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Case 20-3061, Document 82, 10/02/2020, 2944267, Page10 of 37 in discovery in the criminal case. (A. 75-86). The Pro- tective Order expressly provides that any and all dis- covery material produced to Maxwell by the Govern- ment, regardless of designation, “[s]hall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action.” (Protective Order 44 1(a), 10(a), 14(a)). The Protective Order further provides that any discov- ery material produced to Maxwell by the Government that is marked “confidential” may not be filed publicly or excerpted within any public filing. (Protective Order {| 15). Maxwell’s criminal defense counsel consented to the foregoing provisions of the Protective Order. (See A. 40, 44-55). C. The District Court Litigation Despite having agreed to the prohibition on using the discovery materials in civil cases, on August 17, 2020, Maxwell asked Judge Nathan to modify the Pro- tective Order to allow her to do exactly that. (A. 124- 31). In particular, Maxwell’s motion sought authoriza- tion to use materials relating to applications the Gov- ernment previously made in 2019 seeking the modifi- cation of certain protective orders in other judicial pro- ceedings. On August 21, 2020, the Government filed an oppo- sition to Maxwell’s motion to modify the Protective Or- der. (A. 90-94). In its opposition, the Government ex- plained the factual background regarding the confi- dential criminal discovery materials at issue. In par- DOJ-OGR-00019617