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Case 20-3061, Document 82, 10/02/2020, 2944267, Page14 of 37 with the appeal currently pending in Giuffre v. Max- well, No. 20-2418. (2d Cir. Dkt. 17). The Government is not a party to the appeal in Giuffre v. Maxwell, which concerns an order issued in a civil case unseal- ing materials that were previously filed under seal. On September 16, 2020, the Government filed a motion to dismiss Maxwell’s appeal for lack of jurisdiction and requested that this Court deny Maxwell’s motion for consolidation (the “Motion to Dismiss’). (2d Cir. Dkt. 37). ARGUMENT POINT I This Court Lacks Jurisdiction To Hear This Appeal As explained in the Government’s Motion to Dis- miss, the final judgment rule precludes jurisdiction over Maxwell’s appeal of the Order. See 28 U.S.C. § 1291. Maxwell fails to explain how the Order falls within the “small class” of decisions that constitute im- mediately appealable collateral orders. See Van Cau- wenberghe v. Biard, 486 U.S. 517, 522 (1988). Accord- ingly, this Court should dismiss Maxwell’s appeal for lack of appellate jurisdiction. A. Applicable Law Title 28, United States Code, Section 1291 ex- pressly limits the jurisdiction of Courts of Appeals to “final decisions of the district courts.” 28 U.S.C. § 1291. “This final judgment rule requires that a party must ordinarily raise all claims of error in a single appeal DOJ-OGR-00019621