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Case 1:20-cr-00330-AJN Document 52 Filed 09/02/20 Page 5of8 The Honorable Alison J. Nathan August 17, 2020 Page 5 parte application. Counsel for Ms. Maxwell then carr ¢(, [i denied the application. xy The pressing issue that necessitates the filing of this request concerns These issues, in turn, impact her rights as the accused in this matter, constitutionally presumed innocent unless and until the government proves her guilt beyond all reasonable doubt. The Protective Order in this case The Protective Order in this case prohibits the use of the discovery materials or confidential- designated materials “for any civil proceeding or any purpose other than the defense of this action” absent mutual agreement in writing between the government and defense counsel or if “modified by further order of the Court.” Doc. # 36 at {J 1(a), 10(a), 18. Ms. Maxwell agreed to that limitation after assurances by the government, consistent with their representation to this Court, that “the Government rarely provides any third party, including a witness, with any material they did not already possess,” and therefore “concerns defense counsel raises about future use in civil litigation are not likely to occur.” Letter of Alex Rossmiller at 6 (Doc. # 33) (July 28, 2020). This Court relied on that representation in its ruling that government witnesses should not be limited in their use of materials gained from the government in any related civil litigation. Memorandum Op’n & Order at 3 (July 30, 2020). Yet as described above, the government must have given a copy of the sealed order to Paragraph 18 of the Protective Order permits modification by the Court. Further, any concerns that the government may raise concerning their on-going grand jury investigation will be obviated by submission of these materials under seal in the other matters. The reasons this Court should grant the request DOJ-OGR-00001756