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Case 20-3061, Document 82, 10/02/2020, 2944267, Page23 of 37

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“issue is finally resolved and is independent of the is-sues to be tried, and the order becomes moot if review awaits conviction and sentence.” Flanagan, 465 U.S. at 266. Unlike a request for bail reduction, however, an order denying modification of a protective order does not become moot upon conviction and sentence.

“The standard for review set forth in Flanagan is not easily met,” and Maxwell has not done so here. Ca-parros, 800 F.2d at 25. To the extent Maxwell still wishes to use materials she obtained through criminal discovery for other purposes after entry of final judg-ment in the criminal case, she can seek authorization from this Court to do so then. If Maxwell complains that her inability to use criminal discovery materials in civil matters may result in premature unsealing or prejudicial pretrial publicity, she can likewise raise those claims before this Court on appeal after entry of final judgment in her criminal case. See, e.g., United States v. Martoma, No. 13-4807, 2014 WL 68119, at *1 (2d Cir. Jan. 8, 2014) (concluding that even though the defendant’s “personal interest in the privacy of embar-rassing information is an interest that, as a practical matter, cannot be vindicated after disclosure,” that in-terest is insufficient to merit interlocutory appeal); United States v. Guerrero, 693 F.3d 990, 998 (9th Cir. 2012) (finding no jurisdiction over defendant’s inter-locutory appeal from unsealing of competency evalua-tion because “any alleged incursions on criminal de-fendants’ rights to privacy and a fair trial do not ren-der the unsealing order effectively unreviewable on ap-peal”); Hitchcock, 992 F.2d at 238-39 (district court’s refusal to seal documents not immediately appealable because “[r]eversal after trial, if it is warranted, will

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