DOJ-OGR-00019594.pdf

Case 20-3061, Document 69, 09/28/2020, 2940206, Page3 of 15 other unsealing requests and Ms. Maxwell's intended motion to stay the unsealing process, all without the benefit of knowing information relevant to those decisions). Finally, the exercise of jurisdiction here adheres to the purposes of the collateral order doctrine. The validity of the order can be assessed now without waiting until the trial is complete, and nothing about this appeal delays the criminal case. Alternatively, for the reasons given below, this Court can exercise mandamus jurisdiction to correct the district court's clear abuse of discretion. Argument I. This Court has jurisdiction under the collateral order doctrine. This Court has jurisdiction under the collateral order doctrine to review a district court decision declining to modify the protective order. Pichler v. UNITE, 585 F.3d 741, 746 n.6 (3d Cir. 2009) (“We have jurisdiction under the collateral order doctrine to review the denial of the motion to modify the Protective Order and the denial of the motion to reconsider.”); Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 742 (2d Cir. 1987) (denial of motion to modify protective order is immediately appealable under the collateral order doctrine) (citing Cohen v. Beneficial Indus. Loan Corp., 337 U.S. 541, 545–47 (1949)); see also Brown v. 2 DOJ-OGR-00019594