DOJ-OGR-00019658.jpg

Case 20-3061, Document 94, 10/08/2020, 2948481, Page12 of 23 repeatedly downplayed the risk of a criminal investigation iii ES Ms. Mewes reliance on the protective order, an unquestionably valid factor weighing against unsealing, is all the more apparent once it is evaluated in its full context. That context now includes: the grand jury investigation; as The information Ms. Maxwell wants to share with Judge Preska and this Court is also relevant to show how the government bypassed Martindell. While this Court (in either appeal) need not pass on the propriety of the government’s conduct, preserving Ms. Maxwell’s right to litigate that issue before Judge Nathan is essential to her due process right to a fair trial. U.S. CONST. amend. V. If the DOJ-OGR-00019658