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Case 1:20-cv-00333-JPA Document 1207-10 Filed 10/22/21 Page 249 of 435
Page 249
1 G Maxwell - Confidential
2 A. I can only testify to the years
3 when I was present.
4 Q. Right.
5 A. And I can also only testify to
6 people I personally either met and/or worked
7 with and/or invited, to find the correct
8 word, I don't know what the correct word is,
9 to come to do exercise or whatever it was at
10 the house.
11
12 female that I brought were all appropriate
13 and age appropriate adults.
14 Q. Over the age of 18?
15 A. We've established them as an adult.
16 Q. You are saying appropriate adults,
17 so we are clear, you didn't hire or bring in
18 or know of any exercise instructors that were
19 under the age of 18 at any of those homes?
20 A. I am also testifying that when I
21 was present at the house and with the people
22 that I brought in, were all age appropriate
23 adults.
24 Q. How do you define age appropriate
25 adults, is that over the age of 18, can we
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