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Apr 17, 2022

Continued motion notes: Deliberate Indifference and Access to Basics

Continuation page (sections 4-6) of the change-of-venue / conditions outline. Argues deliberate indifference, requests injunctive relief, and itemizes deprivation of basics like haircuts (13 mo), shower (5 days), worship/communion (never), family contact.

Source: J6 Scan 10 folder / Drive

Apr 17, 2022

Habeas/Conditions/Discovery notes for change-of-venue, Apr 17 2022

Ryan Nichols handwritten outline at DC Jail CTF (C2B) preparing change-of-venue arguments: PTSD habeas motion, conditions-of-confinement claims, and discovery issues. Lists supporting evidence types and complaints about lockdown.

Source: J6 Scan 10 folder / Drive

Apr 17, 2022

Motion outline continued: informants, media, PTSD triggers, guards

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.

Source: J6 Scan 10 folder / Drive

Apr 16, 2022

Timeline - p9 (23-1 lockdown, mail delays, Ryan Samsel beating, Fairlamb)

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.

Source: J6 Scan 4 folder / Drive

Apr 13, 2022

DC DOC Formal Grievance: inadequate mental health treatment (4/13/22)

DC DOC Inmate Formal Grievance Form (PP 4030.1, IGP #20220420-921) filed by Ryan Nichols #376795 C2B on 4/13/22 escalating Informal Grievance #20220330-526 — appointments only 3-10 minutes long, asking only to schedule another appointment, no mental-health therapy at DC DOC. Witnessed by Sgt Kenneth Harrelson U.S. Marines.

Source: J6 Scan 8 folder / Drive

Apr 13, 2022

IGP 20220420-921 Formal Grievance re: Mental Health Treatment Denied (CENTRAL EVIDENCE) (4/13/22)

DOC PP 4030.1 Inmate Formal Grievance Form (Attachment D), IGP # 20220420-921, the central mental health grievance referenced throughout the case file. Filed by Ryan Nichols (DCDC# 376795, Unit C2B) on 4/13/22, signed by inmate again 4/13/22. Escalates Informal Grievance # 20220330-526 about mental health appointments being inadequate. DOC Response from DeVera Jones (OMHS) dated 4/19/22, Manager: Beth Jordan, dated 4/20/2022. "Witnessed by Sgt Kenneth Harrison."

Source: J6 Scan 15 — April 2022 / Drive

Apr 13, 2022

Inmate Formal Grievance — Mental Health Care, USMC Veteran PTSD (4/13/22)

DC DOC Inmate Formal Grievance Form (PP 4030.1, Attachment D), filed by Ryan Nichols, DCDC# 376795, Unit C2B, signed 4/13/22. IGP #20220420-921. Health Care category. Complains 3/25/22 appointment was only 3-5 min to schedule, 3/30/22 was 10 min with therapist who said shed check back. Notes hes an honorably discharged Marine Corps veteran with PTSD; needs more than 10 min every 2 weeks of mental health care. Cites Sgt Kenneth Thornton, USMC Ret. as witness. DOC Response by De Vera Jones, OMSA: Nichols seen 3/25 and 3/30/22 for consultations; Dr. Bowes will reach out for blood work appointment and discuss long-term therapy options. Manager Names not filled out correctly per Ryan.

Source: J6 Scan 8 folder / Drive

Apr 13, 2022

IGP Informal Resolution Complaint Form re: Kosher/Halal meal quality (4/13/22)

DOC PP 4030.1 Inmate Informal Resolution Complaint Form filed by Ryan Nichols (DCDC# 376795, Unit C2B) on 4/13/22 complaining that Jewish Kosher and Muslim Halal meals are noticeably better quality than the regular diet meals.

Source: J6 Scan 15 — April 2022 / Drive

Apr 11, 2022

Envelope to Kelly Meggs from Connie Meggs (wife/co-defendant), Apr 2022

…(Offender 376780) at DC CTF from Connie Meggs (his wife and J6 co-defendant), 14100 SW 101st Ln, Dunnellon FL 34432. Postm…

Apr 6, 2022

James McGrew veteran witness statement re DC DOC (p.2, signed 4-6-22)

McGrew page 2 (signed 4-6-22): Judge Howell has tried to step in to facilitate his treatment which jail still has not provided; mental health in constant decline; moods up and down; chronic pain worse; has watched other veterans' mental health decline across the board; spends most time in his cell because anxiety is too bad to be around people. Signed James McGrew 4-6-22.

Source: J6 Scan 34 — Witness Statements / Notes / Drive

Apr 6, 2022

Jessica Watkins veteran witness statement re DC DOC (p.1)

…air fell out, bruises, eyesight), and staff harassment over J6 political beliefs blaming detainees for DC police suicides.

Apr 6, 2022

Jessica Watkins veteran witness statement re DC DOC (p.2, signed 6 Apr 22)

Page 2 (signed) of Watkins' affidavit: filthy peroxide cleaner instead of bleach, black mold/sewer flies/cockroaches, Marjorie Taylor Greene and Louie Gohmert congressional visit, due process violations (seized/lost Discovery), constant mail interference, improper strip searches of transgender detainee. Signed Jessica Watkins #376520, 6 Apr 22.

Source: J6 Scan 34 — Witness Statements / Notes / Drive

Apr 4, 2022

Peter Stager — Religious Services request denied, no Sunday services (Ryan Nichols, 4/4/22)

DC DOC Religious Services Inmate Request Form submitted by Ryan Nichols (DCDC #376795, C2B-10) asking to attend Sunday church services. Staff response highlighted: "There are no Sunday services at this time." Response ID 176827, dated 04-05-2022.

Source: J6 Scan 25 — Peter Stager / Drive

Apr 4, 2022

Peter Stager — Case Management request for family visit, Ryan Nichols 4/4/22

DC DOC Case Management Inmate Request Form by Ryan Nichols (DCDC #376795, C2-B-Level 57, Cell 10) asking for a 2-hour visit with his wife and father on 4/8/22 or 4/15/22. Notes family coming from Texas; may require deputy warden approval. Handwritten annotation: "Request sent McCui[n] 4/7". Top: "Stan, Ian, or Dan" notation.

Source: J6 Scan 25 — Peter Stager / Drive

Apr 2, 2022

IGP #20220330-520 — DOC response to Shane Jenkins formal grievance (4/2/22)

DCDOC Formal Grievance Tablet Submission Response for Shane Jenkins (DCDC #377186, C2B) on IGP #20220330-520. DOC affirms ongoing medical stay-in-place by Mayor due to Covid-19, will be modified based on CDC updates.

Source: J6 Scan 26 — Witness Statements / IGPs / Drive

Mar 31, 2022

Conditions log — DC DOC Notes page 7, Mar 21-31 (Cpl Allen, PTSD requests, NPR contact)

Page 7: 3/21 Cpl Allen incident & mental-health request, 3/22 Major Talley questioning re email grievance, 3/23-24 no mental-health appt, 3/30 therapist says no long-term mental health treatment available, 3/31 outside party (Brandon) enters at 6:45pm soliciting statements for NPR about Mellis and others — Capt Wilson notified.

Source: J6 Scan 27 — Notes / Drive

Mar 30, 2022

Formal Grievance 3/30/22 — IGP denial appeal (IGP 20220328-441)

DC DOC Inmate Formal Grievance Form filed by Nichols 3/30/22 escalating denial of IGP 20220328-441 (informal). Claims his informal grievance was denied as non-grievable; argues per inmate handbook page 12, denial of access to informal resolution/IGP process is itself a grievable issue, and that prior IGPs have been ignored or unanswered.

Source: J6 Scan 14 — March 2022 / Drive

Mar 29, 2022

Peter Stager — handwritten statement on IGP #20220201-685 irregularities and PREA

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.

Source: J6 Scan 25 — Peter Stager / Drive

Mar 29, 2022

IGP #20220330-520 — Shane Jenkins Formal Grievance, lockdown unconstitutional (3/29/22)

DCDOC Formal Grievance Form (Response ID 174908, IGP #20220330-520) by Shane Jenkins (DCDC #377186, C2B) escalating earlier lockdown grievance IGP #20220105-069. Argues 22-hr cell confinement is cruel and unusual punishment for pretrial detainees.

Source: J6 Scan 26 — Witness Statements / IGPs / Drive

Mar 29, 2022

Peter Stager — CONFIDENTIAL envelope received 3/29/22 by Officer Pittman

Front of envelope (companion to scan 006) bearing red "CONFIDENTIAL" stamp. Handwritten annotation: "Received 3-29-22 9:00 AM Officer Pittman." Documents receipt timing claimed in IGP #20220201-685 statement.

Source: J6 Scan 25 — Peter Stager / Drive

Mar 29, 2022

Peter Stager — envelope receipt: Received 3/29/22 11:00 AM by Officer Pittman

Front of envelope (paired with scan 010) bearing handwritten receipt annotation: "Received 3/29/22 11:00 AM Pittman" — matches the 11:00 AM time and Officer Pittman name from Stager statement scan 003.

Source: J6 Scan 25 — Peter Stager / Drive

Mar 28, 2022

Peter Stager — DOC Memorandum PREA Case Closure from C. Savage (3/28/22)

DC DOC official Memorandum to Stager, Peter DCDC 376784, C2B-8, from C. Savage, PREA Compliance Specialist, dated March 28, 2022. Subject: PREA Case Closure. Text: "Please be advised, your PREA allegation reported on 2/16/2022 was withdrawn by you. The PREA Compliance Specialist met with you on 2/17/2022 and during your interview, you withdrew your complaint and signed (attached) documentation confirming such." Initialed "CS" by Savage.

Source: J6 Scan 25 — Peter Stager / Drive

Mar 28, 2022

DOC Denial of IGP 20220328-491 — T. Campbell

Denial of Inmate IGP Form (PP 4030.1 Attachment B) by IGP Coordinator T. Campbell denying Ryan Nichols IGP # 20220328-491 dated 3/28/22. Marked X: There is no indication that you were personally affected by a Department or facility action or policy/procedure. Note CTF facility, C2B housing.

Source: J6 Scan 14 — March 2022 / Drive

Mar 28, 2022

Stamped IGP 20220328-491 — US Marshals grievance, marked Non-Grievable by Plant Mgr

…2 informal grievance (IGP # 20220328-491) — content matches j6s14-012 (US Marshals Anderson/Bickham confirming DC DOC IGP…

Mar 24, 2022

Grievance 3/24/22 mental health request denied — witnessed by Kenny Harrelson, IGP 20220330-526

DC DOC Informal Resolution Complaint Form by Ryan Nichols 3/24/22 (IGP # 20220330-526). After returning from medical visit on 3/21/22 he put in a mental health request witnessed by Kenny Harrelson. Has not been seen by medical or asked about his mental health status. PTSD - requests to be seen. DOC response: appointment 3/25/2022 - grievance resolved. Witnessed by Kenny Harrelson.

Source: J6 Scan 14 — March 2022 / Drive

Mar 24, 2022

Pink IGP Coordinator copy — mental health grievance 3/24/22 (originating form)

…e stamped Mar 30 2022 received version with DOC response is j6s14-006.

Mar 23, 2022

Shane Jenkins — Warden Step 3 Appeal re: mailroom flash drive (IGP #20220323-324)

Step 3 Warden Administrative Remedy appeal filed by Shane Jenkins #377186, Unit C2B, escalating IGP #20220311-131 about mailroom mishandling of his highly-sensitive DOJ discovery flash drive that delayed his speedy-trial preparation.

Source: J6 Scan 29 — Shane Jenkins / Drive

Mar 22, 2022

Witnessed narrative — Major Talley conversation 3/22/22 (signed by Kelly Meggs)

…jor Marr. Witnessed and signed by Kelly Meggs (Oath Keepers J6 defendant) who attests he heard the entire conversation and…

Mar 21, 2022

DC DOC Informal Resolution: mental health grievance (3/21/22)

DC DOC Inmate Informal Resolution Complaint Form (PP 4030.1, IGP #20220330-526) filed by Ryan Nichols #376795 in unit C2B alleging he was put in a mental-health request after returning from a medical visit on 3/21/22, witnessed by Kenny Harrelson. Resolved 3/25/22 with mental-health appointment scheduled.

Source: J6 Scan 8 folder / Drive

Mar 21, 2022

Grievance vs Cpl Allen 3/21/22 — verbal assault during medical transfer (KN95 mask)

DC DOC Informal Resolution Complaint Form by Ryan Nichols dated 3/21/22 against Cpl Allen. Alleges that during transfer to medical, Cpl Allen became aggressive, hostile, confrontational and threatening toward him and other inmates over the specific type of mask Nichols was wearing (KN95). Notes the verbal assault and cursing were captured on video surveillance, that he returned to his cell and asked for an LT (lieutenant) to escalate.

Source: J6 Scan 14 — March 2022 / Drive

Mar 21, 2022

Peter Stager — Major Sheila Marr DOC response to IGP grievance #20220201-685 (3/21/22)

DC DOC response memo. TO: Inmate Peter Stager, DCDC# 376784. FROM: Major Sheila Marr, #2 Shift, dated 3/21/22 (initialed SM). SUBJECT: Response to Inmate Grievance. RE: Grievance #20220201-685. Text: "Upon review of your grievance 20220201-685, on this date the officer may have requested that you ask due to maintenance being present in an effort to prevent unnecessary injury to staff and inmates. The latter portion of your grievance will be referred to the PREA Coordinator."

Source: J6 Scan 25 — Peter Stager / Drive

Mar 19, 2022

Grievance 3/19/22 — US Marshals (Anderson, Bickham) confirm DC DOC IGP process is broken

DC DOC Informal Resolution Complaint by Nichols dated 3/19/22 documenting that on 3/18/22 US Marshals Mr. Anderson and Mr. Marvin T. Bickham visited Pod C2B and informed inmates that the DC DOC grievance process was broken, along with the Internal Affairs report showing the same. Nichols states he has filed many grievances by paper and electronically that have been ignored or covered up — including grievances about racist language used against himself and other inmates, abusive behavior, discrimination, and conditions of confinement. As a veteran diagnosed with PTSD, demands accountability of IGP staff according to policy.

Source: J6 Scan 14 — March 2022 / Drive

Mar 18, 2022

Conditions log — DC DOC Issues page 6, Feb 26 to Mar 18 (haircuts, 'insurrectionist', US Marshals)

Page 6: Officer Ugwe admits clippers delivered to C2A and other pods but not theirs; Capt Saunders writes 5 DRs about masks; Guy Reffitt gets clippers via court order, others denied; Sgt Franklin and Ms McCain refuse to add Ryan to haircut list until 3/11 when he is 'called an insurrectionist'; Major Marr brushes off grievance; Marvin T. Buckner from DOC/US Marshals confirms grievance process broken — directs to FOIA Internal Affairs.

Source: J6 Scan 27 — Notes / Drive

Mar 18, 2022

Step 4 Deputy Director Appeal 3/18/22 — haircut/vaccine broken promise (Judge Hogan bond hearing)

DC DOC Appeal-Deputy Director Form (Step 4, PP 4030.1 Attachment G) filed by Nichols 3/18/22 appealing Warden response to IGP # 20220316-236. Documents that on 11/1/21 and 11/2/21 DC DOC told Nichols he would be eligible for a haircut BEFORE his bond hearing if he took the vaccine. He was fully vaccinated 12/4/21 but never received haircut or shave; his bond hearing was 12/20/21 in front of Judge Thomas Hogan and he looked terrible/embarrassed/ashamed.

Source: J6 Scan 14 — March 2022 / Drive

Mar 17, 2022

DC DOC Memorandum 3/17/22 — Deputy Warden Jones re Warden Admin Remedy IGP 20220316-236 (haircut)

DC DOC official Memorandum to Ryan Nichols 376795 from Deputy Warden Jones (signed) dated March 17 2022. Subject: IGP 20220316-236 Wardens Administrative Remedy, Ref: Personal Hygiene. Acknowledges Nichols personal hygiene grievance about not receiving a haircut, confirms he was fully vaccinated as of 12/29/21. Cites Modified Medical Stay in Place effective 12/22/21 suspending barbering/cosmetology for vaccinated residents (except those with upcoming jury trials), and the 2/14/22 modification resuming barbering for fully vaccinated residents and those with upcoming jury trials effective 2/28/22. States C2B haircuts scheduled second Friday of each month, next service April 8 2022. Officer assigned to barbering indicates Nichols received barbering service on March 11 2022.

Source: J6 Scan 14 — March 2022 / Drive

Mar 17, 2022

Step 3 Wardens Administrative Remedy 3/17/22 — Formal IGP 22091385-795 with constitutional/due-process case cites

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.

Source: J6 Scan 14 — March 2022 / Drive

Mar 17, 2022

Shane Jenkins — DOC Formal Grievance response IGP #20220311-131 (mailroom flash drive)

DC DOC Formal Grievance response in IGP #20220311-131 by responder Ben Collins (Manager: COVID-19), apologizing and confirming a meeting was held with mailroom staff about incoming mail materials such as flash drives needing to be forwarded to Litigation Department.

Source: J6 Scan 29 — Shane Jenkins / Drive

Mar 17, 2022

IGP #20220311-131 — DOC response to Shane Jenkins mailroom grievance (3/17/22)

DCDOC Formal Grievance Tablet Submission Response to Shane Jenkins (DCDC #377186, C2B) IGP #20220311-131. Responder Ben Collins apologizes, references mailroom meeting and flash drive forwarding to Litigation Department.

Source: J6 Scan 26 — Witness Statements / IGPs / Drive

Mar 16, 2022

Grievance vs Major Marr — stamped Mar 16 2022 with DOC response from Talley

DC DOC stamped copy of Nichols 3/15/22 Informal Resolution Complaint against Major Marr (IGP # 20220316-330) received Mar 16 2022. DOC response by Talley: I spoke to Ryan Nichols concerning the email from Maj. Marr and he did not have it. I did speak on staff professionalism. Any specific complaints will be addressed ASAP. Signed Talley.

Source: J6 Scan 14 — March 2022 / Drive

Mar 15, 2022

Grievance vs Major Marr — Dec 16 2021 email re grand scheme

DC DOC Inmate Informal Resolution Complaint Form filed by Ryan Nichols against Major Marr. Nichols alleges he discovered a Dec 16 2021 6:52am email from Major Marr to other ranking jail officers describing a grand scheme against the officers including Nichols and other CZB inmates. Claims untrue, discriminatory, unprofessional, intentional target on his back.

Source: J6 Scan 14 — March 2022 / Drive

Mar 14, 2022

Step 3 Warden Admin Remedy 3/14/22 — IGP 20220316-236 (haircut/Major Marr classification)

…esponse: See attached, with signature and date [referencing j6s14-015 Memo]. Coordinator signature 3/17/22.

Mar 14, 2022

Pink IGP Coordinator copy of Step 3 Warden Admin Remedy 3/14/22 (IGP 22091885-797 → 20220316-236)

…s Administrative Remedy Form dated 3/14/22. Same content as j6s14-017 (haircut grievance, Major Marr classification issue,…

Mar 9, 2022

Grievance 3/9/22 — request to add investigative attorney to APDS tablet (atty Joseph McBride, 6A counsel)

DC DOC Informal Resolution Complaint Form by Ryan Nichols 3/9/22. Requests his investigative attorney be added to his APDS Tablet because discovery has been shared on the APDS tablet and he needs to share that information with his legal team. On 3/7/22 he requested for his Investigative Attorney to be added but was denied. For his attorney Joseph McBride this is a violation of his 6th Amendment right to counsel. Asks resolution so he can properly prepare for trial.

Source: J6 Scan 14 — March 2022 / Drive

Mar 8, 2022

Step 2 Formal Grievance 3/8/22 — denial of video visits (IGP 22092786-088, Maj Talley, Lt Dowery)

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.

Source: J6 Scan 14 — March 2022 / Drive

Mar 8, 2022

Shane Jenkins — Step 2 Formal Grievance re: mailroom (IGP #20220311-131)

DC DOC Step 2 Inmate Formal Grievance Form filed by Shane Jenkins #377186, Unit C2B, complaining about the mailroom returning his discovery to his lawyer rather than delivering it, alleging mailroom worker Officer Hamil/Hamilton or Hampton mishandled materials and grievances are being delayed and ignored.

Source: J6 Scan 29 — Shane Jenkins / Drive

Mar 8, 2022

Shane Jenkins — Step 2 Formal Grievance: nail clippers/hygiene (IGP #22092796-165)

Pink DC DOC Step 2 Formal Grievance Form filed by Shane Jenkins #377186, Unit C2B, escalating the Personal Hygiene complaint that the original IGP #22092796-165 (1/14/22) was unacceptably answered 3/4/22 and asking how it is humane to leave someone 60+ days without toenail clippers, alleging the Barbershop, DC DOC and Federal BOP are denying basic personal hygiene care and the Inmate Grievance Coordinator is abetting the neglect and blocking court access.

Source: J6 Scan 29 — Shane Jenkins / Drive

Mar 8, 2022

IGP — Shane Jenkins Formal Grievance, mailroom returned grievance (3/8/22)

DC DOC Inmate Formal Grievance Form (PP 4030.1 Att. D), paper version. Shane Jenkins (DCDC #377186, C2B) protests delayed response and mailroom returning his earlier grievance through his lawyer's office. Names Officer Hampton.

Source: J6 Scan 26 — Witness Statements / IGPs / Drive

Mar 8, 2022

IGP #20220311-131 — Shane Jenkins Formal Grievance, mailroom (stamped copy, 3/8/22)

…" with IGP coordinator signature 3/18/22. Same complaint as j6s26-014 with DOC routing markings.