Assented-To Motion for Protective Order — United States v. Sniders Jean-Jacques et al. (Dkt. 44)

Summary

The government's Assented-To Motion for Protective Order, Document 44, filed March 5, 2026 in United States of America v. Sniders Jean-Jacques, German Olivo, Jim Kelly Michel, Tanya Pierre and Rosalie Clement-Jackson, Criminal No. 26-10030-RGS-JCB, in the United States District Court for the District of Massachusetts. The government asks the court to enter a protective order so it can produce evidence to the defendants while protecting confidential information, including Social Security numbers, dates of birth and bank account numbers. It states that redaction is infeasible given the quantity and nature of the materials, and moves under Rule 16 and Local Rules 7.2 and 116.6. A Local Rule 7.1 certification states that counsel for defendants assents. Assistant U.S. Attorney Kristen A. Kearney signs it /s/.

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       Case 1:26-cr-10030-RGS          Document 44        Filed 03/05/26     Page 1 of 3




                            IN THE UNITED STATES DISTRICT COURT
                             FOR THE DISTRICT OF MASSACHUSETTS


                                                  )
      UNITED STATES OF AMERICA                    )
                                                  )
                v.                                )   Criminal No. 26-10030-RGS-JCB
                                                  )
      (1) SNIDERS JEAN-JACQUES,                   )
      (2) GERMAN OLIVO,                           )
      (3) JIM KELLY MICHEL,                       )
      (4) TANYA PIERRE, and                       )
      (5) ROSALIE CLEMENT-JACKSON,                )
                                                  )
                        Defendants                )
                                                  )

                     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 2 of 3




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

                                                 2
        Case 1:26-cr-10030-RGS           Document 44        Filed 03/05/26      Page 3 of 3




                                 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




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