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Case 20-3061, Document 94, 10/08/2020, 2948481, Page18 of 23 “the Government had charged her with perjury in connection with civil cases.” Ans.Br. 23 n.7. But knowing that the government had copies of her depositions is a far cry from knowing [Ss eee Vis. Maxwell’s original consent to the criminal protective order is irrelevant to this appeal. The government next argues that Ms. Maxwell has not offered a “coherent explanation of how the criminal discovery materials could have any conceivable impact on the issues pending in civil litigation.” Ans.Br. 24. To the contrary, Ms. Maxwell has repeatedly explained why the criminal discovery is relevant to Judge Preska and the panel of this Court reviewing Judge Preska’s order. Op.Br. 26-33. In addition to the reasons identified above, This Brief, supra at 7-10, Judge Preska simply never had before her the full picture when deciding whether to unseal the deposition material. So Judge Preska never considered the government’s position that the sealed material should not be released because it might prejudice the ongoing investigation. Nor did she consider Judge Nathan’s view, embodied in modification of the criminal protective order is fully consistent with that purpose, because she seeks only: (1) to share relevant information with Judge Preska; (2) under seal; (3) iS ; and (4) to facilitate Judge Preska in performing a non-merits task assigned to her by this Court. 15 DOJ-OGR-00019664