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Case 20-3061, Document 16, 09/10/2020, 2928287, Page4 of 5 In turn, she asks for leave to file the unredacted copy of the Motion to Consolidate in the criminal appeal under seal with this Court, along with Exhibit B. The government does not oppose this Motion for Leave to File under Seal, although it does oppose the Motion to Consolidate. For these reasons, Ms. Maxwell requests leave to file her Unredacted Motion to Consolidate under seal. September 10, 2020. Respectfully submitted, s/ Adam Mueller Laura A. Menninger Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Tel 303.831.7364 Fax 303.832.2628 Imenninger@hfmlaw.com tgee@hmflaw.com amueller@hmflaw.com Counsel for Defendant-Appellant Ghislaine Maxwell DOJ-OGR-00019285