Grand jury subpoena seeking access to information shielded by a valid protective order.
This document is page 32 of a legal filing (dated Sept 24, 2020) arguing against the unsealing of deposition material. The text contends that unsealing the material would prevent Judge Preska from reconsidering her decision based on new information about how the government obtained the material, and would prejudice Ms. Maxwell's ability to argue before Judge Nathan that perjury counts should be dismissed due to the government's circumvention of the 'Martindell' precedent.
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