Untreated Medical Issues (Ear)

grievance_form · Feb 18, 2022

Formal grievance 2/18/22: ENT confirmed ear infection (escalates IGP 20220208-914)

Pink DCDOC Formal Grievance Form, 2/18/22. Escalation of IGP #20220208-914 (ear/medical). Outside ENT doctor confirmed ear infection with scarring; documented in doctor records. Nichols requests a copy and demands to know who responded to the informal grievance.

other · Feb 15, 2022

Notes: Outside Medical at Howard University Hospital (Dr. Kawas, ENT)

Handwritten yellow legal pad notes titled Outside Medical. Documents Howard University Hospital visit with Dr. Kawas (white man) and a second doctor (Black woman, name with a J). Confirms ear infection diagnosis cited in scan 011 grievance.

grievance_form · Feb 5, 2022

IGP 2/5/22: ear infection medical neglect — Howard ENT confirmed scarring

Pink DCDOC Informal Resolution Form, 2/5/22. Chronicles ear-pain timeline: medical visit 11/8/21, IGP #22111183-794 on 11/15/21 (response 11/24/21 saw no signs, ENT to be scheduled), Howard University ENT visit 2/4/22 confirming white spots and scarring on eardrums from a recent ear infection — directly contradicting prior DOC medical response. Likely the IGP #20220208-914 referenced by scan 011.

grievance_form · Nov 15, 2021

IGP #22111183-794 ear infection meds — Grievance Resolved by DOC (DOC response 12/6/21)

DC DOC PP 4030.1 Inmate Informal Resolution Complaint #22111183-794 by Ryan Nichols dated 11/15/21 re ear infection denied meds; DOC RESPONSE filled in handwriting 12/6/2021 noting medication delivered 11/16/21, chronic care appointment with ENT referral, no signs of infection, grievance resolved. Stamps RECEIVED 11/18/21 and COMPLETED 12/6/2021.

grievance_form · Nov 15, 2021

IGP Informal Resolution Complaint — Medical/ear infection denied meds (11/15/21)

Pink DC DOC PP 4030.1 Inmate Informal Resolution Complaint filed by Ryan Nichols 11/15/21 over Health Care issue: prescribed ear infection medication never delivered despite multiple requests to the medical Nurse/Dr.

grievance_form · Nov 12, 2021

Informal Grievance Form #133853 (IGP #22111173-720) — DC DOC Medical denied ear meds (11/12/21)

Electronic Informal Grievance Response ID 133853 / IGP #22111173-720 submitted by Ryan Nichols 11/12/21 11:48 PM against DC DOC MEDICAL for failure to deliver prescribed ear infection pill; stamped RECEIVED Nov 15 2021 and Nov 18 2021, COMPLETED 12/3/2021.

other

Bond Points: U.S. v. Salerno + Gorsuch quote

Ryan's notes for bail/bond motion citing U.S. v. Salerno (Supreme Court) mixed with U.S. v. Melendez-Carrion - page 747 max length of pretrial detention for Speedy Trial Act, page 748 pretrial not to be held in same facility as convicted or those waiting on appeal (WE ARE), page 750 no conditions of release has to be argued. Quote The Constitution is not suspended during times of crisis - Justice Gorsuch, cited by Ketanji Brown Jackson at confirmation hearing re Gitmo detainees indefinitely held.

other

Bond Points: U.S. v. Vasquez-Benitez (DC Cir 2019) parallels to Ryan

Ryan's notes on U.S. v. Vasquez-Benitez (DC Cir 2019) drawing parallels to his own case: defendant ruled not a danger to community under Section II (Bail Reform Act Release); had wife, 2 children, job (just like me); only 1 obstruction conviction although accused of multiple crimes (Ryan: no past convictions); left his gang (Ryan: never been in a gang); demonstrated willingness to appear (Ryan: turned himself in); never convicted of violent crime. Quotes appellate court re not well-positioned to make credibility determinations.

motion

Ryan notes: FOIA, Grievance Process Broken, Howard Univ Hospital

Handwritten notes from Ryan listing requests: FOIA Request Info (US Marshalls, Internal Affairs DC Jail), names Marlene T. Bickham (US Marshalls consultant/former DOC) and Mr. Anderson, calls grievance process broken, asks for electronic grievance, and references Howard University Hospital records re: ear scarring/infection, Don Caldwell legal.

other

Habeas Corpus notes: Rutherford v. Pitchess on cell searches & visits

Legal research notes page 4 sub-topic 4: Punishment AND Cell Search AND Pre-Trial Detainee, citing Rutherford v. Pitchess, 710 F.2d 572 (9th Cir 1983). Bullet notes: cell searches; contact visits - punishment = no visits without vaccine; contact vs non-contact visit, we get neither.

other

Habeas Corpus notes: Farmer v. Brennan deliberate indifference (p.2)

Habeas notes page 2 continuing Farmer v. Brennan analysis: Ryan's own thoughts in margin (what are minimal civilized measures? what does case law say re solitary & mental health?), Wilson v. Seiter on culpable state of mind, Estelle v. Gamble 429 U.S. 97 on deliberate indifference standard requiring more than mere negligence.

affidavit

Timothy Hale (Hale-Cusanelli #376441) veteran witness statement (signed)

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.

affidavit · Apr 6, 20222 pages

Jessica Watkins veteran witness statement (2 pp., signed 4/6/22)

Page 1 of Jessica Watkins (#376520) veteran witness statement: 172 days solitary in 2021 plus 60 more in 2022, choir-singing hallucinations, refused therapy after declining drugs, nutritional deficiency (hair fell out, bruises, eyesight), and staff harassment over J6 political beliefs blaming detainees for DC police suicides.

affidavit · Sep 14, 2021

Jeffrey McKellop witness statement re DC DOC solitary (p.3, signed)

Final signed page of McKellop affidavit citing Farrakhan Final Call & The Criterion (Sep 6-14 2021) circulated by Chaplin saying all white people should be treated as dogs, hogs, beasts. Reports startle fear, sleep meds, hopelessness. Signed Jeff McKellop, declared political prisoner not forced/coerced/paid.

affidavit

James McGrew veteran witness statement re DC DOC (p.1)

James McGrew (USMC Veteran, honorable discharge 2007, 60% disabled, IED blast 2005) page 1: VA records well-documented; DC DOC ignored his requests for over a year to get VA records and prescribe medications; constant hyper-vigilance since off meds; nightmares of war.

affidavit2 pages

Daniel Caldwell witness statement (3 pp., 11/14/21)

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.

motion · Aug 10, 202223 pages

Petition for Writ of Habeas Corpus (Civil Action 1:22-cv-02356, Nichols v. Garland, filed 8/10/2022, 65 pp.)

First page of the Table of Contents listing sections I–VI.F of the Nichols habeas petition: Introduction, Jurisdiction, Venue, Parties, Statement of Facts (incl. PTSD, DC Jail conditions, Dec 20 2021 bail hearing, model prisoner), constitutional rights deprivations (1st/5th/6th/8th Amendments), deliberate indifference to medical condition, broken grievance process, and Legal Standard sections.