Joint Initial Status Report — United States v. Sniders Jean-Jacques et al. (District of Massachusetts) (Document 48)
Summary
A Joint Initial Status Report filed March 24, 2026 under Local Rule 116.5(a) in United States of America v. Sniders Jean-Jacques, German Olivo, Jim Kelly Michel, Tanya Pierre and Rosalie Clement-Jackson, Case 1:26-cr-10030-RGS, in the United States District Court for the District of Massachusetts. It states that the government made its first production on March 24, 2026, comprising more than 15,000 pages of automatic discovery and an index, and anticipates further rolling productions on or about April 30, 2026 and May 29, 2026. It states that a protective order is in place and that the parties request an interim status conference in approximately 60 days, and ask the court to exclude time under 18 U.S.C. § 3161(h)(7). The report bears /s/ signatures for the government and for counsel for the defendants.
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“Joint Initial Status Report — United States v. Sniders Jean-Jacques et al. (District of Massachusetts) (Document 48).”
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Case 1:26-cr-10030-RGS Document 48 Filed 03/24/26 Page 1 of 5
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
)
UNITED STATES OF AMERICA )
)
v. ) Criminal No. 25-10030-RGS-JCB
)
(1) SNIDERS JEAN-JACQUES, )
(2) GERMAN OLIVO, )
(3) JIM KELLY MICHEL, )
(4) TANYA PIERRE, and )
(5) ROSALIE CLEMENT-JACKSON )
)
Defendants
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 2 of 5
(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.
2
Case 1:26-cr-10030-RGS Document 48 Filed 03/24/26 Page 3 of 5
(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
3
Case 1:26-cr-10030-RGS Document 48 Filed 03/24/26 Page 4 of 5
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
4
Case 1:26-cr-10030-RGS Document 48 Filed 03/24/26 Page 5 of 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
5
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