INDIANAPOLIS (AP) — The former director of a children’s foundation created by longtime Subway spokesman Jared Fogle says his former boss was psychologically abusive, referred to himself as “daddy” and reminded him that “daddy” was paying for his things.

In a sentencing memorandum filed Friday, 44-year-old Russell Taylor and his attorneys ask a judge to consider a sentence ranging from 15 years to nearly 23 years for providing homemade child pornography to Fogle.

Federal prosecutors want a 35-year prison sentence.

The court document says Fogle maintained control over Taylor’s job and home and “had the perfect person to carry out his sexually deviant pursuits.”

Taylor is scheduled to be sentenced Thursday.

Fogle was sentenced to more than 15 years in prison for trading in child pornography and paying for sex with underage girls.