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Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 17 of 28 7. Jean Luc Brunel (33 % hours). Mr. Brunel’s deposition is set for June 7, 2016, in New York. He has relevant information because he has known Maxwell and Epstein for many years and was present with Epstein and Defendant on many occasions at Epstein’s homes in New York, Palm Beach and the USVI, and he has personal knowledge of the disputed issues in this case 8. Ross Gow (3% hours). Mr. Gow is Defendant’s press agent who issued the press statement at issue in this case on Defendant’s behalf. He will be able to testify regarding the defamatory statement, its distribution, any other defamatory statements that were distributed, and any information he had regarding the basis for the statement. Ms. Giuffre has requested that Defendant agree to produce Mr. Gow rather than requiring the time and expense of having to serve a subpoena on Mr. Gow, located in London, under the Hague convention, but counsel for Defendant has not agreed to produce Ross Gow for deposition. 9. Dana Burns (3 % hours). Ms. Burns’ deposition is set for June 8, 2016, in New cad} ° 5 > Q S 10. Jo Jo Fontanella (3% hours). Jo Jo Fontanella is a critical witness because he has been working as Jeffrey Epstein’s butler in his New York mansion for a number of years