Prosecutors want a judge to sentence the former director of a foundation created by longtime Subway spokesman Jared Fogle to 35 years in prison followed by a lifetime of supervised release for providing homemade child pornography to his former boss.

A sentencing memorandum filed Thursday and signed by U.S. Attorney Josh Minkler says Russell Taylor "repeatedly engaged in criminal activity targeting children" and that his actions "greatly impacted the lives of 12 children and their families."

Taylor is expected to plead guilty Dec. 10 to child exploitation and child pornography charges. He's admitted using hidden cameras to produce child pornography.

Taylor's attorney hasn't filed a sentencing request yet.

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