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Case 20-3061, Document 94, 10/08/2020, 2948481, Page16 of 23 Argument Apart from obscuring the relief Ms. Maxwell actually seeks, the other major feature of the government’s brief is its confusion of the arguments Ms. Maxwell actually makes on the merits. And nothing is more illustrative of the government’s confusion than this fact: The answer brief doesn’t even cite this Court’s decision in Martindell. The closest the government comes to acknowledging Ms. Maxwell’s argument is to say this: “To maintain the integrity of the grand jury investigation and in accordance with both Federal Rule of Criminal Procedure 6(e) and its standard practice, the Government did not notify Maxwell or her counsel of the Subpoenas.” Ans.Br. 5. But standard practice doesn’t justify circumventing a thirty-year-old decision of this Court, which required notice to Ms. Maxwell. Martindell, 594 F.2d at 294; App. 368-69 Moreover, nothing in Rule 6(e) relieved the government of its burden to comply with Martindell by seeking to intervene in the civil case or by otherwise giving Ms. Maxwell notice of the subpoena and an opportunity to move to quash. » « Rule 6(e)(2)(vi) says that “an attorney for the government” “must not disclose a matter occurring before the grand jury.” The Pe «Was not a “matter occurring before the grand jury.” And 13 DOJ-OGR-00019662