Assented-To Motion for Protective Order — United States v. Jean-Jacques

Record facts

U.S. District Court for the District of Massachusetts · No. 1:26-cr-10030-RGS · Doc. 44 · 2026-03-05 · Docket on CourtListener

Summary

The government's assented-to motion for a protective order, filed March 5, 2026 as Document 44 in United States of America v. Sniders Jean-Jacques et al., Criminal No. 26-10030-RGS-JCB, in the U.S. District Court for the District of Massachusetts. The motion asks the Court to enter an attached proposed order so the government can produce discovery while protecting Social Security numbers, dates of birth and bank account numbers. It states that the indictment alleges bank and wire fraud conspiracy through fraudulent misrepresentations, and that the investigation gathered thousands of pages of loan and rental applications and bank statements, an iCloud account search warrant return, and cell phones. It states redaction is infeasible given the quantity of material, and moves under Rule 16 of the Federal Rules of Criminal Procedure and Local Rules 7.2 and 116.6.

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Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MASSACHUSETTS 
 
 
 
UNITED STATES OF AMERICA 
 
 
 
v. 
 
(1) SNIDERS JEAN-JACQUES,  
(2) GERMAN OLIVO,  
(3) JIM KELLY MICHEL,  
(4) TANYA PIERRE, and 
(5) ROSALIE CLEMENT-JACKSON,  
 
 Defendants 
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Criminal No. 26-10030-RGS-JCB 
 
 
ASSENTED-TO MOTION FOR PROTECTIVE ORDER 
 
The government hereby moves for the entry of a protective order, which will enable the 
government to produce relevant evidence to the defendants while protecting confidential 
information, including the Social Security numbers, dates of birth, and bank account numbers of 
victims, witnesses, defendants, and unindicted co-conspirators.  As grounds for this motion, the 
government states as follows: 
The indictment alleges that the defendants committed bank and wire fraud conspiracy by 
conspiring to obtain money and property, including mortgage loans and apartment leases, through 
fraudulent misrepresentations, including fake paystubs, altered bank statements, fraudulent credit 
histories, and the unauthorized use of Social Security numbers belonging to others.  As part of its 
investigation, the government has, among other things, (1) obtained thousands of pages of 
mortgage loan and apartment rental applications; (2) collected thousands of pages of bank 
statements for victims, defendants, and unindicted coconspirators; (3) executed a search warrant 
on the iCloud account of defendant Sniders Jean-Jacques, which includes multiple chats in which 
co-conspirators exchange bank statements as well as personal identifying information of 
Case 1:26-cr-10030-RGS     Document 44     Filed 03/05/26     Page 1 of 3

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themselves and victims; and (4) executed search warrants that led to the collection of five cell 
phones from Sniders Jean-Jacques and one cell phone from Jim Kelly Michel.   
The government wishes to produce these materials, both in an attempt to move the case 
toward resolution or trial, and to guard against the possibility that the documents contain 
information the defendants might argue is material to their respective defenses.  Because of the 
sensitive nature of the documents in question, however, the government does not wish to produce 
the materials without a protective order.  While the government intends to redact Social Security 
numbers, dates of birth, and bank account numbers from a large swath of discovery materials, the 
quantity and nature of the materials subject to discovery in this case make redaction infeasible.  
Further, in some instances, the Social Security number, date of birth, or bank account number used 
on a particular document are relevant to the charge, making redaction unproductive in those 
instances. 
For those reasons, the government moves, pursuant to Rule 16 of the Federal Rules of 
Criminal Procedure and Local Rules 7.2 and 116.6, for a protective order and proposes that the 
Court enter the order attached.  The proposed protective order differentiates between classes of 
discovery material, with some materials subject to greater restrictions than others.  The proposed 
protective order also defends against the possibility that the disclosure of victim information leads 
to their revictimization, either by defendants or by others to whom documents might be disclosed 
in the absence of a protective order like the one proposed.   
 
 
 
 
 
 
 
      Respectfully submitted, 
 
 
          LEAH B. FOLEY 
          United States Attorney 
 
By:    /s/ Kristen A. Kearney 
          Kristen A. Kearney 
          Assistant U.S. Attorney 
Case 1:26-cr-10030-RGS     Document 44     Filed 03/05/26     Page 2 of 3

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CERTIFICATE OF SERVICE 
I hereby certify that this document, filed through the ECF system, will be sent 
electronically to the registered participants as identified on the Notice of Electronic Filing. 
 
Dated: March 5, 2026  
 
 
 
/s/ Kristen A. Kearney  
 
 
 
 
 
 
 
 
Assistant United States Attorney 
 
 
 
LOCAL RULE 7.1 CERTIFICATION 
 
I certify that I have conferred with counsel for defendants and counsel assents to this 
motion. 
 
Dated: March 5, 2026  
 
 
 
/s/ Kristen A. Kearney  
 
 
 
 
 
 
 
 
Assistant United States Attorney 
Case 1:26-cr-10030-RGS     Document 44     Filed 03/05/26     Page 3 of 3

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