Assented-To Motion for Protective Order — United States v. Sniders Jean-Jacques, et al. (D. Mass.)

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U.S. District Court for the District of Massachusetts · No. 1:26-cr-10031-RGS · Doc. 38 · 2026-03-05 · Docket on CourtListener

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IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MASSACHUSETTS 
 
 
 
UNITED STATES OF AMERICA 
 
 
 
v. 
 
(1) SNIDERS JEAN-JACQUES,  
(2) LORNE JOHNSON,  
(3) TANYA PIERRE, and 
(4) ASHLEY SPIKE 
 
 Defendants 
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Criminal No. 26-10031-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 
witnesses, defendants, and unindicted co-conspirators.  As grounds for this motion, the 
government states as follows: 
The indictment alleges that the defendants conspired to obtain Paycheck Protection 
Program (“PPP”) loans for dozens of borrowers by submitting fraudulent PPP loan applications to 
PPP lenders in which they fraudulently stated the borrowers’ gross income and created fake 
Schedule C forms to substantiate the claimed income.  As part of its investigation, the government 
has, among other things, (1) obtained PPP loan records for hundreds of borrowers (“the 
Borrowers”), which comprise more than 6,300 separate files; (2) collected the Borrowers’ tax 
returns filed with the Internal Revenue Service (“IRS”); (3) obtained records, including the 
Borrowers’ tax forms, from the tax preparation software company defendants used to create the 
fake Schedule C forms; (4) executed a search warrant on the iCloud account of defendant Sniders 
Jean-Jacques, which includes multiple chats in which co-conspirators exchange bank statements 
Case 1:26-cr-10031-RGS     Document 38     Filed 03/05/26     Page 1 of 3

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as well as personal identifying information of themselves and victims; and (5) executed search 
warrants that led to the collection of five cell phones from Sniders Jean-Jacques.   
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—in particular, the Borrowers’ tax returns 
filed with the IRS—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 the PPP loan files and chats between co-conspirators, the quantity and 
nature of the remaining materials subject to discovery in this case make redaction of these other 
materials infeasible.   
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 Borrowers’ tax returns filed with the 
IRS 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 
 
 
 
 
 
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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-10031-RGS     Document 38     Filed 03/05/26     Page 3 of 3

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