Proposed Protective Order — United States v. Sniders Jean-Jacques et al. (Dkt. 44.1)

Summary

Document 44-1, a [Proposed] Protective Order 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. It is framed as an order on the government's Assented-To Motion for Protective Order under Federal Rule of Criminal Procedure 16(d) and Local Rules 7.2 and 116.6. Its paragraphs would limit the defendants' use of government discovery materials to defending the case and require defense counsel to redact third parties' Social Security numbers, dates of birth and financial account numbers from copies shown to witnesses. It also states that any party may apply to the Court for further relief or modification.

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

      Case 1:26-cr-10030-RGS           Document 44-1          Filed 03/05/26   Page 1 of 4




                            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                   )
                                                     )

                            [PROPOSED] PROTECTIVE ORDER

       Upon consideration of the government’s Assented-To Motion for Protective Order, and

pursuant to Federal Rule of Criminal Procedure 16(d) and Local Rules 7.2 and 116.6, it is hereby

ORDERED that:

       1)      The discovery materials produced by the government in this case may be used by

the defendants, defendants’ counsel, and any experts or employees or agents of defendants’

counsel solely in defense of this case, including any appeal, and for no other purpose and in

connection with no other proceeding.

       2)      The defendants and defendants’ counsel shall not disclose any discovery materials,

directly or indirectly, to any other person except those assisting the defense, persons who are

interviewed as potential witnesses, or potential experts employed during the course of and as

necessitated by the investigation and defense of this case.

       3)      Except in the case of expert witnesses, copies of discovery materials may only be

shown to or played for, but not given to, potential witnesses. Defendants’ counsel shall redact any

                                                 1
      Case 1:26-cr-10030-RGS           Document 44-1        Filed 03/05/26      Page 2 of 4




Social Security numbers, dates of birth, and financial account numbers of third parties from the

copies of materials shown to or played for any witnesses (excluding defendants, subject to the

terms of Paragraph 4, below). However, if the materials shown to or played for a particular

witness contain confidential information belonging to that particular witness, that information need

not be redacted from the materials shown to or played for that witness.

       4)      Defense counsel and their office staff (“the defense”) shall maintain any discovery

materials marked confidential by the government (“the Confidential Discovery Materials”),

including any copies the defense makes, as follows:

               a)      Except as provided below, the defense shall maintain possession of all

                       copies of the Confidential Discovery Materials. No copy may be left in the

                       possession of the defendants, nor may the defendants write down,

                       photograph, or otherwise record the content of the Confidential Discovery

                       Materials. A copy may be left with the Plymouth County Correctional

                       Facility or the Donald W. Wyatt Detention Facility (collectively, “the

                       Facilities”) for secure review of the materials by any detained defendants as

                       described below.

               b)      A copy of this protective order shall be kept with the copies of the

                       Confidential Discovery Materials at all times.

               c)      The only people who may view the Confidential Discovery Materials are

                       the defense, the defendants, and any experts or other trial preparation

                       professionals (“defense professionals”) designated by the defense, as

                       detailed below. Defendants who are not detained may access and view the


                                                 2
      Case 1:26-cr-10030-RGS          Document 44-1        Filed 03/05/26        Page 3 of 4




                      Confidential Discovery Materials solely in the presence (including via

                      remote technology) of the defense (defense counsel or their office staff) and

                      under the direct supervision and control of the defense. Detained defendants

                      may access and view the Confidential Discovery Materials provided to them

                      by their counsel at the Facilities, according to the protocols established by

                      the Facilities for the secure review of evidence by detained defendants,

                      consistent with this Order, including the restrictions in subparagraph 4(a),

                      above.

              d)      In no event shall the defense or the defendants disclose or describe any of

                      the Confidential Discovery Materials to any other person or entity other than

                      the government or this Court, other than under the terms laid out below, or

                      as necessary during a court proceeding, subject to redactions protecting

                      confidential information in accordance with this Court’s Local Rules.

       5)     The defense and the defendants may describe or provide copies of the Confidential

Discovery Materials to any defense professional retained by them, but only if:

              a)      The defense professional signs a copy of this Order, and by doing so, agrees

                      to maintain the Confidential Discovery Materials in accordance with the

                      above procedures as if they were members of the defense and solely for the

                      purposes of assisting the defense in this case, and not for any commercial

                      or other purpose; and

              b)      The procedures outlined above shall govern the defense professional’s use,

                      maintenance, disclosure, and safekeeping of the evidence, except that the


                                                3
      Case 1:26-cr-10030-RGS           Document 44-1       Filed 03/05/26      Page 4 of 4




                       defense professional may maintain the discovery materials at their offices,

                       but only under the same secure conditions provided above.

         6)    Defense counsel shall promptly notify the government and the Court if any

Confidential Discovery Materials are disclosed to anyone not designated by this Order or further

order of the Court, either intentionally or unintentionally. The defendants and any defense

professional shall promptly notify defense counsel of any such disclosures.

         7)    At the end of these proceedings, the defendants, the defense, and the defense

professionals shall return the Confidential Discovery Materials to the government or certify to the

government that the Confidential Discovery Materials have been destroyed.

         8)    Nothing in this Order will preclude any party from applying to the Court for further

relief or for modification of any provision hereof.




Dated:    _______________                     __________________________________________
                                              HON. JENNIFER C. BOAL,
                                              United States Magistrate Judge




                                                 4


File and source

File

gov.uscourts.mad.295478.44.1.pdf

Size

102,066 bytes

SHA-256

fb6107207039d2aa632e7c33cccf627655e3a0d8f2f71a368dc7b85a68db27d2

Our copy

gov.uscourts.mad.295478.44.1.pdf

Original

No public link identified.