Solitary Confinement Conditions

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 · 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.

grievance_form · Jul 24, 2022

Handwritten IGP (Inmate Grievance Procedure) tracking calendar listing 16+ grievance issues with Step 1-4 dates from March 2022 through July 2022. Tracks business-day deadlines and responses.

grievance_form · Jul 5, 2022

DC DOC IGP Appeal - Deputy Director (Step 4) by Ryan Nichols 376795 C2B dated 7/5/22. Step 1 4/20/22, Step 2 5/13/22, Step 3 6/10/22 about being placed in punitive solitary confinement over allegation by inmate, no investigation done before being segregated. Pre-Trial detainees with diagnosed PTSD should not be placed in punitive solitary confinement without internal hearing, or without any kind, in fact. Demands answers to these due process violations.

grievance_form · Jun 22, 2022

Pink DC DOC Warden Administrative Remedy form (PP 4030.1 Attachment F) filed by Ryan Nichols (DCDC# 376795, C2B) on 6/22/22. Escalates a Formal IGP from 5/20/22 about informing LT Allen he was suicidal while in punitive solitary confinement in SHU-A. Says the IGP was supposed to be answered by 6/13/22 and was not. Notes it is the first day in almost 2 weeks that Step 3 and Step 4 IGPs have been available.

grievance_form · Jun 22, 2022

Pink DC DOC Appeal-Deputy Director form (PP 4030.1 Attachment G) submitted by Ryan Nichols (DCDC# 376795, Unit C2B) appealing Warden IGP response. Complains that an IGP filed 5/24/22 was not addressed regarding water being shut off in cell in SHU-A by officer in nearby cell for 20+ hours as a punitive issue.

exhibit · Jun 21, 2022

Inmate witness statement by Joshua David Roberts (#00046579, mom 804-210-6553) dated 6/21/22 describing 6/16/22 incident: 5 officers cuffed him after he refused to pack up, Officers Kent and Taylor threw him against wall and Officer Taylor said "I have your bitch."

grievance_form · Jun 10, 2022

Pink DC DOC Appeal-Deputy Director form (PP 4030.1 Attachment G) filed by Ryan Nichols (DCDC# 376795, C2B) on 6/10/22. Responds to Deputy Director response of 6/9/22. Of 6 dates mentioned in their response, he was actually only seen and helped by mental health 2 of 6 times (4/27 and 5/17). Was not seen by mental health on 5/6, even though he requested to be seen on 5/5 and 5/6. Mental health was not available; the chaplain only asked whether he was suicidal or not, and not (in worsened conditions) cell that he was in at SHU-A. On 5/7 (5/8) he was only asked questions through a glass for everyone around to hear, the same questions being are you still feeling suicidal. The same exactly happened on 5/9. Mental Health only once a month for documented PTSD/ICD-10 sufferer is wholly inadequate.

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.

grievance_form · Jun 8, 2022

Pink DC DOC Warden Administrative Remedy form (PP 4030.1 Attachment F) filed by Ryan Nichols (DCDC# 376795, C2B) on 6/8/22. Escalates Formal IGP # 20220516-377. Two points: (1) Has been asking for Step 3 Warden IGPs for a week without response; numerous IGPs and C2B just received them today, hence the late response. (2) The IGP for mental health is not resolved: he did NOT get seen by mental health provider on 5/6 as stated in Formal response. Was seen by a doctor who then took him to a worse location than SHU; received no mental healthcare on 5/6, which is the day he informed the facility for the 2nd day in a row about suicidal ideation. Mental health staff put him on medical 82.

grievance_form · May 24, 2022

DC DOC Step 3 Warden Administrative Remedy Form (PP 4030.1, Attachment F) by Ryan Nichols dated 5/24/22, escalating Informal IGP # 20220512-288 and Formal IGP 20220523-501 regarding water shut off in his cell for 20+ hours over the actions of another inmate. References Sept 18 incident as example of past retaliation.

grievance_form · May 22, 2022

DC DOC Step 4 Appeal-Deputy Director Form (PP 4030.1, Attachment G) by Ryan Nichols dated 5/22/22 (IGP # 20220527-612). Appeals failure to receive mental health treatment after solitary confinement, including punitive solitary 4/20/22-5/10/22. References Major Marrs responses. Deputy Director response 6/9/2022: See Attached.

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 · May 13, 2022

DC DOC Step 2 Formal Grievance Form (IGP # 20220516-377) by Ryan Nichols dated 5/13/22 with DOC RESPONSE filled in. Companion to j6s13-044. DOC Response by D. Jones, DHSA, 5/20/22: Mr Nichols has been seen by an MH provider on the following dates 5/6 and 5/17. Grievance answered. Manager B. Jordan 5/29/22.

grievance_form · May 13, 2022

DC DOC Step 2 Formal Grievance by Ryan Nichols dated 5/13/22, escalating Formal IGP # 20220513-291 and Informal IGP # 22090716-282. Was told he would return to his cell after population on 4/27-4/28 but did not until almost 2 weeks later. Mental health/solitary confinement issues for about 2 weeks regardless; not seen for mental health treatment since 4/27/22. Health Care selected.

exhibit · May 13, 2022

Continuation of DC DOC issues log. 5/9/22 Taken back to SHU-B from medical S2. 5/10/22 Taken back to C2B. 5/13/22 Legal mail & commissary returned.

grievance_form · May 10, 2022

DC DOC Inmate Informal Resolution Complaint Form (PP 4030.1, Attachment C), filed by Ryan Nichols, DCDC# 376795, unit C2B (then unit listed 2A), 5/10/22. Categories checked: Health Care; Staff Treatment; Safety and Security; Other. Date of incident 5/5/22. Complaint about being placed in solitary confinement for 13 days, allegedly without proper notification or process. Faint handwriting. No DOC response visible.

grievance_form · May 10, 2022

DC DOC Inmate Informal Resolution Complaint Form (PP 4030.1 Attachment C), filed by Ryan Nichols, DCDC# 376795, C2B / SMU-A, 5/10/22. IGP #20220512-289. Stamped RECEIVED MAY 12 2022. Categories: Health Care, Staff Treatment, Safety/Security. Date of incident 5/5/22 evening. Offender: LT Allen. Reason: On 5/5/22 Ryan informed LT Allen he was suicidal after being in SMU-A solitary confinement for 15 days; LT Allen refused to come up and have a conversation, then said put a request in, then said sorry you feel that way, I hope you dont die, told officer to write that in the book, and left without checking. DOC Response: DOC records clearly state inmate received mental health treatment when it was deemed necessary in a timely manner; he stayed in Medical 82 solo 5/6-5/9. IGP Coord 5/17/22. Ryans note: No mental health care that night, or the next day until the following evening after I told 4-6 officers of the state of my mental health condition.

grievance_form · May 10, 2022

DC DOC Step 1 Informal Resolution Form (IGP # 20220512-289) by Ryan Nichols dated 5/10/22 - critical mental-health/suicide grievance. On 5/5/22 informed LT Allen he was suicidal after 15 days in SMU-A. LT Allen refused conversation, walked away saying Sorry you feel that way, I hope you dont die. Stayed in Medical 82B Solitary cell 5/6-5/9. DOC Response by Tagley 5/10/22 confirms no mental health treatment until 4-6 officers told. Manager: COVID-19.

grievance_form · May 10, 2022

Inmate copy (Copy 2) of DC DOC Informal Resolution Form (IGP # 20220512-288) by Ryan Nichols dated 5/10/22 about water shutoff. Blank DOC response side; manager name field amusingly written as Covid-19. Companion to scan j6s13-007.

grievance_form · May 10, 2022

DC DOC Inmate Informal Resolution Complaint Form (PP 4030.1, IGP #20220512-289) filed by Ryan Nichols #376795 C2B/SMU-A 5/10/22 alleging Lt. Allen refused to engage when Ryan reported being suicidal after 15 days in SMU-A solitary, walked away saying "Sorry you feel that way, I hope you don't die." Tracks lack of mental-health care; Ryan ended up in Medical 82 5/6-5/9. Witnessed by Roberts.

grievance_form · May 10, 2022

DC DOC Inmate Informal Resolution Complaint Form (PP 4030.1) — faded copy from Ryan Nichols 376795 C2A dated 5/10/22. Complaint relates to incident 5/5/22 — being held in solitary confinement for 15 days. Health Care/Safety and Security/Staff Treatment/Other selected. Form blank in DOC response section. Faded ink, partially illegible.

grievance_form · May 1, 2022

Page 2 of electronic IGP # 2022050-120 (companion to j6s13-012). Continuation of Ryan Nichols 5/1/22 grievance about water shutoff, describing being locked in solitary 50+ hours, severely affected mental state, anxiety rising, no disciplinary issues, approved to return to C2B. Key quote: This is punishment without a need for guilt.

grievance_form · Apr 21, 2022

DC DOC Warden Administrative Remedy Form (PP 4030.1 Attachment F, IGP #20220425-991) — Ryan Nichols #376795 C2B SMU-A appealing IGP #20220420-921: mental-health treatment inadequate, conditions of confinement worsening PTSD, mental-health medication not delivered, placed in solitary confinement in segregation as punishment for not signing a form. Warden response: "No response, elevated to next level."

grievance_form · Apr 21, 2022

DC DOC Wardens Administrative Remedy Form (PP 4030.1) filed by Ryan Nichols, DCDC# 376795, Unit C2B, signed 4/21/22, stamped RECEIVED APR 25 2022, IGP #20220425-991. Appeals lack of mental health treatment: missed 3/25/22 evaluation, scheduled with therapist 3/30/22, told would receive long-term mental health treatment at OCDC but never checked in 2/3 weeks later. PTSD diagnosis, anxiety/depression triggered, mental health meds not delivered, sitting in solitary confinement as punishment for not signing a form. Wardens response: No response, elevated to next level. Inmate Grievance Coordinator signature 5/27/22.

grievance_form · Apr 21, 2022

DOC PP 4030.1 Warden Administrative Remedy Form (Attachment F), IGP # 20220425-991, filed by Ryan Nichols (DCDC# 376795, Unit C2B SMU-A) on 4/21/22 appealing the failure to provide mental health treatment. Stamped RECEIVED Apr 25 2022. Warden response 5/27/22: "No response, elevated to next level."

motion · Apr 17, 2022

Continuation page (sections 7-11). Notes motions for final call, informants, media motion, Mike Pence/PTSD triggers citing Boyland/White et al., guard names/badges, solitary, media infiltration (NPR, Randy Ireland, Feds), and cameras/bodycams.

affidavit · Mar 29, 2022

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.

grievance_form · Mar 17, 2022

DC DOC Wardens Administrative Remedy Form (Step 3, PP 4030.1 Attachment F) by Ryan Nichols dated 3/17/22 appealing Formal IGP # 22091385-795 [likely 2202(or 220x)1385-795]. Original informal grievance concerned solitary confinement and constitutional/due process violations from solitary confinement of a pretrial detainee. Cites multiple electronic grievances since December that were never answered, and cases: Porter v. PA Dept of Corr (W.D. Pa 2018), Campbell v. McGruder 580 F.2d 521 (DC Cir 1978), Williams v. Secy PA Dept of Corr 848 F.3d 549 (3d Cir 2017), Lock v. Jenkins 641 F.2d 488 (7th Cir 1981), Bell v. Wolfish 441 U.S. 520 99 S.Ct. 1861 60 L.Ed.2d. Witness: blank.

grievance_form · Mar 8, 2022

DC DOC Inmate Formal Grievance Form (Step 2) by Ryan Nichols 3/8/22 in response to IGP # 22092786-088 (Discrimination category). Disputes Major Talleys response that CTF is not setup for video visits. States Lieutenant D. Dowery said CTF does have video visit capabilities and uses them in D Pod. Requests opportunity to see his family by video since the facility does not allow his family (wife and 2 young children) to visit in person. Notes mental health side effects caused by prolonged period of isolation from family, wife and children.

grievance_form · Feb 10, 2022

DCDOC Formal Grievance #22091885-795 escalating IGP #20220126-551. Nichols argues 22-hr-a-day lockdown meets Merriam-Webster definition of solitary confinement and violates constitutional rights. DOC response (Major Marr 3/9/22): all CDF housing units on 5 hours out-of-cell as of Feb 28, 2022; IGP was during modified medical stay-in-place (22:2).

other · Jan 15, 2022

Handwritten lined notebook page with numbered list items 7-11 covering case strategy: Final Call, Informants motion, Media motion, Mike Pence, PTSD triggers (Boyland/Whito et al.), Guards (need names/badge numbers/descriptions/background), Solitary lockdowns in pod/SHU/elsewhere, Media infiltration (NPR, Randy Ireland, Feds), Camera situation including body cams.

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 · Dec 31, 2021

DC DOC Inmate Informal Resolution Complaint Form filed by Ryan Nichols (DCDC# 376795, Unit C2B) on 12/31/21, complaining that multiple electronically-filed grievances dating back to the Sept 18 incident have gone unanswered during the lockdown.

grievance_form · Dec 30, 2021

Page 2 (continuation) of the typed electronic Informal Grievance #20220105-053 by Ryan Nichols (12/30/21). Continues from j6s18-011, describing gross medical negligence, fear of cover-ups, and characterizes 22+ hour solitary confinement as "mental torture." Completed 1/12/22.

grievance_form · Dec 30, 2021

DC DOC IGP Informal Resolution Complaint #20220121-361 filed by Ryan Nichols on 12/30/21. Documents the Dec 19-25 COVID outbreak, lockdown to 22-2 solitary conditions, no testing, and names Officer Cabbagestalk as the COVID-positive officer who worked the C-2B unit. Marr signed see-attached response 1/27/22.

other · Dec 24, 2021

Short log of two tablet (electronic) grievances Ryan submitted re: lockdown — 12/23 cites 5th, 6th, 8th, 14th Amendment due-process violations; 12/24 adds Supreme Court solitary confinement / torture case law.

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 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?"

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."

letter

Page 2 of Ryan Nichols timeline: cell #11 with black mold over all walls, denied potable water, female guard aimed body cam at him while changing and laughed. "Almost three days w/o sleep." March 24 - April 28 guards beating on cell during checks. Names guards Pinky, Hays, Armstrong, Holmes, Adams. 23/1 lockdown with choice between phone or shower. ERT (Emergency Response Team) sleeps in cell block back room — names Hays, Pinky, Adams, Holmes, Hauser, Franklin.

letter

Continuation page (likely Hale-Cusanelli p2). Laundry never done properly, stains on uniforms never cleaned, towels & sheets always stained w/ urine and feces. Witnesses never called for testimony during disciplinary hearings, inmates isolated in The Hole w/o any paperwork. Force used for inmates by guards excessive and often cruel; guards brag about racism. Civilian property and clothing destroyed by jail after 14 days despite being pretrial detainees. Bond denied completely inconsistent for C2B defendants from other jail inmates or similar political cases. Law library withheld for 4 months. All C2B inmates are in administrative segregation without hearing and no option to opt out for general population. Conversely, guards frequently threaten to send inmates to general pop where its promised well be stabbed to death.

letter

Page 3 of Ryan timeline (May 1 - Aug 1): toilet water diaphragm fails 5 times, flooding cell block. ERT comes with mace cans, Guard Franklin screams "Lock it down! Step back in! You people are all alike!" Ryan, a 70% disabled veteran, denied VA care — took 8 months to get sleep meds and acid reflux meds. Put into isolation cell 25 with human fecal matter, urine smell, jizz dried on wall, black mold. Guards send detainees to "the hole" for arguing.

exhibit

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.

exhibit

Signed witness statement by inmate Joshua Roberts describing being slammed face-first into a door frame, head busted open, hands bent in handcuffs, denied nurse, told to shut the fuck up, and forced to sleep on concrete floor.

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.

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.

other

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.

other

Habeas notes page 3 continuing Farmer: Eighth Amendment claimant must show more than indifference, Whitley standard purposeful/knowing conduct not necessary for conditions cases; deliberate indifference = recklessness; prison official liable only if aware of facts from which inference of substantial risk could be drawn and actually draws inference. Ryan's margin note: he has many grievances about conditions, solitary, mental health; facility is aware.

other · Feb 7, 2022

Ryan's page 2 of Feb 7 incident notes: Mr Burris promised to handle it, detainees stepped back into cells and were locked down rest of day in solitary confinement. Notes inmates above are on lighter lockdown due to school GED program even though they are convicted. Detainees expressed which rights had been violated; told LT Bruce 22/2 lockdown was affecting them mentally.

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.

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 9 of McGrew letter. Cruel and Unusual Punishment claims: 1) transportation in medical condition, 2) long period in solitary confinement, 3) bar at which prosecuted compared to past protest. Denial of Medical Treatment. 6th Amend Procedures to Resolve Complaints: grievance procedures unheard or no response. 14th Equal Protection: denied post-secondary education through DC-DOC/CTF education dept despite handbook saying provided - several grievance forms no relief.

letter

Page 2 of Byerly letter. PC status leak resulted in physical threats and threats of throwing urine, feces, sperm. Last day at CDF, he and cellmate sent to Disciplinary Segregation (the hole) for NO reason at all - upon getting there accused of being racist because they looked racist "white." Threatened with extortion and putting urine and feces in food. In PA bail denied due to 31-year-old conviction; told by temporary counsel that since none of January 6 people were getting bail, he waived his bail hearing temporarily. Rest of jail can do video visits on tablet, J6 detainees cannot - promised early June still not by mid-September.

letter

Page 3 of Meggs testimony. Housed in solitary without request - forms signed for them when they refused (refused 3 times then form signed for him). No video visits despite rest of jail having them. No video visits with attorney. "Have seen 0 evidence of my charges other than a copy of a few documents." Attorney calls take weeks. Food horrible no nutrition - all carb/fat/soy. Cells rust and mold. No chiropractic - "Too bad, we don't do that", denied additional mattress for back pain. Rusty shower areas. In-person Capitol Police served civil suit via guy with visitor tag - did not have to quarantine, but legal visits require detainee quarantine/lockdown. Beyond 24 hours no food or water on arrival.

exhibit · Sep 1, 2022

Page 2 of Ryan Nichols The Final Call essay. Officers told detainees they would be stabbed and killed for being white and Trump Supporters. June 1: Officer Holmes ran into Scott Fairlambs cell threatening Beat his ass for singing the National Anthom and God Bless America, told entire unit to Shut the Fuck Up and Fuck America. Sep 1: Chaplain rounds passing out The Final Call newspaper that inspired the essay title.

exhibit · May 17, 2022

Detailed account of mental health meeting with therapist Ms. White on 5/17/22. Ryan Nichols and Jorden Mink discovered they had been told same scripted responses to separate complaints about officer mistreatment, family visit inability, solitary confinement, no haircuts for 15 months, lengthy pre-trial detention. Therapist claimed it was first time hearing these issues and other inmates told her things weren't so bad here.

affidavit · May 14, 2022

Witness statement authored and signed by Ryan Nichols on 5/14/22 recounting that CPL Abdullah reported on Saturday May 14 at ~10:30am that Divontay Brown had hanged himself in SHU. Nichols had shared a medical safety cell with Brown in early May and reports LT Lancaster refused to release Brown from 22+ months in isolation despite repeated requests for help. Co-witnessed by Peter Stager, Kenny Harrelson, Jeff McKellop, Kelly Meggs.

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 · 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.

grievance_form · Dec 30, 2021

Typed electronic version of the Informal Grievance Form submission by Ryan Nichols on 12/30/21 11:04 PM (Response ID 154119, IGP #20220105-053). Documents the December 19-25 COVID outbreak in DC DOC, names Officer Cabbagestalk as the COVID-positive officer, and names inmate Robert Palmer as confirmed COVID-positive. Received Jan 5 2022; completed 1/12/22.

exhibit · Oct 19, 2021

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.

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."

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. Describes Maria Jacob helping prosecution at detention hearing whose PowerPoint failed to load, coaching McHugh to "sit down, shut up and smile" and nod yes. Alleges Jacob released info to media pre-indictment claiming it proved his innocence while planning to implicate him; says releasing "Findings" from "Bias Judge Howell’s" detention hearing pre-indictment violated his equal-protection rights. Repeats complaints that Jacob waived speedy trial citing complexity/government not ready, refused to file motions, refused to provide detention-hearing transcripts (claiming they cost money and require justification), then claimed to have mailed them after he complained.

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.

motion

Page 2 of pro se ineffective-assistance motion. McHugh accuses Maria Jacob of: (1) waiving his speedy-trial rights on day 30 of incarceration before indictment, framing it as inevitable; (2) coaching him before his 2nd detention hearing to "sit down, shut up, smile, nod my head and reply yes when asked questions"; and (3) exhausting his second detention hearing within 30 days while in Sacramento before reviewing evidence.

letter · Sep 15, 20212 pages

Letter dated Wednesday 9-15-21 from Julian Khater inmate #377187 (J6 detainee charged in Officer Sicknick assault). Got to DC prison 4/13/21 - purposely transferred on bond hearing day to make him miss. Tested negative twice with two different tests but they said half had COVID. Arrived DC with 5 others: Peter S, Jorden M, Tom W, Chris W came from Warsaw Virginia (Northern Neck). Heard short lady saying multiple racist things about them, calling them dangerous, told to "throw us in the Redneck Tank where all the other Jan 6ers are." Still had to quarantine in inhumane/sub-human conditions, 23 hours locked down. First week sleeping on metal no pillow/blanket. Denied medication for chronic congestion and allergic rhinitis - took MONTHS. Chest pains.

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.

affidavit · Apr 6, 2022

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

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.

affidavit

Page 1 of Jeff McKellop signed witness statement describing isolation 24/1, 48/1, 72/1, guards banging cell door nightly, racial harassment, and unsanitary cell conditions (feces, urine, mold) on arrival.

motion · Oct 28, 2022

Page 3 of 11 of Doc 177. Responds to govt argument: drive held less than 90 min was enough to copy. Defends Nichols exemplary record - never charged with disciplinary violation in 2 years. Notes Sept 30 reply (ECF 168), Oct 6 govt supplement (ECF 169) with Washington affidavit.

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.

motion · Aug 10, 202229 pages

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.

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.

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.

motion · Sep 8, 2022

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.

grievance_form · Feb 17, 2022

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.