Denied Attorney Access

grievance_form · Apr 15, 2024

DC DOC Inmate Informal Resolution Complaint Form draft by Ryan Nichols regarding Officer Brown interfering with a medical doctor visit over mask compliance. Names Doctor Andre. Complaint about Staff Treatment/Health Care categories.

exhibit · Mar 28, 2024

Brief note documenting 1:30-1:45 PM call to attorney on 3/28/24 regarding upcoming sentencing.

grievance_form · Nov 3, 2022

Rappahannock Regional Jail Inmate Request Form filed by Ryan Nichols (ID 2022-1662, Housing Unit C4/18) dated 11/3/22 requesting permission to take all drawers/papers in property to court with him on Tuesday November 8, 2022 for attorney visit. Received by Officer Bean.

grievance_form · Oct 19, 2022

Page 1 of 3 of Document 172 - Government Second Supplement to Opposition to Motion for Release. In advance of Oct 24 2022 motion hearing. References inventory log from Rappahannock Regional Jail.

grievance_form · Oct 17, 2022

Rappahannock Regional Jail Inmate Request Form #1209691 PROG-0024 — Ryan Nichols (ID #20221663, SSN xxx-xx-4381) Housing Unit C-4/18 dated 10/17/22 requesting access to a computer (secured) to view evidence.com/relativity.com and hard-drive discovery before trial, asking DC DOC help. Received by Officer Lucas 10/18/22 at 1000. Action taken by C/O Pruitt: "We do not allow access to outside.com for any inmate. It is unlikely the hard drive request could be sent to US Marshals. Discovery this is appropriate I will see if we can accommodate this request." Response received by counselor 10/25/22 at 1300.

grievance_form · Oct 14, 2022

Rappahannock Regional Jail Inmate Request Form #1209696 PROG-0024 — Ryan Nichols (ID #20221663, SSN-4381, Housing C-4/18) dated 10/14/22 documenting that from 10/7/22-10/13/22 he lost 680 minutes (11.3 hours) of rec due to assortment of other reasons given that aren't to do with med calls, trays, officers going late, etc. Predicts based on this trajectory he will lose 8 days/month for unlawful incarceration. Requests SORP. Received 10/15/22 by Officer Casey/Gray. Action: Request Denied. Returned to inmate 10/27/22 at 5:35 pm.

grievance_form · Oct 14, 2022

Official Rappahannock Regional Jail Inmate Grievance Form filed by Ryan Nichols (ID 20221683) on 10/14/22 protesting receiving only 30-40 minutes of 2.5-hour recreation time and being locked down 18-20+ hours/day as a federal pretrial detainee, impairing ability to prepare for trial.

grievance_form · Oct 6, 2022

Page 3 of 5 of Doc 169. Includes a photograph of evidence bag with SanDisk USB drive labeled Nichols, COVID-19 vaccination record. Section III argues second drive that Nichols claims disappeared was not operable and returned in 2021.

grievance_form · Oct 6, 2022

Page 4 of 5 of Doc 169. Continues quoting Nichols motion. Notes Nichols asserts in reply brief (ECF 168) and affidavit (ECF 168-4) that he had TWO hard drives on Aug 29 2022. Government requests court deny emergency release.

motion · Sep 30, 2022

Section E: alleges USMS transferred Nichols to moot habeas petition. Argument II.A: thumb drive confiscation is sufficient basis for release under § 3142(i).

grievance_form · Sep 15, 2022

Government characterizes Aug 29 incident as routine 2-week laptop rotation. Sept 5 incident: another inmate allegedly assaulted jail official; pepper spray deployed; Nichols allegedly visible.

grievance_form · Sep 11, 2022

DC DOC Complaint by Ryan Nichols dated 9/11/22 regarding being held in punitive solitary confinement 50+ hours (close to 72) without disciplinary hearing, denied secure call with attorney despite asking. Cites pretrial detainee constitutional right not to be punished until found guilty. Names Deputy Warden Tortura. Cruel and unusual punishment claim.

grievance_form · Sep 9, 2022

Second DC DOC Inmate Complaint Form same date by Ryan Nichols. Documents being placed in administrative segregation/solitary confinement by Lt. Lancaster (Capt. Lancaster) on false allegations, with hard drives containing attorney-client privileged notes, FBI reports, and habeas corpus case information CONFISCATED AND NEVER RETURNED. Major Sixth Amendment / due process violation.

motion · Aug 30, 2022

Argument I.B: Defendant ability to prepare for trial irreparably compromised by raid and confiscation of discovery. Cites United States v. Ali and Barker v. Wingo.

motion · Aug 30, 2022

Details of ERT raid: Corporal Feliciano and officer Stretch covered badges, no body cam. Reference to Exhibit A (email from counsel to DOC). Discusses PTSD aggravation and suicide watch.

motion · Aug 12, 2022

Doc 138 p.8 of 21. Section 2: The Statute is Unconstitutional in Arbitrary Application. Argues 1512(c)(1) and (c)(2) viewed as disjointed via the word "otherwise" (conjunctive adverb), no relation to witness/evidence required. Notes there was not a single witness on January 6; Electoral Count Act never mentions "witness" or "evidence." References Colbert TV crew exception.

exhibit · May 17, 2022

Notes from mental health visit on 5/17/22. Checklist of points raised: family visits & video visits, solitary confinement, sit down in unit, haircuts, aerium mistreatment, change of venue over DC trial, vaccination policies, group therapy lack due to pandemic, feeling hopeless and in despair, just trying to make it through this alive. Asked multiple times how to help mental health treatment, but no help offered.

other · Mar 18, 2022

Page 6: Officer Ugwe admits clippers delivered to C2A and other pods but not theirs; Capt Saunders writes 5 DRs about masks; Guy Reffitt gets clippers via court order, others denied; Sgt Franklin and Ms McCain refuse to add Ryan to haircut list until 3/11 when he is 'called an insurrectionist'; Major Marr brushes off grievance; Marvin T. Buckner from DOC/US Marshals confirms grievance process broken — directs to FOIA Internal Affairs.

grievance_form · Jan 29, 2022

DC DOC Inmate Informal Resolution Complaint Form filed by Ryan Nichols (DCDC# 376795, Unit C2B) on 1/29/22 alleging 6th Amendment violation: phones down 7 days since 1/22/22, unable to communicate with attorney or family during ongoing court case and active motions.

grievance_form · Jan 8, 2022

DC DOC Inmate Informal Resolution Complaint Form filed by Ryan Nichols (DCDC# 376795, Unit C2B) on 1/8/22 regarding undelivered mail/books since Dec 27, 2021. Mail from his wife and attorney sent in November and December never made it to him. Communications department complaint.

grievance_form · Jan 7, 2022

DC DOC IGP Form by Ryan Nichols (DCDC# 376795, C2B) 1/7/22 on Personal Hygiene/Health Care/Communications/Religious Services. IGP# 22020126-551, stamped received Jan 26 2022. About state of his mental health being affected by DC DOC policies as pre-trial detainee. No haircut/shave since arrival March 4, 2021 even though all requirements met. Denied family visits, attorney visits, religious services, banished to solitary confinement despite being fully vaccinated. DOC response 2/8/2022 by M. May references fully vaccinated, modified medical stay-in-place policy, all services approved. Refers to history of housing pre-trial detainees per current modified unit movement, 2 hours out of cell per DOC COVID protocols.

grievance_form · Jan 2, 2022

DC DOC IGP Form (white original) by Ryan Nichols (DCDC# 376795, C-2B) 1/2/22 re Officer/Corporal Menyongai locking inmates out of cells/bathroom 1/2/22 9:30 PM. IGP# 22020126-549, stamped received January. DOC response by K. White 2/2/22 confirms Cpl. Menyongai counseled on importance of opening cells and giving inmates time before lockdown. Inmate Grievance Coordinator signed 2/3/2022. Contrasts with j6s17-013 (pink carbon copy with no response).

exhibit · Oct 19, 2021

Page 2 of jail staff town hall notes. Documents that on Sep 17, Ms Nesbitt wore a Kamala Harris For The People shirt into Pod C2B despite policy against political clothing. Inmates raised concerns about legal visit room shortages, video visitation only on CDF side, and Captain Cobb confirming non-contact visits would be made available.

other · Oct 17, 2021

Dated conditions log for cellblock C-2B: short food portions, religious-service and visitation grievances, Lambert civil-rights ruling on 10/13, attorney/laptop access issues, LT Hines and Annmarie food-delivery dispute.

grievance_form · Oct 15, 2021

Formal Grievance Form filed by Ryan Nichols on 10/15/2021 regarding denial of religious services due to refusing COVID-19 vaccination. Argues unequal treatment vs attorney visits and persecution for unvaccinated status.

letter · Jul 30, 2021

July 30 2021 follow-up letter from Files Harrison P.C. (FR Files Jr) to Ingrid Washington at the DC Correctional Treatment Facility, enclosing an additional flash drive of discovery material for inmate Ryan Taylor Nichols, Case 1:21CR-00117. Companion to j6s7-022 — second drive sent three days later, relevant to the two-drives factual dispute in Doc 169.

letter · Jul 27, 2021

July 27 2021 letter from Files Harrison P.C. (Tyler, TX) attorneys Brett Harrison and F.R. Files Jr to Ingrid Washington, Correctional Treatment Facility, 1901 D Street SE Washington DC 20002. Encloses flash drive of US Attorney discovery for inmate Ryan Taylor Nichols (co-defendant Alex Kirk Harkrider), Case 1:21CR-00117, ahead of Aug 4 status hearing. This is the original transmittal of the discovery drive at issue in Doc 169.

letter

Ryan letter (demand list). "Where is my change of prosecutors? Change of judge? VA Rep? Civil Rights Defense Attorney? Divorce paperwork/identification? Medical & Dental Rep? Why am I being treated like a dog, pig, beast in a cage? "The Final Call"." White-shirt came into cell block yelling about mask, wrote him up for violence & disobedience. Franklin came in playing good cop/bad cop, pulled aside, claimed he put a stop to paperwork. Cites case: "627 F.3d 345 (9th Circuit 2010) United States v. Waters: 3.5 yrs for burning, building & distruction. Crime of violence then reversed conviction. Environment Earth Liberation Front (ELF)(ALF) as well as Vail Colorado Ski Resort burning 10 million." "No plea w/ no lawsuit! Im swing the fuck out of this place!" Heard on news Prince Georges County inmates sued jail for 12 million for no hand soap & face masks. Sick call: spoken to like dog. Another copy of Honorable Louis Farrakhan The Final Call #44 Aug 10 issue. Water break - inmates work together to stop diaphragm break before guards run everyone back into cells.

letter

Page 2 of Ryan Nichols letter detailing DC Jail abuses at 1901 D St SE, Washington DC 20003 — including no visitations, no religious services, no attorney access, prisoners begging for help/water/medical aid through cold metal door windows.

letter

Page 3 of Ryan letter: chained, shackled, slurs continue ("shithead, honkey, cracker, Trumper, threaten"). Describes "The Final Call" newspaper promoting radical Islam, white hate, racial violence, downgrading America — "the entire staff of 98% black read this paper every week." Asks "Where are my civil rights? Where is the ACLU, NAACP, civil rights attorney?" Names guards: Pinky, Hays, C. Adams, McDade, Franklin, Robinson, Armstrong, Holmes, Hauser, Lt. Shumer, Brown — "most female guards dont wear name tape." Describes "Gestapo intimidation techniques / SERE School textbook tactics": pulled from cells (Robinson is ERT boss), May 2021 mean-mugged: "How are you, how are living conditions?...WTF am I suppose to say? Answer incorrectly you go to the hole." March: shackled, two female guards (Hays, Pinky) yelling "Trump Boy, supremist, you people on & on, led down hallway to remote room."

motion

Page 3 of defense argument outline. Lays out the Dupree factors case law for 3142(i) trial-preparation release: cites United States v. Lee (D.D.C. 2020), United States v. Buswell (W.D. La. 2013), United States v. Dupree, 833 F.Supp.2d 241, 246 (E.D.N.Y. 2011). Dupree argued limited phone (300 min/mo), limited monitored email (3) no morning counsel access (4) limited MDC storage (5) no GDC Hedberg database access.

motion

Page 2 of US v. North-based pro se argument. Notes 700+ witnesses called to Jan 6 Select Committee, primetime hearings selectively edited, body-worn camera and CCTV evidence shown to Congress but withheld from defense - argues this is a Brady violation. Accuses Congress of holding a Trial before the trial. Also raises protective-order asymmetry.

letter

Page 4 of Ryan timeline. After ass kicked (j6s11-021 trailing). "How does 300 yrs feel?" Hayes seems to be CDR (cell delivery rep) of the four — pro-Biden, wished Trump would die, on a tangent about being a team player. March-April led to dental cuffed/shackled, random inmates wandering freely, high-fiving guards. Cell hygiene (March-Oct): "I have not been in one cell where it was clean. Human fecal matter & chunks, urine smell in/around/smashed/under beds/in corners. Human snot, dried snot, man spray (semen), jizz, DNA (semen), dried running down walls. Rust from iron work on windows dripping down. Black mold coming from air vents on walls/sink/toilet, rust around beds." March-June handcuffed/shackled to attorney visit while inmates roam free; Hays "Fuck you white boy, ill fuck your ass cracker, fuck you, on & on. Guards laughing." April-May: Dan & I pulled cells once again by ERT & Robinson. "How is it going? Glad your doing well, hope your stay is a pleasant one." Then locked back in cell for another 36 hrs.

grievance_form

Work Performance Comments narrative authored by Sergeant Shawn Franklin, C Building Zone Supervisor at Correctional Treatment Facility (CTF, DC DOC). States inmate Nichols, Ryan, DCDC# 376-795, has been housed in C2B since entering CTF, has been outstanding, natural leader, 100% effort. Since entering CTF, Inmate Nichols hasnt had any adverse action or any Disciplinary Reports for negative institutional behavior. Mentor used daily by uniform and non-uniform staff. Morale booster and counselor. Recommends Nichols be given next position based on excellent work ethic and positive institutional behavior.

motion

Page 4 of defense argument outline. Continues Dupree analysis (Hedberg software unavailable at MDC; attorneys fees). Cites government counter-arguments and additional case law: US v. Acevedo-Baldera (D. Conn. 2020), US v. Stephens, 447 F. Supp. 3d 63, 67 (S.D.N.Y. 2020) where 3142(i) was granted due to pandemic, and US v. Jeffries (E.D. Tenn. 2011) on means short of release.

letter

Page 3 of Ryan timeline: characterizes Farrakhan as "hard core racist Marxist paid for by US tax dollars" teaching there is no god other than Allah, all whites are dogs/pigs/beasts. Slurs documented: white boy, white bitch motherfucker, you people, clown, whites. After attorney visit guards put him in isolation for 10 days, 24hr lockdown, not even COVID-checked. 2:00 AM medical run aborted — when he gets back his legal paperwork is gone. Names guards Pinky, Hays, Armstrong. "Who am I going to tell?"

motion

Page 5 of defense argument outline. Addresses ample time, additional burdens, complexity, expense factors under 3142(i). Argues defendant lost hundreds of pages, must restart strategy, no TV news access, no internet, phone calls cost a fortune, was moved far from DC. States US v. Chressen is irrelevant because it goes to section (g), not (i).

exhibit

Handwritten contact list titled "Contact Info For Jail Suit" - co-plaintiffs/witness pool for a planned civil suit over jail conditions. Includes name, attorney name, phone, and email for: Edward A Florez, Trenton Allen (atty MLAJ), Dorian S Murphy (atty Benjamin Berchot), Larry Chambers II, Shane Ray, Eli Jaramillo, Austin Reeder, and Kimbell Chew. Highly material for compensation case linking other J6 detainees.

other

Handwritten list documenting Sixth Amendment access-to-counsel and access-to-courts barriers at jail: 15-minute calls, expensive non-privileged calls, golfer pencil only, books inspected and approved, no laptop, no law library, scanned mail.

other

Continuation of conditions notes - nearly impossible to use library, constant tablet log-ins, locked-down codes, restricted internet, no Google or search engine, J6 hearings watched, 20-24 hour lights on.

exhibit

Numbered list of takeaways from Jan 6 Select Committee hearings: (1) Rudy Giuliani drunk informing Trump should claim victory on election night (witnessed by house staffers), (2) Trump conned supporters with claims of fraud, (3) Bill Barr re: 2000 Mules metadata, (4) Eugene Goodman testifying against J6ers, (5) White House attorney Hirshmann orderly transition, (6) Body cam footage MPD officer trying to convince protesters it worked, (7) Goggles man Shamen, (8) Sidney Powell admitted to lying about Dominion.

exhibit · Oct 18, 2021

Handwritten essay by Ryan Nichols titled Discovery Delays describing failure to receive discovery for 2.5 months post-arrest, partial discovery thumb drive, internet requirements, and 10+ months in jail with 8 in solitary as of Oct 18 2021.

letter2 pages

Page 3 of handwritten essay listing specific grievances at DC Jail: no attorney access, mail delays, laundry contamination, malnutrition, rust, black mold, broken sinks/toilets, denial of cleaning supplies.

grievance_form2 pages

Handwritten numbered list of 9 grievances after being placed in the hole: hard drive disappeared, no evidence.com access, no meds 48+ hours, denied mental health visits despite ERT direction, sleep deprivation, denied outside counsel, punishment without finding of guilt, motion claims he did not pick up a chair when he admits he did, Officer King referred to him as insurrectionist, no pens/pencils.

letter · Oct 4, 2022

Email dated October 4, 2022 from Ted Hull (Superintendent, Northern Neck Regional Jail) to attorney Jonathan Gross (jonathansgross@gmail.com), cc Michelle Lewis, regarding J6 co-defendant Christopher Quaglin's missing discovery materials. Hull dismissively says he has no interest in resolving the "mystery" of disappeared discovery and offers to swap volumes if too large. Documents jail interference with attorney-client discovery in another J6 case.

letter · Oct 4, 2022

Page of Hull/Gross email thread continued. Ted Hull asserts "A Court of Record has reviewed your client's complaints and found them without merit" regarding Quaglin's habeas corpus motion. Hull refuses further engagement and refers to court ruling. Documents the official position that resulted in further mistreatment of J6 detainee Quaglin.

letter · Oct 4, 2022

Email exchange between J6 defense attorney Jonathan Gross and Northern Neck Regional Jail Superintendent Ted Hull regarding J6 defendant Christopher Quaglin health concerns and missing discovery documents, referencing Judge McFadden.

grievance_form · Apr 20, 2022

DOC PP 4030.1 Informal Resolution Complaint Form filed by Ryan Nichols (DCDC# 376795, Unit C2B) on 4/20/22 in the evening about being asked by Lt Bruce to sign a Non-Animosity/Non-Aggression form regarding Brandon Fellows. DOC response: "Non-grievable - See attached." This is the grievance that was denied in scan 005 (#2209716-259). Stamped RECEIVED APR 25 2022.

exhibit · Apr 16, 2022

Page 9 of timeline. 23-1 lockdown until April 16 when given detail; some days 30 hours in cell. Mail extremely late (March mail in August). No haircut/shave since before arriving March 9. No religious or VA services. Cannot have in-person attorney meeting unless vaccinated; Ryan sent to quarantine 2 weeks of July for in-person with vaccinated attorney. 2 black inmates told us white boys would be treated worse without them. Ryan Samsel beaten March in C2B. Officer Holmes incident with Scott Fairlamb singing God Bless America Fuck America Shut the fuck up.

exhibit · Dec 30, 2021

Typed memo from DC Department of Corrections announcing 117 COVID-19 positive cases tied to Omicron variant and a modified stay-in-place: end of social visits, virtual programming, reduced recreation at CDF and CTF, vaccine/booster push, contact legal visits suspended in favor of unscheduled non-contact and virtual legal visits, mandatory 14-day intake quarantine. Bottom handwritten annotation by Ryan Nichols (Detainee #376795), dated 12/30/21: "This was given to us the day before 22 & 2 lockdown started at DC DOC in December." Found in McHugh’s folder.

letter · Dec 29, 2021

Dated 12/29/21 letter from Sean McHugh to attorney Joseph McBride characterizing public defender Maria Jacob as his "public prosecutor not my public defender." Says Jacob would only consider a "public authority" defense to blame Trump for January 6; rejected the Declaration of Independence as a legal document; encouraged him to take a 92-115 month plea on Assault with a Deadly Weapon (federal officer) because she was "afraid they might use the terror enhancement" for a window-breaking charge. Notes he was charged with assault despite no victim identification or weapon found; the only alleged victim looks like an MPD officer, not a federal officer. The one motion Jacob filed sought investigation into Trump ("TDS — Trump Derangement Syndrome") and omitted his requested Comms between Pelosi, Schumer, Capitol Police, MPD, National Guard & Secret Service in days leading up to and on Jan 6th. Was thrilled when John Pierce took his case so he could fire Jacob.

motion · Dec 29, 2021

Page 5 of pro se IAC motion, dated 12/29/21. Items 15-16: (15) his girlfriend sent Judge Bates emails between him and Maria Jacob; Jacob was upset only because it exposed her, alleging breach of attorney-client privilege "according to Maria" — "We have more emails"; (16) Jacob said "defense of another party is an argument for trial and not to get me out" and that his mother is not a good witness. McHugh writes: "I have NO Defense with Maria as of 12/29/21."

letter · Dec 29, 2021

Handwritten letter from Sean McHugh to attorney Joseph McBride dated 12-29-21, reporting that his appointed counsel Maria Jacob and co-counsel Ms. Schroff (a "terrorist lawyer from NY") have told him McBride is "not credible" and "reckless," and warning that he has a story he plans to publish on Gateway Pundit to support his son financially.

motion · Dec 28, 2021

Page 4 of pro se IAC motion, dated 12/28/21. Items 11-14: (11) at last court date Judge Bates would not let him explain why Maria Jacob was ineffective; counsel later lied in a breakout room about the topic being jail/discovery; (12) Jacob said his mother wouldn’t be a good witness because prosecution would call her biased; (13) Jacob has no defense theory, refuses critical discovery, won’t challenge the DA; (14) Jacob said she represents him not all J6ers, so the Darren Beattie / Revolver entrapment-and-lack-of-security defense is "out of the question."

grievance_form · Nov 17, 2021

Page 2 of Ryan Nichols' Informal Grievance #135251/IGP #22111223-848 dated 11/17/21 — cites Inmate Handbook page 1 number 8 non-discrimination clause, references unresolved 9/18/21 incident, lists J6 co-detainee witnesses, and requests copy for attorney Joseph McBride.

exhibit · Oct 19, 2021

Notes from a 10/19/21 town hall meeting between J6 detainees and DC jail staff. Lists attendees including Debby Clark (case management), Ben Pellorin & Marvin Brown (Aramark), Shirley Smith (litigation), Annisica Point (mailroom), Captain Cobb, Sgt Franklin, Sgt Robinson, Officer Sorwanni. Shane Jenkins opened with prayer. Bryan Mock spoke about issues as pro se attorney; case manager Nesbitt refused to help with motions, phone lists; controversy over a Trump Won case management form.

letter

Letter signed by Timothy L. Hale-Cusanelli (#376441), J6 detainee, listing DC Jail conditions in bullet form. Church Services cannot be accessed/religious material is unavailable or has blatant discrimination. Dietary needs nearly impossible to attain without having a heart attack first. Meals devoid of nutrition, no real protein, rotten vegetables, excessive soy. Water metallic taste, contaminated w/ mold; ventilation contaminated w/ mold. Limited hygiene/grooming, no shaving/haircuts, sewage in showers. Recreation arbitrarily given, often in cells over 24 hrs straight, outdoor rec frequently cancelled. Access to court limited, attorney calls monitored, legal visits blocked, late for court because guards. Legal mail stolen by guards, discovery blocked by staff, grievances opened & read by offending officers. Guards make copies of personal mail and info of loved ones, share inmate court info w/ other guards for fun. "Testimony of physical abuse and threatened sexual abuse expressed by officers and Jail (beating of Ryan Samsel)." Mail and books withheld for weeks-months after safe arrival. Medical treatment withheld after numerous requests, lack of nutrition + exercise caused atrophy ignored despite appointments. Broken door locks fixed overnight but toilets go weeks without repair, toilet floods often fill whole C2B pod up to ankles. Inmate uniforms impossible to get replaced, clothing cheaply made.

affidavit

Timothy Hale veteran statement listing experiences in DC DOC: religious discrimination, ideological repression, no nutrition or gym access, extended solitary, no veterans/mental health services, mail/phone/electronic abuses, denial of legal counsel, mold/insects, targeted political/racial harassment by staff, jailhouse-snitch sabotage, restricted law library, and 1.5 years isolation. Specifically references Ryan Nichols' decline. Signed Timothy Hale #376441.

letter

Letter from J6 detainee Nathaniel DeGrave #376789 titled "Amendment Violations." At Pahrump County Jail in Nevada: subjected to 20 minutes rec time 3 times per week, denied legal calls prior to bond, kept in solitary confinement, retainer thrown out. Taken to solitary confinement for 30 days at DC DOC without cause. Shown photos of Stab Victims. Allowed 1 hr rec at DOC first 60 days. No law library, no video visits, no religious services or classes. 26 hr lockdowns as of today (sic). No haircut for 6 months. 60+ day mail delays. Birthday card returned. No hardcover books, publisher only. No in-person attorney visits or from friends/family. Clothing thrown out. Communication w/ friends/family difficult & expensive. 8 month detainment based off speculation. Poor nutrition, Bologna 5 days/wk. Due Process Violation. "Assault charge but no assault? Pull away door lie. Turned away Congressmen. Govt lies - no body armor."

letter

Letter from J6 detainee Nathaniel DeGrave #376789 titled "Amendment Violations." At Pahrump County Jail in Nevada: subjected to 20 minutes rec time 3 times per week, denied legal calls prior to bond, kept in solitary confinement, retainer thrown out. Taken to solitary confinement for 30 days at DC DOC without cause. Shown photos of Stab Victims. Allowed 1 hr rec at DOC first 60 days. No law library, no video visits, no religious services or classes. 26 hr lockdowns as of today (sic). No haircut for 6 months. 60+ day mail delays. Birthday card returned. No hardcover books, publisher only. No in-person attorney visits or from friends/family. Clothing thrown out. Communication w/ friends/family difficult & expensive. 8 month detainment based off speculation. Poor nutrition, Bologna 5 days/wk. Due Process Violation. "Assault charge but no assault? Pull away door lie. Turned away Congressmen. Govt lies - no body armor."

motion

Continuation of pro se IAC brief with margin annotation noting Maria Jacob waived his time on the 30th day of incarceration absent indictment. Alleges Jacob ran the DA’s PowerPoint at the detention hearing when prosecution’s wouldn’t open — "clearly indicating a conflict of interest and thus virtue signaling she’s playing ball on his team." Notes the DA is from Utah and that prior counsel Lexi Negin traveled to Utah for a week during transition of representation. References July 24 hearing where Maria said she had to waive time because she was not ready and government needed more time, and July 11 conversation about motions she promised to handle.

motion

Caption page of Sean Michael McHugh’s pro se Ineffectiveness of Counsel brief, U.S. District Court for the District of Columbia, Magistrate No. 1:21-MJ-436, labeled "Brief Outline to go into more detail later." Narrative begins by describing first federal defender Lexi Negin (Sacramento) telling him she is a BLM supporter, that if he were black this would be considered assault, and warning him not to fire Maria Jacob "once out in DC." Both Negin and Jacob waived his 30-day indictment rights; Lexi insisted Sacramento judges are "podunk hillbillies" and only DC "do findings." At his 2nd detention hearing, Maria "went out of her way to implicate my guilt without conferring with me."

exhibit

Signed witness statement from inmate Richard Jong Pak (DOB 10/24/70, ID 98201) attesting denial of diabetic medication for 3.5 months, missed 13 video attorney visits, placement in Ad-Seg for 8 months, separation from co-defendants by US Marshals, and witnessing inmates beaten in handcuffs.

motion

Earlier draft (page 1) of Sean McHugh’s ineffective-assistance brief. Top margin: "from the start Lexi told me to admit to alcoholism since I have a DUI." Body alleges federal defender Lexi Negin said she was a BLM supporter, said if he were black it would be considered assault, and warned him not to fire Maria Jacob "in DC else I would look really bad implying I would look racist." Negin told him to exhaust his next detention hearing with Jacob because Sacramento judges are "podunk hillbillies" and DC courts "actually do findings." During 2nd detention hearing, Jacob said things to implicate his guilt without consulting him, told him beforehand to "sit down, shut up and just smile." He felt humiliated.

affidavit

Handwritten witness statement from Sgt Kenneth Harrelson (US Army, ret.) describing 10+ months of hate mail received while detained at DC DOC, postmarked Orlando FL, including harassment of his wife via GiveSendGo and misuse of bible verses.

motion

Page 1 of handwritten pro se motion by Sean McHugh against court-appointed counsel Maria Jacob, alleging ineffective assistance of counsel and gross incompetence. Details begin with point (1): Jacob failed to inform him about the 30-day indictment rule and that he was being held only on a complaint.

letter · Sep 15, 20212 pages

Letter from J6 detainee Alan Byerly #378160. The Final Call newsletter circulated with racist theology calling white people swine/pigs/dogs by Louis Farrakhan. Denied Church/Clergy/Barber unless vaccinated. Food barely edible - dinner 9/15/21 at 8:40pm was 2 hard boiled eggs, 4 pieces bread, scant noodle salad, 4 cookies, tartar sauce. Over half his GTL tablet contacts cant message him, including Power of Attorney and his father. Filed informal complaint - reply said they were blocked but he can check himself. Contact visits with family/attorneys require vaccine or 2-week quarantine - yet same people served papers via outside visitor (rules only when inconvenient). Added 5 new phone numbers, waited 2 days, none worked. At C.D.F. intake told would be PC to get to CTF but sent to quarantine with General Population prisoners. COs blurted out his cell # so other prisoners knew.

letter · Mar 8, 20212 pages

Testimony from Oath Keepers Kelly Meggs (#376780), arrival DC Jail 3/8/21. Religious services denied except 2 periodicals: "Daily Bread" and "The Final Call" (filled with hate of white people, beasts/hogs/dogs/devils, directed toward Muslims). No haircut/beard trim 200+ days, nails not cut 4 months. Locked in cell without shower 4 days after arrival - no contact with family or attorney 96 hours - case manager off until Fri 3/12. CPL Pinky called them "crackers" repeatedly, threatened to send to main jail "to be stabbed because they all hate us." Shackled every time walked out of unit while other jail inmates free to roam. Lockdowns for using "Trump" on grievance forms.

affidavit

Daniel Caldwell (#376977, arrested 3/10/21) veteran statement page 1 listing experiences in DC DOC: hyper-vigilance, hygiene tactics denial, mold in cells/showers, memory loss, total mental breakdown, extended solitary, lack of trial date for 1 year 2 months, denial of Bail v. Brunfardo 2020 (Brunson?), stacked charges, food service failures.

letter

Letter from Shane Jenkins #377186. 11 days no shower at FDC Houston. Early morning military style raid with bull horns, laser beams, armored personnel carrier, both ends of street blocked. No phone 26 days. After 11 days shower only MWF, no free calls, 15 minutes shower MWF only. Filed complaint w/ US Marshalls re inmates calling him "racist ass white boy" "racist ass Trump supporter" - nothing done. February Denver ski trip with church Singles ministry - SSSS on boarding pass, super intrusive pat down, electronics swabbed for explosives, bomb sniffing dog, second-time pulled aside - "humiliated and treated like a terrorist." Transported in black box restraint over cuffs/shackles. In DC denied attorney access weeks, placed in PC against will. Requested chaplain brought Catholic Knights of Malta Bible (not James or NKJV). No church/volunteers - given Farrakhan News letters promoting racism. Law library never accessible. No books/vending in quarantine. Mail held at least 2 months. Northern Neck Regional Jail diet doesnt meet federal guidelines. Witnessed Officer Holmes threaten and run into Scott Fairlamb cell with 3 officers - Fairlamb said "Fuck America" re J6 detainees singing anthem and God Bless America.

motion · Oct 28, 2022

Page 11 of 11 (final page) of Doc 177. McBride contact info continued (phone, email). CERTIFICATE OF ELECTRONIC SERVICE: filed Oct 28, 2022 via CM/ECF by /s/Jonathan Gross.

motion · Oct 28, 2022

Page 5 of 11 of Doc 177. Explains THREE drives at issue: red+blue thumb drives delivered Jul 2021 by Buck Files (prior attorney), black terabyte drive Oct 2021 by McBride. Red drive given to McBride during attorney visit; Officer Solwannii witness with body cam.

motion · Oct 28, 2022

Page 7 of 11 of Doc 177. Begins ARGUMENT section. Point One: Missing hard drive justifies release. Section 3142(i) provides release for defense preparation. Three questions Washington must explain. Sept 5 removal as pretext to steal blue drive.

motion · Oct 28, 2022

Page 10 of 11 of Doc 177. Section 3142(i) factors weigh in favor of release. Government released massive discovery drop including thousands of videos. Cong J6 Committee revealed new footage. CONCLUSION requesting release. Signatures of Jonathan Gross and Joseph D. McBride.

motion · Oct 28, 2022

Page 6 of 11 of Doc 177. Details: Aug 29 confiscation of black terabyte (blue thumb not noticed); Sept 5 someone took blue thumb drive. Rappahannock Jail (now holding Nichols) does not allow electronic discovery review outside attorney visits. Sgt. Foster told Nichols Oct 28 jail aware of Court order.

motion · Oct 28, 2022

Page 8 of 11 of Doc 177. POINT TWO: Government admits current conditions prevent trial preparation - Sixth Amendment violation. Sgt Foster admitted. Extensive footnote: jail deprives rec time, locked in cell, inadequate law library (no internet, no cases past 2017), Foster says Nichols target for filing grievances.

motion · Oct 28, 2022

Page 9 of 11 of Doc 177. US Marshal Lamont Ruffin email (Exhibit C) - US Marshals are primary custodian. Refused Sukkot religious holiday request for 15 min outside. Begins POINT THREE - recent discovery drop and J6 congressional hearings show govt at fault for long detention.

motion · Oct 28, 2022

Page 1 of 11 of Document 177 - Defendant Nichols Supplement to Motion for Pretrial Release. Background section references Aug 30 2022 Emergency Motion (ECF 150), DC Jail hard drive confiscation, Salerno precedent.

letter · Oct 14, 2022

Oct 14 2022 1:17 PM Gmail message from Jonathan Gross (attorney and Jewish rabbi) to Supervisory Deputy US Marshal Derek Haywood (Derek.Haywood@usdoj.gov), cc Joseph McBride. Reports Marshal Ruffin identified Haywood as contact. Says Ryan Nichols (USMS custody at Rappahannock Jail) wants to observe Sukkot (Leviticus 23:44) by having a meal in a Sukkah; Jail denied his 15-minute outside-under-sky request; grievance filed but holiday ends Sunday.

affidavit · Oct 5, 2022

Page 3 of 13 of Washington affidavit. Describes Aug 29 2022 incident where Washington attempted to retrieve discovery laptop and USB drive from Nichols. Nichols refused, became confrontational, other inmates yelled. Other COs retrieved USB drive, returned shortly after.

letter · Oct 3, 2022

Continuation of email from defense attorney Jonathan Gross (The Clevenger Firm, Baltimore MD) re Quaglin: requests neutral third-party food observer for gluten cross-contamination, raises pattern of disappearing discovery documents, attorney visit policies.

motion · Sep 30, 2022

Page 14 of 14 (final page) of Emergency Motion for Release. Contains signatures of Jonathan Gross and Joseph D. McBride, and Certificate of Electronic Service.

motion · Sep 28, 2022

Page 8 of 8. Signed by Joseph D. McBride (McBride Law Firm PLLC, NY) and Jonathan S. Gross (Clevenger Firm, Baltimore MD). Dated September 28 2022 Washington DC. Certificate of service via ECF.

letter · Sep 13, 2022

Email exchange dated Sept 13, 2022 between attorney Jonathan Gross and U.S. Marshal Lamont Ruffin (cc: Joseph McBride, SDUSM Derek Haywood). Marshal Ruffin cites Judiciary Act of 1789 and Title 28 USC for authority over remanded prisoners; refuses to share move policy. Gross challenges sudden transfer of a pretrial detainee without notice to counsel or family.

letter · Sep 13, 2022

Sept 13 2022 12:17 PM email from US Marshal (A) Lamont Ruffin (Lamont.Ruffin@usdoj.gov) responding to attorney Jonathan Gross. Cites Judiciary Act of 1789 and 28 USC, asserts USMS authority over District Court prisoners, refuses to share policy (suggests FOIA), states moves were within policy and movement details not provided to anyone until completed. Designates SDUSM Haywood as contact. Includes Grosss earlier Sept 13 12:06 PM reply asking who is the immediate custodian and to identify the policy authorizing sudden transfer of a pretrial detainee without informing him, counsel, or family.

letter · Sep 12, 2022

Sept 12, 2022 3:15 PM email from Jonathan Gross (The Clevenger Firm) to U.S. Marshal Lamont Ruffin (cc: Joseph McBride). Gross reports learning of activity at the DC Jail involving a possible transfer of Mr. Nichols without notice to attorneys or family; DC Jail counsel deflected to USMS as actual custodians. Requests information about transfer plans.

letter · Sep 12, 2022

Sept 12, 2022 email exchange between Jonathan Gross and Eric S. Glover, General Counsel for DC Department of Corrections (cc: McBride, Andrew Mazzuchelli/DOC). Glover confirms Mr. Nichols, a federal defendant, was picked up by USMS today and is technically in USMS custody; DC DOC does not know where he is being housed.

letter · Sep 12, 2022

Sep 12 2022 3:15 PM email from defense attorney Jonathan Gross (Clevenger Firm) to U.S. Marshals Service Marshal Lamont Ruffin (LRuffin@usms.doj.gov), cc atty Joseph McBride (jmcbride@mcbridelawnyc.com). Reports that an unannounced transfer activity involving Nichols occurred at the DC Jail; DC Jail counsel said Nichols was in US Marshals custody and to contact Ruffin. Demands information on what happened and Marshals plans for Nichols.

motion · Sep 8, 2022

Page 5 of 5 of Motion to Dismiss (Doc 155). Signed Joseph D. McBride Esq., Bar ID NY0403, The McBride Law Firm PLLC, 99 Park Avenue 6th Floor, New York NY 10016, jmcbride@mcbridelawnyc.com. Certificate of Service dated September 8, 2022 via ECF.

motion · Aug 30, 2022

Final page: Argument II proposing wife Bonnie Nichols as third-party custodian. Conclusion seeking immediate release. Signed by Joseph D. McBride of The McBride Law Firm PLLC.

motion · Aug 12, 2022

Doc 138 p.20 of 21. Notes VP Pence Jan 6, 2021 letter calling his role ceremonial. Argues Electoral Count Act revisions add word "ministerial" to solidify no decision-making. Section V Conclusion + WHEREFORE: Nichols moves to dismiss Count Two of Indictment for failure to state offense under 18 U.S.C. 1512(c)(2) and 18 U.S.C. Section 2; and for unconstitutional application of both statutes. Dated August 12, 2022. Signed Joseph D. McBride, Esq.

motion · Aug 12, 2022

Doc 138 p.21 of 21. Final page — Certificate of Service dated 12th day of August 2022, signed by Joseph D. McBride, Esq. ECF System service.

motion · Aug 11, 2022

Page 5 of 5, signature page of Nichols motion in limine. WHEREFORE clause requests exclusion of terms: terrorism, terrorist, insurrection(ist), mob, rioter, treason, traitor, sedition, conspiracy, attack on Capitol/democracy/Congress, white supremacy, police were killed, Oathkeepers, Proud Boys, Three Percenters, areas of Capitol Nichols never entered. Signed by Joseph D. McBride, Esq.

motion · Aug 11, 2022

Page 4 of 4 of Doc 134 Motion to Join Harkrider Omnibus Reply. Certificate of Service signed Joseph D. McBride dated August 11, 2022.

motion · Aug 11, 2022

Doc 137 filed 08/12/22. Nichols (by McBride) moves to adopt co-defendant Alex Harkrider Motion to Compel (ECF 96) regarding viewing, measuring, and inspecting areas of the alleged crimes.

motion · Aug 11, 2022

Page 2 of Doc 129 Motion to Continue trial filed by Joseph D. McBride for Nichols. Cites US v. Bailey 2021 WL 5798045. Notes co-counsel Kira West has no objection, government objects. Signed New York, NY August 11, 2022.

motion · Aug 11, 2022

Page 3 of Doc 134. Cites In re Grand Jury Subpoena 870 F.3d 312 (4th Cir 2017) on opinion work product. Asserts USCP shot first, launched barrage at peaceful protestors, no authorization to fire concussion grenades at faces/heads/torsos. Calls for Court to grant ECF 117 and deny Govts ECF 100-104. Signed Joseph D. McBride 8/11/22.

motion · Aug 11, 2022

Page 3 of 3 of Doc 132 Motion to Join Harkriders ECF 94 motion. Signature page and certificate of service. Signed by Joseph D. McBride dated August 11, 2022. Certificate of Service via ECF system.

motion · Aug 10, 2022

Defendant Ryan Taylor Nichols Motion to Continue, Doc 129, filed 8/10/22 in US v. Nichols (Case 21-cr-00117-TFH). Page 1 of 2. Requests continuance of November 1, 2022 trial date due to defendants recently diagnosed chronic Lyme disease and ongoing Long Covid recovery. References Exhibit A treatment plan filed under seal.

other · Jul 15, 2022

DC Department of Corrections Request for Legal Visit form (PP 4160.3 Att. B) for inmate Ryan Nichols (DCDC #376795, housing C2B) by attorney Joseph McBride, Bar #5445879. Dated 7/15/22 with pink date stamp.

grievance_form · May 10, 2022

DC DOC Informal Resolution Form (IGP # 20220512-290) filed by Ryan Nichols 5/10/22 alleging legal mail, US Mail, legal documents, letters from Congressman and pictures have been lost/stolen/sabotaged from property hold during placement in SMU-A 4/20/22. Demands his legal property and sensitive documents not be seen by DC DOC; if not released should be sent to attorney Joseph McBride.

grievance_form · May 2, 2022

Page 2 of electronic IGP # 2022050-120 dated 5/2/22 - Ryan Nichols reiterates no disciplinary issues since arrest 1/18/21 or arrival 3/9/21, asks for MAX damages in civil court for Solitary Confinement at DC DOC, demands release from DC DOC due to unconstitutional conditions of confinement. Provides attorney Joseph McBride contact 917-757-9537 for settlement.

grievance_form · May 1, 2022

Electronic Informal Grievance Form (IGP # 2022050-120, Response ID 192673) submitted by Ryan Nichols on 5/1/22 at 9:53 PM detailing 3-4 hour water shutoff in cell while cell 9 inmate had medical emergency and threw up. Officers shut water off to punish cell 9 inmate but his water was also shut. Will inform attorney Joseph McBride.

grievance_form · Mar 9, 2022

DC DOC Informal Resolution Complaint Form by Ryan Nichols 3/9/22. Requests his investigative attorney be added to his APDS Tablet because discovery has been shared on the APDS tablet and he needs to share that information with his legal team. On 3/7/22 he requested for his Investigative Attorney to be added but was denied. For his attorney Joseph McBride this is a violation of his 6th Amendment right to counsel. Asks resolution so he can properly prepare for trial.

grievance_form · Mar 7, 2022

Printed DC DOC Inmate Request Form (Response ID 167429) 3/7/22: Ryan asks staff to add investigator David Sumrall (903-355-4683), working for attorney Joseph McBride (917-757-9537) of McBride Law Firm, to his private call list and tablet contacts. Handwritten 'updated 3/8 McCain'.

other · Oct 18, 2021

Single-entry note that Sgt Franklin warned Ryan he has one week left with his laptop & discovery; per attorney Joseph McBride Ryan needs longer, must request through Ms Wilson at general counsel.

exhibit

Handwritten notes by Ryan Nichols for attorney Joseph McBride on pre-trial release arguments. Cites US v. Sinmyah Amera Ceasar (Nos 19-2881(L), 19-2892), an alleged ISIS terrorist released pretrial with ankle monitor, and US v. Melendez ruling pretrial detention based solely on alleged dangerousness unconstitutional past 8 months. Notes Ryan was helping people in the hallway, built a gun box for legal compliance, did not bring weapons into DC, owns RTU search-and-rescue non-profit.

transcript

Page 18 of a federal court hearing transcript. Defense attorney Joseph McBride argues that FBI raided Ryan Nicholss home in Longview while he was in Oklahoma over MLK weekend visiting in-laws; Nichols self-surrendered within four hours, cooperated, was interviewed by FBI, never tried to flee. McBride cites D.C. Circuit decisions U.S. v. Munchel and U.S. v. Tanios on future dangerousness.

motion

Defense attorney working draft / opening statement outline for Nichols motion (likely ECF 150 emergency release / 177/177-1/177-2 supplements). First-person attorney McBride enumerates timeline: FBI surrender Jan 18 2021 in Texas; FTC Oklahoma; DC Jail Mar 2021 - Sept 6 2022; Files & Harrison representation Jan-Aug 2021; thumb drive #1 (red) sent Jul 27 2021 (Ex A ECF 177-1); thumb drive #2 sent Jul 30 2021 (Ex B ECF 177-2); McBride retained Aug 2021; bought 1 TB hard drive with USAFX downloads delivered Oct 7 2021; mac-adapter issue, Ingrid Washington email same day stating drive inoperable.

motion

Page 2 of the McBride opening-statement outline. Establishes three Nichols hard drives (two Files & Harrison thumb drives — red + blue — and one black 1 TB McBride drive). Notes that Officer Swolwannii at DC Jail let Nichols keep red drive during a McBride visit and the event is verifiable via Swolwannii bodycam. Itemizes Ingrid Washingtons Aug 29 2022 confiscation of hard drives, Sept move six days later with blue thumb drive stolen, no discipline charge, Marshals demand for FOIA. Argues DOJs position relies entirely on the Ingrid Washington affidavit which is provably false (Washington at CTF vs Nichols at CDF; all J6ers kept drives 6+ months).

exhibit

Brief handwritten yellow legal pad note: "McBride told me to come to you about getting statement for being mentally ill / sexual assault." Likely refers to attorney Joseph McBride (Ryan's defense team). Top of page has code CVUb5a04XDM and timestamps 9:30, 3:14, 1:40, 6:00 - possibly a bodycam reference.

motion · Aug 12, 20222 pages

Page 4 of 6 (Doc 135). Argues federal government decided to investigate J6 at any cost, J6 Committee robbed Nichols of impartial jury. Quotes McBrides July 21 2022 status hearing statement about Committee framing Nichols as leading angry lynch mob, citing ECF No. 113 transcript 12:5-20 and 13:9-17.

motion · Aug 10, 202216 pages

Caption page of Ryan Taylor Nichols petition for writ of habeas corpus under 28 U.S.C. 2241 and complaint for declaratory and injunctive relief, filed in the U.S. District Court for the District of Columbia against AG Merrick Garland and D.C. Jail Deputy Warden Michelle Jones.

order · May 1, 2024

Texas state court Register of Actions for State v. Ryan Taylor Nichols, Case 2018-0666, Class A Assault misdemeanor filed 10/04/2018 in County Court at Law #1 before Judge Joe Black. Includes case history through 2020.

grievance_form · Oct 6, 2022

Signature page of ECF Doc 169 (Govt Supplement to Opposition to Motion for Release). Signed by Matthew M. Graves US Attorney DC; /s/ Douglas B. Brasher AUSA Federal Major Crimes (Dallas TX); Sarah W. Rocha Trial Attorney (Chicago IL).

grievance_form · Oct 6, 2022

Page 1 of 5 of Government supplement (ECF Doc 169) to its opposition to Nichols motion for release in 1:21-cr-117 (TFH). Discusses DOC confiscation and return of Nichols electronic-discovery hard drive at DC jail on Aug 29, 2022, citing affidavit of Ingrid Washington (DOC Litigation Support Unit).

grievance_form · Oct 6, 2022

Page 4 of 5 of ECF Doc 169. Quotes Nichols motion claims about USB drive, notes Nichols reply (ECF 168) and affidavit (ECF 168-4) introduce a second blue drive for first time. Notes Ms. Washington stated first discovery drive delivered to DOC was not operable or not compatible with DOC discovery laptops; attorney notified Oct 7, 2021. Government concludes by requesting Court deny emergency-release motion.

grievance_form · Oct 6, 2022

Page 3 of 5 of ECF Doc 169. Includes photo exhibit of a bagged Nichols USB hard drive labeled Nichols, Ryan alongside COVID-19 vaccination card. Government denies prosecution team ever examined or possessed the drive. Section III rebuts Nichols claim that hard drive mysteriously disappeared.

motion · Aug 12, 2022

Page 1 of 6 of Motion to Join, Adopt, and Supplement Co-Defendant Alex Harkriders Motion to Transfer Venue in US v Nichols, Case 1:21-CR-117 (TFH), filed Aug 12 2022. References June 9 2022 January 6 Committee video presentation seen by 20 million people and tweet with 5.5M views, argues poisoning of DC jury pool.

transcript · Dec 20, 2021

Transcript page from Ryan Nichols' December 20, 2021 second bond hearing before Hon. Thomas F. Hogan. The Judge acknowledges 22-23 hour/day cell retention as "terrible, confining, and difficult" and accepts defense counsel's argument that Ryan's due-process rights were violated — "that should be another basis for his release." On the same page, attorney Joseph McBride lays out retaliation: the DC Jail confiscated Ryan's discovery and revoked his laptop access immediately after he raised conditions of confinement in his November 1 papers. Despite this on-record admission, bond was again denied.

exhibit · Mar 15, 2021

Page 6 of 13 of ECF Doc 169-1: DC Department of Corrections procedure dated March 15 2021 for voluminous or electronic evidence review during COVID-19 pandemic. Lists DOC Litigation Support Unit contacts Kimberlee Smith (nee Lewis) kimberlee.lewis@dc.gov and Ingrid Washington ingrid.washington@dc.gov.

letter

Letter from J6 detainees protesting retaliation after Judge Lamberth held the DC Jail warden and DC DOC deputy director in contempt of court. Within 24 hours, detainees report being cut off from counsel and family communications. They demand restoration of WiFi/attorney access and pledge prayer-protest until rights restored.

motion · Sep 8, 20222 pages

Page 3 of 4 (Doc 156). Details aftermath: 24-hour shower denial after chemical spray, scolded staff after 36 hours, mental health visits canceled ("Fuck you. You aint going to see mental health"), attorney-client materials and discovery confiscated, electronic grievance shut off, staff gave him grievance form written in Spanish and laughed, no pen. Argues Lancasters cruelty retaliation for habeas petition.

exhibit2 pages

Handwritten notes by Ryan Nichols analyzing his Detention Hearing Transcripts (items 1-8) - raising ineffective assistance of counsel claim, noting Congress was no longer in session when he arrived, and discussing first aid kits.

letter · Mar 9, 2026

Deficiency notice from Eastman Credit Union (Kingsport TN) to Ryan T Nichols (20256 Fm 450 N, Diana TX) regarding sale of 2024 Ford F-150 (loan 119647256). Deficiency of 7,888.82 after private sale on March 3, 2026.

grievance_form · Oct 27, 2022

Rappahannock Regional Jail (RRJ) Returned Grievance Form Control No. 032590 dated 10/27/22, returned by Ombudsman (Boyce?) to Ryan Nichols. Marked: failed to file an Inmate Request Form to attempt informal resolution, complaint not grievable issue, improperly filed. Cites IRF #1209691, references US Marshals approval, Inmate Handbook Sections 23-24. Federal judges have no control over RRJ facility.

grievance_form · Oct 19, 2022

Page 3 of 3 (final page) of Doc 172. Certificate of Service - served on defense counsel via email Oct 19 2022 by /s Sarah W. Rocha.

grievance_form · Oct 19, 2022

Page 2 of 3 of Doc 172. Government does not oppose transfer if other facility can accommodate. DOC confirms only 2 drives. No personal belongings remaining. Requests DOC General Counsel attend Oct 24 hearing virtually. Signature block.

exhibit · Oct 6, 2022

Page 8 of 13 of Doc 169-1. Final page of DOC procedure letter (Exhibit A). Note about contact visits causing 14-day medical enhanced monitoring.

grievance_form · Oct 6, 2022

Page 5 of 5 (final page) of Doc 169. Signature page with Matthew M. Graves (US Attorney), Douglas B. Brasher (AUSA Federal Major Crimes - Detailee), Sarah W. Rocha (Trial Attorney).

grievance_form · Oct 6, 2022

Government supplement to opposition to motion for release (Doc 169), page 1 of 5. Addresses status of electronic discovery and DOC confiscation of USB hard drive from Nichols on August 29, 2022.

exhibit · Oct 6, 2022

Page 7 of 13 of Doc 169-1 (Washington affidavit attachments). Continuation of DOC procedure letter (Exhibit A) describing inmate evidence review rules, two-week review periods, waitlists, refusal process.

motion · Sep 30, 2022

Cover page of Defendant Nichols Reply to Government Opposition to Motion for Pretrial Release (Doc 168). References Exhibit A (habeas petition) and Exhibit C (further conditions of confinement).

grievance_form · Sep 15, 2022

Conclusion: government requests Court deny Nichols motion. Signed by Matthew M. Graves (USA), Douglas B. Brasher (AUSA, Dallas), and Sarah W. Rocha (Trial Attorney).

motion · Aug 30, 2022

Background section explaining 20-month detention since January 18, 2021, habeas petition, and DC Jail confiscation of USB drive containing attorney-client privileged discovery materials on Aug 29, 2022.

exhibit · Aug 30, 2022

Final page (13/13) of Doc 169-1. End of Exhibit C - Aug 30 2022 DOC updated procedure letter. Contact info for DOC General Counsel Eric S. Glover and Attorney Advisor Andrew Mazzuchelli.

exhibit · Aug 30, 2022

Page 12 of 13 of Doc 169-1. Exhibit C - the Aug 30 2022 DOC updated procedure letter referenced in Washington affidavit para 8. Updates the March 15 2021 procedure for voluminous/electronic discovery review.

exhibit · Oct 7, 2021

Page 10 of 13 of Doc 169-1. Exhibit B - email from Ingrid Washington (DOC) to Joseph McBride (Nichols attorney) on Oct 7 2021 re: bringing new discovery to CTF and picking up non-operable drive.

exhibit

Glowing character/work performance statement from Sgt. Shawn Franklin, C Building Zone Supervisor at the Correctional Treatment Facility, regarding Inmate Ryan Nichols (DCDC 376-795). States Nichols has had zero adverse actions or disciplinary reports, serves as mentor/morale booster, mediates disputes, and recommends him for next position.

other

Page 18 of the DC Department of Corrections inmate handbook describing Veteran Services (VA staff member visits CDF weekly), Reentry programs (TAP, Better and Beyond/DOES Work Readiness, Aramark In2Work, Howard Inside Out), CJCC Resource Locator, Public Defender Service, Maryland Resource Locator, Photo ID, and Release. Referenced by Ryan Nichols (j6s11-011) where he asked for a VA Rep per this page and staff told him "We dont have that here."

exhibit9 pages

Page 10 of DC DOC Inmate Handbook covering Emergency Drill Inspections, Staff Contact via APDS tablet, Movement, Escorted Trips (medical, funerals), and Emergency Procedures.

photo · Nov 4, 2022

Excerpts/typed notes from House Judiciary GOP report pages 40-41. FBI not aggressively investigating Jan 6 pipe bombs vs Jan 6 defendant cases; cites USAO DC stats: 880 arrests, 272 charged, 280 sentenced as of Oct 6 2022; raises pre-trial detention concerns and selective info sharing with the Democrat-led Select Committee.

photo · Nov 4, 2022

Page 2 of 1050: Executive Summary of the same House Judiciary GOP staff report. Names FBI Director Christopher Wray and AG Merrick Garland, accuses FBI leadership of inflating domestic violent extremism statistics by miscategorizing Jan 6 related cases as organic, and of abusing counterterrorism authorities against parents at school boards.