In People v. Zambia (2009) 173 Cal.App.4th 1221, a female undercover officer posed as a prostitute. The defendant identified himself as a pimp, and offered to provide her with housing and clothing in exchange for her earnings. The Zambia court concluded that the defendant's statements constituted encouragement within the meaning of the statute. (Id. at p. 1227.) The court added that it was unnecessary to address Wagner on the merits. Nevertheless, it stated that People v. Wagner (2009) was factually distinguishable because the woman solicited in that case was already a prostitute, while the woman solicited in Zambia was a policewoman and had not engaged in prostitution. (Zambia, at p. 1227.)