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Jan 6, 2021

Handwritten evidence catalog: stingball/grenade timeline, Officer Jimmy

Continuing handwritten evidence catalog with timestamps documenting officers throwing grenades into crowd, comments admitting they were spraying their own people, OC spray being useless, and admissions of "hitting innocent people" and "multiplying them by hitting them."

Source: J6 Scan 1 folder / Drive

Jan 6, 2021

Handwritten Evidence.com catalog: pistols, NY officers, taser/munition timeline

Long handwritten catalog of evidence.com bodycam videos with timestamps showing pepper-ball deployments, super-soaker spray, taser deployments without warning, identification of plainclothes officers, including Suffolk County NY badge #6504.

Source: J6 Scan 1 folder / Drive

Jan 6, 2021

Handwritten Evidence.com video catalog (Waldo, Divonnie Powell, Boyland)

Detailed handwritten catalog of multiple Evidence.com bodycam videos noting officer brutality including a woman thrown through gate, a man punched 13+ times after surrender, Waldo references, and Rosanne Boyland body being recovered.

Source: J6 Scan 1 folder / Drive

Jan 6, 2021

Handwritten notes: Alex & Ryan entering stage — discovery video timeline

Detailed timestamp annotations across three discovery videos tracking Ryan Nichols and Alex (likely Alex Harkrider) entering the Capitol grounds and pointing toward tunnel.

Source: J6 Scan 1 folder / Drive

Jan 6, 2021

Handwritten notes: Inside Tunnel View — USCH BA Lower West Terrace videos

Handwritten notes referencing two USCH BA Lower West Terrace Door video files from 2021-01-06 documenting hallway events that prompted calls for more people.

Source: J6 Scan 1 folder / Drive

Jan 6, 2021

Statements Trump & Rudy G Made on Jan 6th - trial by combat quote

Final page of Trump/Rudy quotes. Trump promised to walk down with crowd, and Rudy Giuliani made the trial by combat statement.

Source: J6 Scan 2 folder / Drive

Jan 6, 2021

Statements Trump Made on Jan 6th - handwritten quotes page 1

Handwritten transcription of statements made by Trump during Jan 6 Ellipse speech. Quotes Rudy Giuliani praise, Pence comments, march to Capitol peacefully and patriotically language.

Source: J6 Scan 2 folder / Drive

Jan 6, 2021

Statements Trump Made on Jan 6th - quotes page 2 (fight like hell, walk down Pennsylvania Ave)

Page 2 of Trump statement transcriptions. Contains the criminal enterprise, fight like hell, and Lets walk down Pennsylvania Ave quotes.

Source: J6 Scan 2 folder / Drive

Jan 6, 2021

Timeline - p4 (Jan 6 morning, march to Capitol, flash bangs)

Page 4 of timeline. January 6 morning: woke early, grabbed chest gear, took a crowbar (looked up DC code, legal); Alex took a tomahawk (legal 3 inch blade per DC code nomenclature); listened to speakers including Trump at Washington Monument side of Pennsylvania Ave; felt asked to fight based on president/legal team statements; marched to Capitol when president told us to; explosions on arrival; Ryan climbed Inauguration stage with Alex, sang National Anthem and God Bless America; spoke about certification; flash bangs/tear canisters thrown into crowd hitting old/young/women.

Source: J6 Scan 4 folder / Drive

Jan 6, 2021

Timeline - p5 (Antifa assumption, spray, saving Michael Fanone)

Page 5 of timeline. Describes hallway with people in black gear Ryan assumed were Antifa agitators (police above not caring); people screaming someone was being killed and coming out bloody; crowd sprayed repeatedly, Ryan sprayed directly, took a canister and sprayed twice to neutralize a sprayer giving them a taste of their own medicine. KEY: saw Officer Michael Fanone being pulled out of hallway with people screaming Kill him with his own gun, Ryan and Alex jumped in to stop the angry mob from killing him, yelled to send him to top of stairs and to not kill him.

Source: J6 Scan 4 folder / Drive

Jan 6, 2021

Timeline - p6 (entering Capitol via window, Roxanne, dads call, curfew)

Page 6 of timeline. Entered through broken window 3rd or 4th in; moved furniture in front of door to block police from coming in and shooting; took pictures. After 10-15 minutes dad called (Alexs phone dead) saying a girl had just been shot (Roxanne, presumably Ashli Babbitt or Roseanne Boyland), people at window saying a girl outside had also been killed. Stepped onto windowsill, microphone shoved in hand, spoke anger/rage/sadness at what he was witnessing. Emergency alert about curfew + Trumps tweet to go home prompted them to leave.

Source: J6 Scan 4 folder / Drive

Jan 5, 2021

Timeline - p3 (Jan 5 night, BLM Plaza, MPD)

Page 3 of timeline. Describes January 5 night around White House: barricades, hearing shouting they first thought was Antifa, crowd moved to BLM Plaza for a BLM/Antifa protest; MPD escorted a BLM/Antifa member to their side to antagonize a fight (per Ryans GoPro footage); Ryan surrounded the man as protection and sent him back; stayed 1-2 hours then Ubered to hotel.

Source: J6 Scan 4 folder / Drive

Jan 5, 2021

Timeline - What I Remember p2 (Cammie Bowker, Zello, Jan 4-5)

…nal card from Vegas birthday trip); added to Stop The Steal J6 Zello group by 1% Watchdog with whom Ryan worked Hurricanes…

Jan 1, 2021

J6 Committee timestamps - Bennie Thompson, Liz Cheney, Trump Stop the Steal tweet

Note documenting Jan 6 Committee hearing timestamps with codes (possibly evidence reference numbers): 4:03 PM Bennie Thompson "wounds visible and invisible", 8:25 PM Liz Cheney misinformation from Trump provoked the violence. Reference codes X6039BKE6, BFYR, BLAL, BF8E, BO76. Records Trump Jan 1 2021 7:55pm tweet Stop The Steal.

otherRecord on file — open to view

other

Sep 27, 2019

Legal research notes: Million Man March, Neil Wolf v. DHS, DC self-defense spray code

Ryan's legal-research scratch notes referencing the Million Man March and Neil Wolf v. Dep Homeland Security; DC Code 7-2502.12 (Definition of self defense spray) and 7-2502.13 (Possession of self defense sprays). Cites Civil Action No. 17-1534 (ABJ), Sep 27, 2019.

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

6th District MPD officers near Rosanne Boyland - helmet IDs

Discovery sheet identifying 6th District Metropolitan Police Department officers Carter Moore (helmet 5229), 5077, Travis Tim Johnson, Divonnie Powell (5586/5213), Foy (1213) and others standing over Rosanne Boyland in tunnel footage.

Source: J6 Scan 5 folder / Drive

Amendment Violations of Lonnie Coffman (71) #376190 — meds, MRI, injection

Amendment violations of elderly J6 detainee Lonnie Coffman (age 71, #376190). Suboxone (opioid…

Bodycam log - guy in tunnel corner with spray can - Axon X6039BJ87

Detailed bodycam discovery log for file Sajumon-20210106-Felony-APO-Riotous-Acts-US-Capitol-Complex.mp4, Axon Body 3 X6039BJ87, identifying an individual civilian in tunnel corner with a spray can and water bottle, American flag hat, dual pink respirator cartridges, between 16:24:01 and 16:28:01 - this is exonerating evidence pointing at a different actor.

Source: J6 Scan 6 folder / Drive

Bodycam log page 2 - Officer Sajumon lets spray-can man walk

Page 2 of bodycam log naming Officer Sajumon, documenting that he placed hands on a civilian clearly holding a spray can in left hand at 16:29:02, patted him to send him out at 16:29:15, and let him walk back into the crowd with the spray can visible at 16:29:18 - police facilitation evidence.

Source: J6 Scan 6 folder / Drive

Bodycam log page 5 - Officer strikes on Kyle Fitzsimmons

Page 5 of bodycam discovery log naming co-defendant Kyle Fitzsimmons being struck over head with baton, additional officer helmet numbers, and timeline of officer violence on civilians.

Source: J6 Scan 5 folder / Drive

otherRecord on file — open to view

other

Bond Points: U.S. v. Salerno + Gorsuch quote

Ryan's notes for bail/bond motion citing U.S. v. Salerno (Supreme Court) mixed with U.S. v. Melendez-Carrion - page 747 max length of pretrial detention for Speedy Trial Act, page 748 pretrial not to be held in same facility as convicted or those waiting on appeal (WE ARE), page 750 no conditions of release has to be argued. Quote The Constitution is not suspended during times of crisis - Justice Gorsuch, cited by Ketanji Brown Jackson at confirmation hearing re Gitmo detainees indefinitely held.

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

otherRecord on file — open to view

other

Bond Points: U.S. v. Vasquez-Benitez (DC Cir 2019) parallels to Ryan

Ryan's notes on U.S. v. Vasquez-Benitez (DC Cir 2019) drawing parallels to his own case: defendant ruled not a danger to community under Section II (Bail Reform Act Release); had wife, 2 children, job (just like me); only 1 obstruction conviction although accused of multiple crimes (Ryan: no past convictions); left his gang (Ryan: never been in a gang); demonstrated willingness to appear (Ryan: turned himself in); never convicted of violent crime. Quotes appellate court re not well-positioned to make credibility determinations.

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

Brandon Fellows page 1 — Police permission, FBI lies, Albany Jail intake

Page 1 of detailed letter from J6 defendant Brandon Fellows. Pre-arrest: police said he could…

Brandon Fellows page 2 — Marshals "you ain't shit", Curtis diabetic, Con-Air

Page 2 of Fellows letter. Albany: no running water, roaches climbed through cracks at night, no free phone call, 1 week to reach family. Constantly requested law library - 1 hour entire stay. No church, pastor, paper, pen. No kosher tray. Most days 15-30 min rec. Con-Air flights: black van 8am-12 or 2pm no AC, 10 in van, 1 man Curtis diabetic - officer Chad forgot food, said he was not allowed to leave area, finally a banana and granola bar. 3 days Troy: no law library, no contact with family, no rec, 5,000 bond, no church, no pastors. Grady County: marshals stole laces/belt, Con-Air 1: lady marshal reading file screamed "you aint shit" in his face in front of others on flight. He responded "I hope metaphase goes better for you soon" - caused 2 male marshalls to scream in face, physically threaten, force to back of plane sit on him entire ride. Con-Air 2: another angry woman, fell asleep mask below nose, woke up screaming "Mom Marshall", told to look at leaked Fauci emails that masks dont work. As punishment placed in "the box" restraint that makes it hard to eat.

Source: J6 Scan 11 — Letters From Inside DC Jail / Drive

Brandon Fellows page 3 — MS-13/cop killer escort, DC Jail SW2 6 days no poop

Page 3 of Fellows letter. Punishment plane ride: Marshall moves him to window seat alone, said something would happen (would touch him out of frustration). Marshall picks two men - MS-13 member and cop killer - sits them next to Fellows, gives them cookies, tells them "you tell me if you need anything." Surprisingly respectful political debate - both men expressed Marshall should treat him better, said he wasnt a bad guy. Marshall confronts: "Whos your judge?" "Judge Stewart." "Ill let him know what a POS you are." Got in face shoved: "Youll be back on this plane." 2 other marshals told same lies. Van ride - mocks, calls terrorist, stupid; 5 min from jail: "Almost to your new home!" Arrival DC Jail - hears "Code ICU" called for stabbing victim. Waited 4-5 hrs before brought to cell. SouthWest 2 housed 2 weeks: no church, no pastor, no kosher tray, no legal library, inadequate nutrition. 1-2 hrs rec/day except Sunday no rec letting out. Everyone else got rec daily 4-6 hrs. Wrote requests for nurse multiple times, grievances nothing. "No fruit in meals so I didnt poop for 6 days straight." Day 5 wrote/verbal requests, no nurse - tried to self medicate by pulling hardened poop bit by bit with fingers. "No toilet paper so I just washed each poop-dig with sink water - no avail." Day 6 refused to enter cell until saw nurse - guards never came - chief came down. Finally got nurse, asked why in jail.

Source: J6 Scan 11 — Letters From Inside DC Jail / Drive

Case Scope I.C.A.P - US v. North motion re: Congressional hearings & tainted jury

Drafted pro se legal argument titled Case Scope I.C.A.P. Caselaw: U.S. v. North 910 F.2d 843, 285 U.S. App. D.C. 343 (D.C. Cir. 1990). Issue: Testimony and statements made to Congress under immunity were publicly broadcasted and used to convict. Argues Jan 6 Select Committee hearings tainted any DC jury pool; Nielsen reported 20 million primetime viewers, and DC residents have been exposed.

Source: J6 Scan 3 folder / Drive

Case Scope ICAP page 2 - Brady violation, Congress withholding BWC video

Page 2 of US v. North-based pro se argument. Notes 700+ witnesses called to Jan 6 Select Committee, primetime hearings selectively edited, body-worn camera and CCTV evidence shown to Congress but withheld from defense - argues this is a Brady violation. Accuses Congress of holding a Trial before the trial. Also raises protective-order asymmetry.

Source: J6 Scan 3 folder / Drive

Case Scope ICAP page 3 - protective order asymmetry, change of venue, time served remedy

Page 3 of pro se argument. Demands either right to rescind protective order to mount public defense, or to exclude all video/testimony shown to Congress, media. Argues change of venue inadequate when only one side shown nationally on primetime. Concludes only fair result is time served or dismissed case.

Source: J6 Scan 3 folder / Drive

Coffman violations (p.2) — 25 lbs lost, flight risk denial, "napalm" lie

Page 2 of Coffman amendment violations. Food so bad Lonnie has lost 25 lbs in captivity, no nutritional value, expired bologna, everything cold/freezer burned. Toilet flush button leaks down wall. No cleaning materials. Mail 10 days to several months late. Denied bail/bond twice, called a flight risk even though Lonnie cant even wipe his own buttocks. "Government lied about napalm in my truck which keeps me in this hell hole." Must use chemical burning cream on scalp - no haircut without vaccine. No video visitation whatsoever.

Source: J6 Scan 11 — Letters From Inside DC Jail / Drive

Conditions list continued — Hale-Cusanelli p2: C2B segregation, bond inconsistency

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.

Source: J6 Scan 11 — Letters From Inside DC Jail / Drive

Contact Info For Jail Suit - co-plaintiffs/witnesses list with attorneys

…l Chew. Highly material for compensation case linking other J6 detainees.

affidavitRecord on file — open to view

affidavit

Daniel Caldwell witness statement re DC DOC (p.1, signed top)

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.

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

affidavitRecord on file — open to view

affidavit

Daniel Caldwell witness statement re Ryan Nichols (p.3, signed)

Caldwell page 3 (signed twice): attests over the past year he has seen and experienced the rapidly declining mental state, loss of hope, total despair and totally broken spirits of Ryan Nichols and himself. Compares conditions to Guantanamo Bay torture handbook. Asks for extreme interdiction and immediate relief. Mental health requested but no therapist provided. #376977, arrested 2/10/2021 (sic). Declares not forced, coerced, bullied, or paid.

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

grievance_formRecord on file — open to view

grievance_form

DC DOC Informal Resolution Response: T. Campbell sabotage denied (IGP #20220527-624)

DC DOC Informal Resolution Response to Ryan Nichols ID #376795 regarding IGP #20220527-624 (the 5/24/22 grievance against IGP Coordinator T. Campbell). DOC determined no IGP could be found on file showing Ms. Campbell marked through Step 4 of Deputy Director Appeal and labeled it Step 1; requests Nichols provide his copy. Concludes no evidence supports intentional or malicious sabotage.

Source: J6 Scan 8 folder / Drive

Defendants Reply to Govt Opposition to Motion to Dismiss p1

Page 1 of 8 of Defendants Reply to Governments Opposition to Defendants Motion to Dismiss (responds to ECF No. 165). Argues this case is distinguishable from all high-profile prosecutions because the US President demonized a specific class of people - MAGA Republicans - to which the Defendant belongs.

Source: J6 Scan 10 folder / Drive

Defense Argument Outline — 18 U.S.C. 3142(i) Temporary Release Motion

Page 1 of a defense argument outline focused on 18 U.S.C. 3142(i) of the Bail Reform Act, seeking temporary release of Ryan Nichols for trial preparation. Notes habeas petition was voluntarily dismissed. Cites United States v. Lee, 451 F. Supp. 3d 1, 5 (D.D.C. 2020) distinguishing 3142(f)(2)(B) reopening from 3142(i) subsequent order.

Source: J6 Scan 8 folder / Drive

Defense Argument p.2 — Thumb Drive Confiscation Makes Trial Prep Impossible

Page 2 of defense argument outline. Legal standard under 18 U.S.C. 3142(i) — subsequent order for temporary release if necessary for trial preparation or another compelling reason. Argues confiscation of Mr. Nichols thumb drive containing privileged litigation strategies makes trial preparation impossible. Thumb drive confiscated Aug 29, then again Sept 5, never returned; government doesnt know where it is.

Source: J6 Scan 8 folder / Drive

Defense Argument p.3 — Dupree Factors, Lee, Buswell Case Law

Page 3 of defense argument outline. Lays out the Dupree factors case law for 3142(i) trial-preparation release: cites United States v. Lee (D.D.C. 2020), United States v. Buswell (W.D. La. 2013), United States v. Dupree, 833 F.Supp.2d 241, 246 (E.D.N.Y. 2011). Dupree argued limited phone (300 min/mo), limited monitored email (3) no morning counsel access (4) limited MDC storage (5) no GDC Hedberg database access.

Source: J6 Scan 8 folder / Drive

Defense Argument p.4 — Acevedo-Baldera, Stephens, Jeffries 3142(i) Case Law

Page 4 of defense argument outline. Continues Dupree analysis (Hedberg software unavailable at MDC; attorneys fees). Cites government counter-arguments and additional case law: US v. Acevedo-Baldera (D. Conn. 2020), US v. Stephens, 447 F. Supp. 3d 63, 67 (S.D.N.Y. 2020) where 3142(i) was granted due to pandemic, and US v. Jeffries (E.D. Tenn. 2011) on means short of release.

Source: J6 Scan 8 folder / Drive

Defense Argument p.5 — Trial Prep Burdens, Complexity, Expense, Chressen

Page 5 of defense argument outline. Addresses ample time, additional burdens, complexity, expense factors under 3142(i). Argues defendant lost hundreds of pages, must restart strategy, no TV news access, no internet, phone calls cost a fortune, was moved far from DC. States US v. Chressen is irrelevant because it goes to section (g), not (i).

Source: J6 Scan 8 folder / Drive

Defense Argument p.6 — 3142(c) Factors: Not Flight Risk, Not Danger

Page 6 of defense argument outline. Distinguishes 3142(i) from 3142(g) renewed motion. Cites US v. Lee, Buswell, Dupree, Jeffries, Birbragher. Calls for relief under 3142(c) factors: not a flight risk, not a danger to community. Notes government conceded history/characteristics weighed for release. References ECF 168-1, pgs 64-72 — Ryans work detail reviews all perfect, no disciplinary issues, no finding of fact on September 5 event.

Source: J6 Scan 8 folder / Drive

Defense Argument p.7 — Ali (Pirate), El-Hage, El-Gabrowny, Millan Comparators

Page 7 of defense argument outline. Lists character letters, biography, and video clips supporting Nichols. Compares Nicholss treatment to more favorably treated dangerous criminals: Ali (Somali pirate released over thumb drive issue); cites US v. El-Hage, 213 F.3d 74, 77 (2d Cir. 2000) — co-defendant of Osama bin Laden; US v. El-Gabrowny, 35 F.3d 63, 64 (2d Cir. 1994) — 93 WTC bombing; and Millan (heroin enterprise leader).

Source: J6 Scan 8 folder / Drive

Defense Argument p.8 — Millan/Rivera Cite, Conclusion: Grant Pretrial Release

Page 8 (final) of defense argument outline. Cites US v. Millan, 4 F.3d 1038, 1041 (2d Cir. 1993) and discusses El-Gabrowny dictum on substantial delay. Conclusion: Defendant has shown release necessary for trial prep because litigation strategies stolen multiple times. Government 90-minute defense fails. Question of dangerousness irrelevant but new evidence of Nicholss extraordinary character — assisting law enforcement, saving lives — weighs in his favor. Asks court to grant pretrial release tailored to trial preparation.

Source: J6 Scan 8 folder / Drive

Defense letter — Discovery access problems at DC Jail (Nichols hard drive & Relativity)

Letter (likely from defense team) detailing longstanding discovery access problems for Ryan Nichols at DC Jail: hard drive confiscated by Sgt. Franklin in November, Evidence.com access only recently restored, no Relativity access. Argues for 60-day continuance.

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

Defense outline p2: three drives, Aug 29 confiscation, Officer Swolwannii bodycam

…is provably false (Washington at CTF vs Nichols at CDF; all J6ers kept drives 6+ months).

Defense outline: Illegal Taking of Nichols thumb drive — opening statement notes

Defense attorney working draft / opening statement outline for Nichols motion (likely ECF 150 emergency release / 177/177-1/177-2 supplements). First-person attorney McBride enumerates timeline: FBI surrender Jan 18 2021 in Texas; FTC Oklahoma; DC Jail Mar 2021 - Sept 6 2022; Files & Harrison representation Jan-Aug 2021; thumb drive #1 (red) sent Jul 27 2021 (Ex A ECF 177-1); thumb drive #2 sent Jul 30 2021 (Ex B ECF 177-2); McBride retained Aug 2021; bought 1 TB hard drive with USAFX downloads delivered Oct 7 2021; mac-adapter issue, Ingrid Washington email same day stating drive inoperable.

Source: J6 Scan 7 folder / Drive

Discovery wishlist: bodycams, Reeder/Hogan, FBI Form 1023 CHS

Handwritten discovery list naming specific Capitol Police bodycam tags (X6039BJJV, X6039B9NO, X6039BF8H) and named officers/officials: Roseanne, Fanone, Robert Reeder, Hogan. Demands FBI Form 321/FD-1023 CHS (Confidential Human Source) reporting documentation KL000239.

Source: J6 Scan 6 folder / Drive