publicly exposed?
LAUREN SALZMAN: Yes, in June 2017.
MS. HAJJAR: How did that happen?
LAUREN SALZMAN: Sarah's husband, Nippy, came and confronted myself and Jim Del Negro at coach summit in a very public way. And then a series of rumors about -- or allegations surrounding DOS started circulating through the West Coast community and so we were hearing back about that. And within a few days a blogger started blogging about everything very publicly, obviously the blog is public.
MS. HAJJAR: When you say rumors and allegations, were they true?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And when you say Sarah's husband approached you, was he angry?
LAUREN SALZMAN: Yes, he appeared angry. He was yelling at me and Jim.
MS. HAJJAR: Did the aspects of DOS after that become publicly -- publicly discussed --
LAUREN SALZMAN: Yes.
MS. HAJJAR: -- within the NXIVM community?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did members of the community raise concerns to you?
LAUREN SALZMAN: Yes, they did.
MS. HAJJAR: Did you try to reach the defendant after Sarah's husband confronted you?
LAUREN SALZMAN: I did. I ws sending him 911 text messages and trying to call him and call anybody I thought he might be with to try to find him.
MS. HAJJAR: What were the 911 text messages?
LAUREN SALZMAN: It was like, I need to talk to you now and I was sending literally 911, which in 20 years I never sent a 911 text message, but like that this is important, this isn't just if you're busy don't get back to me now, it's serious.
MS. HAJJAR: I you eventually reach him?
LAUREN SALZMAN: I did.
MS. HAJJAR: And what was the conversation you had with him?
LAUREN SALZMAN: I told him that Nippy was really upset and that he had said, My wife had Keith's initials branded next to her vagina, you know, like this is not okay and basically resigned from all his positions within our community and didn't want to speak to me ever again, didn't want to speak to Keith ever again, so I relayed that.
MS. HAJJAR: And how did the defendant respond?
LAUREN SALZMAN: He responded saying, Well, Nippy found out that my initials were branded next to his wife's vagina, how do you think I feel learning that this wife branded my initials next to her vagina.
MS. HAJJAR: How did you -- what did that mean to you?
LAUREN SALZMAN: Well, it was Keith's initials and Keith knew it was his initials and I knew it was his initials and I knew he knew that it was his initials, so I interpreted it as him acting out how I should respond to Nippy, like Keith didn't know this, how do you think he's feels learning this. That was the party line on it, like Keith just learned this, you know, how do you think he feels knowing that a bunch of women went around and did this?
MS. HAJJAR: Were there subsequently meetings with the defendant and the first line of DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And can you describe those meetings?
LAUREN SALZMAN: That we went to the DOS house and were trying to figure out how to deal with everything that was happening. And everybody's questions and upsets surrounding it and basically, you know, Keith directed that we were not going to tell anybody about his involvement, it was going to be secret, that he didn't know anything about it, that he wasn't associated with it, that the brand was not his initials and he gave several options for how we could address the concerns that were being raised to make it look like they were all things that were not the truth. Which is that the brand instead of being his initials could be explained that it had seven lines so it was the seven chakras or it was the four elements or it was bar alpha mu. It wasn't Keith and Allison's initials because there were assertions that it was Allison's initials, too, which it wasn't bit those were going around as well. And then things about the seduction assignment which he said could be described as a dare or a test of Abraham, that it was a test to see if the slave was committed enough that they would carry out the act but that they didn't -- it was never intended that they actually would follow through on the act, that it was just a test to see -- a trust test.
MS. HAJJAR: What did the test of Abraham, that phrase, what did that mean to you?
LAUREN SALZMAN: My understanding of test of Abraham is in the Bible, God tasked Abraham to sacrifice his son on the alter. It's a test of faith and loyalty and Abraham was willing do it and then at the end God said you didn't have to do it, I just wanted to see if you were willing to do it.
And so that's how we went out and described it, that the women had been tasked to seduce Keith but the intent was that it was never carried out and that Keith don't know anything about it.
MS. HAJJAR: The -- how did the defendant -- what did the defendant instruct you to say regarding the brand?
LAUREN SALZMAN: That it was the seven chakras and the four elements or it was bar alpha mu but that it was not his -- but it was not intended to be his initials but that when the design was being created somebody noticed that it looked like his initials and so it was refashioned to include -- incorporate them as tribute.
MS. HAJJAR: Now, these explanations of seven chakras, the four elements or bar alpha mu, had you ever heard of these things before to explain the brand or refer to the brand?
MS. HAJJAR: You testified earlier that the DOS meetings where the defendant attended were recorded?
LAUREN SALZMAN: Yes.
MS. HAJJAR: After DOS was publicly disclosed were your meetings recorded?
MS. HAJJAR: How was bar alpha mu going to be an explanation of the brand? Can you explain that?
LAUREN SALZMAN: Yeah, because it looked like the brand, like if you look at the K facing downward, you know, with an A under it, it could have been a bar like a line with an alpha, you know, which is a Greek letter. And the R, the squiggle for the R actually did look like an M, which is why people thought it was Allison's initials. So it was like making it like it was Greek letters, like the bar is a mathematical symbol but it was the bar and then an alpha Mu, so it was like logical that it could have been Greek letters because we were a sorority and all the sororities had Greek letters.
MS. HAJJAR: And who came up with this idea of bar alpha mu?
LAUREN SALZMAN: Keith.
MS. HAJJAR: Okay. I'm showing you what's in evidence as Government's Exhibit 429. Can you just explain with reference to the brand as it actually looked what the story was about bar alpha mu?
LAUREN SALZMAN: To show the bar alpha mu.
MS. HAJJAR: Yeah.
LAUREN SALZMAN: The bar, the alpha and the Mu.
MS. HAJJAR: Were there other steps that you were to take with represent to bar alpha mu to make it seem as though that's what DOS had been?
LAUREN SALZMAN: Yes. Keith wanted us to make a website and so we did and that the formal name of the sorority was going to be Bar Alpha Mu, we decided that, after, like in the fall.
MS. HAJJAR: And some point after that did you communicate with Monica Duran?
LAUREN SALZMAN: I did.
MS. HAJJAR: What did you say?
LAUREN SALZMAN: She had gone back to Mexico. Her mother was ill and she was caring for her and so she wasn't present and so I was texting her saying, you know, I miss you and FYI the new name of the sorority is Bar Alpha Mu and she said since when? And I said since always.
MS. HAJJAR: What did you mean -- what did you mean by that?
LAUREN SALZMAN: That the party line, the story on it was this was always the name.
MS. HAJJAR: And do you understand that Monica got that?
LAUREN SALZMAN: Yeah. She said okay, got it. Yeah, yeah, she understood what I was saying which is that it was always Bar Alpha Mu, it was never Keith's initials.
MS. HAJJAR: Did you follow the defendant's instructions about what to tell people about DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And did you deny the defendant's involvement in DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did you lie to your mother about the defendant's involvement in DOS?
LAUREN SALZMAN: I did. I lied to everybody about it.
MS. HAJJAR: How did your mother react?
LAUREN SALZMAN: Horribly. My mother -- well, I mean, this going public and all of the allegations and everything that we've been talking about, inspired a massive like de-enrollment from NXIVM. People were scared, people were leaving and my mom felt -- and the only people whose names had been public were mine and Allison's. So my mom felt that basically a group of women impulsively didn't think things through and decided somehow that it was a good idea to go give tribute to Keith be branding his initials next to their vaginas and giving seduction assignments. And she was like how could you do this? How could you be so impulsive and not think and put our whole company, everything that we've worked for, for 20 years in jeopardy? Like I just don't even understand how you could do this. She was like so upset, so upset, and she blamed me and my friends, I mean, Allison she knew of, there were others she suspected but basically she blamed us for destroying her company.
MS. HAJJAR: Was it difficult for you not to tell your mom the truth about the defendant's role as your master?
LAUREN SALZMAN: Yes, it was so hard. And she said, I went to Keith and he told me he had -- he knew nothing of this. And so I was like, yes, it was me.
MS. HAJJAR: Who else did you lie to?
LAUREN SALZMAN: I lied to everybody. I lied to the entire community about it. I lied to the media about it, I lied to everybody about it.
MS. HAJJAR: Did you address the community publicly?
LAUREN SALZMAN: I did.
MS. HAJJAR: Did you lie about the defendant's involvement then?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did your DOS slaves learn more information about DOS during and after this period of time when DOS went public?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What happened?
LAUREN SALZMAN: Well, Sarah left the initial weekend and then Audrey started to learn more and she started bringing concerns to me and she had a discussion with Danielle who knew that Keith was involved and Danielle told her that Keith was involved and so Audrey came back to me and said, I'm very troubled to learn that Keith's involved, you know, and basically you lied to me, you know, and that's troubling and as well like I just really think that there's a big ethical issue and an incredible -- like a situation where abuse -- like she was very concerned about abuse of power and she was like this is an incredible abuse of power and I think that there's no ethical checks on Keith and this is very concerning to me.
MS. HAJJAR: I'll show you what's evidence as Government's Exhibit 432. Again, this is Page 60. This is -- are these messages with Audrey in the immediate wake of public disclosure of DOS?
LAUREN SALZMAN: Yes, they are, yes.
MS. HAJJAR: And where you write, Do you understand that I didn't know any of the stuff I shared with you the other night and also that Keith didn't know any of this, he just found this out when we did.
Was that truthful?
MS. HAJJAR: What were you telling her there?
LAUREN SALZMAN: I was telling her that everything we were learning about Keith's initials and seduction assignments was something that I just found out and that Keith also didn't know.
MS. HAJJAR: At around this time, and subsequently, did you receive requests for return of collateral?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Who asked for their collateral back?
LAUREN SALZMAN: Audrey and Kristin did but many other people did, too. People who I didn't enroll and other people below me in line and in my lineage.
MS. HAJJAR: Did you personally receive requests for collateral back?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: And what did you when you received those requests?
LAUREN SALZMAN: I forwarded them to Clare.
MS. HAJJAR: Why?
LAUREN SALZMAN: Because Clare was heading up our legal initiatives.
MS. HAJJAR: Do you recall when Audrey requested her collateral back from you?
LAUREN SALZMAN: Not the specific date, but I recall that she did. I remember that she did.
MS. HAJJAR: Would there be something that would refresh your memory about that?
LAUREN SALZMAN: I believe she sent me an e-mail.
MS. HAJJAR: Your Honor, may I show the witness what's marked as Government's Exhibit 418?
THE COURT: Go ahead.
LAUREN SALZMAN: So she sent this on July 10th, 2017.
MS. HAJJAR: Just take a moment to read this, Ms. Salzman.
LAUREN SALZMAN: To myself?
MS. HAJJAR: Yes.
LAUREN SALZMAN: (Witness complies.) I see. She sent me this on July 7th and then requested it to the executive board on July 10th. The executive board of NXIVM.
MS. HAJJAR: What was the content of the request for collateral back? What did she want?
LAUREN SALZMAN: She wanted to know that her collateral basically would be destroyed. She wanted the collateral -- all the collateral back and she listed it and she said that if I didn't respond to it she was going forward the request to the executive board.
MS. HAJJAR: Did she list out the collateral she had --
LAUREN SALZMAN: Yes.
MS. HAJJAR: -- she had given you?
LAUREN SALZMAN: Yes, specifically she listed it.
MS. HAJJAR: What was the list that she requested the return of?
LAUREN SALZMAN: It was the naked pictures she had given me, the videos that we had made together disparaging people in her life, the letter accusing her boyfriend of domestic violence, two videos or a paddling video and some pictures that she had taken with -- naked pictures that she had taken with her circle.
(Continued on next page.)
LAUREN SALZMAN: (Cont'g.) I recall -- I mean her bank accounts were part of the collateral but I don't recall specifically what was to be done with that.
MS. HAJJAR: Did she say anything about the circumstances under which the collateral had been taken?
LAUREN SALZMAN: Yes, that she believed that it was under false pretenses, that we had lied about Keith's involvement and gained it based on misrepresentations.
MS. HAJJAR: You testified that Audrey sent this request for collateral to you on July 7th?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Was it then forwarded onward?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Why?
LAUREN SALZMAN: Why did I forward it or why did Audrey?
MS. HAJJAR: Had Audrey said that she would forward it if you didn't respond?
LAUREN SALZMAN: She did, she said if I didn't respond she was going to forward it to the executive board --
MS. HAJJAR: And did she?
LAUREN SALZMAN: -- of NXIVM.
Yes, she did.
MS. HAJJAR: Who did she send it to?
LAUREN SALZMAN: She sent it to all members of the board. The initial request came to Keith, Allison and myself. Then she forwarded it to I believe the executive board at the time which was myself, Karen Unterreiner, Clare Bronfman, Alex Betancourt, Omar Boone, I can't remember if Emiliano Salinas was still part of the board or not and I don't recall if my mom was on it as well.
MS. HAJJAR: Was it forwarded to the defendant?
LAUREN SALZMAN: Yes, it was sent to him. I think initially it was sent to just me, Keith and Allison but it was sent to Keith, yes.
MS. HAJJAR: Your Honor, I'm just going to show this to the witness to refresh her memory on this.
LAUREN SALZMAN: I see. Initially she sent it to me and then she forwarded it to myself, Keith Allison and cc-d Nancy, Karen, Omar, Alex Emiliano and Clare.
MS. HAJJAR: What was the date on which the email was forwarded?
LAUREN SALZMAN: It on July 10th, 2017.
MS. HAJJAR: Did Audrey get her collateral back?
LAUREN SALZMAN: No, nobody their collateral back.
MS. HAJJAR: Did Kristin make a similar request for the return of her collateral?
LAUREN SALZMAN: She did, yes.
MS. HAJJAR: When was that?
LAUREN SALZMAN: Around the same time, a little bit later than Audrey.
MS. HAJJAR: Did she send it to you -- what form did that request take?
LAUREN SALZMAN: It was an email as well.
MS. HAJJAR: Who did she send the email to?
LAUREN SALZMAN: I don't recall but it was at least me and if I saw the email I could tell you.
MS. HAJJAR: I'm going to show you what's marked as Government Exhibit 428-R. Just take a minute to look that over.
(Pause in the proceedings.)
LAUREN SALZMAN: Yes.
MS. HAJJAR: Around when was this email sent to you?
LAUREN SALZMAN: The end of September in 2017.
MS. HAJJAR: And who else was it sent to?
LAUREN SALZMAN: It was sent to the entire executive board.
MS. HAJJAR: To include?
Would you like to see it again?
LAUREN SALZMAN: Yes, yes, can I look at it again?
(Pause.)
LAUREN SALZMAN: It was sent to Alex, Emiliano, Clare, Karen, Omar, and myself.
MS. HAJJAR: And in the email what did Kristin request the return of?
LAUREN SALZMAN: She requested the return of a video about her business and religion, a letter to her sister, a false journal entry about her parents and a photo of a letter denouncing her religion.
MS. HAJJAR: And were these all items of collateral that had been committed?
LAUREN SALZMAN: Yes, they were.
MS. HAJJAR: Did Kristin express anything about the circumstances under which this collateral -- she had given the collateral?
MR. AGNIFILO: I'm going to object to this, Your Honor.
THE COURT: You may answer. (Pause.) You may answer.
LAUREN SALZMAN: That she felt that they were false pretenses and that she was lied to on multiple occasions in the enrollment process about the brand and specifically the obtaining of collateral.
MS. HAJJAR: Why wasn't their collateral returned to them or destroyed?
LAUREN SALZMAN: I mean in the end because Keith said not to but, you know, the theory behind it was that it had been given to hold a promise and that promise was still valid even if they broke their promise, it was given for something in exchange for something, there was an agreement and so that agreement still existed at least in theory.
THE COURT: Are you discussing the written contract?
LAUREN SALZMAN: No, their agreement, they gave collateral in exchange for information about DOS as access and it was to secure the privacy and secrecy of the group and also for them to stay forever. So, even if they chose to leave, that that collateral was subject for forfeiture which was the agreement.
THE COURT: It was an oral agreement?
LAUREN SALZMAN: Oral agreement. Audrey signed a contract but the contract was never finalized but it was an oral agreement.
THE COURT: I see.
MS. HAJJAR: Did a woman named Carly also request -- make a request in connection with DOS?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And when was that?
LAUREN SALZMAN: I don't recall specifically but if I saw the email again I could tell you.
MS. HAJJAR: Just to refresh your memory I'm going to show you what's been marked as Government Exhibit 1473, just take a moment to read this.
(Pause.)
LAUREN SALZMAN: Okay.
THE COURT: Could I see the top of that please?
MS. HAJJAR: Yes.
THE COURT: All right.
MS. HAJJAR: Ms. Salzman, when was this email sent to you?
LAUREN SALZMAN: On the 4th of July, 2017.
MS. HAJJAR: And who did Carly send this email to?
LAUREN SALZMAN: She sent it to the executive board, the greens and the admin team and then cc-d all of the leadership in Vancouver where she was a member of the ESP center.
MS. HAJJAR: Can you name the individuals who are the executive board please?
LAUREN SALZMAN: Myself, Clare, Alex, Emiliano and Karen and then she also sent it to the greens and Pam who is -- I'm not sure which Pam that is but she sent it to the greens who are myself, Esther, Emiliano, Alex, Sara Bronfman, and then included in that group as part of the leadership council was Sara and Mark Vicente. Then she sent it to the admin team which included my sister. She also sent it to Rosa Laura, whose line she was in in DOS, and to my mother, Nancy Salzman; and then additionally to Lucas Roberts, Leah Mottishaw, Chris, Wendy, Rosen, Ariella Subalewski (ph), Anthony Ames and she said this is her formal resignation.
MS. HAJJAR: And what did she ask for in this request, what did she want?
LAUREN SALZMAN: She wanted outstanding refunds that she was waiting for from NXIVM and V Week and I believe she was also asking for her collateral back.
MS. HAJJAR: What collateral did she request back?
LAUREN SALZMAN: A pornographic style video and a video about her business as well as some photographs.
MS. HAJJAR: And this request for her collateral, a pornographic video and the video about her business, was sent to the entire executive board?
LAUREN SALZMAN: Yes.
MS. HAJJAR: And --
LAUREN SALZMAN: It was sent to the entire leadership base of NXIVM and in her area.
MS. HAJJAR: In July of 2017?
LAUREN SALZMAN: Correct.
MS. HAJJAR: Did Carly express negative views about her experience in DOS?
LAUREN SALZMAN: She was, she was expressing that. She was saying she felt she had been lied to, that Keith's identity was withheld as well as other information that she felt was withheld until she gave collateral and then she learned about the brand and the collar and then she was upset about the way that the leadership was handling it and felt that we were all lying to her which we were.
MR. AGNIFILO: Your Honor, I'm sorry, can we have a sidebar?
I object and I respectfully move to strike that for the reasons that we talked about this morning.
THE COURT: Next.
MS. HAJJAR: Around this time, Ms. Salzman, were there efforts to aggregate and to secure collateral?
LAUREN SALZMAN: Yes, there were.
MS. HAJJAR: And at this point was it your understanding that collateral would be released if a DOS slave left or spoke out publicly about DOS?
LAUREN SALZMAN: Initially it was and when it became public there were discussions where Keith wasn't sure that we should release the collateral.
MS. HAJJAR: Were there discussions with the defendant where he considered whether or not to release collateral?
LAUREN SALZMAN: Yes.
MS. HAJJAR: Did the defendant express a concern about releasing collateral at that point after it had been made public?
LAUREN SALZMAN: Yeah, that it would validate the allegations being made against us and also wouldn't serve any purpose because the purpose that it was given for was already broken.
MS. HAJJAR: At this time were there efforts to discredit the allegations that were made by former DOS slaves including Sarah?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What were those efforts?
LAUREN SALZMAN: We made efforts to show that -- to discredit her accounting of her branding ceremony and pointing to inconsistencies in her statements as well as sharing alternate hypotheses about why she had actually left that wasn't this.
MS. HAJJAR: And were there other statements or efforts you made to discredit those allegations?
LAUREN SALZMAN: Well, in conjunction with creating the website, Keith wanted us to write like position statements. We didn't ever release those but we all wrote position statements as well as securing testimonials that DOS was a positive experience and women -- and a consensual experience that many women would attest to.
MS. HAJJAR: And did you gather materials that would assist you in making and putting forth that position?
LAUREN SALZMAN: I did, yes.
MS. HAJJAR: What did you do?
LAUREN SALZMAN: I asked all of the first line DOS masters for examples that showed consent and positivity about positive experiences about DOS.
MS. HAJJAR: Did that include photos where DOS slaves appeared to look happy?
LAUREN SALZMAN: Yes.
MS. HAJJAR: You've discussed the requirements of the photographs in the context of DOS; do you have a view on photographs where DOS slaves appeared happy now?
LAUREN SALZMAN: Yes, well, some of the photographs that I included in this compilation were photographs that I had instructed them to retake specifically to look happy and it wasn't -- I mean it wasn't a thorough representation, a full representation of like the positives and the negatives, it was just cherry- picking the positive, the things that looked positive. There were also I mean within my group concerns that were negative and allegations of extortion going on before, before this happened and during this time, so they were left out.
MS. HAJJAR: Who else was involved in these efforts with you?
LAUREN SALZMAN: All of the first line DOS and Keith.
MS. HAJJAR: At some point in August of 2017 did the defendant address the NXIVM community?
LAUREN SALZMAN: He did, yes.
MS. HAJJAR: When was that?
LAUREN SALZMAN: He addressed the leadership at V Week, so proctors and above, and he also wrote a statement on the website.
MS. HAJJAR: And V Week is the abbreviation for Vanguard Week?
LAUREN SALZMAN: Vanguard Week, yes.
MS. HAJJAR: Which is a celebration of his birthday?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What did the defendant say?
LAUREN SALZMAN: He said he wasn't affiliated with DOS, that he had very little knowledge about it but he advocated for the group and he said some of the things in the group were a little racy and could be seen as, you know, alternative but that ultimately he thought they were good and essential.
MS. HAJJAR: Was that true?
LAUREN SALZMAN: No. No, he created DOS and was very involved in all the aspects of it and I think what was going on in the group was more than just a little racy or alternative.
MS. HAJJAR: Was there --
LAUREN SALZMAN: Or he said edgy, edgy was the word he used.
MS. HAJJAR: Was there a coach summit that took place shortly after?
LAUREN SALZMAN: Yes.
MS. HAJJAR: What was the subject of that coach summit?
LAUREN SALZMAN: The entire coach summit focused on basically the difference between using the media versus the legal system to address disputes and laid out that our adversaries basically were using the media which was vigilante justice and this was not considered to be honorable or ethical and that we thought that the more honorable or ethical means would be to use the legal system and that we believed in the justice system of this country and so that was what we were going to do.
MS. HAJJAR: What do you think of that coach summit now?
LAUREN SALZMAN: Well, I think generally when there were valid concerns being raised in the organization at different times throughout the organization there was always curriculum that was released about that specifically helped reframe your perspective about how to look at it and who to look at as the good guys and the bad guys, you know, so to speak and who was being honorable and who was being noble and so everybody who wanted to believe this was good was given a lot of information about how specifically to view it as good and why it was good but there were very real and very valid allegations being made about things that were true and we were lying about them so, you know, and here we are so I don't --