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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 3 of 43 United States District Court FILED BY Southern District of Florida By. SEP 20 2016 STEVEN (4 Uisyanne LERK US DIST Ge 5D OFFA FT Lan 7 LA Virginia L. Giuffre, Plaintiff, Case No.: Underlying Case No.: 15-cv-07433-RWS (Southern District of New York) (Sweet, J.) v, Jeffrey Epstein, Defendant. / PLAINTIFF’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 Plaintiff Virginia Giuffre, 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 Epstein under Seal Pursuant to Local Rule 5.4(b) and Motion to Place the Entire Docket Under Seal, and hereby states as follows, lL FACTUAL BACKGROUND The motion to compel seeks 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 Jeffrey Epstein 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. Giuffre to have the requested documents from him in discovery.