Case 1:18-cr-10364-DPW Document 101 Filed 02/07/20 Page 1 of 2

UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA )

) Criminal No. 18-10364-DPW
v. )
)
(1) JASIEL F. CORREIA, II, and )
(2) GENOVEVA ANDRADE, )
)
Defendants )

ASSENTED-TO MOTION TO AMEND PROTECTIVE ORDER

The United States of America, by and through the undersigned Assistant United States

Attorneys, with the assent of counsel for both defendants, hereby moves to amend the existing

protective order in this case, ECF Dkt. No. 27, to allow the government to share certain materials

with the Massachusetts Cannabis Control Commission (“CCC”) so that the CCC can perform its

legitimate regulatory duties. In support of this motion, the government states as follows:

1. On December 11, 2018, on joint request by the parties, U.S. Magistrate Judge Cabell
entered the existing protective order in this case. See ECF Dkt. No. 27. In pertinent
part, that order states that, “[t]he discovery materials and information contained therein
shall be used solely for the purpose of litigating matters in this case and shall not be
divulged to any other person.”

2. The government has received a request from the CCC to, in the performance of its
legitimate regulatory duties, review information in the government’s possession that is
currently subject to the protective order in this case.

3. In accordance with 935 CMR 500.000 and 935 CMR 501.000, the CCC may revoke or
suspend a license if an individual or entity associated with a marijuana establishment
or medical marijuana treatment center has committed, permitted, aided, or abetted any
illegal practices in its operations, and may take other appropriate administrative or
enforcement actions.

4. Specifically, the CCC has requested permission to review the interview reports of the
individuals identified in the Second Superseding Indictment as MJ Vendor #1, MJ
Vendor #2, MJ Vendor #3, MJ Vendor #4, and MJ Vendor #5 (hereinafter, “the
protected information”).
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5. Through counsel, the CCC has read and understands the proposed Amended Protective
Order. The CCC understands that it is permitted to use the protected information in the
performance of its legitimate regulatory duties. This includes the CCC making public
disclosures that, in sum and substance, in its interactions with law enforcement
officials, it has not identified any concerns regarding suitability for
licensure. However, to the extent that the CCC believes explicit disclosure of the
protected information is necessary, the CCC agrees to seek this Court’s permission
before disclosing such information.

6. Through counsel, both defendants assent to this motion.

7. Attached hereto is a proposed Amended Protective Order, including an

Acknowledgement of Protective Order executed by General Counsel for the CCC.

Respectfully submitted,

ANDREW E. LELLING
United States Attorney

By: /s/ Zachary R. Hafer

Zachary R. Hafer
David G. Tobin
Assistant U.S. Attorneys

CERTIFICATE OF SERVICE

I hereby certify that this document filed through the ECF system will be sent electronically
to the registered participants as identified in the Notice of Electronic Filing.

/s/ Zachary R. Hafer

Zachary R. Hafer
Assistant U.S. Attorney
Date: February 7, 2020
 Case 1:18-cr-10364-DPW Document 101-1 Filed 02/07/20 Page 1 of 2

UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA )

) Criminal No. 18-10364-DPW
v. )
)
(1) JASIEL F. CORREIA, II, and )
(2) GENOVEVA ANDRADE, )
)
Defendants )

[DRAFT] AMENDED PROTECTIVE ORDER

An assented-to motion having been made by the government for an amended protective

order in this case, it is hereby ORDERED that:

As to any discovery materials produced by the government to the defendant during the

discovery process in this case, defense counsel may question or confront potential witnesses about

matters or information contained in the discovery materials produced by the government, and may

disclose such materials and their contents to the defendant and to those members of defense

counsel’s staff who are necessary to assist counsel in this case. The discovery materials and

information contained therein shall be used solely for the purpose of litigating matters in this case

and shall not be divulged to any other person, except that the government may disclose the

interview reports of the individuals identified in the Second Superseding Indictment as MJ Vendor

#1, MJ Vendor #2, MJ Vendor #3, MJ Vendor #4, and MJ Vendor #5 (hereinafter, “the protected

information”) to the Massachusetts Cannabis Control Commission (“CCC”) so that the CCC can

perform its legitimate regulatory duties.

The CCC understands that it is permitted to use the protected information in the

performance of its legitimate regulatory duties. This includes the CCC making public disclosures

that, in sum and substance, in its interactions with law enforcement officials, it has not identified
 Case 1:18-cr-10364-DPW Document 101-1 Filed 02/07/20 Page 2 of 2

any concerns regarding suitability for licensure. However, to the extent that the CCC believes

explicit disclosure of the protected information is necessary, the CCC agrees to seek this Court’s

permission before disclosing such information.

This Order does not apply to any such materials that are already in the public record.

_____________________________
HON. DOUGLAS P. WOODLOCK
United States District Judge

Dated:

Acknowledgment of Protective Order

I, Christine Baily, declare that I have read and understood the attached draft Amended
Protective Order in United States v. Correia et. al., 18-10364-DPW, and agree to be bound by its
terms. I understand that if I violate the terms of this Amended Protective Order I may be liable for
contempt of court.

/s/ Christine Baily

Christine Baily, Esq.
General Counsel
Mass. Cannabis Control Commission

Date: February 7, 2020