DOJ-OGR-00019568.jpg

Came 2202 06 00BB0AUENt Docume 0 Filed DS02 Rag eR agenb ots The Honorable Alison J. Nathan August 17, 2020 Page 6 There are at least three compelling reasons to modify the Protective Order. First, The partial secrecy surrounding the Material has also fundamentally undermined the fairness of the adversarial process. Although the grand jury subpoena and government investigation were = 8 fe} = 5 a 6 Re | be rule does not impose any obligation of secrecy on witnesses.” Fed. R. Crim. P. 6, Advisory Committee Note to Subdivision 6(c)2. Too many questions remain unanswered including exactly what was said between the government and ggg, when was it said, and precisely what was turned over. Without the ability to use the Material in the very limited fashion proposed Ms. Maxwell she is unfairly disadvantaged Jy Bl Moreover, instead of candidly revealing the fact of the subpocna d, Secon App.109 DOJ-OGR-00019568