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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 2 of 43 Case 9:16-mc-81608-DMM *SEALED* Document 4 Entered on FLSD_Docket 09/20/2016 Page 1 of 6 FILED BY ~—--— Ba ——— United States District Court SEP 2.0 2016 Southern District of Florida STEVEN iv Larne CLERK U's bist Gy. as pte ET LAD Virginia L. Giufire, Plaintiff, Case No.: _ _ Underlying Case No.: 15-cv-07433-RWS (Southern District of New York) (Sweet, J.) Vv. Jeffrey Epstein, Defendant. PLAINTIFBE’S SEALED AGREED MOTION TO FILE MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS AND TESTIMONY FROM JEFFREY EPSTEIN UNDER SEAL PURSUANT TO LOCAL RULE 5.4(b) AND MOTION TO PLACE THE ENTIRE DOCKET UNDER SEAL Plainuff Virginia Giulfre, by and through her undersigned counsel, respectfully submits this Unopposed Motion to file her Motion to Compel the Production of Documents and Testimony from Jeffrey Fpstein under Seal Pursuant to Local Rule 5.4(b) and Motion to Place the Entire Docket Under Seal, and hereby states as follows. I. FACTUAL BACKGROUND The motion to compel sccks to compel production pursuant to a valid Rule 45 subpoena issued to Jeffrey Epstein in the above-styled case, pending in the Southern District of New York (the “New York case”). The case concerns a defamation action brought by a child victim of convicted pedophile Jeflrey lpstein against his live-in girlfriend who assisted him in procuring underage girls, including the plaintiff, Ms. Giuffre. Because of Epstein’s central role in the New York case. it is important for Ms. Giufire to have the requested documents from him in discovery,