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Case 1:15-cv-07433-LAP Document 1328-39 Filed 01/05/24 Page 4 of 8 Video Deposition of Tony Figueroa (Volume 1) 106 20 21 22 23 24 25 Q Do you know her name? A I think it was Carolyn -- Caroline, Carolyn -- I don't know -- something like that. Q Did Jeffrey call you directly about getting more girls? A Q > Q A Yes. On the phone? Uh-huh (affirmative) . What did he say? He was just asking me if I had any other girls that wanted to come work. Q A Q A Okay. Is that the term that he used? Yeah. And did he pay -- he paid you personally? Yeah. He handed me $200 for every girl that I walked in that door, whether they did stuff with him or not. Q In cash? Cash. Did you ever get paid by Ms. Maxwell for No. Did you ever bring a girl to Ms. Maxwell? No. Did Ms. Maxwell ever call you and ask you Southern Reporting Company (386)257-3663