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Case 20-3061, Document 17, 09/10/2020, 2928288, Page3 of 15 Defendant-Appellant Ghislaine Maxwell moves this Court to consolidate United States v. Maxwell, No. 20-3061 (the “criminal case,” Case No. 20-CR-330 (AJN) (S.D.N.Y.)), with the pending appeal in Gzuffre v. Maxwell, Case No. 20- 2413 (the “civil case,” Case No. 15-CV-7433 (LAP) (S.D.N.Y.))." Background These two appeals are inextricably intertwined. As Ms. Maxwell explained in her opening brief in the civil case, the district court unsealed the deposition material without knowing critical new information discovered to Ms. Maxwell in the criminal case bearing directly on whether the deposition material should be unsealed. Giuffre v. Maxwell, Case No. 20-2413, OB, pp 13-15. Since Ms. Maxwell seeks to consolidate both appeals, she is filing this motion in both cases. But because of the protective order in the criminal case, EXHIBIT A, Ms. Maxwell can file an unredacted version of this motion in the criminal appeal only. She cannot file an unredacted version of this motion in the civil appeal. Accordingly, in the criminal appeal, Ms. Maxwell will file a sealed and unredacted copy of this motion along with a motion for leave to file under seal. She will publicly file on ECF the redacted copy of this motion. In the civil appeal, Ms. Maxwell will file on ECF the redacted copy of this motion only. DOJ-OGR-00019289