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May 9, 2022

Habeas Petition p.34 — IGP Coordinator T. Campbell grievance handling

Page 34 of habeas petition detailing IGP Step 1/Step 2 grievance failures by Coordinator T. Campbell; mental health appointments Mar 25 and Mar 30 2022 inadequate; therapist Bruce Reid mentioned.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.35 — Steps 3 and 4 grievance: solitary, water shutoff, suicide watch

Page 35 of habeas petition describing Step 3 Warden Admin Remedy and Step 4 Deputy Director Appeal; mentions retaliatory solitary, water shut off, medication denial, suicide watch in medical 82.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.36 — Step 4 Appeal sabotaged, IGP Coordinator changed form

Page 36 documents Step 4 Appeal to Deputy Director where IGP Coordinator T. Campbell crossed out "Step 4: Appeal" and rewrote as "Step 1: Informal," sending petitioner back to start.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.37 — Grievance against IGP Coordinator T. Campbell

Page 37 continues IGP critique; May 24 2022 grievance filed against T. Campbell; June 9 2022 response denies sabotage allegation; cites EXHIBIT C at 5-6.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.38 — 108 grievances, 42 ignored, intimidation of J6 detainees

…% non-response rate); cites system-wide obfuscation against J6 Detainee Cohort.

May 9, 2022

Habeas Petition p.39 — Grievance sabotage, Nov 11 2021 gassing of multiple prisoners

Page 39 describes deliberate grievance sabotage: changed grievance numbers, no group grievances allowed; Nov 11 2021 guard gassed prisoners, three removed on stretchers.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.40 — Inaccessible grievance process; Section VI Legal Standard begins

Page 40 closes Section K (grievance) showing process inaccessible — no handbook, Step 3 form missing — and time limits expanded May 20 2022 in retaliation. Section VI Legal Standard opens with Blackstone quote on arbitrary imprisonment.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.41 — Suspension Clause, 28 USC 2241 jurisdiction, Section A conditions of confinement

Page 41 continues Legal Standard with 28 U.S.C. 2241 habeas authority and 28 U.S.C. 1331 jurisdiction; cites Boumediene v. Bush, Ziglar v. Abbasi; begins Section A: Conditions of Confinement Claims Are Proper In Habeas.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.42 — Section B Due Process Rights of Pretrial Detainees

Page 42 closes Section A with Aamer v. Obama, Thompson v. Choinski; opens Section B Due Process Rights of Pretrial Detainees citing Bell v. Wolfish and Kingsley v. Hendrickson.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.43 — Section C Deliberate Indifference to Underlying Medical Condition

Page 43 ends Section B and opens Section C on Deliberate Indifference, citing Baker v. DC, Farmer v. Brennan, Gordon v. Orange County, Castro v. LA.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.44 — Section D Solitary Confinement as Punishment; Biblical and historical examples

Page 44 opens Section D on solitary confinement as unlawful punishment for pretrial detainees; cites Sierra Club v. Army Corps, Power Mobility Coal v. Leavitt; Biblical examples (Daniel, Jeremiah, John); Stalin and Vilensky.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.45 — Nelson Mandela, Eastern State Penitentiary 1829, Senator Warren on ICE solitary

Page 45 continues solitary confinement history with Mandela quote, Eastern State Penitentiary 1829 origins, Justice Miller 1890, and Senator Elizabeth Warren Oct 31 2019 letter to DHS CRCL on ICE solitary abuse.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.46 — Section E HALT Act, NY Solitary Confinement, Senator Salazar

Page 46 opens Section E on New York HALT Act signed Mar 18 2021 by Gov. Cuomo, adopting UN Mandela Rules; quote from Senator Julia Salazar (Chair of Crime Victims Committee).

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.47 — Section F UN Standard Minimum Rules (Nelson Mandela Rules)

Page 47 opens Section F on UN Nelson Mandela Rules; cites WHO, UN, NCCHC declaring solitary >15 days as torture; Rule 1 inherent dignity.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.48 — Section G Prolonged Solitary as Torture; Section VII PRLA Exhaustion

Page 48 details Mandela Rules 43, 44, 45 banning prolonged solitary, dietary punishment, and solitary for disabled; opens Section VII on PRLA exhaustion 42 U.S.C. 1997e(a).

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.49 — PRLA Unavailability, Thwarting Process, Interference

Page 49 explains PRLA exhaustion exceptions: unavailability (Booth v. Churner, Ross v. Blake), thwarting (Woodford v. Ngo), and interference by officials.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.50 — Section A Petitioner Excused from PRLA Exhaustion

Page 50 cites Davis v. Hernandez, Schultz v. Pugh, Pavey v. Conley, Tuckel v. Grover, Goebert v. Lee County to support exhaustion exception; Section A argues unavailable grievance procedure.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.51 — Unavailability and Thwarting/Interference as PRLA exceptions

Page 51 lays out specific PRLA exhaustion exceptions: 196 unavailability with Ross v. Blake and 197 thwarting/interference with Woodford v. Ngo.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.52 — Intimidation, Misleading; US Marshals declared grievance process broken

Page 52 continues PRLA exceptions: 198 intimidation/threats; 199 misleading — references US Marshals surprise inspection declaring DC Jail grievance process broken; 200 Petitioner is excused.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.53 — Section VIII First Claim: Deliberate Indifference Violates 5th Amend Due Process

Page 53 opens Section VIII Causes of Action with First Claim — Respondents Garland and Jones deliberate indifference to medical safety/needs violates Fifth Amendment Due Process Clause.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.54 — WaPo Op-Ed by ACLU Gregg + NYCLU Liberman on solitary torture

Page 54 quotes Apr 28 2021 Washington Post op-ed by ACLU National Prison Project deputy director Tammy Gregg and NYCLU executive director Donna Liberman declaring prolonged solitary is torture; 60,000-300,000 held in solitary in US.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.55 — Congressman Gohmert wellness check, 3 weeks solitary April 2022

Page 55 alleges Respondents repeatedly placed Petitioner in solitary despite PTSD diagnosis; April 2022 3-week solitary for refusing to admit guilt; April 21 2022 Congressman Louie Gohmert wellness check.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.56 — Gohmert Aug 8 2022 follow-up; Second Claim: Solitary Violates Due Process

Page 56 quotes Aug 8 2022 Congressman Gohmert follow-up letter to USMS Director Davis; opens Second Claim for Relief — illegal solitary confinement violates Fifth Amendment Due Process.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.57 — Third Claim: Prolonged Solitary Violates 5th and 8th Amendments

Page 57 details Petitioner held in prolonged solitary first 9 months of detention and 3 weeks more recently; opens Third Claim for Relief — Fifth and Eighth Amendment violations.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.58 — ACLU 2013 Report "A Death Before Dying" on solitary effects

Page 58 cites ACLU July 2013 report "A Death Before Dying: Solitary Confinement on Death Row" listing psychological/physical symptoms of solitary including EEG decline after 7 days and increased suicide rates.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.59 — Fourth Claim: 6th Amendment Right to Counsel Violations

Page 59 opens Fourth Claim: monitoring of attorney-client privileged calls, discovery confiscation, denial of law library access, blocked legal calls, denied discovery for all of May 2022.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.60 — Fifth Claim 1st Amendment Retaliation; Section IX Conclusion

Page 60 references Judge Thomas Hogan ordering Relativity database access 3 times; opens Fifth Claim — First Amendment retaliation for press/Congressional contact; Section IX Conclusion summarizes claims.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 9, 2022

Habeas Petition p.61 — Section X Prayer for Relief: release, injunction, release to wife Bonnie

Page 61 opens Section X Prayer for Relief: writ under 28 USC 1331/2201-02 and FRCP 57/65; TRO and injunction against pretrial solitary; immediate release to wife Bonnie Nichols; 28 USC 2243 within 3 days; FRE 706 expert site visits.

Source: J6 Scan 33 — Habeas Corpus / Drive

May 8, 2022

Statement in defense of Ryan Nichols — page 2 (signatures)

Page 2 of 2 — signature roster of nine J6 co-detainees attesting to the page-1 statement (j6s24-003)…

May 7, 2022

Statement in defense of Ryan Nichols (re: Brandon Fellows tablet message) — page 1

Page 1 of 2 of a multi-detainee witness statement dated 5/7/2022, drafted in response to a tablet message (DCDOCTA-2085, pod C2B) authored by Brandon Fellows. The drafter recovers Fellows's message accusing Ryan Nichols (the "detail member") of physically threatening him over an NPR article, names corroborating witnesses, and asserts the allegations are false and misleading.

Source: J6 Scan 24 — Witness Statements / Drive

May 6, 2022

DC DOC Issues log - April-May 2022 (CPL Abdullah, water shutoffs, suicidal)

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.

Source: J6 Scan 3 folder / Drive

May 2, 2022

Electronic IGP #2022050-120 (5/2/22 follow-up): 20+ hours no water, TORTURE

Second electronic IGP # 2022050-120 (Response ID 192766) submitted by Ryan Nichols 5/2/22 3:47 PM, following up about being deprived of water 20 hours 15 minutes (2:45 PM 5/1 to ~11 AM 5/2) over actions of cell 10 inmate. Calls treatment cruel and unusual punishment, the better word for it is TORTURE, compares to China, North Korea, Russia.

Source: J6 Scan 13 — May 2022 / Drive

May 2, 2022

IGP #2022050-120 page 2: Civil court max damages, McBride contact, release demand

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.

Source: J6 Scan 13 — May 2022 / Drive

May 1, 2022

Electronic IGP #2022050-120: Water shut off 3-4 hrs, cell 9 inmate medical emergency

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.

Source: J6 Scan 13 — May 2022 / Drive

May 1, 2022

IGP #2022050-120 page 2: solitary 50+ hrs, anxiety, mental state, dehydration

Page 2 of electronic IGP # 2022050-120 (companion to j6s13-012). Continuation of Ryan Nichols 5/1/22 grievance abou…

Apr 26, 2022

IGP Formal Grievance re: Food Service unanswered (4/26/22, ref 20220414-304)

DOC PP 4030.1 Inmate Formal Grievance Form filed by Ryan Nichols (DCDC# 376795) on 4/26/22 escalating informal grievance #20220414-304 about the disparity in food quality between Kosher/Halal meals and regular diet meals.

Source: J6 Scan 15 — April 2022 / Drive

Apr 21, 2022

DC DOC Warden Appeal: solitary, denied PTSD medication (4/21/22)

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."

Source: J6 Scan 8 folder / Drive

Apr 21, 2022

Warden Admin Remedy Form IGP 20220425-991 re: mental health treatment denied (4/21/22)

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."

Source: J6 Scan 15 — April 2022 / Drive

Apr 21, 2022

Wardens Administrative Remedy Form — Mental Health Treatment Denial (4/21/22)

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.

Source: J6 Scan 8 folder / Drive

Apr 21, 2022

Envelope to Kelly Meggs (co-defendant) from Zachry Meggs, Florida, Apr 2022

Envelope addressed to fellow J6 co-defendant Kelly Meggs (Offender ID 376780) at DC CTF, po…

Apr 20, 2022

Handwritten daily log of SMU-A segregation 4/20-5/5/22 (Ryan Nichols journal)

Handwritten daily log/journal by Ryan Nichols documenting his time in SMU-A (Special Management Unit / segregation) from Wed 4/20/22 through Thu 5/5/22 after refusing to sign a non-animosity form. Names multiple DOC officers (Lt Lancaster, Lt Allen, Cpl Pittman, Cpl Wilson, Sgt Franklin, Lt Bruce, supervisor refused to come). Documents denials of recreation, phone calls, showers, water shutoff, suicidal ideation, and ICPs filed electronically.

Source: J6 Scan 15 — April 2022 / Drive

Apr 20, 2022

IGP 20220414-804 Informal Resolution w/ DOC Response by Dalton (filed 4/13, resp 4/20/22)

DOC PP 4030.1 Informal Resolution Complaint Form, IGP # 20220414-804, filed by Ryan Nichols (DCDC# 376795, Unit C2B) on 4/13/22 re: Kosher/Halal meal quality vs regular diet. Stamped RECEIVED Apr 14 2022. DOC Response from Dalton (COVID-19 manager) dated 14 Apr 22 / 4/20/22.

Source: J6 Scan 15 — April 2022 / Drive

Apr 20, 2022

IGP 2209716-259 Informal Resolution re: Non-Animosity form / Brandon Fellows / Lt Bruce (4/20/22)

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.

Source: J6 Scan 15 — April 2022 / Drive

Apr 20, 2022

IGP 2209716-282 Informal Resolution re: Mental Health follow-up nondelivery (4/20/22, resp 4/29/22)

DOC PP 4030.1 Informal Resolution Complaint Form, IGP # 2209716-282, filed by Ryan Nichols (DCDC# 376795, Unit C-2B) on 4/20/22 complaining mental health follow-up promised at 2-week intervals was not happening. DOC response dated 4/29/22: "Seen for Mental Health Follow-Up appointment 4/27/2022. Assessment plan was completed and will be referred to open. Grievance Resolved." Stamped RECEIVED APR 25 2022 and COMPLETED.

Source: J6 Scan 15 — April 2022 / Drive

Apr 20, 2022

Step 1 IGP #22090716-282: Original mental health follow-up grievance, return to open pop

DC DOC Step 1 Informal Resolution Form (IGP # 22090716-282) by Ryan Nichols dated 4/20/22 - the foundational mental health follow-up grievance referenced throughout the May 2022 chain. Met with therapist 3/30/22 but no long-term mental health care; meeting consisted of being told he talks about PTSD and conditions of confinement. DOC Response 4/29/22 by Hodges: Seen for Mental Health Follow-Up appointment 4/27/2022, assessment plan was completed and will be returned to open population. Grievance resolved. Manager COVID-19, 5/3/22.

Source: J6 Scan 13 — May 2022 / Drive

Apr 20, 2022

DENIAL of Inmate IGP Form 2209716-259 by T. Campbell (4/25/22)

DOC PP 4030.1 Denial of Inmate IGP Form (Attachment B), grievance # 2209716-259, dated 4/20/2022, denied by IGP Coordinator T. Campbell on 4/25/2022. Returned because the issue is addressed in Grievance # 2209716-260.

Source: J6 Scan 15 — April 2022 / Drive

Apr 19, 2022

Shane Jenkins — DC DOC response on returned flash drive (IGP #20220323-324)

Letter from Wanda Patten, DC DOC Deputy Director of Operations, responding to grievance about resident Shane Jenkins #377-186, confirming his flash drive was returned to sender due to employee error (employee was unaware that all discoveries are sent to the litigation department).

Source: J6 Scan 29 — Shane Jenkins / Drive

Apr 19, 2022

Shane Jenkins — DCDOC Tablet Submission Response cover (IGP #20220323-324)

DC DOC Inmate Informal Resolution Complaint Form / Tablet Submission Response cover sheet for Warden Administrative Remedy Grievance IGP #20220323-324, with response Please see attached and Inmate Grievance Coordinator signature dated 4/21/2022.

Source: J6 Scan 29 — Shane Jenkins / Drive