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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 6, 2022
Govt Supplement Doc 169 p3/5: bagged USB drive photo, prosecution team denial
Page 3 of 5 of ECF Doc 169. Includes photo exhibit of a bagged Nichols USB hard drive labeled Nichols, Ryan alongside COVID-19 vaccination card. Government denies prosecution team ever examined or possessed the drive. Section III rebuts Nichols claim that hard drive mysteriously disappeared.
ReadOct 6, 2022
Govt Supplement Doc 169 p4/5: TWO drives argument, prayer to deny release
Page 4 of 5 of ECF Doc 169. Quotes Nichols motion claims about USB drive, notes Nichols reply (ECF 168) and affidavit (ECF 168-4) introduce a second blue drive for first time. Notes Ms. Washington stated first discovery drive delivered to DOC was not operable or not compatible with DOC discovery laptops; attorney notified Oct 7, 2021. Government concludes by requesting Court deny emergency-release motion.
ReadOct 6, 2022
Govt Supplement to Opposition to Motion for Release re USB hard drive (Doc 169, p1/5)
Page 1 of 5 of Government supplement (ECF Doc 169) to its opposition to Nichols motion for release in 1:21-cr-117 (TFH). Discusses DOC confiscation and return of Nichols electronic-discovery hard drive at DC jail on Aug 29, 2022, citing affidavit of Ingrid Washington (DOC Litigation Support Unit).
ReadOct 6, 2022
Govt Supplement Doc 169 p5/5: signature block (Graves/Brasher/Rocha)
Signature page of ECF Doc 169 (Govt Supplement to Opposition to Motion for Release). Signed by Matthew M. Graves US Attorney DC; /s/ Douglas B. Brasher AUSA Federal Major Crimes (Dallas TX); Sarah W. Rocha Trial Attorney (Chicago IL).
ReadOct 6, 2022
Govt Supplement to Opposition - Doc 169 p.1/5 - Hard Drive Status
Government supplement to opposition to motion for release (Doc 169), page 1 of 5. Addresses status of electronic discovery and DOC confiscation of USB hard drive from Nichols on August 29, 2022.
ReadOct 6, 2022
Govt Supplement to Opposition - Doc 169 p.2/5 - Washington Aff. Details
Page 2 of 5 of Doc 169. Details Ms. Washington (DOC) administering Voluminous and Electronic Evidence Review program at CDF and CTF. Nichols hard drive transported to Central Virginia Regional Jail.
ReadOct 6, 2022
Govt Supplement to Opposition - Doc 169 p.3/5 - SanDisk Photo & Sect III
Page 3 of 5 of Doc 169. Includes a photograph of evidence bag with SanDisk USB drive labeled Nichols, COVID-19 vaccination record. Section III argues second drive that Nichols claims disappeared was not operable and returned in 2021.
ReadOct 6, 2022
Govt Supplement to Opposition - Doc 169 p.4/5 - Two Drives Issue
Page 4 of 5 of Doc 169. Continues quoting Nichols motion. Notes Nichols asserts in reply brief (ECF 168) and affidavit (ECF 168-4) that he had TWO hard drives on Aug 29 2022. Government requests court deny emergency release.
ReadOct 6, 2022
Rappahannock Jail Grievance 10/6/22 - lockdown over staffing
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.
ReadOct 6, 2022
Doc 169-1 p.7/13 - DOC Voluminous Evidence Review Procedure (Exhibit A pt 2)
Page 7 of 13 of Doc 169-1 (Washington affidavit attachments). Continuation of DOC procedure letter (Exhibit A) describing inmate evidence review rules, two-week review periods, waitlists, refusal process.
ReadOct 6, 2022
Doc 169-1 p.8/13 - DOC Procedure Letter end (Exhibit A pt 3)
Page 8 of 13 of Doc 169-1. Final page of DOC procedure letter (Exhibit A). Note about contact visits causing 14-day medical enhanced monitoring.
ReadOct 6, 2022
Govt Supplement to Opposition - Doc 169 p.5/5 - Signatures
Page 5 of 5 (final page) of Doc 169. Signature page with Matthew M. Graves (US Attorney), Douglas B. Brasher (AUSA Federal Major Crimes - Detailee), Sarah W. Rocha (Trial Attorney).
ReadOct 6, 2022
Doc 169-1 p.11/13 - Exhibit C or separator (small inline)
Page 11 of 13 of Doc 169-1. Small file size suggests blank page or short content - likely start of Exhibit C (Aug 30 2022 DOC letter clarifying Voluminous/Electronic Discovery procedure).
ReadOct 6, 2022
Doc 169-1 p.9/13 - Exhibit content (small inline file)
Page from Document 169-1 attachments. Small file size suggests mostly blank page or simple exhibit (likely Exhibit B - Oct 7 2021 email or beginning of Exhibit C).
ReadOct 6, 2022
Doc 169-1 Washington Affidavit - exhibit page (largely blank)
Page from Document 169-1 attachments (Washington affidavit exhibits A/B/C). File is largely blank/empty page based on small file size, likely separator page between exhibits.
ReadOct 5, 2022
Affidavit of Ingrid Washington - Doc 169-1 p.3/13 (Aug 29 incident)
Page 3 of 13 of Washington affidavit. Describes Aug 29 2022 incident where Washington attempted to retrieve discovery laptop and USB drive from Nichols. Nichols refused, became confrontational, other inmates yelled. Other COs retrieved USB drive, returned shortly after.
ReadOct 5, 2022
Affidavit of Ingrid Washington - Doc 169-1 p.4/13 (Signature, conclusion)
Final page of Washington affidavit text. Paragraphs 7-9 conclude. Aug 30 2022 DOC issued letter clarifying Voluminous/Electronic Discovery procedure. Washington did NOT confiscate USB. Signature of Ingrid Washington, executed Oct 5, 2022.
ReadOct 5, 2022
Affidavit of Ingrid Washington - Doc 169-1 p.1 of 13
First substantive page of Affidavit of Ingrid Washington (Doc 169-1), Legal Instruments Examiner in DOC Litigation Support Unit. Describes her role administering Voluminous/Electronic Evidence Review program.
ReadOct 5, 2022
Rappahannock Jail Grievance 10/5/22 - second day lost rec time
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.
ReadOct 4, 2022
Email Ted Hull (NNRJ Supt) to attorney Gross re: Quaglin discovery disappeared
Email dated October 4, 2022 from Ted Hull (Superintendent, Northern Neck Regional Jail) to attorney Jonathan Gross (jonathansgross@gmail.com), cc Michelle Lewis, regarding J6 co-defendant Christopher Quaglin's missing discovery materials. Hull dismissively says he has no interest in resolving the "mystery" of disappeared discovery and offers to swap volumes if too large. Documents jail interference with attorney-client discovery in another J6 case.
ReadOct 4, 2022
Email thread Hull/Gross re: Quaglin weight loss, court concerns - jail refusal
Email thread Oct 4, 2022 between attorney Jonathan Gross and Superintendent Ted Hull. Gross informs Hull that the court has expressed concern multiple times about Quaglin's health (dangerous weight loss) and asks parties to put differences aside. Hull responds with single word "NO". Documents jail's deliberate indifference toward J6 detainee health concerns even after court expression.
ReadOct 4, 2022
Hull email continued - cites court ruled habeas without merit, refuses further
Page of Hull/Gross email thread continued. Ted Hull asserts "A Court of Record has reviewed your client's complaints and found them without merit" regarding Quaglin's habeas corpus motion. Hull refuses further engagement and refers to court ruling. Documents the official position that resulted in further mistreatment of J6 detainee Quaglin.
ReadOct 4, 2022
Atty Jonathan Gross to Supt Ted Hull re Quaglin health/discovery (Oct 2022)
Email exchange between J6 defense attorney Jonathan Gross and Northern Neck Regional Jail Superintendent Ted Hull regarding J6 defendant Christopher Quaglin health concerns and missing discovery documents, referencing Judge McFadden.
ReadOct 3, 2022
Atty Gross to Hull cont: Quaglin gluten food/missing discovery
Continuation of email from defense attorney Jonathan Gross (The Clevenger Firm, Baltimore MD) re Quaglin: requests neutral third-party food observer for gluten cross-contamination, raises pattern of disappearing discovery documents, attorney visit policies.
ReadSep 30, 2022
Defendant Reply — page 10 of 14
Argues jail policies constitute prima facie denial of right to meaningful defense participation. Section II.B: § 3142(i) does not require material change in § 3142(g) factors.
ReadSep 30, 2022
Defendant Reply — page 11 of 14
Cites Thorne extensively: § 3142(g) factors considered without requiring new/material change. Discusses Thorne defendant facing life imprisonment, 44 kg heroin/fentanyl, released for COVID.
ReadSep 30, 2022
Defendant Reply — page 12 of 14
Argues this case is easier than Thorne/Ali because no flight risk, no genocide attempt. Trial earliest March 2023. Section C: jail conditions complaints directly relevant.
ReadSep 30, 2022
Defendant Reply — page 2 of 14
Continues B (character: Marines, Ellen talk show, saved lives). C: Sept 5 incident - Nichols allegedly abused by lieutenant, never charged. D: confiscation of thumb drives.
ReadSep 30, 2022
Defendant Reply — page 3 of 14
Section E: alleges USMS transferred Nichols to moot habeas petition. Argument II.A: thumb drive confiscation is sufficient basis for release under § 3142(i).
ReadSep 30, 2022
Defendant Reply — page 4 of 14
Arguments: 90 minutes is enough time to copy thumb drive contents; government representation that prosecution team has not reviewed is meaningless.
ReadSep 30, 2022
Defendant Reply — page 5 of 14
Argues government carefully worded representation about prosecution team possessing thumb drive does not cover guards, jail litigation team, US marshals, J6 committee, or news media.
ReadSep 30, 2022
Defendant Reply — page 6 of 14
Argues litigation strategies could be leaked to media or J6 committee. Cites Mohamedou Ould Salahi v. Obama for proposition that even Guantanamo detainees have right to legal materials in cell.
ReadSep 30, 2022
Defendant Reply — page 7 of 14
Subsection 3: thumb drive confiscated again Sept 5, still missing two weeks later. Subsection 4: Ali findings on harsh conditions not reversed.
ReadSep 30, 2022
Defendant Reply — page 8 of 14
Distinguishes Ali: D.C. Circuit only reversed on flight risk grounds; the harsh conditions findings stood. Ali was a Somali pirate; Nichols is American citizen, veteran, philanthropist.
ReadSep 30, 2022
Defendant Reply — page 9 of 14
Argues Ali findings on harsh DC Jail practices were not reversed. Subsection 5: government policies make trial prep impossible due to opaque 2-week laptop rotation.
ReadSep 30, 2022
Defendant Reply to Government Opposition — page 1 of 14
Cover page of Defendant Nichols Reply to Government Opposition to Motion for Pretrial Release (Doc 168). References Exhibit A (habeas petition) and Exhibit C (further conditions of confinement).
ReadSep 30, 2022
Emergency Motion for Release - Doc 168 p.13/14 - Conclusion
Page 13 of 14 of Emergency Motion for Release (Doc 168). Discusses PTSD, solitary confinement, government as immediate custodian, transfer as due process violation, and conclusion requesting pretrial release.
ReadSep 30, 2022
Emergency Motion for Release - Doc 168 p.14/14 - Signature/COS
Page 14 of 14 (final page) of Emergency Motion for Release. Contains signatures of Jonathan Gross and Joseph D. McBride, and Certificate of Electronic Service.
ReadSep 29, 2022
Ryan Nichols Biography By Bonnie Nichols
Ryan Nichols Biography By Bonnie Nichols — from the Ryan Nichols master exhibit archive (EX-172), preserved and published as part of the complete J6 record.
ReadSep 28, 2022
Defense Reply — Motion to Dismiss (ECF 167)
The defense reply in support of dismissal.
ReadSep 28, 2022
Reply to Govt Opposition p8: McBride & Gross signature, cert of service
Page 8 of 8. Signed by Joseph D. McBride (McBride Law Firm PLLC, NY) and Jonathan S. Gross (Clevenger Firm, Baltimore MD). Dated September 28 2022 Washington DC. Certificate of service via ECF.
ReadSep 26, 2022
DOJ guilty-plea record — Daniel Ray Caldwell
Official Justice Department record reporting Caldwell’s September 26, 2022 guilty plea to assaulting, resisting, or impeding certain officers using a dangerous weapon. Government descriptions remain attributed to the plea and DOJ record.
ReadSep 23, 2022
Douglas Austin Jensen Jury Verdict — DOJ Record
Official DOJ verdict announcement recording a September 23, 2022 jury finding on five felony and two misdemeanor counts. Government descriptions of the evidence remain attributed.
ReadSep 22, 2022
Stephen Ayres Sentenced to Probation, Community Service, and Restitution
Contemporaneous court reporting states that Judge John D. Bates sentenced Stephen Ayres to 24 months of probation, 100 hours of community service, and $500 restitution. The native signed judgment remains a capture priority.
ReadSep 21, 2022
Government Response to Motion to Dismiss (ECF 165)
The government's opposition to the motion to dismiss.
ReadSep 21, 2022
DOJ plea release for Andrew Alan Hernandez
Official DOJ announcement recording the single obstruction plea and government account; press-release characterizations remain attributed.
ReadSep 20, 2022
C-2B notes Sept 17-20: Kamala Harris shirt, EKT/TKU riot gear, food
Continuation of C-2B contemporaneous jail conditions log Sept 17-20. Documents case manager wearing Kamala Harris for the People shirt, 30+ EKT/TKU officers in full riot gear, an officer calling Padilla a Pussy Ass Cracker, detainees locked in cells without toilet/water access until 2:50pm, night shift officer banging flashlight 1am-5am, inadequate dinner trays, multiple grievances filed.
ReadSep 19, 2022
Criminal Complaint — United States v. Rebecca Lavrenz
One-page complaint signed September 19, 2022, listing four misdemeanor charges. This is a charging document and not a finding of guilt.
ReadShowing 529–576 of 1,866 documents