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Case 20-3061, Document 82, 10/02/2020, 2944267, Page11 of 37 ticular, the Government explained that those discov- ery materials related to the Government’s requests to modify certain protective orders in civil cases to permit compliance with grand jury subpoenas (the “Subpoe- nas’). (A. 91). Those Subpoenas were issued to a cer- tain recipient (the “Recipient”) in connection with a grand jury investigation into Jeffrey Epstein and his possible co-conspirators. (A. 91). To maintain the in- tegrity of the grand jury investigation and in accord- ance with both Federal Rule of Criminal Procedure 6(e) and its standard practice, the Government did not notify Maxwell or her counsel of the Subpoenas. (A. 91). In response to receiving the Subpoenas, the Recipient advised the Government that it believed that certain existing protective orders precluded full compliance. (A. 91). Accordingly, in or about February 2019, the Government applied ex parte and under seal to each relevant court to request modification of the respective protective orders to permit compliance with the Subpoenas. (A. 91). In or about April 2019, one court (“Court-1”) granted the Government’s applica- tion, and permitted the Government to share Court-1’s order—and only that order, which itself prohibited fur- ther dissemination—to the Recipient.? (A. 91). Subse- 2 The Government notes that this entire litiga- tion took place months before Judge Preska was as- signed to handle Giuffre v. Maxwell on July 9, 2019. DOJ-OGR-00019618