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Sep 30, 2022

Defendant Reply — page 12 of 14

…rgues this case is easier than Thorne/Ali because no flight risk, no genocide attempt. Trial earliest March 2023. Section C:…

Sep 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 Som…

Aug 30, 2022

Emergency Motion for Release — page 9 of 12

Argues Defendant is neither flight risk nor danger. Discusses how Government has needlessly added c…

Aug 10, 2022

Habeas Corpus petition — page 29 (Deliberate indifference to medical condition begins)

…n arrival informed staff of PTSD, placed in solitary anyway risking suicide; summer 2021 asked for psychologist who prescrib…

Aug 10, 2022

Habeas Corpus petition — page 31 (McBride/Glover correspondence on solitary)

…from solitary and medical care for Nichols (warning suicide risk, threatening civil lawsuit and personal liability). Include…

Oct 17, 2021

Informal Grievance - Haircut/Shave Request (Oct 17, 2021)

…t use Magic Shave cream due to sensitive skin/chemical burn risk.

Mar 17, 2021

Order of Detention Pending Trial for Thomas Sibick

…eview of the release decision. The order addresses pretrial risk rather than final guilt.

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

…everal months late. Denied bail/bond twice, called a flight risk even though Lonnie cant even wipe his own buttocks. "Govern…

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

…agher. Calls for relief under 3142(c) factors: not a flight risk, not a danger to community. Notes government conceded histo…

Habeas Corpus notes: Farmer v. Brennan recklessness standard (p.3)

…only if aware of facts from which inference of substantial risk could be drawn and actually draws inference. Ryan's margin…