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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 6 of 43 Federal Rule of Civil Procedure 26 authorizes a court, for good cause, to enter a protective order to seal or to limit disclosure. Indeed, courts have the discretion to place entire cases under seal. See e.g. Beaches MLS, Inc. y. Miami Association of Realtors, Inc., 2015 WL 11170925, at *3 (S.D.Fla, 2015) (Marra, J.) (granting motion to file under seal and sealing the case). Local Rule 5.4(b) provides the procedure to follow when a party seeks to file something under seal: the party must file a motion, “setting forth a reasonable basis for departing from the general policy of a public filing,” and courts in this district routinely grant parties” motions to file under seal for good cause. See e.g. Shire Development LLC v. Watson Pharmaceuticals, Inc., 932 F,Supp.2d 1349, 1359 (S,D.Fla, 2013) (Middlebrooks, J.); Air Turbine Technology, Inc. y. Atlas Copco AB, 2003 WL 22939256, at *1 (S.D.Fla. 2003) (Marra, J.). Ms, Giuffre has articulated good cause to grant her motion to file under seal and to seal this case, as it would facilitate the execution of a valid Rule 45 subpoena issued upon Jeffrey Epstein and follow the confidentiality order previously entered in this case by the U.S, District Court for the Southern District of New York. Counsel for Ms. Giuffre has conferred with counsel for Epstein, and counsel for Epstein has agreed to the filing of the Motion to Compe! under seal. Ul. CONCLUSION For the reasons set forth above, plaintiff, Virginia Giuffre, respectfully requests that the Court grant her Agreed 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 for the reasons set forth above. Dated: September 20, 2016 Respectfully Submitted,