Motion 3: Release the Bodycam — The Recording That Settles It

This is the heart of my whole case. There is an objective recording of what happened at that church — bodycam, dispatch, CAD, 911 audio, the police report, and possibly the church's own cameras. I called the police myself. I want every second of it preserved and produced, before anything gets overwritten or quietly lost.

If they told the truth, the bodycam shows it. If I told the truth, the bodycam shows it. So release it.

The motion as filed — page one.

What I'm asking the court to do

Preserve and produce — now, or at minimum preserve plus in-camera review:

• All bodycam and dash-camera footage and officer audio.
• All CAD records, call sheets, dispatch audio, 911/non-emergency audio, and radio traffic.
• All police reports, supplements, narratives, field notes, and officer notes.
• Any photo, video, screenshot, or post that any witness or church member gave to law enforcement.
• Any church surveillance footage from that day.
• All preservation letters, open-records responses, and communications with the records custodian and HCSO.

Why it matters

The allegation reported in the media was that I "raised my shirt and put my hand on the grip of a firearm." I deny drawing, brandishing, pointing, pulling, or threatening anyone. Online, that story mutated into "pulled a gun at church." The only thing that cuts through rumor is the official record — and right now it's being withheld. Evidence that isn't preserved gets overwritten. That's why this is an emergency.

I already asked Harrison County — in writing

This isn't theoretical. I went through the records custodian. Here is the exchange.

On May 18, 2026, Lt. Cindy Black of the Harrison County Sheriff's Office Civil/Open Records office told me the case is "still active" and the call sheet "is all I am able to release at this time."

I wrote back that the body cam is exactly what would settle the gun claim, that body cams get released all the time, and that I did not appreciate my case being obstructed.

On May 19, 2026, I sent a second written request — with my attorney copied — for the report and the body cam.

The proper channel for this is not an open-records request — it is Article 39.14 and a Brady demand through the criminal case. That is exactly what this motion does.

The law behind it

• U.S. Const. amends. V, VI, XIV — due process, confrontation, and the right to present a defense.
• Tex. Const. art. I, §§ 10, 19 — rights of the accused and due course of law.
• Tex. Code Crim. Proc. art. 39.14 — Texas criminal discovery; production of reports, recordings, and material evidence.
• Brady v. Maryland, 373 U.S. 83 (1963) — favorable, material evidence must be disclosed.
• Giglio v. United States, 405 U.S. 150 (1972) — impeachment evidence must be disclosed.
• United States v. Bagley, 473 U.S. 667 (1985) — materiality includes evidence that undermines confidence in the outcome.
• Kyles v. Whitley, 514 U.S. 419 (1995) — the prosecutor must learn of favorable evidence known to police.
• California v. Trombetta, 467 U.S. 479 (1984) — due process requires preserving apparently exculpatory evidence.
• Arizona v. Youngblood, 488 U.S. 51 (1988) — bad-faith failure to preserve potentially useful evidence violates due process.
• Crawford v. Washington, 541 U.S. 36 (2004); Davis v. Alaska, 415 U.S. 308 (1974) — confrontation, including exposing witness bias.
• Washington v. Texas, 388 U.S. 14 (1967); Chambers v. Mississippi, 410 U.S. 284 (1973) — the right to present a defense.

The facts, and how I've classified them

• FACT: Public reporting described the allegation as raising a shirt and placing a hand on the grip of a firearm.
• RYAN STATEMENT: I deny drawing, brandishing, pointing, pulling, or threatening anyone with a firearm.
• RYAN STATEMENT: I called law enforcement myself.
• FACT / NEEDS AUTHENTICATION: The records-request screenshots reflect the case was treated as active, only a call sheet was released, and bodycam/report review and redaction were still pending.
• DOCUMENTED INFERENCE: The bodycam, CAD, dispatch, reports, and church cameras are material because they show the timeline, who called first, and whether accounts changed.
• NEEDS AUTHENTICATION: The originals must be produced in native or certified form.

My declaration

My name is Ryan Nichols. DOB December 6, 1990. I am the Defendant. Under penalty of perjury (Tex. Civ. Prac. & Rem. Code § 132.001):

• This case arises from an alleged church-related encounter.
• I deny drawing, pointing, pulling, brandishing, firing, or threatening anyone with a firearm.
• I called law enforcement myself.
• I believe the bodycam, dispatch, CAD, reports, and church-camera footage will show what actually happened and whether the story changed.

Executed June 1, 2026, in Harrison County, Texas. /s/ Ryan Nichols

Exhibits EX-008 through EX-011 (the Joe & Cindy Black open-records folder and the screenshots above); each needs authentication.

The proposed order

• The State, HCSO, and all agencies shall preserve all bodycam, dashcam, CAD, dispatch, 911 audio, call sheets, reports, notes, logs, and witness-provided media.
• The State shall produce all discoverable materials by a deadline set by the Court.
• Any withheld material shall be submitted for in-camera review.
• The State and HCSO shall identify the custodians, officers, dispatchers, and reviewers connected to the records.

The bottom line

I'm not asking anyone to take my word. I'm asking for the tape. Preserve it now. Produce it, or let the judge watch it in camera. If the bodycam shows no threat, no brandishing, and a story that changed — that's Brady, that's Giglio, and it's mine to use.