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Case 20-3061, Document 37, 09/16/2020, 2932231, Page16 of 24 appeal from unsealing of competency evaluation because “any alleged incursions on criminal defendants’ rights to privacy and a fair trial do not render the unsealing order effectively unreviewable on appeal”); Hitchcock, 992 F.2d at 238-39 (district court’s refusal to seal documents not immediately appealable because “[rJeversal after trial, if it is warranted, will adequately protect . . . interest[s]” asserted by defendant); cf’ Mohawk Indus., 558 U.S. at 109 (holding that orders to disclose privileged information are not immediately appealable even though they “intrude[] on the confidentiality of attorney-client communications”). 20. To the extent Maxwell complains that unsealing filings in a civil case may result in unfair pretrial publicity in her criminal case, such a concern is not an issue that is effectively unreviewable on appeal from a final judgment. Indeed, that very issue has been reviewed by this Court in multiple cases on post- judgment appeal. See, e.g., United States v. Sabhnani, 599 F.3d 215, 232-34 (2d Cir. 2010) (evaluating on post-judgment appeal whether publicity biased the venire); United States v. Elfgeeh, 515 F.3d 100, 128-31 (2d Cir. 2008) (evaluating on post-judgment appeal whether publicity biased trial jurors). Should the Court determine that the jury at Maxwell’s trial was biased based on disclosure of material in a civil case, and that such material would not have been unsealed had Judge Nathan permitted modification of the Protective Order, then vacatur of the defendant’s conviction — if warranted — will adequately vindicate the defendant’s 15 DOJ-OGR- 00019358