DOJ-OGR-00019430.jpg
Extracted Text (OCR)
Case 20-3061, Document 60, 09/24/2020, 2938278, Page31 of 58
Giuffre v. Maxwell unseal proceedings, into which Ms. Maxwell seeks to introduce
criminal protective order-sealed information relevant to Judge Preska’s unseal
decisions.
This situation is fundamentally unfair to Ms. Maxwell. There is no reason all
judicial officers presiding over any case implicating Ms. Maxwell’s interests should
not have access, whether under seal, 77 camera, or otherwise, to all relevant
information, and there is no reason Ms. Maxwell should be barred from providing
such relevant information to them.
A. Preservation and standard of review.
Ms. Maxwell preserved this issue for appeal. App. 124-31, 293-98.
This Court reviews for an abuse of discretion an order denying a motion to
modify a protective order. Martindell, 594 F.2d at 295. A district court by definition
abuses its discretion when it makes an error of law. Koon v. United States, 518 U.S.
81, 100 (1996).
B. The district court erred in declining to modify the protective order.
Federal Rule of Criminal Procedure 16(d)(1) authorizes district courts to
enter or modify protective orders for good cause. Fed. R. Crim. P. 16(d)(1). In this
case, several reasons exist for the narrow modification of the criminal protective
order Ms. Maxwell proposes.
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DOJ-OGR-00019430
Extracted Information
Dates
Document Details
| Filename | DOJ-OGR-00019430.jpg |
| File Size | 587.2 KB |
| OCR Confidence | 95.1% |
| Has Readable Text | Yes |
| Text Length | 1,329 characters |
| Indexed | 2026-02-03 19:43:15.686941 |