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United States v. Nichols
Case No. 1:21-cr-00117 · U.S. District Court for the District of Columbia · 10 federal charges · Judge Hon. Thomas F. Hogan (pretrial & detention, 2021–2023); Hon. Royce C. Lamberth (plea, sentencing & judgment, 2023–2025)
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Oct 28, 2022
Nichols Supplement to Pretrial Release - Doc 177 p.4/11 - Washington testimony rebutted
Page 4 of 11 of Doc 177. Argues Washington testimony provably false. Officer Feliciano took drive (with body cam off), not Washington with envelope. Drive returned by Officer Saunders without envelope. Washington carefully fails to admit/deny full chain of custody.
ReadOct 28, 2022
Nichols Supplement to Pretrial Release - Doc 177 p.5/11 - Three drives explained
Page 5 of 11 of Doc 177. Explains THREE drives at issue: red+blue thumb drives delivered Jul 2021 by Buck Files (prior attorney), black terabyte drive Oct 2021 by McBride. Red drive given to McBride during attorney visit; Officer Solwannii witness with body cam.
ReadOct 28, 2022
Nichols Supplement to Pretrial Release - Doc 177 p.6/11 - Missing blue drive & Rappahannock Sgt. Foster
Page 6 of 11 of Doc 177. Details: Aug 29 confiscation of black terabyte (blue thumb not noticed); Sept 5 someone took blue thumb drive. Rappahannock Jail (now holding Nichols) does not allow electronic discovery review outside attorney visits. Sgt. Foster told Nichols Oct 28 jail aware of Court order.
ReadOct 28, 2022
Nichols Supplement to Pretrial Release - Doc 177 p.7/11 - ARGUMENT Point One
Page 7 of 11 of Doc 177. Begins ARGUMENT section. Point One: Missing hard drive justifies release. Section 3142(i) provides release for defense preparation. Three questions Washington must explain. Sept 5 removal as pretext to steal blue drive.
ReadOct 28, 2022
Nichols Supplement to Pretrial Release - Doc 177 p.8/11 - Point Two: Sixth Amendment
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.
ReadOct 28, 2022
Nichols Supplement to Pretrial Release - Doc 177 p.9/11 - Marshals custodian, Point Three
Page 9 of 11 of Doc 177. US Marshal Lamont Ruffin email (Exhibit C) - US Marshals are primary custodian. Refused Sukkot religious holiday request for 15 min outside. Begins POINT THREE - recent discovery drop and J6 congressional hearings show govt at fault for long detention.
ReadOct 28, 2022
Nichols Supplement to Pretrial Release - Doc 177 p.11/11 - COS
Page 11 of 11 (final page) of Doc 177. McBride contact info continued (phone, email). CERTIFICATE OF ELECTRONIC SERVICE: filed Oct 28, 2022 via CM/ECF by /s/Jonathan Gross.
ReadOct 27, 2022
Rappahannock Regional Jail Returned Grievance (improperly filed, 10/27/22)
Rappahannock Regional Jail (RRJ) Returned Grievance Form Control No. 032590 dated 10/27/22, returned by Ombudsman (Boyce?) to Ryan Nichols. Marked: failed to file an Inmate Request Form to attempt informal resolution, complaint not grievable issue, improperly filed. Cites IRF #1209691, references US Marshals approval, Inmate Handbook Sections 23-24. Federal judges have no control over RRJ facility.
ReadOct 27, 2022
Rappahannock Regional Jail Returned Grievance Form (Control No. 032582)
Official Rappahannock Regional Jail grievance return form rejecting Ryan Nichols grievance about lockdown conditions. Cites improper filing procedure and claims complaint is not grievable. References Officer Riverson informing Nichols that lockdown for security reasons is not grievable as it is a jail operation. Signed by Ombudsman A. Joyce 10/27/22.
ReadOct 27, 2022
RRJ Returned Grievance #032581: duplicate, Abuse of Grievance System warning (10/27/22)
Rappahannock Regional Jail Returned Grievance Form Control No. 032581 dated 10/27/22, signed by Ombudsman (Boyce). Marked: failed to file Inmate Request Form first, complaint not grievable, duplicate (refers to GR #032523, #032536, #032538), improperly filed. Comment: "Continuous Grievance submissions for the same non-grievable issue in which you ve already received response for is considered an abuse of the system and further submissions will result in you being institutionally charged with Abuse of the Grievance System. No action to be taken." Punitive denial of grievance access.
ReadOct 26, 2022
RRJ Grievance: Judge Hogan ordered evidence.com access (10/26/22)
Rappahannock Regional Jail Inmate Grievance Form OPER-0019, Control No. 032590, filed by Ryan Nichols (ID #20221663, SSN xxx-xx-4381) housing C-4/18 on 10/26/22 at 17:20 to Officer Vick. Grievance: Judge Thomas Hogan in Federal Court ordered that Ryan could view evidence.com/relativity.com and have access to his discovery in jail to prepare for trial. Cites violation of 6th Amendment right. References Inmate Request Form #1209691 returned 10/25/22 3:25 PM. Returned by Ombudsman 10/27/22 (the form returned in j6s8-044).
ReadOct 25, 2022
Rec Lockdown Schedule log continuation: 10/25-10/27/22 - 755 total minutes lost
Continuation of Ryan Nichols handwritten rec-lockdown log (from j6s8-058) for 10/25-10/27/22 at RRJ C-4. Compiled totals: 10/21 70 + 10/22 140 + 10/23 45 + 10/24 285 + 10/25 5 + 10/26 165 + 10/27 45 = 755 total minutes lost for the week.
ReadOct 24, 2022
Inmate Grievance Form (Control 032582) - Officer Riverson, 10/24/22
Rappahannock Regional Jail Inmate Grievance Form filed by Ryan Nichols (ID 2022/663, C4/18) against Officer Riverson for improperly rejecting an earlier grievance about jail policy lockdown. Filed 10/24/22 20:42; received by ombudsman 10/25/22. Compares jail policy to historical examples of laws that were overturned (women and Black voting rights).
ReadOct 24, 2022
RRJ Grievance #032581: 1265 minutes lost, names O Connor/Alexander/Barnett (10/24/22)
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.
ReadOct 24, 2022
RRJ Inmate Grievance: 1265 minutes lost rec week 2 (10/24/22)
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.
ReadOct 24, 2022
RRJ Inmate Grievance: Officer Riverson — IGP held no merit (10/24/22)
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 20:42 to Officer Barry. Grievance: Officer Riverson came to the door 20 minutes after Ryan submitted his grievance and told him his grievance held no merit. References Inmate Request Form #1209696 (j6s8-061). Faded handwriting partially illegible.
ReadOct 21, 2022
Rec Lockdown Schedule log 10/21-10/27/22 - C-4 daily lost minutes
Ryan Nichols handwritten daily "Rec Lockdown Schedule" log for Rappahannock Regional Jail C-4 covering 10/21/22 through 10/27/22. Each day records scheduled rec start times, actual lockdowns, reasons (maintenance, slow inspection, trays, code red, meds, late officer, laundry), and minutes lost. Names officers Ms Burns, Ms Barry, Barnett. Quoted: "There isn't enough resources to give us rec at tray time."
ReadOct 20, 2022
Returned Grievance Form 10/20/22 (Control 032562) - Zoloft
Official Rappahannock Regional Jail returned grievance form rejecting Ryan Nichols Zoloft grievance. States while incarcerated, medical/mental health/jail physician serve as PCP and decide medical protocol. Records indicate Zoloft prescription was renewed on 10/13/22. Signed by Ombudsman A. Joyce 10/20/22.
ReadOct 19, 2022
Govt Second Supplement to Opposition - Doc 172 p.1/3
Page 1 of 3 of Document 172 - Government Second Supplement to Opposition to Motion for Release. In advance of Oct 24 2022 motion hearing. References inventory log from Rappahannock Regional Jail.
ReadOct 19, 2022
Govt Second Supplement to Opposition - Doc 172 p.2/3 + signatures
Page 2 of 3 of Doc 172. Government does not oppose transfer if other facility can accommodate. DOC confirms only 2 drives. No personal belongings remaining. Requests DOC General Counsel attend Oct 24 hearing virtually. Signature block.
ReadOct 19, 2022
Govt Second Supplement - Doc 172 p.3/3 - Certificate of Service
Page 3 of 3 (final page) of Doc 172. Certificate of Service - served on defense counsel via email Oct 19 2022 by /s Sarah W. Rocha.
ReadOct 19, 2022
Medical Request 10/19/22 - Ibuprofen Refill with Response (back pain)
Same Ibuprofen refill request as j6s8-078 but with nurse response. Response dated 10/20/22 prescribes Ibuprofen 600mg twice a day for back pain. Signed by nurse B. Lyle (?).
ReadOct 19, 2022
Medical Request Form 10/19/22 - Ibuprofen refill
Yellow Medical Request Form from Ryan Nichols dated 10/19/22 (Officer Berry note: 10/19/22 0830) requesting refill of Ibuprofen for pain. Short routine request, no response filled in.
ReadOct 18, 2022
Status Conference Transcript — Sep 21, 2022 (ECF 171)
Status conference before Judge Thomas F. Hogan, September 21, 2022. Official transcript.
ReadOct 17, 2022
RRJ Inmate Request Form #1209691: evidence.com access (10/17/22)
Rappahannock Regional Jail Inmate Request Form #1209691 PROG-0024 — Ryan Nichols (ID #20221663, SSN xxx-xx-4381) Housing Unit C-4/18 dated 10/17/22 requesting access to a computer (secured) to view evidence.com/relativity.com and hard-drive discovery before trial, asking DC DOC help. Received by Officer Lucas 10/18/22 at 1000. Action taken by C/O Pruitt: "We do not allow access to outside.com for any inmate. It is unlikely the hard drive request could be sent to US Marshals. Discovery this is appropriate I will see if we can accommodate this request." Response received by counselor 10/25/22 at 1300.
ReadOct 17, 2022
RRJ Inmate Request: observe Jewish holiday Sukkot in outdoor rec yard (10/17/22)
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.
ReadOct 15, 2022
Handwritten log: Issues in C-4 (10/15-11/1/22) - understaffing, grievance log
Ryan Nichols handwritten log titled "Issues in C-4" documenting daily problems at Rappahannock Regional Jail housing unit C-4 from 10/15/22 to 11/1/22. Names officers (O'Connor, Barry, Garnett, Riverson, Vick, Halegan) and incidents: severe understaffing (3 pods one corrections officer), lockdowns, 3rd person added to 2-man room, IGP retaliation, and being denied appeal forms. Key evidence of conditions of confinement.
ReadOct 15, 2022
Witness statement: Cpl O Connor admits understaffing (10/15/22, co-signed John Obarr)
Handwritten sworn witness statement titled "Afternoon Lockdown" by Ryan Nichols #20221663 and co-signed by cellmate John Obarr #20180387, dated 10/15/22. Statement recounts Cpl O Connor twice telling them they were locked down for "Security Reasons" before privately admitting at 1:43 pm to John Obarr that the real reason was understaffing. Both attest the conversation was true; John Obarr signs that he was not paid, tricked, coerced or forced to sign. Critical contemporaneous corroborated evidence of false reasons for confinement.
ReadOct 14, 2022
Rec-time loss log: RRJ C-4 week of 10/14-10/20/22, 1265 minutes lost
Handwritten daily rec-time tracking log for Rappahannock Regional Jail housing C-4 — detailed minute-by-minute accounting of recreation deprivation from 10/14/22 through 10/20/22. Each day shows scheduled rec start time, actual lockdowns, reasons given ("security reasons," understaffing, COVID issues, mass punishment for "19 minutes to lockdown"), and minutes lost. Bottom totals: 1265 rec minutes lost = 21.08 hours = 3.51 days of rec. References IGP submitted 10/24/22, handed to Ms Barry at 6:35 PM through tray slot. Companion to grievance #032590.
ReadOct 14, 2022
RRJ Inmate Request #1209696: 680 minutes lost rec — request denied (10/14/22)
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.
ReadOct 14, 2022
Atty/Rabbi Gross to SDUSM Haywood: Nichols Sukkot religious accommodation (Oct 2022)
Oct 14 2022 1:17 PM Gmail message from Jonathan Gross (attorney and Jewish rabbi) to Supervisory Deputy US Marshal Derek Haywood (Derek.Haywood@usdoj.gov), cc Joseph McBride. Reports Marshal Ruffin identified Haywood as contact. Says Ryan Nichols (USMS custody at Rappahannock Jail) wants to observe Sukkot (Leviticus 23:44) by having a meal in a Sukkah; Jail denied his 15-minute outside-under-sky request; grievance filed but holiday ends Sunday.
ReadOct 14, 2022
Rappahannock Regional Jail Inmate Grievance - rec time denied
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.
ReadOct 13, 2022
Bradley and Matthew Bokoski Plead Guilty to One Misdemeanor Count
Contemporary report identifying the four original misdemeanor charges, the single parading count to which each man pleaded guilty, and the reported agreement to dismiss the other three counts.
ReadOct 13, 2022
RRJ Medical Request Form: John O. mental-health crisis in C-4/18 (10/13/22)
Rappahannock Regional Jail Medical Request Form filed by inmate John O. (apparent surname Obass/Oboss), DOB 10/29/90, SSN ending 7900, housing C-4/18 (same block as Ryan Nichols), dated 10/13/22 — mental-health request: hearing voices, imaginary friend named Jeffrey talks to him all night and doesn't let him sleep, being locked in this room all day is doing weird things. Stamped received 10/14/22 0700. May be witness/contextual evidence of conditions in Ryan's housing unit.
ReadOct 13, 2022
RRJ Medical Request: John O. shoulder pain (10/13/22)
Rappahannock Regional Jail Medical Request Form filed by same inmate John O. (DOB 10/29/90, SSN ending 7900, housing C-4/18) dated 10/13/22 — medical request: right shoulder hurts really bad, needs to be seen for pain. Companion form to j6s8-049. Same Ryan-adjacent cellblock.
ReadOct 12, 2022
Inmate Grievance Form 10/12/22 - PTSD/Zoloft (Control 032562, received 10/17/22)
Cleaner copy of the 10/12/22 PTSD/Zoloft Inmate Grievance Form filed by Ryan Nichols (ID 2022/663). Control No. 032562, received by ombudsman 10/17/22 by Officer Vick. Same content as j6s8-075 (this is the formal copy that produced the 10/20/22 returned grievance in j6s8-076).
ReadOct 12, 2022
Inmate Grievance Form 10/12/22 - PTSD/Zoloft Discontinuation
Rappahannock Regional Jail Inmate Grievance Form filed by Ryan Nichols (ID 2022/663, C4/18) on 10/12/22 grieving denial of mental health meds. States he was diagnosed with PTSD, on Zoloft for over a year, and on 10/9/22 was told he would be taken off meds unless seen by Mental Health, but was never seen.
ReadOct 12, 2022
Medical Request Form 10/12/22 - 2nd Mental Health Request (Zoloft)
Second Medical Request Form from Ryan Nichols dated 10/12/22 escalating mental health concern. Documents he has been on Zoloft for over a year and was told 2 days before the 9th that he would not be receiving his mental health meds after 11th. Stresses I HAVE TO HAVE THESE MEDS.
ReadOct 12, 2022
Status Conference Transcript — Oct 7, 2022 (ECF 170)
Status conference before Judge Thomas F. Hogan, October 7, 2022. Official transcript.
ReadOct 12, 2022
Medical Request - Zoloft 2nd Request with Nurse Response 10/14/22
Duplicate of the 2nd mental health Medical Request Form from 10/12/22, now showing nurse response dated 10/14/22 14:51 confirming Zoloft has been renewed and is being delivered from the med-cart.
ReadOct 9, 2022
Rappahannock Medical Request - Zoloft refill 10/9/22 (Nurse Response)
Medical Request Form from Ryan Nichols dated 10/9/22 requesting Zoloft refill. Response from medical staff dated 10/28/22 indicates psych med was updated 10/25/22 and inmate is on one med, with medical following.
ReadOct 9, 2022
Rappahannock Regional Jail Medical Request Form 10/9/22 (Rx refill)
Yellow Medical Request Form from Ryan Nichols (C4/18, DOB 12/06/1980) dated 10/9/22 requesting med/mental health follow-up regarding Bicalut[amide/Buspar] refill. States nurse said prescription was running out and he cannot come off the medication.
ReadOct 7, 2022
Rec Math page 2/2 conclusion: 25.4 days/month locked in cell = MENTAL TORTURE
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.
ReadOct 7, 2022
Rec-time loss log: RRJ C-4 week of 10/7-10/13/22, 680 minutes lost
Companion handwritten daily rec-time tracking log for Rappahannock Regional Jail C-4 covering 10/7/22 to 10/13/22, totaling 680 rec minutes lost = 11.3 hours. Daily breakdown with reasons: codes, shakedown, meds/trays, laundry, inspection, suicide (Cole Brown 10/10/22 4:00). Documents 10/9/22 "lost all morning rec."
ReadOct 7, 2022
Notice of Voluntary Dismissal — Nichols v. Garland (ECF 12)
October 7, 2022: the habeas petition is voluntarily dismissed. Weeks later, on November 22, 2022, the criminal court ordered release on personal recognizance.
ReadOct 7, 2022
Rec Math scratch page 2: 25.24 days in cell per month = TORTURE
Continuation of scratch rec-math calculations (page 2 of j6s8-056) by Ryan Nichols, concluding 25.24 days in a cell per month = TORTURE / 25.4 days = TORTURE. Companion working calculation to the formal grievance attachment.
ReadOct 7, 2022
Rec Math scratch revision: 1835 minutes lost / 605.70 hours in cell
Scratch handwritten revision of Ryan Nichols rec-math calculations (companion to j6s8-052, 053, 054, 055, 067). Shows arithmetic corrections: 1265 amended to 1155 for week 2, yielding 1835 total rec minutes lost in 2 weeks instead of 1945. Recomputes projected monthly cell hours at 605.70/720.
ReadOct 6, 2022
Govt Supplement Doc 169 p2/5: CDF/CTF discovery review program, USB transfer to CVRJ
Page 2 of 5 of ECF Doc 169. Explains DOC Central Detention Facility (CDF) vs Central Treatment Facility (CTF) Voluminous Evidence Review program, Ingrid Washingtons Aug 29 2022 collection of Nichols laptop and USB drive, claim she did not review or copy USB contents, and US Marshals transfer of Nichols USB drive to Central Virginia Regional Jail (CVRJ).
ReadShowing 481–528 of 1,866 documents