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Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 21 of 28 17. Jeffrey Epstein (3% hours). Ms. Giuffre’s counsel have been in touch with Epstein’s counsel and is continuing to work to schedule his deposition. Epstein lies at the center of this case, and he can testify that Defendant recruited females for sex with him, including Mrs. Giuffre, under the offer of being a massage therapist, and ultimately paid these females for sex. He can testify that Defendant lured dozens if not hundreds of young females, including many underage females, to his residences for sexual purposes. Il. DISCUSSION Ms. Giuffre has attempted to conduct discrete, focused discovery in this case to limit any burdens on the Defendant and on the Court. Nonetheless, this case presents numerous challenges that require that she take more than ten depositions — not the least of which is Defendant’s extraordinary lack of memory about many events that would appear to have indisputably taken place. Ms. Giuffre, however, is not seeking to exceed the allotted hours for depositions under Rule 45 -- only the number of depositions. Ms. Giuffre seeks leave of Court to 7 additional depositions, for a total of seventeen depositions. Under the rules, each party is entitled to take ten depositions which total seven hours each. Fed. R. Civ. P. 29(d)(1). Thus, the presumptive time limit for depositions is a total of seventy hours (10 depositions x 7 hours per deposition). For the convenience of opposing counsel, Ms. Giuffre has stipulated that they may have half of the seven hour deposition time for each third party witness. Thus, if the Court grants Ms. Giuffre’s motion, she will end up taking less than seventy hours of deposition testimony. Specifically, she will only take one deposition of seven hours (Defendant’s) and sixteen depositions of three-and-a-half hours — a total of 66 and ’% hours of depositions. 17