DOJ-OGR-00019425.pdf

Roman Catholic Diocese of Albany, N.Y., 745 F.3d 30, 35 (2d Cir. 2014). All three conditions exist here. First, as elaborated below, Judge Nathan clearly abused her discretion in declining to modify the protective order. Second, Ms. Maxwell has no other adequate means to attain the relief necessary because her request for Judge Preska to reevaluate her unsealing order with the benefit of knowing what everyone else knows [REDACTED] [REDACTED] will become moot once the deposition material is unsealed (as this Court already recognized by staying the unsealing order pending appeal). Finally, it is appropriate for this Court to issue a writ of mandamus because, as explained in Ms. Maxwell's motion to consolidate, the judges in the Southern District of New York have reached inconsistent decisions to prejudice of Ms. Maxwell. And while there is no dispute Ms. Maxwell has the right to appeal Judge Preska's order, [REDACTED] [REDACTED] [REDACTED] And now the government is trying to prevent Ms. Maxwell from [REDACTED] 21