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Case 20-3061, Document 94, 10/08/2020, 2948481, Page11 of 23 ES And Ms. Maxwell’s deposition testimony in the civil case provides the substantive basis for two of the six charges she faces. App. 27-29. As explained in Ms. Maxwell’s opening brief, Doc. 60, her motion to consolidate, Doc. 17, and the reply in support, Doc. 54, For example, in balancing the qualified First Amendment presumption of access (a presumption that is significantly less as applied to the deposition material than the summary judgment material this Court released in Brown v. Maxwell), Judge Preska and this Court must evaluate countervailing considerations including, most prominently, Ms. Maxwell’s reliance on the civil protective order. Giuffre v. Maxwell, No. 20-2413, Doc. 40, pp 21-23. ee Vis. Giuffre’s attorneys repeatedly used the existence of the civil protective order to deflect Ms. Maxwell’s arguments about her right to privacy, her right against self-incrimination, and her concern that Ms. Giuffre would use documents in the civil action to support a criminal investigation. Guffre v. Maxwell, No. 20-2413, Doc. 111, p 20. Ms. Maxwell then did not invoke her Fifth Amendment right to remain silent and instead testified at two depositions. Jd. DOJ-OGR-00019657