Assented-To Motion for Protective Order — United States v. Sniders Jean-Jacques et al. (Dkt. 38)

Summary

An Assented-To Motion for Protective Order, Document 38, filed March 5, 2026 by the government in United States v. Sniders Jean-Jacques, Lorne Johnson, Tanya Pierre and Ashley Spike, Criminal No. 26-10031-RGS-JCB, in the U.S. District Court for the District of Massachusetts. The government asks for an order that lets it produce evidence while protecting confidential information. It states that it has obtained Paycheck Protection Program loan records comprising more than 6,300 separate files, along with tax returns and records from a tax preparation software company, and that it executed search warrants including one on an iCloud account. The motion cites Rule 16 and Local Rules 7.2 and 116.6, attaches a proposed order, and includes a Local Rule 7.1 certification that counsel assents.

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       Case 1:26-cr-10031-RGS          Document 38       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. 26-10031-RGS-JCB
                                                 )
      (1) SNIDERS JEAN-JACQUES,                  )
      (2) LORNE JOHNSON,                         )
      (3) TANYA PIERRE, and                      )
      (4) ASHLEY SPIKE                           )
                                                 )
                        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

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 2 of 3




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




                                                 2
       Case 1:26-cr-10031-RGS         Document 38       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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