Recreation Time Cut

exhibit · Apr 29, 2024

Medical log noting testosterone shot, bloodwork, Dr Johnson re Zoloft, Officer McKelton delivering manilla envelope of denied grievances, wrong Levothyroxine dosage, and Dr. Salami denial.

grievance_form · Oct 24, 2022

Yellow inmate copy of Rappahannock Regional Jail Inmate Grievance Form OPER-0019 filed by Ryan Nichols (ID #20221663, SSN-4381, housing C-4/18) on 10/24/22 at 18:35 to Officer Barry. Companion grievance to j6s8-063. Documents 1265 minutes (21.08 hours) lost rec from 10/14/22-10/20/22, names Officer Barnett. References Inmate Request Form #1209696. Faded handwriting partially illegible. Mentions prolonged lockdowns affecting mental health.

grievance_form · Oct 17, 2022

Rappahannock Regional Jail Inmate Request Form #1209685 PROG-0024 — Ryan Nichols (ID #20221663, SSN xxx-xx-4381) housing C-4/18 dated 10/17/22 requesting observation of Jewish holiday Sukkot in the outdoor rec yard for 5 outings on both Monday and Tuesday for Oct 10 & 11, on Sukkot we stay outside and eat a piece of bread (grain) — not requesting more than 15 minutes to eat, pray and observe the holiday. Received by Officer Edwards 10/18/22 at 0830.

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 7, 2022

Back/page 2 of the handwritten Inmate Grievance Form rec-math attachment (continued from j6s8-067/054), Ryan Nichols. Combines projected cell hours and concludes 25.4 days/month spent locked in a cell, labeled MENTAL TORTURE.

grievance_form · Oct 6, 2022

Rappahannock Regional Jail Inmate Grievance Form filed 10/6/22 by Ryan Nichols protesting being locked down at 11:10pm with 2 hours of rec lost due to lack of staff, asserting jail unpreparedness is not his fault.

grievance_form · Oct 5, 2022

Rappahannock Regional Jail Inmate Grievance Form filed 10/5/22 at 14:58 by Ryan Nichols protesting second consecutive day of lost rec time, asserting rec is a right not a privilege and naming 1st Sgt Shaw and Officer Berry.

other · Sep 11, 2022

Handwritten grievance tracking spreadsheet logging dates of complaints (8/8/22 through 9/11/22) and escalation deadlines at 15, 15, 20, 30 business days for issues like Protest Phones Tablets, Outdoor Rec, Cpl Carter Doors, LT Lancaster, denial of shower after being sprayed, locked in cell, etc.

grievance_form · Sep 1, 2022

DC DOC IGP Complaint by Ryan Nichols 376795 C2B dated 9/1/22 1:00pm. Once again denied outdoor recreation by DC DOC; officers claim grass isnt mowed yet inmates can literally see the rec yard and it was just mowed. Argues being lied to. Sunlight deprivation adding stress. Witnessed by Kenneth Thornton.

grievance_form · Aug 30, 2022

DC DOC IGP Complaint by Ryan Nichols 376795 C2B dated 8/30/22. Facility woke him 7:45am for inside gym rec - denying ability to go outside. After he was up and dressed told there was no longer any rec. Multiple weeks since he went outside. Wants to be treated like a human being. Witnessed by Kosh L Kelly.

grievance_form · Aug 26, 2022

DC DOC IGP Complaint Form by Ryan Nichols DCDC 376795 Unit C2B dated 8/26/22. Complains he has not been outside in over 27 weeks; facility tells inmates they have outdoor rec but only takes them to the gym. Wants natural sunlight on his skin. Departments cited: Facilities Management, Discrimination, Staff Treatment. Witnessed by Kenneth Harrelyn 377692.

grievance_form · Jun 10, 2022

Pink DC DOC Warden Administrative Remedy form (PP 4030.1 Attachment F) filed by Ryan Nichols (DCDC# 376795, C2B) on 6/10/22. Escalates Formal IGP written 5/18/22 not responded to in 15 business days. Recounts being sent to SHU on 4/20/22 for refusing to sign a non-animosity form from LT Buck over an accusation that was not under his control, with no evidence; was not given a hearing, was never found guilty of an infraction or rule violation, but was punished with water turned off 20+ hours, denied proper mental health care after asking/begging, and locked in cell 70+ hours at a time with no recreation or contact with anyone.

letter · Sep 17, 2021

Letter dated 09/17/21 documenting transit/holdover conditions across multiple facilities. "During my incarceration in Sacramento County Jail I was subjected to extended periods of lockdown without showers or phone calls. Sometimes they would exceed 72 hours without coming out of my cell while in quarantine. No hand sanitizer was provided or new masks and majority of staff and inmates did not follow any COVID protocols. While in general population no hand sanitizer or masks provided in pod. Also time exceeded 48 hours of lockdown on occasion without showers. There was no rec yard provided to me during the whole stay at Sacramento County Jail. There was no clergy that I am aware of." Transit Sacramento → Nye County Southern Nevada Detention Center: no food or water. At Nevada: properly fed, came out 15 min every 2 days, no yard, no clergy, no hand sanitizer. Transport Nevada → Oklahoma: no food/water. At Grady County Jail: no mask, no hand sanitizer, crammed in small space with 30 other individuals.

other

Legal research notes page 5 sub-topic 5: Punishment AND Visits AND Pre-Trial Detainee. a) Pugh v. Elrod, 542 F.2d 998 (7th Cir 1976) - family visits. b) Lock v. Jenkins, 641 F.2d 488 (7th Cir 1981) - time as pre-trial detainee = punishment; conditions of confinement same/worse than convicted at DC DOC; video visits, recreation time.

grievance_form

Handwritten attachment to Inmate Grievance Form by Ryan Nichols (C4/18) calculating recreation time lost during lockdown periods 10/7-10/13 and 10/14-10/20. Documents 1,945 total rec minutes lost in 2 weeks, projecting 69.7 hours/month of lost rec time and 330.84 hours/month confined to cell.

grievance_form

Continuation page of Ryan Nichols inmate grievance form calculating total cell confinement: 609.72 hours/month in cell, only 4.6 days/month out, 25.4 days/month locked in cell. Concludes with explicit characterization: Mental TORTURE.

letter · Sep 18, 2021

Page 5 of Morss letter. Insulting food portions - 4 pieces bread, 2 cheese, or hard boiled egg with tartar sauce as "meal." Has to buy from commissary or be "skin and bones." September 18th: ripped from cells, relocated miles away due to event near jail. Officer "Armstrong" jammed his face with cell door. Vitamin deficient - majority show signs of scurvy. Outdoor rec taken regardless of weather.

letter3 pages

Page 4 of McGrew letter. Food well under serving temp, bread thrown on top getting soggy, meal in 3-slot tray intertwined - argues this constitutes "demoralizing cruel and unusual punishment." No nutritionally balanced diet at any facility. Recreation: at Florence County held in single-man cage on separate yard alone, no pull-up bars or recreation equipment.

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.

grievance_form · Oct 24, 2022

Rappahannock Regional Jail Inmate Grievance Form OPER-0019 Control #032581 — Ryan Nichols 10/24/22 18:35 to Officer Barry. Filed against conditions of confinement: 1265 minutes (21.08 hours) lost rec from 10/14-10/20 due to trays, meds, codes, but mainly not enough officers working pod. Cites quote from multiple officers — "including O'Connor, Alexander, Barnett and more." Projects 609.72 hours/month (25.4 days) locked in cell. Identifies that DS pod above gets rec while C-4 stays locked. Cites Inmate Request Form #1209696. Notes witness statements available, mentions 3 people in a 2-man room. References his Lockdown Logbook. Received by Ombudsman 10/25/22, returned as duplicate per j6s8-065.

exhibit · May 6, 2022

Dated log of DC DOC (DC jail) issues April-May 2022. 4/9/22 CPL Abdullah said LT Moore was fired over Nov 11 spray incident on Mock; Kenny and Wally Knight unaccounted for. 4/20/22 Division of Infectious Disease (Mr. Carlos Franco-Paredes of University of Colorado Anschutz) visit re: Covid lawsuit; LT Bruce, Sgt Adam Cola listed. 4/20/22 Taken to SHU-A. 4/28/22 board hearing. 5/1/22 water turned off at 2:45pm; 5/2/22 water back on. 5/5/22 told LT Allen suicidal; CPL Ngumdo too. 5/6/22 told other officers suicidal, finally taken to mental health.

grievance_form · Feb 26, 2022

Pink DCDOC Informal Resolution Form. Nichols grieves that inside/outside rec was called twice at 6:30am, but Inside Gym Recreation on 2/25/22 was cut short — called back early before morning shift change/count. Got only half of gym rec, the rest denied. Witnesses include Kash Kelly.

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

Brainstorming page mapping conditions to constitutional amendments. Includes co-detainee Sean McHugh #378159. 1st Amendment: church, clergy, grooming, nutrition/diet, rec time, communication w/ lawyers & family, journalist interviews, congress. 4th: cell searches, let my dog out, food, water, mattress, excessive heat south 2, fires/drugs/fights guards did nothing. Administrative segregation without a hearing. 8th: no bail/excessive bail, cruel and unusual punishment, chained shackled in hallways while others were not. 6th: courtrooms, law library, slow medical treatment, responding with legal paperwork, people quarantine in C2B. Case law filtered. 14th equal protection: Muslims get church, more tablets, rec time, better food, contact. Mail in/mail out, not enough clothes, Final Call racist. Black mold, cockroaches, shit/piss/semen, sexual harassment in front of guards. "Going to the hole without punishment ie written up, cancelling commissary, being placed on PHD."

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 · 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 · Aug 10, 20223 pages

Page 8 details Nichols PTSD symptoms (paragraphs 27-35): brain fog, sleeplessness, anxiety, depression, hypervigilance, short term memory loss, anger, suicidal thoughts. Pre-incarceration management with psychotherapy, medical marijuana, exercise, family time, outdoors. Triggers include isolation, lack of sunlight, hostile environments. Cites United States v. Perry (D. Neb. 1995). Respondents refused access to prior treatment regimen on arrival at DC Jail.

letter · Sep 13, 2021

Page 2 of Garret Miller civil rights timeline. (8) Oklahoma Transfer Center 23-hour 15-min lockdown, 45 min/day rotating for phone/law library/showers. Bone solidified with multiple bone shards before received shoulder surgery. (9) Chickasaw County overnight no bedding/extra clothing, slept on floor. (10) DC-CTF: no religious services, observant Jew - inseparable requests and Bible requests unanswered. No outdoor rec for a month (3 months including Oklahoma). Mail withheld, no haircuts, no visitation. Harassment for actions of others. 2 hand-drawn American Flags confiscated for showing patriotism on Memorial Day. Refers to attorney Clint Broden (214) 563-3154, 2600 State St, Dallas TX 75204.