Coerced COVID Vaccination as Condition of Court Access

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.

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.

grievance_form · Dec 7, 2021

Typed electronic version of the vaccine denial Informal Grievance Form (Response ID 140283, IGP #22112144-412) submitted by Ryan Nichols on 12/07/21 10:44 PM. Adds key context: family from Texas planned to travel for the upcoming Dec 20th bond hearing he needs to be presentable for. Received Dec 08 2021.

grievance_form · Dec 7, 2021

Page 2 of typed Informal Grievance #22112144-412 (vaccine denial). Continues family-from-Texas point about Dec 20 bond hearing — first time seeing them all year — and signoff by Ryan Nichols 12/07/21.

grievance_form · Dec 7, 2021

Inmate (pink) copy of DC DOC Informal Resolution Complaint by Ryan Nichols dated 12/07/21 documenting that DC DOC denied him his second COVID vaccine dose (due 12/01/21), even though he took the first shot only to comply with the court and access family visits, haircut/shave, and religious services.

grievance_form · Dec 2, 2021

Printed DC DOC Case Management Inmate Request Form (Response ID 138708) submitted 12/2/21 by Ryan Nichols, DCDC# 376795, C2-B Level 57 cell 10: requests haircut and second COVID shot before Dec 20 bond hearing. Handwritten note: 12/3 request sent — Davies.

letter

Page 4 of Ryan Nichols letter — list continues: lead paint in cells, no discovery access, no legal printers, denial of legal motions, vaccine requirements for visits/haircuts/religious services, CRT and re-education propaganda on tablets, 25.5+ hour solitary confinement, Congressional visits denied, racial and religious profiling, political mockery by staff wearing Democrat/BLM/Kamala/Biden attire, sent to The Hole for political views.

letter

Page 4 of handwritten DC Jail conditions essay listing further grievances: 9 days without shower, medical care denied, lead paint, no discovery access, CRT propaganda, vaccine mandates, solitary confinement, political mockery.

letter

Page 2 of Khater letter. Shallow breathing - nurses/doctors dismissive. "This isnt CVS" - given nasal spray (Nasonex), denied allergy pills. Refused barber services since day 1 despite covid antibodies from Dec 2020. Law library refused months. No video visits despite promise, hasnt seen attorney once or family since day 1. No religious services months - only tablet w/ few sermons. Refused comfortable mattress multiple times - doctors dismissive. Refused adequate nutrition for months including cardiac diet despite heart condition. Names Dr Danielle Finch.

letter

Page 2 of Coffman amendment violations. Food so bad Lonnie has lost 25 lbs in captivity, no nutritional value, expired bologna, everything cold/freezer burned. Toilet flush button leaks down wall. No cleaning materials. Mail 10 days to several months late. Denied bail/bond twice, called a flight risk even though Lonnie cant even wipe his own buttocks. "Government lied about napalm in my truck which keeps me in this hell hole." Must use chemical burning cream on scalp - no haircut without vaccine. No video visitation whatsoever.

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.

grievance_form · Feb 19, 2022

Warden's Administrative Remedy Form (Response ID 164343, Grievance #22092746-038) by Shane Jenkins (DCDC #377186, Unit C2b) appealing denial of haircut access due to vaccine status. Received Feb 22 2022. Step Formal Request.

grievance_form · Feb 15, 2022

DC DOC Step 2 Formal Grievance Form filed by Shane Jenkins #377186, Unit C2B, escalating his haircut complaint from 2-5-22 — calling the archaic vaccine mandates and denial of basic human needs cruel and unusual and noting he has been at DC DOC since 4-13-21 without access to a haircut. Marked as future litigation. Stamped received 2/16/22; assigned IGP #22092816-279.

grievance_form · Dec 31, 2021

DCDOC Informal Grievance Form (Response ID 154226, IGP #20220105-069) by Shane Jenkins (DCDC #377186, C2B) protesting administrative lockdown limiting inmates to 2 hours out of cell per day due to omicron mandate from Mayor Bowser.

exhibit · May 17, 2022

Ryan Nichols handwritten page 3 documenting a meeting with Jorden Mink on 5/17/22 listing solitary confinement, family/video visits, IAP issues, officer mistreatment, haircuts, medication vs mental health therapy, vaccine requirements, hopelessness, possible C2B informants, sit-in over constitutional violations, and lack of outside therapy. Notes the 5/9/22 suicide-watch caution cell stay was not addressed.

letter · Sep 15, 2021

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 · Sep 14, 2021

Page 2 of Jenkins letter. In Mr Fairlamb cell they took off all jewelry and body cams. Many wrote grievances about it - returned by Officer Holmes (the very officer they were written on). Edward Lang arguing with Sgt Robinson when door opened and sprayed him with pepper spray. Nurses refer to pod/dorm as "the Red Neck Tank." Bologna. Breakfast 2AM many months - "form of torture." Jordan Mink had officers handcuff and threaten over discovery after DOJ told him not to share. DCDOC cell 1.5 months no hot water, several months no rec. No vaccine no haircuts denied fingernail clippers. Officer McCade worked 9-14-21 wearing hardened knuckle gloves with "some heat" written across knuckles, carrying mag, slapping in hand - threats of violence. FB & IG locked over arrest "innocent until proven guilty." Jeep/Compass lost due to ruined credit. Excessive bail - Houston judge accused him of attempting to "overthrow our fragile democracy" by flying to DC armed. Multiple harassment over political statements like Trump won. Re-education tablet CRT, book "White Supremacy and Me." 4 case managers in 4 months, revolving door. Mail tampered (return address, postmark removed).

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.

grievance_form · Mar 18, 2022

DC DOC Appeal-Deputy Director Form (Step 4, PP 4030.1 Attachment G) filed by Nichols 3/18/22 appealing Warden response to IGP # 20220316-236. Documents that on 11/1/21 and 11/2/21 DC DOC told Nichols he would be eligible for a haircut BEFORE his bond hearing if he took the vaccine. He was fully vaccinated 12/4/21 but never received haircut or shave; his bond hearing was 12/20/21 in front of Judge Thomas Hogan and he looked terrible/embarrassed/ashamed.

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.