Joint Initial Status Report — United States v. Jean-Jacques

Record facts

U.S. District Court for the District of Massachusetts · No. 1:26-cr-10030-RGS · Doc. 48 · 2026-03-24 · Docket on CourtListener

Summary

A joint initial status report under Local Rule 116.5(a), filed March 24, 2026 as Doc. 48 in United States v. Sniders Jean-Jacques, German Olivo, Jim Kelly Michel, Tanya Pierre and Rosalie Clement-Jackson, No. 1:26-cr-10030-RGS, in the U.S. District Court for the District of Massachusetts. It reports that the government made a first discovery production on March 24, 2026 of more than 15,000 pages, including mortgage loan files and text chats, and expects further rolling productions on or about April 30, 2026 and May 29, 2026. The report notes a protective order at Dkt. 45 and sets expert disclosures at 60 days before trial for the government and 30 days for the defendants. It states that 70 days remain on the Speedy Trial clock and asks for an interim status conference in about 60 days, with time excluded under 18 U.S.C. § 3161(h)(7).

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

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 
) 
) 
) 
) 
) 
) 
) 
) 
) 
) 
) 
 
 
 
 
Criminal No. 25-10030-RGS-JCB 
 
 
JOINT INITIAL STATUS REPORT 
 
Pursuant to Local Rule 116.5(a), the United States and defendants Sniders Jean-Jacques, 
German Olivo, Jim Kelly Michel, Tanya Pierre, and Rosalie Clement-Jackson state as follows: 
(1) 
Status of Automatic Discovery and Pending Discovery Requests 
 
At the defendants’ respective arraignments, the government notified the Court of the 
complex nature of the discovery in this matter and the need for rolling productions.  On March 24, 
2026, the government made its first production, comprising more than 15,000 pages of automatic 
discovery and an index of the discovery. This production consisted of about half of the mortgage 
loan files the government has collected, search materials, and text chats between co-conspirators, 
among other items.  The government anticipates making its next rolling production on or about 
April 30, 2026, which will include the remaining mortgage files in the government’s possession, 
as well as additional text chats and apartment rental files. 
 
The government has requested reciprocal discovery under Fed. R. Crim. P. 16(b) and Local 
Rule 116.1(d).  There are no other pending discovery requests.   Defendants have not yet produced 
any discovery to the government. 
 
 
Case 1:26-cr-10030-RGS     Document 48     Filed 03/24/26     Page 1 of 5

2 
 
(2) 
Timing of Any Additional Discovery To Be Produced 
 
As noted above, the government anticipates making a supplemental production on or about 
April 30, 2026, which will include the remaining mortgage files in the government’s possession, 
as well as additional text chats and apartment rental files.  The government anticipates a further 
rolling production on or about May 29, 2026, with borrowers/renters’ true bank statements.  
Additionally, the government is still processing and reviewing electronic devices obtained during 
the execution of search warrants on defendant Jean-Jacques’s person and residence and Jim Kelly 
Michel’s person and will produce these materials on a rolling basis as they are processed and 
reviewed.  The government is additionally collecting body camera footage from defendants’ 
arrests.  The government will provide additional discovery as it is received and processed pursuant 
to Local Rule 116.7.   
(3) 
Timing of Any Additional Discovery Requests 
 
Defendants are reviewing the materials produced thus far and have no current plans to 
make a discovery request, but reserve their rights to do so after having reviewed all the automatic 
and supplemental discovery produced by the government. 
(4) 
Protective Orders 
 
There is a protective order currently in place.  See Dkt. 45. 
(5) 
Pretrial Motions Under Fed. R. Crim. P. 12(b) 
 
Defendants propose to file any motions under Fed. R. Crim. P. 12(b) at a time set at an 
interim status conference. 
 
 
Case 1:26-cr-10030-RGS     Document 48     Filed 03/24/26     Page 2 of 5

3 
 
(6) 
Timing of Expert Disclosures 
 
Should expert testimony prove necessary, the government agrees to make the requisite 
expert witness disclosures 60 days before trial, and the defendants agree to make reciprocal expert 
disclosures 30 days before trial. 
(7) 
Speedy Trial Act Calculation 
 
The Court excluded all time between defendants’ respective initial appearances in this 
District and March 31, 2026 from the Speedy Trial clock.  See Dkts. 30, 33, 36, 41.  Accordingly, 
on the date of the scheduled status conference, no non-excludable delays will have elapsed, and 
70 days will remain on the Speedy Trial clock. 
(8) 
Timing of an Interim Status Conference 
 
The parties request that the Court convene an interim status conference in approximately 
60 days to give the defendants and their counsel sufficient time to review the discovery 
productions, including the forthcoming rolling productions.  The parties ask the Court to exclude 
the period until that conference under 18 U.S.C. § 3161(h)(7) in order that the defendants may 
have adequate time to review discovery and formulate a discovery plan, if necessary.  The 
defendants agree to exclude the time between March 31, 2026, and the date of the interim status 
conference from the Speedy Trial calculation.   
 
In light of the status of the case, the parties agree that an initial status conference is 
unnecessary and request that the Court issue an order cancelling the initial status conference. 
 
Respectfully submitted, 
Respectfully submitted, 
 
LEAH B. FOLEY 
SNIDERS JEAN-JACQUES 
United States Attorney 
 
By: /s/ Kristen A. Kearney 
 
By: /s/ Jane Peachy  
 
 
 
KRISTEN A. KEARNEY 
JANE PEACHY  
 
 
Assistant U.S. Attorney 
Peachy Hackett & Sunderland 
Case 1:26-cr-10030-RGS     Document 48     Filed 03/24/26     Page 3 of 5

4 
 
 
88 Broad Street, Suite 101 
 
Boston, MA 02110 
 
 
 
 
GERMAN OLIVO 
 
 
By: /s/ Ian Gold 
 
 
 
 
IAN GOLD 
 
Law Office of Ian Gold 
 
185 Devonshire Street, Suite 302 
 
Boston, MA 02110 
 
 
 
JIM KELLY MICHEL 
 
 
By: /s/ Paul J. Garrity 
 
 
 
PAUL J. GARRITY 
 
Law Office of Paul Garrity 
 
14 Londonderry Road 
 
Londonderry, NH 03053 
 
 
 
TANYA PIERRE 
 
 
By: /s/ Mark W. Shea 
 
 
 
MARK W. SHEA 
 
Shea & LaRocque, LLP 
 
88 Broad Street, Suite 101 
 
Boston, MA 02110 
 
 
 
 
ROSALIE CLEMENT-JACKSON 
 
 
By: /s/ Lorenzo Perez 
 
 
 
LORENZO PEREZ 
 
Law Office of Lorenzo Perez 
 
One Boston Place, Suite 2600 
 
Boston, MA 02108 
 
 
 
Date:  March 24, 2026 
 
 
 
 
 
Case 1:26-cr-10030-RGS     Document 48     Filed 03/24/26     Page 4 of 5

5 
 
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 24, 2026 
 
 
 
/s/ Kristen A. Kearney  
 
 
 
 
 
 
 
 
Kristen A. Kearney 
Case 1:26-cr-10030-RGS     Document 48     Filed 03/24/26     Page 5 of 5

File and source

File

gov.uscourts.mad.295477.48.0.pdf

Size

153,925 bytes

SHA-256

0511440315fd50e5b2f66966fbb9755df1ab00ef58133455ad269666587d5d71

Our copy

gov.uscourts.mad.295477.48.0.pdf

Original

PACER (login required)