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The Honorable Alison J. Nathan August 24, 2020 Page 3 v. State of New York, 779 F.2d 861 (2d Cir. 1987); Abbott Laboratories v. Adelphia Supply USA, Case 2015-cv-5826 (CBA) (MDG), 2016 WL 11613256 (S.D.N.Y. Nov. 22, 2016) (“In the Second Circuit, there is a presumption in favor of enforcing protective orders against grand jury subpoenas.”); United States v. Kerik, 07 CR 1027, 2014 WL 12710346 (S.D.N.Y. July 23, 2014). It seems that a majority of courts in this district have rejected the claimed “standard practice” arguments made by the Government M.A notable difference is that the other applications were not conducted ex parte. Ms. Maxwell is not asking this Court to decide that question today. But Ms. Maxwell is seeking The Government Does Not Explain How Any “Secret” Investigation Will be Compromised. Third, the government claims that the materials at issue are “Confidential” because the “full scope and details” of their very-public proclamations of an ongoing criminal investigation “have not been made public.” Resp. at 3. This argument too is nonsensical: the sealed materials that Ms. Maxwell seeks to file, under seal, Certainly the subpoena recipient, otherwise known as counsel for the adverse party to the Civil Litigation, knows the two things that Ms. Maxwell seeks to file under seal in DOJ-OGR-00001765