Proposed Protective Order — United States v. Sniders Jean-Jacques et al. (District of Massachusetts)

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Document 39, filed March 6, 2026, is a [Proposed] Protective Order for the criminal case against Sniders Jean-Jacques, Lorne Johnson, Tanya Pierre and Ashley Spike in the U.S. District Court for the District of Massachusetts (No. 1:26-cr-10031-RGS). It is framed on the government's Assented-To Motion for Protective Order and Federal Rule of Criminal Procedure 16(d). Paragraph 2 bars disclosure of discovery materials to anyone other than those assisting the defense, interviewed potential witnesses and potential experts. Paragraph 4 sets conditions for materials marked confidential by the government, including secure review by detained defendants. Paragraph 7 provides that materials are returned to the government or certified destroyed at the end of the proceedings.

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Case 1:26-cr-10031-RGS Document39 _ Filed 03/06/26 Page1of4

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA

V. Criminal No. 26-1003 1-RGS-JCB
(1) SNIDERS JEAN-JACQUES,
(2) LORNE JOHNSON,

(3) TANYA PIERRE, and

(4) ASHLEY SPIKE

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
Case 1:26-cr-10031-RGS Document39 _ Filed 03/06/26 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)

b)

Except as provided below, the defense shall maintain possession of all
copies of the Confidential Discovery Materials. No copy may be Icft 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 matcrials by any detained defendants as
described below.

A copy of this protective order shall be kept with the copies of the
Confidential Discovery Materials at all times.

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
Case 1:26-cr-10031-RGS Document 39 _ Filed 03/06/26 Page 3of4

d)

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 Matcrials 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.

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)

b)

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 solcly for the
purposes of assisting the defense in this case, and not for any commercial
or other purpose; and

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

maintenance, disclosure, and safckecping of the evidence, except that the
Case 1:26-cr-10031-RGS Document 39 _ Filed 03/06/26 Page4of4

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.

N. JENNIFER C. BOAL,
United States Magistrate Judge


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