Ryan Nichols
Grievance #6Staff Conduct·

Officer Violence / Threats / Assaults

Documented officer threats and assaults against Ryan and other inmates.

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filings
5/5
severity
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Full write-up pending. Cross-referenced documents will appear here.

Officials named in the evidence

33 people named

Tap any name to see their case page and every document where they appear.

C-2B pod, DC DOC

DC DOC

DC DOC / IA

DC DOC Medical

Eastern District of California Federal Defender (Sacramento)

Federal Public Defender (DC)

January 6 Capitol crowd

MPD / U.S. Capitol Police

Private counsel

U.S. District Court for the District of Columbia

Other

Evidence on file

75 documents on file

Every page below is a watermarked scan from Ryan's own case file. Click any one to read it, share it, or copy the link.

Ryan29 documents in 27 items

Ryan Nichols' own paperwork — grievances, motions, letters, cell notes.

exhibit · Mar 20, 2024

DC DOC Inmate Grievance Form re Andrew Taake assault on Dominic Box

DC DOC PP 4030.1 Inmate Informal Resolution Complaint Form (Attachment C) filed under pseudonym John Smith (#123456) in C3A documenting J6 defendant Andrew Taakes assault on fellow inmate Dominic Box and threats against other inmates.

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grievance_form · Sep 15, 2022

Government Opposition — page 2 of 9 (Aug 29 and Sept 5 incidents)

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.

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grievance_form · Sep 9, 2022

DC DOC Inmate Complaint Form 9/9/22 - chemicals/Lt. Lancaster

Official DC Department of Corrections Inmate Informal Resolution Complaint Form (PP 4030.1) filed by Ryan Nichols (DCDC# 376795) on 9/9/22. Incident 9/5/22-9/6/22 at 11:39 AM, Unit South 1, alleging Lt. Lancaster violently assaulted Ronald [Dr...] with OC spray; Ryan also sprayed and caught chemicals; cells went without chemicals being decontaminated for nearly 24 hours. Direct evidence of jail mistreatment relevant to compensation.

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motion · Sep 8, 2022

Motion to Dismiss page 4: Bidens speech conclusion, US v Thomas cite

Page 4 of 5 of Motion to Dismiss (Doc 155). Finishes statements 28-31 from Bidens speech, argues President backlit by red and flanked by Marines, incited nation to hate J6 defendants, cites United States v. Thomas, 22 M.J. 388, 393 (C.M.A. 1986), and moves to dismiss the indictment in its entirety.

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affidavit · Mar 29, 2022

Peter Stager — handwritten statement on IGP #20220201-685 irregularities and PREA

Handwritten witness statement (page 1 of 2) detailing irregularities with IGP grievance #20220201-685: written 1/31/22, submitted, shown received 2/1/22 yet not signed; document received 3/29/22 around 11:00 AM from Officer Pittman showing Major Sheila Marr signed off 3/21/22 (long delay). PREA investigation handoff questionable. Lost detail job. Visited 2/17/22 by PREA Compliance Specialist C. Savage; placed in isolation by Officer Pittman 2/7/22 with no privileges. PREA allegation reported 2/16/22 but received 2/1/22 — date/name/procedural irregularities documented.

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grievance_form · Mar 21, 2022

Grievance vs Cpl Allen 3/21/22 — verbal assault during medical transfer (KN95 mask)

DC DOC Informal Resolution Complaint Form by Ryan Nichols dated 3/21/22 against Cpl Allen. Alleges that during transfer to medical, Cpl Allen became aggressive, hostile, confrontational and threatening toward him and other inmates over the specific type of mask Nichols was wearing (KN95). Notes the verbal assault and cursing were captured on video surveillance, that he returned to his cell and asked for an LT (lieutenant) to escalate.

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letter · Dec 15, 2021

DC DOC memo — Major Marr response to Grievance #20220121-361 (COVID precautions, 1/27/22)

Official DC DOC memorandum from Major Sheila Marr to Inmate Ryan Nichols dated 1/27/22, responding to Grievance #20220121-361 with the agency boilerplate on COVID-19 precautions (PPE, two-hour wipe-downs, cleaning crew, Modified Medical Stay in Place). Underlying grievance dates from December 2021.

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grievance_form · Oct 15, 2021

Formal Grievance - Religious Services/COVID Vaccine (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.

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other · Sep 27, 2019

Legal research notes: Million Man March, Neil Wolf v. DHS, DC self-defense spray code

Ryan's legal-research scratch notes referencing the Million Man March and Neil Wolf v. Dep Homeland Security; DC Code 7-2502.12 (Definition of self defense spray) and 7-2502.13 (Possession of self defense sprays). Cites Civil Action No. 17-1534 (ABJ), Sep 27, 2019.

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letter

From Ryan — Sept 8 update: water flood, Drs Walls & Coffman, Taylor Etcaranto suicide

Ryan update Sept 8: water diaphragm broke in cell 32, water floods like Red Sea fills entire cell block. Names ERT and guards on duty: Franklin, Cobb, white shirt Hays, Pinky. Identifies "Dr Walls & Dr Coffman, chiropractors both here in DC, both Democrats, both on video beating police, both released for picketing." Two inmates have discovery video showing beating to death of two women during riot — never shown on TV, no officers held accountable. Names officer who allegedly assaulted/assisted in suicide: "Taylor Etcaranto: Responsible for death of officer who committed suicide; Assault & assist in suicide on officer." Recounts again March 18 intake — "the only white man taken into roach infested, dimly lit, holding facility...inmates figured out I was a white Trump supporter...we be ass fucking you white boy."

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other

Unconstitutional Conditions of Confinement habeas outline (Chandler v DC DOC)

Ryan's outline for Writ of Habeas Corpus on unconstitutional conditions of confinement and due-process violations. Lists Eighth Amendment cruel/unusual punishment incidents: Pussy Ass Cracker incident Sep 18; J. Johnson white privilege incident Nov 17; mace sprayed/everyone choking Nov 29; Staff Appreciation Day lockdown; Dec 18 & 19 24-hour lockdown. Cases: 1) Chandler v District of Columbia Dept of Corrections; 2) Irish Republican Army Hunger strike Bobby Sands.

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letter

From Ryan — "I am a political prisoner in my own country," ex-wife took everything

Ryan letter. Led down hallway into telephonic meeting w/ lawyers at 13:42 met with distain, mean mugging, talk-down by guards: "What you looking at? Shy! Wah! Talk! Dont stand shy!" "I am no longer a human being." When water diaphragm or toilet breaks, met w/ lock down, told how lucky to be there, told other side of door = ass-raped, killed, stabbed, robbed. Guards extort money & food from inmates for special privileges & favors. "I am a political prisoner in my own country!" Names Hays, Armstrong, Pinky, Holmes, Franklin — "list is goodless w/ guards who commit crimes!" "I am a white Christian male in a 98% African American ran facility, everything I say and do is met w/ extreme measures of resistance. I have been called: honkey white boy, Trump cracker, on & on." Cant trust anyone working here. "This is my message in a bottle." Asks where the ACLU/NAACP/BLM/Nancy Pelosi & others would be beating down his door to get him out — if he were a black male in an all-white facility. Notes ex-wife got document allowing her to buy/sell/trade in his name — lost home, car, clothes, accounts.

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motion

Reply to Govt Opposition p6: defend our democracy, J6 Committee theory

Page 6 of 8. Quotes Bidens Red Speech "I will defend our democracy with every fiber of my being." Notes J6 Committees underlying theory that single presidential speech can inspire crime. Cites Rep. Aguilars opening statement playing Trump-Pence clip followed by clip of Nichols walking to Capitol expressing anger about Pence.

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letter

From Ryan — March 18 to Sept 13 jail timeline, page 1 (FBI HQ → CTF intake)

Page 1 of Ryan Nichols handwritten timeline March 18 - Sept 13: arrival at FBI HQ (shoelaces/belt/ID/truck taken), transport in waist shackles/handcuffs/leg irons while guard yells "Dead Man Walking he be a Trump supporter," roach-infested 5x8 cell, 2 bologna sandwiches/day, begging for water, no blanket/pillow. Two days of inmates beating on cells, yelling slurs and threatening homosexual rape, throwing urine and feces. Moved to CTF March 22 — intake nurse, strip search shower routine.

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discovery

Discovery wishlist: bodycams, Reeder/Hogan, FBI Form 1023 CHS

Handwritten discovery list naming specific Capitol Police bodycam tags (X6039BJJV, X6039B9NO, X6039BF8H) and named officers/officials: Roseanne, Fanone, Robert Reeder, Hogan. Demands FBI Form 321/FD-1023 CHS (Confidential Human Source) reporting documentation KL000239.

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letter

From Ryan — guard assaults, Rohr Knives, political prisoner narrative, page 5

Page 5 of Ryan Nichols letter: list continues — denial of hot water, prevented from attending court, maced/assaulted/harassed by guards, cell invasions, threatened/nearly stabbed with "Rohr Knives," toilets poop-poisoned 6 months. Concludes the bullet list and pivots to declaring J6 detainees "Political Prisoners on American Soil" subjected to selective prosecution, slander by media, and death threats inside the jail and to their families through mail.

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exhibit

Spray Incident - Officers Viewpoint timecode p1 (Fanone, white shirt cop)

Page 1 of detailed video-timecode log titled Spray Incident - Officers Viewpoint. Actual time 16:02:34 Ryan sprays. 7min 43sec: Is Fanone in hallway? Left hand side. White shirt cop starts assaulting helpless woman with baton and fists. Relentless - Woman in Red shirt. Officer on ledge grabs baton of white shirt cop after he hit protestors 7 times in the head. 9:30 video time: officer in white shirt has struck 28 times. 11:24 officer punches woman in red shirt with left hand. 14:01 officer batons man out of tunnel in back and back of the head - Helmet #4011.

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exhibit

Legal research notes: Speed v US, Bell v Wolfish, Mandela rules

Handwritten legal research notes citing Entrapment by Estoppel; Speed v United States 562 A 2d 124 (DC 1989) DC Code 22-505 on right of citizen to defend against officers excessive force; Dr David Walls-Kaufman DC chiropractor (not charged, on video assaulting in hallway); Taylor F. Taranto; Robert Reeder picketing, registered Dem, on video assaulting police; Bell v Wolfish on pretrial release vs punishment 441 US 520; Hendrickson v Kingsley 2015 (7th Cir 2015); Nelson Mandela rules - international rules for solitary confinement.

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motion

Jail conditions notes: weight loss, food, Baltimore Bloods, rats

Handwritten conditions-of-confinement notes: weight loss 35 lbs (1:07PM-176 lbs), scant medical records, no food notes, request list of certified GF foods, blood, malnourished. Box - closed door cell. Baltimore Bloods - 30 days no comm, cherries-brand name vs Bev, slowly poisoning. Rats/Kyenga/Roaches/mice. Mentions Thomas Caughlin/M. Caldwell assaulted, ha ha ha.

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other

Defense strategy notes - 302, AUSA, plea options, NYT articles

Handwritten attorney/defendant strategy notes referencing FBI 302 reports, AUSA plea offers (5-20 years), megaphone leadership issue, NY Times article transcripts on firearms adjustments, Hurricane Rescue (Cajun Navy) angle.

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other

DC Jail notice — Routine COVID-19 testing policy (Unity Health Care, English/Spanish)

Printed Unity Health Care / DC Jail notice explaining new weekly COVID-19 testing of asymptomatic residents; refusing the test will not cause lockdown but may bar court trips, outside medical, programs and activities. Spanish translation included.

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exhibit

Handwritten sentencing legal research notes - Glover v. United States

Handwritten legal research notes on federal sentencing law including Glover v. United States, 531 U.S. 198 and 18 USCS Appx 3D1.2 grouping counts, with reference to U.S. v. Lombardi.

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exhibit

Ryan Nichols handwritten essay: Why I Geared UP For Jan 6th

Handwritten essay by Ryan Nichols titled Why I Geared UP For Jan 6th explaining his rationale for chest protection and crowbar - 2020 riots, Antifa violence, social media warnings about Antifa attacks, Marine Corps training about sucking chest wounds.

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letter

Khater — Hayes "beat Ryan Samsel", 6 days lockdown Trump bday (p.4)

Page 4 of Khater letter - critical evidence. Names officer Hayes "purposefully walking around intimidating us, saying hes gonna write DRs (Disciplinary Reports) on us, you know what youre looking at? A proud blackman." Khater alleges Hayes "beat Ryan Samsel up and ziptied his hands behind his back. Ryan almost lost his sight in one eye and had blood clots. They had to take him out of here and to a medical facility in VA." Breakfast at 2:30AM, lights at night. Shackled wherever moved despite being pretrial detainees. "Locked us down for over 6 DAYS STRAIGHT for Trumps Birthday - only let us shower once (hardly 10 minutes). It also happened to be my brothers birthday, and they wouldnt even let me make a couple private phone calls." Service turned off all tablets. Discovery taken from Jorden, threatened him.

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letter

Handwritten Essay - Guard Misconduct & Political Prisoner Claim (p.5)

Page 5 of handwritten essay detailing guard misconduct - racial profiling, harassment, assaults, court access denials - and Ryan framing himself and codefendants as political prisoners on American soil.

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exhibit2 pages

Ryan Nichols — Hand-drawn Jan 6 Network Diagram + Timeline

Handwritten timeline page for Jan 5 detailing Ryan Nicholss arrival in Virginia, viewing the White House, encountering BLM/Antifa protests, his anti-Antifa speech, with GoPro video references and timestamps.

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exhibit2 pages

Ryan Nichols — Tunnel Bodycam / Capitol Discovery Notes

Continuation of timestamp notes covering crowd assaults by police and Lombardini, and quoted statements attributed to M. Dowling describing physical altercations.

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Co-detainee20 documents

Witness statements and letters from fellow January 6 detainees. These are attributed accounts, not court findings.

exhibit · Jun 12, 2022

Timeline - JM (June 2022) - Jon Mellis recording, NPR Tom Dreisbach

Detailed timeline of June 2022 interactions with Jon Mellis (JM). 6/5/22 Ryan recorded Mellis 3 times admitting to nefarious activities including assaulting J6 inmates wanting to kill Tim, being behind an NPR article. 6/8/22 Mellis allegedly threatened to go nuclear / mutual destruction if Ryan shared the videos. James McGrew overheard. Witness intimidation evidence.

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exhibit · Apr 16, 2022

Timeline - p9 (23-1 lockdown, mail delays, Ryan Samsel beating, Fairlamb)

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.

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letter · Mar 28, 2022

Peter Stager — DOC Memorandum PREA Case Closure from C. Savage (3/28/22)

DC DOC official Memorandum to Stager, Peter DCDC 376784, C2B-8, from C. Savage, PREA Compliance Specialist, dated March 28, 2022. Subject: PREA Case Closure. Text: "Please be advised, your PREA allegation reported on 2/16/2022 was withdrawn by you. The PREA Compliance Specialist met with you on 2/17/2022 and during your interview, you withdrew your complaint and signed (attached) documentation confirming such." Initialed "CS" by Savage.

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grievance_form · Feb 1, 2022

Peter Stager — original Informal Grievance Form IGP #20220201-685 (2/1/22, PREA allegation)

Original Informal Grievance Form (Response ID 160504), submitted 2022-01-31 15:49 by Peter Stager (DCDC# 376784, Unit C2B). Hand-annotated "IGP# 20220201-685". RECEIVED stamp: FEB 01 2022. Department: Staff Treatment. Offender: "Female officer". Complaint: came in from rec, sat due to maintenance servicing shower stalls; guard yelled "I need to ask her permission to shower" (Stager: has been in facility since 03/08/21 and never had to ask permission); then "the guard stared at the men showering like they were desert. This peeping tom like behavior is creepy and not a issue out side of her. The other female gaurds dont behave like this." Signed: Peter Stager, 02/01/22.

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grievance_form · Jan 11, 2022

IGP #20220105-069 — DOC response to Shane Jenkins lockdown grievance (1/11/22)

DCDOC Informal Grievance Tablet Submission Response for Shane Jenkins (DCDC #377186, C2B) IGP #20220105-069 re lockdown. DOC justifies restrictions citing DOC/DOH mandates to slow Covid-19 spread.

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exhibit · Dec 30, 2021

DC DOC COVID-19 Omicron memo (Dec 2021) annotated by Ryan Nichols — 22 & 2 lockdown trigger

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.

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letter · Dec 29, 2021

Sean McHugh — letter to Joe McBride (12-29-21) re: Jacob TDS, John Pierce, 92-115mo plea offer

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.

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exhibit · Oct 19, 2021

Meeting With Jail Staff page 4 - grievances, PREA, racial discrimination, CPL Hayes/Armstrong/Holmes

Page 4 of jail town hall notes. Documents extensive grievances filed by Pod C2B detainees: legal mail not mailed (Tim Hale), PREA violation grievance by Sean McHugh witnessed by Alan Byerly, racial discrimination by Ryan Nichols/Shane Jenkins/Jose Padilla. Names CPL Hayes (harassed Kash Kelly), CPL Armstrong (door-kicking incident), CPL Holmes (told detainees Shut The F up and F America when singing National Anthem), Scott Fairlamb confronted Hayes. Sgt Robinson, Lt Shoemake mentioned.

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letter

From Timothy L. Hale-Cusanelli #376441 — conditions list (Ryan Samsel beating note)

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.

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letter

From Nathaniel DeGrave #376789 — Amendment Violations: Pahrump NV → DC DOC timeline

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."

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letter

From Nathaniel DeGrave #376789 — Amendment Violations: Pahrump NV → DC DOC timeline

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."

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motion

Sean McHugh — pro se ineffective assistance brief (caption + Lexi Negin / Maria Jacob narrative)

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."

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motion

Sean McHugh — earlier draft IAC brief (Lexi Negin BLM, DUI/alcoholism, 2nd detention hearing)

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.

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other

Peter Stager — envelope to PREA Coordinator, return address DCDC #376783

Mailing envelope addressed to "The Office of the PREA Coordinator." Return address handwritten: "Inmate Stager Peter, DCDC 376783, C2B Cell #8." Confirms Peter Stager identity and housing as of mailing.

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other

Sean McHugh — notes from status conference re: discovery, trial schedule

Handwritten notes (likely McHugh’s) summarizing a status conference: case-specific discovery (jail calls outstanding, plus one other), global discovery on evidence.com (23,000 files, 17k Capitol footage, body cam remaining, GPS spreadsheet for radios), end-of-January completion; 17 hours withheld due to Executive of Congress (interior mostly, some exterior). Prosecutor "Strain" estimates 5 trial days / ~10 witnesses; defense "Jacob" suggests 7 days. Court ("Bates") could start 9th or 21st; tentatively March 9th.

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affidavit · Nov 14, 2021

Daniel Caldwell witness statement re DC DOC (p.2, Nov 14 2021)

Caldwell page 2 dated Nov 14 2021: pepper-spray incident in confined space, failed to follow protocol, denied oxygen, medical refused vitals; Nov 15 fainted, ER at GW Univ told he was suffering from Post Concussion Syndrome ignored; Nov 11 attacking & unanswered. Broken grievance systems, well-documented within US Marshall Services; political prisoners with 0 rights, doubts Red Cross would help.

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exhibit · Oct 26, 2021

Co-detainee Statement Concerning Thomas Sibick, Part 4 (October 26, 2021)

Page 4 of four handwritten statements concerning Thomas Sibick, dated October 26, 2021. The scan bears the names and signatures of Ryan Nichols, Robert Morss, Scott Fairlamb and Tim Hale. It alleges physical contact and other conduct involving Morss and refers to a jail investigation. The investigation's outcome is not established by this statement. These are attributed allegations, not court findings.

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letter · Sep 13, 2021

Garret Miller — Civil rights abuses log, FBI agent Palombo (p.1)

Sworn-style timeline from J6 defendant Garret Miller dated Monday September 13 2021. (1) Jan 20 vehicle window smashed after complying with arrest, gave keys to FBI agent Palombo. (2) Held down while Agent Palombo and Richardson police officers attempted to force facial unlock of his phone violently. (3) Ignored 3 lawyer requests before questioning. (4) Threatening behavior after refused DNA swab - taken next Monday after more threats. (5) Dallas County Lew Sterrett - no soap/cups/books, toxic food, no covid protection, no religious services, no access to law library. (6) Johnson County better but no religious services or law library. (7) Eden Detention Center - 228 inmates communal dorm, no law library, shattered collar bone, did not see orthopedic; transferred 2 days later with broken collar bone locked in chains and shackles, 4 hr painful car ride and 2 hr plane to Oklahoma. No vitamins, leg cramps after 1 week.

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letter

Testimony of Kelly Meggs — Samsel beaten, Coffman missed meds, AC off 4 days (p.2)

Page 2 of Meggs testimony. Sgt Franklin & CPL Hubbard ("both great people") had preconceived white supremacist/racist notions from staff/media. No bail at 52 with no prior arrests, designated terrorist at FL bond hearing over "destruction charge" DOJ now says no evidence of but won't drop to keep him detained. Heard screams at 3:15-3:30am - found out next day Ryan Samsel had been brutally beaten in next pod. Lonnie Coffman age 72 several times 3-4 hrs late for medication every 12 hours. In June AC turned off 4 days in C2B at 95+F, slept on concrete floor in underwear.

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affidavit

Jeffrey McKellop witness statement re DC DOC solitary (p.2)

Page 2 continuing McKellop's account of black mold, mice droppings, ignored grievances, and an IQ-test/transfer offer with conditions never met. Notes he is 70% disabled and that 98% of facility population is African-American.

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Attorney11 documents in 2 items

Defense counsel correspondence (Joseph McBride, Jonathan Gross).

Court3 documents in 2 items

Court orders, rulings, transcripts, and docket entries.

Govt response12 documents in 3 items

Responses from DC DOC, the U.S. Marshals, and federal agencies.

letter · Mar 21, 2022

Peter Stager — Major Sheila Marr DOC response to IGP grievance #20220201-685 (3/21/22)

DC DOC response memo. TO: Inmate Peter Stager, DCDC# 376784. FROM: Major Sheila Marr, #2 Shift, dated 3/21/22 (initialed SM). SUBJECT: Response to Inmate Grievance. RE: Grievance #20220201-685. Text: "Upon review of your grievance 20220201-685, on this date the officer may have requested that you ask due to maintenance being present in an effort to prevent unnecessary injury to staff and inmates. The latter portion of your grievance will be referred to the PREA Coordinator."

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grievance_form · Feb 17, 2022

Peter Stager — PREA Notice of Withdrawal signed 2/17/22 (the contested signature)

DC DOC PREA Notice of Withdrawal form, Print Name/DCDC#: "Peter F Stager 376784", checked box: "I would like to withdraw the PREA complaint that was made. I am not withdrawing this complaint under duress or coercion but of my own free will." Date: 2-17-22. Marked "Inmate Copy" at top. Per scan 003 statement, Stager signed this without understanding what it was, while isolated and trying to regain privileges. Form warns refusal to sign would trigger PREA investigation moving forward — coercive design.

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exhibit10 pages

DC DOC Inmate Handbook 2022-2023

Table of Contents page of the DC Department of Corrections Inmate Handbook 2022-2023, listing sections including Inmate Rights, Medical Services, Legal Access, Inmate Grievance Procedures, PREA, and Disciplinary policies.

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