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Case 20-3061, Document 54, 09/23/2020, 2937091, Page4 of 6 the Government’s applications to modify certain protective orders in other judicial proceedings.” Ms. Maxwell’s point is that, unless the unsealing order is reversed, she might not ever be able to litigate “the lawfulness of the Government’s applications.” Moreover, the motion to consolidate is not an attempt to circumvent Judge Nathan’s order before this Court can reach the merits. The motion to consolidate simply endeavors to ensure that this Court does not find itself in the same position as the several judges below, where only some of the judges are privy to the relevant facts. There is no merit to Ms. Giuffre’s argument that consolidation will cause meaningful delay. Doc. 123, pp 4-5. This Court has scheduled oral argument in both cases on the same day, as well as an argument on the motion to consolidate. Whether that motion is granted or not will have no effect on the dispatch with which this Court addresses the issues. This Court should grant the motion to consolidate. September 23, 2020. DOJ-OGR-00019397