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Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 4 of 10 Q. Did you ever tell Johanna that she would get extra money if she provided Jeffrey massages? A. 1 was always happy to give career advice to people and I think that becoming somebody in the healthcare profession, either exercise instructor or nutritionist or professional massage therapist is an excellent job opportunity. Hourly wages are around 7, 8, $9 and as a professional healthcare provider you can earn somewhere between as we have established 100 to $200 and to be able to travel and have a job that pays that is a wonderful job opportunity. So in the context of advising people for opportunities for work, it is possible that I would have said that she should explore that as an option. Q. Did you tell her she would get extra money if she massaged Jeffrey? A. I'm just saying, I cannot recall the exact conversation, I give career advice and I have done that. Q. Did you ever have Johanna massage you? A. | did. Q. How many times? A. 1 don't recall how many times. Q. Was there sex involved? A.No.... Q. Did you ever have sexual contact with Johanna? MR. PAGLIUCA: Object to the form and foundation. You need to give me an opportunity to get in between the questions. Anything that involves consensual sex on your part, I'm instructing you not to answer. Q. Did you ever have sexual contact with Johanna? A. [MR. PAGLIUCA?] Again, she is an adult -- Q. I’m asking you, did you ever have sexual contact with Johanna? A. I’ve just been instructed not to answer. Q. On what basis? A. You have to ask my lawyer. See McCawley Decl. at Exhibit 4, Tr. of Maxwell Depo. (Apr. 22, 2016) at 60-62 (emphasis added).