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Case 1:20-cr-00330-AJN Document 51 Filed 09/02/20 Page 4 of 5

3. In February 2019, the Government, ex parte and under seal, sought modification of
those civil protective orders so as to permit compliance with the criminal grand jury
subpoenas;

4. In April 2019, one court (“Court-1”) permitted the modification and, subsequently,
another court (“Court-2”) did not;

5. That as a result of the modification of the civil protective order by Court-1, the
Recipient turned over to the Government certain materials that had been covered by
the protective order; and

6. That the Defendant learned of this information (sealed by other courts) as a result of
Rule 16 discovery in this criminal matter.

With the exception of identifying the relevant judicial decision makers and specific civil
matters, all of the information listed above is available in the public record, including in the letter
filed on the public docket by the Government on this issue. See Dkt. No. 46. Although this
Court remains in the dark as to why this information will be relevant to those courts, so that
those courts can make their own determination, to the extent it would otherwise be prohibited by
the protective order in this matter, the Court hereby permits the defendant to provide to the
relevant courts under seal the above information, including the information identifying the
relevant judicial decision makers and civil matters.

In addition, the Government has indicated that “there is no impediment to counsel
making sealed applications to Court-1 and Court-2, respectively, to unseal the relevant
materials.” Dkt. No. 46 at 3 n.5. In her reply, the Defendant asserts that she is amenable to such
a solution if the Court agrees with the Government that doing so would not contravene the
protective order in this case. To the extent it would otherwise be prohibited by the protective

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