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Case 20-3061, Document 38, 09/16/2020, 2932233, Page4 of 23 Government, in filings Maxwell intended to submit in separate civil litigation. (District Court Docket Entry 52). In particular, Maxwell’s motion sought authorization to use materials relating to applications the Government previously made in 2019 seeking the modification of certain protective orders in other judicial proceedings. 5. On August 21, 2020, the Government filed an opposition to Maxwell’s motion to modify the Protective Order. (Dist. Ct. Docket Entry 46). In its opposition, the Government explained the factual background regarding the confidential criminal discovery materials at issue. In particular, the Government explained that those discovery materials related to the Government’s requests to modify certain protective orders in civil cases to permit compliance with grand jury subpoenas (the “Subpoenas”’). Those Subpoenas were issued to a certain recipient (the “Recipient’) in connection with a grand jury investigation into Jeffrey Epstein and his possible co-conspirators. In order to maintain the integrity of the grand jury investigation and in accordance with both Federal Rule of Criminal Procedure 6(e) and its standard practice, the Government did not notify Maxwell or her counsel of the Subpoenas. In response to receiving the Subpoenas, the Recipient advised the Government that it believed that certain existing protective orders precluded full compliance. Accordingly, in or about February 2019, the Government applied ex parte and under seal to each relevant court to DOJ-OGR-00019370