page 168 for the district of new jersey and first .... salzman deposition... · 09/06/2009 · 17,...

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2 UNITED STATES DISTRICT COURTFOR THE DISTRICT OF NEW JERSEY

3 CIVIL ACTION NO. 2:06-cv-01051-DMC-MF

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NXIVM CORPORATION, f/k/aEXECUTIVE SUCCESS PROGRAMS, INC.and FIRST PRINCIPLES, INC.,

Plaintiffs,v.

MORRIS SUTTON, ROCHELLE SUTTON,THE ROSS INSTITUTE, RICK ROSS,a/k/a "RICKY" ROSS, STEPHANIEFRANCO, PAUL MARTIN, Ph.D., andWELLSPRING RETREAT, INC.,

Defendants.

12 RICK ROSS,13 Counterclaim-Plaintiff,14 v.

15 KEITH RANIERE, NANCY SALZMAN,KRISTIN KEEFFE, INTERFOR, INC.,

16 JUVAL AVIV, ANNA MOODY, JANE DOEand JOHN DOES 1-10,

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Counterclaim-Defendants.18

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DAY II DEPOSITION OF NANCY SALZMANNewark, New Jersey

Tuesday, June 9, 2009

Reported by:25 JOMANNA DeROSA, CSR

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•Page 169 Page 170

2 APPEARANCES;3 RIKER, DANZIG, SCHERER,

HYLAND & PERRETII, LLP4 Attorneys for Morris Sutton,

Rochelle Sulton, Stephanie Franco5 Headquarters Plaza

One Speedwell Avenue6 Morristown, New Jersey 07962-1981

BY; HAROLD L KOFMAN, ESQ.

TOMPKINS MCGUIRE WACHENFELD & BARRY19 Attorneys for the Witness, Nancy Salzman

Four Gateway Center20 100 MUlberry Street, Suite 5

Newark, New Jersey 0710221 BY: WILLIAM B. MCGUIRE, ESQ.22232425

•LOWENSTEIN SANDLER, PCAttorneys for The Ross lnstinne,Rick Ross, Paul Martinand Wellspring Retreat, Inc.

65 Livingston AvenueRoseland, New Jersey 07068

BY: PETER L. SKOLNIK, ESQ.THOMAS S. DOLAN, ESQ.

DRINKER, BIDDLE & REATH, LLPAttorneys for Keirn Raniere

500 Campus DriveFlorham Park, New Jersey 07932-1047

BY: ROBERT M. LEONARD, ESQ.FRIEDMAN, KAPLAN, SEILER & ADELMANAttorneys for lnterfor, Inc., Juval Avivand Anna Moody

1633 BroadwayNew York, New York 10019-6708

BY: ROBERT S. LANDY, ESQ.17

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June 9, 200910:10 a.m.

Day II Deposition of NANCY SALZMAN, 8

held at the offices of Tompkins McGuire, 100 9

Mulberry Street, Newark, New Jersey,10

pursuant to Notice, before Jomanna DeRosa, aCertified Shorthand Reporter and NotaryPublic of the State of New York.

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IT IS HEREBYSTIPULATED AND AGREED, by 3and between the attorneys for the respective 4parties herein, that filing and sealing be 5and the same are hereby waived. 6

IT IS FURTHERSTIPULATED ANDAGREED 7that all objections, except as to the form 8of the question, shall be reserved to the 9time of the trial. 1 0

IT IS FURTHERSTIPULATED ANDAGREED 11that the within deposition may be sworn to 12and signed before any officer authorized to 13administer an oath, with the same force and 14effect as if signed and sworn to before the 15Court. 16

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SALZMAN - DAY IINAN C Y SAL Z MAN, called as a witness,

having been previously duly sworn by aNotary Public, was examined and testifiedfurther as follows:

CONTINUED EXAMINATION BYMR. KOFMAN:

Q. Good morning, Ms. Salzman.We're going to continue the

deposition that we started yesterday. The samerules apply, the same instructions that Mr. Landand I gave you.

I want you to turn hack to Salzman17, please. And that was Exhibits A, Band Cattached to the August 26th, 2005 letter fromMichael Quinn.

Looking on the second page, whichis Exhibit A.

A. Yes.Q. Do you see on the first paragraph,

the last sentence ofthe first paragraph states:"Plaintiffs estimated per capital

loss of revenue of $38,500, which is broken downas follows: One, 6,000 in revenue for the coursesthat the person would have taken himself; and,


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1 SALZMAN - DAY II 12 two, 32,500 in revenue for referrals that the 23 person would have made." 34 Do you see that? 45 A. Yes. 56 Q. And am I correct that NXIVM 67 estimates that for each person listed on Exhihit 78 A, it suffered $38,500 in net loss? 89 A. That's correct. 9

10 Q. Okay. And that 38,500 consists of 1011 $6,000 that the person themselves would have spen 1112 and $32,500 in referrals that the person would 1213 have made? 1314 A. Yes. 1415 Q. Okay. How did NXIVM calcnlate that 1516 each person would have taken an additional $6,000 1617 worth of courses? . 1718 A. What NXIVM did was it evaluated 1819 retrospectively the past enrollments at -- in 1920 total, and evaluated, based on that, what it would 2021 be per person. 2122 Q. Okay. How did it involve - who 2223 did that evaluation? 2324 A. The actuary in our company, Karen 2425 Unterriener. 25


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SALZMAN - DA Y IIQ. Okay. How did Ms. Unterriener

evaluate past enrollments?A. I think she did them in total, but

I don't have very specific information.Q. Okay. Did she determine that each

person who takes a NXIVM class spends $6,000?A. That's the cost of an intensive, so

I imagine she was calculating that as an average,but I'm not sure.

Q. Does NXIVM keep statistics aboutthe average amount that a person spends?

A. Karen is an actuary, and she'sworked with these figures on more than oneoccasion to come up with this. And I don't have agreat in-depth knowledge ofactuarial skills, butI know that she's fully certified.

Q. Okay. Do you, as you sit heretoday, have knowledge about how much each personthe average student, spends at NXIVM?

A. I think that an average student,over the totality of our enrollments, this is it.

Q. Okay. On what hasis didMs. Unterriener determine that each person wouldhave spent $6,000 more than they already had?


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SALZMAN - DAY II 1MR. Me GUIRE: Aren't these 2

questions more properly directly to 3Karen Unterriener? 4

A. Yes, I think probably I would like 5to forfeit any really specifics to her because she 6can give you better data than I can. 7

MR. KOFMAN: Well, counsel, we can 8move on, but she was designated as -- 9Ms. Salzman has been designated as the 1030(b)(6) witness on damages. 11

Q. Let me now turn to the number of 12$32,500 in revenue for referrals. 13

How was that calculated? 14A. I believe the average person who 15

comes into our program has a certain number of 16

referrals, which is usually two, I believe, to the 17best of my knowledge. 18

Q. SO, it's your understanding, as you 19sit here today, that the average person refers twc 20individuals to NXIVM? 21

A. Correct That's my belief. 22Q. And my question would he iftbe 23

average was two referrals, wouldn't that lead to 24$12,000 in revenue, rather than 38,000 - or 25


SALZMAN - DAY II$32,500?

A. We have multiple products. Manypeople take more than one course. Not everyone,though.

Q. Wbo performed the calculations thatled to the $32,500 number?

A. Karen Unterriener.Q. Did you snpervise her in doing

that?A. I asked her to do it. Sbe's an

actuary. I know that sbe's fully certified. Iassumed the results she gave me were good. And Ialso know that we are submitting her results toexperts.

Q. Do you know what statisticsMs. Unterriener looked at to compute the $6,000number in the $32,500 number?

A. I don't.Q. In looking at Exhibit A, I noticed

that there are certain names that are duplicated.For example, if you look at the

name on number 23 on Exhibit A, Bruce McClellan iidentified, and then he's also identified underExhibit C as No.2.


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SALZMAN - DAY IIA. Yes.

MR. KOFMAN: Let's mark this asSalzman 22 for identification.

(Exhibit Salzman 22 marked foridentification.)

MR. KOFMAN: And, for the record,Salzman 22 is a one-page document. Theheading says:

''Nancy Salzman, President ofExecutive Success Programs."

And it's been produced indiscovery, Bates Stamp No. P000004778.

Q. Ms. Salzman, do you recognize thisdocument?

A. Yes.Q. And what is this?A. This is a bio on me.Q. And did you review this biography? •A. Just now? ~

Q. No, at some point in the past.A. At some point in the past.Q. To the best of your knowledge, is

everything on this bio about you accurate?A. Yes.


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1 SALZMAN - DAY II2 And my question is do you know on3 what hasis he appears on hoth lists?4 A. One would be from -- to the best of5 my knowledge, reading this one, it would be6 individually, and then in a professional capacity.7 Q. During your deposition yesterday, I8 asked you questions about the amount of money tha9 Sara Bronfman had contrihuted to payment of

10 NXIVM's legal fees.11 A. Yes.12 Q. Do yon have that information?13 A. Yes. She's contributednone.14 Q. Okay. Has sbe contributed money to15 NXIVM's expenses?16 A. I don't have that information.17 Q. Okay. Are you aware of newspaper18 articles that indicate that Clare and Sara19 Bronfman have purchased townhouses for your use?20 A. I don't believe that's true.21 Q. Okay. Are you aware of articles22 tbat say tbat?23 A. Yes.24 Q. And it's your testimony that that's25 incorrect?

TSG Reporting - Worldwide (877)702-9580

SALZMAN - DAY IIMR. MC GUIRE: Why don't you read

123 it?4 Q. You can take the time to read it,5 just to make sure.6 A. I think it's true.7 Q. Okay. Looking at tbe bottom,8 there's a stamp tbat says bighly confidential.9 Why did NXIVM mark this document a

10 highly confidential?11 A. I don't think I know.12 Q. Okay. Getting back to tbe13 biography, in the first sentence it says that14 you've bad:15 "Over 20 years of intensive study16 and practice in the fields of."17 And it says "human potential and18 human empowerment."19 Can you tell me what - can you20 describe for me your 20 years of study in human21 potential and human empowerment?22 A. I studied Ericksonian techniques23 and brief, solution-based models of therapy for24 the first ten years of my career. And then I25 studied neurolinguistic programming for a number


1 SALZMAN - DAY II2 of years, and I became a trainer in the field of3 neurolinguistic programming, and I studied Gestalt4 techniques. I studied transactional analysis. I5 studied a series of different models over the6 years, and then I worked with individuals7 individually for a number ofyears.S And then I worked for a seminar9 company that was based in Hawaii, and I traveled

10 all over the United States and Canada teaching11 goal-setting seminars as a trainer of12 neurolinguistic programming.13 Q. What was tbe seminar company in14 Hawaii that you worked for?15 A. Advanced Neurodynamics.16 Q. Okay. I'm going to back up and ask17 you a few questions.18 First of all, what do you mean by19 the phrase "human potential"?20 A. It refers to a series of techniques21 that were developed in the '80s that are designed22 to enhance what an individual's potential for23 producing results in the world are, depending on,24 you know, what it is that they want to do.25 Q. And am I correct that NXIVM is in


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SALZMAN - DAY IILandmark or EST?

A. I took one class.Q. Was that at Landmark or when it was

called EST?A. It was when it was called EST.Q. Did Virginia Satir or Fritz Perls

publish anything on the field of human potential?A. Virginia Satir published a number

of books in family systems therapy, and FritzPerls created Gestalt techniques, and they werevery popular in the '80s. Both ofthem were verypopular in the '80s.

Q. Is there any text that's considereddefinitive in the field of human potential orhuman empowerment?

A. I don't think so. I think thereare a series of texts.

Q. And one of the things you mentionedearlier was neurolinguistic programming. What ithat?

A. It's a blend of behavioral andcognitive psychology, and it's modeled after thework of Milton Erickson. Milton Erickson was apsychologist and a psychiatrist. He had a double


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1 SALZMAN - DAY II2 the field of human potential?3 A. That's correct.4 Q. What is human empowerment, if it's5 anything different from human potential?6 A. I think they're similar ways of7 describing the same thing.8 Q. Okay.9 A. It has to do with one's individual

10 understanding of one's own ability, and then11 expressing that in the world.12 Q. You said that the human potential13 movement began in the 1980s. Who were some oftb14 people responsible for starting it; if you know?15 A. Virginia Satir, Fritz Perls. They16 were two of the main ones that I personally17 studied, but there are a whole number of different18 models that were produced in the '80s. Landmark19 Education might be considered one. It was EST in20 the early days. Even scientology, I think, may be21 considered to he that sort of a model, but I don't22 know much about it.23 Q. Have you studied scientology?24 A. I have not.25 Q. Did you take any classes at


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1 SALZMAN - DAY II 12 degree. And he was considered to be the creator 23 of brief, solution-based models of therapy in the 34 United States. 45 Q. That's brief, solution-based? 56 A. Yes. It's a non-traditional 67 approach to therapy. The more traditional 78 approach would be a more Freudian approach, which 89 is a psychoanalyst analyzing someone, which is a 9

10 very time consuming process and the person who 1011 would undergo such a process would do multiple 1112 visits a week, whereas brief, solution-based 1213 models of therapy were designed to create change 1314 in a short period of time. Much of the human 1415 potential movement is based on those types of 1516 theories. 1617 Q. The theory tbat human behavior can 1718 be changed in a short period of time? 1819 A. Exactly. Milton Erickson was the 1920 first practitioner who believed that in a short 2021 number of sessions, maybe six to ten sessions, 2122 change could be created. 2223 Q. Now, was NLP done on a one-to-one 2324 basis with a teacher and one student, or was it 2425 doneinagroup? 25


SALZMAN - DAY IIA. Both. There is a training which

teaches individuals a series of techtriques, andthen there are the techniques that they teach.So, one can take a training and learn a series ofstrategies, techniques, tools, language patterns.

So, Milton Erickson did a certaintype ofwork. Also, Virginia Satir and Fritz IPerls did different types of work. And Bandler -and Richard Bandler and John Grinder workedtogether in California at the University ofCalifornia back in 1975.

Richard Bandler was a student ofJohn Grinder in linguistics, and he was also astudent of mathematics. And what Bandler did was.

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he came up with a theory, and the theory that he ~

brought to his linguistics professor was thatVirginia Satir, Milton Erickson, and Fritz Perlswere all doing very similar things. And if theycould be broken down into processes that could betaught to people, it could increase theireffectiveness.

And that was the whole basis ofneurolinguistic programming, and the basis ofmodeling, which is what he believed that children


1 SALZMAN· DAYII 12 And then I studied with Wyatt 23 Woodsmall. He had an institute in Washington, 34 D.C. I studied with Tad James, who is the person I 45 ended up working with in his company that was 56 Advance Neurodynamics. His company was based in 67 Hawaii. And I also took a limited number of 78 courses with John Grinder. 89 Q. DoesNLP focus ou the language 9

10 someone uses to try and ascertain patterns of 1011 behavior? 1112 A. I'm not surel understand the 1213 question. 1314 Q. The name implies that there's a 1415 focus on linguistics. What is the use of 1516 linguistics or communications theory, if that's an 1617 accurate description? 171B A. I thinkif youreally look at 1819 neurolinguistic programming, in the early days 1920 when John Grinder andRichardBandlercreated 2021 neurolinguistic programming,they looked at a 2122 model for transformational grammar that was 2223 developedby Noam Chomsky. And what Noam Chomsky 2324 said in his paperthat theymodeledNLP after was 2425 the map is not the territory. 25


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SALZMAN·DAYII 1did anyway naturally. And he believed that you 2could create a series of processes to teach people 3these techniques. They could then become much 4more effective in anything that they did. 5

Q. Did Dr. Erickson publish books or 6articles concerning his research? 7

A. Milton Erickson wrote a number of 8books. His main student was Ernest Rossi. He and 9

Ernest Rossi worked together for the last ten 10years of Erickson's life to the point where Ernest 11Rossi had enough data codified from his time with 12Milton Erickson that he wrote 10 additional books 13with Erickson after his death. 14

So, Erickson himself wrote a series 15of books that documented his work. Several other 16therapists wrote books with him and about his 17work, and he is the person who took things like 18brief, solution-based therapy and hypnosis, and 19created the American Medical Association looking 20at those things as therapeutic tools in the 21practice ofmedicine. 22

Q. When did you first become 23iutroduced to -- NLP I'll call it for short? 24

A. In the '80s, after Erickson's 25TSG Reporting- Worldwide (877) 702-9580

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SALZMAN - DAY IIdeath.

Q. How did you become introduced toNLP?

A. Through Erickson's work. MiltonErickson had a certain amount of time that hespent with Bandler and Grinder, which was ratherlimited, but he found their approach to be veryeffective in evaluating his techniques, moreeffective in some ways than other practitionerswho tried to model him or recreate his work.

Q. And where did you learn NLP?A. I learned it mostly from Richard

Bandler, who was one of the creators ofNLP, andthen I learned it from some of the students,including Robert Dilts, who is their main student.

Robert Dilts studied with Bandlerand Grinder. He was a student when they firstpartnered back in the mid '70s, and he created aninstitute in California, and then he traveled allover the United States teaching seminars.

I took a number of seminars withRobert Dilts. And then I took a number ofseminars with Linda Sommers and Joe Yeager, whohad an institute in Pennsylvania.


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SALZMAN - DAY IIAnd what they were talking about

was each of us, when we experience the world,looks at the world, and we take in data. And youcan kind of think of the mind as a computer, butthe way that the human mind takes in data isthrough visual, auditory, and kinesthetic input,and also olfactory -- meaning we see, we hear, wefeel, we taste, and we smell.

What Chomsky was doing was he waslooking at if there is an external event in theworld that occurs, multiple people will havedifferent understandings of that event.

In other words, if you and I havethe same experience, you have one understanding ofthat experience, I have a separate understanding,and then maybe Bill or Bob would have anotherunderstanding of that.

So, what Chomsky was seeking to do,and in his paper, was to understand how it wasthat different human beings could have the verysarne experience externally, but internally have avery different experience.

And so, he began to look at that.And what he carne up with was an understanding that


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SALZMAN - DAY IIwe create internally an internal representation ofthe external events of the world. And what hebegan to look at was the fact that the internalrepresentation is not the external event. Andmost of the problems that were created for humanbeings have to do with the confusions hetween theinternal representation and the external event.Most people think their internal representation isthe external event.

Now, neurolinguistic programmingwas designed to break apart or somehow figure outa way of reprogramming or changing the confusionsthat occur.

Q. SO, that somebody's internalrepresentation would be integrated with tbeexternal event?

A. No. They confuse the internalrepresentation with the external event.

Q. But NLP sought to have peopleintegrate tbe -- or have tbe internalrepresentation equal the external event?

A. I think they sought to teachstrategies and tools to correct thosemisunderstandings.


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1 SALZMAN - DAY II2 Q. Okayv Is there one definitive hook3 on neurolinguistic programming?4 A. No. Richard Bandler wrote a series5 of books with John Grinder. They wrote -- the6 very first books they wrote probably were the best7 books that they wrote. And what they did in their8 very first books were a series of -- they created9 a series of tools that could be used by different

10 practitiouers. I think they were trying to create11 some sort of reproducible results.12 But what they did, and probably the13 best books that they have are they evaluated -14 they made a linguistic model. In other words,15 they took linguistic categories, and they studied16 the work of Milton Erickson, and the work of17 Virginia Satir and Fritz Perls.18 And what they found was tbat they19 could look at the patterns that Milton Erickson20 used in his work, the patterns that Virginia Satir21 used in her work, and the patterns that Fritz22 Perls used in his work. And what they found was23 that ou one side of the spectrum, Milton Erickson24 was using patterns that seemed abstract in nature.25 On the other side, Virginia Satir


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1 SALZMAN- DAY II2 and Fritz Perls used linguistic patterns that3 seemed much more specific and brought about4 specificity. And each of them believed that5 through using these different patterns, they could6 create results that would give someone insight7 into their own process through a series of8 questions that they could apply, or that9 practitioners could apply in a very consistent

10 way.11 Q. When you taught neurolinguistic12 programming, was there a manual or a book that yo13 used to teach it?14 A. I read the books that Bandler and15 Grinder wrote. I read the books that other16 authors wrote with them. I studied a lot of17 Ericksonian work before that. And as a result of18 that, I wrote my own manuals and created my own19 versions ofthose things, or I worked with other20 people who had done that, and I experimented with21 theirs or worked with theirs.22 Like wheo I worked for Tad James,23 he had a series of ways that he developed of using24 the model with Richard Bandler because he25 partnered with RichardBandler for a number of


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SALZMAN - DAY IIyears. He taught me the methods that he used, andthen I used those methods for a while and workedfor him and taught seminars all over the UnitedStates and Canada.

Q. When did you write manuals?A. My own manuals?Q. Yes.A. After I left Tad James.Q. Have you retained copies of the

manuals that you wrote?A. I don't know. I did for a while,

and then after I met Keith I didn't really fmdthem very valuable anymore. I may still havethem, but I don't know.

MR. KOFMAN: Okay. I'll make arequest, and I'll follow it up with a letter,for copies of any manuals that Nancy Salzmanwrote.

Q. And, by the way, have you ever beenlicensed hy any state as a psychotherapist orpsychiatrist or psychologist?

A. To be a psychologist in the Stateof New York, you have to bave a Ph.D., and sixyears of -- or two years of supervision, and I



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1 SALZMAN - DAY II2 A. Yes.3 Q. How long was International Center4 For Change an active company?5 A. Probably 1988, or 1986 through6 1997.7 Q. Did you do anything with8 International Center For Change after 1997?9 A. No. I stopped using it.

10 Q. Do you know if it remained an11 active corporation?12 A. I think it stopped being an active13 corporation in 1999.14 Q. But between 1997 and 1999, you15 didn't do anything with it?16 A. No, I didn't.17 Q. Did you continue teaching at NLP18 after you became involved with Executive Success19 Programs?20 A. No, I did not.21 Q. Okay. By the way, the company that22 was formed as Executive Success Programs, is tha23 company now known as NXIVM Corp.?24 A. Yes, it is.25 Q. Okay. So, I can use those


I don't.(The requested portion of the

record was read.)Q. Have you ever represented to anyone

that you held a master's degree?A. No.

(The requested portion oftherecord was read.)

Q. You mentioned yesterday a companythat you had, The Institute For - and it wentthrough some different names. InternationalCenter For Change was one ofthe names.

Was that a company that youoperated to teach NLP?


1 SALZMAN - DAY II2 don't have that degree.3 Q. How about as a psychotherapist?4 A. A psychotherapist doesn't have5 licensure in the State of New York.6 Q. Okay. How about in any other7 state? Have you ever been licensed as a8 psychotherapist?9 A. I've lived in New York State.

10 Q. Okay. Do you hold a master's11 degree?12 A.13141516171819202122232425

1 SALZMAN - DAY II 12 interchangeably? 23 A. You can. 34 Q. At tbe time that you were 45 teaching -- strike that. 56 Was there one organization or 67 company that was responsible for licensing NLI 78 materials? 89 A. There was not. 9

10 Q. Okay. Did you bave any non-compet 1011 or confidentiality agreements relating to your 1112 teaching ofNLP? 1213 A. I did not. 1314 Q. Have you ever taken any classes 1415 with Tony Robbins? 1516 A. Only one. 1617 Q. When was that? 1718 A. Somewhere around -- somewhere in 1819 the late '90s, maybe '96. 1920 Q. Is Tony Robbins involved in the 2021 field of human potential? 2122 A. He is. 2223 Q. What technique does he use; if you 2324 recall? 2425 A. Tony Robbins took a basic NLP 25


SALZMAN - DAY IIcourse, and he uses the techniques in histraining, but, to the best ofmy knowledge, he'sdoing new and different things now, and he'sincorporated other models.

He's worked with otherpractitioners through the years. And myunderstanding of this happened because Iparticipated in a seminar recently where he did apresentation there, and he talked about some ofthe new things that he's doing. So, he's notdoing just neurolinguistics, but years ago, when Itook the course, he was utilizing techniques thatI would say were from the field ofearly -- verybasic NLP.

Q. Is it fair to say that nobody -that there was no business that had a pruprletaryownership of the NLP concepts?

A. That's true. Actually, I thinkboth John Grinder and Richard Bandler both voicedregret that they hadn't ever done that in theearly days of their model.

Q. You mentioned that you met KeithRaniere in late I997?

A. That's correct.TSG Reporting - Worldwide (877) 702-9580

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1 SALZMAN - DAY II 12 Q. Was it Toni Natalie who introdnced 23 ~n~h~? 34 A. No, it was not. 45 Q. Who was it? 56 A. Sandy Padilla, P-A-D-I-L-L-A. 67 Q. And Mr. Raniere had taught you 78 rational inquiry method? 89 A. He did. 9

10 Q. When did he start teaching you 1011 that? 1112 A. I would say about six weeks after 1213 we met, six weeks to eight weeks after we met. 1314 Q. And at the same time - was that 1415 the same time that the idea offorming Executive 1516 Success Programs arose? 1617 A. No. We had no thought of that at 1718 all. 1819 Q. When did the idea of forming 1920 Executive Success Programs arise? 2021 A. July 4th, 1998. 2122 Q. How did it arise? 2223 A. On a walk with him that lasted 2324 about four hours of discussion about our results 2425 in the first months of our work together. 25


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SALZMAN - DAY IIQ. And what was the discussion about

forming Executive Success Programs tbat you hadwith bim?

A. I met Keith in 1997, and I hadthree conversations with him about our worktogether. And he explained to me what it was thathe thought might be possible, which I believeddidn't exist in my field or in any of the thingsthat I studied. And I became interested instudying his hypothesis with him.

And so, for the first severalmonths, we were studying his hypothesis. Andafter -- from the time in between February toJuly, he showed me something that caused me tobelieve it was possible to do what he wanted todo, and that led to the concept ofExecutiveSuccess Programs.

Q. Okay. Before Mr. Raniere beganteacbing you tbe rational inquiry method, did heask you to sign any confidentiality agreement?

A. We spent several weeks where we hadseveral very long discussions. And at the end ofabout six -- I think it was somewhere about sixweeks, he had demonstrated to me that he could do


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1 SALZMAN - DAY II2 something that I had never seen before in a -- in3 a verbal interaction with respect to beliefs. And4 I asked him ifhe would mentor me.5 I had talked to him a lot about why6 he thought he could do this, and what he thought7 it was, and then I watched him work with some8 individuals. And after that, I asked him ifhe9 would mentor me. And when I asked him to mentor

lame, he said that if he mentored me, I would never11 be able to resume my career in the same way.12 And he told me that I would -- if!13 didn't want to continue to work with him, that I14 would have a problem because he would make it15 impossible for me to -- through the education that16 he gave me, to go back to doing what I was17 currently doing. And, therefore, I had to agree18 either to consistently use his model or figure out19 another way of sustaining myself.20 Q. Wbat did you understand he meant21 wben he said that he would make it impossible for22 you to go back to what you were doing?23 A. Well, in my own mind, he had24 already made it impossible for me to go back to25 what I was doing, because he showed me what he had


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SALZMAN - DAY IIwas far superior to anything that I had ever seenbefore. And he was able to do it in a consistentway. And I had never seen that in my field. AndI believed that he had an ability that might havebeen unique, but might have been something thatwas teachable, reproducible, verifiable, andmeasurable. And if it was, it would be science.

And the idea of a reproduciblemodel that was quantifiable, measurable andconsistent, to me, was what I was trying to findmy entire career. And if he hadn't, I was willingto invest the rest of my life in helping himdevelop it. And if he didn't have it, I decided Iwas going to find a new career.

Q. Okay. Did he say saying to youabout the confidentiality of what he was going tteach you?

A. He did.Q. What did he say?A. Well, he said multiple things. In

fact, when he first -- in our very firstinteraction he began to explain to me that he haddeveloped a couple of things that ifhe sharedthem with me would change the way that I saw


I1 SALZMAN - DAY II 12 things or experienced things. And he asked me if 23 I was the kind ofperson who would recognize when 34 somebody had given me somethingthat I didn't own 45 or didn't belong to me and give them credit for 56 it, or was I the kind of person that just assumed 67 that because somebody taught me something I had 78 the right to use it or own it. 89 And he began to show me that his 9

10 intellectual property really was his intellectual 1011 property. And that if! intendedto use it, I had 1112 a limited -- it was up to him how I could use it 1213 or he didn't want to teach it to me. 1314 Q. Did he -- at any point did you sign 1415 a confidentiality agreement with him? 1516 A. No. I believe he filmedme. He 1617 filmed most of our early interactionswith a video 1718 camera. 1819 Q. Does NXIVM have copies of those 1920 videotapes? 2021 A. I don't have them. I've never seen 2122 them. They were something that he had, and I've 2223 never seen where he stores them or how he stored 2324 them or what he did with them. I don't know where 2425 they are, but I know that I made those agreements 25


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SALZMAN - DAY IIwith him.

Q. Okay. And when in the process didyou make those agreements, before he startedteaching yon the method?

A. Well, the first day that we evenbegan speaking, he offered me a document to read,which I didn't take with me because I reallywanted to think it through. And then the secondday he offered me the document to read again, andI didn't take it with me because I just -- itseemed like he was asking something of me that Iwasn't sure what -- how to handle.

And then the third day he gave methe document, I took it with me and I didn't readit because I wasn't sure what to do with it, forabout a week. And then when I went back and wediscussed it some more, I had an understanding ofwhat he was asking me, but he was very, very clearon his requirements for teaching me.

Q. Briefly, what is rational inqnirymethod?

A. I'm not sure how to explain itbriefly. Because it is a method that creates aseries of perceptual shifts that changes one's


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Does it teach the method?Right.

SALZMAN - DAY IIthere are different trainings that teachdifferent -- that have different objectives.

Q. SO that the method itself is notwhat's taught, but it's a means of teaching?

MR. MC GUIRE: Object to the fonnof the question.

A. The method itself is not taught inthe basic curriculum. It's a means of teachingthe basic curriculum. In the higher levels, thereare aspects -- you know what?

Can you read back the question?(The requested portion of the

record was read.)A. It's a means of teaching.Q. What is the basic curriculum that

you're referring to?A. The Ethos curriculum.Q. Is that what's taught in the 16-day

intensive?A. Yes. The Ethos and the Origins

curriculums are both taught in the 16-dayintensives, and those are both very basiccurriculum.

Q. What are the advanced curriculum TSG Reporting - Worldwide (877)702-9580

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It does.Okay. Does NXIVM - strike that.

Does NXIVM teach rational inquirymethod?

A.Q.A. Itself? I'm not sure -- I don't

understand the question.Q. Is NXIVM - is rational inquiry

method a tool that NXIVM uses to ohtain theresults that you described?

A. The modules employ the method, sothe method is used in teaching, and the method isused in every area of the training itself. And


1 SALZMAN - DAY II2 understanding and experience of their existence.3 And in doing so, a person, it appears, becomes4 less troubled, more joyous, less burdened with5 thought patterns or types of limitations.6 So, it consistently seems to help7 people think differently so they become less8 linear thinkers and more systems thinkers.9 Q. Does it seek to have people's

10 internal perceptions of events match the externa11 reality?12 A.13 Q.141516171819202122232425

1 SALZMAN - DAY II I 12 what is the advanced classes in which the method! 23 is taught? 34 A. I'm not sure that we ever teach the 45 method. I clarified that on purpose. 56 I think the method is used to teach 67 the entire model, but I don't think we ever teach 78 the method. 89 Q. Does NXIVM, in the basic 9

10 curriculum, use -- strike that. 1011 Does NXIVM, in the basic 1112 curriculum, employ means of teaching other thar 1213 the rational inquiry method? 1314 A. I don't understand the question. 1415 Q. Does NXIVM use anything that you 1516 learned in NLP in teaching the basic curriculum 1617 A. In the module communication and 1718 being at cause, which is one of 600 modules, there 1819 is a portion that is a compilation of some of the 1920 information that I learned in NLP. I would say 2021 about 60 percent of that one module. 2122 And then there's another module 2223 called assumptions of presuppositions that I 2324 worked on that has a series of assumptions and 2425 presuppositions that are linguistic in nature that 25

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1 SALZMAN - DAY II 12 cause was an entire weekend. I would teach it for 23 two or three days, and now I teach it -- it's 40 34 percent of one two-hour module. 45 The application of all ofthe data 56 has elements ofother things from different 67 fields, but the way that it's taught, the method 78 that is taught, is the method of rational inquiry, 89 which I've never seen anything like it anywhere. 9

10 Q. To this day? 1011 A. Yes. 1112 Q. Do you know if Keith Raniere had 1213 ever studied NLP? 1314 A. I think he took a portion of a 1415 course in .- when he was involved in developing 1516 CVI, and the way that I know that is because one 1617 ofhis sales reps carne to my office and tried to 1718 introduce me to Keith to teach him a course ten 1819 years before I met him, and then he found somebody 1920 else to teach him the course because I didn't call 2021 him back. 2122 (Exhibit Salzman 23 marked for 2223 identification.) 2324 MR. KOFMAN: For the record, 2425 Salzman 23 is a one-page document entitled "We 25

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SALZMAN - DAY III learned when I was studying NLP. I would say -also the rapport module, which is a half of amodule.

Q. That's rapport, R-A-P-P-O-R-T?A. Yes, the rapport module. I would

say the rapport techniques I learned in NLP.Other than that, I don't think so.

Q. Is there anything used besides NLPand rational - strike that.

Other than what you've described asthings you took from - or things that you learnedin NLP, are there any other tools that are used inNXIVM's curriculum that you had learned beforemeeting Keith Raniere?

A. Even though the modules that Idescribed have information that I learned in NLP,the application is different because Keith'smethod, the rational inquiry method, is adifferent .- utilizes a different process.

So, although the material seemedsimilar to what I learned and what I taught atNLP, the rapport module, for instance, I used toteach an entire weekend ofrapport, and now it's aone-hour module. And communication and being at

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SALZMAN - DAY IITeach Logic and Critical Thinking," BatesStamp No. P000004779.

Q. Do you recognize this document?A. Yes.Q. What is this? IA. This was something that we put

together in the early days of the company to tryto describe what we do.

Q. Is this something that you would •give to people who might be interested in takinj !NXIVM classes?

A. Back then.Q. Back then. And this is copyright

2003, so back in that time period?A. Yes.Q. Okay. Do you know why this has

been stamped highly confidential?A. I don't know.Q. Okay. About halfway down in the

second paragraph, it says:"In light of this, we provide a

series of tools that people can use to becomecritical, independent thinkers. These toolsinclude. "


SALZMAN - DAY II2 And then it lists seven things hy3 bulletpoints.4 Does that indicate that NXIVM usesS seven tools in teaching its students?6 MR. MC GUIRE: Object to the form7 of the question. Are you asking present?8 MR. KOFMAN: At the time ofthis9 document.

10 Q. Is that supposed to indicate that11 there are - is that supposed to communicate that12 there are seven tools that NXIVM uses in teaching.13 A. No.14 MR. MC GUIRE: Object to the form15 of the question. If you can answer, go ahead.16 MR. KOFMAN: Strike that.17 Q. What did NXIVM mean that "these18 tools include" and then the seven items listed19 here?20 A. I think it means these tools21 include the seven items listed here.22 Q. SO, there might be additional tools23 besides this?24 A. Yes.25 Q. Okay. And these seven items all


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SALZMAN - DAY IIconstitute tools that NXIVM uses in teaching orused in teaching at this time?

A. Yes.Q. Which of these tools did Keith

Raniere develop?A. Rational inquiry.Q. He did not develop scientific

method. Correct?A. He did not.Q. And communications theory, does

that include NLP?A. NLP teaches some communications

theories. NLP is a model that also teachescommunication theory.

Q. Any other types of communicationtheory that NXIVM uses as a tool, besides NLP.

A. Well, you would have to define"communications theory" to me because it's apretty broad scope.

Q. And what was meant by"communication theory" in this document?

A. It was meant by the pretty broadscope of connnunications theories.

Q. I'm correct in - are -- none ofTSG Reporting - Worldwide (877) 702-9580

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•1 SALZMAN - DAY II 12 these communication theories were developed by 23 Keitb Raniere? 34 A. I think he utilized all of these 45 processes in his development, and in our teaching 56 they are used. 67 (Exhibit Salzman 24 marked for 78 identification.) 89 (Recess taken.) 9

10 Q. The document that we've just marked 1011 as Salzman 24, do you recognize this? 1112 MR. MC GUIRE: Take as much time as 1213 you want to look at it. 1314 A. I actually do recognize it. 1415 Q. What is it? 151 6 A. It is an analysis by Kathy Russell, 1 617 who is the controller ofmy company from a number 1718 of years ago when we were evaluating how the 1819 company had been put together. 1920 I think it was when I was working 2021 with her, and Joe O'Hara might have been there at 2122 that time, and we were looking at how we put the 2223 company together in the beginning. 2324 Q. Did you ask Ms. Russell to prepare 2425 tbis? 25


SALZMAN - DAY IIA. We had a number of conversations,

and she did it because she wanted to document ourunderstanding.

Q. Okay. Looking back - looking atthis document, do you see tbe entry under1997/1998, PC markets rational inquiry?

A. Yes.Q. Who is PC?A. Pam Cafritz. I believe it's Pam

Cafritz.Q. And is she a part of your company?A. Yes.Q. What is her role in your company?A. She's in charge of ethics.Q. Okay. What does the phrase "PC

markets rational inquiry" mean?MR. MC GUIRE: If you know.

A. To the best of my memory, Pam hadbeen working with Keith for a number ofyears inhis first company, CVI, with the current endeavorshe was doing when I met him. And Pam and I havebeen working together since I met Keith and I mether. She's worked with him for in excess of 20years.


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1 SALZMAN - DAY II 12 Q. What did it mean that she was 23 marketing rational inquiry? 34 MR. MC GUIRE: If you know. 45 A. I think he may have licensed -- I 56 don't know. I could just be guessing. So, I'm 67 not going to guess. 78 MR. MC GUIRE: Don't guess. 89 Q. The next entry is -- do you know if 9

10 she showed rational inquiry materials to 1011 third-parties to try and get them interested in 1112 it? 1213 A. No. 1314 Q. You don't know? 1415 A. She didn't. 1516 Q. Okay. And under 7/1/98 there is a 1617 Letter of Intent between PC and NS, rational 1718 inquiry. Are you NS? 1819 A. I am. 1920 Q. What's the Letter of Intent that's 2021 referred to here? 2122 A. My intent to undergo learning and 2223 recreating the model to be reproducible in the 2324 context of Executive Success Programs. 2425 Q. Okay. Was this a written document 25


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1 SALZMAN - DAY II 12 Q. What is Jness? 23 A. Jness is an organization that is a 34 women's organization that has its own curriculum 45 that was developed based on rational inquiry. 56 Q. When was that founded? 67 A. I believe 2005. 78 Q. And are you involved with Jness? 89 A. I'm the spokeswoman for Jness. 9

10 Q. Who is the president? 1011 A. Pam Cafritz. 1112 Q. And who owns Jness? 1213 A. Pam Cafritz. 1314 Q. Okay. What is Rainbow Garden? 1415 A. It is a children's education 1516 program, which is developing its own curriculum 1617 based on rational inquiry. 1718 Q. When was the rational inquiry 1819 method licensed to Rainbow Garden? 1920 A. I believe 2006, but it may have 2021 been 2007. It was right around -- I think 2006. 2122 Q. And tbe last one is Nataraja. What 2223 isthat? 2324 A. Nataraja is a studio that is owned 2425 by Ivy Nevares, and it teaches a curriculum called 25


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SALZMAN - DAY IIthe Letter of Intent?

A. I don't remember.Q. Okay. Do you know ifNXIVM has I

copy of that Letter ofIntent?A. I can look.

MR. KOFMAN: Okay. I'll make arequest.

Q. On 7/21/98 it says:"Letter of agreement hetween PC and

ESP."Do you know what that refers to?

A. I'm going to -- I can't remember.Q. And next to that is:

"N. Salzman forms FirstPrinciples."

What is First Principles?A. It's the company that licenses the

rights to rational inquiry to other entities.Q. And to whom does it license the

rights to rational inquiry?A. Executive Success Programs, Jness,

Rainbow Gardens, and Nataraja.Q. What's the last one?A. Nataraja.


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SALZMAN - DAY IIUltima, which is a derivative of rational inquiryas well.

Q. To wbom does it teach Ultima?A. People who sign up and take that

training.Q. How does tbat differ from ESP?A. It's a different company, and it's

a different curriculum.Q. How does the curriculum differ?A. That particular curriculum has more

physical applications, and it's applied more toartists that do dance, athletics; things likethat.

Q. Are you involved with eitherNataraja or Rainbow Gardens?

A. No, not involved in that I teach,but I help administrate them.

Q. Who owns Nataraja and RainbowGardens? %

A. Ivy Nevares owns Nataraja, and iRainbow Gardens is owned by my daughter, Lauren 'Salzman.

Q. What age children are taught byRainbow Gardens?


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SALZMAN - DAY IIA. They are.Q. Does First Principles pay a fee

to -~ strike that.Does NXIVM pay fees to First

Principles to license the material- rationalinquiry method?

A. It does.Q. Okay. Looking at Salzman 24, do

you know why there are various agreements betweeMs. Cafritz and First Principles ESP forlicensing?

A. Because she had originally __ it'smy understanding that she was the first person whoKeith gave rights to his model to.

Q. And those rights now are held byFirst Principles, among -- and I guess these otherthree organizations that you just mentioned?

A. First Principles.Q. First Principles?A. First Principles can license the

material.Q. Okay. What is Buyer's Advocate?A. It was a company that Pamela owned.Q. Is it still in business?


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Q. Is the idea to have this functionas an elementary school and a junior high schoolor is it to be an after school program?

A. I think it will function as its ownschool system, but it's not there yet, so thatwould be my hypothesis.

Q. Understood. Do you know ifstudents at Jness are required to signconfidentiality agreements?

A. They are.Q. How about teachers of Rainbow

Gardens?A. They are.Q. And how about students at Nataraja?


1 SALZMAN - DAY "2 A. It will be eventually, when we3 develop the full curriculum, everything:4 Preschool, elementary education, and whatever you5 call junior high.6 Q. Middle school?7 A. Right. Middle school. It right8 now is focused on preschool children. Our9 programs usually are kind of organic in nature,

10 and they start from the basic and work their way11 up.1213141516171819202122232425

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1 SALZMAN - DAY II 12 A. It's not active. 23 Q. Okay. What did it do? 34 A. It originally taught people sales 45 skills and how to market. 56 Q. Did it use rational inquiry? 67 A. You know, it was before my work 78 with Keith. My hypothesis is it was designed to 89 do that, but we decided not to use it in -- it was 9

lOan early iteration of an enrollment company. 1011 Q. SO, as far as you know, it never 1112 used rational inquiry? 1213 A. No. 1314 Q. What are the terms in wbich Keitb 14

15 transferred ownership of rational inquiry to Firs 1516 Principles? 1617 A. We have an agreement, a licensing 1718 agreement. 1819 Q. And what did -- did First 192a Principles pay Keith for the rational inquiry 2a21 method? 2122 A. No, not in money. 2223 Q. How did it pay him? 2324 A. It was an agreement to uphold a 2425 standard that he -- an ethical standard that he 25


SALZMAN - DAY IIwanted.

Q. Does Keith Raniere have the rightto take back ownership of rational inquiry if hedoesn't believe that First Principles or the othercompanies are upholding that standard?

MR. MC GUIRE: Object to the formof the question. Go ahead and answer.

A. He does.Q. It's your understanding that if he

asked you to convey it back, that you would do so.A. I would.Q. Okay. Have any payments been made

to Mr. Raniere by NXIVM or First Principles?A. No.Q. Has the rational inquiry method

been patented?A. It bas a patent pending.Q. Do you know what the status of that

patent application is?A. Pending.Q. Has the patent application ever

been rejected?A. It has not.Q. How long has that application been


t

1 SALZMAN - DAY II2 pending?3 A. Since 2003.4 Q. Does First Principles have any5 sources of income other than the licensing fees i6 receives from rational inquiry method?7 MR. MC GUIRE: If you know.8 A. I don't believe so.9 Q. Okay. Just to confirm, you're the

10 president and sole owner of First Principles?11 A. Correct.12 Q. Does First Principles pay any13 licensing fees to third parties?14 A. Does it pay licensing fees? No.15 (Exhibit Salzman 25 marked for16 identification.)17 MR. KOFMAN: And Salzman 25 is a18 document that was -- a two-page document19 produced to us in discovery, Bates Stamp Nos.20 SP-2278 througb SP-2279.21 Q. Do you recognize this document?22 A. I don't think I've ever seen it23 before.24 Q. Who is Fruci & Associates?25 A. They are an accounting firm that we


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1 SALZMAN - DAY II2 A. Yes, in the same way that I did in3 the other curriculums.4 (Exhibit Salzman 26 marked for5 identification.)6 Q. Do you recognize this document?7 A. I think I saw it. I've seen it8 before.9 Q. Turning to page 7.lOA. That's my signature.11 Q. That saved me a question. I'd like12 you to take a look at Paragraph 9, which is on the13 top ofthe third page.14 MR. SKOLNIK: This is Salzman 25?15 MR. KOFMAN: Yes.16 MR. MC GUIRE: 26.17 Q. Turning to the top ofthe third18 paragraph, Paragraph 9, it says:19 "The first full training materials20 for the training program are written materials21 developed by NXIVM and its consultants using th22 pending patents of First Principles, Inc."23 And then it goes on. Who were the24 consultants that you were referring to in25 Paragraph 9?


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SALZMAN - DAY IIuse.

Q. Do you review income statements forFirst Principles?

A. Karen Unterriener goes over thosewith me, but she reviews them and then reports tome.

Q. Do you see on the second page,under the column"expenses," it says licensingfees at 782,246.32?

A. It does say licensing fees.Q. Do you know what that refers to?A. I don't.Q. Okay.A. I don't.Q. Did anyone hesides Keith Raniere

develop rational inquiry?A. He developed the concepts, and I

developed the modules, the educational modulesthat teach.

Q. Anyone else that you're aware ofinvolved in the creation of rational inquiry?

A. Ivy Nevares participated, I think,in the development of the Ultima curriculum.

Q. The Ultima curriculum?TSG Reporting - Worldwide (877) 702-9580

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SALZMAN - DAY IIA. Myself, Ivy Nevares, Lauren

Salzman, and Karen Unterriener.Q. They were all involved in creating

the manuals?A. Not writing them, the rational

inquiry model, but in the manuals to teach thewriting effort.

Q. SO, they all took the rationalinquiry method and used that to create theteaching, the student manuals?

A. They took the modules that I wroteand created manuals out of those modules. Theyedited them, looked for consistency, worked tocreate and put together, based on my direction.And possibly Nicki Clyne.

Q. Nicki Clyne?A. Yes.Q. Has NXIVM ever posted any of its

course materials on the Internet?A. I don't believe so.Q. Has the mission statement ever been

posted on the Internet?A. I believe it was posted for a very

short period of time, but I'm not sure.TSG Reporting- Worldwide (877) 702-9580

SALZMAN - DAY IIQ. In connection with this litigation,

has NXIVM compiled a list of its competitors?A. I don't know if we ever compiled a

complete list.Q. Have you compiled a partial list?A. I don't know that we've ever

compiled a partial list. We've considered who owcompetitors are.

(Exhibit Salzman 27 marked foridentification.)

Q. Ms. Salzman, do you recognize thisdocument?

A. I have seen it before.Q. I'd like you to turn to

Interrogatory No. 33.A. What page is that?Q. It starts on page 31 and it

continues.(Recess taken.)

Q. Ms. Salzman, have you had a chanceto review Interrogatory No. 33?

A. Not the whole thing.Q. Does this represent a list of aU

of the entities, all of the people that NXIVMTSG Reporting - Worldwide (877)702-9580

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1 SALZMAN - DAY II2 Q. Do you know when that was?3 A. I don't.4 Q. Do you know who might have5 knowledge ofthat?6 A. Karen Unteniener.7 Q. Do you know whether anything else8 was posted on the Internet?9 A. Anything else?

10 Q. Any other materials, NXIVM course11 materials?

. 12 A. I don't believe so.13 Q. Do you know why it was posted?14 MR. Me GUIRE: Object to the form15 of the question. She didn't say it was.16 MR. KOFMAN: Okay.17 A. To the best of my memory, someone18 from our commerce department liked it and thought19 it was a good idea, and didn't go through the20 proper channels. And as soon as it was posted, we21 took it down.22 Q. How long was it up?23 A. A number of days. And that's to24 the best ofmy knowledge and recollection of the25 events that occurred.


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1 SALZMAN-DAY II 12 considers competitors? 23 A. We're not sure if it's all, but 34 it's a pretty good list. 45 Q. Are you aware of any competitors of 56 NXIVM that aren't on that list? 67 A. I didn't read it all. Do you want 78 me to read it all? 89 Q. We can do that maybe later In the 9

10 dep. How was this list compiled? 1011 A. We started looking at types of 1112 organizations that did things that are -- modeled 1213 us, and would compete in the same market, for the 1314 same people. 1415 Q. What is NXIVM's market? 1516 A. These different subtitles. It says 1617 it right here in the third paragraph. Do you want 1718 me to read that? 1819 Q. Ifyou could. 1920 A. It says: 2021 "Without waiving and foregoing 2122 objections, or those stated in general objections, 2223 plaintiffs state that they have not conducted such 2324 an analysis on their own. However, plaintiffs 2425 believe that their competitors include companies 25


SALZMAN - DAY IIthat provide services included but not limited tothe following: Behavior change, businessconsulting, change management, cognitive therapy,communications specialists, communications theory, s

corporate restructuring, corporate strategy, ,corporate turnaround, cost reduction, valueoptimization, consulting nonmedical, creativethinking, and innovative thinking workshops,creative thinking consulting, critical thinkinganalysis, entrepreneurship, ethics, ethicsconsulting for business, ethics consulting forgovermnent, executive coaching, executivetraining, existential humanistic psychology,financial restructuring, goal-oriented brieftherapy, goals achievement, government consulting,govemment streamlining, holistic health, huroanperception, human performance, human resourceconsulting, outsourcing, humanistic psychology,hypnotherapy, innovative R&D leadership training,motivational speaking, optimal functionaltraining, personal coaching, personal development,personal development coaching, personal growth,positive psychology, problem solving coaching,problem solving consulting, problem solving


A. Our training develop people who canperform those services.

Q. Does NXIVM engage in psychiatry?A. It does not.Q. Then why would you say that

psychiatry is a -- people who engage in psychiatryare competitors?

A. Often times people who engagepsychiatrists engage psychiatrists because theyhave an inability to make decisions effectively,as opposed to a medical reason.

If they had more effective decisionmaking strategies, they might not believe theyneed to go to a psychiatrist.


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1 SALZMAN - DAY II2 workshops, professional coaching for business,3 psychology, psychiatry, self-help, social work,4 sports performance, sports psychology, succession5 in governance, systems design, systems6 sustainable, systems analysis, systems thinking,7 team building, team development, team integration,8 think tanks, and training and seminars in9 persistence and motivation.

10 Q. Does NXIVM perform all ofthose11 services?1213141516171819202122232425

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1 SALZMAN - DAY II2 Q. Would the same be true for your3 listing of psychologists?4 A. Yes.S Q. How about corporate turnaround?6 Does NXIVM perform corporate turnaround work?7 A. Keith has developed a model called8 RMS, and RMS is Raniere Management System, and it9 has outlined that model.

10 Q. Is that taught at NXIVM?11 A. It's used at NXIVM. And I12 developed it with Keith back in 1998 when he was13 mentoring me and I was working at ConEdison in14 their nuclear power plant, Indian Point 2.15 Q. Are all psychiatrists competitors16 ofNXIVM?17 A. I don't know.18 Q. What types of psychiatrists would19 be competitors of NXIVM?20 A. Psychiatrists who see clients who21 have problems with decision making.22 Q. And that's hecause NXIVM believes23 that it can help people who have problems with24 decision making?25 A. Correct.


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1 SALZMAN - DAY II 12 Q. Is there any geographical 23 limitation to whom NXIVM considers a competitor? 34 A. Anywhere where someone might come 45 to take our programs that knows someone else who 56 had taken our programs that would invite them. 67 Q. SO, that potentially is worldwide. 78 Correct? 89 A. It could be. 9

10 Q. Who from NXIVM put together this 1011 list or how was it put together? Strike that. 1112 Let me make it clear. How was the list put 1213 together? 1314 A. There were a series of -- I think 1415 it was a brainstorming session, where a group of 1516 people sat down and created this. 1617 MR. LEONARD: Did that group 1718 include lawyers? 1819 THE WITNESS: I believe it did. 1920 Q. You also mentioned social workers 2021 in that list. How do social workers compete with 2122 NXIVM? 2223 A. Social workers will often work with 2324 people who have different types of personality 2425 issues that they feel limited in resolving, and, 25


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SALZMAN - DAY IItherefore, their beliefs limit them. Socialworkers will often engage in individual work orgroup work with people who have problems withdecision making.

Q. You mentioned succession ingovernments. What's that?

A. Succession planning?Q. Yes.A. It's how to plan to recreate

yourself after you are gone, so that whatever itis that you're doing can be reproduced by someoneelse.

Q. That's at a business?A. Yes. It's called succession

planning. If you don't plan properly, then whenyou leave, there's a -- you can't continue to dothe business in the way the business was beingdone when you were there, and, therefore, you makeyourself indispensable, as opposed to making amodel that can be reproduced again and again.

Q. Does NXIVM teach successionplanning?

A. Yes.Q. And is that part of the curriculum?


1 SALZMAN-DAY II Page 23311 1

2 A. Yes. 23 Q. Okay. Does NXIVM teach hypnosis? 34 A. No. 45 Q. How are organizations that teach 56 hypnosis competitors of NXIVM? 67 A. People who engage in going to 7

8 hypnotherapists are usually dealing with 89 problematic areas in their life that could be 9

10 addressed in other ways. Mostly it's decision 1011 making again. 1112 Q. SO, anyone in any organization 1213 that's trying to get to the same end as NXIVM is a 1314 competitor? 1415 A. I would think so, because we would 1516 be competing for the same market. 1 617 Q. Before students takes classes at i 718 NXIVM, are they asked whether they have any 1819 experience in any of these types of organizations? 1920 A. They are. 2021 Q. When in the process are they asked? 2122 A. By the person who introduces them 2223 to the program or to the field trainer. 2324 Q. SO, the person who introduces them 2425 to the program, how do they know to ask somebodj 25


Page 235

1 SALZMAN - DAY II 12 What does NXIVM - does NXIVM do 23 anything to make sure that I've done this 34 screening for the person. 45 A. Yes, we do. 56 Q. What do you do? 67 A. The field trainer -- the way that 7

8 an application is processed, it has to go through 89 a field trainer, and the field trainer does a 9

10 check on that. And if the person seems to be 1011 involved in one of these fields, the person has to 1112 have the interview, and then if they are in this 1213 field, we explain to them what the -- there's a 1314 discussion that ensues, and we make a 1415 determination whether this would conflict with 1516 their gainful employment or not. 1617 Q. SO, NXIVM's field trainers 1718 review the applications to determine whether 1819 there's anything that reveals whether they've 1920 had- 2021 A. Every-- 2122 Q. Let me finish the question. 2223 NXIVM looks at the field trainers 2324 who look at the applications to see whether or not 2425 someone has had experience with one of these type 25


Page 234

SALZMAN - DAY IIwhether they have experience with one of thesetypes of organizations?

A. It's a fact that we -- that weperpetuate within the organization. I mean, it'sa company that you have to be invited to come toone of its programs.

Q. And if) were a NXIVM student whowanted to refer another student to the class, howwould I know to ask them whether they've had an)experience with, say, hypnotherapy?

A. Because we teach that to them. Welet me them know, if they're interested inbringing their friends, who would be somebody whowould be able to take the program or fit thecriteria.

Q. When are they taught that?A. If they have a desire to enroll -

because we don't do that in classes, but iftheyhave a desire to enroll, they can meet with afield trainer who helps them understand who wouldfit the program and what it would mean to enrollin the program.

Q. Now, let's say I've taken a class,and I've referred somebody to NXIVM.


Page 236

SALZMAN - DAY IIof groups?

A. Yes, because it's a personalrecommendation. The field trainers discuss, withthe people in their organization, who's coming in.

Q. What is the field trainers'organization? What do you mean by that?

A. Each one of the -- everyapplication that is submitted for a newparticipant in our program has to be submitted bya field trainer. So, the field trainer caninterview anyone in their own organization.

So, when you -- if you are someonewho wants to enroll someone, you have to choose a J

field trainer, and then you have to tell the fieldtrainer who you're bringing in.

Q. Are the field trainers given a listsimilar to the list that you just read ofthetypes of organizations that NXIVM considers to b .competitors?

A. No.Q. How would a field trainer know that

corporate turnaround is considered a competitive ~

field for NXIVM?A. To be a field trainer in my


«

1 SALZMAN - DAY II 12 organization, you have to go through a very 23 rigorous training and meet a series of criteria, 34 and through that criteria, they learn this. 45 Q. Have psychiatrists and 56 psychologists become students at NXIVM? 67 A. They have. 78 Q. Can you estimate how many? 89 A. Very few. Maybe under ten. 9

10 Q. Under ten? And that's because of 1011 the screening process that you just described? 1112 A. If a psychologist or a psychiatrist 1213 has a private practice, and this would interfere 1314 with the way that they do therapy, then we advise 1415 them not to come in. 1516 If they do something else, and they 1617 don't have a private practice as a way ofearning 1718 money, and they want to learn the model, it's more 1819 appropriate for them to study. 1920 MR. KOFMAN: Please mark this with 2021 the next number. 2122 (Exhibit Salzman 28 marked for 2223 identification.) 2324 Q. Are you familiar with this 2425 document? 25


Page 239

1 SALZMAN - DAY II 12 Q. What do you mean by "misquoted"? 23 A. I think I probably gave that 34 information to someone over the phone, and I don't 45 believe it's accurate with respect to 56 psychiatrists and psychologists, although it is 67 with respect to doctors. 78 We have had psychiatrists and 8

9 psychologists take our program, but very few. I 910 think in addition, the reason that this may have 1011 been misquoted was because there was a 1112 psychiatrist who took a class with Kristin, and he 1213 didn't recognize anything unusual about her 1314 behavior. 1415 Q. Okay. Are you familiar with the 1516 form application that NXIVM uses for new students? 1617 A. The short form? 1718 Q. Yes. 18

19 A. Yes. 1920 Q. That's a one-page document that has 2021 writing on the front and the back? 2122 A. Correct. 2223 Q. Wbo drafted that or did you have 2324 any involvement in the drafting of that document? 2425 A. I believe Karen Unterriener drafted 25


Page 238

SALZMAN - DAY IIA. I was just reading. Yes.Q. Are you familiar with that

document?A. Yes.Q. What is that?A. It is a directive that went out

throughout my company after the article brokeabout Kristin Snyder's death, a year after herdeath.

Q. Who drafted it?A. I did.Q. Okay. Did you try to make sure

that everything in this was accurate?A. I did.Q. And to the best of your knowledge,

is everything in here accurate?A. Yes. Just to clarify, we've had

many medical doctors take our program, very fewpsychologists or psychiatrists.

Q. Okay. Although that statement thatyou issued said "we've had numerous doctors,psychiatrists and psychologists," what you mean.there, that you had had only numerous doctors?

A. I think it was misquoted.TSG Reporting - Worldwide (877) 702-9580

Page 240

SALZMAN - DAY IIthat document with Arlin Olsen.

Q. Okay. Does NXIVM require a studenttn sign an application for each class that thestudent attends?

A. Each class?Q. Yes. For example, each session of

classes - for example, ifl take a 16-dayintensive and then a five-day intensive, am Irequired to sign the application before botbclasses, the short form application?

A. Yes.Q. SO, if I take four sets of classes,

I'm required to sign four applications?A. It's the application to get into

the class, so, yes.Q. Okay. Are there any instances

where a student would not be required to sign anapplication before taking a particular class?

A. It's the enrollment applicationthat the administrative office uses, so I thinkthat it's necessary.

Q. Okay. When in the process ofenrolling a student does NXIVM require tbe studento take tbe - to sign the application?


1

23456789

10111213141516171819202122232425

Page 2411

SALZMAN - DAY IIA. When they're applying to take the

program.Q. Before they start taking the

program?A. That's correct.Q. Does NXIVM provide the student wit

materials before they've signed the application?A. Not routinely.Q. What about any promotional

materials? You mentioned the Ethos brochure.A. Not routinely.Q. On occasion?A. On occasion.Q. Wh at does NXIVM do once it receives

a signed application? What does it do with theapplication?

A. When we get it up from the fieldtraining in corporate?

Q. Yes.A. They process it. They enter it

into a database. They're assigoed a studentnumber, and they're added to a list for whateverprogram they're going into.

Q. You mentioned that Ms. UnterrienerTSG Reporting - Worldwide (877) 702-9580

Page 242

1 SALZMAN· DAY II2 and Mr. Olsen were involved in the drafting of th3 agreement. Did you review and approve the4 language after it was drafted?5 A. I read it over, but I let Arlin6 make the final decision.7 Q. You did not have any changes to8 the language or any of the - strike that.9 You didn't have any objections to

10 the language that's presently used. Correct?11 A. I did not.12 Q. Does NXIVM require students to13 return course materials after they've taken14 after they leave the group?15 A. At times.16 Q. When?17 A. When we determine that it's18 important that they do.19 Q. Can you think of examples when20 that's happened?21 A. The -- some of the people who most22 recently left the company, we asked them to return23 the materials.24 Q. That's Ms. Bouchey and the seven25 others I think you mentioned?


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Page 243

1 SALZMAN - DAY II 12 A. That's correct. 23 Q. Can you think of any examples other 34 than those? 45 A. On some occasions, students have 56 given them back to me because they wanted not to 6

7 keep them. 78 Q. Any other examples that you can 89 think of? 9

10 A. Yes. There were a limited number 1011 ofpeople who came to intensives who were asked to 1112 leave, and we asked them to get the -- in the 1213 first five days. And in those circumstances, we 1314 asked for the materials back. 1415 Q. Why were they asked to leave? 1516 A. We didn't think they were 1617 appropriate for our program. Actually, we didn't 1718 think our program was appropriate for them. 1819 (Exhibit Salzman 29 marked for 1920 identification.) 2021 Q. Ms. Salzman, do you know what the 2122 document marked as Salzman 29 is? 2223 A. Yes. This is our confidentiality 2324 agreement. 2 425 Q. This is also known as the long form 25


Page 244

SALZMAN - DAY IIconfidentiality agreement?

A. That's correct.Q. Did you have any role in drafting

this?A. Yes.Q. What role did you have?A. I participated with Keith Raniere

and Arlin Olsen in its creation.Q. When was that?A. In the very beginning before we

started teaching classes.Q. What is the purpose of this

agreement?A. To protect our intellectual

property.Q. Does NXIVM require a student to

sign a long form confidentiality agreement before "each class that they take?

A. No.Q. When is it required?A. Before intensives and before

classes in our Ethos program.Q. SO, before each intensive a student

takes, they're required to sign a long form


SALZMAN - DAY IIA. If they are a student who meets

directly with someone who has the long form whenthey first sign up, they're asked to sign it.After they complete the short form, they get thisin a packet. If on occasion -- and almost alwaysthat happens, before an intensive, or before theEthos program they're asked to bring it. Some ofthem don't bring it with them, and then they haveto sign it when they come to the first class.

Q. What does NXIVM do with the signedconfidentiality agreements after they receivethem?

A. They're filed.Q. Where?A. We have file cabinets in the

document room.Q. Is the document room locked after

business hours?A. It is.Q. And who has keys to that?A. Kristin Keeffe and members of our

legal team. Karen Unterriener and selectedmembers of her team.

Q. Was that true in 2001?TSG Reporting - Worldwide (877)702-9580

Page 246Page 245 i 1

23456

7

89

10111213141516171819202122232425

1 SALZMAN - DAY II2 confidentiality agreement?3 A. No. They need to sign this one4 before their intensives.5 Q. SO, if they take two intensives,6 they're only required to sign this once?7 A. It's binding in all of their8 intensives.9 Q. Okay. Does this

10 agreement provide -- to the best of your11 knowledge, does this agreement provide any12 protection to NXIVM that isn't provided by the13 application?14 MR. Me GUIRE: Object to the form15 of the question. Go ahead.16 A. I'm not a lawyer, and I -- I don't17 know specifically, but I wanted an agreement that18 would protect us so that the students had an19 understanding, a greater understanding. And I20 thought that the long form better explained to21 them what was -- what they were being asked of in22 the intensive.23 Q. After - when in the process does a24 student ordinarily sign the long form25 confidentiality agreement?


Page 247 Page 248

SALZMAN - DAY IIA. They were stored in a different

room back in 2001, but now because we have somany, they're stored with the other things -- theother legal documents.

Q. Where were they stored in 2001?A. They were stored in the proctor

1 SALZMAN - DAY II2 A. I did.3 Q. SO, proctors and above?4 A. Proctors and above, yes. Oh, I'm5 sorry. Yes. Proctors and above.6 Q. And that was also where the7 curriculum was kept?8 A. That's correct.9 Q. Would that include facilitator

10 notes and coach's notes?11 A. That's correct.12 Q. Okay. What is an exploration of13 meaning?14 A. An exploration of meaning is the15 term that is used to describe the individual ,16 process that we use when somebody has a limiting ~17 belief and they want to disconnect the stimulus18 response.19 Q. Is that - is an exploration of20 meaning something that is uniqne to NXIVM?21 A. To the best of my knowledge, it is22 something that is unique to NXIVM or unique to23 rational inquiry.24 Q. Is it part of the rational inquiry25 method?


That would be proctors.And only proctors?Only proctors.Was it locked at night?It was.Okay. How about -

room.

123456789 Q. Where's the proctor room?

10 A. That's where we store the student11 notes and the curriculum. It was outgrown, and12 also our curriculum now is larger, so we needed13 more room for other things. So, we shifted things14 around about three years ago.15 Q. Who had access to the proctor room16 in 2001?17 A.18 Q.19 A.20 Q.21 A.22 Q.23 A. It's actually locked all day long.24 You have to know a combination to get in.25 Q. Did you have access to it?


I

Page 251

Did she leave the group?I believe she did.What were the circumstances?

case.Q. For this deposition?A. Uh-huh.Q. Did you see it back then?A. I probably did.Q. Do you see the reference to


Q. It was not a student application?A. It was not.Q. Okay. The last page ofSP-1202

contains what purports to be a student enrollmentapplication for Ms. Soble,

Can you see that that .decumentis


1 SALZMAN - DAY II2 A. Yes.3 Q. It is part of it. And to the hest4 of your knowledge, no competitors are engaged i5 explorations of meaning?6 A. I've never been shown anything7 that's remotely like it from any other model.8 Q. Are you familiar with someone named9 Helen Sobie?

10 MR. Me GUIRE: You have the wrong11 name, I think.12 Q. Are you familiar with a Helen13 Sohie?14 A. I believe she was a student a15 number of years ago, or a participant in my16 program.17 Q.18 A.19 Q.20 A. If she's the person that I think21 you're speaking about -- and the reason I'm having22 difficulty is because she had a Sanskrit name that23 she went by, and I didn't know her real name.24 Q. Is it Nirbhaya Sohie?25 A. That would be it. Nirbhaya worked


1 SALZMAN - DAY II2 Ms. Sobie was making a claim for commission sh3 thought she'd earned?4 A. That's true. That's what she5 thought.6 Q. Well, what did you do after you7 received the letter?8 A. I gave it to my legal team.9 Q. Who was that?lOA. At the time, I gave it to Les11 Apple, who was my attorney.12 Q. Was he the attorney for NXIVM?13 A. He was.14 Q. The front page is a letter dated15 July 23rd, 2002, from Karen Unterriener to16 Mr. Apple?17 A. Correct.18 Q. Have you seen that before?19 A. I saw it in preparing for this202122232425

Page 250

1 SALZMAN - DAY II2 for a woman named --3 MR. MC GUIRE: There was no4 question.5 Q. Who was Nirbhaya Sobie?6 A. She was a participant in the7 program.8 Q. Okay. Did she ever hold a - was9 she ever a facilitator?lOA. I don't remember.11 (Exhibit Salzman 30 marked for12 identification.)13 MR. KOFMAN: And these are14 documents that were produced to us in15 discovery. They bear Bates Stamp Nos. SP-1l9916 through SP-1202.17 Q. Are you familiar with these18 documents?19 A. Yes.20 Q. The first page is a letter - the21 second page, actually, is a letter from an22 attorney, from Ms. Sobie, to you, dated June 22nd23 2002. Did you receive that letter in 2002?24 A. I did.25 Q. And was it your understanding that


Page 252

1 SALZMAN - DAY II2 under the paragraph "I have included the following3 documents," the last bulletpoint is:4 "Ms. Sobie should have been5 required to sign the confidentiality agreement.6 I've been unable to locate our copy of that7 agreement. 1 will forward it to you if I can8 locate it."9 Do you see that?

10 A. Yes.11 Q. Did NXIVM ever locate a copy of the12 confidentiality agreement signed by Ms. Sobie?13 A. I don't know.14 Q. Okay. The next sentence it says:15 "Several points to note: Ms. Sobie16 never signed her application."17 A. That refers to the application for18 the terms of three and it's free. It's a program19 we had.202122232425

•

•

•

1 SALZMAN - DAY II 12 not signed? 23 A. I do see that. 34 Q. Do you know whether NXIVM has a 45 signed application for Ms. Sobie? 56 A. I do not. 67 Q. In the first paragraph it refers 78 to: 89 "We would like for the response to 9

10 include a suit for malicious tort that she has 1011 told will be filed with the matters unresolved." 1112 What did NXIVM contend Ms. Sobie 1213 had done? 1314 A. Ms. Sobie was an employee of one of 1415 our representatives, Jeanie Sterner, and she was 1516 receiving compensation from Ms. Sterner for her 1617 work and wanting to be recompensated by us, when 1718 Ms. Sterner was being compensed for those sales. 1819 Q. Was there anything else that NXIVM 1920 thought constituted a malicious tort? 2021 A. She was perpetuating, I think, this 2122 information throughout the organization. 2223 Q. What information? 2324 A. That it was unethical that she 2425 couldn't get recompensed, but I think there were 25

TSG Reporting- Worldwide (877)702-9580

Page 255

1 SALZMAN - DAY II 12 MR. KOFMAN: Yes, that might be it. 23 MR. MC GUIRE: And Salzman 30 also 34 contained a JJO number. Correct? 45 MR. KOFMAN: That's correct. 56 Q. Ms. Salzman, are you familiar with 67 this document? 78 A. No, I'm not. 89 Q. Did you ever see this back in 2002? 9lOA. I don't think that I did. 1011 Q. Who are Barbara Jeske and Carole 1112 Bergeron? 1213 A. Barbara Jeske was the field trainer 1314 who enrolled Jeanie Sterner and her organization. 1415 And Carole Bergeron, I think, worked with Barbara 1516 Jeske. 1617 Q. Are they both still involved with 1718 NXIVM? 1819 A. Barbara Jeske is a very high-level 1920 participant in the program. She has the highest 2021 level -- she holds the highest level. She's been 2122 around since we started the company. And Carole 2223 Bergeron is a proctor. 2324 Q. Okay. What's Barbara Jeske's level 2425 called? 25


Page 254

SALZMAN - DAY 11other things too, and I don't remember them all.

MR. KOFMAN: Let's mark this asSalzman 31.

(Exhibit Salzman 3I marked foridentification.)

MR. MC GUIRE: Let the record showthat Salzman 30, the July 23,2002 letter, mayhave been something that was inadvertentlyproduced. It seems to me that that's clearlyprotected by the attorney/client privilege.

MR. KOFMAN: I think it's probablybeen waived as to that document. We can fightabout that later.

MR. MC GUIRE: Okay. I just wantthe record to note my observation.

MR. KOFMAN: And, for the record,Salzman 31 is a three-page document markedBates Stamp Nos. SP-1204 through SP-1206.

MR. MC GUIRE: As well as?MR. KOFMAN: As well as a pair of

Bates Stamp Nos. JJO-00097 through JJO-00097.It's an interesting method.

MR. MC GUIRE: I think there is adigit left off.


Page 256

SALZMAN - DAY IIA. Senior counselor.Q. Turning to the last page of tbis

document, under "Testimony of Carole Bergeron."A. Yes.Q. It says:

"Nirbhaya also shared witb me thatwhile she and others were slandering the company,and the tecbnology, and the people in it, theywere also breaching contracts that they had signedby nsing the very technology that tbey werespeaking witb dishonor about by baving regular ENparties (a tecbnical part oftbe tecbnology is anEM or exploration of meaning.) I explained to berthat this was a serious ethical breach, as well asa legal breach of contact, and sbe said sbe knewthat.

Were you aware, in 2002, thatNirbhaya Sobie was slandering the company?

A. I think back then I was aware ofit. I think I just said that.

Q. And what was she saying about tbecompany that you were aware of?

A. Back then she was questioning theethics of the company, and the practices of the


1 SALZMAN - DAY II 12 company in a way that I believed was slanderous. 23 Q. Was she doing it in public? 34 A. With these groups of people. 45 Q. And were you aware, in 2002, that 56 she was using the technology to conduct EM 67 parties? 78 A. I don't remember now. 89 Q. What was Barbara Jeske's rank in 9

10 2002? 1011 A. She was either a senior proctor or 1112 a counselor. 1213 Q. How about Carole Bergeron? Was ShE 1314 a proctor back in 2001? 1415 A. I think she was a coach. 1516 Q. Okay. How did the situation with 1617 Ms. Sobie resolve? 1718 A. She resigned and left the company. 1819 Q. Was a commission ever paid to her? 1920 A. No. 2021 Q. Did NXIVM ever take any action 2122 about the allegation that she was conducting EM 2223 parties? 2324 A. Yes. We asked her to stop. Not 2425 legal action, no, and she said she would. 25


Page 259

1 SALZMAN - DAY II 12 were recently trained, but it's been a long time. 23 (Luncheon recess: 12:45 p.m.) 34 THE WITNESS: This document was in 45 the documents that Joe O'Hara created, and it 56 was never sent out. 67 Q. And by "this document," to what are 78 you referring? 89 A. Exhibit 28. 9

10 Q. Okay. I believe you testified this 1011 was something that you wrote or dictated. Is tha 1112 the case? 1213 A. Yes. And he wrote this up as a 1314 result of that, and it was never sent. It was 1415 never approved. 1516 Q. Okay. So, you dictated something 1617 to him, he wrote it up, but it was never approved 1718 for dissemination? 1819 A. I dictated a series of notes, and 1920 he wrote this up as a result of what I dictated, 2021 which was his interpretation of that, and his 2122 ideas. 2223 Q. Okay. 2324 A. Andldidn'tagree,anditnever 2425 went out. 25


Page 258

SALZMAN - DAY IIQ. And she said sbe would?A. And she resigned.Q. There's some other people who are

mentioned in these letters. There's a MichaelVanderHoof!

A. Yes.Q. Are you familiar with him?A. lam.Q. Do you know if he was involved in

these EM parties?A. He was. Well, he was involved with

her. I don't know ifhe was involved in the EMparties.

Q. Okay. Did NXIVM ever ask him tostop doing anythiug?

MR. MC GUIRE: I object to thatquestion. There's no basis in this paper.

A. Does it says that he was involvedin the EM parties?

Q. Do you know who the others werethat were slandering the company in this lastparagraph besides Nirbhaya?

A. You know what? Back then Iremember knowing who were they were because they


Page 260

SALZMAN - DAY IIQ. Looking at the document we marked

as Salzman 30, do you know why there are two setsof Bates Stamp numbers on there? There's SP-1l99and then through SP-1202, and also Bates Stampnumbers with a JJO number?

MR. MC GUIRE: I can explain that.I'mnot sureshe would.

MR. KOFMAN: Okay.MR. MC GUIRE: 110 documents were

produced in this case , and there was asupplemental production made by NXIVM afterthat, which included the 110 documents thathad been served.

MR. KOFMAN: Okay.MR. MC GUIRE: That's my

understanding of how that happened.MR. KOFMAN: Okay. Thank you,

counselor.MR. MC GUIRE: You're welcome.(Exhibit Salzman 32 marked for

identification.)MR. KOFMAN: Salzman 32 is a

document produced to us in discovery. Itbears Bates Stamp Nos. P000004110 and 4111,


•

4

1 SALZMAN - DAY II 12 and it purports to be a student enrollment 23 application for Stephanie Franco. 34 Q. Ms. Salzman, is this the form of 45 application that you were testifying about earlier 56 this morning, the application form? 67 A. Yes, this is the application form. 78 Q. And was that the application form 89 that NXIVM used in 200I? 9

10 A. It is. 1011 Q. Has NXIVM changed the language of 1112 the application form since 2001? 1213 A. I'm not sure. 1314 Q. Okay. Looking at Paragraph 1 under 14

15 student terms and conditions, are you familiar 1516 with thatianguage? 1617 A. Yes. 1718 Q. And that's language that you 1819 reviewed? 1920 A. Yes. 2021 Q. Okay. What does the - in the 2122 sentence "these materials, methods and information 2223 cannot be copied, duplicated, transmitted, taught 2324 or otherwise used in part or in whole," what is 2425 the phrase "otherwise used" mean? 25


Page 263

1 SALZMAN - DAY 11 12 What would he an indirect use of 23 the materials that would be prohihited by this 34 agreement? 45 MR. MC GUIRE: Same objection as to 56 furm. 67 MR. KOFMAN: Okay. 78 A. Where is that? 89 Q. The sentence that I read to you 9

10 said: 1011 "These materials, methods and 1112 information cannot be copied, duplicated, 1213 transmitted, taught or otherwise used, in part or 1314 in wbole, directly or indirectly, without express 1415 written permission of ESP.ft 1516 My question is what would he an 1617 indirect use? 1718 A. To give it to someone else that 1819 would disseminate it. 1920 Q. Okay. Would this language prohibit 2021 someonefrom - strike that. 2122 Would a student discussing the 2223 NXIVM materials to someone outside the group in a 2324 negative fasbion be prohibited by these terms and 2425 conditions? 25


Page 262

SALZMAN - DAY IIMR. MC GUIRE: Object to the form

of the question, but you can ask herunderstanding.

Q. What's your understanding of thephrase "otherwise used"?

A. That anything like that otherwiseused would be included, duplicating them,transmitting them, any way that you would do that.

Q. Okay. What are the methods - Iunderstand the materials, the phrase "thesematerials." What were you referring to or what isNXIVM referring to as to the term "methods"?

A. The processes that they learn inESP or any of the other companies.

Q. Okay. And how ahout the word"information"? What does information mean in thasentence, to your understanding?

A. To my understanding, anything thatthey learned that is new to them that is taught byour technology.

Q. SO, anything that they would hearat a NXIVM training class that is new to them?

A. That's right.Q. Okay. How would - strike that.


Page 264

SALZMAN - DAY IIMR. MC GUIRE: Same objection.

A. I don't understand the question.Q. Would this agreement prohibit a

student from discussing NXIVM's materials innegative way with someone outside the group?

A. If they're voicing an opinion aboutthe information, as opposed to teaching theinformation, it wouldn't be prohibited. Peopleare entitled to have opinions.

Q. What if someone said, you know, Ilearned about these explorations of meaning,here's how you do it, and I think it's bunk?

Would that be prohibited?MR. MC GUIRE: Same objection.

A. If they're teaching?Q. Yes. If they explain what an

exploration of meaning is?A. If they explain what an exploration

of meaning is without teaching it.Q. Okay.A. If I'm teaching it, attempting to

teach how to do it, or teaching someone else howto do it, that's very different than saying thisis what it is.


I51

1 SALZMAN - DAY II J 12 Q. And how about -- strike that. 2

3 So, the use that would be 3

4 prohibited would be the teaching of the materials. 45 A. Yes, or disseminating the 5

6 information itself that is included in it. 67 Q. Okay. Would disseminating the 7

8 information for the purpose of trying to get 8

9 someone to join NXIVM be prohibited? 910 A. Yes. 10

11 Q. SO, if someone said Itook this 1112 class, they had exploration of meanings where you 1213 do this to get this result, that might be 1314 probibited? 1415 A. No, that's fine. 1516 Q. Okay. What would be a prohibited 1617 use of the materials other than teaching? 1718 A. Let's say I was writing an article, 1819 and I included the concepts within the article as 19

20 though they were my concepts. 2021 Q. Okay. How about if) mention that 2122 these were NXIVM concepts? 2223 A. You would have to have permission. 2324 Q. And why would permission be 2425 reqnired? 25


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1 SALZMAN - DAY II 12 whether they are in a business engaged in 23 something with a type of competitor. Is that 34 policy of NXIVM written down anywhere? 45 A. I don't think it is. 56 Q. Okay. What is a facilitator at 67 NXIVM? 78 A. A facilitator is someone who leads 89 discussion groups within educational modules. 9

10 Q. Am I correctthat during the course 1011 of an intensive, there are breakout sessions wher 1112 smaller groups discuss the materials? 1213 A. That's correct. 1314 Q. And is that where a facilitator has 1415 a role, in those breakout sessions? 1516 A. That's where the facilitator has a 1617 role. 1718 Q. What does the facilitator do in 1819 those breakout groups? 1920 A. They facilitate the questioning. 2021 Q. Meaning what? 2122 A. They ask questions and direct the 2223 students and their ideas. They also keep the 2324 students within a certain parameter, as opposed to 2425 getting lost and going off and discussing things 25


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SALZMAN - DAY IIA. I think it's included in this.Q. Okay. Would someone telling a

friend here's what NXIVM thinks about money, let'say, would that be prohibited?

MR. Me GUIRE: Same objection asbefore. You're asking for a legal conclusion.You can ask for her understanding. But thatcalls fOT a legal conclusion.

Q. I'm asking your understanding.A. My understanding is that we don't

share the specific definitions in ESP becausethey're part ofthe technology itself.

Q. And so, whether that information isbeing used to persuade or dissuade someone fromjoining NXIVM, it would make no difference as towhether it was prohibited?

A. It's prohibited to disclose thespecifics that are taught within the modules.

Q. SO, the answer would be yes if itdisclosed the information that was in the modules?

A. Whether to promote it or dissuadepeople.

Q. Okay. You mentioned earlier apolicy that NXIVM has to ask prospective students


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SALZMAN - DAY IIthat aren't part of the discussion group'spurpose.

Q. What is a coach at NXlVM?A. A coach is a rank in ESP that is an

apprentice learning to facilitate -- depending onthe level of the coach, they learn to facilitateindividuals and groups, set goals, and they learna body of knowledge that allows them to get to a ~

level where they can be a professional at that,which is called a proctor.

Q. Okay. Does one - along the pathof development at NXIVM, does one become a coach 1first or a facilitator first? ~

A. You become a coach first. 'Q. SO, one becomes a facilitator after

they already served as a coach?A. Part of the coaching curriculum

includes facilitation training.Q. Okay. And the coaching curriculum

is taught after one has become a coach or hi order Rto become a coach?

A. After one becomes a coach.Q. They then take tbe coaching

curriculum?


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SALZMAN - DAY II2 A. That's correct. They qualify to3 take the coaching curriculum.4 Q. Okay. And the coaching curriculum5 involves what?6 A. A series of modules that are --7 educational modules that give them all the skills8 necessary to be a full coach.9 Q. Do they start out as full coaches

10 when they have this or do they start out as11 apprentice coaches?12 A. They start out as a provisional13 coach and then they work their way through to14 become a full coach.15 Q. And in the course ofthe coach's16 curriculum, they also learn how to facilitate?17 A. That's correct.18 Q. The modules that are taught in the19 coaching curriculum, are they the same module20 that are taught as part of an intensive?21 A. No.22 Q. Are they entirely different modules23 or are they the same modules taught from a24 different perspective?25 A. They're an entirely different


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SALZMAN - DAY IIcurriculum.

Q. Is there a list of the coachingcurriculum somewhere that NXIVM keeps?

A. There is.Q. What is taught in the coaching

curriculum, or what are the modules that aretaught?

A. There are three levels of modulestaught in the coaching curriculum. The firstlevel teaches facilitation skills. It teaches thestructure and nature of emotions, and howfacilitators can work with emotions. It teachesprotocol. It defmes what -- it definesprofessionalism and coaching, and it teachescertain skills of listening and redirecting for amore accurate understanding of data.

The next two levels are levels thatteach EM technology.

Q. Are these three levels taugbt atthe same time, or are they taugbt one at a timewith some gulf of time in between them?

A. They're taught -- they're pre andco-requisites in that matrix of modules, and thereare certain educational requirements and personal


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1 SALZMAN - DAY II 12 requirements that the participant has to be tested 23 and pass certain certifications to get to. 34 So, you qualify for the ability to 45 be taught or to learn different levels of 56 curriculum in the coaching. 67 Q. Okay. How does one qualify to take 78 the first level of coaching in tbe coaching 89 curriculum? 9

10 A. It's a series of personal 1011 behavioral ability, and there is an enrollment 1112 qualification and an interview, which has to do 1213 with meeting an ethical standard. 1314 Q. What is the enrollment 1415 qualification for taking the first level of the 1516 coaching curriculum? 1617 A. We have to enroll two people in the 1718 program. 1819 Q. And those are two people who 1920 actually take classes? 2021 A. That's correct. 2122 Q. What is the educational requirement 2223 that they have to satisfy to get to this first 2324 level? 2425 A. They have to go through the basic 25


SALZMAN - DAY IIcurriculum, which has three levels as a student,and they have to be able -- they have to have awell-integrated knowledge of those three levels.

Q. Would that be the -- the threelevels are what? What are the three levels?

A. Levell, Level II and Level III.They're pre and co-requisites, and there'scertifications in between.

Q. Would someone who took tbe Ifi-dayintensive have satisfied the tbree levels?

A. No. No.Q. What, in addition to the 16-day

intensive, would somebody have had to take tosatisfy the educational requirement?

A. They usually need to -- now theyneed to take that at least two times to have anintegrated understanding of the curriculum. Andnow there are certification tests in place.

Q. When was the certification test putin place?

A. Recently.Q. Did the requirement of taking the

intensive twice, is that new?A. It's something that over the years


I1 SALZMAN - DAY II 12 since we've been developing the model we've corne 23 to understand allows the coach to move through 34 coaching faster and more effectively through the 45 different levels. 56 Q. What was the educational 67 requirement, in 2001, to get to the first level of 78 the coaching curriculum? 89 A. 1 believe back then you had to go 9

10 through the entire curriculum once and the 1011 five-day once. 1112 Q. SO, the entire 16-day intensive and 1213 then a five-day? 1314 A. 1believe that was the requirement 1415 back then. 1516 Q. Okay. And then what would -- would 1617 there be a test at the end of the five-day to see 1718 whether you can move on? 1819 A. We didn't have a test back then. 1920 Q. There was no certificational 2021 requirement at that point? 2122 A. Correct. 2223 Q. Was there still the enrollment 2324 requirement - the requirement that someone enrol 2425 two people? 25


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1 SALZMAN - DAY II 12 with that to evolve it. 23 Q. Are tbese tests in writing to go on 34 to tbe next level? 45 A. Some of them are in writing and 56 some of them are observed by facilitators and 67 evaluated based on that. 78 Q. SO,someone would actually 89 facilitate a module before tbey became a 9

10 facilitator. Is tbat correct? 1011 A. They're called a shadow coacb at 1112 first, and they work with another coach and they 1213 facilitate under the guidance of someone else. 1314 Q. And tbey would facilitate tbese 1415 breakout sessious under the guidance of someone 1516 else? 1617 A. That's correct. 1718 Q. Okay. And one ofthe tbings tbat's 1819 required to getto tbe second level oftbe 1920 coacbing curriculum is -- strike tbat. 2021 Was that requirement in place in 2122 2001, or what was the requirement in 2001 to tak 2223 tbe second level of coaching curriculum? 2324 A. I'm not sure we had the requirement 2425 in place -- the requirements in place. I don't 25


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SALZMAN - DAY IIA. If you wanted to be a coach, yes.

Not if you wanted to go on to higher levels or adifferent curriculum. But ifyou wanted to be acoach specifically, that's a very specificcurriculum.

Q. SO, if you wanted to take tbe firstlevel of the coacbing curriculum, you bad toenroll two people?

A. Right. Because that was anecessary pre-requisite in that program.

Q. What were tbe requirements fortaking tbe second level of tbe coacbingcurriculum?

A. There were -- tbey had to gothrough -- they have to now go through a series 0

tests at the end of each module so that they havea well-integrated understanding of them. Theyhave to facilitate a certain number of moduleseffectively and be able to -- before they can goon to Level II, they have, I believe, be able tofacilitate all of the basic modules effectively.

They have to understand their lifeissue as it relates to their current limitations,and develop a plan for how they're going to work


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SALZMAN - DAY IIthink we had the requirements in place. I thinkwe learned we needed to put them in place as time ,went all.

Q. SO, in 2001, how would someone takethe second -- strike that.

In 2001, what wonld NXIVM requireof a student before they could take the secondlevel ofthe coaching curriculum?

A. They were evaluated by othercoaches and proctors, but they weren't evaluatedin a test that had a standardized format. Thosewere developed as we developed the curriculum. I'think back in 2001 we were still developing thecoaching curriculum.

Q. Okay. So, they were observed?A. They were observed, yes.Q. And could someone go from taking

the - strike that.How long were the first level of

coaching curriculum? How long did it take toteach that, in 2001?

A. You know, I can't give you a time,even now, because it's not so much a time. It'smore a matter of the learning style of the person,


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1 SALZMAN - DAY II 12 how committed they are, how much time they put 2

3 into it. And it also has certain things to do 34 with their personality, and the other things that 45 they've done in their life. 56 So, it's some of the things about 67 facilitating have to do with rapport skills, have 78 to dowith skills that some people seem to come by 89 more naturally than others or need to be trained 9

lOin. So, a lot of these things are specific to the 1011 individual. That's why I said a lot of the tests 1112 aren't so much written tests because, you know, 1213 just to do facilitation, it's a skill that someone 1314 has to do in real time. 1415 Q. Could someone take the 16-day 1516 intensive, then take that extra five days, and 1617 then the very next day start the coaching 1718 curriculum, or does there have to be some interva 1819 oftime? 1920 A. Back then? 2021 Q. Right. 2122 A. Yes. 2223 Q. There had to be some time interval? 2324 A. No. 2425 Q. They could go right from that 25


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1 SALZMAN - DAY II 12 requirement of an interval in time between the 23 first level of the coaching curriculum and the 34 second level? 45 A. This program has been organic in 56 nature, meaning we were developing it and testing 67 it as we were doing it. So, we recognized based 78 on the way our facilitation went and how much 89 training they needed and would create more modules 9

10 at the time. We were still creating the coaching 1a11 curriculum at that time. 1112 So, back then I don't think it was 1213 as formalized as it is now. So, there wasn't such 1314 a pre-requisite but now there is. 1415 Q. Now, I understand that NXIVM uses 1516 sashes to denote rank within the group. 1617 Is that correct? 1718 A. Yes. 1819 Q. What rank would someone who is in 1920 the -- accepted into the coaching curriculum have 2a21 attained? 2122 A. A yellow sash. 2223 Q. Could one receive a yellow sash 2324 before they had been accepted into the coaching 2425 curriculum? 25


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SALZMAN - DAY IIfive-day to the coaching curriculum?

A. Depending on how they did in it,yes. If they exhibited good rapport skills, andif any they exhibited a good ability to work withpeople, and they seemed to have a good level ofintegration of the material, we probably wouldhave let them.

Q. In that five-day period, arethey -- did they facilitate breakout groups durinthat five-day period?

A. Back then it was possible we mayhave let them.

Q. And who would make thedetermination if they would be allowed tofacilitate?

A. The person who was teaching thetraining based on their evaluation of how theperson did learning the curriculum itself. That'strue.

Q. SO, they may have been allowed tofacilitate, even though they weren't in thecoaching curriculum at that point?

A. That's true.Q. Okay. Now, would there be a


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SALZMAN - DAY IIA. No.Q. Okay. A student who was taking

the - this - had taken the 16 days, and wastaking the five-day course, what sash - wouldcolor sash would they have?

A. It depends on what happened duringthat 16-day and after it.

Q. Could they have been awarded ayellow sasb?

A. They could have.Q. Even iftbey were not yet in the

coaching curriculum?A. Yes.Q. SO, one could have the yellow sash

witbout being in tbe coacbing curriculum?A. Yes. It could be a provisional

thing until they finish the basic curriculum.Q. Okay. And by tbe basic curriculum

you mean the 16 days plus tbe five days, or justbe 16 days?

A. I believe they couldn't have ituntil they had fmished the l6-day.

Q. On a provisional basis?A. Exactly.


1 SALZMAN - DAY II2 Q. And someone who completed the first3 level ofthe coaching cnrriculum, what would the4 receive, in terms of a sash?5 A. They mayor may not receive6 anything else. It depends on meeting certain7 other objectives.8 In other words, they could have no9 stripe and it's just a yellow sash, and have

10 completed the whole first level of coaching11 curriculum.12 (Exhibit Salzman 33 marked for13 identification.)14 MR. KOFMAN: Ms. Salzman, for the15 record, this is a two-page document that was16 produced by my client -- my clients in this17 litigation. I'm sorry. It's a three-page18 document. It's got Bates Stamp Nos. SF0001219 through SFOOO 14.2 a Q. Are you familiar witb this21 document?22 A. I am.23 Q. What is tbis?24 A. This is the qualification to reach25 stripes for a promotion at the basic levels of


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1 SALZMAN - DAY II2 document.3 Q. Okay. Although it's still required4 an enrollment of two, that same requirement tbat5 you mentioned?6 A. It's still the same requirement for7 Ethos. This isn't the intensive requirement.8 Q. Okay. What does "people on stripe9 pathn mean under" con fig. " or in the column afte

10 the phrase "config." It says "people on stripe11 path."12 A. In the program it is necessary -13 in this particular program, this is a specific14 curriculum intended for a specific objective. The15 coach needs to enroll two people, and they don't16 need to have anybody else who wants to be a coach.17 They just need to enroll two people.18 Q. Okay.19 A. If somebody is on the stripe path,2a that's somebody who wants to be a coach.21 Q. Okay. The next category is "One22 Stripe (Coach)." Is that the requirements in23 order - does that set forth what the requirements24 were in 2001 to get into the coacbing curriculum?25 A. No. That satisfies the requirements


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1 SALZMAN - DAY II2 coach.3 Q. And wbat is an apprentice at NXIVM?4 Or wbat was an apprentice as of 2001?5 A. It was someone who was awarded a6 yellow sash who was what I call a provisional7 coach.8 Q. Okay. And that would bave been9 awarded the yellow sash before tbey completed tb

10 16-day and tbe five-day?11 A. Before or after.12 Q. Okay. What is the - on tbe13 right-hand side next to tbat it says:14 "Min. time, 12 weeks."15 Wbat does that mean?16 A. This would be if somebody was17 taking the Ethos program, which is the program18 where you take the two-hour modules, one at a19 time, as opposed to an intensive. That's what20 this was designed for.21 So, what that meant was, and what22 it still means is that you have to be a part of23 that program for J2 weeks. We later developed-24 this was an older document before we developed the25 intensive. We developed the intensive after this


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1 SALZMAN - DAY II2 to actually begin coaching or facilitate.3 Q. Okay. And so, the requirements4 would be three enrollments and one person on tb5 stripe patb in the configuration.6 Is tbat correct?7 A. That's correct.8 Q. What are facilitator notes?9 A. They're notes that accompany the

10 educational modules, and they're the ones that the11 facilitators refer to, to guide them through12 facilitating a module, an educational module.13 Q. Does NXIVM give the facilitator14 notes to someone who is not yet a facilitator?15 A. A facilitator's notes are never16 supposed to leave the building. Unless somebody17 takes them, they don't leave the building.18 Q. Okay. Well, my question was:19 Would someone be given them for use - strike20 that.21 Would someone be given those for22 use in a course inside the building ifthey23 weren't yet a facilitator?24 A. Yes.25 Q. Under what circumstances?


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SALZMAN - DAY II 1A. If they're facilitating a module. 2Q. And that would be perhaps as part 3

of their shadow coaching responsibilities? 4A. Or coaching responsibilities. 5

Also, they are used during the coaching 6facilitation training. 7

Q. Does someone at NXIVM have 8responsibility for collecting the facilitator 9notes at the end of each day? 10

A. Yes. 11Q. Who is the person -- what's the 12

rank of the person who has that responsihility1 13A. Proctor. 14Q. And what does the proctor do to 15

make sure that the materials are collected? 16A. They're now numbered, and the 17

proctor signs them out and has to sign them back 18in at the end of the module, or at the end of the 19day if it's an intensive. 20

Q. Was that a practice followed in 212001? 22

A. I don't believe it was. 23Q. What practice was followed in 2001 24

to keep track ofthe facilitator notes? 25TSGReporting - Worldwide (877) 702-9580

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SALZMAN - DAY IIA. The proctor in charge was supposed

to keep track of them. I think we began numberingthem right after that.

Q. Right after 2001?A. Yes.

(The requested portion of therecord was read.)

Q. How many people have served asfacilitators who had the title facilitator atNXIVM?

MR. MC GUIRE: When?MR. KOFMAN: In its history.

A. I would have to guess.Q. What's your approximation?

MR. MC GUIRE: Is it a guess or isit an approximation?

A. I can give you an approximation.Q. Sure.A. One in ten people becomes a coach.

One in ten people who take the course becomes acoach. And I would say about half of themfacilitate.

Q. Okay. So, am I correct thatthere's heen about 7,000 students at NXIVM?


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1 SALZMAN - DAY II2 A. Correct.3 Q. SO, about 700 have become coaches?4 A. I would say that's true.5 Q. And out of those, perhaps 350 have6 become facilitators?7 A. Did I say one in two? About 350.8 Q. Yes.9 A. I would say about 350 have

10 facilitated.11 Q. And all of those 350 have used12 facilitator notes in trainings?13 A. Yes.14 Q. And aU ofthe coaches also used15 facilitator notes in training?16 A. Anyone who is facilitating is17 considereda facilitator.18 Q. SO, every coach, in the course of19 their coaching curriculum, would have facilitated?20 A. That's right, if they get up to one21 stripe.22 Q. Also, it's possible that23 individuals who were not in the coaching24 curriculum, but who were considering it, may hay25 been allowed to facilitate?


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SALZMAN - DAY IIA. You mean the apprentices?Q. Yes.A. Yes.Q. Okay. Is there something called

coaches notes?A. They're the same as the facilitator

notes.Q. They're the same as the facilitator

notes.Ms. Salzman, when did you meet

Michael Sutton?A. Michael Sutton, I believe, took a

weekend intensive in 2000.Q. Did you have some role in that

intensive?A. I believe I taught the whole thing.

. Q. Was that up in Albany?A. Yes.Q. Was Michael the first member of his

family that you had met?A. Yes.Q. Did there come a time where you

learned about Stephanie Franco?A. Yes.


Q. Did he mention to you that she hadbeen a therapist?

A. Yes, he did.Q. What did he say about her therapy


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1 SALZMAN - DAY II2 Q. How did you first hear about3 Stephanie?4 A. Michael told me that he had a5 sister that he thought was struggling with her6 career, and he thought that she would really love7 this program.8 Q. When did he have this conversation9 with you?lOA. He had that conversation with me11 very early in the time that I knew him.12 Q. Sometime in 2000?13 A. I believe so.14 Q. Did he tell you what her career15 was?16 A. He told me that she taught classes17 at Rutgers.18 Q. Did he tell you what types of19 classes she taught?20 A. He told me that she was a social21 worker.22232425

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1 SALZMAN - DAY II2 practice?3 A. He didn't think that she felt like4 she wanted to keep doing that. I don't think she5 felt like she was effective.6 Q. Did he indicate to you that she was7 still involved in her therapy practice?8 A. I don't know if we discussed that9 much of it when he first talked to me about her.

10 As time went on, I knew that she had a therapy11 practice.12 Q, And was that from Michael that you13 learned that?14 A. Michael talked to me about15 Stephanie a number of times.16 Q. What else did he tell you abont17 Stephanie?18 A. Mainly that he really loved her,19 that he thought that she was really wonderful, and20 he thought she would just love this.21 Q. Did be indicate to you that she bad22 taken otber classes in human potential?23 A. No.24 Q. Did be mention - strike that.25 Did he mention his family's


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1 SALZMAN-DAY II 12 economic circumstances to you? 23 A. No. 34 Q. Okay. Did he mention something 45 called Center For Personal Growth? 56 A. I don't remember. 67 Q. After Michael talked to you about 78 Stephanie, did you decide to attempt to get 89 Stephanie to enroll? 9lOA. He asked me if! would meet her. 1011 Q. When did he ask you that? 1112 A. Somewhere in the first few months 1213 ofknowing him. 1314 Q. Sometime in 2000? 1415 A. I think so. 1516 Q. Did he mention you meeting his 1617 parents? 1718 A. He wanted me to meet everyone. 1819 Q. What did he say about you meeting 1920 his parents? 2021 A. He said they would love me. 2122 Q. Did there come a time wbere you me 2223 Stephanie Franco? 2324 A. Yes. 2425 Q. When was tbat? 25


SALZMAN - DAY IIA. I visited Deal with him, Deal, New

Jersey, and he brought me to the family home, andI met his parents, and I met Stephanie.

Q. Do you remember what time of yearthat was?

A. I went a couple of times. I thinkit was winter.

Q. Okay. Anybody besides you andMichael go to the family home?

A. Not that I recall.Q. Did you travel from Albany to Deal

to meet the Suttons and Ms. Franco?A. I don't know if! went specifically

for that. My family lives in New Jersey. I mayhave just come to meet them because Michael askedme to.

Q. SO, you're not sure if you combinedtbat with a visit witb your family or just wentstraight there?

A. I think I combined it with a visit.I think I was here and he asked me to come meethis family.

Q. And did you have dinner at Mr. andMrs. Sutton's house?


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SALZMAN - DA Y II 1A. Yes. 2

Q. Who else was there? 3

A. You know, there were a number of 4

different people who came and went. I was there 5like for a day, like an afternoon, all the way -- 6

I may have even spent the night. 7

Q. Were Aaron and Leslie Kasson there? 8A. Yes, I met Aaron and Leslie as 9

well. 10Q. On that same trip? 11A. I think I met the whole family on 12

that trip. 13Q. Was it unusual for you to visit the 14

family of a student? 15A. Outside of Albany? 16Q. Yes. 17A. I think it was. I think Michael 18

made it a point. And because I was in New Jersey 19visiting my family, it was something easy for me 20to do. I think it -- you know, it was something 21that would have -- if! had to travel, it might 22not have been as easy a thing to do, whereas in 23Albany, I met the family ofmy students from time 24to time. 25


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SALZMAN - DAY IIQ. Duriug the course of this day, did

you discuss -- strike that.Did Michael tell you that Morris

and Rochelle Sutton might he interested in NXIVM.A. Michael really loved our curriculum

and found it of great value in the way that hespoke of it to me. And he told me that he thoughtit would be of great value in his community, andhe wauted me to tell his parents about it. .

Q. What did you understand he meant bythe term "his community"?

A. He lived in an area with people whoare all Sephardic Jews, and his family is veryactive in that community. And Michael believedthat our model would be something that thatcommunity would really like.

Q. Did be tell you why he tboughtthat?

A. Because he liked it, I think.Q. Did he tell you what the

socioeconomic circumstances were of thatcommunity?

A. I don't know that we discussed itever, but I think when I was there, I became aware


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1 SALZMAN - DAY II 12 ofwhat it was. 23 Q. And what were the socioeconomic 34 circumstances? 45 A. Well, I didn't know exactly, but I 56 could tell that it was a very successful -- 67 economically successful community. 78 Q. Okay. Were the Suttons cordial to 89 you at that meeting? 9

10 A. Cordial, yes. Mrs. Sutton was very 1011 warm, very friendly, very inviting. She was 1112 extremely friendly. 1213 Mr. Sutton was very serious. 1314 Although I didn't think he minded that I was 1415 there, I don't think he was particularly excited 1516 by my visit. 1617 Q. Were either of the Suttons hostile 1718 to you? 1819 A. Oh, uo. 1920 Q. Are you aware that Michael had a 2021 child out of wedlock? 2122 A. I was. 2223 Q. Do you know if by the time of this 2324 meeting he had told his parents about that child? 2425 A. I don't believe he had. 25


SALZMAN - DAY IIQ. Do you know when he told his

parents about that?A. When or what?Q. When.A. It took Michael a while to feel

comfortable telling his parents. I think one ofthe things he was struggling with the most was howto tell his parents that, and I think it took himabout a year.

Q. SO,you think it would have beensometime in 2001 ?

A. It may have been later.Q. Okay. What did you say about NXIVlV

at this meeting, or at this - "meeting" soundstoo formal -- at this gathering at the Suttons'borne?

A. I talked about my experiences withKeith, and in the field with other things that Ihad taught, and why I thought this was superior.

Q. Did you bring any materials,written materials, with you?

A. I may have.Q. Do you recall one way or the other?A. No.


i1 SALZMAN - DAY II 12 Q. Is it your practice to hand out 23 materials to potential students of NXIVM? 34 A. It isn't now, and it hasn't been in 45 a while, and I don't remember if it ever was. 56 Q. Okay. 67 A. I know that a lot of our 78 participants want to give things to other people. 89 It's not really something that either Keith or 9

10 myself think is necessary. 1011 Q. Did you indicate, during your 1112 discussion with the Suttons, that NXIVM was a 1213 science? 1314 A. I probably talked about -- that it 1415 was our attempt to make a reproducible, 1516 quantifiable, measurable model. 1617 Q. When you say you probably talked 1718 about it, does that mean you don't recall 1819 specifically what you said? 1920 A. To the best ofmy recollection, 2021 that's how I always have spoken about it. 2122 Q. Did you talk about results that 2223 NXIVM had achieved? 2324 A. I'm not sure. Sometimes people ask 2425 me about my experience with the model and all. 25


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SALZMAN - DAY III'll tell them about my experiences.

Q. What did you say about KeithRaniere?

A. I don't remember.Q. Okay. Did you iudicate that one of

the goals of NXIVM was to change the world?A. I think one of the goals ofNXIVM

is to change the way people relate to each otherin the world, which I think would change the waythe world is for people.

Q. Is that something you mentioned atthis dinner?

A. I don't know.Q. Do you recall a discussion with

Morris Sutton, where he expressed some skepticismabout NXIVM's desire to change the world?

A. He was sort of skeptical. I thinkthat's how he is.

Q. What did he express skepticismabout?

A. Most things that were discnssed atdinner that night.

Q. Did you - strike that.Did you discuss with Stephanie i


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1 SALZMAN - DAY II2 her -- anything ahout her background during tha3 gathering?4 A. Stephanie didn't come to dinner.5 She came later.6 Q. After dinner she was there?7 A. That's right.8 Q. As part ofthe same visit while you9 were there. Correct?lOA. Right. I remember -- the way that11 I remember it was that Stephanie came after most12 people left, and I ended up having a conversation13 with Stephanie. I think it was just Michael and14 Stephanie, or just Stephanie.15 Q. What was discussed during that16 conversation?17 A. Stephanie was talking about --18 well, she was asking me a lot ofquestions about19 the model, and she was telIing me that she was20 thinking of taking a course or some other21 education. She wasn't really sure what she wanted22 to do with her life and she was looking for23 something new. She talked to me about her24 divorce. She talked to me about her teaching.25 Things like that I remember.


1 SALZMAN - DAY II2 Q. Did she tell you about any ofthe3 other courses that she had taken?4 A. Outside ofacademic courses?5 Q. Yes.6 A. I don't remember her telling me7 that she took courses outside ofher academics.8 Q. Did she indicate to you that she9 was familiar with NLP?lOA. I don't remember her telling me11 that, and I usually sorted for those things. And12 I don't remember that she knew anything about NLP.13 So, if she took it, I don't remember her ever14 telIing me that she took it.15 Q. If it's Stephanie's recollection16 that she told you that, would you say that's17 incorrect?18 A. You know, I usually look for people19 who have studied NLP because it's a common thing,20 and I usually kind ofkeep track of them in my21 mind because it's a common thing to discuss. I22 don't ever remember Stephanie telling me that. It23 doesn't mean it didn't happen, but I really don't24 remember it at all.25 Q. Did she mention that she had taken


No.Did she say where she taught them?

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1 SALZMAN· DAY II 12 EST? 23 A. Yes. 34 Q. Was that in that conversation she 45 mentioned that? 56 A. Well, I had a couple of 67 conversations with her, and I remember that she 78 said she took EST. 89 Q. You mentioned that she said to yon 9

10 that she was interested in taking another course 1011 What course did she say she was 1112 interested in taking? 1213 A. She said she was thinking of taking 1314 a course that would teach her how to do coaching. 1415 Q. Did she say who was giving that 1516 course? 1617 A. I don't remember if she told me, 1718 and if she told me, I wasn't familiar with it, so 1819 it didn't mean much to me. 192 a Q. Was it Tabie Keller? 2021 A. If she told me, that's -- I'm sure 2122 that's what she told me. But I've heard that 2223 since then, so I'm not sure that she told me. 2324 Q. What was your response when she 2425 said that she was interested in taking a course 25


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1 SALZMAN - DAY II 12 continue to work there. 23 Q. Did she mention anything about the 34 Center For Personal Growth? 45 A. You know, when you say the name of 56 it, I don't know if it's just a common center that 67 people call their place, or I've heard it from 78 her, but I've heard that term before, that name. 89 I just don't place it with her. I don't know if 9

1 0 she had a center for personal growth, or I've seen 1 011 it in the literature. I don't remember. 1112 Q. I can't answer you. 1213 A. Yes. I don't remember. 1314 Q. Did she indicate to you that she 1415 had done work as a therapist? 1516 A. Yes. 1617 Q. And what did she tell you about her 1718 therapy practice? 1819 A. She told me that it was small, and 1920 she wasn't sure she wanted to continue to do it 2021 because she didn't think she was effective. 2122 Q. What did you say in response? 222 3 A. That I understood. The reason that 2324 I was studying this with Keith Raniere and working 2425 in this is because before I learned this model, I 25


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SALZMAN - DAY IIahout coaching?

A. I told her to take ours. When Iheard she was interested in taking a course, Ijust assumed that it would be better for her totake ours. And so I am certain that I told her ifshe was going to take a coaching course, I wouldlike her to take ours. I liked her.

Q. You felt that you hit it off withher?

A. Yes.Q. And did you tell her that you

thought she'd be a good fit?A. Yes.Q. Did she mention anything - what

did she tell you about the courses that shetaught?

A. She said that she wanted to learnsomethiug that would help her help people better. i

Q. Did she say what courses she hadtaught?

A.Q.A. Rutgers. She did say that she

didn't -- she wasu't sure if she wanted toTSG Reporting- Worldwide (877) 702-9580

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SALZMAN - DAY nhad the same feelings about most of the thingsthat I had learned.

Q. How did you leave your conversationwith Stephanie about her potential involvementwith NXIVM?

A. Well, I liked her, and I thoughtshe would be a wonderful person to have in ourprogram. And I let her know that I really thoughtthat she would be -- that she would not only likeit, but that I would like having ber.

Q. Did you make any plans at theconclusion of that gathering with StephanieFranco?

A. Stepbanie -- I think Stephanieliked me as well, and I don't think she wanted tocommit to taking the program or not taking theprogram. But she said she was interested ingetting together again.

Q. And what did you say?A. I said great.Q. Did you have any discussions with

Morris Sutton or Rochelle Sutton about them takimthe program?

A. Michael did.


1 SALZMAN - DAY II2 Q. At that -- at the meeting that you3 were - at the gathering that we're talking ahout4 now?5 A. Michael wanted everybody to take6 the course. He was very excited about the course.7 But I believe he thought that if they took the8 course, it would make it easier for him to share9 the information he needed to share with them about

10 his child. I think that that was probably his11 intent for inviting his family and asking me to12 come.13 Q. Did Michael ever tell you that14 Stephanie might be able to get other people rolled15 inNXIVM?16 A. He was more interested in her being17 a facilitator and coach, and figuring out18 something that would be more satisfying for her to19 do with her life then what she was currently20 doing, than enroliing people in the program.21 Q. Did she mention that she might be22 able to enroli people in the program?23 A. He said that he believed that24 people respected Stephanie in the community and25 that if Stephanie did this, she might want to open


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1 SALZMAN - DAY II2 Q. Can you be any more definite than3 within a year?4 A. I think it was 2001.5 Q. Do you remember what part of the6 year?7 A. I think it was winter.8 Q. SO, perhaps early 2001?9 A. It may have been late in the year.

10 It may have been iike November, December.11 Q. Had Stephanie Franco been a student12 at NXIVM already at the time that this class too'13 place at the Kassons' home?14 A. No.15 Q. SO,it was before Stephanie came16 for an intensive?17 A. Yes. It was probably early then.18 Q. How did it come about that you19 taught a class at the Kassons' home?20 A. They invited me. Michael asked --21 Michael wanted to enroll people in the community,22 and he asked me ifhe got enough people together,23 would I bring the staff there, rather than making24 ali of the people go there, because it was less25 people traveling in one direction.


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1 SALZMAN - DAY II2 a center within the community, and then that would3 help the community. And he thought that -- I4 think Michael loved his community, and he wanted5 something good for his community, and he thought6 this was something good.7 Q. And was that something that would8 be attractive to NXIVM, to have her open a cente9 in the community?lOA. Weli, I think what we want to do is11 we want as many people as find our model12 beneficial to take it because we think it's a good13 thing in the world.14 Also, it's a business. And in15 didn't say I wanted to promote my business, I16 wouldn't be a very good entrepreneur; would I?17 Q. Did there come a time where you18 taught a class at the home of Aaron and Leslie19 Kasson?20 A. Yes.21 Q. When was that?22 A. It was within probably a year of23 meeting the Suttons.24 Q. Do you remember what year this was?25 A. I'm sony. I'm not good with that.


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1 SALZMAN - DAY II2 Q. And did you agree to teach the3 class?4 A. I did.5 Q. And you came down from Albany for6 the purpose of teaching this class?7 A. I did.8 Q. How many people from NXIVM came9 with you?lOA. Probably about six.11 Q. Do you remember who they were?12 A. I don't.13 Q. Do you remember anybody who was14 with you?15 A. Probably Barbara Jeske was with me,16 my daughter, Lauren, was probably with me. I17 think Carole Bergeron was probably with us.18 That's ali I can remember now; maybe Lisa Durkes.19 Q. How many attendees were there at20 this class?21 A. There were 20.22 Q. What was the class that you taught?23 A. It was -- we used to cali it a24 one-day. And what it was, was we have programs.25 We have the Ethos program and we have the Origins


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1 SALZMAN - DAY II 12 program. The Ethos programhas a curriculum where 23 you get a membership, and then classesare taught 34 several times a week and you can take as many as 45 you want. 56 The Origins program is more of an 67 introspective program, where you take usually one 7

8 class a week, and each Origins integration 89 consists offour classes. The one day was the 9

1 0 first four classes of that. 1 011 Q. SO, the one day was the first four 1112 classes of the - 1213 A. The Origins program. 1314 Q. - the Origins program. Do you 1415 remember what modules that would include? 1516 A. There is an introduction, there's a 1617 communications module, an honesty module, and then 1718 an emotionalmodule. 1819 Q. Did the participants of this module 1920 have to sign an application? 2021 A. They did. 2122 Q. Do you remember how much NXIVM 2223 charged? 2324 A. I believe we charged $200 a person. 2425 Q. Did NXIVM distribute any materials 25


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SALZMAN - DAY IIat this one-day event at the Kassons' home?

A. There were student notes,participant notes that went along with eachof the -- probably two of their modules andprobably an introduction.

Q. Did the information that wasdistributed include elements of rational inquiry?

A. Well, the student notes.Q. That's a yes with the student

notes?A. Yes, the student notes.Q. Did Rochelle Sutton attend that

gathering?A. I believe she did.Q. Did NXIVM obtain an application

from Rochelle Sutton?A. I believe we did.

MR. KOFMAN: I represent that we'venever seen a copy of the application thatRochelle Sutton signed, and we request itspecifically. I'll repeat the request now.

Q. Do you remember any of tbe otherattendees at the one-day?

A. Leslie and Aaron Kasson were there.TSGReporting - Worldwide (877) 702-9580

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SALZMAN - DAY II 1I don't really remember the others. 2

Q. Okay. Was Stephanie Franco there? 3A. She just stopped in. 4Q. Do you know why she didn't attend? 5A. She was going on a trip. 6Q. Did she iudicate what trip she was 7

going on? 8A. ~. 9Q. Did she indicate to you that she 10

was Onher way to Tabie Keller? 11A. No. 12Q. Do you recall her telling you 13

anything about where she was going? 14A. No. She said she was going away for 15

the weekend, for the week. It was a Sunday. 16Q. Did NXIVM let the people who took 17

this one-day class keep the materials that had 18been distributed? 19

A. The materials that are distributed 20in the one-day are for them to keep. 21

Q. Okay. Did NXIVM obtain a list of 22the attendees? 23

A. Yes, I'm sure we did. 24Q. Does NXIVM still have that list? 25


SALZMAN - DAY IIA. I'm sure it's in our enrollment

information. All the students that have evertaken are in it.

MR. KOFMAN: Okay. I'd like tomake a request for that. It hasn't beenproduced, despite being requested.

MR. MC GUIRE: Have any studentapplications been given to you?

MR. KOFMAN: They have been, butamong them was not Rochelle Sutton. There'snothing that's a list indicating who was atthat specific event.

MR. MC GUIRE: Maybe Imisunderstood. I mean, she said she had thelist. She had the application is what Ithought she said.

Q. Do you have a list of theattendees?

A. I could try to go hack and put ittogether.

Q. I appreciate that.Was the seminar videotaped or audio

taped?A. I don't remember.


Q. Okay. Did Rochelle Sutton everattend an intensive with NXIVM?

A. No.Q. Have you ever spoken to Rochelle

Sutton after this one-day event at the Kassons'home?


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1 SALZMAN - DAY II2 Q. Would it have been your practice to3 videotape or audio tape a one-day?4 A. I know that we do that now. I know5 that we always try to do that. So, my guess is6 that we did do it back then, as long as we had the7 technology off premises to do it.8 Q. Did any ofthe attendees9 subsequently take more classes with NXIVM, othe

10 than Aaron and Leslie Kasson?11 A.] don't rememberwho came. I'm12 sorry. It was a long time ago.13 Q. Were you familiar with Tabie Keller14 in 2001?15 A. No.16 Q. When did you first become aware of17 Tabie Keller?18 A. I think at the beginning of this19 lawsuit.202122232425

1 SALZMAN - DAY II2 Morris Sutton after this one-day gathering at his3 house?4 A. I think I was in his house one5 other time, and I'm certain that I said hello to6 him, but I don't think we've ever had any long7 discussions.8 Q. Do you recall the circumstances9 where you might have been in his house?lOA. I think it was when I went down for11 that event, and I believe Stephanie brought me12 next door because it was in the home right next13 door to theirs.14 Q. After the event at the Kassons'15 home, when is the next time you spoke to Stephani16 Franco?17 A. I don't remember. I remember that18 I spoke to Stephanie from time to time.19 Q. This would be by phone?20 A. I probably didn't see her again21 until she came to the intensive, but I don't22 remember.23 Q. Did you have phone conversations24 with her hetween the time that you first met her25 and the time she came to the intensive?


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1 SALZMAN - DAY II2 A. Yes.3 Q. When?4 A. Stephanie invited me to a charity5 event that occurred at the home next to the6 Suttons that was a community event, and she asked7 me to be a speaker there.8 Q. And Rochelle Sutton was there?9 A. And Rochelle Sutton came.

10 Q. What did you and Rochelle Sutton11 discuss?12 A. I don't think we had a lot of time13 together. I don't remember.14 Q. What this at the home of someone15 named Ms. Carrie (phonetic)?16 A. Yes.17 Q. Okay. Did Stephanie introduce you18 at that event?19 A. Stephanie invited me. I was her20 guest, and she did introduce me.21 Q. Was this in the summer of 2001?22 A. It was.23 Q. Was Morris Sutton there?24 A. No. I think it was a women's event.25 Q. Okay. Have you ever spoken to


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1 SALZMAN - DAY II2 A. I can't remember.3 (Recess taken.)4 (Exhibit Salzman 34 marked for5 identification.)6 MR. KOFMAN: Ms. Salzman, we've7 marked document Salzman 32, Bates Stamp No.8 P000004 109.9 Q. Are you familiar with this

10 document?11 A. This is an enrollment application.12 Q. For Stephanie Franco?13 A. Yes.14 Q. And does this indicate that she's15 enrolled for an intensive starting June 23rd in16 Albany?17 A. Yes, it is ..18 Q. Do you know why this document is19 Bates stamped highly confidential?20 A. No, but it seems as though it's a21 pattern. Everything we've given you says highly22 confidential.23 Q. Okay. Was this the application for24 the first class that Ms. Franco signed up to take?25 A. I think it was.


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1 SALZMAN - DAY II 12 Q. And she signed np to take a 23 five-day class? 34 A. Yes. 45 Q. Do you know what the -- on the top 56 left-hand corner there's the letter F circled. 67 Do you know what that means? 78 A. I don't. 89 Q. And do you know whose handwriting 9

10 appears in the middle at the top, "set up grade" 1011 and it looks like "attached"? 1112 A. I don't know. 1213 Q. Do you know what that means? 1314 A. No. 1415 Q. Okay. So, this indicates that she 1516 had signed up for a five-day intensive beginning 1617 June 23rd, and that the cost was $2,160? 1718 A. That's correct. 1819 Q. Okay. Do you know how Stephanie 1920 Franco came to sign up for this or what led her t 2021 sign up for this intensive? 2122 A. I assume she had further 2223 discussions with people, including Michael. 2324 Q. Did she have further discussions 2425 with you? 25


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1 SALZMAN - DAY II 12 Q. Did you have any communications 23 with Stephanie between the date of this 34 application, which is May 5th, 2001, and June 45 23rd, 2001, when she arrived at the intensive? 56 A. I don't remember. 67 Q. Okay. After Stephanie arrived at 78 the intensive, do you recall going out to dinner 89 with her? 9

10 A. I prohably did. I believe that I 1011 went out to dinner with her at some point, and it 1112 may have been during the intensive. 1213 Q. Okay. Was that a common practice 1314 of yours, to go out to dinner with students? 1415 A. I had met Stephanie prior to that 1516 and we liked each other. I will often go out with 1617 people who are either students that I like or 1718 students that there's a special consideration. 1819 And Stephanie was a therapist. So, there was a 1920 special consideration to let her into the program 2021 at all. And so, for me to check in with her would 2122 not be unusual, under those circumstances. 2223 Q. When you say there was a special 2324 consideration, that's the fact that Stephanie wa 2425 a therapist? 25


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SALZMAN - DAY IIA. I want to say yes.Q. Do you recall any of those

discussions?A. I remember knowing she was coming,

and I remember looking forward to seeing her, so Iknew that she was coming, and I think I knew thatbecause she told me.

Q. Okay. And this indicates thatMichael Sutton was the person who referred her tthe group?

A. That's correct.Q. Did Michael Sutton receive a

commission for Stephanie's enrollment?A. I don't know ifhe was a

salesperson at that time or he just enrolled her.There was a requisite of how many people you hadto enroll to become a salespeople.

Q. Would somebody who was not asalesperson receive a commission for enrollingpeople?

A. No.Q. Okay. So, it was only salespeople

who received commissions?A. That's correct.


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SALZMAN - DAY IIA. That's correct.Q. You mentioned before that NXIVM

does a screening before letting psychiatrists,psychotherapists, psychologists in. What was thnature of that screening that was done withStephanie?

A. I remember discussing with her thereason why we didn't let people who weretherapists normally take the program, and underwhat circumstances I would let her take theprogram.

Q. And what did you say was the reasonyou don't like therapist to take the programordinarily?

A. Because once they take theprogram -- because of the nature of the materialand how the model works, it's hard for them to notuse what they've leamed. So, rather than havethem have to have the dilemma trying to figure outwhat they knew before the program and what theylearned in the program, and rather than taking thematerial and accidentally incorporating it in andwatering it down in some way, we want to keep thematerial very clean and teach it.


1 SALZMAN - DAY II 12 Q. When did you have that discussion 23 with Stephanie? 34 A. The first night I met her. 45 Q. That was at the Suttons' home? 56 A. Yes. And I believe that I had it 67 with her again at least one other time before she 78 decided to take the program. And I don't remember 89 ifit was a phone conversation or if] saw her 9

10 again. I have a vague recollection of actually 1011 seeing her a second time before. 1112 Q. And what did she say in response? 1213 A. She said that was fine and she 1314 understood. 1415 Q. Did she indicate that she was 1516 thinking of giving up her therapy practice anyway. 1617 A. She did. 1718 Q. Did you mention, at the dinner, 1819 that you went out -- strike that. 1920 Did you take any other students out 2021 to dinner at the same time as Stephanie? 2122 A. I don't remember. 2223 Q. Do you remember wbo else attended 2324 the dinner? 2425 A. I don't remember. 25


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SALZMAN - DAY IIQ. Was your daughter, Lauren, there?A. She might have been.Q. Are you aware that Lauren Salzman

became Stephanie's coach?A. I think she liked my daughter a lot

and I think she asked for her to be her coach.Q. Who's responsible for selecting

coaches for students? Strike that.Does each student get a coach?

A. Yes, they do.Q. And who is responsible for the

selection of coaches?A. Normally there's a committee that

decides.Q. And who was on that committee in

2001?A. Probably Pam Cafritz headed up that

committee. And I believe back then Barbara Jeskewas on that committee, and Lauren, my daughter,would have been on that committee.

Q. Did you have any involvement?A. I did because of Stephanie being a

therapist.Q. SO, you -- and did you agree that


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1 SALZMAN - DAY II2 Lauren should coach Stephanie?3 A. When she asked for Lauren and4 voiced her intent to not only become a coach but5 to become a proctor I told her that she could have6 Lauren, she wouldn't normally have gotten Lauren7 because Lauren's rank would have not been someone8 who would have been coaching Stephanie, unless it9 was a special circumstance.

10 But Stephanie made assertions that11 she wanted to move through the program quickly12 because she wanted to be ahle to leam the13 technology.14 Q. When did she make those assertions?15 A. Right in the beginning, when she16 starting taking the class and liked it.17 Q. Was that at the dinner that you18 attended?19 A. It was before the end of that20 intensive.21 Q. Before the end of that intensive22 that she signed np for?23 A. Yes.24 Q. But you're not certain where within25 that intensive -- when within that intensive she


1 SALZMAN-DAY II2 made the statement?3 A. We normally assign the coach the4 last day of the intensive.5 Q. Okay. Oh, the coach is not6 assigned on the first day of the intensive, it's7 after?8 A. Always. We try to get to know the9 student and what they're interested in and what

10 their goals and objectives are during the five-day11 and then match them to a coach that can hest coach12 them.13 Q. Did you indicate, during this14 dinner, that you had plans for Stephanie within15 the organization?16 A. I indicated to Stephanie that if17 she liked the model, because ofher prior18 education, and there were very few people, whoever19 came into the program with her prior education,20 that I saw it as an advantage to us and to her21 because I thought she'd move through it quickly,22 and I thought she would learn it easily, and that23 obviously she enjoyed that sort of thing because24 that's what she picked as her career. And so, if25 she wanted to do that, I thought that this -- if


to?A. Lisa Durkes.Q. When was this?A. The fourth day.Q. Was this after you had gone to'

dinner with her or before?A. I'm not quite sure.


SALZMAN - DAY IIQ. Did you see a copy ofthe long form

confidentiality agreement with her signature onit?

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1 SALZMAN - DAY II2 she liked it, this would be perfect.3 Q. What prior education were you4 referring to in your answer that you thought mad5 her well-suited?6 A. Well, she liked social work, and7 she really enjoyed working with people, which I8 think coaching is working with people.9 Q. Did you discuss with her the

10 prospect of her opening a school?11 A. I don't know if! did it then, but12 I knew that Michael wanted to have a school in his13 community.14 Q. And he thought that Stephanie might15 he a good person to run it?16 A. She was looking for a new career or17 something else to do. So, it seemed like that18 would be a good fit. And I know that at some19 point we discussed that if she liked it, that20 would be -- she wouldn't have to move to Albany to21 do it. She could do it right there.22 Q. Did you ever have discussions with23 Michael ahout him opening a school?24 A. Michael is in New York City. He25 lives in New York City, and he's very active in


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12345 A. I did.6 Q. Where did you see it?7 A. It was an ordeal because the first,8 day that she came, she was late, and she hadn't9 signed it, and we asked her to sign it and she

10 wanted to get into the class, and she was reading11 it, and she determined that there was something in12 the agreement that caused her to not want to sign13 it until she showed it to her attorney.14 I guess Lisa offered her the15 opportunity to call her attorney, but she said16 that it was Sabbath, and she couldn't call her17 attorney until after Sabbath. So, the next day18 came, and it was Sunday, and she said she couldn't19 reach her attorney because it was Sunday, so we20 made a special consideration and said that on21 Monday you need to call your attorney.22 And on Monday we asked her for the23 long form, and she said that she was getting in24 touch with her attorney. By the end ofMonday we25 still didn't have it, and we told her that she


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1 SALZMAN - DAY II2 the center in New York City. I don't know about3 ever asking him to open one, but I know that he4 was very active in helping with facilitation in5 that one.6 Q. Do yon recall an issue concerning7 Stephanie's long form confidentiality agreement.8 A. Yes, there was quite an ordeal9 about her long form, which was in Albany.

10 Q. Did you personally see her sign the11 long form confidentiality agreement?12 A. I did.13 Q. You witnessed it?14 A. I did.15 Q. Where did you see -16 A. I didn't witness her signing it. I17 witnessed her giving it.18 Q. Okay. Who did you see her give it19202122232425

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1 SALZMAN - DAY II2 couldn't come back to class the next day unless3 she had it because we had already waited three4 days, and we couldn't wait any longer, and she5 couldn't come back to class without it. She gave6 it back to us on the fourth day.7 Q. Okay. And she gave it to Lisa8 Durkes?9 A. Yes.

10 Q. Who was Lisa Durkes in 2001?11 A. She was the chairman of the12 intensive committee, and she oversaw the13 administration of the intensive itself.14 Q. How did it happen that you saw her15 give it to Lisa Durkes?16 A. I was teaching that morning.17 Q. And when did you see the agreement18 signed by Stephanie or witb Stephanie's signature, ,19 A. The other thing was that sbe wanted ..20 to come to a forum that Keith was giving, and she21 couldn't come to the forum without it. And so, in22 the morning, I wanted to be sure that I had the23 agreement because there was a decision as to24 whether Keith was going to come and do a forum or25 not, and whether we were going to let her stay or


file?A. No, I didn't.Q. Do you know whether the agreemen


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1 SALZMAN - DAY II2 not, because she was Michael's sister, and there3 were a series of things that were going on where4 Stephanie got special consideration because of5 being Michael's sister.6 Q. Okay. So, you physically saw the7 agreement signed by her?8 A. I did.9 Q. How do you recall that?lOA. Well, I looked for it.11 Q. Where did you look for it?12 A. When she came in that morning, I13 was looking for it and I asked her for it, and I14 saw her give it to Lisa, and then I looked at it.15 Q. While Lisa had it?1 6 A. Correct.17 Q. What did Lisa do with it?18 A. Lisa had a series of folders much19 like this, where every student had a name. And20 she had one in each, and she had it in her bag,21 and she was carrying it because there22 were certain -- there are certain documents in23 each intensive for each student, and the24 facilitators fill out certain forms, and they're25 added to the files, so the files are out. And the


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1 SALZMAN - DAY II2 confidentiality was in there at the end of the3 five-day. At that point, they were filed.4 Q. And where were they filed?5 A. In the room where we lock them.6 Q. Is that the proctor room?7 A. That's correct.8 Q. SO, they were in Lisa Durkes'9 possession during that day?

10 A. Yes.11 Q. And that was the fourth day?12 A. Yes.13 Q. Did she put them in the room that14 night or would it be after the fifth day?15 A. After the fifth day.16 Q. But they were in her bag?17 A. They were in her bag.18 Q. Do you have any idea whether Lisa19 left her bag unattended at any point?20 A. Lisa left her bag unattended at21 some point. She walked out of the room.22 Q. Did you ever see Stephanie take the232425

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1 SALZMAN-DAY II 12 was ever placed in the proctor room? 23 A. According to Lisa, when they went 34 to file it, the long form wasn't there. 45 Q. When did they go to file it? 56 A. AttheendoftheI6-day. 67 Q. Did she tell you that at the end of 78 the 16-day? 89 A. She did not. 9

10 Q. When did she tell you? 1011 A. I don't remember. 1112 Q. Was it before or after this lawsuit 1213 was filed? 1314 A. I don't remember. 1415 Q. What did you do after she told you? 1516 A. I asked if they had followed up or 1617 ever called her or tried to get another one. 1718 Q. And what did she say? 1819 A. She said no. 1920 Q. Okay. Just so I'm clear, Lisa 2021 helieves that the material was put in tbe proctor 2122 room, or helieves that it was not, that that 2223 application went into the proctor room? 2324 A. No. She said when she went to file 2425 it, it wasn't there. 25


SALZMAN - DAY IIQ. Okay. Now, you mentioned a 16-day.

Stephanie origiually signed up for a five-dayintensive starting June 23rd

Did it turn out that she stayed fora full 16 days?

A. I believe she stayed through thewhole training. She may have gone home and comeback. My recollection was that she ended upfinishing it, that intensive.

Q. SO, sbe finisbed tbose 16 days?A. That's my recollection.Q. Do you remember what led her to

extend her stay from five days to 16 days?A. I think she liked it.Q. Did you attempt to persuade ber to

stay tbe full 16 days?A. I'm sure I was optimistic about it.

I liked Stephanie. I wanted her to stay. Iwanted her to like it.

Q. Do you see tbat sbort formapplication?

A. Yes.Q. And it's dated June 27th, 2001?A. Yes.


1 SALZMAN - DAY II 12 Q. That would have been the fifth day 23 of her intensive? 34 A. Yes. 45 Q. And is that her application to 56 extend her stay for the full 16 days? 67 A. It appears it is. 78 Q. And the fee for that was $4,590? 89 A. That's correct. 9

10 Q. And so, she stayed through, I 1011 guess,1I days plus June 27th? 1112 A. That's correct. 1213 Q. Okay. Does NXIVM have any other 1314 applications for Stephanie Franco? 1415 A. These two. 1516 Q. Are you aware of any others? 1617 A. J don't know. I'm not a lawyer. 1718 Q. Okay. During the J6-day intensive 1819 that Stephanie Franco attended, did NXIVM presen 1920 her with any materials heyond what a student would 2021 ordinarily receive? 2122 A. NotthatJrecall. 2223 Q. Did it give her facilitator notes 2324 during those 16 days? 2425 A. Not that J recall. 25


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SALZMAN - DAY IIQ. Would that have been contrary to

NXIVM's practice to give facilitator notes to astudent taking their first 16-day intensive?

A. Well, it would be because theywouldn't be prepared for them.

Q. Did Stephanie advance in rank atNXIVM as a result of completing the 16-dayintensive?

A. She met the requirements, inaddition to completing the intensive. Oh, you canadvance in rank. You can get a couple of stripesas a student, but not a coaching sash.

Q. You can get your couple of stripeson your white sash?

A. That's correct.Q. Did she; do you know?A. She probably got at least one, and

she may have gotten two, but she would have had toenroll someone to get the second one.

Q. Did Stephanie enroU people atNXIVM?

A. She became a coach, so that meansshe enrolled at least two.

Q. That's what I was going to ask you.TSG Reporting- Worldwide (877) 702-9580

Page 336

1 SALZMAN - DAY II2 Did she obtain the rank of coach at NXIVM?3 A. She did.4 Q. Did she take the coaching5 curriculum?6 A. She did.7 Q. Did she complete the coaching8 curriculum?9 A. I don't believe she completed it.

10 Q. How did she hecome a coach without11 completing the coaching curriculum?12 A. You take the coaching curriculum13 while you're a coach, and then you work your way14 up. You get stripes and things, which I don't15 think she ever did.16 Q. And so, you become a coach after17 you take the five-day - that five-day intensive?18 A. You don't nonnaily. If you choose19 to, you do.20 Q. Okay.21 A. It's a different -- you're entering22 a different program. It's a different curriculum.23 There are several different curriculums you can2 4 take after you take your first 16-day.25 Q. And to enter the coaching


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SALZMAN - DAY IIcurriculum, she would then have had to havecompleted the 16-day and then completed anothefive days?

A. To enter the coaching curriculum?Q. Yes.A. She may have been able to take some

of the early coaching modules while she wasfinishing the pre-requisites for the secondfive-day.

Stephanie traveled to Albany, in myrecollection, a couple of times to take modulesoutside of intensives in our Ethos program.

Q. Okay.A. And, also, I believe that there

were some modules that were taught in Deal withsome of the students. And I don't remember whatthe circumstances were, but I do remember that afacilitator went down and taught a couple.

Q. Who was the facilitator who wentdown and taught?

A. I think Barbara Jeske went down andtaught. And I remember also that I stopped in andvisited, but I don't think I was the one who wasteaching those classes.


I

1 SALZMAN - DAY II2 Q. When did you stop in and visit?3 A. During that time that Barbara was4 doing something in Deal with Stephanie.5 Q. Was that at the time you were at6 this event at the next door neighhor's house?7 A. I think it was at the same time. I8 remember Stephanie wanted us to teach the9 curriculum. She seemed to be -- have a strong

10 desire to learn as much as she could, as fast as11 she could.12 Q. And did - were applications13 required for the Ethos classes that she may have14 taken in Deal?15 A. Probably not.16 Q. Why not?17 A. Stephanie made strong assertions18 that she wanted to become a coach. My guess was19 because she signed up for the next five-day, she20 signed up for another five-day, she was permitted21 to take some of those classes because they were22 just repeated classes from the previous intensive.23 And what she was really trying to do was qualify24 for the coaching curriculum.25 Q. What was taught at the next


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1 SALZMAN - DAY II2 five-day that she attended?3 A. The same thing as the first4 five-day but the second time around it has a5 different meaning to you.6 Q. Okay. But as you sit here today,7 you're not aware of an application she filled out8 for that second five-day?9 A. I don't know. I would have to go

10 back and look and see if she did or she didn't.11 MR. KOFMAN: Okay. And I represent12 that none has been produced here.13 Q. Did you teach the second five-day14 that she attended?15 A. I don't remember. I wasn't16 teaching all of the intensives back then. I only17 taught some, you know, selected classes usually at18 that point.19 (Exhibit Salzman 35 marked for20 identification.)21 Q. By the way, did Stephanie ever22 become a facilitator at NXIVM?23 A. I don't think so.24 Q. Looking at Salzman 35, do you25 recognize this document?


•

•

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SALZMAN - DAY II 1A. This was a document that I think 2

classified the people that she enrolled in her 3organization. It also told who her upline proctor 4was, and her coach, and her field trainer. 5

Q. Okay. Let's go through this. 6First of all, "signer Michael 7

Sutton." That refers to the person who brough 8her into the group? 9

A. Yes. 10Q. "Parent Michael Sutton." What do 11

you mean by "parent"? 12A. Isn't that funny? I was thinking 13

the same thing. I wonder who created this. I 14guess that is the person who brought her in. 15

Q. Okay. What's the reference to 16"field trainer Barbara Bouchey"? 17

A. Your field trainer is the person 18who is the sales expert whose organization you're 19m. 20

Q. Is Barbara Bouchey the person who 21conducted tbat five-day training that Stephanie 22bad - 23

A. No. 24Q. - after the 16-day? 25


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SALZMAN - DAY IIA. A field trainer is not a head

trainer. A field trainer is a salesperson. IQ. And "proctor Carole Bergeron," what

does that refer to?A. Carole Bergeron was, I guess, a

proctor at that time. And Carole Bergeron is theperson who brought Michael Sutton in. So,Stephanie was in Carole Bergeron's organizationbecause she was in Michael's organization.

Q. Okay. And"coach Lauren Salzman" •we've already gone over. Wbat is "first child"?

A. Well, if! look at this, the twopeople she brought in were Jo Ann and Jennifer. I .don't understand. I'm not really quite sure. Wedon't use this anymore.

Q. Do you know wbo was responsible forentering in student information in 2001?

A. It might have been Angel Smith.Q. Is he still with tbe group?A. She.Q. She. I'm sorry.A. Yes, she is. And I believe sbe's

still doing the same job.Q. Do you know who Linda Hidarq is?


,Page 3411

1 SALZMAN - DA Y II 12 A. I don't, but I'm going to imagine 23 that Stephanie brought them both in. 34 Q. And then it says: 45 "Per students personally sponsored 56 to Jo Ann Levy and Jennifer Ancona." 67 A. I'm going to guess that Stephanie 78 enrolled Jo Ann and Jennifer, and that Jo Ann 89 enrolled Linda, and that's why I think it says it 9

10 that way. 1011 Q. That's what made Linda next 1112 sibling? 1213 A. I think so. In other words, 1314 they're in the same level, not underneath. 1415 Q. Do you know if Jo Ann Levy and 1516 Jennifer Ancona were students at NXIVM? 1617 A. The fact that it says "personally 1718 sponsored" by Stephanie would cause me to think 1819 so, but I would have to check to be sure. 1920 Q. Would they actually have had to 2021 have been students for her to qualify for the fas 2122 track for the coaching curriculum? 2223 A. Yes. I'm not questioning whether 2324 she did it or not. I'm questioning whether they 2425 were the ones that are why she did it. 25


Page 343

1 SALZMAN - DAY II 12 series of proctors. I don't know who you're 23 referring to. 34 Q. You mentioned before tbat tbe 45 person who is responsible for coJlecting 56 facilitator materials at the end of each day is a 67 proctor. Do you know who the proctor was? 78 A. At that intensive? 89 Q. At tbat intensive. 9lOA. I don't know offhand, and it's 1011 probably in the documentation somewhere. 1112 Q. I was going to ask tbat. Does 1213 NXIVM have documentation that shows who would be 1314 the proctor? 1415 A. I can lookand see who the head 1516 proctor of that intensive was. If it's kept, it 1617 was a longtimeago. 1718 MR. KOFMAN: If you could, I'd 1819 appreciate that, and maybe mention it 1920 tomorrow. 2021 Q. Did you allend the live-day session 2122 that Stephanie allended? 2223 A. I attended it, and I taught some of 2324 theclasses. 2425 Q. But not all of tbem? 25

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SALZMAN - DAY IIQ. Okay. Does NXIVM have a list of

its coaches that it keeps somewhere?A. It has a list of all of its

students and the rank that they've achieved.Q. Is that kept on a computer

somewhere?A. Yes.Q. SO, for Stephanie Franco there

should be a document that indicates that she wascoach?

A. Yes.Q. Whose responsibility was it to

enter that information? Would that have beenAngel Smith?

A. That's what Angel Smith used to do,although it may have been -- some of theinformation in that may have been also theresponsibility ofher proctor.

Q. Who was the proctor who - and herproctor being Carole Bergeron?

A. Correct.Q. Who was the proctor at the live-day

intensive that Stephanie attended?A. The proctor? It could have been a


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SALZMAN - DAY IIA. I don't think I taught all of them.

I may have, but I don't think that I did.Q. By the way, did you ever do an

exploration of meaning with Stephanie hefore shhad taken any classes there?

A. Not that I remember.Q. It's possihle that you did?A. It's possible. Sometimes I did.Q. Does NXIVM videotape its breakout

sessions?A. No.Q. Did NXIVM give Stephanie

facilitator notes during the five-day trainingthat she attended?

A. I wouldn't know.Q. Who would know?A. I don't know what she did in that

five-day training. If she was coaching, she mayhave had facilitator notes. If she was a student,she wouldn't have had facilitator notes.

Q. Okay. Did Kristin Keeffe have anyinvolvement with that five-day training?

A. I don't remember, but it's possibleshe could have because back then she used to do


Page 346

1 SALZMAN - DAY II 1 SALZMAN - DAY II2 that as a function. 2 ended her relationship with NXIVM?3 Q. And, by the way, just to get a time 3 A. Well, yes, she did end her4 frame, is it your recollection that tbe five-day 4 relationship.5 training was in August of2001? 5 Q. When was that?6 A. The second one? 6 A. She did her five-day, and during7 Q. Yes. 7 the five-day she seemed very positive and wanting8 A. Yes. 8 to do more. And so I invited her to come to an9 MR. Me GUIRE: The second five-day? 9 intensives we were teaching in Mexico, which she

10 THE WITNESS: Yes. The first one 10 was very excited to come to because she said she11 was in June. 11 spoke Spanish and she thought it would be great.12 Q. Did Stephanie complete the second 12 It was our first intensive in13 five days oftraining? 13 Mexico, and we were very excited about it. And14 A. I believe she did. I think -- I 14 she asked if she could come, and I thought it15 have a vague recollection that somebody died in 15 would be great for her to come and have that16 her family during that training, or somebody close 16 experience. And she said she was going to come17 to her, and she needed to leave at a certain 17 and she seemed very positive about it, and that18 point. And I can't remember if it was at the end 18 she was going to come. And the last that I spoke19 or she left in the middle and came back. But I do 19 to her, I assumed she was coming, and then we got20 remember that there was some reason that she had 20 there and she never showed up.21 to leave. 21 Q. You expected her to be tbere in22 Q. Was she supposed to stay longer 22 Mexico?23 tban the five days? 23 A. Yes. e

24 A. Not that I recall. 24 Q. Who raised the idea of her going to •,25 Q. Did there come a time wben she 25 Mexico? Was it her or you?

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1 SALZMAN - DAY II 1 SALZMAN - DAY II2 A. It may have been her and it may 2 somewhere around September of 2001?3 have been me. I remember at the time it was sort 3 A. Yes, because she didn't come and I4 of an exciting possibility and everyone wanted to 4 thought maybe something had happened, and I was i5 go. 5 worried about her.6 Q. And this was the first time you had 6 Q. And did you ever speak to ber?7 taught in Mexico? 7 A. I don't remember whether she took8 A. This was the first time we had 8 my call, but I remember leaving -- I remember9 taught in Mexico, and it was a large intensive, 9 looking for her and trying to fmd her because I

10 and we were all excited about the possibility. 10 couldn't understand what had happened.11 But the reason that she said that 11 Q. Do you remember leaving her a12 she thought it would be really fun for her to go 12 message that her failure to complete NXIVM wa13 was because she spoke Spanish. 13 indicative of other problems she had in ber life? -14 Q. Okay. After she left, did yon make 14 A. I don't remember saying that, but15 any attempt to contact Stephanie to get her to 15 it may have matched a pattern that she was working16 come back to NXIVM? 16 on. ,;

17 A. I tried to contact her to make sure 17 Q. And so, you might have pointed out ~18 everything was all right because it seemed odd to 18 that this matched a pattern in her life? I

19 me that she didn't show up. 19 A. I might have.20 Q. And would tbis have been sometime 20 Q. When was the last time you tried to I

21 in August or September of 2001? 21 contact her? ~,22 A. That intensive happened in 22 A. I think it was during that -23 September, at the very beginning, because we were 23 intensive from Mexico. I don't know if I did when24 there during 9/11. 24 I came home or not.25 Q. And so, you tried to contact her 25 Q. Did you ever discuss with Michael

TSG Reporting - Worldwide (877) 702-9580 TSG Reporting - Worldwide (877) 702-9580

..

..

!

1 SALZMAN - DAY II 12 why she left? 23 A. I'm sure I did. 34 Q. Do you recall what he said? 45 A. I don't. 56 (Exhibit Salzman 36 marked for 67 identification.) 78 MR. KOFMAN: For therecord, this 89 is a document that we produced in discovery 9

10 that bearsBates Stamp SF 00042. 1011 Q. Do you recognize this document? 1112 A. I do. 1213 Q. What are projectivequestions for 1314 facilitators? 1415 A. They arepartof the coaching 1516 curriculum. They're a high level of coaching 1617 curricwum. 1718 Q. When in the coachingcurriculum are 1819 tbey taugbt? Which of the three levels? 1920 A. Now? 2021 Q. Back in 2001. 2122 A. We hadn'tdesignated the three 2223 levelsback then. 2324 Q. Wben would they be provided? Wben 2425 in the coacbing curriculum would tbey be provided? 25


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SALZMAN - DAY IIA. Back then?Q. Yes.A. This had just been developed back

then. I think that she was one of the first andonly students to ever take this class.

Q. What class was this taught in?A. Projective questions.Q. Did NXIVM, at some point, stop

teaching projective questions?A. We developed the curriculum and

then we created -- we finished creating the matrixof how the classes would be taught, and wedidn't -- we haven't yet taught this again.

Q. How long was -- what period oftimewas this taught in?

A. This was taught in -- well, rightthen, when Stephanie was there. That's when wewere first developing it.

Q. Sometime in 2001?A. That's correct.Q. And when was it discontinued?A. It wasn't discontinued. It's just

that it's in a part ofthe curriculum that's ahigh level that very few students have. It's not


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SALZMAN - DAY IIthat we've never taught it, but there are onlyvery few students who have gotten to that level.

Q. Right. But at the time thatStephanie took the classes, it was not part ofthat high level?

A. We were looking for people whowanted to learn the tech, how to use it with otherstudents, the EM technology, and Stephanie madeassertions that she really wanted it and asked ifshe could be included in that class.

Q. This is part ofthe exploration ofmeaning technology?

A. Correct.Q. Do students who complete the

coaching curriculum, are they exposed to thismaterial now?

A. If they reach a certain level withthe EM technology.

Q. And how many people have reachedthat level?

A. Under 25.Q. Do you have a list of who those

people are?A. I probably could assemble one, but


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SALZMAN - DAY III know there aren't more than 25.

Q. And that's because most otherstudents don't want to take this level oftechnology?

A. No. It's because they haven'treached a level where they test beyond this level,to get to this level.

Q. Since 2001 you've put certainobstacles before students can get to this level,is that fair to say, or requirements?

A. Yes. Having developed thecurriculum and understanding better how it worksin the development of it, it appears that teachingthis too soon makes it harder, not easier, forthem to learn the pre-requisites.

So, it's easier, once they'vecompleted those, to then introduce this, than tointroduce it earlier, in terms oflearning style.

Q. Who are some of the other peoplewho have been taught this?

A. I would say Lauren Salzman -- offthe top of my head, Lauren Salzman, KarenUnterriener, Tracy Christopher, Lisa Durkes,Kristin Keeffe, Pam Cafritz, Shavone Hoteling



says:

Yes.Did it submit this to the copyright

"Copyright 2000 Executive SuccessPrograms, Inc."

Did NXIVM register a copyright on

She probably did.How about Susan Dones?I don't think so.Okay.. I note that at the bottom it

•

•1 SALZMAN - DAY II2 Q. What are - you mentioned where3 this fits in. What are the projective questions4 for students? What are tbese used for?5 A. They're used for the process of6 exploration of meaning.7 Q. This is to help someone guide a8 student through an exploration of meaning?9 A. Correcl.

10 Q. And this indicates questions tbat11 might be used to guide tbem through?12 A. It does.13 Q. Could someone who bad this piece of14 information conduct an exploration of meaning, 0

15 would they need something else?16 A. Well, it wouldn't be -- they could17 explore meaning with this, but it wouldn't be, in18 my opinion, the best first thing to teach somebody19 in teaching them the exploration ofmeaning.20 Q. SO, someone who had this and just21 asked these questions, how would they go about22 doing an exploration of meaning?23 A. Someone who understood the nature24 ofprojection and had these questions could25 explore someone's deep structure.

TSG Reporting - Worldwide (877) 702-9580(877) 702-9580

this?A.Q.

office?A. Yes.

TSG Reporting - Worldwide

SALZMAN - DAY II(phonetic), probably Edgar Boone. Loretta Garza,Daniela Padilla, Marcello Ortez.

I can't remember others, but I knowthat there are more than that, just off the top ofmy head.

Q. Can one be a field trainer withoutbaving taken this class?

A. Field trainer has nothing to dowith EM technology. Head trainer does.

Q. Did Barbara Bouchey bave access tothis?

A.Q.A.Q.

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Page 355 Page 356

1 SALZMAN - DAY II2 Q. But they would have to have had3 some background in projection?4 A. Psychology, yes.S Q. SO,someone in psychology?6 A. Or understand the nature of7 projection.8 Q. Okay. Does everyone who - do all9 NXIVM students undergo an exploration of meaning?

10 A. If they choose to. It's not a11 pre-requisite.12 Q. It's not a necessary requirement13 for an intensive?14 A. If someone chose not to have it,15 they wouldn'thaveto.16 Q. Each student can make their own17 decision?18 A. Absolutely.19 Q. Does the exploration of meaning20 help NXIVM market itself! Do you market yourself21 as conducting these exploration of meanings or22 tell prospective students about them?23 A. One ofthe things that is probably24 unique to us is the process of exploration of25 meaning, and it's a very effective process. So,


1 SALZMAN - DAY II2 it might be described to an incoming student, and3 very likely would be.4 Q. And so, this is something that they5 might make their decision whether or not to attend6 classes on?7 A. Yes. In my opinion, yes.8 Q. And it's explained to them before9 they take the classes or after they've signed up?lOA. It isn't traditionally explained,11 but it could be.12 Q. And when could it be explained?13 A. One of the things that our program14 does well is if one has a limiting belief, that15 belief is an area of their life where they feel16 limited where they're not actually limited.17 An exploration ofmeaning will18 uncover the fact that they're not actually limited19 and show them that it was just -- that it was an20 area of inconsistency in their belief system.21 Q. But in order to do that, somebody22 would need to knuw more than just this, this23 document. They'd need to know a projection. An<24 would they also need to know other elements of25 rational inquiry? Strike that.


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1 SALZMAN - DAY II2 Q. Were you aware that Stephanie3 Franco had requested a refund for a course tha4 she had attended?5 A. I don't remember.6 Q. Okay. Do you see that the letter7 says, in the second paragraph:8 "In reviewing her request for9 refund, I was unahIe to locate Stephanie's long

10 form confidentiality agreement."11 Do you see that?12 A. Yes.13 Q. Is that how NXIVM learned that the14 signed long form confidentiality agreement was15 missing?16 A. I don't know.17 Q. Okay. You believed that Ms. Durkes18 had told you that earlier?19 A. I do.20 Q. Okay. Put this aside.21 When did you learn that Rick Ross22 had been hired to conduct an intervention with23 Michael Sutton?24 A. It was Thanksgiving of that year.25 Q. What year?


SALZMAN - DAY IIIs this an element of rational

inquiry?A. This is an element of rational

12345 inquiry.6 Q. Would they need to know more7 elements of rational inquiry besides this to8 conduct a valid exploration of meaning?9 A. That would depend on how you would

10 define a valid exploration ofmeaning.11 Q. Would they need to know more12 elements of rational inquiry than this to condue13 a useful exploration of meaning?14 A. I don't know. I'm not sure.15 (Exhibit Salzman 37 marked for16 identification.)17 Q. Ms. Salzman, are you familiar with18 this document?19 A. I don't think that I ever saw this2 0 document.21 Q. Okay. Do you know ifthe Lauren22 here is Lauren Salzman?2 3 A. I'm sure it is.24 Q. Do you know who Karen is?25 A. Karen Unteniener.


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1 SALZMAN - DAY II 12 A. 2002, I believe. 23 Q. And how did you learn that? 34 A. Michael called me from Florida. 45 Q. And what did Michael say? 56 A. That he was on vacation with his 67 family, and that there was this guy there who was 78 a cult deprogrammer, and he was attempting to 89 deprogram Michael. 9

10 Q. Had you ever heard of Rick Ross 1011 before? 1112 A. I don't think I had. 1213 Q. How many times during the course 0 1314 the time he was on vacation in Florida did you 1415 speak to Michael? 1516 A. I thinkI spoke to him more than 1617 once, and I know others in the organization had 1718 been speaking to him as well. 1819 Q. While he was down in Florida? 1920 A. Yes. I believe he made a number of 2021 calls. 2122 Q. Who did he call; if you know? 2223 A. I believe he called Pam Cafritz, 2324 because I remember that Pamela told me that 2425 Michael was in Florida, and that she had gotten a 25


SALZMAN - DAY IIphone call that she thought was odd.

Q. What did - do you know anyone elsethat he called?

A. I can remember that a number ofpeople knew, but I can't remember who specificallyit was. It was a long time ago.

Q. Who - what did you tell Michaelwhen you spoke to him?

A. Well, I don't think I took itseriously. It seemed odd to me, and it seemedkind oflike not, you know, something that wouldbe real. I mean, we're not a cult. There'snothing about us that's cult-like. And thethought of somebody thinking it was a cult, Ithought it was kind ofhumorous.

But then I realized it was seriouswhen I realized that he said that this man wasspending a lot of time with him and asking him alot of questions, and pursuing -- it was like aproblem.

Q. Was that all in the course of-did he tell you that this man was spending a lotof time while he was still down in Florida?

A. He called me the first time, and atTSG Reporting - Worldwide (877) 702-9580

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Ross?A. I actually -- I think -- I remember

discussing it with my daughter, and my daughterstarted doing some research on it.

Q. On the computer?A. On the computer and also she

started looking up books and things that she couldfind out what this cult deprogranuning was.

Q. And what did she tell you aboutRick Ross?

A. She didn't tell me much then. Itwas later that I found more out about Rick Ross.But back then it sort of didn't seem all thatserious.

Q. When you say "later," what do youmean by "later"?

A. Well, I remember that I think whenMicbael came home, he seemed more concerned. SoI mean, at first it wasn't something that I knewwas serious or thought was serious. And at firsthe was laughing when he toldme about it, and itseemed like a joke.

Q. When did you first believe it wasserious?


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1 SALZMAN - DAY II2 first I didn't take it all that seriously because3 he was sort oflaughing and joking about it, but4 then by the next day I realized that he had called5 other people too and he wasn't laughing anymore.6 Q. Did you give Michael any7 suggestions as to what he should say to Mr. Ross.8 A. I asked him to just find out as9 much information as he could, because I hadn't

10 ever had any experience with anything like this11 before.12 Q. Did you do anything as a result of13 hearing that Rick Ross was trying an interventio14 with Michael?15 A. I believe I started to try to16 figure out what it was all about. I think I17 started to try to figure out what it meant to18 do an intervention, who was doing this19 intervention, was he a therapist. I remember20 asking those kinds of questions.21 Q. To whom did you ask those22 questions?23 A. I think I asked Michael what he24 was. I had never heard of it.25 Q. Did you do any research on Rick


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1 SALZMAN - DAY II 12 A. I don't remember, but it was after 23 he came home. 34 Q. Okay. Did you have any discussions 45 with Michael about the possibility of hiring an 56 expert to evaluate NXIVM? 67 A. I remember back then when it seemed 78 like it was a real question as to whether we were 89 a cult we thought it would be a good idea if 9

10 someone evaluated us so that they would know we 1011 weren't a cult. 1112 Q. Did you say that to Michael? 1213 A. Yes. 1314 Q. And do you know if - did you have 1415 any suggestions as to who could be hired? 1516 A. No. 1617 Q. Did Michael or did you have - were 1718 any names presented to you by Michael or anyone 1819 else of potential experts? 1920 A. I don't think so at that time, but 2021 I do remember it was more ofa problem Michael was 2122 having, and that was more ofa solution we thought 2223 might be good for Michael to figure out. 2 324 Q. Did you encourage Michael to 2425 discuss hiring an expert? 25


Page 364

SALZMAN - DAY IIA. We discussed with Michael that if

he had concerns, it might be a good way toalleviate the concerns.

Q. When you say "we," who is we?A. I think there were a number ofus

in the organization who when Michael posed this asa real problem in his family, and was trying tofigure out what to do with it, that that becamesort of the solution we thought was a good one.

Q. This was after he came back fromFlorida?

A. Yes, to the best ofmyrecollection.

Q. Was this a discussion you had onthe phone or in person with Michael?

A. It was probably in person. He usedto corne up pretty frequently back then.

Q. Who were some of the peopleinvolved in those discussions besides yuu andMichael?

A. Probably Barbara Jeske and CaroleBergeron. Keith might have been involved becauseI remember that we had a few of these discussionsat volleyball.


1 SALZMAN - DAY II 1

2 Q. Did Michael ever tell you what 2

3 happened with the suggestion about hiring an 34 independent expert? 45 A. I knew he didn't, but I knew that 56 later as time went on. 67 Q. Did you and Michael talk about what 7

8 the independent expert would have to do to make an 89 evaluation? 9

10 A. No. It never got that far. 1011 Q. Okay. Did Michael ever tell you 1112 that Ross was asking him for course materials? 1213 A. I think he did tell us that. I'm 1314 pretty sure be did tell us he asked him for course 1415 materials. 1516 Q. Do you remember when yoo had that 1617 discussion? 1718 A. I think it was right after he got 1819 back from Florida. 1920 Q. And what was your response? 2021 A. Did you give them to him? 2122 Q. And what did you say? 2223 A. No. 2324 Q. After Michael got back from 2425 Florida, what was the next thing you heard about 25


Page 367

1 SALZMAN - DAY II 12 A. You know, I don't know who told me. 23 I believe it was Michael. 34 Q. What did Michael tell you? 45 A. That Stephanie gave her materials 56 to Michael's younger brother, Jeffrey, and Jeffrey 67 gave them to Ross. 78 Q. Did he tell you why Stephanie had 89 done that? 9lOA. It was Aaron Kasson who told me. 1011 Q. Oh, it was Aaron Kasson and not 1112 Michael? 1213 A. Yes. 1314 Q. Did Aaron tell you why Stephanie 1415 had turned over the materials? 1516 A. He didn't tell me why she did it. 1617 He told me that she did it. 1718 Q. Do you have any understanding, one 1819 way or the other, as to why Stephanie Franco 1920 turned over materials? 2021 A. No, I don't. 2122 Q. Okay. We previously marked an 2223 affidavit of yours. We had marked it as 26. I'd 2324 like you to read Paragraph 13, which is on page 3 2425 and carries over to page 4. 25


Page 366

SALZMAN - DAY IIRick Ross?

A. I think it was a while. I don'tthink I heard much about it until the spring orsummer of the next year. I can't really remember.

Q. Oe2003?A. Right.Q. Did you hear anything about Ross

before the Hochman and Martin articles appeared 0

the website?A. I don't remember that I did. But I

don't remember.Q. Did you take notes of any of your

conversations with Michael?A. I didn't.

(Recess taken.)(Exhibit Salzman 38 marked for

identification.)Q. What's your understanding of how

Mr. Ross obtained the materials?A. I was told that --

MR. MC GUIRE: Were you told byattorneys?

THE WITNESS: No.MR. MC GUIRE: Okay. Go ahead.


Page 368 "

SALZMAN - DAY IIA. Exhibit 3?Q. No, no, no. It's page 3 and page 4

of your affidavit.A. Do you want me to read 13?Q. Yes, Paragraph 13.

Who are the third parties that youcontend in that paragraph paid Rick Ross to obtai lthe materials?

A. Michael told me his father did.Q. What did Michael tell you?A. He told me that his father paid

Rick Ross to get those materials and to get himout of the organization.

Q. Did he specifically say to you thathis father paid to get the materials?

A. He specifically said his fatherhired Rick Ross and that Rick Ross wanted thematerials.

Q. But did he say to you that RickRoss had been paid to get the materials?

A. He said that his father promotedthe getting of the materials by encouragingStephanie to give them.

Q. Were those the words that he used?


IPage 369

1 SALZMAN - DAY II 12 A. No, those are my words. 2

3 Q. Okay. Do you remember what he 34 specifically said? 45 A. That he and Stephanie decided to 56 give them Stephanie's materials, and that his 67 father -- it's something to the effect of 78 promoting Stephanie giving the materials to Ross. 89 MR. Me GUIRE: When you say "he" -- 9

10 Q. When you said "he and Stephanie 1011 decided to give the materials," who is the "he" it 1112 that sentence? 1213 A. Stephanie's father, Morris Sulton, 1314 and Stephanie. 1415 Q. Did Morris Sutton have any 1516 materials? 1617 A. No. 1718 Q. Okay. Other than -- when did 1819 Michael tell you this? 1920 A. A number ofyears ago. 2021 Q. Other than what Michael told you, 2122 do you have any other iuformation that the 2223 Suttons - that Morris Sutton paid to -- paid Ros 2324 to obtain the materials? 2425 A. Aaron Kasson told me also that his 25


Page 371

1 SALZMAN-DAYII 12 Q. Okay. Do you know - strike that. 23 Do you know, one way or the other, 34 whether the Suttons were aware that Stephanie hac 45 a confidentiality agreement with NXIVM? 56 A. I don't have firsthand knowledge of 67 that. 78 Q. Do you have any knowledge? 89 A. I believe that Aaron told me that 9

10 they knew. I believe that Aaron told me that he 1011 told them. 1112 Q. When did Aaron tell you that they 1213 knew? 1314 A. It was when this first started 1415 happening. I had a conversation with Aaron when 1516 he carne to Albany once. 1617 Q. And Aaron told them - says he told 1718 them what? 1819 A. That the material -- that he had 1 920 signed a confidentiality agreement, that all the 2021 students who carne to NXIVM signed them, and that 2122 the materials were protected. 2223 Q. Did he say that he told that to 2324 Rick Ross? 2425 A. Yes, he did. 25


Page 370

SALZMAN - DAY IIfather-in-law paid Ross, and that Ross came to hishouse to try to get his materials, and that he,Aaron Kasson, told Ross that they were protectedand he couldn't have them.

Q. Did Aaron Kasson tell you that hisfather had paid Ross to get the materials or justthat he paid Ross?

A. That he paid Ross.Q. Okay. Other than what Michael and

Aaron have told you, do you have any otherevidence that Morris Sutton paid Ross to get thematerials?

A. I don't.Q. Do you have any other information

that Morris Sutton encouraged Stephanie to turnover the materials? ~

A. I don't. sQ. Do you know whether Rochelle Sutton

encouraged Stephanie to turn over materials toRoss?

A. I don't.Q. Do you know whether Rochelle Sutton

encouraged Stephanie to turn over materials?A. No, I don't know.


Page 372

SALZMAN - DAY IIQ. Did he say he told that to Morris

Sutton?A. Yes, he did.Q. Did he say he told that to Rochelle

Sutton?A. I don't remember.Q. Do you know whether that

conversation took place before or after Stephaniehad given materials to Ross?

A. My conversations with Aaron?Q. His conversation with Morris

Sutton.A. I can't remember. I do know that

it happened when Ross asked Aaron for thenotebook. He said that he told his father-in-lawthen.

Q. And that's your understanding,based on what Aaron had told you at some point?

A. That's correct.Q. Okay. When did you first learn

that materials - strike that.Do you know, one way or the other,

as to whether Stephanie gave the materials to Rosor to her brother, Jeffrey?


•

•

•

Ji

1 SALZMAN - DAY II 12 A. I don't have firsthand information. 2

3 I only have information from Aaron and Michael. 34 Q. And what did Aaron and Michael te 45 you? 56 A. That she gave them to Michael's 67 younger brother, Jeffrey, who gave them to Ross. 78 Q. Okay. When did you firstlearn 89 that materials had been given to Hochman and 9

10 Martin? 1011 A. I guess it was after the articles 1112 came out. 1213 Q. And when was that? 1314 A. I think it was sometime in the 1415 spring of2003. 1516 Q. Is it possible it was later than 1617 that? 1718 A. I think it was before the Forbes 1819 article came out. I believe that, if I remember 1920 correctly, the Forbes reporter started trying to 2021 contact me. And at that time, when he started 2122 contacting me, I started wondering why he was 2223 contacting me, if it was a good thing or not a 2324 good thing. And that's when I believe Kristin 2425 first showed me the article. 25


Page 375

1 SALZMAN - DAY II 12 A. Yes. 23 Q. And what was Mr. Raniere's 34 reaction? 45 A. He said it was inaccurate. 56 Q. Did you know, at that point, how 67 Hochman had gotten the materials? 78 A. No. 89 Q. Did you have a discussion with -- 9

10 strike that. 1011 Did you decide to take any action 1112 after seeing the Hochman article? 1213 A. I'm not sure when we decided that 1314 it would be good to take the action. I think I 1415 was waiting to see what kind of a reaction would 1516 be generated by the article. 1617 Q. When did you become aware of the . 1718 Martin articles? 1819 A. It was later. 1 920 Q. How much later? 2021 A. I can't remember. I'm sorry. 2122 Q. Okay. Did you have a discussion 2223 with Michael Sutton about trying to find out from 2324 Stephanie Franco how Hochman had gotten the 2425 articles? 25


Page 374

SALZMAN - DAY IIQ. Which article?A. On the website. I think she showed

me Hochman's article on the website, or she had itprinted it up and she gave it to me.

Q. I'll represent to you that thefirst lawsuit against Stephanie Franco was filedin early August 2003.

Do you know how Soon hefore thatyou were aware of an article being posted on theRoss wehsite?

A. Well, it was before my birthday.Q. When is that?A. It's in July. It was in the

spnng.Q. What did you do after you saw the

Hochman article?A. I read it.Q. Did you do anything else?A. I don't believe there was anything

to do.Q. Did you show it to anyhody?A. I think Kristin showed it to me and

to Keith at the same time.Q. To Keith Raniere?


Page 376

SALZMAN - DAY IIA. The material?Q. Yes.A. I think there were ongoing

discussions with Michael while I was fmding allof these things out.

Q. At any point did you and Michaeldiscuss the prospect of him tape-recording aconversation with his sister?

A. No.Q. Did you ever have a discussion with

him where the subject of him tape-recording aconversation with his sister was raised?

MR. Me GUIRE: Was that with ameeting? Or strike that. Was any attorneypresent if the answer to that is "yes"?

A. I don't remember having adiscussion with him about taping a meeting withStephanie.

Q. Were you ever aware that he made atape of a conversation he had with Stephanie?

A. I heard that he had.Q. How did you hear that if it wasn't

from an attorney?A. I think he told me.


•Page 378

•

•

•Yes, it is.MR. KOFMAN: I'd like to repeat a

request that's been made several times forthat settlement agreement. We'll follow it upin the letter.

MR. MC GUIRE: When I get thesettlement agreement between Mr. Ross' clientand Mr. Mandy's client, I'll consider it.

Q. Do you know whether Morris orRochelle Sutton had anything to do with theposting of the Hochman and Martin articles on th !website?

MR. MC GUIRE: You mean directly orindirectly?

MR. KOFMAN: Well, let ber answerthe question.

A. I was going to say do you mean do Ihave direct knowledge from them?

Q. Yes. Do you have any knowledgethat they were aware that the material was going •to be posted on the website before it happened?

A. No.TSG Reporting - Worldwide (877) 702-9580

SALZMAN - DAY IIQ. Is that agreement set forth in

writing?A.

Page 377

1 SALZMAN - DAY II 12 Q. Did you ever hear the tape? 23 A. I never heard the tape. 34 Q. Did you ever see the tape? 45 MR. MC GUIRE: See the tape? 56 Q. The physical tape. 6

7 A. I know he gave it to Kristin 7

8 Keeffe, and I do believe I actually saw the tape. 89 Q. How do you know he gave it to 9

10 Kristin? 1011 A. I was -- it was at volleyball, I 1112 believe, or she told me he gave it to her. But 1213 she had it, and she was going to listen to it. 1314 Q. Had you ever heard of Dr. Hochman 14

15 before seeing the article? 1516 A. No, I never heard of Hochman. 1617 Q. How about Martin? 1718 A. No, I never heard of him either. 1819 Q. Am I correct that NXIVM had settled 1920 a lawsuit with Dr. Hochman? 2021 A. Yes. 2122 Q. As part of that settlement, did 2223 NXIVM require Dr. Hochman to return any materials 2324 he had in his possession? 2425 A. I can't remember. 25


Page 379 Page 380

Do I have direct knowledge of that?Yes.I don't have direct knowledge of

1 SALZMAN - DAY II 12 Q. Have you ever heard from anyone 2

3 that the Suttons were aware that it was going to 34 be posted on the website? 45 A. Not the way that you just stated 56 it. 67 Q. Well, bave you ever heard that tbe 78 Suttons encouraged Ross to put materials on his 89 websites? 9

10 A. No. 1011 Q. Have you ever heard that the 1112 Suttons were aware that Ross had websites? 1213 A. From? 1314 Q. From anyone. 1415 A. I don't know that I ever had a 15

16 discussion like that. 1617 Q. Do you know whether Stephanie 1718 Franco was aware, before it happened, that the 1819 Hochman and Martin articles were going to be pu 1920 on the website? 2021 A. I don't think I ever had a 2122 discussion like that either. 2223 Q. Okay. Did NXIVM's filing of this 2324 lawsuit generate articles in the press concerning 2425 NXIVM? 25


SALZMAN - DAY nMR. MC GUIRE: Object to the form

of the question. Go ahead.A. Not that I remember.Q. Do you have any understanding as to

whether the Suttons or Ms. Franco had anyinvolvement - had any involvement with the Forbesarticle?

A.Q.A.

that, no.Q. Has anyone ever told you that they

were responsible for the Forbes article?A. Not the Suttons,Q. How about Ms. Franco?A. No.

MR. KOFMAN: Let me check my notes.I may be done.

(Discussion off the record.)Q. Are you familiar with the Hochman

and Martin articles?A. I've read the Hochman and the

Martin articles a couple of times.Q. Do you know whether any of the


1 SALZMAN - DAY II 12 facilitator materials are -- strike that. 23 Do you kuow whether any of NXIVM's 34 facilitator materials appear in the Hochman and 45 Martin articles? 56 A. I would go back and check that, but 67 I believe in Martin's articles they appear. 78 Q. In one article or both article? 89 A. I think it's one. 9

10 Q. Okay. And that's one section - 1011 strike that. 1112 Is that the facilitator projection 1213 notes that I showed you earlier? 1314 A. I believe it is. 1415 Q. Are there any other facilitator 1516 materials or coaching materials that appear in 1617 those articles? 1718 A. Not that I remember. I would have 1819 to look again, but I'm pretty sure that's the 1920 main. 2021 MR. KOFMAN: Okay. I have no 2122 further questions. I'll reserve my time for 2223 after Peter and see what that comes to. But, 2 324 Ms. Salzman, thank you very much for your time 242 5 the last day and a half. 2 5


Page 383

Page 382

SALZMAN - DAY IIMR. MC GUIRE: Peter, you indicated

before -- that's when Mr. Kofinan said hethought he'd be finished around 4:00 -- thatyou thought you'd finish tomorrow.

Is that still true?MR. SKOLNIK: Yes, we'll still be

finished tomorrow.MR. MC GUIRE: Okay. Because I'm

prepared to stay late tonight ifyou --MR. SKOLNIK: Oh, we'll never

finish tonight, but we'll certainly --MR. MC GUIRE: No, I meant ifyou

didn't think you were going to finishtomorrow.

EXAMINAnON BY MR. SKOLNIK:Q. Ms. Salzman, I'm Peter Skolnik. I

represent Rick Ross and the Ross Institute andDr. Martin and Wellspring.

Let me show you a document that hasbeeu previously marked as NXIVM 1.

And I think you told us, at thebeginning of yesterday's session, that you wereprepared to testify with respect to Items 11 and12 iu NXIVM 1.


Page 384

SALZMAN - DAY IIMR. LANDY: Peter, you may want to

go back into that since I only asked questionsconcerning the Interfor notice.

A. Yes.Q. You are prepared to testify about

this?A.

1 SALZMAN - DAY II2 I was listening to your testimony3 today about the relationship between rational4 inquiry and NXIVM's teaching and its methods of5 teaching?6 And let me make sure I understand.7 Is it your position that the way that NXIVM8 teaches everything that it teaches is unique to9 NXIVM hecause of the power of the rational lnquirj

10 method?11 A. Because of the method -- the power12 of the method, I don't understand.13 Q. Well, okay. Delete the word14 "power" then. Is it your position that the way15 that NXIVM teaches everything it teaches is unique16 to NXIVM because of the rational inquiry method?17 A. Yes.18 Q. And is it - the way that NXIVM19 teaches its materials using the rational inquiry20 method that makes NXIVM unique?21 A. Could you repeat the question?22 Q. Is it the way that NXIVM teaches23 it's material, through the use of the rational24 inquiry method, that makes NXIVM unique?25 MR. MC GUIRE: Object to the form


1 SALZNV\N-DAYII 12 of the question. 23 A. It's a little hard to understand. 34 The way that it teaches -- I'm sorry -- 45 Q. Well, you testified that NXIVM uses 56 the rational inquiry method as a tool in its 6

7 teaching. Correct? 78 A. Yes. 89 Q. Okay. And my question is - is the 9

10 way in which the rational inquiry method is used 1011 to form the way that NXIVM teaches, is that the 1112 thing that makes NXIVM unique? 1213 A. That's one of the things that makes 1314 NXIVM unique. 1415 Q. That's one ofthem. Okay. You 1516 were here during all of Mr. Raniere's deposition. 1617 Is that correct? 1718 A. I was. 1819 Q. Now, during his deposition, he 1920 identified you as the person at NXIVM who is mos 2021 knowledgeable about NXIVM's trade secrets. 2122 Do you agree with that assessment? 2223 A. I think he said that he was most 2324 knowledgeable about trade secrets, and next to him 2425 it would be me. 25


Page 387

1 SALZMAN - DAY II 12 MR. MC GUIRE: Object to the form 2

3 of the question. Go ahead. 34 A. No. 45 Q. Okay. Now, Mr. Raniere defined 56 trade secrets as something that NXIVM believes i 67 unique that NXIVM keeps as a secret, and that if 78 it were not kept secret, would be a disadvantage 89 to you. Do you accept that definition? 9

10 A. Yes. 1011 Q. Mr. Raniere also testified that he 1112 understands that anything that NXIVM has made 1213 publicly available, whether by posting it to the 1314 copyright office, in court filings, on NXIVM's 1415 website, or in it's puhlicly-available patent 1516 application, is not a trade secret because it has 1617 been released to the public. 1718 Do you have that same 1819 understanding? 1920 MR. LEONARD: Object to the form of 2021 the question. 2122 MR. MC GUIRE: So do I. 2223 A. Did he say that exactly that way? 2324 Q. I'm asking you the question. 2425 MR. LEONARD: I'm interposing an 25


Page 386

SALZMAN - DAY IIQ. Well, okay. I think he actually

said he's most knowledgeable about rationalinquiry, and you about the trade secrets, but areyou knowledgeable about NXIVM's trade secrets.

A. Well, I'm not an attorney, so Idon't really know what a trade secret is.

Q. Well, you do understand that you'rethe president of a corporation who is suing fortheft of trade secrets.

A. I do.Q. One would think that you would know

what trade secrets you're claiming have heenstolen.

MR. LEONARD: Object to that tone.Be civil.

MR. MC GUIRE: Objection.Q. Are you familiar with NXIVM's trade

secrets?A. I'm familiar with the fact that

rational inquiry has trade secrets, and that it'smy responsibility to protect them.

Q. Is there anyone at NXIVM, otherthan Mr. Raniere, who is more familiar withNXIVM's trade secrets than you?


Page 388

SALZMAN - DAY IIobjection. It's improper and inappropriate.

MR. SKOLNIK: Your objection isnoted. The witness can answer the question.

MR. LEONARD: You're notinstructing the witness to do anything.

Mr. McGuire can do that. You

MR. MC GUIRE: I'm objecting to theform of the question. Ifthe witnessunderstood the question, she can answer it.

A. It wasn't my understanding thatthat's what he said.

Q. All right. Let me ask you this:Do you understand that if NXIVM has made some 0

its material publicly available through filing ofthe copyright office, that that material is nolonger a trade secret?

MR. MC GUIRE: I object to the formof that question. That it calls for a legalconclusion.

MR. SKOLNIK: I'm asking for herunderstanding.

MR. MC GUIRE: She's not a lawyer.MR. SKOLNIK: I don't care if she's


•

•

•

•

1 SALZMAN - DAY II 12 a lawyer, Bill. 23 MR. MC GUIRE: If you don't care, 34 okay. It's like asking the president of 45 General Motors or General Electric whether he 56 or she is aware of every trade secret and what 67 ~~ 78 A. I can't say that I understand 89 fully, legally what the term "trade secret" means, 9

10 and, therefore, I can't answer the question. 1011 Q. All right. Are you aware that 1112 NXIVM has posted several of its modules and othe 1213 materials at the copyright office? 1314 A. Yes. 1415 Q. Are you aware of the fact that once 1516 they are posted at the copyright office, they are 1617 available to anyone wbo wants to go into the 1718 Library of Congress and read them? 1819 MR. MC GUIRE: Well, that calls for 1920 a legal conclusion also. 2021 MR. SKOLNIK: I'm asking her 2122 awareness, Bill. 2223 MR. MC GUIRE: You can ask. I'm 2324 not directing her not to answer, Peter. I'm 2 425 preserving my record. 25


Page 391

1 SALZMAN - DAY II 12 lawsuit against Mr. O'Hara. 23 A. I don't know exactly what they -- 34 Q. Or in connection with this lawsuit. 45 MR. MC GUIRE: Same objection. In 56 order to save time, can I have a standing 67 objection to the entire line, Peter, or do you 78 want me to object to each one? 89 MR. SKOLNIK: Your objection to the 9

10 entire line is noted. 1011 A. I didn't know that. 1112 Q. You didn't know that. 1213 A. Or I don't remember. 1314 Q. And I think you told us today that 1415 you know that the 12-point mission statement was 1516 posted on NXIVM's own website for a brief perlod 1617 of time? 1718 A. Yes, I did know that. 1819 MR. SKOLNIK: Okay. Let me 1920 introduce three exhibits, in that order. 2021 MR.KOFMAN: I had her mark 38, but 2122 never showed it to the witness. 2223 (Exhibit Salzman 39 through Salzman 2324 41 marked for identification.) 2425 Q. Ms. Salzman, you heard, during 25


Page 390

SALZMAN - DAY IIA. Well, I know that by patenting it

does release the information within the patent.Q. Okay. And now I'm also asking

about the copyright office. Are you aware thatwhen you filed materials with the copyrightoffice, they are made puhlicly available?

MR. MC GUIRE: Same objection.A. I don't -- I don't know that I knew

that exactly in that way.Q. Are you aware of the fact that

NXlVM's attorneys attached to its court filings ithe Northern District of New York several ofNXIVM's modules?

MR. MC GUIRE: Were they markedconfidential or filed under seal?

MR. SKOLNIK: That were not filedunder seal.

MR. MC GUIRE: Object to the formof the question.

Q. Are you aware that your lawyersfiled several modules at the Northern District ofNew York?

A. For patenting?Q. No. In connection with your


Page 392

SALZMAN - DAY IIMr. Raniere's testimony, his several references tothe appearance of what he characterized as windowinto NXIVM's trade secrets in these articles.

Is that correct?A. I did.Q. What I am going to ask you to do,

and we're going to stop for the day so that youcan be prepared to testify about this in themorning, is I would like you to go through thesethree articles and identify, to the best of yourability, every actual trade secret - not windowto a trade secret, but every actual trade secretthat is revealed in these tbree articles, andwe'll talk about them tomorrow.

MR. LEONARD: Just so you know, andI'm not speaking for the witness or Mr.McGuire, I object to this request. I thinkit's inappropriate. I don't think you're in aposition to assign homework to this witness.

We've been through this testimonypreviously. And what Mr. McGuire is going tochoose to do is one thing, but I think it'sabsolutely inappropriate, and, therefore, Iobject.


I

Page 3931

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10111213141516171819202122232425

SALZMAN - DAY IIMR. SKOLNIK: Okay. We certainly

haven't been through this with this witness.MR. LEONARD: Understood.MR. SKOLNIK: And the whole point

of doing this now and asking the witness toreview it overnight is to avoid everybodysitting around for a half an hour at a time,as we did with Mr. Raniere, while he read it.

MR. LEONARD: The whole exercise isinappropriate, in my opinion.

MR. SKOLNIK: All right. That'sfine. And ifyou order the witness, or ifMr. McGuire orders the witness not to do it,the record will so reflect. But that is myrequest, and that's what I'm intending.

MR. MC GUIRE: I join in theobjection. I also believe that this was partof the subject matter ofMr. Kofman'sexamination. So, it would be repetitive.

MR. SKOLNIK: Mr. Kofman did notask the witness to identity every trade secretin these articles. That's what I'm asking herto do.

MR. MC GUIRE: Oh, I think he did.TSG Reporting - Worldwide (877) 702-9580

123456789

10111213141516171819202122232425

Page 394

SALZMAN - DAY III think he asked about trade secrets in thesearticles, but the record will speak foritself.

MR. SKOLNIK: It will.(Time Ended: 5:03 p.m.)

NANCY SALZMAN

Subscribed and sworn tobefore me this dayof June, 2009


I

I

41

Page 395 Page 396

10

13

Exhibit Salzman 23 Program Description 20711 Bates No. P00000477912 Exhibit Salzman 24 Timeline 211

BatesNo.SP1167

Exhibit Salzman 25 Statement oflncome 22114 Dated 12131103

Bates No. SP2278 -15 SP227916 Exhibit Salzman 26 Affidavit 223

No Bates Number

t

15

12 EXHmITS

Exhibit No. Page

Exhibit Salzman 35 Student Organization 33814 Information Page

Bates No. POOO004098

13

3Exhibit Salzman 31 Statement ofTestimony 254

<4 Dated 7/15/02Bates No. SP1204-

5 SPI2066 Exhibit Salzman 32 Executive Success 260

ProgramStudent7 Enrollment Application

Bates No. POOOOO4110·8 POOOOO4I1l9 Exhibit Salzman 33 Sash Descriptions 281

BatesNo. SFOO012-10 SFOOOl411 Exhibit Salzman 34 Executive Success 316

ProgramStudent12 Enrollment Application

BatesNo. POOOOO4109

178

PAGE:5

EXHIBITSExhibit No. PageExhibit Salzman 22 Biography

Bates No. POOOO04778

12 INDEX:3 WITNESS EXAM BY:4 N. Salzman Mr. Kofman5 Mr. Skolnik 3826789

24Exhibit Salzman 30 Letter dated 7123/02 250

25 Bates No_SPll99-


Exhibit Salzman 28 Statement Dated 212104 23721 Bates No. SP157322 Exhibit Salzman 29 Confidentiality 243

Agreement23 BatesNo.POOOO04133-

POOOO04139

17Exhibit Salzman 27 Second Amended

18 Responses to SecondSet oflnterrogatories

19 Dated 11128/05No Bates Number

20

226Exhibit 'Salzman 36 Projective Questions 349

16 For FacilitatorsBates No. SF00042

17Exhibit Salzman 37 Letter dated 10/31101 357

18 Bates No. POOO00412219 Exhibit Salzman 38 Ijeclaraticn 366

No Bates Number20

Exhibit Salzman 39 Evaluation 39221 Dated February 2003

Bates No. NXROOO3S -22 NXROOO3723 Exhibit Salzman 40 Criteria of 392

Thought Refonn24 Dated 2112103

Bates No. NXR00047 •25 NXROOO57


page 398

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10111213141516171819202122232425

EXHIBITSExhibit No. Page

Exhibit Salzman 4 I Critical Analysis ofExecutive SuccessPrograms, Inc.Dated 2/12/03Bates No. NXR00038NXR00046

392

123

45

6

78

910

111213141516171819202122232425

LITIGATION SUPPORT INDEXDIRECTION TO WITNESS NOT TO ANSWER

Page Line Page Line(NONE)

REQUEST FOR PRODUCTION OF DOCUMENTSPage Line Page Line192 16 214 7310 23 312 9378 IOINFORMATION TO BE FURNISHED

Page Line Page Line(NONE)

QUESTIONS MARKED FOR A RULINGPage Line Page Line

(NONE)

CERTlFlCATE3 STATEOF NEW YORK)

)85:4 COUNTYOF NEW YORK)

I, JOMANNA DeROSA, a Certified5 Shorthand Reporter and Notary Public within

and for the State ofNew York, do hereby6 certify:7 That NANCY SALZMAN, the witness whose

deposition is hereinbefore set forth, was8 duly sworn by me and that such deposition is

a true record of the testimony given by such9 witness.

10 I furthercertify that I am notrelated to any of the parties to this action

11 by blood or marriage, and that I am in noway interested in the outcome of this

12 matter.13 In witness whereof, I have hereunto

set my hand this 19th day ofJune, 2009.

222324

12

14

1516171819202122232425


Page 399

JOMANNA DeROSA



Page 400

12 '" '" "'ERRATA SHEET'" 11< ...

3 NAME OF CASE: NXIVM v. Sutton4 DATE OF DEPOSITION: 6/9/095 NAME OF WITNESS: N. Salzman6 Reason codes:7 1. To clarify the record.

2. To conform to the facts.8 3. To correct transcription errors.9 Page Line Reason __

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NANCY SALZMAN25


A 173:24174:13 176:12 217:20218:10 392:3 article (16)

Aaron (22) added (2) 246:12 appeared (I) 238:8265:18,19

293:8,9306:18 241:23329:25 ahead (6) 366:9 373:19,25374:2,4

310:25313:10 addition (3) 209:15220:8245:15 appears (5) 374:10,17375:12

367:10,11,14 239:10 272:13 334:11 366:25 380:3 387:3 177:3203:3317:10 375:16377:15

369:25370:4,6,11 additional (3) Alhany (10) 333:7352:14 380:8,14381:8,8

371:9,10,12,15,17 173:16185:13 209:22 288:18292:12293:16 Apple (2) articles (20)

372:11,15,19373:3 addressed (I) 293:24308:5 251:11,16 177:18,21185:7

373:4 233:10 316:16325:20 application (44) 366:9373:11

ahility (6) ADELMAN (I) 326:9336:11 206:18207:5220:20 375:18,25378:14

181:10200:5271:4 170:15 371:16 220:22,25 235:8 379:19,24380:22

271:11278:5 administer (I) allegation (I) 236:9239:16240:4 380:24381:5,7,17

392:12 171:14 257:22 240:10,11,15,19,20 392:4,11,14393:23

ahle (10) administrate (I) alleviate (I) 240:25241:8,16,17 394:3

199:11 200:3234:15 216:18 364:4 245:13252:16,17 artists (I) h

272:3274:20,21 administration (1) allowed (3) 252:20,24253:5 216:13

305:14,22323:12 328:13 278:15,21287:25 261:3,5,6,7,8,12 ascertain (I)

336:7 administrative (1) allows (2) 309:20310:16,20 187:10

ahsolutely (2) 240:21 268:9273:3 312:16316:11,23 aside (I)

355:18392:24 advance (3) Amended (I) 319:4331:23 358:20

abstract (I) 187:6334:7,12 395:17 332:22333:5338:7 asked (39)

190:24 advanced (3) American (I) 387:16396:7,12 176:11177:8199:4,8

academic (I) 180:15204:25205:2 185:20 applications (7) 199:9201:2220:11

300:4 advantage (I) amount (3) 216:12235:18,24 233:18,21242:22

academics (I) 324:20 174:12177:8186:6 240:14312:9 243:11,12,14,15

300:7 advise (I) analysis (6) 333:14337:12 245:21246:4,8

accept (I) 237:14 180:4211:16227:24 applied (I) 257:24291:10

387:9 Advocate (1) 228:11229:6397:3 216:12 292:16,22307:20

accepted (2) 218:23 analyzing (I) apply (3) 307:22314:6322:7

279:20,24 affidavit (3) 183:9 172:11 191:8,9 323:3 327:9,22

access (3) 367:23368:4395:16 Ancona (2) applying (1) 329:13331:16

247:15,25353:11 afternoon (1) 341:6,16 241:2 346:14351:10

accidentally (I) 293:6 Angel (3) appreciate (2) 354:21361:8,23

320:23 age (I) 340:19342:15,16 312:22343:19 365:14372:15

accompany (1) 216:24 Ann (5) apprentice (4) 383:3394:2

284:9 ago (8) 340:14341:6,8,8,15 268:6 269:11 282:3,4 asking (18)

acconnting (1) 196:12211:18247:14 Anna (2) apprentices (1) 202:12,19209:7

221:25 249:15313:12 168:16170:16 288:2 266:7,10 299:18

accurate (6) 343:17360:7 answer (12) approach (4) 305:11 326:3

178:24187:17238:14 369:20 209:15220:8266:20 183:7,8,8186:8 360:19361:20

238:17239:5 agree (5) 303:12325:4 appropriate (3) 365:12387:24

270:17 199:17259:24308:2 376:16378:18 237:19243:17,18 388:22 389:4,21

achieved (2) 322:25385:22 388:4,11 389:10,24 approve (I) 390:4393:6,23

297:23342:5 AGREED (3) 398:3 242:3 aspects (1)

achievement (1) 171:3,7,11 answers (1) approved (2) 204:11

228:16 agreement (37) 383:24 259:15,17 assemble (1)

action (6) 198:21201:15214:10 anybody (5) approximation (3) 351:25

168:3257:21,25 219:17,18,24242:3 283:16292:9308:13 286:15,17,18 assertions (4)

375:11,14399:10 243:24244:2,14,18 374:22383:23 area (4) 323:10,14337:17

active (7) 245:2,10,11,17,25 anymore (3) 203:25294:13 356:15 351:10

194:4,11,12219:2 252:5,7,12263:4 192:14340:16361:5 356:20 assessment (1)

294:15325:25 264:4326:7,11 anyway (2) areas (1) 385:22

326:4 327:3,12328:17,23 185:2321:16 233:9 assign (2)

actual (2) 329:7 330:25 apart (1) Arlin (3) 324:3 392:20

392:12,13 358:10,14371:5,20 189:12 240:2 242:5 244:9 assigned (2)

actuarial (1) 378:2,7,10 395:22 appear (3) arose (1) 241:22 324:6

174:16 agreements (6) 381:4,7,16 197:16 Associates (1)

actuary (3) 195:11 201:25202:4 appearance (I) arrived (2) 221:24319:5,7 Association (1)

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185:20 390:7 329:20330:16,17,19 182:22271:11 better (5)assume (1) Aveuue (2) 330:20 beings (2) 175:7245:20302:5317:22 170:5,9 Bandler (13) 188:21189:7 302:19 352:13assumed (4) average (7) 184:9,10,13,15 186:7 belief (5) beyond (2)176:13201:6302:5 174:9,12,20,21 186:14,17187:20 175:22248:17356:14 333:20352:7

346:19 175:15,20,24 190:4 191:14,24,25 356:15,20 BIDDLE (1)assumptions (2) Aviv (2) 196:20 beliefs (2) 170:12205:23,24 168:16170:15 Barbara (14) 199:3232:2 Bill (3)atbletics (1) avoid (1) 255:11,13,15,19,24 believe (59) 188:17 389:2,22216:13 393:7 257:9308:15 175:15,17177:20 binding (1)attacbed (3) awarded (3) 322:19 336:22 198:16201:16 245:7172:15317:11 390:12 280:9282:5,9 337:3339:17,21 212:10215:7,20 bio (2)

attained (1) aware (29). 353:11 364:22 220:5221:8224:21 178:18,24279:21 177:17,21222:21 BARRY (1) 224:24225:12 biograpby (3)attempt (4) 227:5256:18,20,23 170:18 227:25 229:24 178:19179:13395:9291:8297:15332:16 257:5294:25 based (11) 231:19 239:5,25 birtbday (1)

347:15 295:20313:16 173:20180:9183:15 249:14,18259:10 374:12attempting (2) 322:4333:16338:7 187:6 215:5,17 273:9,14274:21 blend (1)264:22 359:8 358:2371:4374:10 224:15275:7 280:22285:23 182:22attend (5) 375:17376:20 278:18 279:7 288:13,17289:13 blood (1)310:13 311:5 313:21 378:23 379:3,12,18 372:19 295:25 305:7 399:11

343:21 356:5 389:6,11,15390:5 basic (15) 309:24310:15,18 Bob (1)attended (10) 390:11,21 195:25 196:15204:9 315:11 319:10 188:17321:23323:18333:19 awareness (1) 204:10,16,23205:9 321:6322:19332:7 body (1)

338:2,14342:24 389:22 205:11,16217:10 335:9336:15 268:9343:22,23344:15 a.m (1) 271:25274:22 340:23345:14 book (2)358:4 169:5 280:18,19281:25 359:2,20,23361:15 190:2191:12

attendees (5) a/k/a (1) basis (7) 362:24367:3371:9 books (14)308:19310:24311 :23 168:9 174:23177:3183:24 371:10373:19,24 182:10185:6,9,13,16

312:19313:8 184:23,24 258:18 374:20377:8,12 185:17190:5,6,7,8attends (1) B 280:24 381:7,14393:18 190:13191:14,15240:5 B (2) Bates (33) believed (10) 362:8attorney (12) 170:21172:14 178:13208:2221:19 183:20184:25185:2 Boone (1)250:22251:11,12 back (60) 250:15254:19,22 191:4198:8200:5 353:2

327:13,15,17,19,21 172:13179:12180:16 260:4,5,25281:18 257:2294:15 bottom (2)327:24376:15,24 184:12186:19 316:7,19349:10 305:23358:17 179:7353:16386:6 199:16,22,24 395:9,11,12,14,16 believes (4) Boucbey (4)

attorneys (8) 202:17204:12 395:19,21,23,25 230:22331:21,22 242:24339:17,21170:4,8,12,15,19 207:21208:13,14 396:4,7,9,12,14,16 387:6 353:11

171:4366:23 208:15212:5220:4 396:18,19,21,24 belong (1) brainstorming (1)390:12 220:11 230:12 397:5 201:5 231:15

attorney/client (1) 239:21243:6,14 bear (1) beneficial (1) breach (2)254:11 247:3251:23255:9 250:15 306:12 256:15,16attractive (1) 256:20,24257: 14 bears (2) Bergeron (11) breacbing (1)306:8 258:24273:9,15,19 260:25 349:10 255:12,15,23256:4 256:10audio (2) 276:14277:20 began (8) 257:13 308:17 break (2)312:23313:3 278:12279:12 181:13 188:24189:4 340:4,6,7342:21 189:12383:13auditory (1) 285:18312:20 198:19200:23 364:23 breakout (6)188:7 313:6322:19328:2 201:9202:7286:3 Bergeron's (1) 267:11,15,19275:15

August (4) 328:5,6 332:9 beginning (7) 340:9 278:10344:10172:15345:5347:21 338:10,16344:25 211:23244:11 313:18 best (18) brief (7)

374:8 345:19347:16 317:16323:15 175:18177:4178:23 179:23183:3,5,12authorized (1) 349:21,23350:2,4 347:23 382:23 190:6,13196:3 185:19228:15171:13 362:14363:7 bebalf (1) 212:19225:17,24 391:16autbors (1) 364:11,18365:19 383:18 238:16245:10 briefly (2)191:16 365:24 381:6 383:3 bebavior (4) 248:21 249:3 . 202:21,24

available (4) background (2) 183:17187:11 228:3 297:20324:11 bring (4)387:13388:16389:17 299:2355:3 239:14 354:18364:13 246:8,9 296:21

bag (5) bebavioral (2) 392:11.


307:23 calculations (1) center (11) 295:21,24305:10 337:22338:17bringing (2) 176:6 170:19193:23194:3 340:12 343:24344:6234:14236:16 California (3) 194:8291:5303:4,6 cbildren (3) 350:13351:5356:6broad (2) 184:11,12186:20 303:10306:2,8 184:25216:24217:8 356:9210:20,23 call (12) 326:2 children's (1) classified (I)Broadway (I) 185:24207:20217:5 certain (20) 215:15 339:3170:16 282:6303:7308:23 175:16176:21184:7 Cbomsky (4) clean (I)

brochure (1) 327:15,16,21348:8 186:6267:24 187:23,23 188:10,19 320:25241:11 359:22 360:2 270:16,25271:3 choose (4) clear (3)broke (I) called (18) 274:19277:3281:6 236:14335:18355:10 202:19231:12331:20238:8 172:2182:5,6205:23 302:6315:5323:24 392:23 clearly (1)broken (2) 215:25230:7 329:22,22,24 chose (I) 254:10172:23 184:20 232:15255:25 345:17351:18 355:14 client (3)

Bronfman (2) 268:11 275:11 352:9 Christopher (I) 281:16378:10,11177:9,19 288:5291:5331:17 certainly (2) 352:24 clients (2)brother (3) 359:4,23 360:4,25 382:12393:2 circled (1) 230:20281:16367:6372:25373:7 361:4 CERTIFICATE (I) 317:6 close (I)brought (9) calls (4) 399:2 circumstance (1) 345:16184:17191:3292:3 266:9 359:21 388:20 certification (2) 323:9 Clyne (2)

315:11339:8,15 389:19 272:19,20 circumstances (l0) 224:16,17340:8,14341:3 camera (I) certificational (I) 243:13 249:19 284:25 coach (46)

Bruce (1) 201:18 273:20 291:2294:22295:4 257:15268:4,5,7,13176:23 Campus (1) certifications (2) 315:8319:22 268:15,17,21,22,23

building (4) 170:13 271:3 272:9 320:11 336:18 269:8,13,14273:3229:7284:16,17,22 Canada (2) certified (4) City (3) 274:2,5275:11,12bulletpoint (1) 180:10 192:5 169:12174:17176:12 325:24,25 326:2 282:2,7283:15,16252:3 capacity (I) 399:4 civil (2) 283:20,22286:20bulletpoints (1) 177:6 certify (2) 168:3386:16 286:22287:18209:3 capital (1) 399:6,10 claim (1) 305:17322:5,7,10bunk (I) 172:22 chairman (I) 251:2 323:2,4324:3,5,11264:13 care (2) 328:11 claiming (1) 324: 11 334:23burdened (I) 388:25389:3 chance (1) 386:13 335:2,10,13,16203:4 career (8) 226:21 Clare (I) 337:18339:5husiness (12) 179:24199:11200:12 change (12) 177:18 340:11 342:11196:17218:25228:3 200:15289:6,14 183:13,22193:23 clarified (1) coaches (9)

228:12 229:2 324:24325:16 194:4,8 200:25 205:5 269:9,11 276:11232:14,18,18 Carole (12) 228:3,4298:7,9,10 clarify (2) 287:3,14288:6246:19267:2 255:11,15,22256:4 298:17 238:18400:7 322:9,13 342:3306:14,15 257:13 308:17 changed (2) class (32) coaching (68)

Buyer's (1) 340:4,6,7,9342:21 183:18261:11 174:7182:3234:9,24 228:13,22,23,24218:23 364:22 changes (2) 239:12240:4,6,16 229:2268:18,20,24

Carrie (I) 202:25 242:7 240:19244:19 269:3,4,19270:3,6C 314:15 changing (1) 246:10 262:23 270:10,15271:6,8,8

C (4) carries (1) 189:13 265:12306:18 271:16273:4,8170:2172:2,14 367:25 channels (1) 307:12,19308:3,6 274:8,13 275:20,23

176:25 carrying (I) 225:20 308:20,22 309:8 276:9,15,21277:17cabinets (1) 329:21 characterized (I) 311:18316:24 278:2,23279:3,10246:16 case (4) 392:3 317:3323:16 279:20,24 280:13Cafritz (8) 251:20259:12260: 11 charge (2) 327:10 328:2,5 280:16281:3,10212:10,11215:11,13 400:3 212:15286:2 350:6,7351:11 283:24284:2285:4

218:11 322:18 categories (1) charged (2) 353:8 285:5,6287:19,23352:25359:23 190:15 309:23,24 classes (31) 301:14302:2,7

calculate (I) category (I) charity (1) 181:25 195:14205:2 323:8325:8334:13173:15 283:21 314:4 208:12233:17 335:4,7,11,12,25calcnlated (I) canse (3) check (5) 234:19240:8,11,13 336:5,8 337:24175:14 205:18207:2341:18 235:10 319:21341:19 244:12,23271:20 341:22344:19

calculating (I) caused (2) 380:18381:6 289:16,19 290:22 349:15,16,18,25174:9 198:15327:12 child (4) 309:3,9,10,12313:9 351:16381:16

336:25 337:13,21 coach's (2)


•

•

•

248:10269:15 210:16,22211:2 concepts (5) 329:4 301:4304:4321:9codes (I) communications (9) 196:18 222:18 265:19 considered (7) 371:15372:9,12400:6 187:16210:11,13,19 265:20,22 181:19,21 182:14 376:9,13,21codified (I) 210:24228:5,5 concerned (I) 183:2226:8236:23 conversations (6)185:12 309:17319:2 362:19 287:17 198:6212:2301:7

cognitive (2) commonity (15) concerning (4) considering (I) 315:23366:14182:23228:4 294:9,12,15,17,23 185:7326:6379:24 287:24 372:11

collected (1) 295:7305:24306:2 383:4 considers (3) convey (1) u285: 16 306:3,4,5,9307:21 Concerns (2) 227:2231:3236:19 220:11collecting (2) 314:6325:13 364:3,4 consistency (I) copied (2)285:9343:5 companies (3) conclusion (5) 224:14 261:23263:12color (1) 220:6227:25262:15 266:7,9304:13 consistent (3) copies (3)280:6 company (33) 388:21 389:20 191:9 200:3,11 192:10,18201:19

column (2) 173:24180:9,13 conditions (2) consistently (2) copy (5)222:9283:9 187:5,6193:20,24 261:15263:25 199:18203:6 214:5252:6,11combination (I) 194:4,21,23 195:7 conduct (5) consists (2) 310:20 327:2247:24 208:8211:17,19,23 257:6354:14357:8 173:10309:9 copyrigbt (10)combIned (2) 212:12,14,21 357:12358:22 constitute (1) 208:14353:18,20,23292:18,21 214:18216:8 conducted (2) 210:2 387:14388:17come (31) 218:24219:10 227:23339:22 constituted (I) 389:13,16390:5,6174:15231:4234:6 234:6238:8242:22 conducting (2) 253:20 cordial (2)

237:15246:10 255:22256:8,19,23 257:22355:21 consultants (2) 295:8,10273:2277:8288:23 256:25257:2,18 ConEdison (1) 223:21,24 corner (1)291:22292:16,22 258:22 230:13 consulting (8) 317:6299:4305:12 compensation (1) confidential (6) 228:4,8,10,12,12,16 Corp (I)306:17307:18 253:16 179:8,10 208:18 228:19,25 194:23328:2,5,20,21,24 compensed (I) 316:19,22390:16 consuming (1) corporate (7)332:8345:25346:8 253:18 confidentiality (22) 183:10 228:6,6,7 230:5,6346:10,14,15,16,18 compete (2) 195:11198:21200:17 contact (6) 236:23241:19347:16348:3 227:13231:21 201:15217:20 256:16347:15,17,25 corporation (4)364:18 competing (I) 243:23244:2,18 348:21373:21 168:4194:11,13

comes (2) 233:16 245:2,25246:12 contacting (2) 386:9175:16381:23 competitive (1) 252:5,12326:7,11 373:22,23 correct (55)

comfortable (1) 236:23 327:3 330:2 358:10 contained (1) 173:6,9 175:22296:7 competitor (3) 358:14371:5,20 255:4 180:25 181:3coming (4) 231:3233:14267:3 395:22 contains (1) 189:24196:25236:5318:5,7346:19 competitors (11) config (2) 252:23 210:9,25221:11

commerce (I) 226:3,9227:2,5,25 283:9,10 contend (2) 230:25231:8225:18 229:18230:15,19 configuration (I) 253:12368:8 239:22 241:6commission (4) 233:6236:20249:4 284:5 context (I) 242:10243:2244:3251:2257:19318:14 compilation (I) confirm (I) 213:24 248:8,11251:17

318:20 205:19 221:9 continue (6) 255:4,5267:10,13commissions (1) compiled (5) conflict (1) 172:9194:17199:13 269:2,17271:21318:24 226:3,4,6,8227:10 235:15 232:17 303:2,20 273:22275:10,17

commit (1) complete (6) conform (1) CONTINUED (1) 279:17284:6,7304:17 226:5246:5335:7 400:7 172:6 286:24287:2299:9committed (I) 345:12348:12 confuse (1) continues (I) 317:18318:12,25277:2 351:15 189:18 226:19 320:2329:16330:7

committee (6) completed (7) confusions (2) contracts (1) 333:9,12334:16322:14,16,19,20,21 281:2,10 282:9 335:9 189:7,13 256:10 342:22350:21

328:12 336:3,3 352:18 Congress (I) contrary (I) 351:14354:9common (4) completing (3) 389:18 334:2 372:20377:19300:19,21303:6 334:8,11335:11 connection (3) contributed (3) 385:7,17392:5

319:13 compute (1) 226:2390:25 391:4 177:9,13,14 400:8communicate (1) 176:17 consider (1) controller (1) correctly (1)209:11 computer (4) 378:11 211:17 373:20communication (6) 188:5 342:6 362:6,7 consideration (5) conversation (13) cost (3)205:17206:25210:15 concept (1) 319:18,20,24327:20 289:8,10299:12,16 174:8228:7317:17

198:17 counsel (2)


175:8 383:22 201:5 207:5270:17 298:1299:1300:1 369:5,11375:13counselor (3) criteria (4) database (I) 301:1302:1303:1 decides (I)256:2257:12260:19 234:16237:3,4 241:22 304:1305:1306:1 322:15Counterclaim-Defe... 396:23 date (2) 307:1308:1309:1,9 decision (9)168:17 critical (4) 319:3400:4 309:11 310:1 311:1 229:23 230:21,24Counterclaim-Plai... 208:2,24228:10 dated (12) 312:1313:1314:1 232:5233:10242:6168:13 397:3 250:22 251:14 332:24 315:1316:1317:1 328:23355:17

COUNTY (1) CSR (1) 395:14,19,20,24 318:1319:1320:1 356:5399:4 168:25 396:4,17,21,24 321:1322:1 323:1 decisions (1)couple (8) cult (6) 397:5 324:1,4,6325:1 229:21200:24292:7301:6 359:8360:13,15 daughter (7) 326:1,22327:1,8,17 Declaration (1)

334:12,14336:12 362:9363:9,11 216:22308:16322:2 328:1,2,6329:1 396:19336:19380:24 cult-like (1) 322:6,20 362:4,4 330:1,9,11,14,15 deep (1)

course (33) 360:14 day (255) 331:1332:1333:1,2 354:25176:4196:2,13 current (2) 168:20169:8172:1 334: I 335:1 336:1 Defendants (1)

207:15,18,20 212:21 274:24 173:1 174:1 175:1 337:1338:1339:1 168:11224:20225:10 currently (2) 176:1177:1178:1 340:1341:1342:1 define (2)242:13267:10 199:17305:19 179:1180:1181:1 343:1,6344:1345:1 210:18357:10269:15280:5 curriculum (89) 182:1 183:1 184:1 346:1347:1348:1 defined (1)284:22286:21 204:9,10,16,18,24,25 185:1 186:1 187:1 349:1 350:1 351:1 387:5287:18294:2 205:10,12,16 188:1 189:1 190:1 352:1353:1354:1 defines (2)

.

299:20301:10,11 206:14215:4,16,25 191:1 192:1 193:1 355:1 356:1 357:1 270:14,14301:14,16,25302:4 216:9,10,11217:3 194:1 195:1 196:1 358:1359:1 360:1 definite (1)302:7305:6,6,8 222:24,25 232:25 197:1 198:1 199:1 361:1,4362:1363:1 307:2358:3359:13 247:11,12248:7 200:1201:1202:1,6 364:1365:1366:1 definition (1)360:22365: 12,14 268:18,20,25269:3 202:10,14203:1 367:1368:1369:1 387:9383:13 269:4,16,19 270:2,4 204:1205:1206:1 370:1371:1372:1 definitions (1)

courses (8) 270:7,10271:6,9,16 207:1,10208:1 373:1374:1375:1 266:12172:24173:17187:8 272:2,18273:8,10 209:1210:1211:1 376:1377:1378:1 definitive (2)

300:3,4,7 302:16,20 274:4,6,8,14275:20 212:1213:1214:1 379:1380:1381:1 182:15190:2court (4) 275:23276:9,13,15 215:1216:1217:1 381:25382:1383:1 degree (4)168:2171:16387:14 276:21277:18 218:1219:1220:1 384:1385:1386:1 183:2193:2,11,16

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created (13) 337:9,24341:22 242:1243:1244:1 243:13277:16 227:10182:11 183:22185:20 349:16,17,18,25 245:1246:1247:1 280:4,20,20,21 department (1)

186:19187:20 350:11,24351:16 247:23248:1249:1 328:4332:6,11,14 225:18~

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creators (1) 170:3 290:1291:1292:1 291:8375:11 359:8186:14 data (6) 293:1,6294:1,2 decided (6) deprogramming (1)

credit (1) 175:7185:12188:4,6 . 295:1296:1297:1 200:14219:9321:8i~

-~~,~

_.TSG Reporting - Worldwide (877) 702-9580

deprogramming (1) died (1) discuss (10) 281:21 282:24 E362:9 345:15 236:4267:12294:3 283:2316:7,10,18 E (2)derivative (1) differ (2) 298:25 300:21 338:25339:2 170:2,2216:2 216:7,10 314:11 325:9 342:10349:9,11 earlier (6)

DeROSA (4) difference (1) 348:25 363:25 356:23357:18,20 182:20 261:5 266:24168:25169:11 399:4 266:16 376:8 382:20 352:19358:18

399:15 different (36) discussed (7) documentation (2) 381:13describe (3) 180:5181:5,17184:9 202:18290:8294:24 343:11,13 early (12)179:20208:9248:15 188:13,21,23 190:9 298:22299:15 documented (1) 181:20187:19196:14

described (5) 191:5 193:22 196:4 325:19364:2 185:16 196:22201:17203:22206:11,17 204:2,3,3206:18,20 discussing (5) documeuts (9) 208:8219:10

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Descriptious (1) 274:4 293:5 335:21 298:15321:2 168:16 237:17396:9 335:22,22,23 338:5 364:15365:17 doing (24) easier (3)design (1) differently (1) 375:9,22376:11,18 176:9184:19188:10 305:8352:15,17229:5 203:7 379:16,22 380:20 196:4,11,12199:16 easily (1)designated (3) difficulty (1) discussions (11) 199:17,22,25203:3 324:22175:9,10 349:22 249:22 198:23304:22315:7 212:22232:12 easy (2)

designed (5) digit(l) 317:23,24318:4 257:3258:16279:7 293:20,23180:21183:13189:12 254:25 325:22363:4 290:4305:20337:4 economic (1)

219:8282:20 dilemma (1) 364:20,24376:5 340:24 354:22 291:2desire (4) 320:20 disbonor (1) 361:18362:5393:6 economically (1)234: 18,20 298:17 Dilts (3) 256:12 DOLAN (1) 295:7

337:10 186:16,17,23 disseminate (1) 170:11 Edgar (1)despite (1) dinner (14) 263:19 Dones (1) 353:2312:7 292:24298:13,23 disseminating (2) 353:14 edited (1)determination (2) 299:4,6319:8,11,14 265:5,7 door (3) 224:14235:15278:15 321:18,21,24 dissemination (1) 315:12,13 337:6 education (8)determine (4) 323:17324:14 259:18 donble (1) 181:19199:15215:15174:6,24235:18 326:24 dissuade (2) 182:25 217:4299:21

242:17 direct (4) 266:15,22 Dr (5) 324:18,19325:3determined (1) 267:22378:21 380:9 distribute (1) 185:6377:14,20,23 educational (9)327:11 380:11 309:25 382:19 222:19267:9269:7develop (7) directing (1) distributed (3) drafted (4) 270:25 271 :22200:14210:6,8217:3 389:24 310:8311:19,20 238:11 239:23,25 272:15273:6

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developed (19) directive (1) divorce (1) 239:24 242:2 244:4 171:15369:7180:21187:23191:23 238:7 299:24 DRlNKER(I) effective (7)

200:24211:2215:5 directly (4) doctors (4) 170:12 185:5 186:9,10222:18,19223:21 175:3246:3263:14 238:19,22,24239:7 Drive (1) 229:23 290:5230:7,12276:13,13 378:16 document (53) 170:13 303:21 355:25282:23,24,25 350:4 disadvantage (1) 178:8,15 179:9202:7 duly (2) effectively (4)350:11 352:12 387:8 202:10,15207:25 172:3399:8 229:21273:4274:20

developing (6) disclose (1) 208:4 209:9 210:22 duplicated (3) 274:22207:15215:16273:2 266:18 211:10 212:3,6 176:21261:23263:12 effectiveness (1)

276:14279:6 disclosed (1) 213:25221:18,18 duplicating (1) 184:22350:19 266:21 221:21 223:6 262:8 effort (1)

development (7) disconnect (1) 226:13 237:25 Durkes (8) 224:8211:5 222:24 228:22 248:17 238:4239:20,24 308:18326:20328:8 eight (1)

228:23 229:7 discontinued (2) 240:2243:22 328:10,15330:8 197:13268:13 352:14 350:22,23 246:17,18252:25 352:24 358:17 either (8)

dictated (4) discovery (5) 254:13,18255:7 D.C (1) 199:18216:15257:11259:11,16,19,20 178:13 221:19 250:15 256:4259:4,7260:2 187:4 295:17297:9260:24 349:9 260:24281:15,18


319:17 377:18 334:24339:3341:8 170:6,10,11,14,17,21 example (3) 201:2379:22 341:9 EST (6) 176:22240:7,8 experiences (2)

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357:7,12 enrollments (4) ethical (3) 347:4 explain (7)EM (II) 173:19174:3,22 219:25256:15271:13 executive (16) 200:23202:23235:13256:12,14257:6,22 284:4 ethics (5) 168:4178:11 194:18 260:7264:17,19

258:11,13,20 ensues (I) 212:15228:11,11,12 194:22197:15,20 383:22270:19351:9,19 235:14 256:25 198:3,17213:24 explained (6)353:10 enter (4) Ethos (II) 214:22228:13,13 198:7245:20256:14

emotional (I) 241:21 335:25336:5 204:18,21241:11 353:18396:6,11 356:8,10,12309:18 342:14 244:23 246:8 397:4 exploration (22).emotions (2) entering (2) 282:17283:7 exercise (I) 248:12,14,19256:14270:12,13 335:21 340:18 308:25 309:2 393:10 264:18,19265:12employ (2) entire (8) 336:13337:13 Exhihit (48) 344:5 351:12 354:6203:23205:12 200:12205:7206:24 evaluate (2) 172:18 173:7 176:20 354:8,14,19,22employee (I) 207:2273:10,12 174:3363:6 176:23,25178:5 355:9,19,21,24253:14 391:7,10 evaluated (7) 207:22211:7 356:17357:8,10,13employment (I) entirely (2) 173:18,20190:13 221:15223:4 explorations (2)235:16 269:22,25 275:7276:10,11 226:10237:22 249:5 264:12empowerment (4) entities (2) 363:10 243:19250:11 explore (2)179:18,21181:4 214:19226:25 evaluating (2) 254:5 259:9 260:21 354:17,25

182:16 entitled (2) 186:9211:18 281:12316:4 exposed (I)encourage (I) 207:25264:10 evaluation (4) 338:19 349:6 351:16363:24 entrepreneur (I) 173:23278:18365:9 357:15366:17 express (2)eucouraged (4) 306:16 396:20 368:2391 :23395:8 263:14298:20370:16,20,24379:8 entrepreneurship (I) event (18) 395:9,10,12,13,16 expressed (I)encouraging (I) 228:11 188:11,13189:5,8,10 395:17,20,22,24 298:16368:23 entry (2) 189:17,19,22310:2 396:2,3,6,9,11,13 expressing (I)endeavors (I) 212:6213:9 312:13313:24 396:15,17,19,20,23 181:11212:21 equal (I) 314:5,6,18,24 397:2,3 extend (2)ended (5) 189:22 315:11,14337:6 exhihited (2) 332:14333:6187:5299:12332:9 Erickson (14) events (3) 278:4,5 external (9)

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facts (1) 236:11,11,15,15,17 221:25 365:19,25 founded (1)400:7 236:22,24,25 first (90) focus (2) 215:6failnre (1) 241:18255:13 168:5172:20,21 187:9,15 four (7)348:12 296:19339:5,17,18 179:13,24180:18 focused (1) 170:19197:24240:13fair (2) 340:2,3353:7,9 183:20185:23 217:8 240:14309:9,10,11196:16352:11 fields (3) 186:18 190:6,8 folders (1) fourth (3)

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216:25217:23 goal-oriented (1) 236:2257:4267:9,12 317:9 399:7Garza (1) 228:15 267:19268:8 happen (2) hereunto (1)353:2 goal-setting (1) 278:10 300:23 328:14 399:13Gateway (1) 180:11 group's (1) happened (11) Hidarq (1)170:19 goes (2) 268:2 196:8 242:20 260:17 340:25

gathering (6) 222:5 223:23 growth (4) 280:7347:22348:4 high (5)296:16 299:3 304:13 going (37) 228:23 291:5 303:4 348:10 365:3 217:5,13349:16

305:3310:14315:2 172:9180:16200:15 303:10 372:15378:24 350:25 351:6general (3) 200:17213:7 guess (13) 379:18 higher (2)227:22389:5,5 214:13233:7 213:7,8218:17 happening (1) 204:10274:3generate (1) 241:24267:25 286:14,16313:5 371:15 higbest (2)379:24 274:25302:7311:6 327:14333:11 happens (1) 255:20,21generated (1) 311:8,14,15319:8 337:18339:15 246:7 highly (5)375:16 328:24,25 329:3 340:6341:7373:11 hard (2) 179:8,10208:18

334:25341:2,7 guessing (1) 320:18385:3


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•

•

•

316:19,21 HYLAND (1) 242:1243:1 244:1 242:18 354:10high-level (1) 170:3 245:1 246:1 247:1 impossihle (3) indicating (1)255:19 hypnosis (3) 248:1 249:1 250:1 199:15,21,24 312:12hired (3) 185:19233:3,6 251:1252:1253:1 improper (1) indicative (1)358:22363:15368:18 hypnotherapists (1) 254:1255:1256:1 388:2 348:13hiring (3) 233:8 257:1258:1 259:1 inability (1) indirect (2)363:5,25 365:3 bypnotberapy (2) 260:1261:1262:1 229:21 263:2,17bistory (1) 228:20 234:11 263:1264:1265:1 inaccurate (1) indirectly (2)286: 13 bypotbesis (4) 266:1267:1268:1 375:5 263:14378:17bit (1) 198:11,13 217:17 269:1270:1271:1 inadverteutly (1) indispensable (1)302:9 219:8 272:1,7273:1274:1 254:9 232:20Hocbman (15) 274:21275:1276:1 inappropriate (4) individual (4)366:9373:9374:17 I 277:1278:1279:1 388:2392:19,24 181:9232:3248:15 1<

375:7,12,24377:14 idea (8) 280:1 281:1 282:1 393:11 277:11377:16,20,23 197:15,19200:9 283:1284:1285:1 include (10) individually (2)378:14379:19 217:12225:19 286:1287:1288:1 208:25209:18,21 177:6180:7380:21,23381:4 330:18 346:24 289:1 290:1 291:1 210:12227:25 individuals (6)

Hocbman's (1) 363:9 292:1293:1294:1 231:18248:9 175:21180:6184:3374:4 ideas (2) 295:1296:1297:1 253:10309:15 199:8 268:8 287:23hold (2) 259:22267:23 298:1299:1300:1 310:8 individual's (1)193:10 250:8 identification (19) 301:1302:1303:1 included (8) 180:22

holds (1) 178:4,6 207:23 211:8 304:1305:1306:1 228:2252:2260:13 information (33)255:21 221:16223:5 307:1308:1309:1 262:8265:6,19 174:5177:12,16holistic (1) 226:11237:23 310:1311:1312:1 266:2351:11 205:20206:17228:17 243:20250:12 313:1314:1315:1 includes (1) 239:4253:22,23home (17) 254:6 260:22 316:1317:1318:1 268:19 261:22262:17,17292:3,10 296:17 281:13316:5 319:1320:1321:1 including (2) 263:12264:8,9

306:18307:13,19 338:20 349:7 322:1 323:1 324:1 186:16317:23 265:6,8266:14,21310:2313:25314:5 357:16366:18 325:1326:1327:1 income (3) 305:9310:7312:3314:14315:12,15 391:24 328:1 329:1 330:1 221:5222:3395:13 340:18342:14,18321:5332:8348:24 identified (3) 331:1332:1333:1 incoming (1) 354:14361:9362:19 363:3 176:24,24385:20 334:1335:1336:1 356:2 369:22370:15

homework (1) identify (2) 337:1338:1339:1 Inconsistency (1) 373:2,3390:3392:20 392:11 393:22 340:1341:1342:1 356:20 396:14398:8honesty (1) II (227) 343:1 344:1 345:1 incorporated (1) innovative (2)309:17 168:20169:8172:1 346:1347:1348:1 196:5 228:9,20hostile (1) 173:1 174:1 175:1 349:1 350:1 351:1 incorporating (1) input (1)295:17 176:1177:1 178:1 352:1353:1354:1 320:23 188:7Hoteling (1) 179:1180:1181:1 355:1 356:1 357:1 incorrect (2) inquiry (49)352:25 182:1 183:1 184:1 358:1 359:1 360:1 177:25300:17 197:8 198:20202:21hour (1) 185:1 186:1 187:1 361:1362:1363:1 increase (1) 203:14,20205:13393:8 188:1189:1 190:1 364:1365:1366:1 184:21 206:19 207:8 210:7hours (2) 191:1 192:1 193:1 367:1368:1369:1 independent (3) 212:7,17213:3,10197:24246:19 194:1195:1196:1 370:1371:1372:1 208:24365:4,8 213:18214:19,21

house (6) 197:1198:1199:1 373:1374:1375:1 INDEX (2) 215:5,17,18216:2292:25315:3,4,9 200:1201:1202:1 376:1377:1378:1 395:2398:2 218:7219:6,12,15

337:6370:3 203:1 204:1 205:1 379:1380:1381:1 Indian (1) 219:20220:4,16human (22) 206:1207:1208:1 382:1383:1384:1 230:14 221:6222:17,22179:17,18,20,21 209:1210:1211:1 385:1386:1387:1 indicate (14) 224:7,10248:23,24

180:19181:2,4,5,12 212:1213:1214:1 388:1 389:1 390:1 177:18209:4,10 310:8356:25357:3182:8,15,16183:14 215:1 216:1 217:1 391:1392:1393:1 290:6,21297:11 357:5,7,12384:4,9183:17188:6,21 218:1219:1220:1 394:1 298:6300:8303:14 384:16,19,24385:6189:6 195:21 221:1 222:1 223:1 III (1) 311:7,10316:14 385:10386:4,21228:17,18,18 224:1 225:1 226:1 272:7 321:15324:13 inside (1)290:22 227:1 228:1 229:1 imagine (2) indicated (2) 284:22

humanistic (2) 230:1231:1232:1 174:9341:2 324:16382:2 insight (1)228:14,19 233:1234:1235:1 implies (1) indicates (4) 191:6humorous (1) 236:1237:1238:1 187:14 317:15318:9342:10 instance (1)360:16 239:1 240:1 241:1 important (1) 206:23


instances (1) 301:10,12,25302:4 235:11242:2 340:24 320:24240: 17 304:18305:16 255:17258:10,12 Joe (3) keeps (3)institute (7) 324:9399:11 258:13,19290:7 186:24211 :21 259:5 270:4342:3387:7168:8170:8186:20 interesting (1) 364:20,23 John (7) Keith (30)

186:25187:3 254:23 involvement (6) 168:16184:10,14 168:15170:12192:13193:21382:18 interfere (1) 239:24 304:5 322:22 187:8,20190:5 196:23 198:5

instructing (1) 237:13 344:23 380:7,7 196:20 206:15207:12,18388:6 Interfor (3) involves (1) join (2) 210:5211:3212:20instructions (1) 168:15170:15383:4 269:5 265:9393:17 212:23218:15172:11 internal (8) in-depth (1) joining (1) 219:8,14,20220:3

integrate (1) 189:2,4,8,9,15,18,21 174:16 266:16 222:16230:7,12189:21 203:10 issue (2) joke (1) 244:8296:19297:9

integrated (2) internally (2) 274:24326:6 362:23 298:3303:24189:16272:18 188:22189:2 issued (1) joking (1) 328:20,24364:23

integration (3) International (3) 238:22 361:3 374:24,25229:7 278:7 309:8 193:22 194:3,8 issues (1) Jomanna (4) Keith's (1)intellectual (3) Internet (3) 231:25 168:25 169:11 399:4 206:18201:10,10244:15 224:20,23225:8 items (4) 399:15 Keller (4)intended (2) interposing (1) 209:18,21,25382:24 joyous (1) 301:20311:11313:13201:11283:14 387:25 iteration (1) 203:4 313:17intending (1) interpretation (1) 219:10 July (5) kept (4)393:16 259:21 Ivy (4) 197:21 198:15251:15 248:7342:6343:16intensive (59) Interrogatories (1) 215:25216:21222:23 254:8374:14 387:8174:8179:15204:20 395:18 224:2 June (12) keys (1)

240:9,9244:24 Interrogatory (2) 168:21 169:4250:22 246:21245:22 246:7 226:16,22 J 316:15317:17 kind (8)267:11269:20 interval (3) James (3) 319:4 332:4,24 188:5201:3,6217:9272:11,14,24 277:18,23279:2 187:4191:22192:9 333:11 345:11 300:20360:12,16273:12277:16 intervention (4) JANE (1) 394:14399:13 375:15282:19,25,25283:7 358:22361:13,18,19 168:16 junior (2) kinds (1)285:20288:14,16 interview (3) Jeanie (2) 217:5,13 361:20307:16313:21 235:12236:12271:12 253:15255:14 Juval (2) kinesthetic (1)315:21,25316:15 introdnce (6) Jeffrey (4) 168:16170:15 188:7317:16,21319:5,8 207:18314:17,20 367:6,6372:25373:7 knew (15)319:12323:20,21 352:18,19391:20 Jennifer (4) K 256:16289:11290:10323:25,25 324:4,6 introduced (3) 340:14341:6,8,16 KAPLAN (1) 300:12318:7,7328:12,13329:23 185:24186:3 197:2 Jersey (10) 170:15 320:21325:12332:4,10 333:3,18 introduces (2) 168:2,20169:10 Karen (13) 360:6 362:20 365:5334:4,9,11 335:17 233:22,24 170:6,10,13,20 173:24174:13175:4 365:5371:10,13337:22342:24 introduction (2) 292:3,15293:19 176:8222:5224:3 390:9343:8,9,16346:12 309:16310:6 Jeske (8) 225:6239:25 know (150)347:9,22348:23 introspective (1) 255:11,13,16,19 246:23251:15 174:17176:12,14,16355:13 309:7 308:15322:19 352:23357:24,25 177:2179:11

intensives (9) invest(l) 336:22364:22 Kasson (9) 180:24181:14,22204:23243:11 244:22 200:13 Jeske's (2) 293:8306:19310:25 192:12,15 194:10

245:4,5,8336:13 invite (1) 255:24257:9 313:10 367:10,11 201:24,25204:11338:16 346:9 231:6 Jews (1) 369:25370:4,6 207:12,16208:17

intent (7) invited (5) 294:14 Kassons (5) 208:19212:18213:17,20,22214:2,5 234:6307:20314:4 JJO (4) 307:13,19310:2 213:4,6,9,14214:4

305:11 323:4 314:19346:8 255:4260:6,10,13 313:24315:14 214:12217:18interaction (2) inviting (2) JJO-00097 (2) Kathy (1) 218:10219:7,11199:3 200:23 295:11 305:11 254:22,22 211:16 220:19221:7

interactions (1) involve (1) Jness (7) Keeffe (5) 222:12225:2,4,7,13201:17 173:22 214:22215:2,3,8,9,12 168:15246:22344:22 226:4,7230:17interchangeably (1) involved (18) 217:19 352:25377:8 233:25234:10,13195:2 194:18195:20207:15 Jo (5) keep (10) 236:22243:21

interested (13) 215:8216:15,17 340:14341:6,8,8,15 174:11 243:7267:23 245:17247:24198:10208:11213:11 222:22 224:4 job (1) 285:25286:3 290:4 249:23 252:13

234:13294:5 300:20311:18,21 253:4258:10,13,21


•

258:24260:3 343:18349:8378:5 learn (19) 250:20,21,23 251:7 limit (1)264: 11 276:23 378:18380:18 184:5 186:12237:4 251:14254:8317:6 232:2277:12290:8 381:21382:3 237:18262:14 358:6378:8395:24 limitation (1)292:14293:4,21 391:21393:21 268:7,8269:16 396:17 231:3294:24295:5,23 395:4 271:5302:18 letters (1) limitations (2)296:2297:7298: 14 Kofman's (1) 323:12324:22 258:5 203:5274:24300:18303:5,6,9 393:19 337:10351:8 letting (1) limited (9)304:9311:5313:4,4 Kristin (10) 352:16358:21 320:4 186:8187:7201:12316:18317:5,7,9,12 168:15238:9239:12 359:3372:21 373:8 let's (6) 228:2 231:25317:13,19318:15 246:22 344:22 learned (20) 178:3 234:24 254:3 243:10 356:16,16 ¥324:8325:11,18 352:25373:24 186:13,15205:16,20 265:18266:4339:6 356:18326:2,3 330:25 374:23377:7,10 206:2,7,12,14,17,22 level (38) limiting (2)333:17334:17 262:20264: 12 255:21,21,24268:7 248:16356:14338:9,17340:17,25 L 276:3288:24 268:10270:11 Linda (4)341:15343:2,7,10 L (3) 290:13 303:25 271:8,15,24272:7,7 186:24340:25341:9344:16,17,18 170:6,10 172:2 304:3320:19,22 272:7273:7274:8 341:11348:23352:2 353:4 Landmark (3) 358:13 274:13,21 275:4,19 line (17)356:22,23,24357:6 181:18182:2,4 learning (5) 275:23276:9,20 391:7,10398:3,3,5,5357:11,14,21,24 Landy (3) 213:22268:6276:25 278:6279:3,4281:3 398:8,8,10,10 400:9 ,358:16359:17,22 170:17172:11 383:2 278:19352:19 281:10341:14 400:11,13,15,17,19360:3,12363:10,14 language (9) leave (10) 349:16 350:25 400:21367:2,2370:19,23 184:6187:9242:4,8 232:17242:14243:12 351:3,6,18,21352:4 linear (1)

s

370:25371 :2,3 242:10261:11,16 243:15249:17 352:7,7,8,10 203:8 ~

372:8,14,23374:9 261:18263:20 284:16,17304:4 levels (16) linguistic (4)375:6377:7,9 large (1) 345:17,21 .204:10270:9,18,18 190:14,15191:2 1378:12379:15,17 347:9 leaving (2) 270:20271:5272:2 205:25380:25381:3386:7 larger (1) 348:8,11 272:4,6,6,11 273:5 linguistics (4)386:12390:2,9 247:12 led (4) 274:3281:25 184:14,17187:15,16391:3,11,12,15,18 lasted (1) 176:7198:17317:20 349:19,23 Lisa (16)392:16 197:23 332:13 Levy (2) 308:18326:20327:14

knowing (3) late (5) left (10) 341:6,15 328:7,10,15329:14258:25291:13318:5 195:19196:24307:9 192:9 242:22 254:25 Library (1) 329:15,17,18330:8knowledge (21) 327:8382:10 257:18299:12 389:18 330:18,20331:3,20174:16,19175:18 laughing (3) 330:19,20 345:19 license (3) 352:24

177:5178:23196:3 361:3,5362:22 347:14349:2 214:20218:6,21 list (23)225:5,24238:16 Lauren (15) left-hand (1) licensed (4) 226:3,5,6,8,24227:4245:11 248:21 216:22224:2308:16 317:6 192:21 193:7213:5 227:6,10 231:11,12249:4 268:9 272:4 322:2,4,20323:2,3 legal (10) 215:19 231:21236:17,18371:6,8378:21,22 323:6,6340:11 177:10246:23247:5 licenses (1) 241 :23 270:3380:9,11383:21 352:22,23357:21 251:8256:16 214:18 311:22,25312:12

knowledgeable (4) 357:22 257:25 266:7,9 licensing (8) 312:16,18342:2,4385:21,24386:3,5 Lauren's (1) 388:20 389:20 195:7218:12219:17 351:23known (2) 323:7 legally (1) 221:5,13,14222:9 listed (3)194:23243:25 lawsuit (7) 389:9 222:11 173:7209:18,21

knows (1) 313:19331:12374:7 length (1) licensure (1) listen (1)231:5 377:20379:24 383:11 193:5 377:13Kofman (43) 391:2,4 LEONARD (10) life (10) listening (2)170:6172:7175:8 lawyer (4) 170:14231:17383:11 185:11200:13233:9 270: 16 384:2

178:3,7192:16 245:16333:17388:24 386:15387:20,25 274:23277:5 listing (1)207:24209:8,16 389:2 388:5392:16393:4 299:22305:19 230:3214:7221:17 lawyers (2) 393:10 348:13,18356:15 lists (2)223:15225:16 231:18390:21 Les (I) Iight(l) 177:3209:2237:20250:13 lead (1) 251:10 208:22 literature (1)254:3,12,17,21 175:24 Leslie (5) liked (14) 303:11255:2,5260:9,15,18 leadership (1) 293:8,9 306:18 225:18294:20302:8 litigation (3)260:23263:7 228:20 310:25313:10 304:7,16319:16 226:2281:17 398:2281:14286:13 leads (1) letter (18) 322:6323:16 little (1)310:19312:5,10 267:8 172:15192:17213:17 324:17325:2,6,19 385:3316:6338:11 213:20214:2,5,10 332:15,19 lived (2)


193:9294:13 299:18314:12 markets (2) 220:7221:7223: 16 medicine (l)lives (2) 322:6 360:I9,20,23 212:7,17 225:14245:14 185:22292:15325:25 love (3) marriage (1) 249:10250:3254:7 meet (8)Livingston (1) 289:6290:20291:21 399:11 254:15,20,24255:3 234:20237:3288:11170:9 loved (3) Martin (12) 258:17260:7,10,16 291:10,18292:13 q

LLP (2) 290:18294:6306:4 168:9170:8366:9 260:20262:2263:5 292:16,22170:3,12 LOWENSTEIN (1) 373:10375:18 264:2,15266:6 meeting (13)

locate (4) 170:7 377:17378:14 286:12,16312:8,14 206:15271:13 281:6252:6,8,11358:9 Luncheon (1) 379:19 380:22,24 345:9366:22,25 291:16,19295:9,24

lock (1) 259:3 381:5382:19 369:9376:14377:5 296:15,15305:2330:5 Martin's (1) 378:9,16380:2 306:23376:15,18locked (3) M 381:7 382:2,9,13 383:9 meets (1)246:18247:20,23 M(2) master's (2) 384:25 386:17 246:2Logic (1) 170:14172:2 193:10,16 387:2,22388:9,19 memher(l)208:2 main (4) match (2) 388:24389:3,19,23 288:20

long (28) 181:16185:9186:16 203:10324:11 390:8,15,19391:5 members (2)194:3 198:23 220:25 381:20 matched (2) 393:17,25 246:22,24

225:22243:25 making (8) 348:15,18 McClellan (1) membership (1)244:18,25 245:20 229:24230:21,24 material (15) 176:23 309:3245:24 246:3 232:5,20233:11 206:21218:6,22 McGuire (7) memory (2)247:23 259:2 251:2307:23 278:7320:17,23,25 169:9170:18,21 212:19225:17276:20,21 313:6,12 malicious (2) 331:21351:17 388:7 392:18,22 mention (12)315:6326:7,9,11 253:10,20 371:19376:2 393:14 265:21289:22290:24327:2,23331:4 man (2) 378:23 384:23 mean (24) 290:25 291:4,16343:17350:15 360:18,23 388:16,17 180:18209:17212:17 300:25302:15358:9,14360:7 management (2) materials (69) 213:2234:5,22 303:3 305:21

longer (3) 228:4230:8 195:8213:10223:19 236:7 239:2 261:25 321:18343:19328:4345:22388:18 Mandy's (1) 223:20224:20 262:17 280:20 mentioned (19)look (15) 378:11 225:10,11241:8,11 282:15283:9288:2 182:19193:20196:23176:22187:18188:24 manual (1) 242:13,23243:14 297:18300:23 218:18231:20

189:4190:19 191:12 261:22262:11,12 301:19312:15 232:6241:11,25211:13214:6 manuals (9) 263:3,11,23264:5 339:12360:13 242:25 258:5223:12235:24 191:18192:6,7,11,18 265:4,17 267:12 362:17,20378:16 266:24283:5300:18329:11 224:5,7,11,13 285:16296:21,22 378:20 298:12301:5,9338:10340:13 map (1) 297:3 309:25 meaning (27) 320:3 332:2343:4343:15381:19 187:25 311:18,20333:20 188:8248:13,14,20 354:2

looked (5) Marcello (1) 343:6365:12,15 249:5 256:14 mentor (3)176:17187:21224:14 353:3 366:20367:5,15,20 264:12,18,20 199:4,9,9

329:10,14 mark (5) 368:9,13,16,19,21 267:21 279:6 338:5 mentored (1)looking (20) 178:3 179:9237:20 368:23369:6,8,11 344:5351:13 354:6 199:10172:17176:20179:7 254:3391:21 369:16,24 370:3,7 354:8,14,17,19,22 mentoring (1)

185:20188:11 marked (28) 370:13,17,20,24 355:9,19,25356:17 230:13211:22212:5,5 178:5 207:22 211:7 371:22372:10,22 357:8,10,13 message (1)218:9227:11260:2 211:10221:15 372:24373:9375:7 meanings (2) 348:12261:14299:22 223:4226:10 377:23 379:8 381:2 265:12355:21 met (20)318:6325:16 237:22243:19,22 381:4,16,16384:19 means (11) 192:13 196:23 197:13329:13 338:24 250:11254:5,18 389:13 390:6 204:5,9,15205:12 197:13 198:5348:9351:7362:8 260:2,21 281:12 mathematics (1) 209:20282:22 207:19212:22,23

looks (3) 316:4,7338:19 184:15 317:7,13334:23 212:23288:21188:4235:23317:11 349:6357:15 matrix (2) 383:20389:9 291 :22292:4,4

Loretta (1) 366:17367:22,23 270:24350:12 meant (8) 293:9,12,24315:24353:2 382:21390:15 matter (3) 199:20 210:21,23 319:15321:4loss (2) 391:24398:10 276:25 393: 19 399:12 238:23 282:21 334:10172:23 173:8 market (6) matters (1) 294:11 361:17 method (39)

lost (1) 219:5227:13,15 253:11 382:13 197:8 198:20202:5267:25 233:16355:20,20 MC (64) measurahle (3) 202:22,24203:15

10t(11) marketing (1) 175:2 179:2204:6 200:8,10297:16 203: 16,21,23,24,24191:16199:5277:10 213:3 209:6,14211:12 medical (3) 204:4,8205:2,5,6,8

277:11 297:7 212:18213:4,8 185:20229:22238:19 205:13206:19,19


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«

«

207:7,8210:9 358:15 298:16 304:23 355:12383:17 247:20293:7298:23215:19218:7 mission (2) 314:23315:2 need (15) 321:4330:14219:21220:16 224:22391:15 369:13,15,23 229:25245:3272:16 Nirbhaya (6)221:6224:10 misunderstandings ." 370:12,16372:2,12 272:17277:9 249:24,25 250:5248:25254:23 189:25 378:12 283:16,17327:21 256:7,19258:23384:10,11,12,16,20 misunderstood (1) Morristown (1) 354:15 356:22,23 NLP (31)384:24385:6,10 312:15 170:6 356:24357:6,11 183:23 185:24 186:4

methods (7) model (27) motivation (1) 383:23 186:12,14187:9,24192:2,3261 :22 181:21186:11 187:22 229:9 needed (5) 189:20193:25

262:10,13 263:11 190:14191:24 motivational (1) 247:12276:3 279:9 194:17195:7,12,25384:4 196:22 199:18 228:21 305:9345:17 196:15,18205:16

Mexico (7) 200:10205:7 Motors (1) needs (1) 205:20206:2,7,9,13346:9,13,22,25347:7 210:14213:23 389:5 283:15 206:17,23207:13

347:9348:23 218:15224:7230:7 move (6) negative (2) 210: 12,13,14,17Michael (74) 230:9232:21 175:9273:3,18 263:24 264:6 300:9,12,19172:16258:5288:12 237:18249:7273:2 323:11324:21 neighbor's (1) Noam (2)

288:13,20289:4 294:16297:16,25 325:20 337:6 187:23,23290:12,14291:7 299:19303:25 movement (2) net (1) nonmedical (1) I,292:10,16293:18 306:11320:18 181:13 183:15 173:8 228:8 :294:4,6,15295:20 324:17 Mulberry (2) Neurodynamics (2) non-compete (1)296:6 299:13 modeled (3) 169:10 170:20 180:15187:6 195:10 !304:25305:5,13 182:23 187:24227:12 multiple (4) neurolinguistic (10) non-traditional (1)306:4307:20,21 modeling (1) 176:3 183:11 188:12 179:25 180:3,12 183:6317:23318:10,13 184:25 200:21 182:20184:24 normally (5)325:12,23,24339:7 models (6) 187:19,21189:11 320:10 322:14 323:6339:11 340:8 179:23180:5181:18 N 190:3 191:11 324:3335:18348:25358:23 183:3,13 196:5 N(7) neurolinguistics (1) Northern (2)359:4,5,9,15,25 module (19) 170:2 172:2,2,2 196:12 390:13,22360:8361:6,14,23 205:17,21,22206:3,4 214:15395:4400:5 Nevares (4) Nos (7) ,

362:19363:5,12,17 206:6,23,25207:4 name (10) 215:25216:21222:23 221:19250:15254:19363:18,21,23,24 274:17275:9 176:23187:14249:11 224:2 254:22 260:25364:2,7,16,21365:2 284:12,12285:2,19 249:22,23 303:5,8 never (25) 281:18383:15365:7,11,24366:14 309:17,17,18,19 329:19400:3,5 199:2,10200:4 Notary (3)367:3,4,12368:10 modnles (32) named (3) 201:21,23207:9 169:12172:4399:5368:11369:19,21 203:23205:18206:16 249:8250:2314:15 219:11249:6 note (3)370:10373:3,4 222:19,19224:12 names (4) 252:16259:6,14,15 252:15254:16353:16375:23376:5,7 224:13 266:19,21 176:21 193:22,23 259:17,24284:15 notehook (1)

Michael's (5) 267:9269:6,7,18,19 363:18 310:20 346:20 372:16329:2,5340:10 367:6 269:22,23270:7,9 Nancy (9) 351:2361:24 noted (2)

373:6 270:24 274:19,22 168:15,20169:8 365:10 377:3,16,18 388:4391:10mid (1) 279:9 282:18 170:19178:10 382:11391:22 notes (28)186:19 284:10309:15 192:18394:10 new (34) 247:11248:10,10

middle (4) 310:5336:8,12,16 399:7 400:24 168:2,20169:10,13 259:19284:8,9,14217:6,7317:10 389:12390:14,22 Natalie (1) 170:6,10,13,17,17 284:15285:10,25

345:19 Monday (3) 197:2 170:20192:24 287:12,15288:6,8Milton (11) 327:21,22,24 Nataraja (8) 193:5,9 196:4,II 288:10310:3,4,9,11182:24,24183:19 money (5) 214:23,25215:22,24 200:15236:9 310:12333:23

184:7,18185:8,13 177:8,14219:22 216:16,19,21 239:16 262:20,23 334:3344:14,20,21186:5 190:16,19,23 237:18 266:4 217:25 272:24 292:2,15 366:13 380:18

Min (1) months (3) naturally (2) 293:19299:23 381:13282:14 197:25198:13 291:12 185:2277:9 325:16,24,25326:2 notice (2)mind (4) Moody (2) nature (9) 390:13,23399:3,4,5 169:11383:4188:5,6199:23 168:16170:16 190:24205:25217:9 Newark (3) noticed (1)

300:21 morning (6) 270:12279:6320:6 168:20169:10170:20 176:20minded (I) 172:8261:6328: 16 320:17 354:23 newspaper (1) November (1)295:14 328:22329:12 355:6 177:17 307:10misquoted (3) 392:10 necessary (7) Nicki (2) NS (2)238:25 239:2,11 Morris (15) 240:22269:8274:11 224:16,17 213:17,18missing (1) 168:8170:4294:4 283:12297:10 night (5) nuclear (1)


230:14 305:15306:8 393:18 194:21,25195:10 241:15245:6273:10number (36) 307:12308:8 objections (4) 198:19200:16 273:11 320:16175:12,16176:7,18 309:22,25 310:16 171:8227:22,22 202:3203:13 352:17359:17

176:18,23 179:25 311:17,22,25313:9 242:9 208:17,20209:25 371:16389:15180:7181:17182:9 313:21320:3 objective (1) 212:5,16213:16,25 ones (3)183:21 185:8 333:13,19334:8,22 283:14 214:4,7215:14 181:16284:10341:25186:22,23 187:7 335:2338:22 objectives (3) 218:9,23219:3 one's (3)191:25211:17 341:16342:2 204:3281:7324:10 220:13221:9 181:9,10202:25212:2,20225:23 343:13344:10,13 obligated (2) 222:14225:16 one-day (8)237:21241:23 346:2347:16 383:21,23 233:3238:13,21 308:24 310:2,24243:10249:15 348:12 350:9 observation (1) 239:15240:3,17,23 311:18,21313:3,24255:4260:6274:19 353:20355:9,20 254:16 245:9247:22 315:2290:15293:4 358:13363:6371:5 observed (3) 248:12 250:8 one-hour (1)359:20360:5 364:6 371:21377:19,23 275:6276:16,17 252:14,22254:15 206:25369:20395:16,19 379:25382:21,25 obstacles (1) 255:24257: 16 one-page (3)396:19 383:18384:7,9,15 352:10 258:15259:10,16 178:8207:25 239:20

numbered (1) 384:16,18,20,22,24 obtain (6) 259:23260:9,15,18 one-to-one (1)285:17 385:5,11,12,14,20 203:21310:16311:22 261:14,21 262:10 183:23numbering (1) 386:23387:6,7,12 335:2368:8369:24 262:16,25263:7,20 ongoing (1)286:3 388:15389:12 obtained (1) 264:21265:7,16,21 376:4numbers (2) 400:3 366:20 266:3,24267:6 open (3)260:4,6 NXIVM's (20) obviously (1) 268:12,20269:4 305:25306:8326:3numerous (2) 177:10,15206:14 324:23 271:7273:16 opening (2)238:22,24 227:15235:17 occasion (4) 275:18276:16 325:10,23NXIVM (169) 264:5298:17334:3 174:15241:13,14 278:25 280:3,19 operated {l)168:4173:6,15,18 379:23381:3384:4 246:6 282:8,12283:3,8,18 193:25

174:7,11,20175:21 385:21386:5,18,25 occasions (1) 283:21284:3,18 opinion (4)179:9180:25 387:14390:12,14 243:5 286:24 288:5 291:4 264:7354:18356:7194:23201:19 391:16392:4 occur (1) 292:9295:8296:14 393:11203:13,14,20,21 NXR00035 (1) 189:14 297:6298:6311:3 opinions (1)205:9,11,15208:12 396:21 occurred (2) 311:22 312:5 264:10209:4,12,17210:2 NXR00037 (1) 225:25314:5 313:20314:17,25 opportunity (1)210:17214:4218:5 396:22 occurs (1) 316:23317:15,19 327:15220:14223:21 NXR00038 (1) 188:12 318:9,23319:7,13 opposed (5)224:19225:10 397:5 odd (3) 324:5326:18328:7 229:22232:20264:8226:3,25227:6 NXR00046 (1) 347:18360:2,11 329:6331 :20332:2 267:24282:19229:10,14230:6,10 397:6 offered (3) 333:13,18335:20 optimal (1)230:11,16,19,22 NXR00047 (1) 202:7,10327:14 336:14 338:6,11 228:21231:3,10,22 232:22 396:24 offhand (1) 339:6,16340:11 optimistic (1)233:3,6,13,18234:8 NXR00057 (1) 343:10 342:2344:22 332:18234:25235:2,2,23 396:25 office (9) 347:14353:16 optimization (1)236:19,24237:6 207:17240:21353:24 355:8357:21358:6 228:8239:16240:3,24 0 387:14388:17 358:17,20363:4 ordeal (2)241:7,15242:12 oath (1) 389:13,16390:5,7 365:11 366:25 326:8327:7244:17 245:12 171:14 officer (1) 367:22369:3,18 order (6)246:11 248:20,22 object (18) 171:13 370:10371:2 268:21283:23356:21251:12252:11 204:6209:6,14220:7 offices (1) 372:21 373:8 391:6,20393:13253:4,12,19255:18 225:14245:14 169:9 375:22379:23 orders (1)257:21258:15 258:17 262:2 380:2 Oh(7) 381:10,21382:9 393:14260:12261:9,11 384:25386:15 248:4295:19324:5 384:13 385:9,15 ordinarily (3)262:13,23263:23 387:2,20388:19 334:11367:11 386:2387:5 389:4 245:24320:15333:21265:9,22266:4,16 390:19391:8 382:11393:25 390:4391:19393:2 organic (2)266:25267:4,7 392:18,25 okay (166) older (1) 217:9279:5268:4,13 270:4 objecting (1) 173:10,15,22174:2,6 282:24 organization (21)276:7 279:15 282:3 388:9 174:18,23177:14 olfactory (1) 195:6215:3,4233:12284:13285:8 objection (12) 177:17,21 179:7,12 188:8 234:5236:5,7,12286:11,25294:5 263:5264:2,15266:6 180:16181:8 190:2 Olsen (3) 237:2253:22296:14297:3,12,23 386:17388:2,3 192:16193:6,10 240:2 242:2 244:9 255:14324:15298:7,8 304:6 390:8391:5,7,9 once (9)


339:4,19340:9,10 400:21 399:10 303:7305:14,20,22 284:4285:12,13359:17364:7 paid (12) partnered (2) 305:24 306:11 304:8309:24368:14383:24 257:19368:8,12,16 186:19191:25 307:21,22,24,25 318:10325:15396:13 368:21 369:23,23 pass (1) 308:8311:17 339:8,15,18,21

organizations (6) 370:2,7,8,9,12 271:3 317:23318:17,21 340:8343:5364:16218:18227:12233:5 pair (I) patent (5) 319:17320:9 364:17385:20

233:19234:3 254:21 220:18,20,22387:15 324:18325:7,8 personal (11)236:19 Pam (9) 390:3 334:21 339:3 228:22,22,23,23

originally (3) 212:10,10,19,22 patented (I) 340:14351:7,20,24 236:3 270:25218:13219:4332:3 215:11,13322:18 220:17 352:20360:6361 :5 271:10291:5303:4Origins (6) 352:25 359:23 patenting (2) 364:19 303:10383:21204:21 308:25309:6 Pamela (2) 390:2,24 people's (I) personality (2)

309:8,13,14 218:24359:24 patents (I) 203:9 231:24277:4Ortez (I) paper (3) 223:22 percent (2) personally (4)353:3 187:24188:20258:18 path (5) 205:21207:4 181:16326:10 341:5outcome (I) paragraph (16) 268:12283:9,11,19 perceptiou (I) 341:17399:11 172:20,21208:21 284:5 228:18 perspective (I)outgrown (I) 223:12,18,18,25 pattern (3) perceptions (1) 269:24247:11 227:17252:2253:7 316:21348:15,18 203:10 persuade (2)outlined (I) 258:23261:14 patterns (9) perceptual (I) 266:15332:16230:9 358:7367:24368:6 184:6187:10190:19 202:25 Peter (7)outside (6) 368:8 190:20,21,24191:2 perfect (1) 170:10 381:23 382:2 ,

263:23264:6293:16 parameter (I) 191:5203:5 325:2 382:17383:2300:4,7336:13 267:24 Paul (2) perform (3) 389:24391 :7

outsourcing (1) parent (2) 168:9170:8 229:10,13 230:6 phone (6)228:19 339:11,12 pay (6) performance (2) 239:4315:19,23overnight (I) parents (8) 218:3,5219:20,23 228:18229:4 321:9360:2364:16393:7 291:17,20292:4 221:12,14 performed (I) phonetic (2)oversaw (I) 294:10 295:24 payment (I) 176:6 314:15353:2328:12 296:3,7,9 177:9 period (8) phrase (6)owned (3) Park (1) payments (I) 183:14,18208:15 180:19212:16261:25215:24216:22218:24 170:13 220:13 224:25278:9,11 262:6,11 283:10owner (I) part (21) PC (6) 350:15391:16 physical (2)221:10 212:12232:25248:24 170:7212:7,9,16 Perls (8) 216:12377:6ownership (3) 249:3 256:13 213:17214:10 181:15 182:7,11 physically (I) i196:18219:15220:4 261:24263:13 pending (4) 184:9,18190:17,22 329:6

owns (3) 266:13268:2,18 220:18,21 221:2 191:2 Ph.D (2)215:12216:19,21 269:20 282:22 223:22 permission (3) 168:9192:24O'Hara (3) 285:3299:8307:5 Pennsylvania (1) 263:15265:23,24 picked (1)211:21 259:5 391:2 349:15 350:24 186:25 permitted (I) 324:24

351:5,12377:22 people (83) 337:20 piece (1)P 393:18 176:4181:14184:21 perpetuate (I) 354:13

P (2) partial (2) 185:3 188:12 189:9 234:5 place (11)170:2,2 226:6,8 189:20191:20 perpetuating (I) 272:19,21275:21,25

packet (1) participant (6) 203:7208:11,23 253:21 275:25 276:2,3246:6 236:10249:15250:6 216:5219:4226:25 PERRETTI (I) 303:7,9307:13Padilla (2) 255:20271:2310:4 227:14229:12,17 170:3 372:9197:6353:3 participants (2) 229:19 230:23 persistence (I) placed (1)

page (35) 297:8309:19 231:16,24232:4 229:9 331:2172:17222:8223:9 participated (3) 233:7236:5242:21 person (45) plaintiffs (4)

223:13226:17,18 196:9 222:23 244:8 243:11256:9257:4 172:25 173:3,7,11,12 168:6172:22227:23250:20,21251:14 particular (3) 258:4264:9 266:23 173:16,21 174:7,12 227:24252:22 256:3 216:11240:19283:13 271:17,19273:25 174:19,24175:15 plan (3)367:24,25 368:3,3 particularly (I) 274:9277:8278:6 175:20183:10 232:10,16274:25395:3,8396:2,14 295:15 283:8,10,15,17 185:18187:4201:3 planning (3)397:2398:3,3,5,5,8 parties (10) 286:9,20,21293:5 201:6203:3218:14 232:8,16,23398:8,10,10400:9 171:5221:13 256:13 294:13 297:8,24 233:22,24235:4,10 plans (2)400:11,13,15,17,19 257:7,23258:11,14 298:9,11 299:12 235:11 249:20 304:12324:14

258:20 368:7 300:18302:19 276:25278:17,19 plant (1)


230:14 power (4) 274:11279:14355:11 340:4,7342:19,20 263:3,24264:9,14Plaza (1) 230:14384:9,11,14 pre-requisites (2) 342:21,23,25343:7 265:4,9,14,16266:5170:5 practice (15) 336:9 352:16 343:7,14,16 266:17,18

please (2) 179:16185:22237:13 Principles (19) proctors (8) projection (5)172:14237:20 237:17285:21,24 168:5214:16,17 247:17,18,19248:3,4 354:24355:3,7

plus (2) 290:2,7,11 297:2 218:3,6,11,17,19,20 248:5276:11343:2 356:23381:12280:20333:11 303:18313:2 218:21219:16,20 produced (11) projective (5)point (20) 319:13321:16 220:5,14221:4,10 178:12181:18221:19 349:13350:8,10178:21,22185:11 334:3 221:12222:4 250:14254:10 354:3396:15

201:14230:14 practices (1) 223:22 260:11,24281:16 promote (2)273:21278:23 256:25 printed (1) 312:7338:12349:9 266:22 306:15293:19319:11 practitioner (1) 374:5 producing (1) promoted (1)325:19330:3,19,21 183:20 prior (4) 180:23 368:22338:18345:18 practitioners (4) 319:15324:17,19 production (2) promoting (1)350:9372:19375:6 186:10 190:10 191:9 325:3 260:12398:5 369:8376:7393:5 196:7 private (2) products (1) promotion (1)

pointed (1) pre (2) 237:13,17 176:3 281:25348:17 270:23272:8 privilege (1) professional (3) promotional (1)points (1) precise (2) 254:11 177:6229:2268:10 241:10252:15 383:15,24 probably (31) professionalism (1) proper (1)policy (2) premises (1) 175:5190:6,12194:5 270:15 225:20266:25267:4 313:7 239:3 251:24 professor (1) properly (2)popular (2) prepare (1) 254:12278:7 184:17 175:3232:16182:12,13 211:24 297:14,17305:10 program (61) property (3)

portion (6) prepared (6) 306:22307:17 175:16215:16217:14 201:10,11 244:16193:13,18204:13 334:6382:10,24 308:10,15,16,17 223:20233:23,25 proprietary (1)

205:19207:14 383:6,17 392:9 310:5,6315:20 234:15,22,23 196:17286:7 preparing (1) 319:10322:18 236:10238:19 prospect (2)

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238:23239:6,9 178:13 395:9 210:6211:3220:3 297:9299:21 400:7320:5 P000004779 (2) 220:14222:16 300:23 304:9 311:2 recreate (2)

psychology (8) 208:3 395:11 230:8244:8298:4 325:7337:23 186:11 232:10182:23228:14,19,24 303:24374:25 340:15347:12 recreating (I)

229:3,4355:4,5 Q 386:24387:5,11 351:10 366:5 386:7 213:23psychotherapist (4) qualification (3) 393:9 reason (16) redirecting (I)192:21 193:3,4,8 271:12,15281:24 Raniere's (3) 229:22239:10249:21 270:16

psychotherapists (I) qualify (5) 375:3385:16392:2 303:23320:9,13 reduction (I)320:5 269:2271:4,7337:23 rank (10) 345:20347:11 228:7puhlic (5) 341:21 257:9268:5279:16 400:6,9,11,13,15,17 refer (3)169:13 172:4257:3 quautifiahle (2) 279:19285:13 400:19,21 234:9284:11 340:5

387:17399:5 200:10297:16 323:7334:7,12 REATH (I) reference (2)puhlicly (3) question (36) 335:2342:5 170:12 251:25339:16387:13 388:16 390:7 171:9 175:23 177:2 rapport (8) recall (15) references (1)puhlicly-availahle (1) 187:13203:19 206:3,5,6,7,23,24 195:24292:11 296:24 392:2387:15 204:7,12205:14 277:7278:4 297:18298:15 referrals (5)puhlish (2) 209:7,15220:8 rational (50) 311:13 315:8 318:3 173:2,12 175:13,17182:8185:6 223:11225:15 197:8198:20202:21 319:8 326:6 329:9 175:24

puhlished (I) 235:22245:15 203:14,20205:13 333:22,25345:24 referred (3)182:9 250:4258:18262:3 206:10,19207:8 349:4 213:21234:25318:10

purchased (I) 263:16264:3 210:7212:7,17 receive (8) referring (7)177:19 284:18363:8 213:3,10,17214:19 246:12250:23279:23 204:17 223:24 259:8

purports (2) 378:19380:3 214:21215:5,17,18 281:4,5318:13,20 262:12,13325:4252:23261:2 384:21385:2,9 216:2218:6219:6 333:21 343:3purpose (5) 387:3,21,24388:4 219:12,15,20220:4 received (2) refers (7)205:5244:13265:8 388:10,11,20 220:16221:6 251:7318:24 175:20180:20214:12

268:3308:6 389:10390:20 222:17,22224:6,9 receives (2) 222:12252:17pursuant (I) questioning (4) 248:23,24 310:8 221:6241:15 253:7339:8169:11 256:24267:20341 :23 356:25357:2,4,7,12 receiving (I) reflect (I)

pursuing (I) 341:24 384:3,9,16,19,23 253:16 393:15360:20 questions (20) 385:6,10386:3,21 recess (5) Reform (1)put (17) 175:3177:8180:17 reach (3) 211:9226:20259:3 396:23208:7211:19,22 191:8267:22 281:24327:19351:18 316:3366:16 refund (2)

224:15231:10,11 299:18349:13 reached (2) recognize (11) 358:3,9231:12272:20 350:8,10354:3,10 351:20352:7 178:14201:3208:4 register (I)276:3277:2312:20 354:21,24360:20 reaction (2) 211:11,14221:21 353:20330:13331:21 361:20,22381:22 375:4,15 223:6226:12 regret (1)352:9 358:20 379:8 383:3396:15 read (24) 239:13 338:25 196:21379:19 398:10 179:2,4191:14,15 349:11 regular (I)

P-A-D-f-L-L-A (1) quickly (2) 193:14,19202:7,10 recognized (I) 256:12197:6 323:11324:21 202:15204:12,14 279:7 rejected (I)

p.m (2) Quinn (I) 227:7,8,18236:18 recollection (10) 220:23259:3394:6 172:16 242:5263:9286:8 225:24297:20300:15 relate (I)P000004098 (I) quite (3) 367:24 368:5 321:10 332:9,12 298:9396:14 326:8,25340:15 374:18380:23 336:12345:4,15 related (I)P000004109 (2) 389:18393:9 364:14 399:10316:8396:12 R reading (3) recommendation (1) relates (1)P000004110 (2) R (I) 177:5238:2327:10 236:4 274:24260:25 396:7 170:2 real (5) recompensated (1) relating (1)P000004111 (I) Rainhow (8) 249:23277:14360:13 253:17 195:11396:8 214:23215:14,19 363:8364:8 recompensed (I) relationship (3)P000004122 (1) 216:16,19,22,25 reality (I) 253:25 346:2,4 384:3

217:22 203:11 record (18)


release (I) 232:12,21 171 :4 187:20 190:4 358:21 359:10390:3 reproducible (5) response (6) 191:24,25196:20 361:7,13 362:2,11released (I) 190: 11 200:7,9 248:18253:9301:24 Rick (17) 362:13365:12387:17 213:23297:15 303:22321:12 168:8,12 170:8 366:2,8,20367:7remained (I) reprogramming (I) 365:20 358:21 359:10 368:8,13,18,18,21194:10 189:13 Responses (I) 361:13,25 362:11 369:8,23370:2,2,4remember (91) reps (I) 395:18 362:13366:2368:8 370:7,8,9,12,21214:3,13250:10 207:17 responsibilities (2) 368:13,18,18,20 371:24372:10,15

254:2257:8258:25 request (10) 285:4,5 371:24382:18 372:24373:7 ,291:6292:5297:5 192:17214:8310:21 responsibility (5) RICKY (I) 374:11 378:10298:5 299:10,11 ,25 310:22312:6358:8 285:9,13 342:13,19 168:9 379:8,12382:18,18300:6,10,12,13,22 378:6392:18 386:22 rigbt (27) Rossi (3)300:24301:7,17 393:16398:5 responsible (7) 201:8203:17215:21 185:9,10,12303:11,13306:24 requested (6) 181:14195:7322:8 217:7,7220:3 routinely (2)307:5308:11,13,18 193:13,18204:13 322:12340:17 227:17262:24 241:9,12309:15,22310:23 286:7 312:7358:3 343:5380:14 274:10277:21,25 rules (I)311:2312:25 require (6) rest(l) 286:4,5287:20 172:11313:11314:13 240:3,24242:12 200:13 299:7,10315:12 RULING (I)315:17,17,22316:2 244:17 276:7 restructuring (2) 323:15325:21 398:10318:5,6319:6320:8 377:23 228:6,15 347:18350:17 run (I)321:8,22,23,25 required (12) result (6) 351:4365:18366:7 325:15331:11,14332:13 217:19240:10,14,18 191:17259:14,20 388:14389:11 Russell (2)336:17,18,23337:8 244:21,25245:6 265:13 334:8 393:12 211:16,24338:15344:7,24 252:5 265:25 361:12 rigbts (4) Rutgers (2)345:18,20347:3 275:19283:3 results (8) 214:19,21218:15,16 289:17 302:24348:7,8,8,11,14 337:13 176:13,14180:23 rigbt-hand (I) R&D (I)353:4358:5359:24 requirement (16) 190:11 191:6 282:13 228:20360:5,6361:19 271:22272:15,23 197:24203:22 rigorous (1) R-A-P-P-O-R-T (1)362:3,18363:2,7,21 273:7,14,21,24,24 297:22 237:3 206:5364:24365:16 275:21,22,24279:2 resume (I) RIKER (1)366:5,11,12369:3 283:4,6,7355:12 199:11 170:3 S372:7,14373:19 requirements (12) retained (1) RMS (2) S (4)375:21376:17 202:20270:25271:2 192:10 230:8,8 170:2,11,17172:2377:25380:4 274:12275:25 Retreat (2) Robbins (3) Sabbatb (2)381:18391:13 276:2283:22,23,25 168:10 170:9 195:15,20,25 327:16,17

remotely (I) 284:3334:10 retrospectively (1) Robert (5) sales (4)249:7 352:11 173:19 170:14,17186:16,17 207:17219:4253:18repeat (3) requisite (1) return (3) 186:23 339:19310:22378:5384:21 318:17 242:13,22377:23 Rochelle (17) salespeople (2)repeated (I) research (3) revealed (1) 168:8 170:4294:5 318:18,23337:22 185:7361:25362:5 392:14 304:23310:13,17 salesperson (3)repetitive (1) reserve (1) reveals (I) 310:21312:11 318:16,20340:3393:20 381:22 235:19 313:20,23314:8,9 Salzman (313)Reported (1) reserved (I) revenue (5) 314:10 370:19,23 168:15,20169:8168:24 171:9 172:23,24 173:2 372:5378:13 170:19172:1,8,13reporter (3) resigned (2) 175:13,25 role (6) 173:1174:1175:1169:12373:20399:5 257:18258:3 review (7) 212:14244:4,7 175:10176:1177:1

reports (1) resolve (I) 178:19222:3226:22 267:15,17288:15 178:1,4,5,8,10,14222:6 257:17 235:18242:3 rolled (1) 179:1 180:1 181:1represent (5) resolving (1) 383:15393:7 305:14 182:1 183:1 184:1226:24310:19338:11 231:25 reviewed (I) room (14) 185:1186:1187:1

374:6382:18 resource (I) 261:19 246:17,18247:3,8,9 188:1 189:1 190:1representation (7) 228:18 reviewing (1) 247:13,15330:5,6 191:1 192:1,18189:2,5,8,9,16,19,22 respect (5) 358:8 330:13,21 331:2,22 193:1194:1195:1

representatives (1) 199:3239:5,7382:24 reviews (I) 331:23 196:1 197:1 198:1253:15 383:18 222:6 Roseland (1) 199:1200:1201:1represented (1) respected (1) Richard (8) 170:10 202:1203:1204:1193:15 305:24 184:10,13 186:13 Ross (44) 205:1206:1207:1

reproduced (2) respective (I) 168:8,8,9,12170:8,8 207:22,25 208:1


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209:1210:1211:1,7 361:1362:1363:1 200:16256:22264:24 332:21338:10 seriously (2)211:11212:1213:1 364:1365:1366:1 348:14 343:15358:6,11 360:11361:2214:1,15215:1 366:17 367:1 368:1 says (22) 375:15377:4,5 served (3)216:1,23217:1 369:1 370:1 371:1 178:9179:8,13,17 381:23 260:14268:17286:9218:1,9 219:1 220: 1 372:1373:1374:1 208:21 214:9222:9 seeing (4) services (3)221:1,15,17222:1 375:1376:1377:1 223:18227:16,20 318:6321:11375:12 228:2229:11,13223:1,4,14224:1,3 378:1379:1380:1 252:14256:6 377:15 session (4)225:1 226:1,10,12 381:1,24382:1,17 258:19 282:13 seek (1) 231:15240:7343:21226:21227:1228:1 383:1384:1385:1 283:10316:21 203:9 382:23 ;229:1230:1231:1 386:1387:1388:1 341:4,9,17353:17 seeking (1) sessions (6)232:1233:1234:1 389:1390:1391:1 358:7371:17 188:19 183:21,21267:11,15235:1236:1237:1 391:23,23,25 392:1 SCHERER (1) seen (12) 275:15344:11237:22238:1 239:1 393:1 394:1,10 170:3 199:2200:2,4 201:21 set (7)240:1241:1242:1 395:4,9,10,12,13,16 school (9) 201:23207:9 268:8283:23317:10243:1,19,21,22 395:17,20,22,24 217:6,7,13,13,14,16 221:22223:7 378:2395:18399:7244:1245:1246:1 396:3,6,9,11,13,15 325:10,12,23 226:14251:18 399:13247:1248:1249:1 396:17,19,20,23 science (2) 303:10310:20 sets (2)250:1,11251:1 397:3 399:7400:5 200:8297:13 SEILER (1) 240:13260:3252:1 253:1 254:1,4 400:24 scientific (1) 170:15 settled (1)254:5,8,18255:1,3 SANDLER (1) 210:8 selected (2) 377:19255:6256:1257:1 170:7 scientology (2) 246:23338:17 settlement (3)258:1259:1260:1,3 Sandy (1) 181:20,23 selecting (1) 377:22378:7,10260:21,23261:1,4 197:6 scope (2) 322:8 seven (7)262:1263:1264:1 Sanskrit (1) 210:20,24 selection (1) 209:2,5,12,18,21,25265:1 266:1267:1 249:22 screening (4) 322:13 242:24268:1269:1270:1 Sara (2) 235:4237:11 320:4,6 self-help (1) SF (1)271:1272:1273:1 177:9,18 seal (2) 229:3 349:10274:1275:1276:1 sash (13) 390:16,18 seminar (4) SFOOOI2 (2)277:1278:1279:1 279:22,23280:5,6,10 sealing (1) 180:8,13 196:9 281:18396:9280:1281:1,12,14 280:15281:4,9 171:5 312:23 SFOOOI4 (2)282:1283:1284:1 282:6,9334:13,15 second (23) seminars (6) 281:19396:10285:1286:1287:1 396:9 172:17 202:9 208:21 180:11 186:21,22,24 SF00042 (1)288:1,11 289:1 sashes (1) 222:8 250:21 192:4229:8 396:16290:1291:1292:1 279:16 274:13275:19,23 senior (2) shadow (2)293:1294:1295:1 sat (1) 276:6,8 279:4 256:2257:11 275:11 285:4296:1297:1298:1 231:16 321:11334:20 sent (2) share (3)299:1300:1301:1 Satir (8) 336:9 338:4,8,13 259:6,14 266:12305:8,9302:1303:1304:1 181:15182:7,9184:8 345:6,9,12358:7 sentence (7) shared (2)305:1306:1307:1 184:18190:17,20 395:17,18 172:21179:13252:14 200:24256:7308:1309:1310:1 190:25 secret(l1) 261:22262:18 Shavone (1)311:1312:1313:1 satisfied (1) 386:7387:7,8,16 263:9369:12 352:25314:1315:1316:1,4 272:11 388:18389:6,9 separate (1) SHEET (1)316:6,7317:1318:1 satisfies (1) 392:12,13,13 188:16 400:2319:1320:1321:1 283:25 393:22 Sephardic (1) she'd (3)322:1,4323:1 324:1 satisfy (3) secrets (12) 294:14 251:3302:13 324:21325:1326:1327:1 271:23272:15383:16 385:21,24386:4,5,10 September (3) shifted (1)328:1329:1330:1 satisfying (1) 386:13,19,21,25 347:21,23348:2 247:13331:1332:1333:1 305:18 387:6 392:4 394:2 series (24) shifts (1)334:1335:1336:1 save (1) section (1) 180:5,20182:18 202:25337:1338:1,19,24 391:6 381:10 184:3,5 185:3,15 short (9)339:1340:1,11 saved (1) see (31) 190:4,8,9191:7,23 183:14,18,20185:24341:1342:1343:1 223:11 172:20 173:4 188:8 202:25 205:24 224:25239:17344:1345:1346:1 saw (11) 212:6222:8230:20 208:23231:14 240:11 246:5347:1348:1349:1,6 200:25223:7251:19 235:24251:23,25 237:3259:19269:6 332:21350:1 351:1 352:1 321:9324:20 252:9,25253:3 271:10274:16 Shorthand (2)352:22,23353:1 328: 14329:6,14 255:9273:17 329:3,18343:2 169:12399:5354:1355:1356:1 357:19 374:16 315:20326:10,15 serious (7) show (7)357:1,15,17,22 377:8 326:18327:2,6 256:15295:13360:17 201:9254:7347:19358:1 359:1 360:1 saying (4) 328:17 330:22 362:15,21,21,25


356:19374:22 298:18 someone's (1) spends (3) 219:25,25 220:6382:20383:9 skepticism (2) 354:25 174:7,12,20 271:13

showed (10) 298:16,20 Sommers (I) spent (5) standardized (I)198:15199:25213:10 skill (I) 186:24 173:11174:25186:7 276:12

327:13346:20 277:13 soon (4) 198:22293:7 standing (I)373:25 374:3,23 skills (8) 225:20352:15374:9 spoke (8) 391:6381:13 391:22 174:16219:5269:7 383:14 294:8315:15,18 start (7)

shown (I) 270:11,16277:7,8 sorry (7) 346:11,18347:13 197:10217:10241:4249:6 278:4 248:5 281:17 306:25 359:16 360:9 269:9,10,12277:17shows (I) Skolnik (19) 313:12340:22 spoken (3) started (13)343:13 170:10223:14382:7 375:21385:4 297:21313:23314:25 172:10202:4227:11sibling (I) 382:11,16,17388:3 sort (8) spokeswoman (I) 244:12255:22341:12 388:22,25 389:21 181:21 190:11 298:18 215:9 361:15,17362:5,8side (3) 390:17391:9,19 324:23347:3361 :3 sponsored (2) 371:14373:20,21190:23,25282:13 393:2,5,12,21394:5 362:14364:10 341:5,18 373:22

sign (25) 395:5 sorted (I) sports (2) starting (4)198:21201:14216:5 slandering (3) 300:11 229:4,4 181:14316:15323:16

217:19240:4,10,14 256:8,19258:22 sought (2) spring (3) 332:4240:18,25244:18 slanderous (I) 189:20,23 366:4373:15374:15 starts (1)244:25245:3,6,24 257:2 sounds (I) SP-1I99 (2) 226:18246:4,4,10252:5 small (I) 296:15 250:15 260:4 state (9)285:18309:20 303:19 sources (I) SP-1202 (3) 169:13192:21,23317:20,21326:10 smaller (I) 221:5 250:16252:22260:5 193:5,7,9227:23327:9,12 267:12 Spanish (2) SP-1204 (1) 399:3,5

signature (3) smell (1) 346:11 347:13 254:19 stated (2)223:10 327:3 328:18 188:9 speak (4) SP-1206 (I) 227:22379:5signed (25) Smith (3) 348:6359:15383:23 254:19 statement (7)171:13,15241:8,16 340:19342:15,16 394:3 SP-2278 (1) 224:22238:21 324:2

246:11252:12,16 Snyder's (I) speaker (I) 221:20 391:15395:13,20253:2,5256:10 238:9 314:7 SP-2279 (I) 396:3310:21316:24 Sohie (15) speaking (6) 221:20 statements (I)317:2,16323:22 249:9,13,24250:5,22 202:7228:21249:21 SPII67 (I) 222:3327:9328:18329:7 251:2252:4,12,15 256:12359:18 395:12 states (6)332:3337:19,20 252:24253:5,12,14 392:17 SPII99 (I) 168:2172:21180:10356:9358:14 256:19257:17 special (6) 395:25 183:4186:21 192:5371:20,21 social (7) 319:18,20,23323:9 SP1204 (I) statistics (2)

signer (I) 229:3231 :20,21,23 327:20329:4 396:4 174:11176:16339:7 232:2289:20325:6 specialists (1) SPI206 (I) status (1)signing (1) socioeconomic (2) 228:5 396:5 220:19326:16 294:22295:3 specific (8) SPI573 (1) stay (7)signs (I) sole (I) 174:5191:3266:12 395:21 328:25332:14,17,19285:18 221:10 274:5277:10 SP2278 (I) 333:6345:22similar (4) solution (2) 283:13,14312:13 395:14 382:10181:6184:19206:22 363:22364:10 specifically (9) SP2279 (1) stayed (3)

236:18 solution-based (5) 245:17274:5292:14 395:15 332:5,7333:10sister (5) 179:23183:3,5,12 297:19310:22 ss (1) Stephanie (102)289:5329:2,5 376:9 185:19 360:6368:15,17 399:3 168:9170:4261:3

376:13 solving (3) 369:4 staff (1) 288:24 289:3sit (3) 228:24,25,25 specificity (I) 307:23 290:15,17 291:8,9174:18175:20338:6 somebody (18) 191:4 stamp (13) 291:23292:4

sitting (I) 201:4,7207:19 specifics (2) 178:13 179:8 208:3 298:25 299:4,11,13393:8 233:25234:14,25 175:6266:19 221:19250:15 299:14,14,17situation (I) 248:16272:14 spectrum (I) 254:19,22260:4,5 300:22304:5,13,15257:16 282:16283:19,20 190:23 260:25281:18 304:15305:14,24six (7) 284:16 318:19 Speedwell (I) 316:7349:10 305:25307:11,15183:21 192:24197:12 345:15,16354:18 170:5 stamped (2) 311:3314:4,17,19

197:13 198:24,24 356:21 360:15 spending (2) 208:18316:19 315:11,15,18308:10 somebody's (1) 360:19,23 standard (4) 316:12317:19

skeptical (I) 189:15 319:3,7,15,19,24


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320:7321:3,21 276:19284:19 studio (1) 260:12 229:6,6322:23323:2,8,10 290:24294:3 215:24 SUPPORT (1)324:14,16325:14 298:24321:19 study (3) 398:2 T328:18329:4 322:9356:25371 :2 179:15,20237:19 supposed (5) Tabie (4)330:22332:3,19 372:22375:10 studying (4) 209:10,11 284:16 301:20311:11313:13333:14,19334:7,21 376:15381:2,11 198:11,13206:2 286:2 345:22 313:17336:11337:4,8,17 stripe (7) 303:24 sure (39) Tad (3)338:21339:22 281:9 283:8,10,19,22 style (2) 174:10179:5187:12 187:4191:22192:9340:9341:3,7,18 284:5287:21 276:25352:19 202:13,16,23 take (71) t342:9,24343:22 stripes (4) subject (2) 203:18205:4 176:4179:4181:25 ,344:5,13 345:12 281:25334:12,14 376:12393:19 224:25227:3235:3 184:5 188:4202:8347:15350:18 335:14 Subjects (2) 238:13 260:8 202:11 211:12351:5,9358:2367:5 strong (2) 383:19,25 261:13275:24 216:5220:4223:12367:8,14,19368:24 337:9,17 submit (1) 285:16286:19 231:5234:15369:5,8,10,14 structure (2) 353:23 292:18 297:24 238:19239:9240:8370:16,20,24371:4 270:12354:25 submitted (2) 299:21301:21,23 240:13,25241:2372:9,24374:7 struggling (2) 236:9,10 302:25 303:20 244:19245:5375:24376:19,21 289:5296:8 submitting (1) 311:24312:2 257:21268:24379:17 student (55) 176:14 326:25 328:22 269:3271:7,20

Stephanie's (8) 174:20,21183:24 Subscribed (1) 332:18340:15 272:14,17274:7,

1300:15318:14322:5 184:13,15185:9 394:12 341:19347:17 275:22276:5,8,21

326:7 328:18 358:9 186:16,18224:11 subsequently (1) 349:3357:14,23 277:15,16282:18369:6,13 234:8,9240:3,5,18 313:9 365:14375:13 286:21 302:3,6,7,8

Sterner (4) 240:24,24241:7,22 subtitles (1) 381:19384:6 305:5306:12309:4253:15,16,18255:14 244:17,24245:24 227:16 Susan (1) 309:7313:9316:24 :stimulus (1) 246:2247:10 Success (14) 353:14 317:2320:10,11,14248:17 249:14252:20,23 168:4178:11194:18 sustainable (1) 320:16321:8,20STIPULATED (3) 261:2,15263:22 194:22197:16,20 229:6 330:22335:4,12,17171:3,7,11 264:5 272:2 276:8 198:3,18213:24 sustaining (1) 335:24,24336:7,12

stolen (1) 280:3293:15 214:22353:18 199:19 337:21 350:6352:4386:14 307:11310:3,9,10 396:6,11 397:4 Sutton (42) 356:9 361:2 366:13stop (5) 310:12312:8 successful (2) 168:8,8 170:4,4 375:11,14383:13257:24258:16337:2 322:10 324:9 295:6,7 288:12,13294:5 taken (18)

350:9392:8 329:19,23333:20 succession (5) 295:10,13 298:16 172:25173:16195:14stopped (4) 334:4,13 340:18 229:4232:6,8,15,22 304:23,23310:13 211:9226:20231:6194:9,12311:4 344:20 354:8 suffered (1) 310:17,21312:11 234:24242:13

336:23 355:16356:2396:6 173:8 313:20,24314:8,9 280:4290:22 300:3store (1) 396:11,13 suggestion (1) 314:10,23315:2 300:25312:4316:3247:10 students (38) 365:3 318:10,13339:8,11 337:14344:6353:8stored (5) 186:15209:5217:19 suggestions (2) 340:8 358:23 366:16201:23 247:2,4,6,7 217:25233:17 361:7363:15 369:13,15,23 takes (5)stores (1) 237:6239:16 suing (1) 370:12,16,19,23 174:7188:6233:17201:23 242:12243:5 386:9 372:3,6,13 375:23 244:25 284:17straight (1) 245:18 266:25 suit (1) 378:13 400:3 talk (3)292:20 267:23,24286:25 253:10 Suttons (15) 297:22365:7392: 15strategies (3) 293:24297:3312:3 Suite (1) 292:13 295:8,17 talked (10)184:6189:24229:24 319:14,17,18 170:20 296:16297:12 196:10199:5290:9

strategy (1) 321:20322:9 summer (2) 306:23314:6321:5 290:14291:7228:6 336:17341:5,16,21 314:21366:5 369:23371:4379:3 296:18297:14,17streamlining (1) 342:5 350:6,25 Sunday (3) 379:8,12380:6,15 299:23,24228:17 351:3,9,15 352:4,10 311:16327:18,19 Sntton's (1) talking (3)Street (2) 354:4355:9,22 superior (2) 292:25 188:2299:17305:3169:10170:20 371:21 200:2 296:20 sworn (5) tanks (1)

strike (27) studied (15) supervise (1) 171:12,15172:3 229:8195:5203:13 205:10 179:22,25 180:3,4,5 176:9 394:12399:8 tape (8)

206:10209:16 181:17,23186:17 supervision (1) system (3) 313:3376:21377:2,3218:4231:11242:8 187:2,4190:15 192:25 217:16230:8356:20 377:4,5,6,8262:25263:21 191:16198:10 supplemental (1) systems (6) taped (1)265:2275:20276:6 207:13 300:19 182:10203:8229:5,5 312:24


tape-recording (2) 203:24204:5,9,15 352:19 They'd (1) 308:17313:18376:8,12 205:12,16209:5,12 territory (1) 356:23 314:12,24315:4,6taping (1) 210:2,3211:5 187:25 thing (18) 315:10316:25376:18 224:11244:12 test (5) 181:7 226:23 280:18 318:7322:6,7325:8

taste (1) 264:8,16,20,22,23 272:20 273:17,19 288:17 293:23 332:15335:15188:9 265:4,17278:17 276:12352:7 300:19,21306:13 336:22,24337:7

tanght (62) 299:24308:6 tested (1) 324:23328:19 338:23339:2341 :9184:21191:11192:2 328:16336:25 271:2 338:3339:14 341:13,18344:2,3

192:4197:7201:7 338:16346:9 testified (4) 354:18365:25 345:14348:22204:5,8,19,22205:3 350:10352:14 172:4 259:10 385:5 373:23,24385:12 350:5353:15206:22207:7,8 354:19384:4,5 387:11 392:23 357:19359:12,16216:24219:4 385:7 testify (4) things (42) 360:10 361:16,23230:10 234:17 team (6) 382:24383:6,18 182:19184:19185:18 362:3,18363:20261:23262:20 229:7,7,7246:23,24 392:9 185:21191:19 364:6365:13,18263:13266:19 251:8 testifying (1) 196:4,11 198:9 366:3,4373:14,18268:21 269:18,20 tech (1) 261:5 200:21,24201:2,2 374:3,23 375:14269:23 270:6,8,10 351:8 testimony (7) 206:12,12207:6 376:4,25379:21270:20,21,23271 :5 technical (1) 177:24256:4384:2 209:2216:13 381:9382:14,22288:17289:16,19 256:13 392:2,21 396:3 227:12247:4,13,13 383:10385:23296:20302:17,21 technique (1) 399:8 254:2267:25 386:2,12391:14302:23306:18 195:23 testing (1) 275:18277:3,4,6,10 392:18,19,23307:19308:22 techniques (12) 279:6 296:8,19297:8 393:25394:2309:3336:16,19,21 179:22 180:4,20 tests (5) 298:22 299:25 thinkers (3)336:23337:25 182:11 184:3,4,6 272:19274:17275:3 300:11304:2329:3 203:8,8208:24338:17343:23 185:4186:9196:2 277:11,12 335:14355:23 thinking (11)344:2347:7,9 196:13206:7 text (I) 356:13362:8376:6 208:2228:9,9,10,10 ,

349:19350:7,13,14 technology (14) 182:14 385:13 229:6 299:20 i350:16,17351:2 256:9,11,13 257:6 texts (1) think (158) 301:13 321:16352:21 262:21266:13 182:18 174:4,21 175:5179:6 339:13360:15

teach (36) 270:19313:7 thank (2) 179:11 181:6,20 thinks (I)184:4185:3189:23 323:13351:9,13,19 260:18381:24 182:17,17187:18 266:4

191:13193:25 352:5353:10 Thanksgiving (1) 188:5 189:9,23 third (6)200:18201:13 tell (37) 358:24 190:10194:12 202:14221:13 223:13203:14,16204:2 179:19236:15289:14 theft (I) 196:19198:24 223:17227:17205:4,6,7206:24 289:18290:16 386:10 202:9203:7205:6,7 368:7207:2,3,18,20208:2 294:4,10,18,21 theirs (3) 206:8207:14 third-parties (I)216:4,17222:20 295:6296:9298:2 191:21,21315:13 209:20211:4,20 213:11224:7232:22233:3 300:2302:12,16 theories (4) 213:5215:21 THOMAS (1)233:5234:12 303:17305:13 183:16210:14,24 217:15221:22 170:11264:23270:19 331:7,10355:22 211:2 222:23223:7229:8 thought (43)276:22301 :14 360:8,23362:10,12 theory (10) 231:14233:15 197:17198:8199:6,6308:2 320:25 337:8 365:2,11,13,14 183:17184:16,16 238:25239:3,10 203:5225:18338:13354:18 367:4,8,14,16 187:16210:11,15 240:21242:19,25 245:20251:3,5

teachahle (1) 368:11369:19 210:17,19,22228:5 243:3,9,16,18 253:20289:5,6200:7 370:6371:12373:4 therapeutic (I) 249:11,20253:21 290:19,20294:8,18

teacher (1) telling (8) 185:21 253:25254:12,24 296:20302:13183:24 266:3 296:7 299: 19 therapist (7) 255:10,15256:20 304:7,9305:7306:3

teachers (I) 300:6,10,14,22 289:23303:15319:19 256:21257:15 306:5312:17217:22 311:13 319:25320:14 264:13266:2267:5 324:21,22,25325:4teaches (16) ten (8) 322:24361:19 276:2,2,14279:12 325:14346:11,14184:3210:13,14 179:24183:21 185:10 therapists (2) 286:3290:3,4 347:12348:4360:2

215:25270:11,11 207:18237:9,10 185:17320:10 291:15292:7,21,22 360:15,16362:21270:13,15384:8,8 286:20,21 therapy (14) 293:12,18,18,21 363:9,22364:10384:15,15,19,22 term (5) 179:23182:10183:3 294:20,25295:14 382:4,5 396:23385:4,11 248:15262:13 294:12 183:7,13185:19 295:15296:7,9,11 three (19)

teaching (42) 303:8389:9 228:4,16237:14 297:10 298:8,10,18 198:6207:3218:18180:10 186:21194:17 terms (6) 289:25 290:7,10 299:13 303:21 247:14252:18

195:5,12197:10 219:14252:18261:15 303:18321:16 304:15,16305:10 270:9,20272:2,4,5198:20 202:5,20 263:24281:4 306:4,10,12307:4,7 272:6,11 284:4


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328:3349:19,22 370:4,11371:9,10 180:2,11 233:23 190:10200:11233:13 234:21 262:11391:20392:11,14 371:11,17,17,23 234:21235:7,9,9 265:8320:20 264:3273:3274:23

three-page (2) 372:2,5,16,19 236:11 ,11,15,16,22 337:23 348:9 279:15294:11254:18281:17 376:25377:12 236:25255:13 361:13364:8 , 340:15348:10time (85) 380:13382:22 339:5,17,18340:2,3 373:20375:23 355:6384:6,12171:10179:4183:10 391:14 340:3353:7,9,10 Tuesday (1) 385:3386:8388:15

183:14,18185:12 tomorrow (6) trainers (5) 168:21 389:8186:6 195:4 197:14 343:20382:5,8,15 235:17,23236:4,6,17 turn (7) understanding (34) ,

197:15 198:14 383:14392:15 training (28) 172:13175:12226:15 175:19181:10188:15208:15209:8210:3 Tompkins (2) , 184:2,5196:3203:25 332:5370:16,20,24 188:16,18,25 196:8 . '

211:12,22224:25 169:9170:18 216:6223:19,20 turnaround (4) 202:18203:2212:4251:10259:2 tone (1) 228:14,20,22 229:8 228:7 230:5,6 236:23 218:14220:10 ~

270:21,21,22276:3 386:15 229:12237:3 turned (2) 245:19,19250:25276:23,24277:2,14 Toni (1) 241:19262:23 367:15,20 260:17262:4,5,18277:19,23279:2,10 197:2 268:19278:18 Turning (3) 262:19266:8,10,11 ,279:11282:14,19 tonight (2) 279:9285:7287:15 223:9,17 256:3 270:17272:18288:23289:11 382:10,12 332:8339:22 twice (1) 274:18352:13290:10 291:22 Tony (3) 344:14,19,23345:5 272:24 366:19367:18292:5293:24,25 195:15,20,25 345:13,16 two (24) 372:18380:5295:23306:17 tool (3) trainings (2) 173:2175:17,20,24 387:19388:12,23307:12313:12 203:21210:17385:6 204:2287:12 181:16192:25 understandings (1)314:12315:5,15,18 tools (14) transactional (1) 207:3245:5260:3 188:13315:18,24,25 184:6185:21 189:24 180:4 270:18271:17,19 understands (1)318:16321:7,11,21 190:9206:13 transcription (1) 272:17273:25 387:12337:3,5,7338:4 208:23,24209:5,12 400:8 274:9283:4,15,17 understood (6)340:7343:17345:3 209:18,20,22210:2 transferred (1) 287:7310:5333:15 217:18303:23321:14345:25347:3,6,8 210:5 219:15 334:19,24340:13 354:23 388:11348:20 350:15 top (6) transformational (1) two-hour (2) 393:4351:4 359:14 360:7 223:13,17317:5,10 187:22 207:4282:18 unethical (1)360:19,24,25 352:23 353:5 transmitted (2) two-page (2) 253:24363:20365:6 tort (2) 261:23263:13 221:18281:15 unique (12)373:21374:24 253:10,20 transmitting (1) type (2) 200:6 248:20,22,22381:22,24391:6,17 total (2) 262:9 184:8267:3 355:24384:8,15,20393:8394:6 173:20 174:4 travel (2) types (12) 384:24385:12,14

Timeline (1) totality (1) 292:12293:22 183:15 184:9203:5 387:7395:12 174:22 traveled (3) 210:16227:11 United (5)times (10) touch (1) 180:9 186:20 336:11 230:18231:24 168:2180:10183:4229:19242:15272:17 327:24 traveling (1) 233:19234:3 186:21 192:4

290:15292:7309:4 townhouses (1) 307:25 235:25236:19 University (1)336:12359:13 177:19 trial (1) 289:18 184:11378:6380:24 track (4) 171:10 unresolved (1)

title (1) 285:25286:3 300:20 tried (6) U 253:11286:10 341:22 186:11207:17331:17 Uh-huh (1) Unterriener (15)today (5) Tracy (1) 347:17,25348:20 251:22 173:25 174:2,24174:19175:20338:6 352:24 trip (4) Ultima (4) 175:4176:8,17

384:3391:14 trade (21) 293:11,13311:6,7 216:2,4 222:24,25 222:5224:3225:6told (51) 385:21,24386:4,5,7 troubled (1) unable (2) 239:25241:25199:12253:11 289:4 386:10,13,18,21,25 203:4 252:6358:9 246:23251:15

289:16,20 294:8 387:6,16388:18 true (11) unattended (2) 352:24357:25295:24296:2 389:6,9392:4,12,13 177:20179:6196:19 330:19,20 unusual (3)300:16301:17,18 392:13393:22 230:2 246:25 251:4 uncover (1) 239:13 293:14319:22301:21,22,23302:3 394:2 278:20,24287:4 356:18 uphold (1)302:6303:19318:8 traditional (1) 382:6399:8 undergo (3) 219:24323:5327:25 183:7 try (10) 183:11213:22355:9 upholding (1)331:15339:4 traditionally (1) 187:10208:8213:11 underneath (1) 220:6358:18 359:24 356:10 238:13 312:20 341:14 upline (1)362:22366:21,22 trained (2) 313:5324:8361:15 understand (21) 339:4367:2,10,17368:10 259:2277:9 361:17370:3 187:12188:20199:20 urge (1)368:12369:21,25 trainer (23) trying (11) 203:19205:14 383: 12


use (25) videotapes (I) 304:16305:5306:4 week (5) 326:16345:10177:19187:15194:25 201:20 306:15307:21 183:12202:17309:4 366:24388:4,6,10

195:23199:18 Virginia (8) 323:11,12324:25 309:8311:16 391:22392:17,20201:8,11,12 205:10 181:15182:7,9184:8 325:12327:10 weekend (4) 393:3,6,13,14,22205:15208:23 184:18 190:17,20 328:19,22332:19 206:24207:2288:14 395:3398:3399:7,9219:6,9222:2 190:25 332:20337:8,18 311:16 399:13400:5248:16263:2,17 visit (6) 347:4351:8,10 weeks (7) witnessed (2)265:3,17284:19,22 292:19,21 293:14 368:18 197:12,13,13 198:22 326:13,17320:19340:16 295:16299:8337:2 wanting (2) 198:25282:14,23 woman (I)351:8 384:23 visited (2) 253:17346:7 welcome (I) 250:2

useful (I) 292:2336:24 wants (4) 260:20 women's (2)357:13 visiting (I) 236:14283:16,20 Wellspring (3) 215:4314:24uses (11) 293:20 389:17 168:10 170:9382:19 wonder (1)187:10 196:2 203:21 visits (I) warm (I) well-integrated (2) 339:14

209:4,12 210:2,17 183:12 295:11 272:4 274:18 wonderful (2)239:16240:21 visual (I) Washiugton (I) well-suited (I) 290:19 304:8279:15385:5 188:7 187:3 325:5 wondering (I)

usually (9) voiced (2) wasn't (IS) went (23) 373:22175:17 217:9 233:8 196:20 323:4 202:13,16 279:13 193:21202:17238:7 Woodsmall (1)

272:16300:11,18 voicing (I) 299:21301:18 249:23 259:25 187:3300:20 309:7 264:7 302:25 303:20 276:4 279:8 290:10 word (2)338:17 volleyball (2) 331:4,25338:15 292:7,14,19293:5 262:16384:13

utilized (I) 364:25377:11 350:23361:5 310:4315:10 wordiug (I)211:4 362:20 376:23 319:11321:19 383:15utilizes (I) W 388:12 331:3,23,24336:19 words (6)206:20 WACHENFELD (I) watched (I) 336:20,22365:6 188:14190:14281:8utilizing (I) 170:18 199:7 weren't (4) 341:13368:25196:13 wait (I) watering (I) 276:11 278:22 284:23 369:2

328:4 320:24 363:11 work (34)V waited (I) way (50) we'll (5) 182:24184:8,9

v (3) 328:3 188:6189:13191:10 378:7382:7,11,12 185:16,18186:5,11168:7,14400:3 waiting (I) 192:20 194:21 392:15 190:16,16,20,21,22

vacation (2) 375:15 199:11,19 200:4,25 we're (6) 191:17197:25359:6,14 waived (2) 207:7,16217:10 172:9227:3305:3 198:6199:7,13

vague (2) 171:6254:13 223:2232:18235:7 360:13383:13 217:10 219:7 229:3321:10 345:15 waiving (1) 237:14,17257:2 392:8 230:6 231:23 232:3

valid (2) 227:21 262:9264:6269:13 we've (14) 232:4253:17357:8,10 walk (1) 279:8293:6294:7 211:10 226:7,8 269:13270:13valuable (I) 197:23 296:24298:9,10 238:18,22273:2,2 274:25275:12192:14 walked (I) 299:10 311:11 310:19315:6316:6 278:5303:2,15

value (3) 330:21 320:24335:13 316:21340:12 325:6335:13228:7294:7,9 want (22) 338:21341:10 351:2392:21 worked (16)VanderHoof (I) 172:13180:24199:13 344:4345:3364:3 wbereof(l) 174:14180:6,8,14258:6 201:13211:13 367:19371:3 399:13 184:10185:10

various (I) 227:7,17237:18 372:23 379:5 384:7 white (I) 191:19,21,22192:3218:10 248:17254:15 384:14,18,22385:4 334:15 196:6205:24verbal (I) 297:8305:25 385:10,11 387:23 WlLLIAM(I) 212:24224:14199:3 306:10,11 309:5 390:10 399:11 170:21 249:25255:15

verifiable (I) 318:2 320:24 ways (4) willing (I) worker (1)200:7 327:12352:4368:5 181:6186:10191:23 200:12 289:21versions (I) 383:2391:8 233:10 window (I) workers (4)191:19 wanted (38) website (10) 392:12 231:20,21,23232:3

video (I) 198:16202:9212:3 366:10374:3,4,11 windows (1) working (9)201:17 220:2234:9243:6 378:15,24379:4,20 392:3 187:5211:20212:20videotape (2) 245:17274:2,3,4,7 387:15391:16 winter (2) 212:23230:13313:3344:10 290:4291:18 websites (2) 292:8307:7 303:24325:7,8videotaped (1) 294:10299:21 379:9,12 witness (25) 348:15312:23 302:18,25 303:20 wedlock (I) 170:19172:2175:11 works (2)

295:21 231:19259:4 320: 18 352:13


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workshops (2) yesterday (3) 100 (2) 194:13,14 395:13228:9229:2 172:10 177:7 193:20 169:9 170:20 223 (1)world (11) yesterday's (I) 10019-6708 (I) 2 395:16180:23 181:11 188:3 382:23 170:17 2 (3) 226 (I)

188:4,12 189:3 York (14) 11 (5) 176:25230:14 400:7 395:17298:7,10,11,17 169:13 170:17,17 333:11382:24383:15 2112/03 (2) 23 (6)306:13 192:24193:5,9 383:19,25 396:24397:5 176:23 207:22,25

worldwide (1) 325:24,25326:2 11128/05 (I) 2/2/04 (I) 254:8395:10398:6231:7 390:13,23 399:3,4,5 395:19 395:20 23rd (5)

worried (I) younger (2) 12 (6) 2:06-cv-01051-DM ••• 251:15316:15317:17348:5 367:6373:7 282:14,23382:25 168:3 319:5332:4worth (I) 383:15,19,25 20 (4) 237 (I)173:17 Z 12-point (1) . 179:15,20212:24 395:20

wouldn't (11) Z (I) 391:15 308:21 24 (4)175:24264:9306:16 172:2 12/31103(I) 2000 (4) 211:7,11 218:9

323:6325:20334:6 395:14 288:14289:12291:14 395:12344:16,21 354:16 s 12:45 (I) 353:18 243 (I)354:17355:15 $12,000 (I) 259:3 2001 (36) 395:22

write (I) 175:25 13 (3) 246:25247:3,6,16 25 (6)192:6 $2,160 (I) 367:24368:5,6 257:14261:9,12 221:15,17223:14

writing (7) 317:17 16(10) 273:7275:22,22 351:22 352:2224:6,8239:21 $200 (I) 280:4,20,21 332:6,11 276:5,7,14,22282:4 395:13

265:18275:3,5 309:24 332:14,17333:6,24 283:24285:22,24 250 (I)378:3 $32,500 (5) 398:6 286:5296:12307:4 395:24

written (6) 173:12175:13176:2 16-day (19) 307:8313:14 254 (I)213:25223:20263:15 176:7,18 204: 19,22 240:8 314:21319:4,5 396:3

267:4277:12 $38,500 (2) 272:10,13 273:12 322:17 328:10 26 (4)296:22 172:23 173:8 277:15280:8,23 332:24 340:18 223:4,16367:23

wrong (1) $4,590 (I) 282:10 331:6,8 345:5347:21348:2 395:16249:10 333:8 332:2333:18334:4 349:21 350:20 26th (I)wrote (18) $6,000 (5) 334:8335:24336:3 352:9 172:15185:8,13,15,17 190:4 173:11,16174:7,25 339:25 2002 (9) 260 (I)

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Wyatt (1) 349:10 178 (I) 208:15221:3366:6 332:24333:11187:2 07068 (I) 395:9 373:15374:8 28 (3)

170:10 19th (I) 396:21 237:22259:9395:20Y 07102 (I) 399:13 2005 (2) 281 (1)

Y (I) 170:20 192 (1) 172:15215:7 396:9172:2 07932-1047 (1) 398:6 2006 (2) 29 (3)

Yeager (I) 170:13 1975 (I) 215:20,21 243:19,22395:22186:24 07962-1981 (I) 184:12 2007 (I)

year (11) 170:6 1980s (I) 215:21 3238:9 292:5 296:10 181:13 2009 (4) 3 (4)

306:22,24307:3,6,9 I 1986 (I) 168:21 169:4394:14 367:24368:2,3400:8358:24,25 366:5 1(4) 194:5 399:13 30 (5)

years (20) 261:14382:21,25 1988 (I) 207 (1) 250:11254:8255:3179:15,20,24180:2,6 400:7 194:5 395:10 260:3395:24

180:7185:11192:2 1-10 (1) 1997 (5) 211 (I) 30(h)(6) (I)192:25,25196:7,12 168:16 194:6,8,14 196:24 395:12 175:11207:19211:18 10 (2) 198:5 214 (I) 31 (5)212:20,25247:14 185:13 398:7 1997/1998 (I) 398:6 226:18254:4,5,18249:15272:25 10/31/01 (I) 212:7 22 (4) 396:3369:20 396:17 1998 (2) 178:4,5,8395:9 310 (1)

yellow (7) 10:10 (I) 197:21230:12 22nd (I) 398:6279:22,23280:10,15 169:5 1999 (2) 250:22 312 (1)

281:9282:6,9 221 (1)


398:6316 (1)396:11

32 (4)260:21,23316:7

396:632,500 (1)173:2

33 (4)226: 16,22 281: 12

396:9338 (1)396:1334 (2)316:4396:11349 (1)396:1535 (3)338:19,24396:13

350 (4)287:5,7,9,11357 (1)396:17

36 (2)349:6396:15366 (1)396:19

37 (2)357:15396:17

378 (1)398:7

38 (3)366:17391:21396:19

38,000 (1)175:25

38,500 (1)173:10

382 (1)395:5

39 (2)391:23 396:20392 (3)396:20,23397:3

44 (2)367:25 368:34th (1)197:21

4:00 (1)382:440 (2)207:3 396:2341 (2)391:24397:3

4111 (1)260:25

55 (2)170:20 395:4

5th (1)319:4

5:03 (1)394:6

500 (1)170:13

66,000 (1)172:24

6/9/09 (1)400:460 (1)205:21600 (1)205:1865 (1)170:9

77 (2)223:9398:67,000 (1)286:25

7/1/98 (1)213:167115/02 (1)396:47/21/98 (1)214:9

7/23/02 (1)395:2470s (1)186:19

700 (1)287:3

782,246,32 (1)222:10

880s (5)180:21181:18182:12

182:13185:25

99 (6)168:21 169:4223:12

223:18,25398:69111 (1)347:2490s (1)195:19

96 (1)195:19


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page 168 for the district of new jersey and first .... salzman deposition... · 09/06/2009 · 17,...

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