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SUPREME COURT OF THE STATE OF NEW YORK
NEW YORK COUNTY
OSG, LLC,
Index No. 155983/2023
Plaintiff,
v. FIRST AMENDED COMPLAINT
SPENCER LEE SCHNEIDER, JURY TRIAL DEMANDED
Defendant.
Plaintiff OSG, LLC (“OSG”), by and through its attorneys at Lex Lumina PLLC, for its
complaint against Defendant Spencer Lee Schneider (“Schneider”), hereby alleges, on
knowledge as to its own conduct and otherwise on information and belief, as follows:
NATURE OF THE ACTION
1. This is an action brought against Schneider for presumed, actual, and punitive
damages stemming from Schneider’s defamation per se in a widespread, malicious campaign to
harm OSG through prolific publications and statements falsely branding OSG as a “cult” and a
criminal organization engaged in “trafficking” and “forced labor.”
PARTIES
2. Plaintiff OSG is a New York limited liability company with its principal place of
business located in New York, New York.
3. Defendant Schneider is an individual residing in the State, County, and City of
New York, where he also has been a practicing attorney for more than 30 years. Schneider also
owns a home in East Hampton, New York.
JURISDICTION AND VENUE
4. This Court has personal jurisdiction over Schneider under CPLR § 301 because
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Schneider is a resident and domiciliary of the State of New York.
5. Venue is proper in this Court pursuant to CPLR § 503(a) because Schneider
resides in New York County.
FACTUAL ALLEGATIONS
Background Regarding OSG
6. OSG is a spiritual organization founded by Alex and Sharon Gans Horn that has
been primarily based in New York City for more than 40 years. OSG espouses the teachings and
practices of the early 20th Century Greek-Armenian mystic and spiritual teacher George
Gurdjieff and his protégé, P.D. Ouspensky, as well as other teachings and practices of the
world’s great wisdom traditions and philosophies.
7. OSG is comprised of an educated and sophisticated membership, including
lawyers, doctors, artists, craftsmen, writers, educators, scientists, actors, hedge fund managers,
and real estate developers. While it is not a requirement for OSG membership, most of OSG’s
members have at least a college education; many attended the nation’s premier universities and
are leaders in their respective fields and professional communities.
8. OSG members pay monthly tuition for OSG classes, which are held on one or two
evenings each week. Prospective OSG members are invited to attend a month of classes for free
or at a reduced rate before deciding whether to continue with membership.
9. Sharon Gans Horn was the primary teacher of OSG classes until her death in
2021, with OSG classes also being led by other teachers. Most OSG teachers began as OSG
members and were invited to become teachers after some time based on their aptitude and
demonstrated understanding of the principles of Gurdjieff’s teachings.
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10. In OSG classes, teachers lead discussions of the texts selected for study, from
Ouspensky’s In Search of the Miraculous, which expounds Gurdjieff’s esoteric teachings, to
classic religious, spiritual, and philosophical texts such as the Bible, the Bhagavad Gita, the
Odyssey, and Shakespeare’s works. OSG members also share their personal experiences, hopes,
fears, goals, and aims related to their life in the world and their inner spiritual inquiry, and they
participate in exercises designed to challenge their fundamental assumptions and bring
awareness to their unconscious, egoic, and self-limiting behaviors and beliefs.
11. OSG members are not required to follow, embrace, or worship any theology,
doctrine, or dogma; rather, OSG’s classes emphasize questions over answers and promote
verification of the methods, principles, and ideas taught by practical application and personal
experience rather than beliefs.
12. One of OSG’s fundamental teachings and practices is Gurdjieff’s “Three Lines of
Work.” The “First Line of Work” consists of each OSG member’s work on his or her own
spiritual evolution through study, daily practices such as meditation or prayer, and participation
in exercises designed to aid the individual’s evolution and spiritual awakening. The “Second
Line of Work” consists of service to one’s neighbor, i.e., fellow OSG members, which benefits
both the individual being served and the one performing the service. The “Third Line of Work”
consists of service to the community or organization (in this case, OSG), which benefits the
whole as well as the individual performing the service. OSG members make a commitment to
participate fully in all Three Lines of Work (collectively, the “Gurdjieff Work”) as a condition of
membership in OSG; indeed, the Gurdjieff Work is the essence of OSG’s raison d’être.
13. OSG has other basic membership rules that are explained to members when they
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join; namely, OSG members are required to be regular and punctual in their attendance of
classes; to participate meaningfully in class and the Gurdjieff Work; and to keep confidential
their membership in OSG and everything discussed in class, as well as to avoid fraternization
with other OSG members in most circumstances outside of class and OSG events, in order to
protect OSG members’ privacy and to maintain the integrity of OSG as a vehicle for deep
emotional and spiritual work.
14. OSG also offers occasional, optional retreats to OSG members. Attendance at
OSG retreats is not a condition of membership in OSG; rather, some OSG members elect to
attend the retreats—and pay to do so—to deepen their spiritual study, to enjoy fellowship with
other OSG members, and to spend time in nature and working with their bodies. For many years,
for instance, OSG held an annual two-week summer retreat in Montana. On that retreat,
members would spend their time alternating between physical labor, such as gardening, cooking,
carpentry, painting, or building projects, reading and discussing spiritual texts and the Gurdjieff
Work, and celebrating with food, wine, music, and dancing. For many OSG members with
white-collar careers in fields like banking and law, such OSG retreats provide rare opportunities
to do physical work with their hands—the challenges and rewards of which are extolled by
Gurdjieff as well as ancient teachings and wisdom traditions.
15. OSG members are not required or requested to cut themselves off, or isolate
themselves, from their family and friends outside of OSG. While OSG members sometimes date
and marry each other, OSG members maintain careers and personal lives outside of OSG and
participate in OSG to the extent that they choose. In fact, Gurdjieff’s “Fourth Way” school
espoused by OSG requires that each individual contribute to society at large and strive to
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engender a strong and healthy personal life, including career, family, and spiritual practice of
choice. OSG members return to their homes after OSG classes, events, and retreats in the same
manner that members of any spiritual group (e.g., a Christian church, Jewish synagogue, or
Buddhist sangha) do after attending their respective groups’ services, classes, events, and
retreats.
16. OSG members are sometimes encouraged, but never required, to identify and
invite other individuals for membership in OSG.
17. OSG members are free to leave OSG at any time. Many long-term OSG members
have left OSG for extended periods of time for various reasons (e.g., new marriages, the birth of
children, relocation, or work commitments) and resumed their OSG membership months or years
later.
18. OSG does not require as a condition of membership that members shun
individuals who leave OSG. In fact, when OSG members leave the organization on positive
terms, OSG informs them that they are welcome to be in touch and to return to OSG at any time.
Former OSG members sometimes reach out to current OSG teachers and members for support in
their lives and spiritual journeys outside of OSG, and OSG teachers and members have happily
and unconditionally provided such former OSG members with such support.
19. OSG additionally organizes opportunities and encourages its members to perform
service and provide charity to communities outside of OSG. For example, OSG members have
volunteered with Habitat for Humanity to build houses for those in need; they have provided
clothing, toys, and other needed items to the Family Child Care Network in the Bronx; they
voluntarily installed a new kitchen, repainted, and fixed water leaks at a Lutheran church in New
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York City where a children’s school is maintained; they have provided food, clothing, toiletries,
and other necessities and worked in soup kitchens at Christian churches in Manhattan and
Queens; they have organized clothing drives for the unhoused, toy drives for underprivileged
children, and winter coat donations for immigrants; and they have performed theater and music
for children without access to arts programs. After attending a dance festival in the country of
Georgia, Gans Horn and other OSG members began sponsoring an orphanage there, with some
returning to Georgia to help build housing for the children and others sending money, clothes,
and gifts to them in the following years.
Schneider’s History with OSG
20. Schneider voluntarily joined OSG in or around 1989 after attending a free month
of classes. At the time, he was 29 years old and an attorney living in New York City, where he
practiced law full time and played in a bar band on weekends.
21. Schneider was a member of OSG for approximately 23 years, and for much of
that time he held leadership positions in the organization and was part of the organization’s inner
circle. Schneider became so close to Alex and Sharon Gans Horn that he was invited to serve as
one of Alex Horn’s caretakers in 2007 when Horn was dying of cancer, alongside Horn’s family
members and other OSG leaders.
22. Schneider maintained an active and successful law practice as a litigator in New
York during his 23 years as a member of OSG. He appeared in New York state and federal trial
and appellate courts in dozens of cases, representing sophisticated clients such as Merrill Lynch.
23. Schneider soured on OSG and Gans Horn, and became hostile to them and other
OSG members, following the breakdown of both his marriage to another OSG member and his
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relationship with one of his top legal clients, also an OSG member.
24. Schneider attended his last OSG classes in December 2012, but he had largely
ceased participating in OSG by that point. While Schneider attended OSG’s annual Christmas
party that month, he did not help to plan or set up for the party or volunteer to serve as a DJ at
the party as he had in years past. Schneider left OSG in or around December 2012 by simply
ceasing to pay tuition and not returning to class.
25. For the last 10 years since leaving OSG, Schneider has bedeviled the organization
and its members through a defamatory blog that he publishes at www.cultrevolt.com (the
“Blog”); with numerous harassing phone calls, letters, emails, and text messages to OSG
members, including at their places of business; by giving interviews for false tabloid press stories
and other media about OSG; by occasionally showing up outside of OSG’s meeting space in
Manhattan to harangue members as they entered or exited class; and by contacting OSG’s
landlord to try to get OSG kicked out of its meeting space in Manhattan.
26. OSG and its members turned the other cheek for a decade in the face of
Schneider’s defamation and harassment. But last year, Schneider dramatically and inexcusably
upped the ante. On or around July 5, 2022, Schneider widely published in hardcover format a
purported memoir about his time with OSG titled Manhattan Cult Story: My Unbelievable True
Story of Sex, Crimes, Chaos, and Survival (the “Book”), falsely and maliciously portraying OSG
as a “cult” and a criminal organization engaged in “trafficking” and “forced labor.” Schneider
republished the Book in audio CD format through a different publisher, Dreamscape Media, on
August 9, 2022. Schneider has actively promoted the Book and repeated its false and defamatory
statements in numerous live events, media interviews, and other publications over the last year.
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27. A few months after his Book was published, in December 2022 Schneider filed a
sham federal lawsuit against OSG falsely alleging that he was a victim of human trafficking and
forced labor by OSG for the 23 years he was a member (and leader) of the organization. The sole
purposes of Schneider’s lawsuit are to harm OSG, to boost his public profile as an author and
purported “survivor,” and/or to try to extract money from OSG and the estate of Sharon Gans
Horn following her death in 2021. As Schneider intended and facilitated, the lawsuit was
reported in the press, including in the New York Law Journal.
28. Schneider’s obsessive, outrageous, malicious, and defamatory vendetta against
OSG has left it with no choice but to file this action to defend its and its members’ rights and
reputations and to put an end to Schneider’s relentless chicanery.
CAUSE OF ACTION
(Defamation Per Se)
Schneider’s Maliciously False and Defamatory Book and Attendant Media Campaign
29. On or about July 5, 2022, Schneider published or caused to be published in
hardcover format his Book, which is premised on and replete with false statements of and
concerning OSG that are designed to injure OSG by falsely portraying it as a dangerous cult and
a criminal organization engaged in human trafficking and forced labor. On August 9, 2022,
Schneider republished or caused to be republished the Book in its entirety in audio CD format.
Specifically, Schneider made the following maliciously false and defamatory material
statements1 of and concerning OSG in his Book:
…we endured (and witnessed) mental, sexual, and physical abuse, forced labor,
swindling of our money, breaking up of our families, and systematic terrorizing.
Some students conspired with her [OSG’s leader, Sharon Gans Horn] to break the
1
This is by no means a comprehensive or exhaustive list of false statements in the Book, which are too numerous to
catalogue herein. OSG sets out here only a selection of salient and material false statements that have injured OSG.
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law. Sharon left her students in shambles: poorer, broken down, beaten up, and
hollowed out.
We would do anything for her. Some would have gone to jail or killed for S, our
teacher, Sharon Gans.
We took an oath of absolute secrecy. We never even told our families who we
really were. We thought nothing of lying. We understood that disclosure would
put in us [sic] grave danger.
…you’d never guess our secret lives, how we lived in silent terror and fervor and
suffering.
During those years, I had nothing else but School—it was my world.
This is the story of how I got entangled in School, the twenty-three years I spent
there, how I narrowly escaped, and how I survived.
…[recruiting] was mandatory, or we’d be forced to leave School, we were told.
Sharon or Fred [OSG leaders] wanted us to start to keep our families at arm’s
length. Sharon used to paraphrase (and misuse) Christ’s injunction to: “hate his
own father and mother and wife and children and brothers and sisters.” She said
that one needed to separate from one’s family to become real students of the
Work.
Departures were like deaths to those who remained. For one, we would never see
them again in class and we were forbidden from contacting them or taking their
calls.
When people left, they were dead to us; and in the event we saw them on the
street we were to run the other way; if they contacted us, we were to shut it down;
they were killer zombies. Obviously, in no circumstances were we to contact
them.
Like Phil, Danny is also a gay man who was married off by Sharon to a woman in
class.
My “self” had been ground away, snuffed out during the past twenty-three years.
My dignity, self-esteem, pride, and self-reliance were distant memories. I was
unable to discern reality…
I didn’t realize School was really a cult until I took the step, out the door…In the
topsy-turvy Gans world, lies are used to keep people in. She drills this into people
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to become fearful of leaving, to be fully dependent upon her, and to doubt
oneself…She didn’t invent this method of abuse, but she is very good at it.
[OSG’s leader, Gans Horn] Was openly bigoted against people of color and
homosexuals. Was a liar and sociopath. Would randomly throw students out of
class. Forced students to work on personal building projects in unsafe conditions
and for free. Forced students to cook all her meals.
I have been able to get at least a few people out of School who happened upon my
blog. I kept in touch with other survivors…I learned how to write about the cult.
I know that former members are understandably fearful and ashamed of speaking
out about anything involving School, but I hope that my story will encourage
them to come out and confront their predators.
There were dozens of construction projects where members were coerced into
working in dangerous conditions for free. Sharon’s and Alex’s apartments were
built with forced labor; the spaces where we met to hold meetings were built with
forced labor; Sharon’s home in the Hamptons was renovated with forced labor;
Sharon coerced students to renovate homes of her favored students.
Sharon had many homes and properties—in the Hamptons, Montana,
Westchester, Mexico, and Manhattan—all of which were used exclusively by
Sharon and her family.
It was a weekend getaway for Sharon’s cult, and it was completely for her profit.
At best, [OSG’s leader] Sharon had a passing knowledge of the Gurdjieff system.
We were forbidden to read any biographies about Gurdjieff.
Other than getting paid by people to ruin their lives, Sharon held no job or
occupation.
Of all her crimes and immorality, Sharon outdid herself when it came to children.
Her depravity knew no limits. There is no greater sadism than to harm families
and children, and Sharon loved it.
[OSG’s leaders] Sharon and Alex wanted their followers to stay close and
encouraged intra-School marriages and for couples to have as many children as
possible. This is standard in all kinds of cults and closed communities. Even if
one parent leaves, the children are essentially held hostage, and this has kept
many people from speaking out about School.
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The long arm of Sharon Gans reaches beyond the grave, covering the mouths of
current and former victims. It’s no different than the pedophile priests or coaches
who can keep their victims quiet. Survivors suffer shame, embarrassment, self-
blame, and a perceived stigmatization of having been duped by a cult.
30. While Schneider refers to OSG as “School” throughout his Book, School is easily
identifiable to readers as OSG due to Schneider’s identification in the Book of OSG’s founders
and other leaders by their real names, his statements identifying OSG on his Blog and in
widespread publications, media, and events where he promotes and has promoted his Book and
personal story, and his federal lawsuit, reported in the press, falsely alleging that he was a victim
of trafficking and forced labor by OSG and its leaders. Additionally, through these and other
statements set out below, Schneider falsely and maliciously portrayed OSG as a cult of
personality revolving around the whims of its founder, Sharon Gans Horn, conflating Gans Horn
and OSG such that his false statements about Gans Horn are imputed to OSG.
31. At the end of Schneider’s Book, he lists “Nine Telltale Signs You’re in a Cult,”
such as “Former members are ostracized and denigrated”, “The group isolates you from your
friends and family”, and “The group discourages you from thinking for yourself.” These
statements are false and defamatory insofar as Schneider clearly and intentionally implies that
they are objective factors that apply to OSG and show that it is a cult.
32. Schneider made similar and additional false and defamatory statements of and
concerning OSG in a widespread campaign to promote the Book after its publication, including:
a. On his personal website at www.spencer-schneider.com (the “Website”),
Schneider published a page promoting the Book that contains the following false
and defamatory statements of and concerning OSG:
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“It didn’t look like a cult. I was relieved. Nobody was in black robes
chanting. No kids running around in rags with faraway gazes. Just a
bunch of young professionals––hedge funders, doctors, entrepreneurs,
lawyers––in a secret loft in Tribeca. They looked, I realized, a lot like
me,” says Spencer Schneider. “I had no way to possibly know they were
brainwashed––hollowed out souls––under the clutches of a leader every
bit as twisted and commanding as Jim Jones.”
This is Schneider’s true story of how he got entangled in a cult known
only as “School,” why he stayed, and how––impossibly––he got out after
twenty-three years.
b. In a video that Schneider embedded on his Website page promoting the
Book, Schneider makes the following false and defamatory statements of and
concerning OSG: that the organization that Schneider spent 23 years in is a “cult”;
that his Book is a “a deep dive, a memoir, in which I try to bring a reader along on
my journey into a cult”; and that “I also recount the kind of abuse that I
witnessed, suffered, and go into the tales and stories about how very intelligent
and highly educated and successful people such as doctors, hedge fund managers,
lawyers, Ivy-educated folks, were radicalized by a leader who was every bit as
demented as Jim Jones.”
c. Schneider published or caused to be published on the www.amazon.com
page where the Book is advertised and sold the following false and defamatory
statements of and concerning OSG:
Right under the noses of neighbors, clients, spouses, children, and
friends, a secret society, simply called School—a cult of snared
Manhattan professionals—has been led by the charismatic, sociopathic
and dangerous leader Sharon Gans for decades. Spencer Schneider was
recruited in the eighties and he stayed for more than twenty-three years as
his life disintegrated, his self-esteem eroded, and he lined the pockets of
Gans and her cult.
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Cult members met twice weekly, though they never acknowledged one
another outside of meetings or gatherings. In the name of inner
development, they endured the horrors of mental, sexual, and physical
abuse, forced labor, arranged marriages, swindled inheritances and
savings, and systematic terrorizing. Some of them broke the law. All for
Gans.
“During those years,” Schneider writes, “my world was School. That’s
what it’s like when you’re in a cult, even one that preys on and caters to
New York’s educated elite. This is my story of how I got entangled in
School and how I got out.”
At its core, Manhattan Cult Story is a cautionary tale of how hundreds of
well-educated, savvy, and prosperous New Yorkers became fervent
followers of a brilliant but demented cult leader who posed as a teacher
of ancient knowledge.
d. Schneider repeated the false and defamatory statement that OSG is a
dangerous cult, based on objective criteria, that abuses its members and engages
in forced labor at Book reading and signing events on or around July 7, 2022, at
Sag Harbor Bookstore and BookHampton Bookstore; at a Book launch event on
or around July 13, 2022, at The North Bar in Manhattan; at a Book reading and
signing event on or around August 3, 2022, at Amagansett Public Library; on or
around August 12, 2022, at East Hampton Library; and at a November 2022 event
for his Book at Shelter Island Public Library, the video of which was published on
or around November 22, 2022, on YouTube by Schneider’s intention and design,
with the caption, “This dialogue is about [Schneider’s] 23 years spent in a secret
cult, which preyed upon highly educated, young professionals, and how he
managed to escape.”
33. By Schneider’s intention and design, numerous media outlets reported on
Schneider’s Book following its publication and repeated Schneider’s false and defamatory
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statements that OSG is a dangerous cult that revolved around the whims of Gans Horn and
abused, coerced, and swindled its members.
34. On or around July 9, 2022, as Schneider intended and facilitated, the New York
Post published an article, titled “Odyssey Study Group cult still going strong after death of
charismatic leader Sharon Gans,” that identified Schneider as a former OSG member and
reported on his Book, repeating Schneider’s maliciously false and defamatory statement that
OSG is a cult. Schneider made additional maliciously false and defamatory statements about
OSG that were published in the article, as follows:
“The whole thing is a pyramid scheme and a hoax,” said Spencer Schneider, a
former OSG member who has written “Manhattan Cult Story: My Unbelievable
True Story of Sex, Crimes, Chaos and Survival,” a tell-all book out now about the
cult. “It’s a long haul hoax and Sharon was a genius at going after vulnerable
people with money.”
35. On or around July 12, 2022, Schneider appeared on Dan’s Papers’ “Who’s Here
in the Hamptons” podcast to discuss and promote his Book. Schneider repeated maliciously false
and defamatory statements from his Book, including that OSG is a dangerous cult that abuses
and coerces its members, that OSG had “complete control” over Schneider’s life, and that OSG
forced its members to perform labor. The YouTube page where a video of the interview was
published states that Schneider “is the only former member of the Odyssey Study Group cult,
also known as the ‘School’ to publish about his experiences in the cult — he was a member of
School’s inner circle for 23 years.”
36. Also on or around July 12, 2022, Schneider appeared on an episode of the Growth
Now Movement podcast in which he discussed and promoted his Book. Schneider repeated
maliciously false and defamatory statements from his Book, including that OSG is a dangerous
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cult that preys on the vulnerable and abuses and coerces its members. Schneider additionally
caused the following false and defamatory statements to be published on the episode’s YouTube
page:
But soon, he found himself trapped in one of the nation’s most secretive and
abusive cults. In the name of personal development, hundreds endured decades of
sexual and physical abuse, forced labor, arranged marriages, swindled savings and
inheritances, and systematic terrorizing. Some of them broke the law. All for their
charismatic and demented leader Sharon Gans.
37. On or around July 23, 2022, by Schneider’s intention and design, the New York
Post published an article titled, “NYC cult bought $925K upstate retreat, uses ‘forced labor’ to
dig ditches,” which repeated false and defamatory statements from Schneider’s Book that OSG is
a cult that coerces its members and uses forced labor. Schneider made additional false and
defamatory statements about OSG that were published in the article, as follows:
“It’s very heavy mind control,” Schneider told The Post Wednesday. “I know it’s
hard to believe, but [members] just don’t look them up. They’re afraid to look. If
you do look them up and tell someone about it, you are punished and berated in
front of the group.”
38. Schneider gave the same maliciously false and defamatory statement about OSG
set out in paragraph 37 in an article in The Mirror published on July 26, 2022, titled “Inside cult
forcing recruits to dig ditches at retreat as leaders live high life,” which also repeated false and
defamatory statements from Schneider’s Book in stating that OSG is a cult that coerces its
members and uses forced labor, as Schneider intended and designed.
39. Also on or around July 26, 2022, Schneider appeared in an episode of Milling
About with Robin Milling, titled “Milling About with ‘Manhattan Cult Story’ Author Spencer
Schneider,” to discuss and promote his Book. Schneider repeated maliciously false and
defamatory statements from his Book, including that OSG is a dangerous cult that preys on the
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vulnerable and abuses and coerces its members.
40. On or around August 2, 2022, Schneider appeared on an episode of MetroFocus
on PBS to discuss and promote his Book. Schneider repeated maliciously false and defamatory
statements from his Book, including that OSG is a “sinister cult” that abuses, coerces, and harms
its members.
41. On or around August 11, 2022, as Schneider intended and facilitated, The East
Hampton Star published a review of Schneider’s Book, titled “We Don’t Need No Education,”
that repeats Schneider’s maliciously false and defamatory statements that OSG is an abusive,
coercive cult and pyramid scheme that preys on its members.
42. On or around February 27, 2023, as Schneider intended and facilitated, the Daily
Mail published an article, titled, “Adam Driver’s mother-in-law, 67, ‘was a teacher at NYC cult
the Odyssey Study Group during the early 2000s’ - as it’s accused of ‘emotional abuse,
pressuring members to commit infidelity, child abuse and forced labor’,” based on and repeating
the maliciously false and defamatory statements contained in Schneider’s Book that OSG is a
“cult” that subjects its members to “forced labor.” Schneider made the following additional false
and defamatory statements of and concerning OSG that were published in the article:
[OSG’s leader, Gans Horn] had gay people marry straight people, because she
believed in gay conversion which of course doesn’t exist, and she would also
break up marriages.
I didn’t realize how bad it was until I was about 10 or 15 years in and I finally
saw how mercilessly [OSG’s leader, Gans Horn] treated people, and how they
weren’t trying to improve anyone’s lives but instead hurt them.
But I couldn’t get out because of how wrapped up my whole life was in that
group.
I was very afraid of leaving.
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Schneider’s Maliciously False and Defamatory Newsweek Article
43. On or around October 19, 2022, Schneider wrote and published or caused to be
published an article in Newsweek titled, “I Was in an Elite Manhattan Cult for 23 Years” (the
“Article”).
44. The Article contains numerous maliciously false and defamatory statements of
and concerning OSG echoed in Schneider’s Book, namely: repeated statements that OSG is a
cult; that OSG members “would normally do anything without question”; that “[s]eniority
[among OSG teachers] was determined by loyalty to Sharon”; that OSG members “worked night
and day on construction projects” and were “too afraid not to do manual labor”; that OSG
“drained [Schneider] of [his] money”; that Schneider’s OSG “friendships and…marriage would
have to end, per School rules” if he left OSG; that Schneider stayed in OSG out of “fear”; that
some OSG members “lost their savings by being forced to turn over money to [Sharon Gans
Horn] for her personal use”; and that Schneider’s “mind had been poisoned by the cult…”
45. The Article, like Schneider’s Book, refers to “School” rather than to OSG by
name, but School is easily identifiable as OSG for the reasons set out in paragraph 30, above.
Schneider’s Maliciously False and Defamatory Sham Federal Lawsuit
46. On or around December 16, 2022—a few months after publishing and
republishing his Book and approximately ten years after he left OSG—Schneider filed a federal
lawsuit against OSG and several of its leaders in the Eastern District of New York (the
“Complaint”) that is based solely on knowing, malicious, material falsehoods, as evidenced by
the self-contradictory allegations on the face of the Complaint and prior statements by Schneider
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that contradict his claims.2 The Complaint thus is a complete sham. Schneider’s statements in the
Complaint purporting to allege claims for “trafficking” and “forced labor” against OSG and its
leaders under the Trafficking Victims Protection Act were made maliciously by Schneider for
the sole purpose of defaming OSG under the guise of litigation and its attendant privilege. A
copy of the Complaint is annexed hereto as Exhibit A and made a part of this complaint.
47. Schneider’s claims for trafficking and forced labor set out in the 51-page
Complaint are entirely based on knowing and material falsehoods, and thus the Complaint in its
entirety is false, defamatory per se, and injurious to OSG.
48. In a nutshell, Schneider falsely and maliciously alleged in paragraph 1 of the
Complaint that OSG and certain of its leaders “collectively operated as a cult and used a scheme,
pattern and plan involving coercive and manipulative techniques that caused SCHNEIDER to
perform thousands of hours of unpaid labor and services by instilling in him a fear that if he did
not perform such labor and services, he would endure serious harm, including psychological,
financial, and reputational harm and other non-physical harm.”
49. Schneider falsely and maliciously alleged in paragraphs 83-123 of the Complaint
that OSG is a “cult” based on its alleged use of objective “tools” identified by cult experts,
including the use of secrecy, isolation, indoctrination, subjugation, shame and humiliation,
emotional abuse and degradation, sleep deprivation, intolerance for dissent, gaslighting,
collateral, and economic abuse (collectively, the “Tools”) “to obtain and maintain control over
individuals,” including Schneider.
2
On September 13, 2023, Magistrate Judge Scanlon stayed all discovery in that case pending resolution of OSG’s
motion to dismiss the Complaint, noting on the record that “defendants have now formally raised before the district
court serious challenges to the theory of the plaintiff’s case as well as to the facts alleged” and that “there are serious
constitutional issues here and those are both the 1st Amendment free exercise and association…”
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50. In fact, Schneider knew or should have known before he filed the Complaint that
OSG does not and did not use the alleged Tools of cults “to obtain and maintain control over”
OSG’s members, including Schneider, and that OSG in fact is not a cult under the alleged expert
criteria set out by Schneider. Schneider made these allegations maliciously and solely for the
purpose of defaming OSG.
51. Some of the other maliciously false and defamatory material allegations that
Schneider made in the Complaint to support his knowingly false and defamatory assertion that
OSG is a cult include:
[OSG] attempted to maintain, and maintained, absolute control over the personal
and professional lives of many of the Students [including Schneider].
During Class and other events orchestrated by the Organization, the Organization
and the Inner Circle used a classic combination of coercive and manipulative
tactics to isolate SCHNEIDER from his family, friends and business colleagues,
indoctrinate SCHNEIDER in the protocols of the Organization, and ultimately to
wholly enmesh SCHNEIDER’s livelihood with that of the Organization.
By and through the design of the Organization and the Inner Circle, SCHNEIDER
distanced himself from his immediate family and lost substantive contact with
close friends from outside the Organization.
By and through the design of the Organization and the Inner Circle,
SCHNEIDER’s family and previously-close friends were replaced by
relationships with other Students of the Organization.
By and through the design of the Organiza
Preview
FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY OSG, LLC, Index No. 155983/2023 Plaintiff, v. FIRST AMENDED COMPLAINT SPENCER LEE SCHNEIDER, JURY TRIAL DEMANDED Defendant. Plaintiff OSG, LLC (“OSG”), by and through its attorneys at Lex Lumina PLLC, for its complaint against Defendant Spencer Lee Schneider (“Schneider”), hereby alleges, on knowledge as to its own conduct and otherwise on information and belief, as follows: NATURE OF THE ACTION 1. This is an action brought against Schneider for presumed, actual, and punitive damages stemming from Schneider’s defamation per se in a widespread, malicious campaign to harm OSG through prolific publications and statements falsely branding OSG as a “cult” and a criminal organization engaged in “trafficking” and “forced labor.” PARTIES 2. Plaintiff OSG is a New York limited liability company with its principal place of business located in New York, New York. 3. Defendant Schneider is an individual residing in the State, County, and City of New York, where he also has been a practicing attorney for more than 30 years. Schneider also owns a home in East Hampton, New York. JURISDICTION AND VENUE 4. This Court has personal jurisdiction over Schneider under CPLR § 301 because 1 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 Schneider is a resident and domiciliary of the State of New York. 5. Venue is proper in this Court pursuant to CPLR § 503(a) because Schneider resides in New York County. FACTUAL ALLEGATIONS Background Regarding OSG 6. OSG is a spiritual organization founded by Alex and Sharon Gans Horn that has been primarily based in New York City for more than 40 years. OSG espouses the teachings and practices of the early 20th Century Greek-Armenian mystic and spiritual teacher George Gurdjieff and his protégé, P.D. Ouspensky, as well as other teachings and practices of the world’s great wisdom traditions and philosophies. 7. OSG is comprised of an educated and sophisticated membership, including lawyers, doctors, artists, craftsmen, writers, educators, scientists, actors, hedge fund managers, and real estate developers. While it is not a requirement for OSG membership, most of OSG’s members have at least a college education; many attended the nation’s premier universities and are leaders in their respective fields and professional communities. 8. OSG members pay monthly tuition for OSG classes, which are held on one or two evenings each week. Prospective OSG members are invited to attend a month of classes for free or at a reduced rate before deciding whether to continue with membership. 9. Sharon Gans Horn was the primary teacher of OSG classes until her death in 2021, with OSG classes also being led by other teachers. Most OSG teachers began as OSG members and were invited to become teachers after some time based on their aptitude and demonstrated understanding of the principles of Gurdjieff’s teachings. 2 2 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 10. In OSG classes, teachers lead discussions of the texts selected for study, from Ouspensky’s In Search of the Miraculous, which expounds Gurdjieff’s esoteric teachings, to classic religious, spiritual, and philosophical texts such as the Bible, the Bhagavad Gita, the Odyssey, and Shakespeare’s works. OSG members also share their personal experiences, hopes, fears, goals, and aims related to their life in the world and their inner spiritual inquiry, and they participate in exercises designed to challenge their fundamental assumptions and bring awareness to their unconscious, egoic, and self-limiting behaviors and beliefs. 11. OSG members are not required to follow, embrace, or worship any theology, doctrine, or dogma; rather, OSG’s classes emphasize questions over answers and promote verification of the methods, principles, and ideas taught by practical application and personal experience rather than beliefs. 12. One of OSG’s fundamental teachings and practices is Gurdjieff’s “Three Lines of Work.” The “First Line of Work” consists of each OSG member’s work on his or her own spiritual evolution through study, daily practices such as meditation or prayer, and participation in exercises designed to aid the individual’s evolution and spiritual awakening. The “Second Line of Work” consists of service to one’s neighbor, i.e., fellow OSG members, which benefits both the individual being served and the one performing the service. The “Third Line of Work” consists of service to the community or organization (in this case, OSG), which benefits the whole as well as the individual performing the service. OSG members make a commitment to participate fully in all Three Lines of Work (collectively, the “Gurdjieff Work”) as a condition of membership in OSG; indeed, the Gurdjieff Work is the essence of OSG’s raison d’être. 13. OSG has other basic membership rules that are explained to members when they 3 3 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 join; namely, OSG members are required to be regular and punctual in their attendance of classes; to participate meaningfully in class and the Gurdjieff Work; and to keep confidential their membership in OSG and everything discussed in class, as well as to avoid fraternization with other OSG members in most circumstances outside of class and OSG events, in order to protect OSG members’ privacy and to maintain the integrity of OSG as a vehicle for deep emotional and spiritual work. 14. OSG also offers occasional, optional retreats to OSG members. Attendance at OSG retreats is not a condition of membership in OSG; rather, some OSG members elect to attend the retreats—and pay to do so—to deepen their spiritual study, to enjoy fellowship with other OSG members, and to spend time in nature and working with their bodies. For many years, for instance, OSG held an annual two-week summer retreat in Montana. On that retreat, members would spend their time alternating between physical labor, such as gardening, cooking, carpentry, painting, or building projects, reading and discussing spiritual texts and the Gurdjieff Work, and celebrating with food, wine, music, and dancing. For many OSG members with white-collar careers in fields like banking and law, such OSG retreats provide rare opportunities to do physical work with their hands—the challenges and rewards of which are extolled by Gurdjieff as well as ancient teachings and wisdom traditions. 15. OSG members are not required or requested to cut themselves off, or isolate themselves, from their family and friends outside of OSG. While OSG members sometimes date and marry each other, OSG members maintain careers and personal lives outside of OSG and participate in OSG to the extent that they choose. In fact, Gurdjieff’s “Fourth Way” school espoused by OSG requires that each individual contribute to society at large and strive to 4 4 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 engender a strong and healthy personal life, including career, family, and spiritual practice of choice. OSG members return to their homes after OSG classes, events, and retreats in the same manner that members of any spiritual group (e.g., a Christian church, Jewish synagogue, or Buddhist sangha) do after attending their respective groups’ services, classes, events, and retreats. 16. OSG members are sometimes encouraged, but never required, to identify and invite other individuals for membership in OSG. 17. OSG members are free to leave OSG at any time. Many long-term OSG members have left OSG for extended periods of time for various reasons (e.g., new marriages, the birth of children, relocation, or work commitments) and resumed their OSG membership months or years later. 18. OSG does not require as a condition of membership that members shun individuals who leave OSG. In fact, when OSG members leave the organization on positive terms, OSG informs them that they are welcome to be in touch and to return to OSG at any time. Former OSG members sometimes reach out to current OSG teachers and members for support in their lives and spiritual journeys outside of OSG, and OSG teachers and members have happily and unconditionally provided such former OSG members with such support. 19. OSG additionally organizes opportunities and encourages its members to perform service and provide charity to communities outside of OSG. For example, OSG members have volunteered with Habitat for Humanity to build houses for those in need; they have provided clothing, toys, and other needed items to the Family Child Care Network in the Bronx; they voluntarily installed a new kitchen, repainted, and fixed water leaks at a Lutheran church in New 5 5 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 York City where a children’s school is maintained; they have provided food, clothing, toiletries, and other necessities and worked in soup kitchens at Christian churches in Manhattan and Queens; they have organized clothing drives for the unhoused, toy drives for underprivileged children, and winter coat donations for immigrants; and they have performed theater and music for children without access to arts programs. After attending a dance festival in the country of Georgia, Gans Horn and other OSG members began sponsoring an orphanage there, with some returning to Georgia to help build housing for the children and others sending money, clothes, and gifts to them in the following years. Schneider’s History with OSG 20. Schneider voluntarily joined OSG in or around 1989 after attending a free month of classes. At the time, he was 29 years old and an attorney living in New York City, where he practiced law full time and played in a bar band on weekends. 21. Schneider was a member of OSG for approximately 23 years, and for much of that time he held leadership positions in the organization and was part of the organization’s inner circle. Schneider became so close to Alex and Sharon Gans Horn that he was invited to serve as one of Alex Horn’s caretakers in 2007 when Horn was dying of cancer, alongside Horn’s family members and other OSG leaders. 22. Schneider maintained an active and successful law practice as a litigator in New York during his 23 years as a member of OSG. He appeared in New York state and federal trial and appellate courts in dozens of cases, representing sophisticated clients such as Merrill Lynch. 23. Schneider soured on OSG and Gans Horn, and became hostile to them and other OSG members, following the breakdown of both his marriage to another OSG member and his 6 6 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 relationship with one of his top legal clients, also an OSG member. 24. Schneider attended his last OSG classes in December 2012, but he had largely ceased participating in OSG by that point. While Schneider attended OSG’s annual Christmas party that month, he did not help to plan or set up for the party or volunteer to serve as a DJ at the party as he had in years past. Schneider left OSG in or around December 2012 by simply ceasing to pay tuition and not returning to class. 25. For the last 10 years since leaving OSG, Schneider has bedeviled the organization and its members through a defamatory blog that he publishes at www.cultrevolt.com (the “Blog”); with numerous harassing phone calls, letters, emails, and text messages to OSG members, including at their places of business; by giving interviews for false tabloid press stories and other media about OSG; by occasionally showing up outside of OSG’s meeting space in Manhattan to harangue members as they entered or exited class; and by contacting OSG’s landlord to try to get OSG kicked out of its meeting space in Manhattan. 26. OSG and its members turned the other cheek for a decade in the face of Schneider’s defamation and harassment. But last year, Schneider dramatically and inexcusably upped the ante. On or around July 5, 2022, Schneider widely published in hardcover format a purported memoir about his time with OSG titled Manhattan Cult Story: My Unbelievable True Story of Sex, Crimes, Chaos, and Survival (the “Book”), falsely and maliciously portraying OSG as a “cult” and a criminal organization engaged in “trafficking” and “forced labor.” Schneider republished the Book in audio CD format through a different publisher, Dreamscape Media, on August 9, 2022. Schneider has actively promoted the Book and repeated its false and defamatory statements in numerous live events, media interviews, and other publications over the last year. 7 7 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 27. A few months after his Book was published, in December 2022 Schneider filed a sham federal lawsuit against OSG falsely alleging that he was a victim of human trafficking and forced labor by OSG for the 23 years he was a member (and leader) of the organization. The sole purposes of Schneider’s lawsuit are to harm OSG, to boost his public profile as an author and purported “survivor,” and/or to try to extract money from OSG and the estate of Sharon Gans Horn following her death in 2021. As Schneider intended and facilitated, the lawsuit was reported in the press, including in the New York Law Journal. 28. Schneider’s obsessive, outrageous, malicious, and defamatory vendetta against OSG has left it with no choice but to file this action to defend its and its members’ rights and reputations and to put an end to Schneider’s relentless chicanery. CAUSE OF ACTION (Defamation Per Se) Schneider’s Maliciously False and Defamatory Book and Attendant Media Campaign 29. On or about July 5, 2022, Schneider published or caused to be published in hardcover format his Book, which is premised on and replete with false statements of and concerning OSG that are designed to injure OSG by falsely portraying it as a dangerous cult and a criminal organization engaged in human trafficking and forced labor. On August 9, 2022, Schneider republished or caused to be republished the Book in its entirety in audio CD format. Specifically, Schneider made the following maliciously false and defamatory material statements1 of and concerning OSG in his Book: …we endured (and witnessed) mental, sexual, and physical abuse, forced labor, swindling of our money, breaking up of our families, and systematic terrorizing. Some students conspired with her [OSG’s leader, Sharon Gans Horn] to break the 1 This is by no means a comprehensive or exhaustive list of false statements in the Book, which are too numerous to catalogue herein. OSG sets out here only a selection of salient and material false statements that have injured OSG. 8 8 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 law. Sharon left her students in shambles: poorer, broken down, beaten up, and hollowed out. We would do anything for her. Some would have gone to jail or killed for S, our teacher, Sharon Gans. We took an oath of absolute secrecy. We never even told our families who we really were. We thought nothing of lying. We understood that disclosure would put in us [sic] grave danger. …you’d never guess our secret lives, how we lived in silent terror and fervor and suffering. During those years, I had nothing else but School—it was my world. This is the story of how I got entangled in School, the twenty-three years I spent there, how I narrowly escaped, and how I survived. …[recruiting] was mandatory, or we’d be forced to leave School, we were told. Sharon or Fred [OSG leaders] wanted us to start to keep our families at arm’s length. Sharon used to paraphrase (and misuse) Christ’s injunction to: “hate his own father and mother and wife and children and brothers and sisters.” She said that one needed to separate from one’s family to become real students of the Work. Departures were like deaths to those who remained. For one, we would never see them again in class and we were forbidden from contacting them or taking their calls. When people left, they were dead to us; and in the event we saw them on the street we were to run the other way; if they contacted us, we were to shut it down; they were killer zombies. Obviously, in no circumstances were we to contact them. Like Phil, Danny is also a gay man who was married off by Sharon to a woman in class. My “self” had been ground away, snuffed out during the past twenty-three years. My dignity, self-esteem, pride, and self-reliance were distant memories. I was unable to discern reality… I didn’t realize School was really a cult until I took the step, out the door…In the topsy-turvy Gans world, lies are used to keep people in. She drills this into people 9 9 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 to become fearful of leaving, to be fully dependent upon her, and to doubt oneself…She didn’t invent this method of abuse, but she is very good at it. [OSG’s leader, Gans Horn] Was openly bigoted against people of color and homosexuals. Was a liar and sociopath. Would randomly throw students out of class. Forced students to work on personal building projects in unsafe conditions and for free. Forced students to cook all her meals. I have been able to get at least a few people out of School who happened upon my blog. I kept in touch with other survivors…I learned how to write about the cult. I know that former members are understandably fearful and ashamed of speaking out about anything involving School, but I hope that my story will encourage them to come out and confront their predators. There were dozens of construction projects where members were coerced into working in dangerous conditions for free. Sharon’s and Alex’s apartments were built with forced labor; the spaces where we met to hold meetings were built with forced labor; Sharon’s home in the Hamptons was renovated with forced labor; Sharon coerced students to renovate homes of her favored students. Sharon had many homes and properties—in the Hamptons, Montana, Westchester, Mexico, and Manhattan—all of which were used exclusively by Sharon and her family. It was a weekend getaway for Sharon’s cult, and it was completely for her profit. At best, [OSG’s leader] Sharon had a passing knowledge of the Gurdjieff system. We were forbidden to read any biographies about Gurdjieff. Other than getting paid by people to ruin their lives, Sharon held no job or occupation. Of all her crimes and immorality, Sharon outdid herself when it came to children. Her depravity knew no limits. There is no greater sadism than to harm families and children, and Sharon loved it. [OSG’s leaders] Sharon and Alex wanted their followers to stay close and encouraged intra-School marriages and for couples to have as many children as possible. This is standard in all kinds of cults and closed communities. Even if one parent leaves, the children are essentially held hostage, and this has kept many people from speaking out about School. 10 10 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 The long arm of Sharon Gans reaches beyond the grave, covering the mouths of current and former victims. It’s no different than the pedophile priests or coaches who can keep their victims quiet. Survivors suffer shame, embarrassment, self- blame, and a perceived stigmatization of having been duped by a cult. 30. While Schneider refers to OSG as “School” throughout his Book, School is easily identifiable to readers as OSG due to Schneider’s identification in the Book of OSG’s founders and other leaders by their real names, his statements identifying OSG on his Blog and in widespread publications, media, and events where he promotes and has promoted his Book and personal story, and his federal lawsuit, reported in the press, falsely alleging that he was a victim of trafficking and forced labor by OSG and its leaders. Additionally, through these and other statements set out below, Schneider falsely and maliciously portrayed OSG as a cult of personality revolving around the whims of its founder, Sharon Gans Horn, conflating Gans Horn and OSG such that his false statements about Gans Horn are imputed to OSG. 31. At the end of Schneider’s Book, he lists “Nine Telltale Signs You’re in a Cult,” such as “Former members are ostracized and denigrated”, “The group isolates you from your friends and family”, and “The group discourages you from thinking for yourself.” These statements are false and defamatory insofar as Schneider clearly and intentionally implies that they are objective factors that apply to OSG and show that it is a cult. 32. Schneider made similar and additional false and defamatory statements of and concerning OSG in a widespread campaign to promote the Book after its publication, including: a. On his personal website at www.spencer-schneider.com (the “Website”), Schneider published a page promoting the Book that contains the following false and defamatory statements of and concerning OSG: 11 11 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 “It didn’t look like a cult. I was relieved. Nobody was in black robes chanting. No kids running around in rags with faraway gazes. Just a bunch of young professionals––hedge funders, doctors, entrepreneurs, lawyers––in a secret loft in Tribeca. They looked, I realized, a lot like me,” says Spencer Schneider. “I had no way to possibly know they were brainwashed––hollowed out souls––under the clutches of a leader every bit as twisted and commanding as Jim Jones.” This is Schneider’s true story of how he got entangled in a cult known only as “School,” why he stayed, and how––impossibly––he got out after twenty-three years. b. In a video that Schneider embedded on his Website page promoting the Book, Schneider makes the following false and defamatory statements of and concerning OSG: that the organization that Schneider spent 23 years in is a “cult”; that his Book is a “a deep dive, a memoir, in which I try to bring a reader along on my journey into a cult”; and that “I also recount the kind of abuse that I witnessed, suffered, and go into the tales and stories about how very intelligent and highly educated and successful people such as doctors, hedge fund managers, lawyers, Ivy-educated folks, were radicalized by a leader who was every bit as demented as Jim Jones.” c. Schneider published or caused to be published on the www.amazon.com page where the Book is advertised and sold the following false and defamatory statements of and concerning OSG: Right under the noses of neighbors, clients, spouses, children, and friends, a secret society, simply called School—a cult of snared Manhattan professionals—has been led by the charismatic, sociopathic and dangerous leader Sharon Gans for decades. Spencer Schneider was recruited in the eighties and he stayed for more than twenty-three years as his life disintegrated, his self-esteem eroded, and he lined the pockets of Gans and her cult. 12 12 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 Cult members met twice weekly, though they never acknowledged one another outside of meetings or gatherings. In the name of inner development, they endured the horrors of mental, sexual, and physical abuse, forced labor, arranged marriages, swindled inheritances and savings, and systematic terrorizing. Some of them broke the law. All for Gans. “During those years,” Schneider writes, “my world was School. That’s what it’s like when you’re in a cult, even one that preys on and caters to New York’s educated elite. This is my story of how I got entangled in School and how I got out.” At its core, Manhattan Cult Story is a cautionary tale of how hundreds of well-educated, savvy, and prosperous New Yorkers became fervent followers of a brilliant but demented cult leader who posed as a teacher of ancient knowledge. d. Schneider repeated the false and defamatory statement that OSG is a dangerous cult, based on objective criteria, that abuses its members and engages in forced labor at Book reading and signing events on or around July 7, 2022, at Sag Harbor Bookstore and BookHampton Bookstore; at a Book launch event on or around July 13, 2022, at The North Bar in Manhattan; at a Book reading and signing event on or around August 3, 2022, at Amagansett Public Library; on or around August 12, 2022, at East Hampton Library; and at a November 2022 event for his Book at Shelter Island Public Library, the video of which was published on or around November 22, 2022, on YouTube by Schneider’s intention and design, with the caption, “This dialogue is about [Schneider’s] 23 years spent in a secret cult, which preyed upon highly educated, young professionals, and how he managed to escape.” 33. By Schneider’s intention and design, numerous media outlets reported on Schneider’s Book following its publication and repeated Schneider’s false and defamatory 13 13 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 statements that OSG is a dangerous cult that revolved around the whims of Gans Horn and abused, coerced, and swindled its members. 34. On or around July 9, 2022, as Schneider intended and facilitated, the New York Post published an article, titled “Odyssey Study Group cult still going strong after death of charismatic leader Sharon Gans,” that identified Schneider as a former OSG member and reported on his Book, repeating Schneider’s maliciously false and defamatory statement that OSG is a cult. Schneider made additional maliciously false and defamatory statements about OSG that were published in the article, as follows: “The whole thing is a pyramid scheme and a hoax,” said Spencer Schneider, a former OSG member who has written “Manhattan Cult Story: My Unbelievable True Story of Sex, Crimes, Chaos and Survival,” a tell-all book out now about the cult. “It’s a long haul hoax and Sharon was a genius at going after vulnerable people with money.” 35. On or around July 12, 2022, Schneider appeared on Dan’s Papers’ “Who’s Here in the Hamptons” podcast to discuss and promote his Book. Schneider repeated maliciously false and defamatory statements from his Book, including that OSG is a dangerous cult that abuses and coerces its members, that OSG had “complete control” over Schneider’s life, and that OSG forced its members to perform labor. The YouTube page where a video of the interview was published states that Schneider “is the only former member of the Odyssey Study Group cult, also known as the ‘School’ to publish about his experiences in the cult — he was a member of School’s inner circle for 23 years.” 36. Also on or around July 12, 2022, Schneider appeared on an episode of the Growth Now Movement podcast in which he discussed and promoted his Book. Schneider repeated maliciously false and defamatory statements from his Book, including that OSG is a dangerous 14 14 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 cult that preys on the vulnerable and abuses and coerces its members. Schneider additionally caused the following false and defamatory statements to be published on the episode’s YouTube page: But soon, he found himself trapped in one of the nation’s most secretive and abusive cults. In the name of personal development, hundreds endured decades of sexual and physical abuse, forced labor, arranged marriages, swindled savings and inheritances, and systematic terrorizing. Some of them broke the law. All for their charismatic and demented leader Sharon Gans. 37. On or around July 23, 2022, by Schneider’s intention and design, the New York Post published an article titled, “NYC cult bought $925K upstate retreat, uses ‘forced labor’ to dig ditches,” which repeated false and defamatory statements from Schneider’s Book that OSG is a cult that coerces its members and uses forced labor. Schneider made additional false and defamatory statements about OSG that were published in the article, as follows: “It’s very heavy mind control,” Schneider told The Post Wednesday. “I know it’s hard to believe, but [members] just don’t look them up. They’re afraid to look. If you do look them up and tell someone about it, you are punished and berated in front of the group.” 38. Schneider gave the same maliciously false and defamatory statement about OSG set out in paragraph 37 in an article in The Mirror published on July 26, 2022, titled “Inside cult forcing recruits to dig ditches at retreat as leaders live high life,” which also repeated false and defamatory statements from Schneider’s Book in stating that OSG is a cult that coerces its members and uses forced labor, as Schneider intended and designed. 39. Also on or around July 26, 2022, Schneider appeared in an episode of Milling About with Robin Milling, titled “Milling About with ‘Manhattan Cult Story’ Author Spencer Schneider,” to discuss and promote his Book. Schneider repeated maliciously false and defamatory statements from his Book, including that OSG is a dangerous cult that preys on the 15 15 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 vulnerable and abuses and coerces its members. 40. On or around August 2, 2022, Schneider appeared on an episode of MetroFocus on PBS to discuss and promote his Book. Schneider repeated maliciously false and defamatory statements from his Book, including that OSG is a “sinister cult” that abuses, coerces, and harms its members. 41. On or around August 11, 2022, as Schneider intended and facilitated, The East Hampton Star published a review of Schneider’s Book, titled “We Don’t Need No Education,” that repeats Schneider’s maliciously false and defamatory statements that OSG is an abusive, coercive cult and pyramid scheme that preys on its members. 42. On or around February 27, 2023, as Schneider intended and facilitated, the Daily Mail published an article, titled, “Adam Driver’s mother-in-law, 67, ‘was a teacher at NYC cult the Odyssey Study Group during the early 2000s’ - as it’s accused of ‘emotional abuse, pressuring members to commit infidelity, child abuse and forced labor’,” based on and repeating the maliciously false and defamatory statements contained in Schneider’s Book that OSG is a “cult” that subjects its members to “forced labor.” Schneider made the following additional false and defamatory statements of and concerning OSG that were published in the article: [OSG’s leader, Gans Horn] had gay people marry straight people, because she believed in gay conversion which of course doesn’t exist, and she would also break up marriages. I didn’t realize how bad it was until I was about 10 or 15 years in and I finally saw how mercilessly [OSG’s leader, Gans Horn] treated people, and how they weren’t trying to improve anyone’s lives but instead hurt them. But I couldn’t get out because of how wrapped up my whole life was in that group. I was very afraid of leaving. 16 16 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 Schneider’s Maliciously False and Defamatory Newsweek Article 43. On or around October 19, 2022, Schneider wrote and published or caused to be published an article in Newsweek titled, “I Was in an Elite Manhattan Cult for 23 Years” (the “Article”). 44. The Article contains numerous maliciously false and defamatory statements of and concerning OSG echoed in Schneider’s Book, namely: repeated statements that OSG is a cult; that OSG members “would normally do anything without question”; that “[s]eniority [among OSG teachers] was determined by loyalty to Sharon”; that OSG members “worked night and day on construction projects” and were “too afraid not to do manual labor”; that OSG “drained [Schneider] of [his] money”; that Schneider’s OSG “friendships and…marriage would have to end, per School rules” if he left OSG; that Schneider stayed in OSG out of “fear”; that some OSG members “lost their savings by being forced to turn over money to [Sharon Gans Horn] for her personal use”; and that Schneider’s “mind had been poisoned by the cult…” 45. The Article, like Schneider’s Book, refers to “School” rather than to OSG by name, but School is easily identifiable as OSG for the reasons set out in paragraph 30, above. Schneider’s Maliciously False and Defamatory Sham Federal Lawsuit 46. On or around December 16, 2022—a few months after publishing and republishing his Book and approximately ten years after he left OSG—Schneider filed a federal lawsuit against OSG and several of its leaders in the Eastern District of New York (the “Complaint”) that is based solely on knowing, malicious, material falsehoods, as evidenced by the self-contradictory allegations on the face of the Complaint and prior statements by Schneider 17 17 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 that contradict his claims.2 The Complaint thus is a complete sham. Schneider’s statements in the Complaint purporting to allege claims for “trafficking” and “forced labor” against OSG and its leaders under the Trafficking Victims Protection Act were made maliciously by Schneider for the sole purpose of defaming OSG under the guise of litigation and its attendant privilege. A copy of the Complaint is annexed hereto as Exhibit A and made a part of this complaint. 47. Schneider’s claims for trafficking and forced labor set out in the 51-page Complaint are entirely based on knowing and material falsehoods, and thus the Complaint in its entirety is false, defamatory per se, and injurious to OSG. 48. In a nutshell, Schneider falsely and maliciously alleged in paragraph 1 of the Complaint that OSG and certain of its leaders “collectively operated as a cult and used a scheme, pattern and plan involving coercive and manipulative techniques that caused SCHNEIDER to perform thousands of hours of unpaid labor and services by instilling in him a fear that if he did not perform such labor and services, he would endure serious harm, including psychological, financial, and reputational harm and other non-physical harm.” 49. Schneider falsely and maliciously alleged in paragraphs 83-123 of the Complaint that OSG is a “cult” based on its alleged use of objective “tools” identified by cult experts, including the use of secrecy, isolation, indoctrination, subjugation, shame and humiliation, emotional abuse and degradation, sleep deprivation, intolerance for dissent, gaslighting, collateral, and economic abuse (collectively, the “Tools”) “to obtain and maintain control over individuals,” including Schneider. 2 On September 13, 2023, Magistrate Judge Scanlon stayed all discovery in that case pending resolution of OSG’s motion to dismiss the Complaint, noting on the record that “defendants have now formally raised before the district court serious challenges to the theory of the plaintiff’s case as well as to the facts alleged” and that “there are serious constitutional issues here and those are both the 1st Amendment free exercise and association…” 18 18 of 86 FILED: NEW YORK COUNTY CLERK 09/18/2023 08:07 PM INDEX NO. 155983/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/18/2023 50. In fact, Schneider knew or should have known before he filed the Complaint that OSG does not and did not use the alleged Tools of cults “to obtain and maintain control over” OSG’s members, including Schneider, and that OSG in fact is not a cult under the alleged expert criteria set out by Schneider. Schneider made these allegations maliciously and solely for the purpose of defaming OSG. 51. Some of the other maliciously false and defamatory material allegations that Schneider made in the Complaint to support his knowingly false and defamatory assertion that OSG is a cult include: [OSG] attempted to maintain, and maintained, absolute control over the personal and professional lives of many of the Students [including Schneider]. During Class and other events orchestrated by the Organization, the Organization and the Inner Circle used a classic combination of coercive and manipulative tactics to isolate SCHNEIDER from his family, friends and business colleagues, indoctrinate SCHNEIDER in the protocols of the Organization, and ultimately to wholly enmesh SCHNEIDER’s livelihood with that of the Organization. By and through the design of the Organization and the Inner Circle, SCHNEIDER distanced himself from his immediate family and lost substantive contact with close friends from outside the Organization. By and through the design of the Organization and the Inner Circle, SCHNEIDER’s family and previously-close friends were replaced by relationships with other Students of the Organization. By and through the design of the Organiza