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Case 20-3061, Document 82, 10/02/2020, 2944267, Page8 of 37 girls by, among other things, helping Epstein to re- cruit, groom, and ultimately abuse minor victims. The Indictment further alleges that in or about 2016, Max- well attempted to cover up her crimes by lying under oath about her role in Epstein’s scheme. On July 30, 2020, upon the Government’s applica- tion, Judge Nathan entered a protective order govern- ing the parties’ disclosure of information produced to Maxwell by the Government in discovery in the crimi- nal case (the “Protective Order’). The Protective Or- der, among other things, prohibits the use of criminal discovery materials in civil litigation. Three weeks later, Maxwell moved to modify the Protective Order to allow Maxwell to use confidential criminal discovery materials, which were produced to Maxwell by the Government, in filings Maxwell intended to submit in separate civil litigation. Judge Nathan denied Maxwell’s motion on Septem- ber 2, 2020, holding, among other things, that Maxwell had failed to establish good cause to modify the Protec- tive Order and failed to coherently explain how the criminal discovery materials related to any argument Maxwell intended to make in the civil litigation. Maxwell filed a notice of appeal on September 4, 2020. Statement of Facts A. The Indictment On June 29, 2020, Indictment 20 Cr. 330 (AJN) was filed under seal in the Southern District of New York, DOJ-OGR-00019615