DOJ-OGR-00019653.pdf

--- Page 1 --- **Document Extraction** **Header:** * Case 20-3061, Document 94, 10/08/2020, 2948481, Page7 of 23 **Page Content:** * and how it obtained it (by circumventing this Court's decision in Martindell). * Judge Preska needs that information now, not later, because her order unsealing the deposition material is about to go into effect and because she is poised to decide whether and to what extent to keep unsealing the sealed material in the civil case. * The panel of this Court reviewing Judge Preska's order needs that information now, not later, because it is poised to review Judge Preska's order unsealing the deposition material without the benefit of knowing all the relevant information. And unless this Court is privy to the relevant information, it won't be able to decide whether Judge Preska should reconsider her order given Ms. Maxwell simply asks this Court to review these issues now, before it's too late. * A post-trial appeal will be too late. By that time, if this Court affirms Judge Preska's unsealing order without the benefit of knowing all the facts, Ms. Maxwell's April 2016 deposition will be publicly released. By that time, Judge Preska will have largely if not entirely decided what other material from the civil case should be unsealed. By that time, it will be too late for Ms. Maxwell to seek a stay of the unsealing process and fairly explain why a stay is appropriate. And by that time, there won't be a way to "re-seal" material prematurely released to the **Footer:** * DOJ-OGR-00019653