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Case 20-3061, Document 82, 10/02/2020, 2944267, Page18 of 37 12 has consistently ruled that protective orders regulat- ing the use of documents exchanged by the parties dur- ing a criminal case are not subject to interlocutory ap- peal. See, e.g., United States v. Caparros, 800 F.2d 23, 24 (2d Cir. 1986) (“We hold that this collateral protec- tive order is not appealable under 28 U.S.C. § 1291 .... ); United States v. Pappas, 94 F.3d 795, 798 (2d Cir. 1996) (“To the extent that the [protective] order imposed restrictions on the parties’ disclosure of mate- rials exchanged in the course of pending litigation, it is not subject to appeal.”); see also H.L. Hayden Co. of N.Y. v. Siemens Medical Sys., Inc., 797 F.2d 85, 90 (2d Cir. 1986) (‘The district court’s denial of modification [of a protective order] does not fall within the ‘collat- eral order’ doctrine of Cohen.”). Because “a litigant does not have an unrestrained right to disseminate in- formation that has been obtained through pretrial dis- covery,” such protective orders do not amount to anim- permissible prior restraint under the First Amend- ment. Caparros, 800 F.2d at 25. Even where a litigant raises a colorable argument that a protective order vi- olates a litigant’s right to release documents outside of criminal litigation, “adjudication of any such right can await final judgment on the underlying charges” be- cause the “purported right at issue is not related to any right not to stand trial.” Jd. at 26. B. Discussion Maxwell’s jurisdictional arguments run afoul of this Circuit’s precedent and offer no justification for including the Order in the “small class” of decisions that constitute immediately appealable collateral or- ders. See Van Cauwenberghe, 486 U.S. at 522. In her DOJ-OGR-00019625