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Case 20-3061, Document 82, 10/02/2020, 2944267, Page12 of 37 quently, the second court (“Court-2”) denied the Gov- ernment’s application.® (A. 91). Because the relevant grand jury investigation remains ongoing, both Court- 1 and Court-2 have ordered that the filings regarding the Subpoenas remain under seal, except that both have expressly permitted the Government to produce those filings to Maxwell as part of its discovery obliga- tions in this criminal case. (A. 91). After providing that factual background, the Gov- ernment argued that Maxwell’s motion should be de- nied for failing to show good cause to modify the Pro- tective Order for several reasons. First, Maxwell had consented to the portions of the Protective Order that prohibit use of criminal discovery materials produced by the Government in any civil litigation. (A. 91-92). Second, Maxwell had cited no authority to support the argument that a criminal defendant should be permit- ted to use criminal discovery in civil cases. (A. 98). Third, Maxwell utterly failed to explain how the crim- inal discovery materials at issue supported any legal argument she wished to make in civil litigation. (A. 94). The Government also noted that to the extent Maxwell sought to challenge the process by which the Government sought compliance with the Subpoenas and obtained certain materials that it intended to use in prosecuting its criminal case, she would have a full 3 The Government notes that Court-1 granted the Government’s application first, and then the Govern- ment provided a copy of Court-1’s decision to Court-2. Court-2 then denied the Government’s application. (A. 207-37). DOJ-OGR-00019619