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Oct 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.

Source: J6 Scan 8 folder / Drive

Oct 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.

Source: J6 Scan 8 folder / Drive

Oct 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.

Source: J6 Scan 8 folder / Drive

Oct 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.

Source: J6 Scan 8 folder / Drive

Oct 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.

Source: J6 Scan 7 folder / Drive

Oct 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.

Source: J6 Scan 6 folder / Drive

Oct 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.

Source: J6 Scan 8 folder / Drive

Oct 13, 2022

RRJ Medical Request: John O. shoulder pain (10/13/22)

…ts really bad, needs to be seen for pain. Companion form to j6s8-049. Same Ryan-adjacent cellblock.

Oct 12, 2022

Inmate Grievance Form 10/12/22 - PTSD/Zoloft (Control 032562, received 10/17/22)

…ived by ombudsman 10/17/22 by Officer Vick. Same content as j6s8-075 (this is the formal copy that produced the 10/20/22 r…

Oct 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.

Source: J6 Scan 8 folder / Drive

Oct 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.

Source: J6 Scan 8 folder / Drive

Oct 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.

Source: J6 Scan 8 folder / Drive

Oct 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.

Source: J6 Scan 8 folder / Drive

Oct 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.

Source: J6 Scan 8 folder / Drive

Oct 7, 2022

Rec Math page 2/2 conclusion: 25.4 days/month locked in cell = MENTAL TORTURE

…n Inmate Grievance Form rec-math attachment (continued from j6s8-067/054), Ryan Nichols. Combines projected cell hours and…

Oct 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."

Source: J6 Scan 8 folder / Drive

Oct 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…

Oct 7, 2022

Rec Math scratch revision: 1835 minutes lost / 605.70 hours in cell

…evision of Ryan Nichols rec-math calculations (companion to j6s8-052, 053, 054, 055, 067). Shows arithmetic corrections: 1…

Oct 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).

Source: J6 Scan 7 folder / Drive

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.

Source: J6 Scan 7 folder / Drive

Oct 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.

Source: J6 Scan 7 folder / Drive

Oct 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).

Source: J6 Scan 7 folder / Drive

Oct 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).

Source: J6 Scan 7 folder / Drive

Oct 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.

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Oct 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.

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Oct 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.

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Oct 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.

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Oct 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.

Source: J6 Scan 6 folder / Drive

Oct 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.

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Oct 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.

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Oct 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).

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Oct 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).

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Oct 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).

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Oct 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.

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Oct 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.

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Oct 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.

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Oct 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.

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Oct 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.

Source: J6 Scan 6 folder / Drive

Oct 4, 2022

Email Ted Hull (NNRJ Supt) to attorney Gross re: Quaglin discovery disappeared

…ss (jonathansgross@gmail.com), cc Michelle Lewis, regarding J6 co-defendant Christopher Quaglin's missing discovery materi…

Oct 4, 2022

Email thread Hull/Gross re: Quaglin weight loss, court concerns - jail refusal

…word "NO". Documents jail's deliberate indifference toward J6 detainee health concerns even after court expression.

Oct 4, 2022

Hull email continued - cites court ruled habeas without merit, refuses further

…official position that resulted in further mistreatment of J6 detainee Quaglin.

Oct 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…

Oct 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.

Source: J6 Scan 7 folder / Drive

Sep 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.

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Sep 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.

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Sep 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.

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Sep 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.

Source: J6 Scan 31 — Emergency Motion For Release / Drive

Sep 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).

Source: J6 Scan 31 — Emergency Motion For Release / Drive