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Case 20-3061, Document 82, 10/02/2020, 2944267, Page15 of 37 following final judgment on the merits. In a criminal case[,] the rule prohibits appellate review until convic- tion and imposition of sentence.” Flanagan v. United States, 465 U.S. 259, 263 (1984); accord United States v. Aliotta, 199 F.3d 78, 81 (2d Cir. 1999). As the Su- preme Court has “long held,” the “policy of Congress embodied in this statute is inimical to piecemeal ap- pellate review of trial court decisions which do not ter- minate the litigation, and ... this policy is at its strongest in the field of criminal law.” United States v. Hollywood Motor Car Co., 458 U.S. 263, 265 (1982); see also Flanagan, 465 U.S. at 270 (noting “overriding pol- icles against interlocutory review in criminal cases” and that “exceptions to the final judgment rule in crim- inal cases are rare”); United States v. Culbertson, 598 F.3d 40, 46 (2d Cir. 2010) (recognizing that “undue li- tigiousness and leaden-footed administration of jus- tice, the common consequences of piecemeal appellate review, are particularly damaging to the conduct of criminal cases’). There is a limited exception to this rule that per- mits immediate appeal from certain collateral orders. See Coopers & Lybrand v. Livesay, 437 U.S. 463, 467- 68 (1978) (citing Cohen v. Beneficial Indus. Loan Corp., 337 U.S. 541 (1949)). To fall within the “small class” of decisions that constitute immediately appeal- able collateral orders, the decision must “(1) conclu- sively determine the disputed question, (2) resolve an important issue completely separate from the merits of the action, and (38) be effectively unreviewable on ap- peal from a final judgment.” Van Cauwenberghe, 486 USS. at 522. DOJ-OGR-00019622