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Case 20-3061, Document 38, 09/16/2020, 2932233, Page3 of 23 perjury, in violation of 18 U.S.C. § 1623. The matter remains pending in the pretrial phase before the Honorable Alison J. Nathan, United States District Judge. Maxwell’s pretrial motions are due on December 21, 2020, and trial has been scheduled to commence on July 12, 2021. 3. On July 30, 2020, upon the Government’s application, Judge Nathan entered a protective order governing the parties’ disclosure of information produced in discovery in the criminal case (the “Protective Order’). (Ex. A). The Protective Order expressly provides that any and all discovery material produced to Maxwell by the Government, regardless of designation, “[s|hall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action.” (Protective Order {/] 1(a), 10(a), 14(a)). The Protective Order further provides that any discovery material produced to Maxwell by the Government that is marked “confidential” may not be filed publicly or excerpted within any public filing. Ud. 4 15). Maxwell’s criminal defense counsel consented to the foregoing provisions of the Protective Order. (See Dist. Ct. Docket Entry 29). 4. On August 17, 2020, Maxwell filed a motion before Judge Nathan seeking an order modifying the Protective Order to allow Maxwell to use confidential criminal discovery materials, which were produced to Maxwell by the DOJ-OGR-00019369