DOJ-OGR-00019667.jpg

Case 20-3061, Document 94, 10/08/2020, 2948481, Page21 of 23 though, is obvious: The government wants to shield itself from Ms. Maxwell’s forthcoming motion before Judge Nathan challenging its circumvention of Martindell. This Court should not prejudge the Martindell issue as the government seeks. Conclusion At bottom, when asked to justify why Judge Preska and this Court should remain in the dark, the government offers little more than this: because the protective order says so. But in the face of all the reasons why the relevant judicial decision makers should have all the relevant information, the government’s answer is not good enough. This Court should reverse the district court’s order denying Ms. Maxwell’s motion to modify the protective order. October 8, 2020. 18 DOJ-OGR-00019667