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Case 20-3061, Document 82, 10/02/2020, 2944267, Page16 of 37 10 The Supreme Court has made clear that the collat- eral order exception should be “interpreted ... with the utmost strictness in criminal cases.” Midland Asphalt Corp. v. United States, 489 U.S. 794, 799 (1989); accord United States v. Robinson, 473 F.3d 487, 490 (2d Cir. 2007). In over 70 years since Cohen was decided, de- spite “numerous opportunities” to expand the doctrine, Midland Asphalt, 489 U.S. at 799, the Supreme Court has identified only four types of pretrial orders in crim- inal cases as satisfying the collateral-order doctrine: an order denying a bond, see Stack v. Boyle, 342 U.S. 1 (1951); an order denying a motion to dismiss on Double Jeopardy grounds, see Abney v. United States, 431 U.S. 651 (1977); an order denying a motion to dismiss under the Speech or Debate Clause, see Helstoski v. Meanor, 442 U.S. 500 (1979); and an order permitting the forced administration of antipsychotic drugs to render a defendant competent for trial, see Sell v. United States, 539 U.S. 166 (2003). In contrast, the circum- stances in which the Supreme Court has “refused to permit interlocutory appeals” in criminal cases have been “far more numerous.” Midland Asphalt, 489 U.S. at 799. As to the third Van Cauwenberghe criterion, “[a]n order is effectively unreviewable where the order at is- sue involves an asserted right the legal and practical value of which would be destroyed if it were not vindi- cated before trial.” United States v. Punn, 737 F.3d 1, 5 (2d Cir. 2013). “The justification for immediate ap- peal must ... be sufficiently strong to overcome the usual benefits of deferring appeal until litigation con- cludes.” Mohawk Indus., Inc. v. Carpenter, 558 U.S. 100, 107 (2009). A ruling that is burdensome to a party DOJ-OGR-00019623