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Case 1:20-cr-00330-PAE Document 732 Filed 07/14/22 Page 24 of 25 The Honorable Alison J. Nathan November 22, 2021 Page 24 behind Ms. Maxwell’s back and under the nose of the presiding judge. This Court and Chief Judge McMahon concluded that Ms. Maxwell could not have reasonably relied on the protective order’s promise of confidentiality because the order was subject to modification and because of the overriding interest in the “truth-seeking function of the judicial process.” June 25, 2021 Order, p 13, 17-18. If that is true, then it’s equally true that Ms. Maxwell’s accusers cannot reasonably expect their submissions to and communications with the EVCP to remain confidential for all time and for all purposes. The EVCP Protocol expressly provides that its confidentiality guarantee is “subject to law, regulation and judicial process.” And in view of the “truth-seeking function of the judicial process” and Ms. Maxwell’s constitutional rights to present a defense and confront her accuses, any remaining interest in confidentiality must give way. CONCLUSION Ms. Maxwell’s subpoena is narrow, specific, and targeted. It seeks only that evidence which is relevant to her defense and admissible at trial. Although the concerns about confidentiality are overblown, Ms. Maxwell nevertheless has asked that this Court review the material in camera before turning it over to the defense. That in camera review would provide another layer of protection, even as there is no reason to think that Ms. Maxwell is on a fishing expedition. Accordingly, and for the reasons given above, Ms. Maxwell requests that this Court deny the motions to quash. DOJ-OGR-00011447